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Stakeholder Meeting to Discuss Scope and Key Concepts November 19, 2010 1.

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Presentation on theme: "Stakeholder Meeting to Discuss Scope and Key Concepts November 19, 2010 1."— Presentation transcript:

1 Stakeholder Meeting to Discuss Scope and Key Concepts November 19,

2 Introduction: Meeting Logistics Note sign-up sheet for attendees Microphone use s during live webcast should be sent to 2

3 Purpose of SSOM Rule Process Recognize state strategy of moving organic material management up the hierarchy Clarify regulatory requirements appropriate to SSOM composting facilities Provide regulatory relief without jeopardizing environmental protection 3

4 Introductions Introductions of attendees Introductions of MPCA participants 4

5 Compost Rules MPCA Mgmt. Team Solid Waste Program Manager: Gary Pulford Permitting Unit Supervisor: Paula Connell Rulemaking Unit Supervisor: Dave Richfield 5

6 Compost Rules MPCA Staff Team Rulemaking Coordinator - Yolanda Letnes Engineering - Tony Bello Hydrogeology related to siting - John Elks Operations and compost testing - Ginny Black Solid Waste Policy Expert - Jim Chiles 6

7 Overview: SSOM Rule Process APA requirements must be followed, once formal process begins MPCA is not yet in that formal process: has been working on scope and key concepts, along with fact-gathering 7

8 Overview: SSOM Rule Process How this meeting fits in the larger timeline, leading to publication of a draft rule Meeting purpose Timeline of rule process 8

9 Layout of Current Minn. R : Two Tracks Yard Waste Composting Solid Waste Composting Subp. 1. ScopeSubp. 4. Design requirements Subp. 2 Notification Subp. 5. Operation requirements Subp. 3 Operation Requirements Subp. 6. Compost classification Subp. 7. Compost distribution & end use 9

10 Fitting SSOM into Current Compost Rule Acceptable materials: yard waste only Permitting: “Permit by Rule” Notification: __ Pad: All-weather Training: Odor controls: Stormwater: Testing: 10 Yard Waste (current) Solid Waste (current) SSOM (to be added) Acceptable materials: source separated yard, food and __ Siting: Min 5 ft to GW Permitting: No change Pad for compost: All-weather, unless __ Training: __ Odor controls: __ Stormwater controls: no change Testing & product classification: no change Acceptable materials: mixed solid waste, other ___ Siting: __ Permitting: Public notice, local role Pad for compost: Impermeable Training: __ Odor controls: __ Stormwater controls: __ Testing & classification of product: __

11 Ideas Source Separated Organic Material (SSOM) must be source separated at the generator, not picked from Mixed Municipal Solid Waste (MMSW) at a transfer station or a landfill Goal is not to develop excessively prescriptive standards, but outcome-based ones that are matched to the needs and any environmental or health risk 11

12 Ideas Portions of Demonstration Agreement template will be used for rule (most current version) Guidance documents to follow will fill in some of the details (e.g. technical standards on how to measure compaction) 12

13 SSOM Rule Concepts - Overall Stringency of requirements might need to reflect how broadly the materials are that a facility can accept: If the variety of SSOM to be accepted were to go beyond food and yard waste, does it make sense to require greater stringency for feedstock testing and monitoring? 13

14 SSOM Rule Concepts - Overall Feedstocks beyond yard waste and food: What about industrial by products from food processing (e.g. vegetable trimmings)? What about industrial byproducts not from food processing (e.g. paper sludge from deinking mill)? 14

15 SSOM Rule Concepts - Continued Stormwater management requirements - carried forward from existing rules Existing requirements Flexibility when storm water managed on-site Less flexible if storm water discharged off site Example, Industrial Stormwater permit requirement is triggered if:--Stormwater/leachate discharge off site, OR --Operator purchases feedstock materials, such as carbon for bulking 15

16 SSOM Concepts - Continued Currently, Financial Assurance (FA) requirements are not planned, retain existing authority based on risk factors Would continue to rely on current 503 standards, as modified in Minn. R , Subp. 6A 16

17 SSOM Concepts, Continued Question to discuss: should MPCA offer lesser requirements for “small” SSOM facilities? What materials would be acceptable? What site evaluation process would be acceptable? What size or input limit? 17

18 Subp. 1. Scope Discussion What should scope allow for SSOM? Statutory definition (broad) Use in rule (narrower) Industrial waste streams? 18

19 Subp. 1. Scope Discussion Feedstocks We are considering the following prohibited materials list.: Treated woods (they introduce metals) Demolition debris (sheet rock, insulation, etc.) Creosote or railroad ties What about manufactured wood? 19

20 Subp. X. Location Stds. Discussion Not on Karst (Anoka Sand Plain?) 5’ minimum separation to water table Flood plain? ? Same as with composting. 20

21 Subp. X. Location Stds. Discussion Should there be a minimal buffer distance? Local government role? 21

22 Subp. 8. Design Rqmts. Discussion Size ______Large (more requirements) ______Small (less requirements) Type Windrows (aerated) Static Piles (non-aerated) In-vessel 22

23 Subp. 8. Design Rqmts. Discussion Pad Impermeable pad required only under certain circumstances All weather work surface required (accessible for all seasons for management operations) 23

24 Subp. 8. Design Rqmts. Discussion Pad Soil infiltration necessary and verified every 5?-10? years with soil boring Curing pad (may not)/(will not) need impermeable surface (in reference to using soil as a form of leachate management) 24

25 Subp. 9. Operation Rqmts: Odor Control Mixing food waste with bulking agent Immediately upon delivery of food waste, IF NOT, Place a biofilter on food waste and mix and incorporate into windrow be end of working day Odor Management Plan required If odor complaints, plan will be required to be modified to include increasing odor mitigation steps (guidance document?) Sampling and Analysis plan 25

26 Subp. 9. Operation Rqmts. Discussion Windrows (aerated)Static Windrows/Piles (no mechanical aeration) Maintain aerobic conditions 55 ° C for at least 3 weeks Maintain aerobic conditions 55 ° C for at least 7 days Turn at least once every 3-5 days O2 requirements Biofilter – VOC/control: approx. 6” to “12”, first 2-4 weeks (metro, non-metro??? Based on AQ classification) Maximum windrow height (8’, 10’,12’ with/without biofilter??) 26

27 Subp. 9. Operation Rqmts. Training Training with ceu’s required for facilities over XX size, if rule proceeds with a “big/small” approach – Need training only if greater than XX size – All should be trained? – Add as a permit requirement? – Training set out in rule language or Guidance? 27

28 Subp. 10. Compost Classification Use readily available test methods (bucket method & log of testing – this list kept up to date by guidance, not a list specified in rule) Industry standard testing methods for finished product 28

29 Subp. 10. Compost Classification Maturity testing – Solvita STA requirements – additional detail on methods? 29

30 Subp. 11. Compost distribution & end use No change to current rule language Class I Unrestricted distribution Comply with DOA Rule 18C.005, if sold as a fertilizer, specialty fertilizer, soil amendment or plant amendment Class II Restricted distribution – commissioner approval Documents required for use 30

31 Closing Thoughts There will be plenty of opportunity in months to come for more public engagement Keeping the scope focused on clarifying technical requirements suitable to SSOM composting will help this rulemaking move more quickly 31

32 Closing Thoughts Minnesota’s source-separated organics- handling capacity (all types, from compost to animal feeding) is much too small to process up to 15% of the MSW stream if source separated as organics 32

33 Closing Thoughts SSOM rule clarification could help bring down the capital costs of future capacity (e.g. by cutting per-acre costs for compost pad) But rules can’t fix other, key factors that drive up total composting costs compared to costs of cheap landfill disposal 33

34 Closing Thoughts Fixing the larger economic problem will need new action by policymakers at county level and in Legislature 34

35 Questions? 35


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