Preliminary Analysis of an Evolving Issue Inert Disposal Sites and Permits Background  Definitions  Non-Traditional Facilities  LA Sites  New Information  Surrendering Permits  Exemptions Potential Impacts  Permit and Regulation  Diversion and Disposal

Background Definitions  PRC – Solid Waste  PRC – Solid Waste Disposal  PRC Disposal Site  PRC – Solid Waste Landfill

Background (cont.) Non-Traditional Facilities and Regulations Tiers Advisory 12 Status of C&D Regulations Mine Survey

Background (cont.) LEA Advisory #12 Currently, a number of inert disposal sites operate without a SWFP based upon LEA Advisory #12 Issued in March 1994, it suggested that EAs wait to accept SWFP applications until the Board determined how they would be slotted

Background (cont.) Advisory #12 “Until the Board takes action on specific handling methods, LEAs are strongly encouraged not to accept applications for a solid waste facilities permit for materials and handling methods which are under evaluation. A delay in the processing of these permits would eliminate the administrative burden of revising or modifying such permits if changes to this process are included in the Board's action.”

Inert Sites within LA Co. LEA Jurisdiction Active – 11 5 with SWFP 6 not currently regulated or to be determined There are 2 sites in LA City that were found exempt by LA City LEA

New Information Water Master correspondence Inquires regarding surrendering permit

Surrender of Permit Statute and regulation do not contain any provisions regarding surrender of permits In the past, permits have been surrendered when sites have closed down No approval necessary because no further activity at the site

Surrender With On-going Activity The potential proposal is unique because there will be continuing operations after surrender Surrender still will not require approval because it’s a voluntary act However, on-going activity will need some type of authorization

Permit Exemption 27 CCR allows exemption from the requirement for a permit Must be one of listed types of sites Inert sites fit on list as unclassified sites EA must make 3 findings after public hearing

Permit Exemption (cont.) 3 Findings for Exemption: Exemption is not against public interest Quantity of solid wastes is insignificant Nature of solid wastes poses no threat to health, safety or the environment

Permit Exemption (cont.) Site must comply with SMS and be inspected quarterly Board has no direct approval or concurrence role Board may provide information at public hearing Board may provide technical assistance to EA regarding intent of three findings

Potential Impacts Permit and Regulations Impacts C&D and Inert Regulations State wide consistency Diversion/Disposal

Permits and Regulation Impacts C&D and Inert Regulations for disposal will determine appropriate level of regulation for disposal of inert material 11 active inert disposal sites throughout the State, 6 more planned

Potential Diversion/Disposal Impacts Surrender of inert facility permit will have impacts on: Base-year waste generation tonnage 2002 disposal tons 2002 diversion rates Identification of specific impacts in progress Many southern California jurisdictions could be impacted

Base Year Generation Impacts Four Board permitted inert landfills were not included in 1990 base year disposal tons About four million tons were not included in LA County jurisdictions’ 1990 base year generation

Base Year Generation Impacts Board approved 28 revised 1990 base year disposal amounts with “LA Fix” Board approved about 40 new base years that include DRS tons disposed at the inert landfills

Base Year Generation Impacts Board’s Disposal Reporting System (DRS) now includes tons disposed at all Board permitted landfills, so new base years include disposal at the four inert landfills

Base Year Generation Impacts If permits are surrendered, tons no longer count as disposal Inerts from the four facilities must be subtracted from base year generation if permits are surrendered

Disposal Reporting System Impacts DRS requires all Board-permitted landfills report jurisdiction of origin for tons disposed and Alternative Daily Cover DRS went into effect in 1995 No participation in DRS if Board Permit for inert facility is surrendered No tonnage at the four facilities counts as disposal once permits are surrendered

Diversion Rate Impacts No impacts on 2000 or 2001 diversion rates because no permits surrendered prior to Diversion rate impacts on jurisdictions will vary depending on tons of inerts from the four facilities in base year and measurement year.

Diversion Rate Impacts Examples Lancaster, Revised 1990 base year, 52% diversion (using default factors)  Remove 50,746 tons in base year allocated through “LA Fix”  Remove 178 tons disposed as reported in DRS  Revised diversion rate 38% (using default factors)

Diversion Rate Impacts Examples Los Angeles County Unincorporated, Revised 1990 base year, 30% diversion (using default factors)  Remove 188,702 tons in base year allocated through “LA Fix”  Remove 43,636 tons disposed as reported in DRS  Revised diversion rate 23% (using default factors)

Diversion Rate Impacts Examples Arcadia, 1990 base year with no revisions, 30% diversion (using default factors)  No tons removed from base year  Remove 35,056 tons disposed as reported in DRS  Revised diversion rate 52% (using default factors)

Diversion Rate Impacts Examples Irvine, 1998 new base year, 44% diversion (using default factors)  Remove 14,708 tons disposed as reported in DRS for 1998 base year  Remove 23,621 in current year DRS  Revised diversion rate 46% (using default factors)

Future Steps Staff will continue to develop the C&D regulations package Staff will continue to identify specific impacts on diversion rates