California Department of Resources Recycling and Recovery (CalRecycle) 

Solid Waste Local Enforcement Agency Regional Round Table Meetings

Winter 2004 Notes

Winter 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 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 (EAC), California Conference of Directors of Environmental Health (CCDEH) or the CIWMB staff recommends any program changes at the State and local level.

List of Highlights

Construction and Demolition (C&D)/Inert Permitting Issues Phase 1 and Phase II):

Phase I: During these round tables, the discussion centered on the ‘written determinations’. The phase I regulations became effective August 9, 2003. The effective date establishes the time frames for existing facilities to come into compliance with the permitting requirements. The EA has 30--90 days to make a written determination of which regulatory tier is appropriate for slotting CDI processing sites. The 90 days in which to make a written determination ended on November 7. Although there is not a requirement to submit the written determinations to the Board, CIWMB staff requested that copies of the written determinations be forwarded to the Permitting and Inspection (P&I) Branch. In response to an inquiry, LEAs were advised to issue a cease and desist from operation to registration or full permit construction and demolition sites that are not in the nondisposal facility elements (NDFEs) even if the time needed to amend the NDFE documents is substantial. To assist LEAs with implementation issues, CIWMB staff created a website with frequently asked questions and responses. Additionally, CIWMB staff sent a CD that contains an extensive guidance package with flow charts to assist with finding the appropriate regulatory tier, a frequently asked questions section, case studies and more. Please let CIWMB staff know if you did not receive one.

Phase II: These regulations will become effective February 24. There was not much discussion at the RTs. There was a request that LEAs send in suggested changes to the draft inspection forms as soon as possible for revision prior to the implementation date.

Training Certification for Landfill Managers and Inspectors: LEAs expressed concerns regarding some of the requirements that may be included in the proposed regulations. The primary concern pertained to specifying SWANA as the sole provider of the certification for LEAs. LEAs commented that SWANA training and certification would be very expensive unless the LEAs and others became members of SWANA. They also said that SWANA’s opinions on solid waste issues may conflict with those of the LEAs and other solid waste regulators. LEAs felt that the certification should be valid if offered by Cal EPA and/or other sources as well as SWANA. Additionally, LEAs wanted to be ‘grandfathered’ into having certification, if they had been certified years ago. LEAs expressed that they would have met the equivalent of the continuing education requirements if they have been working in solid waste programs. The draft regulations will be out for review soon. There are two workshops scheduled to discuss the proposed draft regulations on March 30 (Sacramento) and April 1 (Whittier).

Notice and Order (N&O) Follow-up: 14 CCR 18304.4: P&I staff asked LEAs to notify them more diligently of the status of compliance orders to assist with the presentations to the Board on these orders and for LEA compliance with California Code of Regulations (CCR) Section 18304.4. LEAs may use the inspection form to inform the Board of operator compliance with enforcement orders. There was some discussion about when an enforcement order has additional requirements beyond compliance with the state minimum standard. The compliance information on the order should be submitted when compliance with all requirements has been attained and should be submitted in writing to the CIWMB.
Questions? Contact the P&I staff liaison for your jurisdiction or Mark de Bie.

Odor Tracking and OIMP (Odor Impact Minimization Plan): LEAs mentioned that the OIMP is a good tool for minimizing odors when there are new operators but it is not enough to prevent odors. Tracking of odor complaints was discussed and a sample tracking form was distributed. Most LEAs already track complaints and document whether the odor was verified or not.
Questions? Contact the P&I staff liaison for your jurisdiction or Mark de Bie.

AB 1497 Implementation Issues: The main new requirements in AB 1497, effective January 1, 2004, pertained to:

  1. A labor transition plan; and
  2. Public Hearings for revised permits

LEAs that had received applications for a revised permit in the last few weeks of December had many questions about the public hearing requirement. CIWMB staff sent out LEA guidance on both issues and created a website with frequently asked questions and responses to assist LEAs.
Questions? Contact the P&I staff liaison for your jurisdiction or Mark de Bie.

Training and LEA ConferenceLEAs are very pleased with the training being offered. LEAs mentioned that they are interested in receiving more compost and odor investigation training. LEAs are looking forward to the annual LEA Conference.
Comments? Contact: Mindy Fox.

Other: During the LEA to LEA discussion, additional topics were discussed including the LEA Annual Award (Ralph Hunter Memorial Award).

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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 18, 2005
LEA Roundtables, http://www.calrecycle.ca.gov/LEA/RoundTables/
Leta Forland: Leta.Forland@calrecycle.ca.gov (916) 341-6395