regulating composting united states composting council compost operations training course march 4,...
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Regulating CompostingRegulating CompostingUnited States Composting Council Compost
Operations Training CourseMarch 4, 2015
Greg ReyesCounty of Riverside
Department of Environmental Health
Ken Decio California Department of Resources Recycling and Recovery
(CalRecycle)
Regulations you may need to know
State• CCR, Title 14.• Environmental Protection– Waste– Water– Air
• Occupational safety• Product
Local• Land Use/Zoning/CUP• Construction &
Occupancy/Building• City/County Code• Solid Waste Mgmt• Hauling Franchise
Agreements
California Regulations(Integrated Waste Management Act)
– Integrated approach to waste management practices: emphasis on recycling and waste reduction.
– Title 14 (compost, transfer station, chip & grind, tiers) – Title 27 (Landfill)– Defined a statewide solid waste permitting and
enforcement program to be administered by CalRecycle and enforced at the local level by certified Local Enforcement Agencies (LEA).
– CalRecycle has dual mandate of assistance and enforcement
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Different types of Compostable Material Handling Permits
Full– Allows processing of all materials
Registration (limited scope)– Limited scope to make it easier to get permit
Enforcement Agency Notification (Permit-by-rule)– Permit deemed automatically within specific set of
conditions– Notify Planning Department
Material Type (Feedstocks)–Agricultural Material–Green Material–Biosolids–Food Material–Mixed Solid Waste
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Tier Placement
Volume to be processed•Compost– Excluded 500 yd3 or less material generated on site– Notification 12,500 yd3 or less green material – Full Permit >12,500 yd3 green material &/or other material
• Chip and Grind– Notification < 200 tons per day– Registration 200 to 500 tons per day– Full Permit > 500 tons per day
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Tier Placement
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TYPE OF FEEDSTOCK
EXCLUDED EA NOTIFICATION FULL PERMIT
BIOSOLIDS STORAGE ON SITE AT A POTW BIOSOLIDS ONLY SEPARATE FROM NORMAL TREATMENT AT A POTW
GREEN MATERIAL ≤500 CU YDS ONSITE≤1000 CU YDS GIVEN AWAY OR SOLD ANNUALLY
≤12, 500 CU YDS >12,500 CU YDS, ORGREEN MATERIAL WITH OTHER WASTE INCLUDING FOOD
AGRICULTURAL MATERIAL(INCLUDES MANURE)
≤1000 CU YDS GIVEN AWAY OR SOLD ANNUALLY
ONLY AG MATERIAL WHEN MIXED WITH OTHER WASTE INCLUDING FOOD
RESEARCH <50 CU YDS ≤5000 CU YDS ON-SITE OR IN-VESSEL(>5000 CU YDS WITH LEA APPROVAL)
FOOD WASTE ≤10 % FOOD WASTE, ONLY WITH GREEN MATERIAL ≤500 CU YDS, ON-SITE AND ≤1000 CU YARDS GIVEN AWAY OR SOLD ANNUALLY
RESEARCH OPERATION
ONLY WHEN ADDED TO THE TREATMENT OF BIOSOLIDS AT A POTW
ALL OTHER SITUATIONS
Locations–Stand-alone operation or facility–Co-located at a permitted solid waste facility–Biomass conversion site–Farm and ranch–Public Operated Treatment Works
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Tier Placement
Site Standards
Construction and Site Preparation– Layout or components– Maps– Signage and security– Leachate/runoff mgmt– Pad materials or performance– Engineering signoff
Site Standards
Permitting Requirements– Methods– Monitoring– Contingency or emergency– Non-compostables mgmt (contaminants)– Time limits– Closure requirement– Odor control (OIMP)
Site Standards
Odor Impact Minimization Plan– Nuisance odor plan, response methodology– Weather variations– Moisture/aeration– Regulatory approval– Documentation, benefit to the operator
Site Standards
Record Keeping– Log of operation– Annual report
Paper or electronic?Specific forms?
– How long to keep– Available for inspection
Site Standards
Sampling and Product Quality– Are there standards?– Sampling methodology and frequency– Labs specified?– Substitution?– Before distribution?– Availability?– Recourse if failed?
Other Environmental Protection Permits
Water Protection– State Water Resources Control Board– Regional Water Quality Control Boards (9)– National Pollution Discharge Elimination System– Erosion and Sediment control during construction– Long term stormwater management
Air Protection– Local air pollution control districts (35)– Odors as nuisance– Air pollutants from point sources
Other Permitting
Zoning– Often requires conditional use permit– Has been approved as an “ag-related” business
Fire Marshal
Solid Waste Management – District, County, Agency, Authority, or ?– May need to approve or include in plan
Sales & Marketing
Agriculture or Consumer ProtectionDepends on claims– Fertilizer, soil amendment or conditioner– Fertilizer includes guaranteed analysis of N-P-K
Label requirements
Facility license and product registration
– Certify and evaluate LEAs– Provide LEAs with technical support and training– Concur or object to issuance of permits– Inspect landfills (18 months) & other facilities as
needed to evaluate & assist LEAs
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CalRecycle Responsibilities
– Process and issue permits– Inspect facilities– Document compliance status– Complaint investigations– Carry out Enforcement Actions
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LEA Responsibilities
LEA Responsibilities
Common Problems– Heat, lack of or too much– Volume of Material – Record Keeping– Sources of liquids– Odors, Odors, Odors!!!!!
Working with Regulators
The InspectionYou know what they will look for!!!
– State Minimum Standards– Permit Conditions– Site volume limits– Organized and complete records– Complaint response
Working with Regulators
Regulators are regular people– Ask questions– Make sure you understand requirements and
expectations– Ask questions– Discuss problems– ASK QUESTIONS!
CalRecycle On-Line Assistance
Tier Placementwww.calrecycle.ca.gov/LEA/Regs/Tiered/TierChart.htm
Permit Toolboxwww.calrecycle.ca.gov/SWFacilities/Permitting/default.htm
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Revisions to Title 14 & Title 27 – 14 Issues
Food waste definition Land application: disposal or beneficial use On-site storage and 12,500 cubic yard limit Odor complaints POTWs accepting food waste and fats, oils and grease Green waste contamination Anaerobic Digestion facility permitting Regulatory coordination of meat, fish, and poultry Max. metal concentrations consistency with federal regulations Clarify “processing” in agricultural material definition Small-scale composting exclusions Clarify “permitted maximum tonnage” on Form E-1-77 Vermiculture EA Notification Inspection frequency language
Formal Rulemaking
- Formal rulemaking process – Oct. 10, 2014
- 45 day written comment period - Dec. 5, 2014
-Public hearing on December 10, 2014
-Staff currently reviewing comments
-Informal workshop – March 2015
Major Changes/Issues
– Food Material Composting
– Physical Contaminants in Compost
– Land Application of Compostable Materials
Food Material Composting
Current Food Material definition is general
Does not distinguish between various food waste types
Food material composting requires a full permit
Proposed Food Material Composting Regulation
Expands food material definition; adds “vegetative food material”
Allows composting of vegetative food material at a “Vegetative Food Material Composting Facility”
Food material composting still requires a Compostable Materials Handling Facility Permit
Proposed Compostable Material Handling Tiers
Excluded TierEnforcement
Agency Notification Tier
Registration Permit Tier
Full Solid Waste Facility Permit
Agricultural material derived from an agricultural site and
returned to the same site
Vermicomposting
Mushroom farming
Small-scale composting(< 100 yd3 or 500 sq. feet)
Refer to Section 17855 for complete list
Agricultural Material Composting Operations (all)
Green Material Composting Operations
(< 12,500 yd3)
Biosolids Composting Operations at POTWs (all)
Research Composting Operations
Chipping and Grinding Operations (< 200 tpd)
Vegetative Food Material Composting Facilities
(< 12,500 yd3)
Chipping and Grinding Facilities
(200 tpd < x < 500 tpd)
Composting Facilities (all)(e.g. biosolids, food material, digestate, mixed solid waste)
Green Material Composting Facilities
(> 12,500 yd3)
Vegetative Food Material Composting Facilities
(> 12,500 yd3)
Chipping and Grinding Facilities
(> 500 tpd)
Physical Contaminants in Compost
Current regulations do not contain a limit for physical contaminants in compost.
Physical Contaminants in Compost
Proposed regulation would require compost to contain no more than 0.1% by weight of physical contaminants
Land Application of Compostable Materials
Application to agricultural land is beneficial use if it meets CA Department of Food & Agriculture requirements.
Need better method to determine when land application is considered disposal.
Proposed Land Application Regulation
Any land, including Agricultural land Meet 0.1% physical contaminant limit, metals concentrations and pathogen density requirements
One application per year, not to exceed 12” total accumulated depth
- EA, in consultation with Regional Water Quality Control Board, can approve alternative depth & application frequency
Agricultural land only Meet 0.1% physical contaminant limit
Finding from CDFA that the use is agronomically beneficial