California Department of Resources Recycling and Recovery (CalRecycle) 

LEA Advisory #13—January 23, 1994

Wood Waste Landfills

To All Local Enforcement Agencies:

This advisory provides updated guidance for regulation of nonhazardous wood waste landfills and replaces LEA Advisory No. 13 issued May 17, 1994. Please note that this is interim guidance prior to adoption of specific regulations for wood waste landfills.

What is a Wood Waste Landfill?

Pursuant to Section 43020.1 of the Public Resources Code (PRC), "Nonhazardous wood waste landfill" means a landfill that exclusively accepts untreated bark, sawdust, shavings, and chips that are the byproducts of primary wood product manufacturing and processes that are not used as raw material and that are destined for disposal. Examples of disposal sites which accept primarily solid waste from primarily wood product manufacturing but do not meet the definition of wood waste landfills include landfills with most categories of pulp mill wastes, codisposed municipal solid waste, significant levels of residual treatment or other chemicals, or ash from contaminated fuel sources.

Solid wastes at a wood waste landfill include bark, scrap lumber, sawdust, and mixed soil and rock generated as waste material from log decks and milling facilities. Wood waste landfills may also accept minor amounts of inert construction and demolition wastes. Ash generated from the burning of wood wastes from on-site, wood-fired boilers, kiln dryers, and tepee burners is also a typical waste component in a wood waste landfill. Larger quantities of ash may be contained at wood waste landfills associated with large scale biomass combustion facilities.

The following table includes current California Integrated Waste Management Board (CIWMB) record of disposal sites which are wood waste landfills:

Site # Site Name Status Comments
(14 CCR 18083)
04-AA-0009 Louisiana Pacific
Oroville
Active Wood ash monofill active
12-AA-0029 Simpson Korbel Active  
12-AA-0076 Pacific Lumber
Hely Creek/Carlotta
Active  
12-AA-0086 Eel River (Mozzeti)
Sawmill #2
Active Closed-1990 reactivated for ash 1995
12-AA-0091 Pacific Lumber Tank
Gulch
Active  
23-AA-0005 Georgia Pacific
Fort Bragg
Active  
23-AA-0007 Harwood Active  
47-AA-0046 Roseburg Weed Active  
52-AA-0002 Louisiana Pacific
Red Bluff
Inactive  
03-AA-0002 Georgia Pacific Martell Closed Clean closure in progress
08-AA-0003 Simonson Site 2 Closed  
08-AA-0004 Simpson Klamath Inactive Last received wastes in 1989
08-AA-0005 Simpson Arrow Mills Closed Regional Board approved closure-1977
08-AA-0017 Arcata Redwood
Smith River #3
Closed Reg. Board WDRs rescinded by 95-48
09-CR-0018 Georgia Pacific
Park Creek
Closed  
11-AA-0003 Louisiana Pacific
Elk Creek
Closed  
12-AA-0013 Pacific Lumber Scotia Closed Closure construction completed- 1992
12-AA-0017 Louisiana Pacific Samoa
Landfill
Inactive Ash monofill remediation under STIP
12-AA-0020 Simpson Orick Woodwaste Closed  
12-AA-0021 Trend Lumber Closed Ceased accepting waste in 1979
12-AA-0024 Twin Harbors Woodwaste Site never used Regional Board WDRs rescinded 6/85
12-AA-0026 Louisiana Pacific
Alder Point
Closed Ceased accepting waste in 1980
12-AA-0031 Allen Maki Closed Ceased accepting waste in 1988
12-AA-0032 McNamara & Peete Closed Ceased accepting waste in 1984
12-AA-0034 Eel River Sawmill #1 Closed Ceased accepting waste in 1979
12-AA-0056 Renner Closed Ceased accepting waste in 1985
12-AA-0085 Simpson Fairhaven Closed Approved final closure 1993
23-CR-0017 Louisiana Pacific
Willits #1
Closed  
23-CR-0018 Louisiana Pacific
Willits #2
Closed  
23-CR-0033 Philo Lumber Company Site never used Proposed landfill at sawmill never used
23-AA-0010 Louisiana Pacific Big Closed Ceased accepting waste in River 1979
23-AA-0011 Louisiana Pacific
Caspar
Closed Clean closure/mining project in progress
23-AA-0012 Louisiana Pacific
Covello Site B
Closed  
23-AA-0013 Louisiana Pacific York
Ranch #3
Closed Ceased accepting waste in 1993
23-AA-0014 Louisiana Pacific
Willits #3, #4
Closed  
23-AA-0015 Louisiana Pacific
Calpella
Closed Ceased accepting waste in 1986
23-AA-0024 Louisiana Pacific
York Ranch #4
Closed Ceased accepting waste before 1984
23-AA-0026 Louisiana Pacific
Covelo #2, #3
Closed Ceased accepting waste 1978(2) 1983(3)
32-AA-0020 Louisiana Pacific
Cresent Mills
Closed Clean closure/mining project completed
32-AA-0021 Collins Pine #1,2,3 Closed Clean closure/mining project in progress
45-AA-0023 Sierra Pacific
Aubrey Ridge
Closed Final in-place closure complete 1993
47-CR-0014 P& M Cedar (McCloud Mill) Closed Sawmill cleanup in progress
47-AA-0025 Roseburg Lumber(City of Mt. Shasta) Closed Clean closure/mining in progress-AB2136 funded project
49-AA-0011 Louisiana Pacific
Cloverdale #2
Closed Closure construction completed 1995
49-AA-0244 Louisiana Pacific
Cloverdale #1
Closed Closure construction completed 1978
52-AA-0009   Sierra Pacific Lazarbil Closed

What Closure Requirements Apply to Wood Waste Landfills?

Wood waste landfills are excluded from the definition of solid waste landfill pursuant to PRC Section 40195 and 14 CCR Section 18251(a)(8) and are therefore exempt from the closure requirements of 14 CCR, Division 7, Chapter 5, Articles 3.4 and 3.5. Wood waste landfills are also not subject to the closure and postclosure minimum standards of 14 CCR, Division 7, Chapter 3, Article 7.8. Although not subject to 14 CCR closure requirements, wood waste landfills are subject to 23 CCR Chapter 15 closure requirements as implemented by Regional Water Boards.

It is important to note when a wood waste landfill closure exemption is not appropriate or when a previously issued exemption warrants reconsideration. Such conditions may include acceptance of pulp mill wastes, contaminated soils or residual wastes, and codisposed wastes such as household wastes or hazardous materials. Other conditions may include acceptance of ash from biomass combustion facilities using contaminated fuel sources or fuel sources other than from primary wood product manufacturing. LEAs should monitor wood waste landfills to ensure that unauthorized wastes are not accepted for disposal.

The above table lists wood waste landfills which are excluded from 14 CCR closure requirements. LEAs should contact CIWMB staff if sites warranting inclusion in the table are not listed, or if a listed site should be reevaluated.

What Permitting Requirements Apply to Wood Waste Landfills?

Section 43020.1 of the Public Resources Code (PRC) directs CIWMB to revise regulations accordingly if operational requirements that apply to nonhazardous wood waste landfills should differ from other categories of solid waste landfills, such as those used for disposal of municipal solid waste. Regulations for wood waste landfills and associated facilities will be established in accordance with the methodology for placement into the regulatory tier structure approved by OAL on March 1, 1995. The projected starting date for placement of landfills, including wood waste landfills, into regulatory tiers is June 1996.

Until CIWMB takes action to place wood waste landfills into the regulatory tier structure, LEAs are strongly encouraged not to accept any applications for a new, modified, or revised SWFPs and encouraged not to proceed with 5 year permit reviews for these sites.

This direction is in no way intended to preclude such facilities from future regulation based upon CIWMB determination or statutory revision and does not affect the need to comply with all other applicable federal, state and local requirements. This direction is also not intended to preclude LEAs from accepting applications for a solid waste facilities permit if specific local concerns exist which can be addressed only through the issuance of a solid waste facilities permit.

What are Appropriate Inspection Procedures for Active Wood Waste Landfills?

Wood waste landfill characteristics may vary greatly, but certain aspects are generally consistent. A wood waste landfill should be considered active if it receives wood waste regularly, either daily, weekly, or monthly. Most sites are not open to the public and may only be operated for short periods during the year. Operations may take place only when a mill is operating and/or when a wood yard is cleaned. Wood waste landfills are often monofills for wood waste which is primarily bark and scrap wood mixed with dirt and sawdust. Others may receive wood ash.

State inspection forms for active wood waste landfill inspections should be marked N/A (not applicable) for 14 CCR Sections 17768, 17787, 17792, and 18255(a). Sections to be marked N (not evaluated) are not evaluated unless strong evidence suggests that they should be. These sections would include, but may not be limited to, entry signs (17657), internal roads (17660), site attendant (17674), confined unloading (17676), spreading and compacting (17677), animal feeding (17702), and litter control (17711). Sections where further clarification is necessary include:

Permits Section: A violation of this section should be noted if a wood waste landfill accepts wastes which are not authorized under the definition of wood waste landfill. If a solid waste facilities permit has been issued, specific terms established in the permit should be evaluated as applicable.

14 CCR Section 17639:  Inspection of Records: Many wood waste landfills are located in remote areas. Operations at the sites may be directed from a mill office or company headquarters away from the site. Records may not be available at the site. A violation of this section should only be noted if records are not available for inspection during normal business hours at the location where they are kept. The inspector may request required information to be sent by mail if the office is remote or too distant for inspection travel.

14 CCR Section 17666: Sanitary facilities may be located at the site or in the immediate area. Whenever practicable, the immediate area should be considered to include the location of the source of the waste.

14 CCR Section 17682: Cover: The frequency of soil cover may be determined by calculating the tonnage received per day during the calendar month preceding the inspection date and relating this figure to the frequency indicated in the standard. Alternative cover materials and frequency of placement may also be authorized by the LEA for wood waste landfills if control of odors, vectors, fires, and leachate is ensured.

14 CCR Sections 17686, 17687, 17688, 17689, 17690, 17691, 17692, 17693:

Salvaging/Processing: These sections will be N for most wood waste landfills; however, if salvaging operations take place at a site they should be evaluated in the same manner as for other disposal sites.

General Equipment (17693): Wood waste sites may operate seasonally or sporadically and may share equipment with mill operations. Equipment need not be located on site, but evidence should be provided by the operator that equipment adequate in type, capacity and numbers to perform operations at the site is available when waste is received.

What are Appropriate Inspection Procedures for Closed, Inactive, and Clean Closing Wood Waste Landfills?

Minimum standards to be evaluated for closed, inactive, or clean closing wood waste landfills should include: site security (14 CCR 17658), grading (17710), cover (17684-intermediate cover), fire control (17703), leachate control (17704), gas control (17705), drainage and erosion control (17708), contact with water (17709), grading of fill surfaces (17710), and ponded liquid (17715). These standards are consistent with those indicated in therecommended inspection format for Closed Illegal, and Abandoned (CIA) Sites (see LEA Advisory No. 3, June 1993 Rescinded January 15, 2002). Other disposal site standards should be evaluated where strong evidence suggests that they should be such as, for clean closing sites, noise, odor, and traffic control (17712, 17713, and 17714). The inspection frequency for inactive and clean closing wood waste landfills should, at a minimum, be once quarterly. The inspection frequency for closed wood waste landfills should, at a minimum, be once annually, unless the LEA receives approval from CIWMB staff that no further inspections are necessary. To gain approval of no further inspections, LEAs should submit their request with completed SIP forms in accordance with see LEA Advisory No. 3, June 1993 Rescinded January 15, 2002.

If you have any further questions regarding wood waste landfills, please contact Scott Walker.

Sincerely,

Original signed by:

Deputy Director
Permitting and Enforcement Division

Publication #232-95-021

The intent of the advisories is to provide guidance to Local Enforcement Agencies (LEA) in performing their duties. Guidance, for this purpose, is defined as providing explanation of the Board’s regulations and statutes.

Unless included by reference in the LEA's Enforcement Program Plan (EPP), advisories are not enforceable in the same manner as regulations because they have not been adopted through the formal rulemaking process (see Government Code sections 11340.5 and 11342.6). Advisories do not take precedence over statute or regulation.

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