California Department of Resources Recycling and Recovery (CalRecycle) 

Solid Waste Local Enforcement Agency Regional Round Table Meetings

Fall 2006 Notes

Fall 2006 Round Tables (RT) were conducted in five venues throughout the state. The agendas for each RT may be different because the topics include issues of regional concern. LEAs from each of the venues worked with CIWMB staff to develop the RT agendas. Each RT venue has an LEA Chair, selected by the LEAs in that region. The LEA Chair also serves on the Enforcement Advisory Council (EAC) as a representative of the LEAs in that region. This collection of notes summarizes some of the dialogue occurring at the RTs and may paraphrase a number of concerns or recommendations of the LEA staff that attended. Since not all LEAs and CIWMB staff are able to attend every RT, 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 EAC, California Conference of Directors of Environmental Health (CCDEH) or the CIWMB staff recommends any program changes at the State and local level. This series of RTs was attended by 76 LEA staff representing 43 jurisdictions.

Highlights

  • Permit Implementation Proposed Regulations
  • Active Disposal Site Gas Monitoring and Control Proposed Regulations
  • 14 CCR 18350
  • Permit Application
  • SWIS Inspection Forms
  • Compliance Toolbox Development
  • Mammalian Tissue Composting
  • PR 410: South Coast Air Quality Management District proposed rule on odors at material recovery facilities and transfer stations
  • Other: Compost Presentation and Vehicle Inspection Survey

Permit Implementation Regulations: The proposed regulations were adopted by the Board in October 2006. At the Round Tables, CIWMB staff presented an update of the changes was presented. The regulations include: 1) Significant Change Defined and a Modified Permit Process 2) RFI Requirements for Community Outreach Efforts and Operator Record Keeping 3) LEA Noticing of the Five Year Permit Review 4) Public Hearing Requirements for New Permits 5) Relationship of SWFP to Other Permits including Land Use Permits Clarified 6) Surprise Random Inspections. The LEAs complimented Mark de Bie on the inclusive process used to develop these regulations. LEAs also requested that CIWMB notify operators of the new requirements and develop flow charts on the requirements for full, revised, modified and registration permits. Mark said that the flow charts are under development and will be posted on the Permit Toolbox webpage.

Questions? Contact the Permitting and Inspection (P&I) staff liaison for your jurisdiction

Active Disposal Site Gas Monitoring and Control Proposed Regulations: A quick survey was taken at each Round table on whether facilities in their jurisdictions have landfill gas monitoring wells placed beyond the permitted boundary rather than at the permitted boundary. LEAs mentioned that a few sites had probes beyond the permitted boundary for reasons including that the boundary was too close to the actual waste or the boundary was inaccessible (Cal Trans property etc). LEAs did not express concerns determining compliance if a probe beyond the boundary measured excessive levels of methane. One LEA believed that the language in T21, CCR 20921 is unenforceable because it states that the concentration of methane gas migrating from the landfill must not exceed 5% by volume in air at the facility property boundary, etc. The LEA stated that the reason for their belief that this is not enforceable is because the methane is measured in CO2 in the probe, not air. The LEA will be submitting comments during the formal comment period. The EAC has already submitted detailed comments on this regulation package, Resolution 2006-03.

14 CCR 18350: Enforcement action taken by the Board This issue was mentioned at the Round Tables as a reminder of the practices outlined in T14, CCR 18350(a) (1-3). LEAs were asked to take a look and see if they have any instances that fit the criteria, such as a site on the Inventory and the LEA has not issued a compliance schedule; an un-permitted, illegal site that is not under a cease and desist order; or an enforcement order with lapsed compliance dates, or chronic permit and/or minimum standard violations and no enforcement order has been issued. If the LEA has not taken an indicated action at a site, then Board staff are expected to take the steps outlined in 14 CCR 18350. At the Round Tables, LEAs wanted to know if this is a new focused effort on the part of the CIWMB. It is not a new effort but a reminder of the requirements in 14CCR 18350.

Questions? Contact the P&I staff liaison for your jurisdiction

Permit Application: LEAs were asked to provide feedback on the permit application and instructions. The feedback received at the Round Tables was very valuable and will be brought to the EAC by the Roundtable Chairs for further discussion. The feedback included:

  • Concerns relative to the methodology for calculating remaining capacity in the landfills
  • Clarification on permitted tonnage, peak daily, beneficial use and recycled materials coming through the gate
  • Clarification on site life determinations
  • Clarification on the instructions
  • Font irregularities and a typo correction

There was also discussion regarding the role of the application after the permit is issued.

Questions? Contact the P&I staff liaison for your jurisdiction

SWIS Inspection Forms: January 2007 conversion to pdf forms Many LEAs use hard copies of the inspection forms and many are using the new PDF forms. There was discussion about putting all narrative in attachments so that the information could be saved. LEAs are looking forward to receiving the CIWMB guidance on reasonably priced software that will help LEAs save the PDF inspection forms. The proposed deadline to convert to the new PDF inspection forms is January 2007.

Questions? Contact the P&I staff liaison for your jurisdiction

Compliance Toolbox/Inspection Tool: This is the development of a self-tutorial to help LEAs and Board staff evaluate solid waste facilities and operations for compliance with State Minimum Standards (SMS). This self-tutorial will be an element of the Compliance Toolbox Web Site, which is currently under development. The self-tutorial will become part of the training curriculum and will provide ongoing guidance for LEA and Board staff to help promote statewide consistency in evaluating SMS. At the Round Tables, CIWMB staff requested LEAs submit the inspection information outlined in the All LEA E-Mail. LEAs were asked to let Board staff know if any facility names in the photos submitted needed to be removed. LEAs were very supportive of the toolbox and mentioned that the toolbox will be a good tool to promote consistency among CIWMB inspectors as well as between LEAs.

Mammalian Tissue Composting: California Department of Food and Agriculture (CDFA) has removed their ban on research demonstrations for composting mammalian flesh. CIWMB regulations still prohibit mammalian flesh composting. CIWMB is looking at emergency regulations or other to remove the prohibition in CCR Title 14 to allow research demonstrations. LEAs at one venue stressed that on-site composting or disposal options are needed to handle sudden deaths due to flooding and/or other unanticipated events. It was recommended that a simple permit for either one-time composting of the animals or even for composting food wastes from a large public event should be explored. LEAs seemed relieved that other disposal options would become available when there are rendering capacity shortages, cattle die-offs and other occurrences.

Questions? Contact the P&I staff liaison for your jurisdiction.

South Coast AQMD Adoption of Proposed Rule 410: On October 6, the SCAQMD Governing Board adopted Rule 410 regarding odor emissions from MRFs and transfer stations. Since Air Districts often adopt the same rules, an update on Rule 410 was given at every Round Table. Although CIWMB questioned the need for the rule given the small number of problem facilities involved, CIWMB also recognized the need to be proactive in preventing future problems, and worked with the SCAQMD to incorporate an alternative approach within the rule that would allow for the submittal of alternative odor management plans by operators to the LEA rather than the SCAQMD. There was some discussion about the enforcement responsibilities of each agency when problems occur. CIWMB will be working on guidance to LEAs, as well as participating in a working group on implementation details.

Questions? Contact the P&I staff liaison for your jurisdiction.

Other:

Presentation on Composting: At one Round Table venue, Jeff Watson gave a very comprehensive and thought provoking power point presentation on composting which included some best management practices. All the LEAs and Board staff present were very impressed with the presentation.

Vehicle Inspection Programs: A quick survey was taken at most of the Round Table venues about LEA vehicle inspection programs. Results varied, some LEAs inspect vehicles on a complaint basis only and others conduct regular inspections. The survey was requested by one Round Table venue and will be followed up at an upcoming meeting of the EAC.

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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: August 18, 2011
LEA Roundtables, http://www.calrecycle.ca.gov/LEA/RoundTables/
Leta Forland: Leta.Forland@calrecycle.ca.gov (916) 341-6395