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I NFORMAL S TAFF W ORKSHOPS Concepts for a Statewide Order for Composting Facilities

S TATE W ATER R ESOURCES C ONTROL B OARD D IVISION OF W ATER Q UALITY. I NFORMAL S TAFF W ORKSHOPS Concepts for a Statewide Order for Composting Facilities. August 31, 2011 Inland Empire Utilities Agency Chino, California. September 1, 2011 Joe Serna Jr./CalEPA Building

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I NFORMAL S TAFF W ORKSHOPS Concepts for a Statewide Order for Composting Facilities

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  1. STATE WATER RESOURCES CONTROL BOARD DIVISIONOF WATER QUALITY INFORMAL STAFF WORKSHOPS Concepts for a Statewide Order for Composting Facilities August 31, 2011 Inland Empire Utilities Agency Chino, California September 1, 2011 Joe Serna Jr./CalEPA Building Sacramento, California Conference Room 550 Roger Mitchell P.G., State Water Resources Control Board

  2. TOPICS TO COVER • Role of Water Boards • Water quality and composting facilities • Goals of a statewide order • Eligible wastes, prohibited wastes, exempt wastes • Water Quality Protection Measures (WQPMs) • Water Quality Protection Areas (WQPAs) • Waste types • WQPM Tiers • Other Requirements – and request for input • Processes for Enrollment • Fees – and request for input • Next Steps & Schedule

  3. WATER BOARD WATER QUALITY RESPONSIBILITY • Protect Water Quality from Discharges of Waste to Surface Waters and Groundwater • Permitting • Discharges that could affect surface water • Implement Federal National Pollutant Discharge Elimination System (NPDES) required by federal Clean Water Act and issue NPDES permit(s) from wastewater or stormwater • Note: Practice of agriculture exempt from NPDES permit, not composting • Discharges that could affect groundwater • Issue or waive waste discharge requirements (WDRs) • Enforcement • Various actions

  4. GROUNDWATER QUALITY: NITRATE AS INDICATOR OF HUMAN IMPACTS (http://geotrackerbeta.ecointeractive.com/)

  5. GROUNDWATER QUALITY: SALINITY AS INDICATOR OF HUMAN IMPACTS (http://geotrackerbeta.ecointeractive.com/)

  6. DISTRIBUTION OF COMPOSTING FACILITIES

  7. CONSTITUENTS OF CONCERN IN LEACHATE AND RUNOFF • Some of the constituents of concern (COCs) at composting facilities are: • Salt (Total Dissolved Solids, Electrical Conductivity) • Nutrients (Nitrates) • Pathogens (E. coli.) • Metals (Iron, Copper, Manganese, Nickel, Zinc, Aluminum, Arsenic)

  8. WATER BOARD WATER QUALITY RESPONSIBILITY • Protect Water Quality from Discharges of Waste to Surface Waters and Groundwater • Permitting • Discharges that could affect surface water • Implement the National Pollutant Discharge Elimination System (NPDES) required by federal Clean Water Act and issue NPDES permit(s) for wastewater or stormwater • Note: Practice of agriculture exempt from NPDES permit, not composting • Discharges that could affect groundwater • Issue or waive waste discharge requirements (WDRs) • Enforcement • Various actions

  9. PERMITTING: NPDES • Q: When is an NPDES permit NOT required? • A: ONLY if NO discharge to waters of the U.S. under any circumstances • Possible ways to not discharge to waters of the U.S. (i.e., no NPDES permit needed) • All potential sources of discharge are protected from precipitation (cover, etc.) • Site graded with potential sources of discharge fully bermed

  10. PERMITTING: WASTE DISCHARGE REQUIREMENTS (WDRs) • Porter-Cologne Water Quality Control Act • California Water Code (CWC) Division 7, section 13000 et. seq. • Dischargers of waste that could affect waters of the state • All surface water and groundwater are waters of the state • Definition of waste is very broad – could be anything that could affect water quality • Report of Waste Discharger (ROWD) • Required of anyone who discharges waste that could affect quality of waters of the state • Includes character, location, volume of discharge, etc.

  11. PERMITTING: WASTE DISCHARGE REQUIREMENTS (WDRs) • Waste Discharges to Land Subject to Requirements Specified in Title 27, Chapter 3, Code of California Regulations • Unless exempt as specified in Title 27 • Unless WDRs waived with conditions (CWC, §13269 et seq.) • Deemed to be in the public interest • Include monitoring and reporting on the waiver conditions • Renewal every 5-years including CEQA analysis, or replacement with WDRs • Consistent with regional water quality control plans (Basin Plans)

  12. PERMITTING: WASTE DISCHARGE REQUIREMENTS IMPLEMENTING TITLE 27 FOR COMPOSTING FACILITIES • Analysis of liquids sampled at composting facilities (from some feedstocks, additives, amendments, unfinished, and finished compost) indicated potential classification as “designated waste” under Title 27 • Title 27 required designated waste to be managed in a Class II waste management unit that: • Meets siting criteria • Contains waste as prescribed • Implements a groundwater monitoring program • Meets closure requirements as prescribed • Funds a financial assurance mechanism

  13. GOALS OF THE STATEWIDE ORDER • Protect water quality to the same extent as waste discharge of similar threat to water quality • Provide streamlined permitting process if facilities meet certain requirements • Waive WDRs with conditions for eligible waste types at composting facilities having the potential to threaten the quality and beneficial uses of the waters of the state • Allow for streamlined individual Waste Board orders where alternatives to prescriptive requirements are proposed • Apply to a broad array of composting facilities • Harmonize, as feasible, with both: • CalRecycle’s composting regulations in Title 14, and • CalRecycle’s waste diversion efforts

  14. GOALS OF THE STATEWIDE ORDER • Recognize the factors affecting water quality: • Waste types • Proximity to groundwater supply as defined by: • Water Quality Protection Areas (WQPAs): • Proximity to identified Hydrogeologically Vulnerable Areas (HVAs) • Proximity to groundwater supply wells for drinking water • Identify Water Quality Protection Measures (WQPMs) to reduce potential threat to water quality • Provide for tiered WQPMs based on waste type and facility location (within a WQPA) • Assess annual fees commensurate with regulatory effort

  15. Vegetative Waste Paper Waste Manure Food Waste Treated Biosolids Animal Carcasses Compostable Municipal Solid Waste Threat To Water Quality CONCEPTS OF STATEWIDE ORDER Waste Types Eligible Facilities Ineligible Facilities Exempt Wastes Prohibited Wastes Prohibited Wastes Eligible Wastes

  16. Medical Wastes Septage Hazardous Waste Petroleum Wastes Mammalian Tissue Ash w/ Heavy Metals Wood w/ Preservatives Sludges CONCEPTS OF STATEWIDE ORDER Waste Types Ineligible Facilities Prohibited Wastes

  17. CONCEPTS OF STATEWIDE ORDER • Factors Affecting Water Quality • Facility location and waste type directly affect water quality and therefore the WQPMs needed • More protective WQPMs are required at facilities with certain wastes or those located in WQPAs • WQPAs would be defined as: • Hydrogeologically Vulnerable Areas • Drinking water supply wells within 300 feet

  18. CONCEPTS OF STATEWIDE ORDER: WQPAs Hydrogeologically Vulnerable Areas (HVAs) • More vulnerable to groundwater contamination because no natural protection to deeper groundwater supplies: • No low-permeability deposits (i.e., confining layers) • Fractured bedrock http://www.swrcb.ca.gov/gama/docs/hva_update.pdf HVAs are where published studies show geologic conditions are more likely to allow surface contaminants to move to groundwater through percolation. For example: areas without an aquitard. Vulnerable areas not mapped, due to their extensiveness, are fractured rock where contaminants can move directly to water.

  19. CONCEPTS OF STATEWIDE ORDER • Proximity to Drinking Water Supply Wells • Areas beyond mapped HVAs may have shallow groundwater used by domestic water supply wells for drinking water • Well structures not meeting siting and construction standards (DWR, bulletins 74-80 and 74-91) may create a conduit for contamination • Facilities within 300 feet of a drinking water supply well would be required to use more protective WQPMs

  20. CONCEPTS OF STATEWIDE ORDER: WQPAs Proximity to Drinking Water Supply Wells Scenario “Z” No measures in place, so greater threat Composting Facility Water Supply Wells Unconfined Groundwater Confined Groundwater 20

  21. CONCEPTS OF STATEWIDE ORDER: WQPAs Proximity to Drinking Water Supply Wells Scenario “M” Measures in place, but setback exceeded, so still a threat Composting Facility Water Supply Wells Unconfined Groundwater 21 Confined Groundwater 21

  22. CONCEPTS OF STATEWIDE ORDER Proximity to Drinking Water Supply Wells Scenario “A” Measures in place, and setback requirement meet, so lower threat Composting Facility Water Supply Wells Unconfined Groundwater 22 Confined Groundwater 22

  23. CONCEPTS OF STATEWIDER ORDER: WHICH WQPMs TIER? Water Quality Protection Measures (WQPMs) Animal Carcasses/ MSW Manure Food Waste/ Biosolids Vegetative Waste/ Paper Waste The waste type is: No No Yes Yes Yes Yes Is the facility located within a hydrogeologically vulnerable area, or within 300 feet of a drinking water supply well Waste Types Water Quality Protection Areas Tiered Water Quality Protection Measures Tier II Tier I Tier III Yes Yes No Animal Carcasses/ MSW Vegetative Waste/ Paper Waste The waste type is: No Manure/ Food Waste/ Biosolids

  24. Animal Carcasses/ MSW Manure/ Food Waste/ Biosolids Vegetative Waste/ Paper Waste The waste type is: No No Yes Yes Yes Yes Is the facility located within a hydrogeologically vulnerable area, or within 300 feet of a drinking water supply well Yes Yes No Animal Carcasses/ MSW Vegetative Waste/ Paper Waste The waste type is: No Manure/ Food Waste/ Biosolids CONCEPTS OF STATEWIDE ORDER: WHICH WQPMs TIER? Water Quality Protection Measures (WQPMs) Tier II Tier I Tier III

  25. CONCEPTS FOR STATEWIDE ORDER: TIER REQUIREMENTS Water Quality Protection Measures (WQPMs) - Pads Tier I Tier III Tier II Hydraulic Conductivity < or = 1 x 10-5 cm/s < or = 1 x 10-7 cm/s < or = 1 x 10-6 cm/s Grade > or = 1/2% > or = 1/2% > or = 1/2% Thickness Minimum 2 feet Minimum 2 feet Minimum 1 foot Narrative Impede percolation Maintain positive drainage Equipment usage does not result in rutting or ponding

  26. Grade > or = 1/2% > or = 1/2% > or = 1/2% Thickness Minimum 2 feet Minimum 2 feet Minimum 1 foot Capable of containing 25 year/ 24 hour storm event Impede percolation Make consideration for wind-driven waves and pump-out disposal Maintain positive drainage Equipment usage does not result in rutting or ponding CONCEPTS FOR STATEWIDE ORDER: TIER REQUIREMENTS Water Quality Protection Measures (WQPMs) - Ponds Tier I Tier III Tier II Hydraulic Conductivity < or = 1 x 10-7 cm/s < or = 1 x 10-5 cm/s < or = 1 x 10-6 cm/s < or = 1 x 10-7 cm/s < or = 1 x 10-7 cm/s < or = 1 x 10-6 cm/s Monitoring and Reporting Program (Ponds Only) Narrative

  27. CONCEPTS OF STATEWIDE ORDER: TIER REQUIREMENTS Water Quality Protection Measures (WQPMs) – Hydraulic Conductivity Tier III Tier I Tier II 1 x 10-5 cm/s ~ 10 ft/yr 1 x 10-6 cm/s 1 x 10-7 cm/s ~ 1 ft/yr ~ 0.1 ft/yr

  28. Distance to Groundwater Wells Distance to Surface Water Precipitation Soil Type Site Slope Depth to Groundwater FACTORS INFLUENCING POTENTIAL WATER QUALITY IMPACT: SITE CONDITIONS Compost Facility Background Water Quality Groundwater Groundwater

  29. FACTORS INFLUENCING POTENTIAL WATER QUALITY IMPACTS: WATER QUALITY PROTECTION MEASURES Scenario “A” Measures in place, so lower threat Composting Facility Groundwater 29

  30. FACTORS INFLUENCING POTENTIAL WATER QUALITY IMPACTS: WATER QUALITY PROTECTION MEASURES Scenario “Z” No measures in place, so greater threat Composting Facility Groundwater 30

  31. CONCEPTS OF STATEWIDE ORDER: CHANGE TIER • Additional WQPMs – Not Yet Identified • Statewide order may identify other WQPMs that would allow a lower Tier pad or pond liner requirements • Demonstrated equivalent ability to protect groundwater • Implementation may allow a facility to meet lower tier requirements • Proposals have included: • Concrete lined drainage ditches to avoid percolation • Modify and coordinate watering with storm events to avoid percolation • Seasonal change pile shape to control evaporation and avoid percolation • Implementation of a groundwater monitoring and reporting program (one-year) to demonstrate whether waste constituents are percolating

  32. CONCEPTS OF STATEWIDE ORDER: CLOSURE • Notice of Intent (NOI) to be submitted to the Water Boards and CalRecycle, 30-days prior to beginning closure activities • Composting facilities will be clean-closed • Clean-closure for pads and ponds constitutes • Removal of all solid and liquid wastes • Dismantle and removal of all containment features • Removal of all contaminated soils • If clean-closure is demonstrated to be infeasible, closure requirements specified in CCR Title 27 will be met • Composting facilities must also comply with CCR Title 14, section 17870

  33. Report Due Reporting Period October 31 April 1 – June 30 July 1 – September 30 April 30 October 1 – December 31 January 1 – March 31 CONCEPTS OF STATEWIDE ORDER: MONITORING • Monitoring and Reporting on conditions of statewide order required pursuant to Water Code, section 13269(a)(2) • Monitoring and Reporting Program (MRP) includes: • Quarterly inspection of facility conditions and monitoring activities • All Wastewater Ponds - Semi-annual monitoring of wastewater for constituents of concern • Semi-annual facility report on all observations and monitoring activities (including field and laboratory tests results) • MRP reporting schedule:

  34. CONCEPTS OF STATEWIDE ORDER: ENROLLMENT PROCESS • Submit a Report of Waste Discharge (ROWD)/ • Joint Composting Document (JCD) with a filing fee • (1st year annual fee) • The ROWD/JCD: • Describes the operation • Identifies the proposed Tier placement (with justification) • Identifies how the discharge will fully meet the requirements of that Tier • Water Board will perform a streamlined review of the ROWD • Dischargers may also be required to obtain an NPDES permit

  35. CONCEPTS OF STATEWIDE ORDER: ENROLLMENT PROCESS Individual Waiver or WDRs Statewide Order Discharger: Submits a ROWD/JCD with engineered alternatives and filing fee Discharger: Submits a ROWD/JCD and filing fee Water Board: Reviews the ROWD/JCD, and issues statement of coverage under statewide order Water Board: Reviews the ROWD/JCD, and issues individual waiver based on statewide order or WDRs Discharger: Implements MRP and pays annual fee Discharger: Implements MRP and pays annual fee Water Board: Reviews the MRP and inspects the facility, invoices annually for fee, and re-issues statewide order every 5 years (including CEQA analysis) Water Board: Reviews the MRP and inspects the facility, invoices annually for fee, and re-issues individual waiver every 5 years (including CEQA analysis) or reviews WDR every 10-15 years

  36. CONCEPTS OF STATEWIDE ORDER: ENROLLMENT PROCESS • Existing Facilities • Allowed to temporarily continue current operations. • Required to submit a ROWD/JCD within 90 days from adoption of the statewide order - if they are: • Facilities with 12,500 cubic yards or more of materials on site at any time; or • Facilities composting food waste, biosolids, animal carcasses, municipal solid waste, or any other specified material under the statewide order. • Required to submit a RWOD/JCD within 180 days from adoption of the statewide order – if they are: • Facilities with less than 12,500 cubic yards of materials on site at any time; or • Facilities composting vegetative waste, paper waste, or manure.

  37. STATEWIDE ORDER CONCEPTS: ANNUAL FEES • Any person discharging or proposing to discharge waste is required to submit a ROWD/JCD and an annual fee. • Options for fees: • Use current fee schedule (CCR Title 23, section 2200) • Fees schedule based on assessment of threat to water quality and complexity posed by the discharge • Most facilities would fall into the lower categories of threat to water quality and complexity with median fee about $3500. • Stakeholders may propose an alternative schedule • Regardless of option, the total fees targeted for collection would remain the same – estimated $500,000 annually.

  38. INTERAGENCY COORDINATION • Joint workshop August 2009 on concepts of statewide order • Water Boards/CalRecycle interagency meetings • Water Boards’ internal workgroup • Stakeholder input • Informal workshops • Stakeholder workgroup (September 28th and October 27th) • Formal public comment • State Water Board consideration of draft statewide order and final CEQA document.

  39. Roger Mitchell, P.G. Engineering Geologist State Water Resources Control Board (858)467-2724 Composting@waterboards.ca.gov State Water Resources Control Board Statewide Order for Composting Facilities http://www.waterboards.ca.gov/water_issues/programs/compost/index.shtml

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