california water board: compost statewide order dan noble association of compost producers ...
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California Water Board:Compost Statewide Order
Dan NobleAssociation of Compost Producers
www.healthsoil.org danwyldernoble@gmail.com
“We Build Healthy Soil”
Topics
• Water Board Compost Statewide Order
• Comments on the Statewide Order– What’s the Rationale?– Using Compost Benefits as BMP
• Next Steps
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
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
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.
Water Board Compost Order – Elements (cont’)
• E. DESIGN SPECIFICATION1. Tier 1: ≤12,500 cubic yards at a time.
• Assure any potential discharge will be contained• Assure no leachate to groundwater
2. 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
Water Board Compost Order – Elements (cont’)
• E. DESIGN SPECIFICATION3. 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)
Water Board Compost Order – Elements (cont’)
• F. MONITORING SPECIFICATION (MRP)1. Tier 1: Reporting, subject to “standard
monitoring provisions”
2. Tier 2: As with Tier 1, but adding detention pond monitoring, semi-annually.
3. Tier 3: As with Tier 1, plus:a. Leachate Monitoring, ongoing, & mitigate it, and
Either:
b. Groundwater monitoring or vadose zone monitoring, semi-annually.
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
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
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?
Questions?Comments?Discussion…
Dan Noble, Executive DirectorCell: (619) 992-8389
danwyldernoble@gmail.comwww.healthysoil.org
“We Build Healthy Soil”
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