California Department of Resources Recycling and Recovery (CalRecycle) 

LEA Advisory #54—October 26, 1998

1998 Inspection Guidance for Solid Waste Landfills

To All Local Enforcement Agencies:

Attached please find a copy of the "1998 Inspection Guidance for Solid Waste Landfills." This document replaces Advisory No. 20--"1995 Inspection Guidance for Solid Waste Landfills." LEA Advisory No. 20 is now obsolete as it addresses standards for disposal sites found in Title 14 of the California Code of Regulations (14 CCR).

The passage of AB 1220 in 1993 required the removal of overlap between the regulatory authority of the LEAs and the California Integrated Waste Management Board (CIWMB) and that of the State Water Resources Control Board. This document addresses the CIWMB Regulatory Standards for the Disposal of Solid Waste (contained in 27 CCR, Division 2, Subdivision 1). These regulations became effective on July 18, 1997, and represent changes in the regulatory authority of LEAs, as well as the CIWMB. Please note that the regulations associated with Subtitle D implementation have been approved by the Office of Administrative Law as of October 1998.

Changes in the regulations mean changes in the guidelines. Although most of the applicable standards that were found in 14 CCR were moved without change to Title 27 of the California Code of Regulations (27 CCR), some have been rewritten and are not identical to the standards that they replace. Significant additions to the regulations include standards addressing alternative daily cover (ADC) and medical waste. Significant deletions from 27 CCR eliminate the authority of the LEA and CIWMB to enforce odor standards associated with disposal sites and issues associated with water quality.

In the spring of 1997 CIWMB staff conducted statewide workshops on State minimum standards interpretation, including daily cover, intermediate cover, and ADC. The interpretations developed during those workshops are included in the guidance contained herein. Specifically, sections regarding ADC, daily cover, intermediate cover, litter control, record keeping, and drainage/erosion include input collected from the participants at those workshops.

Further changes in the responsibilities and enforcement authority of various agencies, including the LEAs, at disposal sites will continue as a result of changes in legislation, statute, or regulatory authority. LEAs should also refer to other advisories as applicable to inspections, including guidance regarding the acceptance of only specific types of waste at solid waste landfills (e.g., wood waste landfills). Any addition or change to the guidance presented in this document will be forwarded to all LEAs.

CIWMB staff has endeavored to present the information contained in this advisory in a format which field staff will find useful and provides helpful guidance regarding the regulations currently contained in 27 CCR. Questions or comments regarding this document should be directed to your CIWMB Permitting and Inspection Branch contact person.


Original signed by:

Julie Nauman, Acting Deputy Director
Permitting and Enforcement Division


Publication #231-98-016

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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