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Greg Kester Biosolids Program Manager gkester@casaweb

Greg Kester Biosolids Program Manager gkester@casaweb.org. SCAP Biosolids Committee. Ordinance Update. Solano County – BOS meeting Tues Very reasonable overall Still allow Class B application but must divert portion of production to Class A, energy, or ADC

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Greg Kester Biosolids Program Manager gkester@casaweb

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  1. Greg Kester Biosolids Program Manager gkester@casaweb.org SCAP Biosolids Committee

  2. Ordinance Update • Solano County – BOS meeting Tues • Very reasonable overall • Still allow Class B application but must divert portion of production to Class A, energy, or ADC • San Luis Obispo – Considering if EIR is necessary and if funds available • Unreasonable – limits application • Only EQ; Permit if >5CY

  3. Ordinance Update Kern Litigation – PI issued June 2011 County is appealing the PI County recently filed reply brief Now wait for Court to set time for oral arguments – could be several months

  4. CalRecycle Jurisdictional Issue • Organic waste into AD is increasing • Supported by CEC, CPUC, SWRCB, and CalRecycle • Renewable energy mandates • 33% by 2020 • 75% Recycling goal by 2020

  5. FOG/FOOD WASTE IN AD Sept ‘09 CalRecycle publishes guidance document on AD Defines compost by temperature rather than process So AD at >122 deg F is compost and subject to composting regs! AD at < 122 MAY need TS/PF Permit

  6. AD AND METHANE USE IN CA TS/PF permit would be at discretion of Local Enforcement Agency (LEA) CASA has argued that POTWs are already regulated for this under water and air permits Patchquilt regulatory landscape creates unneccesary disincentive

  7. ISSUES WITH TS/PF PERMIT Oversteps legal authority of CalRecycle No permitting tier remotely resembles AD CEQA process lengthy and expensive Neighbor to SW facility plus POTW

  8. FOG/Food Waste in Digesters Worked closely with CalRecycle to understand what problem is that they perceive need to solve Numerous meetings and letters sent Past/current Directors sympathetic Have agreed to undergo rulemaking but will be lengthy

  9. FOG/Food Waste in Digesters Worked with SWRCB on notification template and permit language Executive Director Howard sent letter on Dec 6 Met with Director Mortensen 12/20 Objective is blanket exemption

  10. FOG/Food Waste in Digesters CalRecycle currently working on AD regulations Have had numerous meetings with them and SWRCB Working on exclusion language.. Still need short term solution!

  11. CDFA Rendering Rules Proposed regs in July 2010 Could have considered POTWs as renderers if accept FOG CASA provided written & verbal comments Modified regs in Feb 2011 provided exemption for POTWs

  12. CDFA Rendering Rules But revised proposal in September 2011 had removed the exemption CASA again provided comment Workshop held Oct 27 Broad support for exemption from all sectors Exemption has now been reinserted!

  13. EPA Report on AD and Gas Use Based on CWNS and thus flawed data – In revision 2007 estimated only 19% use CASA reviewed 2010 draft w/NACWA Drastically undercounted AD & methane use in CA – Still published!!

  14. Response to WEF RFP National effort to quantify AD and methane use Responded along with Regional Biosolids Assn’s; NACWA; BioCycle, consultants; others Will provide much needed information on renewable energy

  15. CalRecycle 75% Recycle Plan AB 341 set Goal to Recycle 75% of solid waste in state by 2020 CalRecycle issued preliminary plan for “discussion purposes” to meet goal Calls for end of diversion credit for ADC Calls for ban on organics in landfills

  16. CalRecycle 75% Recycle Plan • CASA, LACSD, EBMUD, SFPUC , others provided comments • Must have alternative options available before banning anything • Infrastructure and markets need development • Philosophical disconnect on value of ADC

  17. USEPA OECA Plans to Disinvest Office of Enforcement and Compliance Assurance Released its National Program Plan for FY 13 Calls for complete disinvestment from Biosolids Will create petri dish for opposition Wrote letter for reconsideration to ADM Jackson – to no avail

  18. USEPA Mtg During DC Conf CASA members met with key officials from 9 different Offices Risk assessment continues along with research (w/WERF) on TOrCs Considering modifications to 503 but no timetable – would require input Fear for loss of expertise from retm’t

  19. Market Technology Summit Sponsored by EPA with DOE, others in DC in May Biogas from Anaerobic Digestion CASA invited to summit to identify markets for which Technology is needed Emission limit compliance is one market to advance

  20. UC Davis Groundwater Report Drs. Harter and Lund released report on sources and solutions of GW impacts Unfortunately blamed biosolids land application as a source – no monitoring but flawed assumptions SWRCB workshop May 23 to get public input on report and path fwd

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