California Water Board: Compost Statewide Order

1. “We Build Healthy Soil” California Water Board:Compost Statewide Order Dan Noble Association of Compost Producers www.healthsoil.org danwyldernoble@gmail.com

2. Topics • Water Board Compost Statewide Order • Comments on the Statewide Order • What’s the Rationale? • Using Compost Benefits as BMP • Next Steps

3. Water Board Compost Statewide Order - Timeline • Process Began Sept. 2011 with Draft Order – “Discussion Paper” • Series of Monthly Workshops – Oct. 2011 through January 2012 • Draft #2 – Actual Wording May 15, 2012 • Last Workshop – May 22 & 23, 2012 • Next Workshops – Aug 27 & 28, 2012 • Comments Due – Sept. 12, 2012

4. Water Board Compost Order - Elements • Only Applies to Groundwater; Stormwater Permits are still managed via NPDES Permits • A. Findings • 3.a.Feedstocks: • i. Agricultural materials; • ii. Anaerobic digestate; • iii. Biosolids; • iv. Food materials; • v. Green materials; • vi. Manure; • vii. Paper materials; and/or • viii. Vegetative food materials

5. Water Board Compost Order – Elements (cont’) • 3.b. Exempt Composting Activities: • i. Agricultural Composting; • ii. Chipping and Grinding Facilities and Operations; • iii. Composting conducted at a Publicly Owned Treatment Works (POTWs), contingent on composting activities are covered by an existing WDR or NPDES permit; • iv. Lot Clearing for Fire Protection; • v. Non-Commercial Composting; and • vi. Within-Vessel and Fully-Enclosed Composting.

6. Water Board Compost Order – Elements (cont’) • E. DESIGN SPECIFICATION • Tier 1: ≤12,500 cubic yards at a time. • Assure any potential discharge will be contained • Assure no leachate to groundwater • Tier 2: >12,500 cubic yards (prescriptive) • Working surfaces, conveyance and detention ponds 1x10-6 cm/s or less • Detention Ponds hold 25-year, 24-hour storm event

7. Water Board Compost Order – Elements (cont’) • E. DESIGN SPECIFICATION 3. Tier 3: >12,500 cubic yards (custom) • Certify no formation of leachate during normal operations • Proper containment during heavy rain (25-year, 24-hour storm event)

8. Water Board Compost Order – Elements (cont’) • F. MONITORING SPECIFICATION (MRP) • Tier 1: Reporting, subject to “standard monitoring provisions” • Tier 2: As with Tier 1, but adding detention pond monitoring, semi-annually. • Tier 3: As with Tier 1, plus: • Leachate Monitoring, ongoing, & mitigate it, and Either: b. Groundwater monitoring or vadose zone monitoring, semi-annually.

9. Comments on the Statewide Order • Association of Compost Producers (ACP) • Participated in all workshops • Interacted with Roger Mitchell (lead staff) periodically throughout • Submitted verbal and written comments: • Attached Letter sent to Mr. Mitchell, 7/23/12 • Sent directly to Water Board, 7/30/12

10. Comments on the Statewide Order - Elements • Process Specific Concerns: • The Case for this Statewide Order Has Not Been Made • Small Compost Facilities Will Be Hurt the Most • Extended Public Process Still Needed • Order Specific Concerns: • Existing WDRs should be exempt from this new order • Chip & Grind portion of Compost Management Unit, should be exempt from this order • Landfill WDRs exempt for composters on landfills (as above) • Liquid food waste: include in food waste definition • Create consistent compost definition with CalRecycle

11. Next Steps • Attend Aug. 2012 Workshops: • SACRAMENTO • Monday, August 27, 2012, 10:00 a.m. – 2:00 p.m. • State Water Resources Control Board, Sierra Hearing Room (2nd Floor) • 1001 I Street, Sacramento, CA 95814 • RIVERSIDE • Tuesday, August 28, 2012, 10:00 a.m. – 2:00 p.m. • Santa Ana Regional Water Board, Highgrove Room (2nd Floor), Suite 200 • 3737 Main Street, Riverside, CA 92501-3348 • Submit verbal and written comments • Seek Injunctive or Legislative Relief?

12. “We Build Healthy Soil” Questions?Comments?Discussion… Dan Noble, Executive Director Cell:  (619) 992-8389danwyldernoble@gmail.com www.healthysoil.org