Mpca rulemaking project for source separated organic material ssom compost facilities
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MPCA Rulemaking Project for Source-Separated Organic Material (SSOM) Compost Facilities. Stakeholder Meeting to Discuss Scope and Key Concepts November 19, 2010. Introduction: Meeting Logistics. Note sign-in sheet for attendees Microphone use & note taking

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MPCA Rulemaking Project for Source-Separated Organic Material (SSOM) Compost Facilities

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Mpca rulemaking project for source separated organic material ssom compost facilities

MPCA Rulemaking Project for Source-Separated Organic Material (SSOM) Compost Facilities

Stakeholder Meeting to Discuss

Scope and Key Concepts

November 19, 2010


Introduction meeting logistics

Introduction: Meeting Logistics

  • Note sign-in sheet for attendees

  • Microphone use & note taking

  • Emails during live webcast should be sent to: [email protected]


Purpose of ssom rule process

Purpose of SSOM Rule Process

  • Recognize state strategy of moving organic material management up the hierarchy

  • Clarify regulatory requirements appropriate to SSOM composting facilities

  • Provide regulatory relief without jeopardizing environmental protection


Introductions

Introductions

  • Introductions of attendees

  • Introductions of MPCA participants

  • We want your opinion – we have made no final decisions


Compost rules mpca mgmt team

Compost Rules MPCA Mgmt. Team

  • Solid Waste Program Manager: Gary Pulford

  • Permitting Unit Supervisor: Paula Connell

  • Rulemaking Unit Supervisor: Dave Richfield


Compost rules mpca staff team

Compost Rules MPCA Staff Team

  • Rulemaking Coordinator - Yolanda Letnes

  • Engineering - Tony Bello

  • Hydrogeology related to siting - John Elks

  • Operations & compost testing - Ginny Black

  • Solid Waste Policy Expert - Jim Chiles


Overview ssom rule process

Overview: SSOM Rule Process

  • APA requirements must be followed, once formal process begins

  • MPCA is not yet in that formal process: has been working on scope and key concepts, along with fact-gathering


Overview ssom rule process1

Overview: SSOM Rule Process

  • How this meeting fits in the larger timeline, leading to publication of a draft rule

    • Meeting purpose

    • Timeline of rule process


Layout of current minn r 7035 2836 two tracks

Layout of Current Minn. R. 7035.2836: Two Tracks


Fitting ssom into current compost rule

Yard Waste

(current)

SSOM

(to be added)

Solid Waste

(current)

Fitting SSOM into Current Compost Rule

  • Acceptable materials: source separated yard, food and __

  • Siting: Min 5 ft to GW

  • Permitting: No change

  • Pad for compost: All-weather, unless __

  • Training: __

  • Odor controls: __

  • Stormwater controls: no change

  • Testing & product classification: no change

  • Acceptable materials: mixed solid waste, other ___

  • Siting: __

  • Permitting: Public notice, local role

  • Pad for compost: Impermeable

  • Training: __

  • Odor controls: __

  • Stormwater controls: __

  • Testing & classification of product: __

  • Acceptable materials: yard waste only

  • Permitting: “Permit by Rule”

  • Notification: __

  • Pad: All-weather

  • Training:

  • Odor controls:

  • Stormwater:

  • Testing:


Ideas

Ideas

  • Source Separated Organic Material (SSOM) must be source separated at the generator, not picked from Mixed Municipal Solid Waste (MMSW) at a transfer station or a landfill

  • Goal is not to develop excessively prescriptive standards, but outcome-based ones that are matched to the needs and any environmental or health risk


Ideas1

Ideas

  • Portions of Demonstration Agreement template will be used for rule (most current version)

  • Guidance documents to follow will fill in some of the details (e.g. technical standards on how to measure compaction)


Ssom rule concepts overall

SSOM Rule Concepts - Overall

  • Stringency of requirements might need to reflect material types accepted at the facility:

    • If the variety of SSOM to be accepted were to go beyond food and yard waste, does it make sense to require greater stringency for feedstock testing and monitoring?


Ssom rule concepts overall1

SSOM Rule Concepts - Overall

  • Feedstocks beyond yard waste and food:

    • What about industrial by-products from food processing (e.g. vegetable trimmings)?

    • What about industrial by-products not from food processing (e.g. paper sludge from deinking mill)?


Ssom rule concepts continued

SSOM Rule Concepts - Continued

  • Stormwater management requirements - carried forward from existing rules

  • Existing requirements

    • Flexibility when storm water managed on-site

    • Less flexible if storm water discharged off site

      Example, Industrial Stormwater permit requirement is triggered if:--Stormwater/leachate discharge off site, OR

      --Operator purchases feedstock materials, such as carbon for bulking


Ssom concepts continued

SSOM Concepts - Continued

  • Currently, Financial Assurance (FA) requirements are not planned, retain existing authority based on risk factors

  • Would continue to rely on current 503 standards, as modified in Minn. R. 7035.2836, Subp. 6A


Ssom concepts continued1

SSOM Concepts, Continued

  • Question to discuss: should MPCA offer lesser requirements for “small” SSOM facilities?

    • What size or input limit?

    • What materials would be acceptable?

    • What site evaluation process would be acceptable?


Subp 1 scope discussion

Subp. 1. Scope Discussion

  • What should scope allow for SSOM?

    • Statutory definition (broad)

    • Use in rule (narrower)

    • Industrial waste streams?


Subp 1 scope discussion1

Subp. 1. Scope Discussion

  • Feedstocks

    • The following list is being considering as prohibited materials:

      • Treated woods (they introduce metals)

      • Demolition debris (sheet rock, insulation, etc.)

      • Creosote or railroad ties

      • manufactured wood (glues)


Subp x location stds discussion

Subp. X. Location Stds. Discussion

  • Not on Karst (Anoka Sand Plain?)

  • 5’ minimum separation to water table

  • Flood plain? 7035.2555? Same as with composting.


Subp x location stds discussion1

Subp. X. Location Stds. Discussion

  • Should there be a minimal buffer distance?

  • Local government role?


Subp 8 design rqmts discussion

Subp. 8. Design Rqmts. Discussion

  • Size

    • ______Large (more requirements)

    • ______Small (less requirements)

  • Type

    • Windrows (aerated)

    • Static Piles (non-aerated)

    • In-vessel


Subp 8 design rqmts discussion1

Subp. 8. Design Rqmts. Discussion

  • Pad

    • Impermeable pad required only under certain circumstances

    • All weather work surface required (accessible for all seasons for management operations)


Subp 8 design rqmts discussion2

Subp. 8. Design Rqmts. Discussion

  • Pad

    • Soil infiltration necessary and verified every 5?-10? years with soil boring

    • Curing pad (may not)/(will not) need impermeable surface (in reference to using soil as a form of leachate management)


Subp 9 operation rqmts odor control

Subp. 9. Operation Rqmts: Odor Control

  • Mixing food waste with bulking agent

    • Immediately upon delivery of food waste, IF NOT,

    • Place a biofilter on food waste and mix and incorporate into windrow be end of working day

  • Odor Management Plan required

    • If odor complaints, plan will be required to be modified to include increasing odor mitigation steps (guidance document?)

  • Sampling and Analysis plan


Subp 9 operation rqmts discussion

Subp. 9. Operation Rqmts. Discussion


Subp 9 operation rqmts training

Subp. 9. Operation Rqmts. Training

  • Training with ceu’s required for facilities over XX size, if rule proceeds with a “big/small” approach

    • Need training only if greater than XX size

    • All should be trained?

    • Add as a permit requirement?

    • Training set out in rule language or Guidance?


Subp 10 compost classification

Subp. 10. Compost Classification

  • Use readily available test methods (bucket method & log of testing – this list kept up to date by guidance, not a list specified in rule)

  • Industry standard testing methods for finished product


Subp 10 compost classification1

Subp. 10. Compost Classification

  • Maturity testing – Solvita

  • STA requirements – additional detail on methods?


Subp 11 compost distribution end use

Subp. 11. Compost distribution & end use

  • No change to current rule language

    • Class I

      • Unrestricted distribution

      • Comply with DOA Rule 18C.005, if sold as a fertilizer, specialty fertilizer, soil amendment or plant amendment

    • Class II

      • Restricted distribution – commissioner approval

      • Documents required for use


Closing thoughts

Closing Thoughts

  • There will be plenty of opportunity in months to come for more public engagement

    • Contact rules staff during informal phase

    • Second stakeholder meeting to share preliminary draft in 2011

    • Formal public comment period when rule is proposed


Closing thoughts1

Closing Thoughts

  • Keeping the scope focused on clarifying technical requirements suitable to SSOM composting will help this rulemaking move more quickly


Closing thoughts2

Closing Thoughts

  • Minnesota’s source-separated organics-handling capacity (all types, from compost to animal feeding) is much too small to process up to 15% of the MSW stream if source separated as organics


Closing thoughts3

Closing Thoughts

  • SSOM rule clarification could help bring down the capital costs of future capacity (e.g. by cutting per-acre costs for compost pad)

  • But rules can’t fix other, key factors that drive up total composting costs compared to costs of cheap landfill disposal


Closing thoughts4

Closing Thoughts

  • Fixing the larger economic problem will need new action by policymakers at county level and in Legislature


Questions

Questions?


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