California Water Board: Compost Statewide Order Dan Noble Association of Compost Producers “We Build Healthy Soil”

Topics Water Board Compost Statewide Order Comments on the Statewide Order –What’s the Rationale? –Using Compost Benefits as BMP Next Steps

Water Board Compost Statewide Order - Timeline Process Began Sept with Draft Order – “Discussion Paper” Series of Monthly Workshops – Oct through January 2012 Draft #2 – Actual Wording May 15, 2012 Last Workshop – May 22 & 23, 2012 Next Workshops – Aug 27 & 28, 2012 Comments Due – Sept. 12, 2012

Water Board Compost Order - Elements Only Applies to Groundwater; Stormwater Permits are still managed via NPDES Permits A. Findings –3.a.Feedstocks: i. Agricultural materials; ii. Anaerobic digestate; iii. Biosolids; iv. Food materials; v. Green materials; vi. Manure; vii. Paper materials; and/or viii. Vegetative food materials

Water Board Compost Order – Elements (cont’) –3.b. Exempt Composting Activities: i. Agricultural Composting; ii. Chipping and Grinding Facilities and Operations; iii. Composting conducted at a Publicly Owned Treatment Works (POTWs), contingent on composting activities are covered by an existing WDR or NPDES permit; iv. Lot Clearing for Fire Protection; v. Non-Commercial Composting; and vi. Within-Vessel and Fully-Enclosed Composting.

Water Board Compost Order – Elements (cont’) E. DESIGN SPECIFICATION 1.Tier 1: ≤12,500 cubic yards at a time. Assure any potential discharge will be contained Assure no leachate to groundwater 2.Tier 2: >12,500 cubic yards (prescriptive) Working surfaces, conveyance and detention ponds 1x10 -6 cm/s or less Detention Ponds hold 25-year, 24-hour storm event

Water Board Compost Order – Elements (cont’) E. DESIGN SPECIFICATION 3. Tier 3: >12,500 cubic yards (custom) –Certify no formation of leachate during normal operations –Proper containment during heavy rain (25- year, 24-hour storm event)

Water Board Compost Order – Elements (cont’) F. MONITORING SPECIFICATION (MRP) 1.Tier 1: Reporting, subject to “standard monitoring provisions” 2.Tier 2: As with Tier 1, but adding detention pond monitoring, semi-annually. 3.Tier 3: As with Tier 1, plus: a.Leachate Monitoring, ongoing, & mitigate it, and Either: b. Groundwater monitoring or vadose zone monitoring, semi-annually.

Comments on the Statewide Order Association of Compost Producers (ACP) –Participated in all workshops –Interacted with Roger Mitchell (lead staff) periodically throughout –Submitted verbal and written comments: Attached Letter sent to Mr. Mitchell, 7/23/12 Sent directly to Water Board, 7/30/12

Comments on the Statewide Order - Elements Process Specific Concerns: –The Case for this Statewide Order Has Not Been Made –Small Compost Facilities Will Be Hurt the Most –Extended Public Process Still Needed Order Specific Concerns: –Existing WDRs should be exempt from this new order –Chip & Grind portion of Compost Management Unit, should be exempt from this order –Landfill WDRs exempt for composters on landfills (as above) –Liquid food waste: include in food waste definition –Create consistent compost definition with CalRecycle

Next Steps Attend Aug Workshops: –SACRAMENTO Monday, August 27, 2012, 10:00 a.m. – 2:00 p.m. State Water Resources Control Board, Sierra Hearing Room (2nd Floor) 1001 I Street, Sacramento, CA –RIVERSIDE Tuesday, August 28, 2012, 10:00 a.m. – 2:00 p.m. Santa Ana Regional Water Board, Highgrove Room (2nd Floor), Suite Main Street, Riverside, CA Submit verbal and written comments Seek Injunctive or Legislative Relief?

Questions? Comments? Discussion… Dan Noble, Executive Director Cell: (619) “We Build Healthy Soil”