I NFORMAL S TAFF W ORKSHOPS Concepts for a Statewide Order for Composting Facilities August 31, 2011...
-
Upload
daniella-reeves -
Category
Documents
-
view
213 -
download
0
Transcript of I NFORMAL S TAFF W ORKSHOPS Concepts for a Statewide Order for Composting Facilities August 31, 2011...
INFORMAL STAFF WORKSHOPS
Concepts for a Statewide Order for Composting Facilities
August 31, 2011Inland Empire Utilities Agency
Chino, California
STATE WATER RESOURCES CONTROL BOARD
DIVISION OF WATER QUALITY
September 1, 2011Joe Serna Jr./CalEPA Building
Sacramento, CaliforniaConference Room 550
Roger Mitchell P.G.,State Water Resources Control Board
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
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
GROUNDWATER QUALITY: NITRATE AS INDICATOR OF HUMAN IMPACTS
(http://geotrackerbeta.ecointeractive.com/)
GROUNDWATER QUALITY: SALINITY AS INDICATOR OF HUMAN IMPACTS
(http://geotrackerbeta.ecointeractive.com/)
DISTRIBUTION OF COMPOSTING FACILITIES
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)
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
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
PERMITTING: WASTE DISCHARGE REQUIREMENTS (WDRs)
Porter-Cologne Water Quality Control ActCalifornia 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.
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)
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
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
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
CONCEPTS OF STATEWIDE ORDER
Waste Types
Exempt Wastes
Prohibited Wastes
Eligible Wastes
Ineligible FacilitiesEligible Facilities
Prohibited Wastes
Compostable Municipal Solid Waste
Animal Carcasses
Vegetative Waste
Paper Waste
Food Waste
Manure
Treated Biosolids
Threat To Water Quality
CONCEPTS OF STATEWIDE ORDER
Waste Types
Ineligible Facilities
Prohibited Wastes
Hazardous Waste
Ash w/ Heavy Metals
Wood w/ Preservatives
Petroleum Wastes
Medical Wastes
Mammalian Tissue
Septage
Sludges
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
CONCEPTS OF STATEWIDE ORDER: WQPAs
Hydrogeologically Vulnerable Areas (HVAs)
http://www.swrcb.ca.gov/gama/docs/hva_update.pdfHVAs 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.
• More vulnerable to groundwater contamination because no natural protection to deeper groundwater supplies:
• No low-permeability deposits (i.e., confining layers)
• Fractured bedrock
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
Scenario “Z”No measures in place, so greater threat
20
Composting Facility
20
Proximity to Drinking Water Supply Wells
Confined Groundwater
Unconfined Groundwater
Water Supply Wells
CONCEPTS OF STATEWIDE ORDER: WQPAs
Scenario “M”Measures in place, but setback exceeded, so still a threat
21
Composting Facility
21
CONCEPTS OF STATEWIDE ORDER: WQPAsProximity to Drinking Water Supply Wells
Water Supply Wells
Confined Groundwater
Unconfined Groundwater
Scenario “A”Measures in place, and setback requirement meet, so lower threat
22
Composting Facility
22
CONCEPTS OF STATEWIDE ORDERProximity to Drinking Water Supply Wells
Water Supply Wells
Confined Groundwater
Unconfined Groundwater
Water QualityProtection Areas
Water QualityProtection Areas Tiered Water Quality Protection Measures
Tiered Water Quality Protection Measures
Is the facility located within a
hydrogeologically vulnerable area,
orwithin 300 feet of a drinking water
supply well
Is the facility located within a
hydrogeologically vulnerable area,
orwithin 300 feet of a drinking water
supply well
WasteTypes
WasteTypes
No
No
No
Ye
s
Ye
s
Ye
s
ManureFood Waste/
Biosolids
ManureFood Waste/
BiosolidsAnimal Carcasses/
MSW
Animal Carcasses/MSW
Animal Carcasses/MSW
Animal Carcasses/MSWThe waste
type is:
The waste type is:
Vegetative Waste/Paper Waste
Vegetative Waste/Paper Waste
Manure/Food Waste/
Biosolids
Manure/Food Waste/
Biosolids
CONCEPTS OF STATEWIDER ORDER: WHICH WQPMs TIER?
Water Quality Protection Measures (WQPMs)
Vegetative Waste/Paper Waste
Vegetative Waste/Paper Waste
The waste type is:
The waste type is:
Ye
s
Ye
s
No
Ye
s
Tier IIITier III
Tier IITier II
Tier ITier I
CONCEPTS OF STATEWIDE ORDER: WHICH WQPMs TIER?
Water Quality Protection Measures (WQPMs)
Is the facility located within a
hydrogeologically vulnerable area,
orwithin 300 feet of a drinking water
supply well
Is the facility located within a
hydrogeologically vulnerable area,
orwithin 300 feet of a drinking water
supply well
No
No
No
Ye
s
Ye
s
Ye
s
Manure/Food Waste/
Biosolids
Manure/Food Waste/
BiosolidsAnimal Carcasses/
MSW
Animal Carcasses/MSW
Animal Carcasses/MSW
Animal Carcasses/MSWThe waste
type is:
The waste type is:
Vegetative Waste/Paper Waste
Vegetative Waste/Paper Waste
Manure/Food Waste/
Biosolids
Manure/Food Waste/
Biosolids
Vegetative Waste/Paper Waste
Vegetative Waste/Paper Waste
The waste type is:
The waste type is:
Ye
s
Ye
s
No
Ye
s
Tier IIITier III
Tier IITier II
Tier ITier I
CONCEPTS FOR STATEWIDE ORDER: TIER REQUIREMENTS
Water Quality Protection Measures (WQPMs) - Pads
Tier IIITier III
Tier IITier II
Tier ITier I
Hydraulic ConductivityHydraulic Conductivity
< or = 1 x 10-5 cm/s< or = 1 x 10-5 cm/s
< or = 1 x 10-7 cm/s< or = 1 x 10-7 cm/s
< or = 1 x 10-6 cm/s< or = 1 x 10-6 cm/s
GradeGrade
ThicknessThickness
Minimum 1 footMinimum 1 foot
> or = 1/2%> or = 1/2%
> or = 1/2%> or = 1/2%
> or = 1/2%> or = 1/2%
Minimum 2 feetMinimum 2 feet
Minimum 2 feetMinimum 2 feet
Narrative Narrative
Maintain positive drainageMaintain positive drainage
Equipment usage does not result in rutting or pondingEquipment usage does not result in rutting or ponding
Impede percolationImpede percolation
Maintain positive drainageMaintain positive drainage
Equipment usage does not result in rutting or pondingEquipment usage does not result in rutting or ponding
Impede percolationImpede percolation
Capable of containing 25 year/ 24 hour storm eventCapable of containing 25 year/ 24 hour storm event
Make consideration for wind-driven waves and pump-out disposalMake consideration for wind-driven waves and pump-out disposal
Monitoring and Reporting Program (Ponds Only)Monitoring and Reporting Program (Ponds Only)
Water Quality Protection Measures (WQPMs) - Ponds
Tier IIITier III
Tier IITier II
Tier ITier I
Hydraulic ConductivityHydraulic Conductivity
< or = 1 x 10-5 cm/s< or = 1 x 10-5 cm/s
< or = 1 x 10-7 cm/s< or = 1 x 10-7 cm/s
< or = 1 x 10-6 cm/s< or = 1 x 10-6 cm/s
GradeGrade
> or = 1/2%> or = 1/2%
> or = 1/2%> or = 1/2%
> or = 1/2%> or = 1/2%
ThicknessThickness
Minimum 1 footMinimum 1 foot
Minimum 2 feetMinimum 2 feet
Minimum 2 feetMinimum 2 feet
< or = 1 x 10-6 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 10-7 cm/s< or = 1 x 10-7 cm/s
Narrative Narrative
CONCEPTS FOR STATEWIDE ORDER: TIER REQUIREMENTS
CONCEPTS OF STATEWIDE ORDER: TIER REQUIREMENTS
1 x 10-5 cm/s 1 x 10-6 cm/s 1 x 10-7 cm/s~ 10 ft/yr ~ 1 ft/yr ~ 0.1 ft/yr
Water Quality Protection Measures (WQPMs) – Hydraulic Conductivity
Tier IIITier III
Tier IITier II
Tier ITier I
FACTORS INFLUENCING POTENTIAL WATER QUALITY IMPACT: SITE CONDITIONS
Soil Type
Background Water Quality
Precipitation
Depth to Groundwater
Distance to Surface Water
Distance to Groundwater Wells
Compost Facility
Site Slope
Groundwater
Groundwater
FACTORS INFLUENCING POTENTIAL WATER QUALITY IMPACTS: WATER QUALITY PROTECTION MEASURES
Composting Facility
Groundwater29
Scenario “A”Measures in place, so lower threat
30 Groundwater
Composting Facility
30
FACTORS INFLUENCING POTENTIAL WATER QUALITY IMPACTS: WATER QUALITY PROTECTION MEASURES
Scenario “Z”No measures in place, so greater threat
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
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
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:
Reporting PeriodReporting Period
October 1 – December 31October 1 – December 31
January 1 – March 31January 1 – March 31 April 30April 30
Report DueReport Due
April 1 – June 30April 1 – June 30
July 1 – September 30July 1 – September 30 October 31October 31
• 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
CONCEPTS OF STATEWIDE ORDER: ENROLLMENT PROCESS
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 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
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
Discharger: Implements MRP and pays annual fee
Discharger: Implements MRP and pays annual fee
Discharger: Implements MRP and pays annual fee
Discharger: Implements MRP and pays annual fee
Water Board: Reviews the ROWD/JCD, and issues statement of coverage under statewide order
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
Water Board: Reviews the ROWD/JCD, and issues individual waiver based on statewide order or WDRs
Discharger: Submits a ROWD/JCD and filing fee
Discharger: Submits a ROWD/JCD and filing fee
Discharger: Submits a ROWD/JCD with engineered alternatives and filing fee
Discharger: Submits a ROWD/JCD with engineered alternatives and filing fee
CONCEPTS OF STATEWIDE ORDER: ENROLLMENT PROCESS
Statewide OrderStatewide Order Individual Waiver or WDRsIndividual Waiver or WDRs
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.
CONCEPTS OF STATEWIDE ORDER: ENROLLMENT PROCESS
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.
• 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.
INTERAGENCY COORDINATION
Roger Mitchell, P.G.Engineering Geologist
State Water Resources Control Board(858)467-2724
State Water Resources Control BoardStatewide Order for Composting Facilities
http://www.waterboards.ca.gov/water_issues/programs/compost/index.shtml