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California Water Board: Compost Statewide Order Dan Noble Association of Compost Producers www.healthsoil.org danwyldernoble@gmail.com “We Build Healthy Soil”
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Topics Water Board Compost Statewide Order Comments on the Statewide Order –What’s the Rationale? –Using Compost Benefits as BMP Next Steps
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Water Board Compost Statewide Order - Timeline Process Began Sept. 2011 with Draft Order – “Discussion Paper” Series of Monthly Workshops – Oct. 2011 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
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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
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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.
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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
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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)
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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.
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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
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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
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Next Steps Attend Aug. 2012 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 95814 –RIVERSIDE Tuesday, August 28, 2012, 10:00 a.m. – 2:00 p.m. Santa Ana Regional Water Board, Highgrove Room (2nd Floor), Suite 200 3737 Main Street, Riverside, CA 92501-3348 Submit verbal and written comments Seek Injunctive or Legislative Relief?
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Questions? Comments? Discussion… Dan Noble, Executive Director Cell: (619) 992-8389 danwyldernoble@gmail.com danwyldernoble@gmail.com www.healthysoil.org “We Build Healthy Soil”
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