IRC pathogen drift petition for negotiated rule making to ISDA

8/14/2019 IRC pathogen drift petition for negotiated rule making to ISDA

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BEFORE THE STATE OF IDAHODEPARTMENT OF AGRICULTURE

IDAHO RURAL COUNCIL, ) Docket No.__________

INC. )Petitioner. ) PETITION FOR INITIATION

) OF RULEMAKING)

________________________ )

1. INTRODUCTIONCOMES NOW the Idaho Rural Council, Inc. and petitions the Director of the

State of Idaho Department of Agriculture for initiation of rulemaking pursuant toIdaho Code 22-101 and IDAPA 02.01.01. This Petition requests that the Director

initiate rulemaking by publication in the Idaho Administrative Bulletin of a noticeof proposed rulemaking pursuant to Idaho Code 67-5220.

Petitioner requests that this Petition be acted upon by the Director within 28days after its submission as required by Idaho Code 67-5230.

The purpose of this Petition is to amend IDAPA 02.04.14, Rules of theDepartment of Agriculture Governing Dairy Waste (the rules). This Petitionseeks an amendment of rules that currently define discharge violations but donot specifically address discharges that occur as a result of aerosolization ofdairy lagoon constituents when land applied through pressurized irrigationsystems.

2. PETITIONERS INTEREST IN THE MATTERThe Idaho Rural Council, Inc. (IRC) is a grassroots organization of family

farmers, ranchers and rural residents that has worked since 1986 to preserve thewell being of Idahos family farms and rural communities.

Many of our members live in rural Idaho where large dairy facilities have beenbuilt with vast waste water lagoons designed to store liquid and semi- solid wasteproduced by the dairy herd for periods as long as 180 days. A routine,widespread practice for disposing of accumulated lagoon water is to land apply itto farm fields through pressurized irrigation systems such as pivots or wheellines.1 Irrigation systems used for this purpose often discharge their contents onpublic roadways and neighboring properties. These events have been reported

frequently by IRC members who live in rural parts of Idaho where large lagoonsare located. Such events are especially common when members are doused with

visible droplets or mists from pivots or wheel lines while driving through southern

1Photographs of two typical systems used for lagoon wastewater application are included

in Appendix A.


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Gooding and Jerome Counties, where one of Idahos greatest concentrations oflarge dairies is situated near popular recreational sites along the Snake River inthe 1000 Springs reach.2

IRC has collected samples of a pivot end-gun discharge from a large dairy in

Twin Falls County. The collection point was across the public roadway from thefield where the pivot was located, within twelve feet of a fenced yard wherechildren played. The overspray tested at over 20,000 FCU ( fecal coliform units)/100ml) - almost 10,000 times the level at which human waste must be disinfected

before it might be used for lawn irrigation where children are present.3While data documenting the total current dairy lagoon storage capacity in

Idaho is not available, a very crude extrapolated estimate of that capacity wouldbe 383,518,800 cu.ft. 4 or approximately 8,800 acre feet of lagoon storagecapacity needed just for the mature milking cow population of Idaho. Thatestimate is based on an extrapolation using:

- Recent industry published population statistics on the milking herd in Idaho

putting the number at 513,000 head; 5- A lagoon storage capacity calculation from a recently proposed dairy/

replacement heifer facility in Twin Falls County consisting of 3,756 animal units.The system was engineered( pursuant to Idaho State Dept. of Agriculture

specifications) to store 2,006,872 cu.ft. of liquid waste;6- The standard accounting of a mature dairy cow as equaling 1.4 animal

units.Either by direct observation or by the very rough calculation described above it

is clear that there is a very significant amount of dairy lagoon effluent capacity inIdaho, a significant part of which is land applied through pressurized irrigation

systems during the Spring and Fall if not more often. Waste water stored in

2The Idaho State Department of Agricultures MOU Annual Report ( April 23, 2007)

reported that at the end of 2006 the milking herd populations of Jerome County andGooding County were 70.735 head and 117,758 head respectively. The National

Agricultural Statistics Service puts the numbers at 70,500 head for Jerome Co. and140,000 head for Gooding Co. as of Jan. 1, 2007. See: www.nass.usda.gov . Many

pressurized irrigation systems operate without the addition of lagoon effluent so it isimpossible to be sure, without sampling, whether these roadside carwashes are just a

normal part of country driving or something more serious. However, during Spring andFall when lagoons are typically emptied it the presence of lagoon water in the irrigation

systems is readily detected because of the color of the water and its very foul odor.3

See Appendix C, Table 4-1.4 ( 534 cu. ft. per a/u) X (718, 200 a/u where a milk cow = 1.4 a/u) = 383,518, 800 cu. ft.5Progressive Dairyman, Vo. 22 No.5, (March 25, 2008)

6That storage capacity includes adequate space for runoff from corrals, roofs, etc. and is

not represented to be the volume of waste the dairy herd excretes.


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lagoons is often diluted with other irrigation water to reduce offensive odors at aratio of anywhere from 4:1 to 9:1. In other words, the 8,800 acre foot of capacityprobably represents a small fraction of the volumeof lagoon effluent (diluted)actually land applied.

In addition to the visible droplets associated with these discharges, wind driftoccurs carrying minute, aerosolized wastewater constituents considerabledistances from wastewater application fields. This phenomenon is well

documented in an Idaho Department of Environmental Quality Report titledTechnical Background Document: Microbial Risk Assessment and Fate and

Transport Modeling of Aerosolized Microorganisms at Wastewater LandApplication Facilities in Idaho ( Feb., 2006) 7. The study had this to say aboutland application of liquid waste from municipal and industrial sources:

A concern surrounding the land application systems commonly used in Idahois the prevention of irrigation wind drift, which includes droplet and aerosol

drift. Wastewater land treatment facilities are often located in close proximityto dwellings, public parks and schools, rivers and streams, irrigation canals,roads, and other features that require special management of wastewater toprotect health, safety, and the environment.

Because municipal and food processing wastewaters contain microbialconstituents that could pose a risk to human health when land applied, theIdaho Department of Environmental Quality (DEQ) has developed apreliminary microbial risk assessment(MIRA) methodology to quantify thisrisk and to protect public health and safety. ( Id., at xiii)

There is no reason to think that microbial constituents from dairy lagoons

behave any differently from those from other sources when land applied throughpressurized irrigation systems- they too must drift. IRC has attempted, through

public information requests to the responsible agencies, to obtain Idaho- specificstudies documenting pathogens and other potential harmful chemical/ biologicalconstituents of lagoon water. Those efforts have not been successful.8 However,in 2005, the Environmental Protection Agency released a report titled Detectingand Mitigating the Environmental Impact of Fecal Pathogens Originating fromConfined Animal Feeding Operations: Review.9That report provides a reliablyscientific basis for believingthat pathogens harmful to human health, livestock

7 The report is available at:

http://www.deq.state.id.us/water/assist_business/engineers/guidance/microbial_risk_assessment.pdf8 The Idaho Department of Agriculture responded to such a request from IRC byacknowledging that it had studied the nutrient values of lagoon water ( because it has

some value as fertilizer) but never analyzed potential harmful constituents.9

The report is available at: http://www.epa.gov/NRMRL/pubs/600r06021/600r06021.pdf


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health, and crop health are present in dairy lagoon waste water. The Director isasked to take note of several parts of the report:

- A chart listing zoonotic pathogens that may be of concern near CAFOsreproduced in Appendix B of this Petition;10

- The reports discussion of the survival of pathogens in manure slurries ( at pp.

18- 21;- The reports finding that Several studies have documented increased

airborne pathogens directly attributable to the spread of human or animal

manure on agricultural lands through spray irrigation with contaminatedwaters or deposition of animal placental and fecal wastes and subsequent

distribution to downwind animal or human receptors ( at pp. 35);- The reports finding that Uncontrolled releases of pathogens may occur via

runoff, aerosolization, or infiltration into soils and groundwater, especiallywhen manure is spread onto land ( at p. 42);

- The reports findings related to the public health risks associated with the

movement of antimicrobial- resistant pathogens from CAFOs:The conditions of widespread, prolonged exposure to antimicrobialcompounds at sublethal doses with little dose control in CAFOs mayexacerbate their development. Once established, the movement of

antimicrobial-resistant microorganisms from animal to animal or animal toanimal care worker may be facilitated by the crowding of animals intoconfinements, often with suboptimal hygiene. .. As much as 75-80% ofan antibiotic may pass undigested through an animal, thus its waste maynot only harbor high concentrations of antimicrobial-resistant bacteria, butalso their resistance genes and raw (undigested) antimicrobial compounds.

.This waste is often stored in open air lagoons and/or spread on fieldswhere these compounds, resistant organisms, and antimicrobial-resistance

gene reservoirs may move into the environment via aerosolization,infiltration into the groundwater, or runoff into surface water resources.

Antimicrobial resistance in zoonotic pathogens is a serious threat tohuman health. Many of the drugs are used in animal agriculture andhuman medicine are the same or very similar including, but not limited to,betalactams (penicillin, ampicillin, cloxacillin), tetracyclines, sulfonamidesand potentiated sulfonamides, cephalosporins, and fluoroquinolones).Exposure to zoonotic pathogens harboring resistance to antimicrobials ofclinical importance may lead to diseases with few or no treatment options

in humans. In cases where pathogens are resistant to administeredantimicrobial compounds, vulnerability to infection can increase up to

three-fold, primarily resulting from a transient decrease in an individualsresistance to colonization by the pathogen. Antimicrobial-resistant

10At pp. 6-10 of the report.


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pathogens tend to be more virulent than their susceptible counterparts,causing more prolonged or severe illnesses ( at p. 17, citations omitted )

While the report does not comprehensively address other chemical

constituents of dairy lagoon waste water that may be a hazard to human health,livestock or crops, large dairy facilities need to control insect pests and usepotentially toxic chemicals for that, and other purposes . 11 It is very likely thatmeasurable amounts of those products find their way into lagoons either as part

of the excretia from the herd or from wash water/wastewater diverted to thelagoons.

Land application of liquid waste from municipal and industrial sources hasbeen regulated under IDEQs Wastewater Land Application Permit (WLAP)

program since 1988 under the authority of IDAPA 58.01.17.12As part of thatprogram IDEQ has promulgated rules and guidance documents designed to

reduce exposure to pathogens. Excerpts from IDEQs Wastewater LandApplication Operators Study and Reference Manual ( October , 2005) areincluded in Appendix C to illustrate what experts believe can minimize exposureto pathogens, including those that might be airborne. The excerpted sections of

the guidance:- characterize five basic types of effluent ( from municipal sources) that are

differentiated by the end-use to which they are put and the populations that mightbe affected by exposure to pathogens;

- describe several methods of wastewater disinfection;- establish buffer zones to protect the public from exposure to particular levels

of effluent being applied dependent on the exposure risk.

Based on the various IDEQ and EPA references cited above in this petitionIRC believes that lagoon pathogens and possibly other substances harmful to

11There is some data about insecticide use at Idaho dairies in a report by USDA titled

Agricultural Chemical Usage: 2006 Dairy and Dairy Facilities Summary available at:

http://usda.mannlib.cornell.edu/usda/current/AgriChemUsDairy/AgriChemUsDairy-05-23-2007.pdf It is unknown whether these insecticides are present in lagoonwater as a result of the washing process cows go through before milking.12

The history of the program is summarized in the preface to IDEQs Guidance forReclamation and Reuse of Municipal and Industrial Wastewater , September2007. Page xvii, on the web at:http://www.deq.idaho.gov/water/permits_forms/permitting/guidance.cfm


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human health and livestock health are aerosolizing in the same manner aspathogens from currently regulated sources. Our members and members of thegeneral public who live near, travel through, or raise livestock or crops withinproximity of farm fields where wind drift occurs as a result of lagoon water land

application through pressurized irrigation systems may be impacted bypathogenic organisms found in bovine dairy waste and other bio/chemicalconstituents of dairy lagoons.

At the time this petition was filed a limited search in other jurisdictions for

regulations similar to those requested had been done. The results were asfollows:

1. California: Most lagoon effluent is applied through flood irrigation systems,minimizing the potential for aerosolizing pathogens. California has noregulations specifically focused on the drift phenomenon;

2. New York: Response pending;3. Wisconsin: Response pending:

4. North Carolina: Moratorium on new sprayfields enacted in 1997 targeted atswine facilities which are prevalent in that state. In 2007 North Carolinaenacted the Swine Farm Environmental Performance Standards Act whichbans the construction or expansion of new lagoons or sprayfields.

IRC will attempt to compile a more thorough summary of regulations in otherstates for review by the Director at the earliest possible time.

3. REQUESTED AMENDMENTS/ADDITIONSIRC proposes amendments and additions to the dairy waste discharge rules

that specifically address discharges that occur when lagoon effluent is landapplied through pressurized irrigation systems. IRC proposes to amend the

current discharge rules to incorporate the same risk assessments and protocolsused by the Idaho Department of Environmental Quality when issuing permits forthe land application of liquid waste from industrial or municipal sources. ( SeeIDAPA 58.01.17 et seq.)

Waste lagoons have been required at confined animal feeding operations(CAFOs) for many years in Idaho to protect our surface and ground water from

pollution. At the same time, land application of lagoon water through pressurizedirrigation systems has been overlooked as a potential threat to air quality. While

current ISDA rules prohibit discharges from dairy facilities, they do not specificallyaddress discharges that may not be visible such as the drift of aerosolizedparticles from pressurized irrigation systems. Adverse human health, livestockhealth, and crop health effects associated with land application of liquid municipal


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and industrial waste through pressurized irrigation systems have beenrecognized for many years as a legitimate basis for regulating that activity. IRCmembers believe the lagoon effluent land applied the same way poses similarrisks and should be specifically addressed in ISDAs discharge rules. The EPA

report cited earlier in this Petition states that livestock CAFO wastes can be asmuch as 100 times more concentrated than human wastes, and the treatment ofhuman wastes is required by law prior to discharge into the environment.13

Exposure to airborne pathogens or other harmful substances associated with

lagoon water land application poses a risk to the health of our members living in,and/ or raising livestock, horses, or crops in rural Idaho.

4. REGULATORY BACKGROUNDPursuant to Idaho Code 22-101 the Director of the Idaho Department of

Agriculture is authorized to adopt rules governing discharges from dairy facilities.

5. CLOSINGIRC appreciates the Directors consideration of this Petition. IRC will make its

staff and members available at any time convenient to the Director to addressquestions or concerns and will similarly help the Department in its review of this

Petition.

Respectfully submitted this __ day of May, 2009.

By: _____________________________Richard Carlson

IRC Legal Counsel

13EPA report, p. 1.


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APPENDIX A

ABOVE: Pivot along public road- Twin Falls CountyBELOW: Wheel line along public road- Twin Falls County


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Table 1. Selected zoonotic pathogens zoonoses that may be of concern for water quality near CAFOs tInfectious Agent Infectious Incubation Disease Host Range ReservoirDose Period SymptomsBacterialBacillus anthmcis 8000-50000(by inhalation) 2-5 days Anthrax, Wool sorter's diseaseCutaneous skin lesions, death (5-20%)

Inhalation respiratory distress, fever, shock,deathIntestinal- abdominal distress, fever,

Humans, cattle,swine, goats,sheep, horsesSpores remainviabIe in so ilcontaminated byanimal wastes foryears

septicemia, death (rare)

0 \

Brucella spp.

Campylobacterjejuni

Clostridium tetani

Unlmown

:::500(by ingestion)

Toxin isextremelypotent

Highly Variable5-60 days

1-10 days

3-21 days

Brucellosis, Undul ant Fever, Ba ng's Disease,Malta Fever, Mediterranean FeverIntermittent fever, headache, weakness, profusesweating, chills, arthralgiaCampylobacter enteritis, Vibrionic enteritis,Traveler's DiarrheaDiarrhea, abdominal pain, malaise, fever,nausea, vomiting, septicemia, meningitis,Guillain-Barre syndrome, death (rare)Lockjaw, TetanusPainful muscular contractions, abdominalrigidity, spasm, death (30-90%)

Hwnans, cattle,swine, goats,sheep, deer,caribou, elk,dogs, coyotesHumans, cattle,swine, goats,sheep, poultry,rodents, birds,household pets,Humans, animals

Cattle mostcommon

Cattle, swine,sheep, poultryhousehold pets,rodents, birdsIntestine ofanimals andhumans, soilcontaminated withanimal feces

Coxiella burnetii 10(by inhalation) 2-3 weeks Q fever, Query Fever, RickettsiaAcute febrile disease chills, headache,weakness, malaise, severe sweats, pneumonitis,pericarditis, hepatitisHumans, cattle,sheep, goats Sheep, cattle,goats, especially atparturition

generalized infections endocarditist Hazen and Toranaos, 1990; WHO, 1993; DuPont et al., 1995; Morris and Levin, 1995; Geldricb, 1996; ASM, 1998; Haines et al., 2004; PHAC, 2005


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Table 1. Selected pathogenic zoonoses that may be of concern for water quality near CAFOs (Continued)Infectious Agent InfectiousDose Incubati,onPeriod DiseaseSymptoms Host Range ReservoirBacterial (Cont.)EnterohemorrbagicEscherichia coli(E. coli 0157:H7 andotbers)

5-10 2-8 days EHEC, Verotoxin-produding E. coli, VTEC,Shiga toxin-producing E. coli, STECHemorrhagic colitis, abdomi nal pain, bloodydiarrhea, fever. hemolytic uremic syndrome,thrombocytopenicpwpura, death (in children)

Humans, cattle,swine, goats,sheep, pouluyHumans andlivestock animals

EnteropathogenicEscherichia coli

108_10 10 inadults,Unknown ininfants

0.5-3 days Attaching and effacing E. coli, enten)adherantE. coli, infantile diarrheal diseaseWatery diarrhea,fever, cramps, vomiting, bloodystool in some cases, serious disease in infants

Hwnans (esp.infants), cattle,swine, goats,sheep, poultry

Hwnans andlivestock animals

-. )

Leptospira spp.

Lister ia mOl1ocytogelles

Unknown, butmay be as lowas 3

Unknown, butlikely less than103

4-19 days

3-70 days(mean = 21)

Leptospirosis, Weil's Disease, Caoicola fever,Hemorrhagic jaundice, Mud fever,Swineherd's diseaseFever, headache, chills, muscle aches, vomiting,meningitis, rash, jaundice death (I-are)Listeriosis, Listerella ,-Fever, muscle aches, nausea, diarrhea,headache, stiffneck, con/us on, loss of balance,convulsions miscarriage or stillbirth, prematuredelivery, death in about 20% ofall cases

Hmnans, cattle,swine, horses,dogs, rats, wildanimalsMammals, birds,fish, cms aceCUls,and insects

Farm and petanimals, rats androdents (wine andabortion products)Domestic and wildmammals, fowl,and humans(aborted fetuses oflivestock animals)

Mycobacterium bovisM. tuberculosis

10(by inhalation)

4-12 weeks Tuberculosis, TnFatigue, fever, cough, chest pain, hemopty sisfibrosis, irreversible damage to lungs

Humculs, cattl e,swine, otheranimals

Humans, diseasedcattle, swine, andother manunals

Salmonella spp.(non-typhi or paratwhi)

100-1000(by ingestion)

0.25-3 days Saimouellosis, Acute GatroeoteritisAbdominal pain, diarrhea, nausea, vomiting,dehydration, septicemia, reactive arthritis

Humans, cattle,swine, poulf:J.y,horses, rodents,household pets

Humculs, cattle,swine, poultry,horses, rodents,domestic pets

Yersinia enterocolitica 106 3-7 days Yersilliosis, enterocolitis,pseudotuberculosisDiarrhea, acute mesenteric lymphadenitismimicking appendicitis, fever, headache,anorexia, vomiting, phatyngitis, reactive arthritis

Humans, swine,household pets

Primarily swine


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zoonoses that may be of concern for water near CAFOs

Balantidium coli may be as lowas 10-100

4-5

VVlos/Jorimum parvum 132 1-12

Giardia LamiJlia 1-10 3-25

Balantidialtenesmus,

andmucoid stools

nUl I1i :Ul1" , wild,Uld domestichousehold

also rodents

and other domesticanimals

nUI l 1


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Table 1. Selected that may be of concern for water nearCAFOsReservoir

dose Period

Schistosoma spp. Unknown 14-42 SnailSwimmer's Itch

S. haematobiumand hematuria

Trichinella Unknownanimals

marine mammals\D


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Table 1. Selected pathogenic zoonoses that may be of concern for water quality near CAFOs (Continued)Infectious Agent Infectious

doseIncubationPerioddays

DiseaseSymptoms

Host Range Reservoir

VirusesHepatitis E Virus Unlmown 14-63 HEVJaundice, anorexia, hepatomegaly, abdominalpain, nausea, vomiting, fever, Liver Failure;

most severe hepatitis during pregnancy of allhepatitis vintses

Humans, swine,rodents, chicken

Unknown-possibly in swine

Influenza A virus 2-790 1-4 FluAcute fever, chills, headache, myalgia, weakness,runny nose, sore throat, cough

Humans, swine,horses, domesticand wild avianspecies

Humans, animalreservoirs(particularly swine)are suspected assotll"ces of newhtunan subtypes

>- 'oLymphocyticchoriomen ingitis viI-us Unknown

8-21 LCM, Lymphocytic meningitisMild iI!fluenza-like illness or maningeal ormeningoencephalomyelitic symptoms, GuillainBarre type syndrome, orchitis or parotitis.

Htunans, swine,household pets,rodents

Rodents, swine,household pets

In more severe cases, temp ormy or permanentneurological damage, abortion, congenitalhydrocephalus , and mental retardation

SARS Coronavirns Unknown 6.4 (mean) SARSHigh fever, dry cough, dyspnoea, myalgia,diarrhea, vomiting, death (13.2% for infectedindividuals under 60, 43.3%for those over 60)

Humans, swinechickens, ferrets,cats, macaques

Unknown - butanimal reservoir issuspected

West Nile Virus Unknown 3-14 West Nile Encephalitis, Viral EncephalitisSudden onset offlu-like illness, malaise,anorexia, nausea, vomiting, rash, andlymphadenopathy.More severe infections can result in asepticmeningitis or encephalitis, ment al statuschanges, seizures, coma, severe neurologicdisease, an d death (4-11%)

Mammal,reptilian, andavian hosts.Mrumnalsgenerallyconsidered deadend hosts

Birds are theamplifying host


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APPENDIX C

Municipal Reclaimed Wastewater Effluent Classes

In the State of Idaho, Department of Environmental Quality Wastewater LandApplication Permit Rules (IDAPA 58.01.17), various classes (Class A Class E)

of municipal reclaimed wastewater are defined. Requirements for the direct useof each class of wastewater are also presented in the rules. Wastewater landapplication is one type of direct use. Partial descriptions of the five effluentclasses are given below.

Class A effluentis municipal reclaimed wastewater that may be used underparticular circumstances for residential irrigation at individual homes(controlled only by the system operator), ground water recharge, surfacespreading, seepage ponds, other unlined water features, and other appropriateuses. Class A effluent shall be oxidized, coagulated, clarified, and filtered, or

treated by an equivalent process and adequately disinfected. Enhanced

filtration approval requirements, nutrient removal requirements, turbiditylimits requirements, monitoring requirements, reliability and redundancyrequirements, and distribution system requirements also apply.

Class A treatment systems are required to be pilot tested at full scale prior tosewer hookups, lifting of sanitary restrictions, and start-up. Class A effluentshall be considered adequately disinfected if, at the point of compliance, themedian number of total coliform organisms does not exceed two and two tenths(2.2) per one hundred (100) milliliters, and does not exceed twenty three(23) per one hundred (100) milliliters in any confirmed sample, as

determined from the bacteriological results of the last seven (7) days forwhich analyses have been completed.

For ground water recharge, surface spreading, seepage ponds, and otherunlined water features, IDAPA 58.01.11, Ground Water Quality Rule,requirements apply. For Class A effluent, analysis shall be based on dailysampling during periods of use. The point of compliance for Class A effluentfor total coliform shall be in the distribution system following finaltreatment, final storage and disinfection contact time. Residual chlorine at thepoint of compliance shall be not less than one (1) mg/L free chlorine after a

contact time of thirty (30) minutes at peak flow (or an alternate disinfectionprocess demonstrated to the satisfaction of DEQ). Class A effluent forresidential irrigation should be applied only during periods of non-use.Additional Class A effluent requirements include limits for turbidity, totalsuspended solids, nitrogen, organics, and pH.

Class B effluentis municipal reclaimed wastewater that may contact anyedible portion of raw food crops or is used to irrigate golf courses, parksplaygrounds, schoolyards and other areas where children are more likely to

have access or exposure.Class B effluent shall be oxidized, coagulated, clarified, filtered, or treated by

an equivalent process and adequately disinfected. Class B treatment systems


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are required to be pilot tested at full scale prior to sewer hookups, lifting ofsanitary restrictions, and start-up. Class B effluent shall be consideredadequately disinfected if, at the point of compliance, the median number oftotal coliform organisms does not exceed two and two-tenths (2.2) per onehundred (100) milliliters, and does not exceed twenty-three (23) per one

hundred (100) milliliters in any confirmed sample, as determined from thebacteriological results of the last seven (7) days for which analyses have beencompleted.

For Class B effluent, analysis shall be based on daily sampling during

periods of application. The point of compliance for Class B effluent for totalcoliform shall be in the distribution system following final treatment, finalstorage and disinfection contact time. Residual chlorine at the point ofcompliance shall be not less than one (1) mg/L free chlorine after a contacttime of thirty (30) minutes at peak flow. Class B effluent shall be appliedonly during periods of non-use by the public.

Class C effluentis municipal reclaimed wastewater that will only contact the

inedible portion of raw food crops, or that is used to irrigate orchards andvineyards during the fruiting season, if no fruit harvested for raw use comesin contact with the irrigation water or ground or will only contact the inedible

portion of raw food crops, or is used to irrigate cemeteries, roadsidevegetation, and other areas where individuals have access or exposure. ClassC effluent shall be oxidized and adequately disinfected.

Class C effluentshall be considered adequately disinfected if, at the point ofcompliance, the median number of total coliform organisms does not exceedtwenty-three (23) per one hundred (100) milliliters, and does not exceed twohundred thirty (230) per one hundred (100) milliliters in any confirmed

sample as determined from the bacteriological results of the last five (5) daysfor which analyses have been completed.

For Class C effluent, analysis shall be based on weekly sampling duringperiods of application. The point of compliance for Class C effluent for totalcoliform shall be at the entrance to the distribution system following finaltreatment and disinfection contact time, but before storage. Class C effluentshall be applied only during periods of non-use by the public.

Class D effluentis municipal reclaimed wastewater that is used to irrigatefodder, seed, or processed food crops and is oxidized and adequatelydisinfected.

Class D effluent shall be considered adequately disinfected if, at some

location in the treatment process, the median number of total coliformorganisms does not exceed two hundred thirty (230) per one hundred (100)milliliters, not to exceed two thousand three hundred (2300) per one hundred(100) milliliters in any confirmed sample, as determined from thebacteriological results of the last three (3) days for which analyses have beencompleted. For Class D effluent, analysis shall be based on monthlysampling during periods of application. Animals shall not be grazed on land


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where Class D municipal wastewater is applied, and animals shall not be fedharvested vegetation irrigated in this manner within two (2) weeks ofapplication.

Class E effluentis municipal reclaimed wastewater that is used to irrigatefodder, seed, or processed food crops or forested sites where public access is

restricted and the municipal wastewater shall be of at least primary effluentquality. Animals shall not be grazed on land where Class E municipalwastewater is applied, and animals shall not be fed harvested vegetationirrigated in this manner within four (4) weeks of application. (See: Wastewater

Land Application Operators Study and Reference Manual IDEQ. Oct. 2005pp1/10-12)

4.1 Disinfection

Disinfection is generally the last form of pretreatment prior to land application

of wastewater. The purpose of wastewater effluent disinfection is to destroydisease producing microorganisms or pathogens. As discussed in Section 1,

pathogens can cause many illnesses, such as typhoid fever, amoebic dysenteryand infectious hepatitis.

The disinfection process should be economical, operationally practical andenvironmentally acceptable. The three major types of disinfection used are thefollowing:

chlorination ultraviolet radiation ozone. ( See: Wastewater Land Application Operators Study and Reference

Manual IDEQ, Oct. 2005, pp.4/1)

4.2 Buffer ZonesA buffer zone is the area beyond the perimeter of a wastewater land applicationfield, which provides the minimum separation needed to reduce the potential for

impacts to public health and the environment as well as minimizing nuisanceconditions and aesthetic concerns. There are three parts that factor into a sitesbuffer zone requirements: buffer zone distances to other land uses of concern,posting requirements, and fencing requirements.

Land uses of concernfor which DEQ has established guideline buffer zonedistances are: areas of public access, surface waters, public or private drinkingwater supplies and occupied dwellings. The guideline buffer zone distances are afunction of the following:

the characteristics of the land applied wastewater (industrial or municipal) level of treatment and disinfection designed for land application site (Class A

municipal effluent, industrial) location of the land application field (suburban/residential or rural/industrialor residential)

mode of irrigation (sprinkler or furrow)For example, allowing spray mist from a wastewater land application sprinkler


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irrigation system to drift onto adjoining properties has the potential to createaesthetic, nuisance, and public health impacts. General buffer zone distancerecommendations for various land uses of concern are as follows:

Inhabited dwelling: 300 feet Private water supply well: 500 feet

Public water supply well: 1,000 feet Public access areas: 50 feet Permanent or intermittent surface water: 100 feet Temporary surface water and irrigation ditches and canals: 50 feet

In general, DEQs guideline buffer zone distances decrease with greaterdisinfection (lower total coliform counts) of the land applied wastewater. Inzoning ordinances.

In Section 1, the disinfection levels of the various classes of municipalreclaimed wastewater effluent were presented. The disinfection requirements,with respect to total coliform counts are summarized in Table 4-1.

Table 4-1. Total Coliform Disinfection Requirements for Municipal

Reclaimed Wastewater.

Effluent Total Coliform Disinfection Requirement Compliance Point

Class

Class A The median number of total coliform organisms In the distributionand does not exceed two and two-tenths (2.2) per system following finalClass B one hundred (100) milliliters, and does not treatment,final

exceed twenty-three (23) per one hundred storage and

(100) milliliters in any confirmed sample, as disinfection contactdetermined from the bacteriological results time.

of the last seven (7) days for which analyseshave been completed.

Class C The median number of total coliform organisms At the entrance todoes not exceed twenty-three (23) per one the distributionhundred (100) milliliters, and does not exceed system, followingtwo hundred thirty (230) per one hundred (100) final treatment andmilliliters in any confirmed sample as disinfection contact

determined from the bacteriological results of time, but before

the last five (5) days for which analyses have storage.been completed.

Class D The median number of total coliform organisms Some location indoes not exceed two hundred thirty (230) per the treatmentone hundred (100) milliliters, not to exceed two process.thousand three hundred (2300) per one hundred


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(100) milliliters in any confirmed sample, asdetermined from the bacteriological results of thelast three (3) days for which analyses have beencompleted

Class E At least primary effluent quality.

The buffer zone distances specified in a land application permit may vary from

DEQs guideline distances due to site specific characteristics. For example,buffer zone distances may be reduced through using mitigation measures,including the following:

Establishment of an effective physical or vegetative barrier to reduce drift oraerosol dispersion

Utilization of non-spray irrigation (drag tubes or equivalent apparatus)

Managing irrigation systems in a manner which would prevent any spray

drift towards the land use of concern Run-off and/or over-spray controls Combining Best Management Practices (BMPs) with standard buffer zone

distances to help protect drinking water supplies. Monitoring well bufferzone distances are typically less that drinking water well buffer zones andare also dependant on the types of BMPs used. Monitoring well buffer zonedistances may vary from site to site and are specified in the site permit.

(See: Wastewater Land Application Operators Study and Reference ManualIDEQ, Oct. 2005, pp.4/ 7-9)

Documents

IRC pathogen drift petition for negotiated rule making to ISDA