Goal: Allow in-state, year-round distribution of all MWRA pellets.
After successfully changing molybenum limit regs, MWRA pellets now hindered by new Department of Agricultural Resources regs…
This installment of News and Notes for October 2016 talks about the new challenges for MWRA pellets.
Advisory Board initiative to increase molybdenum limits successful!
Our victory on establishing a science-based, defensible molybdenum limit, which would allow for the year-round, in-state, beneficial reuse of MWRA pellets, was thrown a curve ball by the recently released Department of Agricultural Resources Plant Nutrient Application Requirements for Agricultural Land Regulations 330 CMR 3.00.
In essence, the scope of the regulation has been dramatically increased, making it practically nonviable for land-use application of MWRA pellets in state.
In our comments, the Advisory Board states that “we laud DAR’s goal to regulate and enforce the registration and application of plant nutrients put on our soil to reduce phosphorus loadings to water bodies. However, all biosolids are not the same and need to be reviewed differently.” Click through to access MWRA and MWRA AB comments.
We will work closely with MWRA staff and DAR to ensure the in-state beneficial reuse of MWRA pellets are not only a goal, but also an attainable reality.
FY 2016 Q2 Goals
- Coordinate with MWRA’s representative to the Advisory Group for EO562.
- Attend Listening Session on EO562, October 1.
FY 2016 Activity
- No new activity for Q1.
- Participated in Molybdenum-in-Biosolids workshop with the EPA, MassDEP and other interested parties, to provide the necessary scientific data required to justify changing the limit.
- Staff contacted Governor’s staff regarding Executive Order 562 recommending the DEP regulations regarding molybdenum as a candidate for review.
- NEFCO presented at Advisory Board meeting on the “Environmental Benefits of Re-evaluating Molybdenum Standard for Biosolids and Residuals Utiliziation.”
- Identified and scheduled meetings with organizations representing commercial property owners using molybdenum.
- Sent AB-approved letter to MWRA outlining concerns and possible solutions.
- Determined potential for in-state market year-round availability.
- Determined actual distribution of pellets by volume and locations throughout US.
- AB fall briefings – MWRA staff also reported, at Residuals briefing, that DEP staff is not receptive to changes to the state limits on in-state application of the Authority’s sludge fertilizer pellets.
- AB staff also spoke informally with Authority staff mid November on options and which members of staff were involved to date.
- AB meets with TRAC and gets molybdenum update.
- MWRA staff reached out to DEP but having difficulty finding receptive staff.
- AB Executive Director called DEP Commissioner to discuss the issue.
- AB staff contacted NY and tracked down studies used to set NY’s new limits
- MWRA’s responses to CaR concur with overall goal and assert that they will put together strategy and present options to the BOD.
- AB approves CaR including directive to MWRA to develop plan to get to year-round, in-state placement of product.
- MWRA staff presents to AB on background and current regulations on molybdenum.
Comments and Recommendations History
FY 2015 (printed May 2014)
- AB recommended that the Authority begin immediately to address molybdenum limits … with the goal of ensuring … pellets can be placed in-state throughout the entire year … and present a specific and detailed plan to do so to the MWRA Board by October 2014 (page 89; #29).