California Department of Resources Recycling and Recovery (CalRecycle) 

Local Enforcement Agency Regional Round Table Meetings

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

Spring, 2003 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 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 1) and Disposal (Phase Two): The Phase I regulations were submitted to the Office of Administrative Law (OAL) at the end of May. OAL has 30 working days for their review and the regulations will take effect 30 calendar days after accepted by OAL. The LEAs expressed concerns about the additional requirements that were placed in the Phase I regulations and their questionable benefit to the protection of public health and safety. Comparisons were made between using the transfer station permit rather than the CDI permit for medium size facilities and the apparent greater advantages. It was of concern that there may not be adequate time to amend nondisposal facility elements (NDFE) so that the newly permitted construction and demolition (C&D) sites are identified in the document. LEAs mentioned that CIWMB’s assistance in getting the word out to the City Planners/Recyclers is appreciated. The draft inspection form was handed out for comment. A work group for Phase II regulations is being developed. Many LEAs were concerned about which of the additional Phase I requirements would be included in Phase II. The Phase II regulations will go to the Board in July and most likely go out for another 15-day comment period.

Permit Requirements & Compostable Regulations: The regulations became effective April 4, 2003. The Odor Impact Minimization Plan (OIMP) is a state minimum standards (SMS) requirement. All existing sites are required to have an OIMP as of April 4, 2003. For proposed sites, the OIMP must be submitted with the permit application. The OIMP should include mitigation measures to prevent fires since smoke is an odor problem. Apparently some mushroom growers in the Bay area were upset that they did not receive notification of the proposed regulations. There was some discussion about the best method for addressing implementation concerns relating to the compostable materials regulations. EAC Chair will be working with CIWMB staff on the best mechanism to collect issues. There may be a website developed with implementation questions posted with the responses added as soon as available. It was suggested that a live compost chat room with a CIWMB monitor may be very useful to LEAs.

Draft Protocol For Burn Dump Site Investigation And Characterization: AB 709 required the Department of Toxic Substances Control (DTSC) publish a guidance document for evaluating dump sites by June/July 2003. A workgroup with representatives from various agencies and LEAs developed the draft protocol. At one venue it was mentioned that the LEAs with the most burn sites in their jurisdictions should be asked to participate on the workgroup. At the RTs there were concerns about the lack of LEA input into the site consultation process to determine which agency would be the lead responsible for the remediation. The draft protocol showed DTSC, California Integrated Waste Management Board (CIWMB), State Water Resources Control Board (SWRCB) and Regional Water Quality Control Board (RWQCB) (without the LEAs) meeting to make the determination. Additionally, it was suggested that the agency designated with regulatory responsibility should retain oversight of the site. In other words, if an agency such as DTSC assumes oversight of the remediation, the site would be removed from the LEAs list of closed, illegal and abandoned (CIA) disposal sites and the site would become a DTSC site. It was mentioned that in Northern California, it may be difficult to differentiate ash from old burn dump sites from the ash from forest burn sites. It was also mentioned by several LEAs that their jurisdictions are beginning to utilize a software program (KIVA) for monitoring changes in land use of and around sensitive sites. The LEAs said they are inputting their inspection reports and assessors; planners are inputting their data for a complete picture of the environment.

Alternative Daily Cover (ADC) Regulations: The public comment period for the proposed regulations ended on June 17. LEAs requested clarification on whether the requirement for a full description of beneficial use would trigger an immediate Report of Facility Information (RFI) and/or permit revision or if the RFI could be updated at the next permit review. Several RT venues requested access to the efficacy studies on which the ADC standards are based. LEAs mentioned that they would like more scientific backing to support them when working with operators. Also, LEAs commented that the biosolids standards seem too general and need to be more specific, including specifying the type and quality of biosolids allowed to be used as ADC. The public hearing on the regulations will be on July 7.

Comments? Contact: Reinhard Hohlwein.

E-Waste: Illegal dumping of cathode ray tubes (CRT) was mentioned as a major increasing problem throughout the State. The disposal costs have increased from $5 to $15 per unit in many jurisdictions which has contributed to the illegal dumping problem. Small landfills may not be able to continue collecting CRTs because of the huge disposal costs when they try to get rid of the CRTs. Some jurisdictions mentioned that they have curbside pick up and some have had an amnesty day for CRTs using the household hazardous waste (HHW) grants. In general, CRT disposal continues to be a huge problem and illegal dumping of CRTs is increasing statewide.

Comments? Contact: Susan Happersberger.

Training: The proposal to have a variety of web-based courses was met enthusiastically by LEAs. LEAs commented that 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. Regarding the annual LEA Conference, the location was questioned and jurisdictions needed to know where the Conference is being held as soon as possible to make the necessary travel arrangements and/or allocate funds from the LEA Grant. Northern California LEAs mentioned that their participation would be very limited if the Conference were to be held in Southern California.

Comments? Contact: Mindy Fox.

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Last updated: February 16, 2005
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