|
Site Information
- All the following activities are located within a 160 acre parcel, which
was previously
a gravel pit:
- 106 acre inert landfill, conditional exemption granted by LEA
- Transfer station, full solid waste facility permit (SWFP), 10 acres, 250
tons per day (tpd)
- Chip/grind, operates adjacent to 10 acre
- Inert recycling (cement and gypsum), operates adjacent to 10 acre
transfer station
- Operations are located in heavy industrial area
Chip and Grind Activity
- Operator accepts green waste and C&D wood including cedar roofing shingles
with roofing paper
- Only limited chipping and grinding due to constant equipment breakdown
- Most volume reduction is crushing by dozer
- Difficult to obtain tonnage records but it is estimated that about 200-500
tpd is accepted
- Material not being moved out due to lack of personnel and equipment to
process and lack of market for contaminated wood product (tar paper)
- Pile temperatures are ranging from 90o F to 185o F
- On site storage is much greater than 7 days
Unprocessed Material Estimated at 200,000+ cubic yards
Chip and Grind History
- LEA observes stockpiling of green material and wood waste
- LEA requests operations plan
- Operator submits plan
- Four months later a fire burns acres of accumulated wood waste
- City fire orders site operations to cease
- Entire site closed for 30 days
- Order is challenged, eventually the site reopens
- LEA notes composting temperatures in piles
- LEA determines site is composting without a permit
- LEA requires material to be removed and operator to apply for a composting
permit
- Order is appealed, no imminent threat, order is stayed pending hearing
LEA Determination
- Contaminant free material is received
- Composting temperatures are present in piles
- Material is left on site for weeks and months past exclusion what is allowed for
an excluded activity
- Volume of material on site exceeds what is allowable for an
excluded activity
- LEA determines that a full compostable materials handling permit is
required
Regulatory Authority
The LEA initially used the following to support their determination that the
activity was not excluded:
- California Code of Regulations, Title 14, Chapter 3.1, Article 2, Section
17855 excludes certain activities from complying with the requirements listed
in this Article. Chipping and Grinding activities that store no more than 1000
cubic yards of material onsite or store any amount for less than 7 days are
excluded from these regulations
New Regulations
The regulations that came into effect in April 2003 clarified authority.
- "Active Compost" means compost feedstock that is in the process of being
rapidly decomposed and is unstable. Active compost is generating temperatures
of at least 50 degrees Celsius (122 degrees Fahrenheit) during decomposition;
or is releasing carbon dioxide at a rate of at least 15 milligrams per gram of
compost per day, or the equivalent of oxygen uptake.
- Chipping and Grinding is defined 17862.1
- Must be moved in 48 hours or 7 days as approved by EA
- Green material composting operations and facilities are defined 17857.1
- Requires a full SWFP for a facility handling material greater than 12,500 cubic yards
|
