California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting

Minutes: Enforcement Advisory Council Meeting—August 20, 2003

I. Introductions

Members present: See attached participant roster. Quorum.

II. Agenda review

Howard Levenson added Electronic filing of inspection reports discussion, Bill Prinz added composting contamination standards discussion, and Greg added Organics regulations. A few changes in order of items to accommodate attendees.

III. Approval of June 19, 2003 Minutes

No changes and approved.

IV. EAC Resolutions - Status & Updates

  • 2002-02 - Burn Dump Advisory Workgroup
    On-going. Little news from the work group. EAC members (haven’t heard much or been involved). However, Howard stated that the protocol has been finalized and came out to some yesterday. Some discussion regarding concern/problem with Department of Toxic Substances Control (DTSC) “selectivity” of projects they will get involved with.
  • 2002-05 - EPP Toolbox
    On-going.
  • 2003-01 - EAC Policy and Procedures
    Completed (Drop from updates).
  • 2003-02 - LEA Survey Partnership Issues (discussion item)
    On-going.
  • 2003-04 - 5-Year Permit Reviews
    Letter completed and handed out at this meeting. Will be a Partnership Workgroup issue. AB 1497 may define significant change, or define “minor” changes that do not need “revision” of solid waste facility permit (SWFP). Need some process, such as delegation or some other, other than permit revision to deal with minor changes.
  • 2003-05 - Odors
    Letter completed and handed out at this meeting. Department of Health Services (DHS) Bioaerosols study on health effects. Need research on what has been done. Cal Poly recent study. Would like anyone with information on what we know or have on previous studies and where they can be found to e-mail Sue Happersberger and Sharon Anderson with that information.

V. EAC Issues for Discussion

  1. Partnership Workgroup: Meeting has been scheduled for next Wednesday (August 27, 2003). CIWMB also  reviewing how they function, do things (permitting, enforcement and regulations). There was the May 8 workshop, and they are going through another Audit (result of Crippen fire). A number of participants are scheduled, including Dan Avera, Patti Henshaw, Matt Fore, Greg Pirie, and others. CIWMB has been having internal meetings and discussions. They are loosing engineers. Had a handout with issues bullets boiling down the issues/topics from last year conference, EAC and CIWMB.
  2. Inspections Reports (Howard Levenson): CIWMB is investigating ways to file inspection reports electronically. They get over 10,000 per year and with staffing issues are falling behind getting them posted into the system. They have a workgroup to evaluate options with 1 Permitting and Enforcement (P&E) staff, 1 LEA and 1 computer technician.
  3. Compost product contamination (Bill Prinz): Had a discussion about issues and options for cross-contamination of compost, such that a composter is adding non-composted dry (chipped brushy) green waste to finished compost. Process to further reduce pathogens (PRFP), storage time, sale as, and other issues. One recommendation was to mix at time of sale.
  4. Construction and Demolition (C&D) Phase 2: Two issues still being discussed: terminology for engineered fill and scale requirements.
  5. LEA-of-the-Year Award: Discussion of having an LEA-of-the-Year Award (Ralph Hunter Award). A draft of award, purpose and requirements was handed out. One recommendation was to call it LEA/EA “Accomplishment” rather than “of the Year” award, so that it wouldn’t be tied into time frame so much, and could go to past achievements. Also, CIWMB staff suggested to do homework before awarding, so it would not go to an LEA under scrutiny or discipline from the CIWMB (maybe should be given an award for that – author comment).
  6. Odor (at compost facilities): Discussion about whether or not CIWMB had accomplished the 4 requirements of SB 88. CIWMB believes that they have and are preparing letter to the legislature addressing how they have addressed the four requirements (should be out in several weeks). Some discussion as to whether “standards and thresholds” had really been addressed. The Odor Impact Minimization Plan (OIMP) covers issue. Also, Air Quality Management District/Air Pollution Control District (AQMD/APCD) thresholds may be used. Advisories 32 and 33 are outdated with new regulations. We’ll see what the letter says before decide what to do with advisories.
  7. CIWMB Audit: Looking at CIWMB priorities. CIWMB responding to requests for things, such as examples of Permitting and Inspection (P&I) inspection reports and exclusions (such as Crippen, and other non-traditional sites). Should be complete by October. May also be looking at LEA evaluation process.
  8. Conformance (PRC 50001 and Location): Lengthy discussion regarding background, past activities and previous conclusions to this ongoing discussion. Surprise that it had re-surfaced. There will be another public workshop before it is an agenda item for the Board. A particular landfill with expansions not discussed or identified in the Siting Element is the reason. Apparently issue is over expansion for a buffer zone, not footprint (or was that for another one that recently went through without issue?). Additional issue because jurisdictions are coming up on 5 year reviews of these Planning Documents. The Board believes there are inconsistencies in CEQA, public noticing,  what is required in Siting Elements and Nondisposal Facility Elements (NDFE), and what is happening.  It was felt that CIWMB needs to evaluate and define what the “purpose” of the County Integrated Waste Management Plan (CIWMP) is for. Dennis Ferrier to track for EAC.

VI: CIWMB Topics, Updates and Discussion.

  • Training - Trying to have one every month:
  1. September/October: Construction, Demolition and Inert Debris (CDI) Regulations
  2. October (21/28th): Radioactive Wastes (30 people – Dennis Corcoran)
  3. October: No Conference
  4. November: Notice and Orders (web training)
  5. November: Illegal Dumping on Tribal Lands
  6. December/January: California Environmental Quality Act (CEQA) and Permitting
  7. January and March: Heath and Safety (H&S) Refreshers for LEAs
  8. Spring: Load Checking (web based)
  9. March: Conference (tentatively 10, 11 and 12), with Recycle trade show (Sheraton Grand in Sacramento), also California Rural Recovery Association (CRRA) that week.
  10. Three-Day Field Tours
  11. April: State Minimum Standards (web based)
  12. April/May: Illegal Dumping on Tribal Lands
  13. Compostable Materials
  14. Hands on Gas Training
  • Would like help on two venues for radiation training.
  • Report of Facility Information (RFI) writing – Toolbox Maintenance Advisory Committee (tMac) team – will have examples of portions of Report of Disposal Site Information (RDSI)/RFI. Jon Whitehill and same people identified for tMac a while back. Next few months will have face to face meetings
  • September/March – Manager of Landfill Operations (MOLO) training
  • Operator Training – Last year of pilot program. Don’t know yet if it will be made a mandatory program. Format to be determined. Envision kind of like Solid Waste Association of North America (SWANA).
  • AB 1497 – August 18 Version. Cleaning up red tape of administrative civil penalties. Additions for landfill closure, such as financial mechanism for retraining for staff. Permit time lines adjustments. Public Hearings/Noticing requirements (65091) (purpose/reason = trying to stop Bradley Landfill)
  • SB 20 – Bill put on suspense (?). 3 main factions fighting. All 2 hated bill and competing sets of amendments. Meeting with Californian's Against Waste (CAW) (Bill Sponsor), Waste Management (see next big market and infrastructure) and others. Will probably get out of Appropriations Committee with July Version. Will probably get amendments on the floor. Cal EPA and CIWMB for support. Scope may be broad. Manufacturing industry wants just cathode ray tubes (CRT’s). Environmental and Solid Waste Industry support. DTSC expected to declare more e-waste items as hazardous.
  • Alternative Daily Cover (ADC) (Bill Prinz is EAC lead to track this) - He provided some comments for his San Diego jurisdiction. Regulations are in 15-day comment period. Will probably go another 15-day comment period. They require soil cover to working face at least once per month. May have option for LEA to require soil when deemed necessary. Require description of ADC use in the RDSI.
  • Conversion Technology - Brian Larimore (Markets Division) is working on. Anticipate November Board meeting for start of 45-day comment period. August 1st Workshop. EAC will “generally” track. Not high on LEA radar screen now.
  • September P&E Committee meeting there will be a presentation on Bark Beetle Infestation resulting from the drought and the resultant fire hazard.
  • California Conference of Directors of Environmental Health (CCDEH) – Sent, or were supposed to send, a letter in July regarding “Critical” positions in P&E.
  • There will be Workshops September 22 and October 30 regarding the “broader application of CDI Phase I additional requirements to the rest of solid waste regulations.

VII. Next EAC meeting scheduled for October 14.

EAC Archive

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Last updated: February 8, 2005
Enforcement Advisory Council (EAC) http://www.calrecycle.ca.gov/LEA/EACouncil/
Leta Forland: Leta.Forland@calrecycle.ca.gov (916) 341-6395