infoCycling, Summer 2001

In this issue:
What disposal reporting means to your jurisdiction
What is disposal Reporting?
The effects on goal measurement
Cooperation is important
What's happening
Allocating of SB 2202 on disposal reporting
EAR facts
Editor's note

Disposal reporting and what it means to your jurisdiction

This issue of infoCycling focuses on the Board’s disposal reporting system––what it is, its place in waste management, and why it’s important for goal measurement. You will read about complexities surrounding disposal reporting as well as procedures the Board has developed and implemented to improve disposal reporting. We also provide examples of how local jurisdictions have used innovative approaches to improve disposal reporting. Also included in this issue is an update of the Board’s effort to evaluate and improve the accuracy of the disposal reporting system through Board-facilitated working groups, mandated by SB 2202 (Committee on Environmental Quality, Chapter 740, Statutes of 2000).To create a new page, copy this and paste it where you need it, then add your text and rename it.

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What is disposal reporting?

The Board’s disposal reporting system tracks landfill disposal amounts by county or regional agency. With the passage of AB 2494 (Sher, Chapter 1292, Statutes of 1992), measurement of 25 percent and 50 percent diversion was changed to a disposal-based measurement system and the Board was required to establish a mechanism to track disposal tonnages. Under the disposal-based measurement system, jurisdictions are required to use the reported disposal information to calculate their diversion rates.

The Board’s disposal reporting system, which took effect in 1995, requires each operator of permitted solid waste disposal facilities (landfills, transfer stations, materials recovery facilities, and transformation facilities) to report disposal data to the county or regional agency. Counties or regional agencies, in turn, report these disposal tonnages each quarter to the Board and to the jurisdictions disposing waste within its boundaries.

Waste origin information is key in determining jurisdictions’ disposal amounts.

Waste origin refers to the city, county, or regional agency in which the waste was produced. Title 14, California Code of Regulations, sections 18805–18810, require that waste origin information be gathered, at a minimum, for one week in each quarter of the year for all solid waste disposed at a solid waste facility.

Solid waste facility operators are required to obtain information from all loads from residential and commercial haulers on where the waste originated (city, county, or regional agency) during the following required survey week periods:

March 8–14
June 8–14
September 8–14
December 8–14

Counties may request that operators conduct more frequent surveys or may impose more restrictive requirements on facility operators, such as surveying and weighing every load every day.

During the quarterly survey week period, operators must collect data on the amount of waste received for disposal from each jurisdiction.

Waste amounts are totaled for each jurisdiction where the waste is assigned. The operator divides the amount received from each jurisdiction by the total amount of waste received for disposal from all jurisdictions at its facility and arrives at a percentage of waste disposed by each jurisdiction. The percentage of waste disposed for each jurisdiction is extrapolated for the quarter to estimate waste disposed for each jurisdiction for that quarter.

Every facility operator reports each jurisdiction’s waste origin and estimated amounts to the county or regional agency disposal report coordinator each quarter.

Disposal reports include the city or county the waste originated in and the estimated amount of waste disposed by each jurisdiction or region.

The amount of material segregated for use as alternative daily cover (i.e., Board-approved materials other than soil used as a temporary overlay on an exposed landfill face) is reported in the quarterly reports, but it is tracked separately as alternative daily cover (ADC), not as disposal.

Finally, counties or regional agencies report jurisdiction-estimated disposal amounts to the affected jurisdictions and to the Board for input into the Board’s disposal reporting system. Jurisdictions must use these disposal numbers when calculating their diversion rates.

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How does disposal reporting affect goal measurement?

The Integrated Waste Management Act of 1989 (AB 939, Sher, Chapter 1095, Statutes of 1989 as amended [IWMA]) requires each jurisdiction to report annually on its progress in implementing diversion programs and in achieving the diversion mandates.

Disposal estimates are one component in determining diversion goal achievement for compliance with the IWMA.

Originally, jurisdictions were required to quantify waste generation in their base year (generation=disposal + diversion). The “base year” is the foundation for diversion rate estimation.

Jurisdictions would have been required to measure disposal and diversion in 1995 to determine if they met the 25 percent diversion goal; they would perform the same task in 2000 to determine if they met the 50 percent diversion goal. Measuring generation proved very difficult and costly in the base year. The solution to this difficulty was to redesign the measurement system.

AB 2494 changed the measurement system from measuring diversion and disposal to measuring disposal reduction and performing systematic tracking of jurisdiction disposal amounts.

A jurisdiction determines diversion goal achievement by comparing its disposal amounts, as measured by the disposal reporting system, to its projected waste generation.

The projected waste generation takes into account impacts of changes in population and economics, which affect waste generation. The comparison of the report-year generation amounts to the report-year disposal tons yields the disposal rate.

For a jurisdiction to increase its diversion over time, its yearly disposal tonnages should decrease or remain stable in proportion to the amount of waste the jurisdiction is generating.

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Why is cooperation from all participants important to disposal reporting?

California jurisdictions dispose more than 35 million tons of waste a year. There are currently 186 permitted landfills, more than 300 active permitted transfer stations, and hundreds of haulers in California.

California is a large and diverse state when it comes to waste disposal. Each region, whether urban or rural, industrial or commercial, coastal or mountainous, has its own unique disposal characteristics.

Since the implementation of the disposal reporting system, we have found waste flow to be complex, involving many complicated jurisdiction boundaries and many levels of reporting. Dynamic waste flow can fluctuate dramatically from week to week, season to season, and year to year. The disposal reporting system relies on waste origin and tonnage allocation information.

The accuracy of this data could greatly affect a jurisdiction’s diversion rate. Disposal reporting is dependent on information from a multitude of sources, including:

• Waste haulers, both commercial and municipal.
• Self-haulers.
• Landfill operators.
• Transfer station operators.
• Materials recovery facility (MRF) operators.
• Transformation operators.
• County disposal report coordinators.

(See flow chart below.)

California has diverse geography, population, and economic areas, and many reporting entities. The cooperation of all parties involved is critical to ensure the integrity of the disposal reporting system.

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What’s happening in disposal reporting?

On November 17, 1999, the Board held a disposal reporting workshop to discuss best practices and potential solutions regarding the Board’s disposal reporting system. Discussions covered issues related to:

• Capturing accurate waste origin information from waste haulers and self-haulers.
• Allocation of waste among jurisdictions.
• The accuracy of the estimates of reported disposal tonnage.
• Handling special waste disposal reporting.

As a result of the comments received at this workshop, Board staff began gathering more data and information on jurisdiction disposal reporting activities:  

• Random surveys of solid waste facility practices for collecting origin information from self-haulers at landfills, transfer stations, and materials recovery facilities throughout California are regularly conducted.
• A telephone survey of landfill operations has yielded information on how disposal data is tracked and verified, including the frequency of waste origin surveys.
• Finally, audits of landfill records assist Board and jurisdiction staff in assessing and resolving jurisdiction allocation and accuracy issues.

Board staff members conduct site visits during survey weeks to help improve disposal reporting accuracy

Because of concerns raised at the November 1999 DRS hearing about self-haul, the Board decided to take a closer look at what occurs at the disposal facility gatehouse, the first point of contact between the self-hauler and the disposal facility staff.

During the survey weeks of July, September, and December 2000, and March 2001, Board staff conducted random unannounced site visits at more than 200 facilities (landfills, transfer stations, and MRFs) in 40 counties.

At each facility visited, a driver would arrive in a small pickup truck or similar vehicle with a load of waste, representing himself or herself as a local residential self-hauler.

The purpose was to observe the survey practices for residential self-haul vehicles at solid waste facilities, anticipating the important question, “Where is your waste from?”

(Public Resources Code section 41821.5—added to statutes by AB 2494—requires all solid waste haulers, transfer station operators, disposal facility operators, and counties to gather information on the jurisdiction of origin of solid waste disposed at landfills.)

The Board staff recorded what waste origin questions, if any, the gate attendant asked.

We must emphasize here that, at this time, residential self-haul is the only sector of the disposal waste stream that the Board has evaluated in this manner.

According to the Board’s 1999 statewide waste disposal characterization study, self-haul comprises about 13 percent of the disposed waste stream, with commercial self-haul accounting for approximately 10 percent and residential self-haul contributing about 3 percent.

Of the facilities visited for the residential self-haul vehicle origin survey:

• 58 percent asked waste origin questions in June 2000.
• 73 percent asked waste origin questions in September 2000.
• 70 percent asked waste origin questions in December 2000.
• 72 percent asked waste origin questions in March 2001.

After each site visit, the operator receives a follow-up letter on the findings of the survey observations. If no waste origin questions are asked, the letter requests the operator to explain the facility’s procedures for obtaining the waste origin information.

A number of facilities that did not ask waste origin questions have been revisited in subsequent survey weeks. The results of revisits have indicated marked improvement (though not 100 percent) in complying with the waste origin survey requirements.

In the December 2000 survey week period, 67 percent of those facilities that did not previously ask for waste origin information from the self-hauler did ask waste origin information. In the March 2001 survey week period, 78 percent of the facilities that did not previously ask for waste origin information from the self-hauler did ask waste origin information.

From these facility site visits we have learned that:

• Facility operators, overall, want to comply with waste origin survey requirements and are willing to make changes in their procedures to meet the requirements.
• For the first facility site visits, some gate attendants did not know of the waste origin requirement or what the waste origin survey is used for.
• Most gate attendants that asked waste origin questions generally ask where the self-hauler is from, rather than where the waste is from. More gate attendants are asking where the waste or load is from. Asking the question about the origin of the waste or the origin of the load is more likely to get a true account of the waste origin.
• More facility operators are now conducting daily surveys for every load of waste, rather than conducting the surveys one week per quarter.

Other discoveries we’ve made through these site visits are the many innovative practices for collecting waste origin information. Many of these practices that are currently being used by operators are relatively simple to implement and effective as well. Some good examples are listed below.

• Post signs explaining a survey week is underway and waste origin questions are being asked.
• Post signs in multiple languages to eliminate language barriers between gatehouse attendants and haulers.
• Distribute information flyers to all customers explaining the purpose and importance of survey week.
• Request a utility bill or a rent receipt to verify the origin of self-haul customers.
• Estimate an average weight for self-haul vehicles by randomly weighing a percentage of the self-haul vehicles. This information can be used to estimate the weight for incoming unweighed self-haul vehicles.
• Place decals with the vehicle's empty weight on the inside door of regular customer self-haul vehicles. This information can be used to obtain an accurate weight of the waste.
• Request and record self-haul business licenses. This information can be used to double-check the validity of the license to do business in the jurisdiction from which the waste is being reported.

The practice of random unannounced site visits during the year 2000 survey weeks proved to be successful in reminding landfill operators the importance of asking waste origin questions.

How the information is obtained—based on the waste origin questions asked—can help the facilities report accurate disposal tons to the county or regional agency disposal report coordinators.

Landfill telephone survey on waste origin frequency

Board staff recently conducted a telephone survey of landfill practices, asking operators how often they conducted origin surveys. Ninety-six out of 143 landfills voluntarily responded to a series of questions, including:

1. How often does your facility conduct origin surveys?
2. Do you use the same survey for self-haul as for commercial haulers?
3. Do you have scales?
4. Do you weigh self-haul and commercial loads?
5. Do you use computers to track data?

The following are preliminary findings from the telephone survey (96 out of 143 responses).

Landfills conducting origin surveys:

• 77 percent conduct daily origin surveys.
• 8 percent conduct origin surveys only during the survey week.
• 8 percent conduct daily origin surveys only for commercial loads.
• 6 percent either do not accept public waste, or all waste loads are assigned to the host jurisdiction.

Scale use by all facilities:

• 58 percent weigh both commercial and self-haul loads.
• 23 percent weigh commercial loads only.
• 10 percent did not respond.
• 7 percent either do not have scales or do not use scales for either self-haul or commercial loads.

Methods used to verify origin data:

• 76 of the 96 operators responded.
• 80 percent do not verify waste origin.
• 8 percent require a driver’s license/other identification or utility bill.
• 4 percent accept other form of verification.
• 2 percent require pre-purchased ticket.

What’s next?

We will periodically conduct the telephone surveys to update the information reported to us as a way to monitor landfill practices of conducting origin surveys, their use of scales, and methods to verify origin information.

This information, reported to us by the landfill operators, will be used to verify actual observations of how origin surveys are conducted at landfill sites. It will also help confirm practices of scale use.

Innovative solutions to waste allocation challenges

Allocation issues?  Get involved in survey week!

Challenges

San Mateo County wanted to:

• Determine if waste was being correctly allocated to jurisdictions.
• Acquire an improved understanding of the waste stream.
• Identify any potential problem areas such as excessive construction and demolition (C & D) waste.
• Educate the drivers on how to correctly identify the origin of self-hauled waste.

Solution

Although Ox Mountain Landfill staff conducts daily waste origin surveys of franchised haulers, county staff decided that a one-week survey of self-haul drivers would help in understanding and resolving allocation issues and would increase confidence in the data received from the landfill. 

Those with an interest in the allocation of waste at the landfill were encouraged to participate on the survey team and to watch the allocation process in action. City and county staff and hauler representatives worked together to conduct the survey for one full week.

The survey concentrated on debris box loads and self-hauled waste. A survey team member asked each driver questions from a standard survey form and recorded the responses. The information was compared with the gatehouse attendant’s receipts. Some survey information was noted from observations, such as the type of vehicle, the name of the company, and contents of the load.

Each driver was also given a letter describing the purpose of the survey, the importance of waste reduction, and their recycling options.

Below are some of the questions that drivers were asked:

• What city or county is that load from?
• What is in your load? What do you have the most of?
• Is the waste residential or commercial? (If it is commercial, what is the name of the business?)
• What is the address the waste is from?
• How often do you haul waste to this landfill?

Results

The survey assisted San Mateo County in:

• Educating all participants on the survey team about the amount of waste coming into the landfill and the actual process of allocation.
• Increasing awareness of the need for waste reduction and, by observation, of the magnitude of the waste stream.
• Acquiring knowledge of issues not known prior to the survey and offering the opportunity to resolve these issues.
• Raising the confidence in the data that is received from the landfill.

If you have questions or would like more information, contact Jill Boone of San Mateo County at (650) 533-1433 or jboone@co.sanmateo.ca.us.

Create an electronic tracking system to improve waste origin information accuracy!

 Challenge

Riverside County’s challenge was to report accurate disposal information to jurisdictions using Riverside County landfills. County representatives tried different approaches to eliminate errors in disposal reporting at landfills located in the county.

One approach was to require commercial waste haulers to carry daily placards with that day’s route number to identify the origin of waste for the landfill gatehouse attendants.  However, the system had some shortcomings.  Holidays and driver errors threw the daily placard system off track.

Solution

Riverside County implemented a three-part ticket system to track the waste origin information and disposal tonnages from commercial waste haulers. At the landfill gatehouse, all trucks were weighed and the weight and waste origin information was recorded on the three-part ticket.

Two parts of the ticket were sent back to the dispatcher via the driver, and the scale house attendant kept one part to send to the office. Once the dispatcher received the two parts of the ticket, he or she would fill in the breakdown of the waste origin for that particular truck. The dispatcher then mailed one part of the ticket back to the county office within five days of the transaction.

This system proved to be very successful and more accurate, but it also added a tremendous data entry workload for the county office staff. To improve this system, Riverside County implemented an electronic version of this system.

Riverside County equipped waste haulers and landfills with a new innovative computerized waste origin tracking system, which included e-mail. The county also trained waste haulers on how to use the electronic tracking system to track waste origin information and disposal tonnages.

The electronic tracking system process is as follows:

1. Every load is weighed at the scale house.
2. Load information (weight and truck number) is recorded into the computer system and is instantaneously sent to the county office.
3. Load information is sent to each of the waste hauling company dispatchers via e-mail within two to three days by the county. The dispatcher enters the origin of waste for each truck from the previous day.
4. Weight and waste origin information is sent back to the county from the dispatcher electronically and then transferred into the systems database. The county uses the computer system to produce allocation reports.

5. All information sent by e-mail is encrypted for security purposes.

Results

This electronic tracking system has:

• Improved accuracy by having the dispatchers enter their own origin information.
• Eliminated a substantial data entry workload for county staff.
• Increased the response time by sending all information electronically.

Riverside County’s new tracking system proves to be an effective way to accurately track waste origin information and disposal tonnages. Self-haul waste is added to the data in the electronic system based on information collected from the self-hauler.

If you have questions or would like more information, contact Stacey Hubbard of Riverside County at (909) 955-1367.

Need a system to track disposal tonnages in remote rural areas? This system may work for you!

Challenge

Riverside County has a special challenge in tracking self-haul waste at landfills located in remote rural areas. These landfills are not equipped to support a computer, phone line, or scales. Most, if not all, residents must haul their own waste to the landfill because there is no mandatory collection.

Solution

Riverside County successfully implemented a punch card system that tracks waste origin information without the aid of a computer and without the exchange of cash.

The steps in using the punch card system are explained below.

1. Before visiting the landfill, a self-haul customer (commercial or residential) must fill out an application and purchase a punch card from the county. Punch cards are available in multiple tonnage amounts depending on the hauler’s needs.  For example, a card can be purchased with 52 available punches in which each punch represents 400 pounds of waste per punch. If the customer has more than 400 pounds of waste, two or more punches from the card may be necessary. The franchise haulers do not have punch cards. Instead, they have accounts and agreements with the county. The origin of waste from these haulers is known to be from the unincorporated county with the exception of a small amount of waste from Imperial County. The hauler rate is based on an average for the vehicle type that is brought in, and the hauler pays a per ton fee.

2. After the customer presents the punch card to the landfill’s gatehouse attendant, the attendant records the customer number and name from the punch card and punches out the appropriate tonnage on the card. The attendant also records the type of refuse and the number of punches on the cards that come into the landfill on a daily basis.

3. On a weekly basis, a county representative picks up the information recorded by the attendant and enters it into the tracking system at Riverside County's main office.

4. After a customer exhausts a punch card, the customer must purchase a new punch card from the county.

Result

This has shown to be an easy, effective way of tracking waste origin and disposal tonnage information in Riverside’s remote rural areas.  Riverside County operates all such remote landfills in the county, which makes this type of program easily implemented.

If you have questions or would like more information, contact Stacey Hubbard of Riverside County at (909) 955-1367.

Establish a nonexclusive franchise program!

Challenge

The City of Vernon, an industrial city in Los Angeles County, experienced significant fluctuations in their reported disposal tonnage, causing them to question the accuracy of the reported data.

Solution

The City of Vernon has recently implemented a non-exclusive franchise program for approximately thirty commercial waste haulers that operate within the city limits. As part of this program:

• Waste haulers submit a quarterly solid waste report to the city including their gross receipts and tonnages.
• Waste haulers pay a franchise fee of ten percent based on their gross receipts.
• The city routinely compares the tonnage information from the solid waste report to the tonnage reported by landfills. This comparison assists the city in locating significant differences between the amounts reported to the landfill and the amounts reported directly to the city.
• The city provides individual technical recycling assistance to the 1,500 businesses in Vernon using funds from the franchise fee collected.
• The city periodically performs on-site reviews of waste haulers to verify the accuracy of the franchise fees paid and to confirm the tonnage reported. In these on-site reviews, the city uses the waste hauler’s information (i.e., size and number of bins and the frequency of pickup) to verify the accuracy of the tonnage reported to the city.

Results

By implementing this non-exclusive franchise program:

• Vernon has developed a method to verify data, improving the accuracy of disposal reporting within the city.
• Vernon now provides technical recycling assistance to individual businesses.

If you have questions or would like more information on this program, contact Lew Pozzebon of Vernon in Los Angeles County at (323) 583-8811.

Forming a regional agency can reduce your disposal reporting workload!

Challenge

Waste from the five jurisdictions and unincorporated areas in Amador County was being unequally assigned and allocated. These errors were causing a fluctuation in disposal tonnage for each of the jurisdictions each quarter in Amador County.

Solution

Amador County formed a regional agency in 1999 to increase its disposal reporting accuracy and to calculate a more precise regional diversion rate.

Results

Forming a regional agency proved to be successful in helping to solve waste allocation problems in Amador County. The benefits of this regionalization include:

• Eliminating incorrect waste allocation to jurisdictions.
• Eliminating individual reports (annual report, source reduction and recycling element, and household hazardous waste element revisions) to the Board.
• Existing local waste management authority or other agreements are unaffected.
• Improving annual report accuracy at a reduced cost to jurisdictions.
• Improving traffic flow at the disposal facilities and the service to commercial and non-commercial waste haulers.
• Reducing the burden on operators to track waste origin information for each of the five jurisdictions during survey week.

If you have questions or would like more information, contact Dennis Grady of Amador County at (209) 223-6546

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Allocating waste from a materials recovery facility (MRF) or transfer station recovery process

Here are the results of that survey. From the 26 responses received, we found in general that there is no one perfect system. Methods used by jurisdictions differ with each facility.

First, we learned that for some jurisdictions, allocation of residual waste is not a problem because all residual waste is reported to only one jurisdiction within the county or reporting agency.

This system is typically used when the facility (transfer station or MRF) exists well within a county or reporting agency region and there is little chance that any other jurisdiction will deliver waste to that facility.

Also, other jurisdictions using a MRF or transfer station haul all of their own residuals back to the landfill. This system is typical of county or regional agencies whose facilities only serve one or two jurisdictions. Each jurisdiction hauls its own residuals, to be counted as disposal at its own landfill facility.

The two most frequently used methods, based upon survey responses, are described below.

Allocation of residual waste based on the percentage of incoming waste

This is the most popular method identified in responses to our survey.

This method relies on a simple calculation using the already known percentage of total waste brought in by each jurisdiction. It is probably the most cost-effective and easy approach to allocate residual waste. For example:

If two jurisdictions bring waste into a MRF and one jurisdiction brings in 70 percent of the total waste processed—while the other brings in 30 percent—then 70 percent of the residual waste would be assigned to the first jurisdiction and 30 percent to the second jurisdiction. (See flow chart below.)

This method may not be as accurate if the waste from different jurisdictions contains very different amounts of materials that can be recycled. For example:

If two neighboring jurisdictions use the same transfer station or MRF but one jurisdiction is predominately residential—while the other jurisdiction is only industrial—the amount of recyclables recovered from each of these jurisdictions waste may vary greatly.

Allocate residual waste based on waste characterization of incoming materials, and determine a percentage based on that characterization

The second most frequent method is to conduct waste characterization studies to determine the allocation of residual waste.

Many jurisdictions are conducting these studies as often as once a quarter.

These studies help determine the percentage of the waste stream that contains recyclable materials. For example:

If a jurisdiction has characterized its waste stream as containing 70 percent recyclable materials, then 30 percent of its total tons processed would be assigned as disposed residual waste.

However, if another jurisdiction uses the same MRF or transfer station facility and performs its own study characterizing its waste stream as containing 90 percent recyclable materials, then only 10 percent of its total waste processed would be assigned as disposed residual waste. (See flow chart below.)

Respondents who are currently using this method stated they were, in general, extremely satisfied with the results of residual allocation using this system.  However, respondents also stated that these frequent studies are quite costly and require a substantial amount of staff time to oversee and implement.

Therefore, jurisdictions should be aware that this method might require additional substantial resources to implement.

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How does SB 2202 affect disposal reporting?

Legislation enacted last year, SB 2202 (Committee on Environmental Quality, Chapter 740, Statutes of 2000) requires the Board to establish, at a minimum, a working group to evaluate the disposal reporting system (Public Resources Code section 41821.5).

It also requires the Board to prepare a report with recommendations for changes and improvements to be submitted to the Legislature on or before January 1, 2002. The report is to include:

• An evaluation of the accuracy of the disposal reporting system under differing circumstances.
• The status of implementation of the disposal reporting system at the local level by waste haulers, landfill operators, transfer station and materials recovery operators, and local agencies.
• The need for modification of the disposal reporting system to improve accuracy.
• Recommendations for regulatory and statutory changes needed to address deficiencies in the disposal reporting system.
• Recommendations to improve implementation and to streamline the reporting system, including ways to assist agencies to meet the reporting and tracking requirements.

As stated previously, disposal reporting is only one component of the diversion rate measurement system.

Another critical part of the diversion rate measurement formula is the adjustment method formula that affects a jurisdiction’s waste generation. The formula uses factors including population and economic factors such as taxable sales and the consumer price index.

Recognizing that disposal tonnages are only one component in calculating a jurisdiction’s diversion rate, the Board in December 2000 directed staff to evaluate the entire diversion rate measurement system. This evaluation includes the adjustment method formula along with the disposal reporting system.

The Board convened working groups composed of representatives of stakeholder groups including cities, counties, regional agencies, the solid waste industry, recyclers, consultants, and environmental organizations to assist the Board in preparing the report. Each of these groups met several times to analyze data and develop recommendations.

Data reviewed in the DRS working group included the site visits and landfill survey data presented in this issue. Other topics covered are described briefly below.

Origin survey data analysis

SB 2202 requires that the Board evaluate the accuracy of the disposal reporting system under differing circumstances.

Some have described this as determining a “margin of error” for DRS. The DRS working group evaluated origin survey data from a study conducted for the Board in 1997 and from 2000 data provided by Riverside County.

The data showed potential error resulting from using one-week origin survey tonnage data versus actual daily recorded tonnage data. This data may not be representative of all counties, and more data from more counties is needed to conduct a thorough analysis. However, analysis of this data does provide several indicators.

First, extrapolating one-week tonnage data results in estimates that are both higher and/or lower than actual tonnage. Second, it appears that smaller jurisdictions are the most adversely affected by DRS errors. Third, the longer the survey period, the more precise the allocation of waste. Finally, some errors are not quantifiable. Thus, creating a reliable “margin of error” percentage for DRS data is not feasible.

DRS patterns and trends analysis

The DRS working group also looked at an analysis of disposal trends. The purpose of the analysis was to determine whether trends and patterns exist in jurisdictional data.

In this analysis, “patterns” included seasonal variations, whereas “trends” described increases or decreases in waste tonnage over several years. Outliers in disposal patterns and trends were identified to determine which jurisdictions have potential accuracy issues.

As a result of the analysis, the working group arrived at several conclusions.

First, quarterly DRS disposal is highly variable at the jurisdiction level. Some jurisdictions show strong patterns or trends, while others show no patterns or trends at all. Second, countywide patterns and trends are generally more stable than jurisdiction data, and most potential outliers disappear when the data is aggregated to the county level. However, smaller counties with annual disposal of less than 60,000 tons may not have more stable countywide data. Finally, in counties where daily waste origin surveys are conducted, even the smaller
jurisdictions have fairly stable disposal, with less variability and fewer potential outliers.

Inert landfills

Working group members were concerned about the inequity in what counts as disposal at inert landfills. The DRS system only tracks disposal at permitted facilities.

Local agencies have required some inert disposal facilities to obtain a solid waste permit to ensure groundwater protection while other similar inert disposal facilities are not required to obtain a permit. Thus tons disposed at an unpermitted facility effectively count as diversion in a disposal-based measurement system.

Special waste

Special waste consists of waste types such as non-friable asbestos, sludge, auto shredder fluff, petroleum contaminated soil, and ash, typically requiring disposal in Class II landfills or Class II cells in landfills.

Each regional water quality control board and air district determines if special waste materials may be used beneficially or must be disposed. This means the same waste type can count as disposal or diversion depending on the environmental protection regulations in effect at a disposal site. There is no consistent method for tracking these materials.

Some jurisdictions were not aware of special waste when they originally did their waste generation studies. The inclusion of these waste types in reporting-year disposal has been problematic for jurisdictions that did not include the waste types in their base-level generation. Consequently, some jurisdictions have seen significant drops in their diversion rates due to disposal of special wastes.

Businesses, rather than jurisdictions, usually control which facilities receive special waste. Additionally, there are few diversion opportunities for special wastes, and jurisdictions do not want to be penalized for waste they cannot divert.

Alternative daily cover (ADC) use

The use of ADC for waste diversion at solid waste landfills has been subject to significant debate and controversy since the development of related Board policies in the early 1990s.

Potential overuse of ADC has been a concern of some stakeholders primarily because of the impact on composting facilities that compete for feedstock with ADC usage.

Board staff conducted an evaluation of ADC use reported to the DRS in the years 1995–99. The first step in the process was to determine who uses ADC.

Next, out of those that use ADC, staff calculated how much is claimed as a percentage of the total reported waste. Finally, the analysis looked to see if there were any trends in ADC use.

The analysis led the DRS working group to several conclusions.  First, there is a definite upward trend, statewide, in the claiming of ADC. Second, there does not appear to be any trend among the 30 counties that claim ADC. That is, it is unclear whether larger counties use a greater percentage of ADC than smaller counties. Furthermore, a county’s previous use of ADC does not predict its future use. Finally, Board staff has been conducting on-site evaluations at landfills throughout the state to assist in monitoring ADC usage and reporting.

Self-haul

The DRS working group was concerned with the amount of self-haul tonnage and self-haul traffic at solid waste facilities.

Many group members recognized that self-haul customers in cars and small pickup trucks transport only a minimal portion of the total waste disposed while contributing to delays in processing vehicles at landfill gates.

The County of Orange Integrated Waste Management department shared the results of a study that examined self-haul waste.

The County of Orange study tracked the number of self-haul loads per month, the pounds per load, and the total tons per month at the county’s three permitted active landfills from May 1998 through February 1999.

The results showed that self-haul customers in cars or small pickup trucks delivered only about 1.3 percent of the total tons disposed. Of all the loads brought to the landfill, almost a quarter of the loads were attributed to these smaller vehicles. The small vehicle self-haul customers delivered only 12 percent of all self-haul tonnage, commercial and residential.

The table “Orange County Residential Self-Haul Study” on page 22 was included in the County of Orange’s study. In this table, loads per month and tons per month were averaged for the three landfills and for the entire county.

The study concluded, based on the ten months of data, that if cars and pickup trucks were excluded from the DRS, the county could speed the processing of almost a quarter of the incoming vehicles. Further, the county could omit origin codes on 1.3 percent of the total tonnage at the landfills but would still capture 88 percent of all self-haul tonnage.

Orange County’s documented findings supported the claim that the small vehicle self-haul customers contribute little to the overall disposed waste stream, and yet they contribute considerably to delays at the landfill gates. Therefore, the group recommended that self-haul vehicles under one ton should be excluded from the DRS.

Report to the Legislature 

The following is the schedule for the Report to the Legislature—A Comprehensive Analysis of the Integrated Waste Management Act Diversion Rate Measurement System, which is to be forwarded to the legislature:

August 2001—30-day public review and comment on first draft

September 2001—Release of revised draft report

October 2001—Final report for Board consideration

January 2002—Final report due to Legislature

For a copy of the latest version of the report, visit the LG Talk forum on the Board’s Web site (http://forum.ciwmb.ca.gov:8080/~LGTalk) or call (916) 341-6227 to request a copy.

If you have questions about the SB 2202 process or on any of the working group recommendations, contact the following Board staff in the Waste Analysis Branch:

• Disposal reporting—Denise Hume at (916) 341-6242 or dhume@ciwmb.ca.gov 
• Adjustment method—Nick Cavagnaro at (916) 341-6213 or ncavagna@ciwmb.ca.gov.  
• Alternatives—Nancy Carr at (916) 341-6216 or ncarr@ciwmb.ca.gov 

If you have any questions about disposal reporting, contact Denise Hume of the Board’s Waste Analysis Branch at (916) 341-6242 or at dhume@ciwmb.ca.gov .

From the Board’s Local Government Central Web site (www.ciwmb.ca.gov/LGCentral/DRS/)you can access information such as:

• How the disposal reporting system is used.
• What is included in “disposal.”
• Disposal system highlights and reporting dates.

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Electronic Annual Report (EAR) Facts!

As of October 9, 2001:

• Annual reports submitted electronically: 312
• Jurisdictions logged in to EAR at least once: 390
• First annual report filed electronically: City of Albany, Alameda County, July 30, 2001.

Congratulations, Judith Lieberman! You filed the first ever CIWMB electronic annual report!

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Editor's Note

I hope you enjoyed this issue of infoCycling.

Look for articles in the Fall 2001 issue of infoCycling on waste diversion business outreach programs and the Basics on the Web.

Please contact me with suggestions on articles you would like to see included in infoCycling and announcements of events in your jurisdiction. I can be reached at (916) 341-6240 or at twebb@ciwmb.ca.gov. 

Your comments and suggestions on infoCycling are always welcome!

Tracy

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Last updated: November 01, 2007