California Department of Resources Recycling and Recovery (CalRecycle) 

Solid Waste Local Enforcement Agency Regional Round Table Meetings

Winter 2007 Notes

Winter 2007 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 Round Table 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 69 LEA staff representing 41 jurisdictions.

Highlights

Guidance for Permit Implementation Regulations: The proposed regulations were adopted by the Board in October 2006 and became effective April 13, 2007. At the round tables, CIWMB staff presented an update on the tools and guidance that will be available to LEAs. The regulations include: 1) significant change defined and a modified permit process, 2) report of facility (RFI) requirements for community outreach efforts and operator recordkeeping, 3) LEA noticing of the five-year permit review, 4) public hearing requirements for new permits, 5) relationship of solid waste facility permit (SWFP) to other permits including land use permits clarified, and 6) surprise random inspections.

  • There will be flow charts posted on the Permit Toolbox webpage to assist with identifying whether a change is significant and which permit tier is most appropriate.
  • The CIWMB will send out a last set of five year registration and standardized permit review notices to designated owners/operators and provide LEAs with a list of those reviews due in the next five years for registration and standardized permits.
  • Tracking tools will be provided to interested LEAs.

All questions on implementation should be sent to the jurisdiction’s permit liaison staff person and they will be forwarded to the Implementation workgroup for response and posting.

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

Permit Application Rulemaking (see Item VI C in the EAC minutes for background): At the previous round tables in the fall, LEAs were asked to provide feedback on the permit application and instructions. After much discussion at the RTs and EAC, the primary issue was identified as a need for clarification on the permitted tonnage, peak daily tonnage, beneficial use and recycled materials coming through the gate and differences between the numbers on the application and the permit. During the Winter round tables, much of the discussion on the permit application was held during the LEA-to-LEA portion of the round tables. The round table chairs will incorporate the comments from each venue into the pending EAC resolution on this issue.

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

Inspection Forms for Multiple Activities at One Site: Discussions came up at the round tables regarding inspections of multiple activities occurring at a permitted site. Some LEAs stated that they are using only one inspection form for all the activities and document their evaluations of the other activities under the remarks section. At facilities that have been issued one permit to cover several different activities (such as a permit issued for a landfill and a composting activity on site) many LEAs provide two inspection reports to the Board ,one for each different activity. Some LEAs do not. To provide for a consistent approach, guidance is being developed and has been reviewed by the EAC. It is hoped that the guidance will be completed in the next few weeks.

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

San Joaquin Valley Air Pollution Control District (APCD) Rule 4565: This rule was adopted on March 15, 2007 to limit volatile organic compound (VOC) emissions from facilities that manage biosolids, animal manure or poultry litter. The new rule will affect landfill operators, composters and land applicators using these materials. Comments were limited from the LEAs on the rule at the time of the round tables. Some of the proposed biosolids legislation, such as AB 1207, was of greater concern. Among other things, AB 1207 would allow for land application of biosolids by creating state regulations with precedence over local ordinances.

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

South Coast Air Quality Management's District (SCAQMD) Rule 410: SCAQMD's Governing Board adopted Rule 410 regarding odor emissions from material recovery facilities (MRFs) and transfer stations. There is 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. At the Southern RT, LEAs stated that most facilities were submitting alternative odor management plans. The LEAs requested additional training on the content of the alternative odor management plan and guidance on the appropriate enforcement steps when an alternative odor management plan fails. The LEAs stated that clarification on the SCAQMD’s and LEA’s roles in enforcement would be very helpful. Additional meetings with SCAQMD will be scheduled to address these and other implementation issues.

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

Other:

  • Presentation on Composting: At two round table venues, Jeff Watson gave a very comprehensive and thought provoking power point presentation on composting. The presentation included some best management practices as well as home composting guidance principles which will help inspectors understand basic processes that occur at larger commercial composting operations.
  • Training Surveys: A training survey was provided to LEAs at the round tables to gather additional information on LEA training needs. The request to complete the on-line survey was sent out to LEAs on October 3, 2006. Due to a limited response, LEAs were requested to complete the survey at the Winter RTs. The information will be used by CIWMB staff to develop valuable training classes for LEAs and operators for FY 2007/08.

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: May 24, 2007
LEA Roundtables, http://www.calrecycle.ca.gov/LEA/RoundTables/
Leta Forland: Leta.Forland@calrecycle.ca.gov (916) 341-6395