Local Enforcement Agency Correspondence

Regional Round Table Meeting Notes: Spring 2004

Date: July 29, 2004

To: All Local Enforcement Agencies

This all LEA E-mail was sent on behalf of the LEA Support Services Branch of the California Integrated Waste Management Board.

Solid Waste Local Enforcement Agency Regional Round Table Meetings

Spring 2004 Round Tables (RT) were conducted in five venues throughout the state. The agendas for each round table may be different because the topics include issues of regional concern. LEAs from each of the venues worked with CIWMB staff to develop the round table agendas. Each round table venue has an LEA Chair, selected by the LEAs in that region. This collection of notes summarizes some of the dialogue occurring at the Round Tables and may paraphrase a number of concerns or recommendations of the local enforcement agency staff that attended. Since not all LEAs and CIWMB staff are able to attend every Round Table, this summary is being presented to make information available on some of the issues with statewide implications. Further, these summaries may help to focus all parties in efforts to determine if the Enforcement Advisory Council (EAC), California Conference of Directors of Environmental Health (CCDEH) or the CIWMB staff recommends any program changes at the State and local level.

Highlights

• Preliminary Discussion of Initial Issues for Regulation Development, including but not limited to AB 1497: Public Hearings, Defining Significant Change not Authorized by the Permit, etc
• Training Certification for Landfill Managers and Inspectors
• Construction and Demolition (C&D) Sites and Enforcement Issues
• TMAC (Permit Toolbox Maintenance Advisory Committee)
• Training and LEA Conference

Preliminary Discussion of Initial Issues for Regulation Development, including but not limited to AB 1497: Public Hearings, Defining Significant Change not Authorized by the Permit, etc

Board staff presented and discussed twenty two regulatory concepts in a one page handout at each Round Table. The concepts were developed to assist with prioritizing, analyzing and eventually resolving some of the crucial permitting implementation issues including CEQA, tiering, Construction Demolition and Inert Materials Phase I issues, statutory mandates relative to significant change (AB 1497) and other issues. The Round Table Chairs (Enforcement Advisory Council Representatives) will be gathering their venue’s input on the regulatory concepts and forwarding to the EAC Chair who will compile the input with Mark de Bie of the CIWMB. In the Southern California RT, there was a very informative presentation on conducting public hearings by Linda Hagthrop, Public Information Officer for the Orange County Integrated Waste Management Department. Several LEAs brought copies of their public hearing notices. The public hearing documents shared at the Round Table will be posted on the CIWMB website and available as a resource to LEAs as part of the collective efforts to implement AB1497.

Questions? Contact the EAC Representative for your Round Table venue or Mark de Bie at (916) 341-6331.

Training Certification for Landfill Managers and Inspectors

An update was given on the proposal to have a mandatory California Specific Manager of Landfill Operations/Inspector Training Certification Program that would have required every on-site landfill manager and each CIWMB and LEA landfill inspector to have and maintain proper training and certification. The training certification would have included continuing education. At the RTs, LEAs continued to convey some of the same concerns expressed at the previous RTs and at the informal workshops, including that there is no demonstrated need for the proposed regulations; SWANA is not the appropriate certifying entity; the cost to local government for the program would be too burdensome. The proposed regulations and training certification program are being reviewed as one of a variety of options to enhance landfill operator training. It is anticipated that the list of options will be presented to the Board in September or October 2004.

Questions? Contact Darryl Petker at (916) 341-6704.

C&D Sites and Enforcement Issues

The effective date of the construction, demolition and inert debris (CDI) regulations established time frames for existing facilities to come into compliance with the permitting requirements. Since the time frames have passed, existing CDI sites should either have completed the notification process, be permitted, or the LEA is taking appropriate enforcement action to bring the sites into compliance with the requirements. The Permitting and Inspection (P&I) Branch is working with jurisdictions on these sites. The Board has set up an internal working group that is identifying barriers to handling CDI materials and the impact of the CDI regulations. The internal workgroup has two members from each Division so that all impediments, related to enforcement, marketing and recycling, may be identified. The workgroup’s findings will be presented to the Board in the Fall 2004.

Questions? Contact the P&I staff liaison for your jurisdiction or Mark de Bie, (916) 341-6331 or Howard Levenson for Working Group information.

TMAC (Permit Toolbox Maintenance Advisory Committee): TMAC is a subcommittee of the Enforcement Advisory Council that provides recommendations and monitors the Permit Toolbox which provides online tools and resources for processing solid waste facility permits and completing other permit-related tasks and responsibilities. At the RTs, LEAs were reminded to complete and submit the survey. The survey will be used to prioritize possible updates and pages for the Permit Toolbox as part of the effort to continually improve the Toolbox’s usability.

Questions? Contact Jon Whitehill at (916) 341-6403.

Training and the Conference

LEAs are very pleased with the training being offered and looking forward to the up-coming web-based training. The next LEA Conference (number eight!!!!) is being planned for next May 11, 12, 13 in Anaheim.

Comments? Contact: Mindy Fox at (916) 341-6701.

Other

At one Round Table venue, there was an extensive discussion on the land spreading of green material on fields. Apparently, contaminated green material from other jurisdictions is being applied as ‘beneficial use’ to agricultural lands. Discussions regarding application as ‘beneficial use’ or disposal were held. The suggestion that conditional use permits (CUPs) and the California Environmental Quality Act (CEQA) could be needed was mentioned. The LEAs requested better guidance on ‘beneficial use’.

Thank you,
Melissa Hoover-Hartwick
LEA Support Services
(916) 341-6813