Chapter 6: Monitoring, Recordkeeping & Compliance

1. Chapter 6: Monitoring, Recordkeeping & Compliance Kentucky Department of Environmental Protection Division of Compliance Assistance 300 Fair Oaks Lane • Frankfort, KY 40601 Phone: 502.564.0323 • 800.926.8111 • Fax: 502.564.9720 Email: envhelp@ky.gov • Website: dca.ky.gov

2. Chapter 6 Objectives • Understand the types of monitoring required for different types of compost materials. • Comprehend the recordkeeping requirements. • Explain the requirements for quarterly or annual reporting. • Learn to read the permit in order to maintain compliance.

3. Facilities that compost yard waste, manures, food processing wastes, etc., are required to have a solid waste composting permit. • Facilities that compost water or WWTS are required to have a special waste composting permit.

4. The regulations that govern both solid and special waste composting facilities specify that certain operational requirements be met. These include such items as: • Monitoring, Sampling and Analysis • Record Keeping • Reporting • EPS Compliance • Distribution of Finished Products

5. Monitoring, Sampling & Analysis Monitoring of the composting process aids in diagnosing potential problems and therefore increases the likelihood of producing a quality-finished compost.

6. Monitoring, Sampling & Analysis • Solid waste facilities do not require specific monitoring of temperature, aeration, etc. • Special waste facilitiesare required by regulation to perform monitoring and are stipulated in the regulations

7. Solid Waste Composting Facilities • The Division requires all solid waste composting facilities to submit a report on a quarterly or annual basis. • The following data about incoming material must be tracked: • Amount • Sources • Types *A representative sample of the compost must be analyzed at least once per year in accordance with 401 KAR 48:200, Section 3(5) or your permit.

8. Special Waste Composting Facilities Wastewater treatment solids (WWTS) composting requires monitoring to show the composted materials have met the process time and temperatures specified for a Process to Further Reduce Pathogens (401 KAR 45:100 Section 12).

9. Special Waste Composting Facilities To comply with the federal regulations, compost must be analyzed: • for nine pollutants, six of which are already required by state regulation • vector attraction reduction • pathogenic organisms Samples must be collected and analyzed at least twice per year, and up to twelve times per year depending on facility conditions.

10. Recordkeeping • Records need to be kept on processing activities relating to the disposed materials such as: • Types (and perhaps analysis) of material received • Dates of grinding and mixing operations • Dates for formation and turning of windrows • Daily temperatures of composting materials as designated by 401 KAR 45:100 and 401 KAR 48:200.

11. Recordkeeping • Documentation of all these items will assist in adapting operational procedures and help prevent the reoccurrence of any problems: • Amount and time the materials spent in the active compost process • Name and addresses of recipients of 20 cubic yards or more of compost • General daily weather observations • Problems such as odors, runoff and dust *records must be kept on-site for no less than 3 years.

12. Reporting Reporting of information stipulated by regulations and your permit shall be accomplished using the required forms which are available from the Division of Waste Management.

13. Reporting In addition to amount, type, and source of incoming materials, the report must include: • Sampling and Analysis • laboratory analyses from the lab • chain of custody documentation • Distribution Logs

14. EPS Compliance • As previously stated, all composting facilities—solid or special waste—are subject to the Environmental Performance Standards (EPS). • The EPS requirements that are most likely to lead to noncompliance at a composting facility include: - Odor - Surface Water - Dust - Fires - Vectors - Karst

15. Distribution of Final Products • It is important to develop a distribution strategy for the end product. • Kentucky regulations state that 75% of the finished product must be distributed or disposed of within one year of completion of curing(401 KAR 48:200 and 401 KAR 45:100). • Some communities give the compost to local residents as a method of distribution as well as a form of public relations for the composting project.

16. Ultimately, the monitoring, recordkeeping and compliance of your composting facility are determined by the regulations and your individual permit.

17. Chapter 6 Objectives • Understand the types of monitoring required for different types of compost materials. • Comprehend the recordkeeping requirements. • Explain the requirements for quarterly or annual reporting. • Learn to read the permit in order to maintain compliance.