California Department of Resources Recycling and Recovery (CalRecycle) 

Local Enforcement Agency Regional Round Table Meetings

Summer 2003 Notes of the Solid Waste Local Enforcement Agency (LEA) Round Tables

Summer 2003 Round Tables (RT) were conducted in five venues throughout the state. Note, this series of Round Tables was held in the summer rather than the fall. 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 paraphrases 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 or the CIWMB staff recommends any program changes at the State and local level.

List of Highlights

CDI Regulations Processing (Phase I): The Phase I regulations became effective August 9, 2003. The effective date establishes the timeframes for existing facilities to come into compliance with the permitting requirements. The EA has 30--90 days to make a determination of which regulatory tier is appropriate for slotting CDI processing sites, and the operator has up to 180 days to obtain a full permit. However, the regulations allow operators to obtain a temporary registration permit to assist in managing timeframes during decision-making processes on the appropriate tier. LEAs expressed concern that there may not be adequate time to amend nondisposal facility elements (NDFEs) in order to identify newly permitted (registration or full) construction and demolition sites in the document. There were comments on the desirability of permitting individual operations versus using one umbrella permit to encompass multiple operations on one site. The CIWMB staff are developing an extensive guidance package with flow charts to assist with finding the appropriate regulatory tier, a Frequently Asked Questions section, case studies and more.

CDI Disposal Regulations (Phase Two): In September 2003, the Board adopted the CDI disposal phase II regulations with regulatory language that does not use the term "disposal" relative to inert debris engineered fill operations and does not require a scale when calculating weight records for engineered fills. However, weight records (based on scales) would be required within 1 year for other CDI disposal sites, except for those in rural counties and cities and that will close within 3 years. At the RTs, there was not much discussion on either issue and discussion focused on scales. Some LEAs expressed the need for scales at all sites in order to evaluate the amounts of residual and appropriate tier, while other LEAs felt that scales would be an unnecessary requirement on the small operators in their jurisdiction.

Partnership Issues: The CIWMB, EAC and the California Conference of Directors of Environmental Health (CCDEH) representing LEAs agreed to work in partnership to identify and resolve issues to better promote their mutual effectiveness in meeting solid waste management legislative mandates and goals. This joint effort is called “Partnership”. The 2002 LEA Conference and a survey by the EAC brought forward three main issues for resolution: permitting, regulations and enforcement/inspection. At several RT venues, LEAs suggested that CIWMB should approach the drafting of regulations differently such as considering LEAs as part of the internal team that writes and reviews draft regulations prior to the informal comment period. This would allow LEAs to have more input and it would save CIWMB staff time in responding to LEA comments during the informal phase. Additionally, LEAs commented that regulations should be based on actual risk rather than political interests. Regarding Enforcement, comments were made that the hearing panel is a huge impediment to enforcement actions. Also, LEAs commented that the next steps for the Partnership group should be defined so that resolution of the issues may be attained.

TrainingLEAs enthusiastically supported the CIWMB’s proposal to develop a variety of web-based courses. They commented that interactive training and/or a live person to respond to questions at the end of a web-based training may be necessary to assure the success of any web-based training course. LEAs are looking forward to the annual LEA Conference and will make the necessary travel arrangements and allocate funds from the LEA Grant as soon as dates and location are finalized.

Comments? Contact: Mindy Fox.

A Few Other Issues:  LEAs commented on several other issues.

  1. PRC 50001: LEAs commented that because this issue was previously resolved, they were surprised that it is coming back up for discussion and that there will be a workshop in October 2003. LEAs were unanimous in their support the existing ‘dot on a map’ policy.
  2. LEAs would like more information from the CIWMB on the accuracy of the GMI gas monitoring meters and would like the gas monitoring advisory revised as appropriate.
  3. Compostable Material Implementation Issues: LEAs are very supportive of the CIWMB’s proposed Q&A website for their questions. Mushroom grower issues are still being resolved and will be posted. In general, LEAs were pleased with the CIWMB internal structure set up to address their issues, which is initiated by the LEA submitting their issue by e-mail to their Permitting and Inspection Branch liaison.
  4. ADC Regulations: LEAs seemed fairly happy with the revisions to the proposed regulations.
  5. Conversion Technology Regulations: Although interested, LEAs did not have many comments.

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Please note: Past meeting agendas and notes are retained for historical purposes. Over time, some information and links on these pages may become dated and/or inaccurate.

Last updated: February 15, 2005
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