Discussion And Request For Direction Relative To Strategic Directive 8.3

Regulation Reviews For Alternative Daily Cover And Food/Green Waste

Composting

Strategic Policy Development CommitteeOctober 6, 2009

Strategic Directive 8.3

Review regulations to ensure that they are:

– grounded in the best available science

– address changing market conditions

– take advantage of developing technologies

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6 Priority Areas

1. Composting –Food Waste

2.Alternative Daily Cover (ADC)

3.Beneficial Use

4.Farm and Ranch Composting

5.Three Part Test/Green Material Contamination

6.Emerging Technologies

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Food Waste Composting Issues

1. Requiring a full permit may be too stringent

2. The current definition of food material is very general

3. Food material contains a large amount of contaminants that are not found in green material which impacts facility operations and product quality.

4. The potential negative environmental impacts of composting food material have not been fully researched.

5. Current regulations may not comprehensively address compost safety issues

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Food Waste Composting Recommendations

1. Change the definition of Food Material in regulation

2. Research and provide Best Management Practices (BMP’s) guidance for composting green material and food material to reduce odors, vectors, litter, air emissions, and water quality impacts as well as product safety

3. Link BMP’s for composting green material and food material to permit tiers

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Food Waste Composting Recommendations (cont.)

4. Continue to monitor and support future studies on handling food materials with green materials to reduce odors, vectors, air emissions, and water quality impacts

5. CIWMB provides Best Management Practices training on food waste composting in partnership with stakeholders to protect the environment and improve compost safety

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Proposed Timeframes – Food Waste Composting

• Research definition of food material and BMP’s

(2 months)

• Stakeholder workshops on food material definition and BMP’s (1 month)

• Develop BMP guidance document (2 months)

• CIWMB partners with stakeholders to provide BMP training

(2 months)

• Informal rulemaking process to revise food material definition (3 months)

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Proposed Timeframes – Food Waste Composting (cont.)

• Formal rulemaking process to revise definition of food material (6 months)

• Discussions on permit tiering of food/green material composting (2 months)

• Continue monitoring and supporting studies on handling food materials with green materials (ongoing)

• Approx. 16-20 month process, depending on available resources and stakeholder assistance

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Alternative Daily Cover Issues1. Optimum amount, depth, and quality of Board-approved ADC

may need to be more fully researched

2. Specifications for some ADC materials may make it difficult to evaluate compliance & could allow the misuse of ADC to go undetected

3. ADC materials may not meet regulatory definitions (contamination)

4. Additional guidance may be needed for site-specific demonstration projects using MRF and C&D fines

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ADC Issues (cont.)

5. Definition of “Green Material” is different than “Processed Green Material”

6. Organic waste-derived ADC is considered beneficial reuse, not disposal, which may be a disincentive to keep green material out of the waste stream.

7. Using organic materials to reduce greenhouse gas emissions at landfills is currently being researched

8. DTSC is re-examining Treated Auto Shredder Waste requirements

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ADC Recommendations

1. Develop standardized guidance on how to evaluate the ability of ADC to control odors, vectors, litter, fire, scavenging as well as the affect on greenhouse gas emissions

2. Develop best practices for ADC regulatory inspection methodology

3. Continue monitoring the life cycle assessment of organic materials in landfills

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ADC Recommendations (cont.)

4. Evaluate the economic impact of green material ADC on the composting industry

5. Continue to monitor the Department of Toxic Substances Control’s approach to regulating treated auto shredder waste

6. Do not address the difference in green material definitions at this time

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Proposed Timeframes - ADC• Research & develop draft ADC evaluation protocol and inspection

methodology (4 months)

• Stakeholder workshops on draft ADC evaluation protocol and inspection methodology (1 month)

• Finalize ADC evaluation protocol & inspection methodology

(2 months)

• LEA/operator training on ADC evaluation protocol & inspection methodology (3 months)

• Continue monitoring life cycle assessment (LCA) of organic materials in landfills & DTSC approach to regulating ASW

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Proposed Timeframes - ADC• Upon completion of LCA, CIWMB staff develop contract concept to

develop methodology to evaluate the economic impact of green material ADC on composting industry & a contract concept on the application of the methodology (1 month)

• RFP/RFQ Process (3 months)

• Begin development of methodology under contract (2 months)

• Begin application of methodology under contract (2 months)

• Approx. 16-20 month process, depending on available resources and stakeholder assistance

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White Papers & Stakeholder Comments

www.ciwmb.ca.gov/Organics/EventsInfo/ADCFoodWaste/default.htm#Materials

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