19QA019_-_(Attch_5)_EAFB_Biosolids_Land_Application_Permit_Renewal.pdf

DEPARTMENT OF THE AIR FORCE

354th fighter wing

MEMORANDUM FOR ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION

SOLID WASTE PROGRAM

ATTN: NEIL LEHNER

610 University Ave Fairbanks AK 99705-3643

FROM: 354 FW/CC

354 BROADWAY AVE, UNIT 19A

EIELSON AFB 99702-1800

SUBJECT: Land Application of Biosolids Permit Renewal, Permit No. SWYA068-19

1. Through this memorandum and the attached permit application information, Eielson Air Force Base (AFB) seeks the renewal of the current Land Application of Biosolids Permit, Permit Number (No.)

SWYA068-19. This memorandum conforms to the Section 4, Cover Letter and Certifications requirement, from the Land Application of Biosolids Permit Application as set forth by the Alaska Department of Environmental Conservation (ADEC), Solid Waste Program. The permit process follows the regulatory requirements as given in Title 18 of the Alaska Administrative Code (AAC) Chapters 60.210, 60.505 and 60.510.

2. Eielson AFB is an active United State Air Force (USAF) installation, located approximately 23 miles southeast of Fairbanks, Alaska in the interior of Alaska. The area experiences a sub-arctic climate, averaging roughly 69 inches of snow annually and over 11 inches of total precipitation. Interior Alaska is known for its widely varying temperatures, with high temperatures that can reach above 90 degrees Fahrenheit (ºF) and low temperatures of -50ºF or colder. Eielson AFB sits in the Tanana River Valley, and the main base is located approximately four to five miles east of the river in a generally flat area with numerous ponded waters and slow flowing creeks and sloughs. Numerous wetlands exist throughout the area, supporting the surface water hydrology. Groundwater flows through the area above and around the interspersed permafrost geology. The Tanana Valley includes boreal forest vegetation that is representative of its climate, consisting mainly of birch and black spruce forest that overlies the broken permafrost areas.

3. The Eielson AFB Wastewater Treatment Plant uses a two-stage anaerobic digestion system to stabilize biosolids produced through the wastewater treatment processes. The first-stage, primary digester keeps the biosolids heated and mixed at a temperature of approximately 98°F, providing primary pathogen reduction. A secondary digester provides further treatment and solids residence time to achieve additional pathogen reduction and volatile suspended solids destruction. The secondary digester operates at roughly 12-15°F cooler temperatures. Stabilized and thickened biosolids, from the secondary digester, are pumped to the sludge drying beds for further dewatering and final pathogen destruction. Biosolids are kept in the drying beds for at least one winter season and at least three months where average temperatures are above freezing. This drying enables the sludge to meet Class B biosolids requirements as given in 40 CFR 503.32(b)(3).

4. As described above, Eielson achieves pathogen reduction and meets the Class B biosolids requirements as given in 40 CFR 503.32(b)(3) through the “Air Drying” process as given in Appendix B, A.2, to Part 503. Following at least three months of drying in the sludge drying beds, Eielson samples the dried and stabilized/treated biosolids to ensure that they do not exceed limits from Table 1 of 40 CFR

503.13 and to calculate the appropriate spreading area requirements and rates based on typical nitrogen uptake rates. Once analytical results are received, biosolids will be spread in areas around the airfield as shown in Figure 2 (Attachment 5). Biosolids will not be applied to snow-covered or wet, saturated soils.

To reduce vector attraction, dried biosolids shall be mixed/tilled into the soil promptly (i.e., within six hours) after application to the land, in accordance with 40 CFR 503.33(b)(10)(i).

5. The procedures that Eielson AFB will use to spread the biosolids are described as follows. At no time will biosolids be spread within 10 meters (33 feet) of surface waters. Similarly, biosolids will not be applied to any athletic field, residential lawn, or other high use or potential residential exposed areas. The total proposed/potential area available for land spreading is roughly 948.4 acres (Attachment 5, Figure 2).

To the extent possible, biosolids will not be applied to areas where solids have been applied in the past five years. This will minimize overall metals and/or other nutrient loading concerns. As shown in Figure 2, Eielson intends to prioritize its biosolids applications in the following locations:

a. Adjacent to, or within the enclosed airfield

b. Near the wastewater treatment plant (area east of plant)

c. An area between the fuel tank farms

d. Other devegetated roadsides in areas not commonly used by base residents

6. Eielson AFB is aware of and intends to abide by all appropriate and applicable local ordinances, zoning requirements, and the stipulations specified in the renewal permit.

7. I certify that the information contained in this cover letter and the attachments are true, accurate, and complete. If you require more information, please do not hesitate to contact Mr. Lonnie Britton, the Eielson AFB Solid Waste Program Manager, at 907-377-3313 or lonnie.britton@us.af.mil.

BENJAMIN W. BISHOP, Colonel, USAF Commander

7 Attachments

1. Land Application of Biosolids Permit Application Form

2. Eielson Public Land Order

3. Land Application of Biosolids Application Supplemental Information

4. Biosolids Analytical Data and Land Spreading Calculations

5. Figures

6. Biosolids Facility Design As-Built Drawing/Schematic

7. Application Area Visual Monitoring Checklist

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ATTACHMENT 1

Land Application of Biosolids Permit Application Form

Instructions:

This application is for a new permit or a permit renewal for the Land Application of Biosolids (treated sewage solids or septage).

If you are treating sewage solids or septage to meet the pathogen reduction and/or vector attraction reduction requirements of 40 CFR 503, a separate biosolids treatment facility application will be required.

However, if the treatment is limited to the addition of lime, or only requires sampling to create Class B biosolids, and the biosolids will be applied to land owned and controlled by the permit applicant, you may include the information required in the Land Application of Biosolids Supplemental Monitoring Requirements and qualify for a Type Y Comprehensive permit.

In the application, the term “facility” refers to all land, structures, other appurtenances, and improvements on land used for treatment or storage of sewage solids, septage, or biosolids. “Application site” refers to the boundaries of the property where biosolids are applied to land.

If a required item is not applicable, please explain why. Include all the applicable information for each item regardless if it has been previously submitted. The specific location of information within each submitted document or attachment must also be noted for each item For a new facility or significant change to an existing facility, prepare a draft application with a list of questions and schedule a meeting with the ADEC Solid Waste Program.

DEC Contact Information For Biosolids

The Alaska Department of Environmental Conservation Division of Environmental Health

Solid Waste Program http://dec.alaska.gov/eh/sw

Anchorage 555 Cordova Street

Anchorage, AK 99501

(907) 269-7622

FAX (907) 269-7600

Fairbanks & Juneau 610 University Avenue Fairbanks, AK 99709

(907) 451-2135

FAX (907) 451-2188

Land Application of Biosolids Permit Application

Alaska Department of Environmental Conservation Solid Waste Program

DEC Office Only:

Facility Name:

Authorization #:

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Version 08-2018

Section 1. Application Site Information – Please complete a copy of this section for each separate application site.

Application Site Identification:

Application Site Address:

City: Zip:

Legal Property Description:

Section: Township: Range: Meridian:

General Description of Location:

Latitude: Longitude:

Agricultural or Silvicultural purpose of the land:

Landowner: Contact Name:

Address: City: State: Zip:

Email: Phone:

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Land Application App Version 08-2018

Section 2. Contact Information

Permit Applicant (Co. or Entity):

Contact Name:

Address: City: State: Zip:

Email: Phone:

Type of Entity: Government Corporation Other:

State of Incorporation or Registration: Alaska Business License Number:

IRS Tax ID Number:

Biosolids Applicator (if different than applicant):

Contact Name:

Address: City: State: Zip:

Email: Phone:

Agent/Consultant:

Contact Name:

Address: City: State: Zip:

Email: Phone:

Section 3. Fees A check or money order for the appropriate fee [listed in 18 AAC 60.700(a) Table E-2] must be submitted with the permit application. If not included, the application will be returned to the applicant.

Submit payment for the first year’s annual fee with the initial application for a facility. No fee is required for permit renewal applications; annual fees will be billed each year.

You will be billed separately for time spent reviewing waiver requests.

This application is for a: New Permit Permit Renewal

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Land Application App Version 08-2018

Section 4. Cover Letter and Certifications Submit a cover letter with the following information and signature.

1. A statement indicating you wish to obtain a permit to apply biosolids to land.

2. A brief general description of the topography, geology, climate, surface hydrology and groundwater hydrology of the land application site(s).

3. A brief description of any onsite processes that will be applied to the sewage solids or septage prior to application.

4. The information for the permitted facility that prepares the biosolids, or a citation of the pathogen reduction method (40 CFR 503.32) and the vector attraction reduction method (40 CFR 503.33) to be met for the biosolids.

5. Provide a brief description of the procedures that will be used to apply the biosolids to the land.

6. A statement that you are aware of all applicable local ordinances and zoning requirements and a list of any other necessary permits or authorizations.

7. The applicant must submit a signed cover letter.

8. The applicant must submit the following signed statement, which may be added exactly as shown in the box below to the cover letter, or the applicant may sign this sheet and submit it as an attachment to the cover letter.

I certify, under penalty of perjury, that all of the information and exhibits in this cover letter and application are true, accurate, and complete.

Printed Name: Title:

Signature: Date:

All applications must be signed as follows per 18 AAC 15.030:

• Corporations: A principal executive officer, an officer that is no lower than the level of vice president, or a duly authorized representative who is responsible for the overall management of the project or operation.

• Municipal, state, federal, or other public entity: A principal executive officer, ranking elected official, or duly authorized employee.

• Partnerships: A general partner.

• Sole proprietorship: The proprietor

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Land Application App Version 08-2018

Section 5. Waste Quantity Information

1. List the sources and quantity of sewage solids and/or septage you expect to receive at the facility each year:

Quantity Tons Gal. CY Generator or Treatment Facility Sewage Solids or Biosolids

Total Tons

Total Gallons

Total Cubic Yards

2. List the amounts of septage and/or biosolids you expect to land apply at each site each year:

Quantity Tons Gal. CY Application Site Biosolids Septage

Total Tons

Total Gallons

Total Cubic Yards

Septage

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Land Application App Version 08-2018

Section 6. Location Information For each application site, please fill out a separate copy of this page and attach the required location and design documentation. Please identify the specific attachment page that addresses each requested item

1. Property Ownership Attachment #/Page

a. Attach a copy of the deed or another legal document that identifies the landowner(s) of the land application site(s).

b. If the applicant is not the landowner, attach a written and notarized statement or a copy of any lease agreement signed by the landowner showing that the landowner consents to the land application of biosolids.

2. Surface Water Information

a. Distance to nearest surface water body: feet

b. Provide information on potential for surface water (storm water or ponds, streams, etc.) to run-on to the facility.

c. Provide information on the potential for septage or biosolids carried by run-off from the facility to impact nearby surface waters.

4. Soil Conditions

a. Describe the soil conditions of the application site, and attach the map in #5.f. of this section. Must be completed for each application site – include Site ID in the description if including more than one site.

b. List the crop(s) that will be grown on the site, and the nitrogen requirements for each crop.

Crop Planting month Harvest Month Nitrogen requirement

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Section 6. Location Information (continued)

5. Maps

Attach maps and/or aerial photographs as needed to show the following. You may submit maps that show more than one of the required items. For example, one map can show property boundaries, wetland and surface water locations, etc. Attachment #/Page

a. Location of all facility and application site property boundaries.

b. Location and flow direction of surface water bodies, streams, and containment or diversion structures, and public drinking water supplies within 2 miles of the facility and application site property boundaries.

c. Location of all residential drinking water wells within one-half mile of each application site. There should be no wells within 100 feet of any land application site.

d. Location of each of the major soil types on the application site(s), including descriptions, depths, and permeability, cation exchange capacity, and pH.

Section 7. Facility Design A complete set of the most recent design drawings and maps that include the following information must be submitted. Please ensure that the documentation represents current conditions of the entire facility.

1. Site map(s) which show site conditions, including: Attachment #/Page

a. All previous, existing and planned land application areas. The drawings should demonstrate all biosolids will be applied at least 50 feet from the property boundary and at least 33 feet from any surface water body.

b. Fences, gates, berms and other access control devices around the application site(s).

c. Access roads to and within the facility.

d. Storage area(s) for biosolids.

2. Plan view drawings with contour lines and cross section drawings that show:

a. All roads, ditches, trenches, and berms associated with the facility.

b. Storage areas (or manufacturer specifications if a commercial product is used)

3. Construction detail drawings and cross sections that show:

a. Storm water drainage structures, culverts and other surface water control devices.

b. Storage areas (or manufacturer specifications if a commercial product is used)

4. Design calculations, data and documentation must include the following and supporting calculations.

a. An estimate (including calculations) of the maximum inventory of septage and biosolids that may be stored onsite at the facility at any given time.

b. An estimate of the total weight (or volume) of biosolids to be land applied each calendar year.

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Land Application App Version 08-2018

Section 8. Operations Plan The operations plan should be a separate document that provides sufficient detail and information that the applier could use it to perform all necessary tasks required for land application.

The operations plan is a flexible document that should be reviewed annually and updated as necessary. The following table represents the minimum requirements which must be included. Additional information should be added, as needed to ensure the facility operates in compliance with the State Solid Waste Regulations and 40 CFR

503. A copy of the operations plan should be kept at the facility and it must include the following information.

Please include a reference page and section of the operations plan where each item is addressed.

1. Access control page/section

a. If the biosolids to be applied are rated Class B, list the requirements for site restrictions required by 40 CFR 503.32(b)(5).

b. List any additional necessary site controls

c. Measures to control access to the facility, including gates, fences, berms or other means of preventing access; hours of operation; signage; and other control measures.

d. Any signage at the facility.

2. Agronomic rate of application

a. Describe how the agronomic rate of application will be determined.

b. If sampling is required by the applicant or applicator, list the test method for each of the required analyses [pH, total Kjeldahl nitrogen (TKN),Nitrate nitrogen (NO3-N), Ammonia nitrogen (NH4-N)], phosphorus (P) and potassium (K)].

c. Include the sampling locations on the map in Section 6. #5.e. for each application area sampled, and list sampling depth(s).

d. Include the timing and frequency of sampling.

e. Include a description of the sampling method and proper handling and shipping of the sample containers and the name of the testing laboratory

3. Material acceptance and handling policy

a. Screening procedures to ensure that only domestic septage or biosolids are stored and applied at the facility.

4. Biosolids Storage

a. Describe the methods and facilities used to store biosolids and how these maintain the pathogen and vector attraction reduction goals. Biosolids may not be stored for greater than 60 days.

b. Describe how run-off from the storage area will be controlled, collected, and disposed or re-used.

5. Biosolids Application

a. Describe the methods and equipment used for application of the biosolids to the field.

b. Describe how the equipment will be monitored to ensure that the proper application rate is met.

c. Include photographs of the application equipment.

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Section 8. Operations Plan (continued)

6. Odor Control Plan page/section

a. Describe how odors will be monitored and controlled at the site. Include drawings of any odor control devices in Section 7.

7. Litter, vector and nuisance control plan

a. Procedures to ensure wildlife and domestic animals do not endanger the public or facility staff, are not harmed by contact with the waste, and do not become a nuisance.

b. Procedures to control dust, noise, traffic, litter, disease vectors and other effects from facility operations so they do not become a nuisance or hazard outside of the facility boundary.

8. Surface & Storm Water Control Plan

a. Describe how run-off from the application site will be controlled to ensure that all biosolids remain onsite and do not pollute any surface water. Include how the system is controlled, monitored, and any if necessary, polluted run-off is collected and disposed or reused.

b. Describe how run-on water from upgradient sources will be controlled to reduce production of leachate from the biosolids if stored.

9. Corrective action plan describe the actions for:

a. Cleaning up any improper or unauthorized waste.

b. Repairing any damage to the facility.

c. Addressing any violations of regulations or permit conditions.

10. Applicator training

a. Identify any training that will be required for an applicator, including on-the-job training.

b. Describe how that training will be documented and filed in the operating record.

11. Visual Monitoring

a. Description of the procedures for visual monitoring of the facility to ensure that permit requirements are met. Including each location that will be visited and the expected items to be observed at each location.

[Application sites should be monitored for at least 60 days after application and storage facilities must be monitored monthly.]

b. A Checklist or visual monitoring form specific to your facility including, at a minimum, the following:

• Signs of damage to the facility – structures, monitoring devices, storage areas, etc.

• Evidence of run on to the storage areas

• Evidence of polluted run off from the facility or application site(s)

• Waste is properly contained

• Evidence of fire or combustion in stored waste

• Evidence of stress to fish or wildlife

• Any permit violations

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Section 8. Operations Plan (continued)

12. Recordkeeping page/section

a. Describe how each load of biosolids received will be identified and how records associated with each application will be organized. Include copies of any forms used for tracking biosolids from delivery at the facility to land application.

b. Include a copy of the certification statements from 40 CFR 503.17 that will be used for each application.

13. Operating record

a. The operating record should at a minimum include the permit, permit application, visual monitoring records, inspection records, training records, testing and analytical data, any other required permits, the operations plan, and batch records with the appropriate certification.

b. The plan must state where the operating record will be located.

14. Reporting

c. Agreement that you will submit an annual report with the information required in the permit conditions.

Recommended EPA Biosolids Reference Links

40 CFR 503 A Plain English Guide to the EPA Part 503 Biosolids Rule www.epa.gov/biosolids FAQs on Sewage Sludge/Biosolids Annual Reporting

Control of Pathogens and Vector Attraction in Sewage Sludge

Process Design Manual Land Application of Sewage Sludge and Domestic Septage A Guide for Land Appliers on the Requirements of the Federal Standards for the Use or Disposal of Sewage Sludge, 40 CFR Part 503 Preparing Sewage Sludge for Land Application or Surface Disposal http://www.ecfr.gov/cgi-bin/text-idx?SID=41a4f5109e86ad2b554a388baacec45c&node=pt40.30.503&rgn=div5 https://www.epa.gov/biosolids/plain-english-guide-epa-part-503-biosolids-rule http://www.epa.gov/biosolids https://www.epa.gov/sites/production/files/2015-03/documents/biosolids-faqs-2014.pdf https://www.epa.gov/biosolids/control-pathogens-and-vector-attraction-sewage-sludge https://www.epa.gov/sites/production/files/2015-06/documents/process_design_manual_land_application_of_sewage_sludge_and_domestic_septage.pdf https://www.epa.gov/biosolids/land-application-sewage-sludge https://www.epa.gov/biosolids/land-application-sewage-sludge https://www.epa.gov/sites/production/files/2015-03/documents/guide_on_monitoring_record_keeping_and_reporting.pdf

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ATTACHMENT 2

Eielson Public Land Order

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Eielson AFB Public Land Order

1379218772C Text Box

1379218772C Text Box

1379218772C Text Box

1379218772C Text Box

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ATTACHMENT 3

Land Application of Biosolids Application Supplemental Information

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SUPPORTING INFORMATION

FOR

LAND APPLICATION OF BIOSOLIDS

PERMIT RENEWAL APPLICATION

FOR

EIELSON AIR FORCE BASE

February 2019

Rev 0

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Supplemental Information – Land Application of Biosolids Permit Application Eielson AFB, Alaska

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TABLE OF CONTENTS

SECTION....................................................................................................PAGE

LAND APPLICATION OF BIOSOLIDS PERMIT RENEWAL INFORMATION ......... 51.0

1.1 Introduction

1.2 ADEC Approved Permit Modification

1.3 Site Information, Hydrology, and Geology

FACILITY DESIGN .................................................................................... 72.0

2.1 Primary and Secondary Anaerobic Sludge Digesters

2.2 Sludge Drying Beds

OPERATIONS PLAN ................................................................................. 93.0

3.1 Access Control

3.2 Agronomic Rate of Application

3.3 Material Handling and Acceptance Policy

3.4 Biosolids Storage

3.5 Biosolids Application

3.6 Odor Control Plan

3.7 Litter, Vector, Noise, and Nuisance Control Plan

3.8 Surface and Storm Water Control Plan

3.9 Corrective Action Plan

3.10 Applicator Training

3.11 Visual Monitoring

3.12 Recordkeeping

3.13 Operating Records

3.14 Reporting

REFERENCES ....................................................................................... 164.0

LIST OF TABLES

Table 3-1. Biosolids Sampling Analytes and Test Methods

List of Photos Photo 1. Eielson AFB Sludge Drying Beds

Photo 2. Digesters and Sludge Drying Beds

Photo 3. Typical Land Spreading/Disking Equipment

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LIST OF ACRONYMS

AAC Alaska Administrative Code ADEC Alaska Department of Environmental Conservation ADNR Alaska Department of Natural Resources ADWF Average Dry Weather Flow AFB Air Force Base AS Alaska Statutes ATC air traffic control BOD Biochemical Oxygen Demand BPTC Best Practicable Treatment or Control CFR Code of Federal Regulations DBL drying bed leachate EAFB Eielson Air Force Base EC Electrical Conductivity / specific conductance E. coli Escherichia coli ºF degrees Fahrenheit FOD foreign objects and debris gpd gallons per day gpm gallons per minute LAA Land Application Area lbs pounds MCL Maximum Contaminant Level mg/L milligrams per liter mg/Kg milligrams per kilogram MPN most probable number No. number NRCS Natural Resources Conservation Service NTU Nephelometric Turbidity Unit PSRP Process to Significantly Reduce Pathogens TDS Total Dissolved Solids TKN Total Kjeldahl Nitrogen TSS Total Suspended Solids tpy tons per year USDA United States Department of Agriculture USEPA United States Environmental Protection Agency WELTS Well Log Tracking System WWTP wastewater treatment plant yd3 cubic yards

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LAND AP P LICATI ON OF B I OS OL IDS PE RMIT RE NE WAL 1.0

INF ORM AT IO N

1.1 INTRODUCTION

The following pages provide supplemental information to support the Land Application of Biosolids Permit Application Form as prepared/provided by the Alaska Department of Environmental Conservation (ADEC), Solid Waste Program. This form was completed for the renewal of Eielson AFB Land Application of Biosolids Permit #SWYA068-19. This form and its attachments comply with all applicable ADEC requirements and Title 18 of the Alaska Administrative Code (AAC) 60.510.

To accompany this information, a cover letter is also provided, which conforms to the application form Section 4, Cover Letter and Certifications requirement and 18 AAC 60.210, 60.505 and 60.510.

1.2 ADEC APPROVED PERMIT MODIFICATION

Eielson Air Force Base (AFB) received Permit SWZA020-19 in March 2014 to permit the continued land application of the biosolids generated from the Eielson Waste Water Treatment Plant (WWTP). As a result of regulatory changes, ADEC issued Eielson AFB a new permit in January 2018, Permit Number (No.) SWYA068-19.

Eielson AFB requested changes to this permit that were subsequently granted through the modification issued in August 2018. The requested modifications included a change to their pathogen reduction methods to meet Code of Federal Regulations (CFR), Title 40, Part 503.32(b)(3), Alternative 2 requirements for Class B biosolids according to Appendix B, A.2, for Processes to Significantly Reduce Pathogens (PSRP) and the “Air Drying” option. Under this option, the biosolids are dried on a sand bed or on paved or unpaved basins for a minimum of three months where the average temperature for at least two of the months is greater than zero degrees Celsius (ºC). The Eielson AFB WWTP Sludge Drying Beds, with their concrete construction and underlying drain system meets these requirements. Additionally, according to the Alaska Climate Research Center, the mean temperature for Eielson Field is above 32 degrees Fahrenheit (ºF) for the months of April (33.1ºF) through September (44.8ºF) (Alaska Climate Research Center, 2019).

With the production of Class B biosolids, the facility must also meet the site restriction requirements for land application as given in 40 CFR 503.32(b)(5). As a controlled access, active military installation with limited/low potential for public exposure to the spread biosolids, public access to the specific land spreading areas must be restricted and posted (i.e., signage installed) for the 30 days following the application of the treated biosolids (40 CFR 503.32(b)(5)(viii)). A further description on the access controls is provided in Section 3.1 of this document.

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1.3 SITE INFORMATION, HYDROLOGY, AND GEOLOGY

Eielson AFB is located approximately 23 miles to the southeast of Fairbanks, Alaska. The installation is located just off the Richardson Highway, which runs through the base and to the west of the runway (see Attachment 5, Figure 1). The installation has fencing that surrounds much of the boundary, especially along the potential public access areas. An entrance/check point with the adjacent Eielson Visitor Center is present at the north end of the installation, where proper identification/permission to enter the base is confirmed or obtained.

Numerous water bodies are located in and around Eielson AFB, including both continuous and intermittent streams/creeks that generally flow to the west and north, to the Tanana River. Groundwater flow is similarly to the north and west, towards the Tanana River, as noted on Figure 2 (Attachment 5).

The location of nearby potable water, non-potable water, and private wells are shown on Figure 1 (Attachment 5). Potable wells on Eielson AFB provide water to the Eielson AFB drinking water system (after treatment), though not all wells are currently in-use. No wells exist within 100 feet of any proposed land application area.

The soils in and around the Eielson AFB airfield are generally comprised of an urban cryothents complex (see Attachment 5, Figure 3); these soils are considered only moderately drained (when not frozen), having a high permeability, and a silty-loamy composition. These soils generally only exist to depths of up to 15 feet, with gravels located beneath (Alaska Department of Natural Resources, 2019). The other predominant soil type in the airfield and surrounding area is the Tanana-Mosquito Complex, which is a poorly drained and shallow alluvium soil (USDA NRCS 1999). For both soil types, groundwater is generally present at depths of less than 20 feet below the surface, with shallower depths around the waterbodies. Neither soil types have significant cation exchange capacities and have generally neutral pH levels (pHs of greater than 6).

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FACIL ITY DE S I GN 2.0

A Process Flow Schematic for the Eielson AFB WWTP and Sludge Drying Beds is included as Attachment 6. A description of components involved in the treatment and disposal of the biosolids is provided in this section to supplement the requirements in Section 7 – Facility Design in the Land Application of Biosolids Permit Application.

2.1 PRIMARY AND SECONDARY ANAEROBIC SLUDGE DIGESTERS

The Primary and Secondary Anaerobic Sludge Digesters are located between the main process building and the Sludge Drying Beds as shown in the Process Flow Schematic provided in Attachment 6 (also see Photo 2). Domestic sludge and scum from the primary clarifiers is pumped to the Primary Sludge Digester. This digester is heated indirectly through the pumping and circulation of the sludge through non-contact heat exchangers which use hot water produced from oil fired boilers. The sludge is kept at a constant temperature of at least 98°F. Mean cell residence time is also maintained for at least 15 days or more in the Primary Digester and 20 days or more in the Secondary Digester (typically in excess of 30 days). This qualifies the process as a PSRP and enables the biosolids to meet the requirements in 40 CFR 503.32(b)(3) and Appendix B, PSRP Alternative 3. However, as noted above (Section 1.2), Eielson is using the PSRP Alternative 2 as the pathogen reduction method to achieve and comply with the Class B biosolids requirements from 40 CFR 503.32(b)(3).

The Secondary Anaerobic Sludge Digester receives and stores digested sludge from the Primary Digester.

Similar to the Primary Digester, pumps recirculate the sludge through non-contact heat exchangers, though the Secondary Digester is operated at a lower temperature of between 85-90°F.

For both digesters, the continuous pumping through the heat exchangers provides mechanical mixing that aids in the solids degradation process and pathogen removal/destruction. Digester gas is collected from both digesters. Gas compressors recirculate the gas (through the sludge) to provide additional mixing/agitation. Excess digester gas is sent to a flare and burned off as pressures warrant.

2.2 SLUDGE DRYING BEDS

Digested Sludge from the Primary and Secondary Digesters is pumped to concrete lined Sludge Drying Beds located just west of the digesters. This facility maintains six (6) individual drying beds, each approximately 40 feet wide, 183 feet long, and roughly 7 feet deep with concrete walls. Each bed slopes at roughly 4% to a loading ramp on the west end. Digested sludge from the digesters is pumped to a distribution manifold on the east side of the drying beds where operators direct the sludge into selected bays by opening and closing manual valves. A drying bed leachate underdrain system collects the liquid that drains through the beds and returns it to the main treatment plant. After free draining of liquids, the digested sludge remaining in the beds continues to air dry. Photo 1 shows a view of the Sludge Drying Beds from the west side, with the concrete loading ramp seen in the foreground. The Primary and Secondary Digesters are in the background, buried beneath their earthen embankment, which also provides additional insulation.

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As described previously, air drying of the biosolids in the Sludge Drying Beds is the method selected for to achieve/meet the PSRP, enabling classification as Class B biosolids (40 CFR 503.32(b)(3) and Appendix B to Part 503, PSRP Alternative 2). It requires the biosolids to be dried on sand beds or on paved or unpaved basins for a minimum of three months with at least two months where the average temperature is above freezing (0ºC). At Eielson, the treated biosolids are dried for at least one winter season and several months before/after. Sludge is loaded to the drying beds throughout the spring and into the fall and allowed to dry over winter and through the following summer. Land application is generally performed in late summer or early fall as described in Section 3.0 of this document. The extreme cold experienced during a typical interior Alaska winter also provides for further pathogen reduction via the numerous periods where ambient temperatures can be -40 ºF or colder.

Photo 1. Eielson AFB Sludge Drying Beds (looking from west)

Photo 2. Digesters and Sludge Drying Beds (looking from north)

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OP E RATI ONS P LAN 3.0

This section provides the Operations Plan as required in Section 8 of the Land Application of Biosolids Permit Application. Each requirement of the Operations Plan is described in the following subsections.

3.1 ACCESS CONTROL

Access to the land application areas as shown in Figure 2 (Attachment 5) are to be restricted for Class B biosolids per 40 CFR 503.32(b)(5)(viii):

Public access to land with a low potential for public exposure shall be restricted for 30 days after application of sewage sludge.

As an active USAF installation, the general public is restricted from access to the entirety of Eielson AFB, and fencing is present along the majority of the installation boundary (see Attachment 5, Figure 2).

Additional restrictions exist for the area around and within the airfield, where access is monitored and controlled to avoid flight disruptions and minimize related safety concerns. While separate fencing does not exist completely around the airfield and adjacent areas, Eielson’s Security Forces Squadron provides regular patrols of this area to monitor for unauthorized access. In addition to the regular patrols, operators within the air traffic control (ATC) tower regularly look over the airfield (from the tower) to identify any unauthorized airfield entrants. Airfield entry requires radio communication to the ATC for each vehicle or entrant. Where biosolids may be spread outside the specific airfield, Eielson Security Forces will be notified to provide increased awareness and monitoring for any entrants into the spreading area.

For the proposed and specific land application areas, appropriate temporary signage will be installed to provide notification on the status of the specific spreading area for the 30-day period following application, consistent with the requirements in 40 CFR 503.32(b)(5)(viii). Signs will likely not be applied to areas within the airfield to avoid aircraft safety considerations; in these areas both Security Forces and ATC personnel will be notified of the land spreading and will provide increased monitoring of the area.

Access is controlled around the Sludge Drying Beds and the Eielson AFB WWTP via a limited use road and video monitoring of areas around the WWTP by the WWTP operators. The operators also perform daily walk-arounds of the plant to identify any operational issues and potential security/access concerns.

3.2 AGRONOMIC RATE OF APPLICATION

Attachment 4 provides the calculations used to determine the agronomic rates of application for Eielson’s biosolids based on the sampling and analysis of the dried sludge. Prior to each land spreading event, the dewatered and dried biosolids stored in the Sludge Drying Beds are sampled and analyzed for ammonia nitrogen, nitrate nitrogen and total Kjeldahl nitrogen (TKN). The results are used to determine total available nitrogen. Additional other parameters required to be analyzed for are listed below.

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Table 3-1. Biosolids Sampling Analytes and Test Methods

Analyte Test Method Units Moisture Content ASTM D2216 % moisture

Solids Content ASTM 2540G % solids Nitrogen Compounds:

Ammonia Nitrogen (NH4-N) EPA 4500 mg/kg Nitrate Nitrogen (NO3-N) EPA 9056 mg/kg Mineralized Organic Nitrogen (TKN-NH4-N)* EPA 351.2 mg/kg

Metals:

Arsenic EPA 6020B mg/Kg Cadmium EPA 6010B mg/Kg Copper EPA 6010B mg/Kg Lead EPA 6010B mg/Kg Mercury EPA 7471B mg/Kg Molybdenum EPA 6010B mg/Kg Nickel EPA 6010B mg/Kg Selenium EPA 6010B mg/Kg Zinc EPA 6010B mg/Kg

* Assuming mineralization rate is 20%

The table provided in Attachment 4 outlines the historical results for these analytes. The Biosolids Worksheet also provided in Attachment 4 outlines the calculated agronomic application rates for the dried biosolids. This calculation is performed on an annual basis based on the nitrogen results from the sampling of the biosolids. The calculation is performed as follows:

• The volume of the sludge to be land applied is measured. Percent solids are obtained by laboratory analysis. Biosolids density (wet weight) is estimated based values typically experienced at other similar facilities with similar solids concentrations (USEPA 1985).

• Total available nitrogen is calculated on a dry weight basis from the nitrogen compounds’ analytical results, resulting in a unit concentration of total available nitrogen, in pounds per ton of biosolids.

• An optimal total nitrogen loading rate of 75 dry pounds per acre is used to calculate the agronomic loading rate in dry ton per acre. This is used to calculate the acres of land required and the volumetric biosolids application rate in cubic yards per acre. The 75 lb/acre application rate is a conservative nitrogen uptake rate for grassy areas (University of Idaho 2005).

Using the biosolids application rate calculated for total available nitrogen, the application rates for the metals listed in Table 3-1 are also calculated and included the Biosolids Worksheet (Attachment 4).

The land application for the biosolids is a seasonal operation typically performed once each year, following the receipt of the sampling results. Eielson WWTP personnel will sample the biosolids, receive the analytical results, and perform the agronomic application rate calculations prior to conducting the land application. Application speeds and spreading rates are adjusted according to the area calculations in the worksheet (Attachment 4). Additionally, the Biosolids Worksheet (Attachment 4) for each year’s operations is included in the annual report to ADEC (described further below). To the extent possible, Atch 3 (12 of 17) biosolids will not be applied to areas used in the past 5 years. The annual reports provided as described in Section 3.14 will be used to help track the areas used for spreading. This restriction on specific spreading areas will assist and ensure that metals loading rates as given in Table 2 of 40 CFR 503.13 are not exceeded. Annual application rates are also maintained below the annual rates as given in Table 3 of 40 CFR 503.13 and the cumulative rates as given in Table 2 of 40 CFR 503.13; the comparison is provided in the Biosolids Worksheet (Attachment 4).

Sampling and testing procedures are performed in accordance with 40 CFR 503.13. A representative composite biosolids sample is obtained from the drying bed(s) to be spread. The procedures used for obtaining the composite sample follow general USEPA guidance and are as follows (USEPA 1989 and 1994):

• The rectangular bed is divided into half lengthwise and then each half is further divided into at least 4 equal sized sections; more sections will be used depending upon the total length and amount of biosolids in the bed. In general each section should not be more than 15 to 20 feet in length.

• Samples are obtained from each of the equivalently sized sections. The depth and specific location in each section where a sample is collected should be varied randomly. A small shovel can be used to collect each sample. Care should be taken to ensure that the random sample collection includes section samples from the surface, mid-depths, and the bottom of the bed.

Samples may be collected into small disposable cups to help ensure equivalent amounts are obtained from each section. The cups can then be combined into the larger composite sample container (i.e., a 1 liter plastic container).

• The large sample containers should be thoroughly mixed to ensure representativeness of the overall sample. Note that the laboratory should also be instructed to perform further mixing and homogenization prior to analysis.

The sample is submitted to the contract laboratory for analysis under appropriate chain-of-custody procedures and via overnight delivery. The laboratory varies according to federal procurement policies and procedures; recent analyses have been performed by ARS Aleut Analytical LLC in Fairbanks, AK.

Should sampling be required for the application areas themselves (soils plus spread biosolids), representative samples will be obtained and shipping/analytical methods shall be followed similar to those described above for the pre-application biosolids.

3.3 MATERIAL HANDLING AND ACCEPTANCE POLICY

This section in the Land Application of Biosolids Permit Application does not apply to Eielson AFB as the facility will only spread (land apply) biosolids generated at/from the Eielson AFB WWTP. No biosolids are accepted for land application from septage haulers or other sources. All biosolids originate from the WWTP as described in Section 2.1.

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3.4 BIOSOLIDS STORAGE

This section in the Land Application of Biosolids Permit Application does not directly apply to Eielson AFB; the facility does not maintain any separate/dedicated biosolids storage facilities. The Sludge Drying Beds, while providing some degree of temporary storage, are considered an integral step in the biosolids treatment process. After proper treatment by dewatering and air drying, the aforementioned procedures are used to spread the biosolids onto the land application areas. As noted in the design information (Section 2) and Attachment 6, the facility has six Sludge Drying Beds and typically only one bed is required for a year’s worth of sludge production and subsequent drying/treatment. Typical dried biosolids production rates are approximately 100 yd3 per year. Based on conservative sludge production assumptions/rates, the six Sludge Drying Beds at the facility provide more than 4 years of drying/treatment capacity.

3.5 BIOSOLIDS APPLICATION

Personnel from the Operations Flight of the Eielson AFB Civil Engineering Squadron (354 CES/CEO) perform the land spreading of the biosolids in the areas designated on Figure 2 (Attachment 5). All biosolids are tilled/mixed into the top layer of the soil after spreading; this mixing/tilling into the soil is accomplished by disking the surface of the soil after land spreading. The disking of the biosolids is performed using equipment similar to that shown in Photo 3. The spreading and prompt tilling/disking of the area following biosolids application conforms to the requirements from 40 CFR 503.33(b)(10)(i) for vector attraction reduction.

Photo 3. Typical Land Spreading/Disking Equipment

3.6 ODOR CONTROL PLAN

Eielson AFB has not historically experienced odors from its biosolids land spreading operations; this is likely due to the significant treatment and drying time that the biosolids receive prior to application. The biosolids are treated as described in Section 2.0, resulting in biosolids that meet the 40 CFR 503 “Class B” criteria. The significant drying and freeze-thaw cycles that occur within the Sludge Drying Beds reduces the anaeraobic conditions that may lead to significant odor generation and concerns. The distance

Atch 3 (14 of 17) of the land spreading areas from any residential or commercial institutions/facilities also minimizes the potential odor concerns.

As described above, following the land spreading, the biosolids are promptly tilled into the soils to further reduce vector attraction and potential odor concerns. The immediate tilling also conforms with the requirements from 40 CFR 503.33(b)(10)(i).

In the unlikely event that an odor problem occurs, Eielson can/will apply lime to the application area to reduce the noted odors.

3.7 LITTER, VECTOR, NOISE, AND NUISANCE CONTROL PLAN

The prompt disking of the biosolids into the soils of the application area reduces the vector and odor potential and also complies with the requirements from 40 CFR 503.33(b)(10)(i) for vector attraction reduction.

Eielson generally keeps large animals and bird populations away from the airfield to provide protection for airfield operations. This will also minimize the potential for these animals to be exposed to the biosolids or linger in the application areas.

As noted above, the proposed locations for the land spreading are a significant distance from commercial and residential buildings, reducing concerns for noise and odors. Eielson maintains an active litter avoidance and cleanup/protection plan as a means to minimize litter in the airfield, which can produce significant safety concerns for aircraft. USAF personnel perform regular patrols of the airfield and nearby areas to collect litter, also known as foreign objects and debris (FOD).

During the 60 days following the application of the biosolids, Eielson will perform periodic visual inspections of the spreading area to ensure that litter, trash, or other nuisance considerations do not arise in the recently spread areas. An informal checklist that will be used for these inspections is provided in Attachment 7.

3.8 SURFACE AND STORM WATER CONTROL PLAN

The following operating procedures will be used to control surface water and groundwater concerns from the proposed land spreading sites.

• Biosolids will not be spread within 200 feet of any drinking water wells; Eielson AFB water supply wells are shown on Figure 2 (Attachment 5).

• A 33 foot (10 meter) buffer will be maintained between the edge of the land spreading and any surface water. The biosolids will only be spread in areas with generally flat topology or where the drainage carries runoff away from nearby surface waters. The areas shown in Figure 2 (Attachment 5) meet this criteria. The flat topology and porous nature of the soils in the potential land spreading areas promotes the prompt infiltration of any precipitation and minimizes storm water runoff.

• To prevent runoff, biosolids spreading operations will not take place if the ground is frozen or saturated. Similarly, biosolids spreading/application operations will not be performed when it is

Atch 3 (15 of 17) raining or significant rain is forecast for the day of application. This will minimize potential biosolids runoff concerns and will ensure that the spreading and tilling equipment can efficiently perform the spreading operations.

The Sludge Drying Beds are designed to prevent storm water run on from the surrounding land (see Photos 1 and 2). The finished grade around the drying beds slopes away from the beds such that the only storm water that may impact the stored/drying sludge is precipitation that may fall directly on each bed.

Any accumulation of storm water in the drying beds is removed by the leachate underdrain system (which collects the water for treatment back through the pre-aeration basin and the front of the WWTP).

Accumulated precipitation may also evaporate from each bed.

3.9 CORRECTIVE ACTION PLAN

Eielson AFB performs regular visual monitoring around the full WWTP, including the Sludge Drying Beds. Records of any pertinent observations are maintained within the WWTP office and if maintenance or other repairs is necessary, appropriate work orders are completed.

Proper operation and maintenance, of both the liquid and solids treatment processes at the WWTP are part of the overall WWTP operations and are carried out by its operators. Operators are trained on the proper operations of the various WWTP processes and maintenance procedures, with most operators maintaining appropriate ADEC WWTP Operator certifications.

3.10 APPLICATOR TRAINING

As described previously, the annual land spreading operations are performed by members of the Operations Flight within the Civil Engineering Squadron (354 CES/CEO).