stakeholder meeting to discuss scope and key concepts november 19, 2010 1
TRANSCRIPT
Stakeholder Meeting to Discuss
Scope and Key Concepts
November 19, 2010 1
Introduction: Meeting Logistics
• Note sign-up sheet for attendees
• Microphone use
• Emails during live webcast should be sent to [email protected]
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Purpose of SSOM Rule ProcessRecognize 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
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IntroductionsIntroductions of attendees
Introductions of MPCA participants
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Compost Rules MPCA Mgmt. Team
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Compost Rules MPCA Staff Team
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Overview: SSOM Rule ProcessAPA 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
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Overview: SSOM Rule ProcessHow this meeting fits in the larger timeline, leading to publication of a draft ruleMeeting purposeTimeline of rule process
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Layout of Current Minn. R. 7035.2836: Two Tracks
Yard Waste Composting
Solid Waste Composting
Subp. 1. Scope Subp. 4. Design requirements
Subp. 2 Notification
Subp. 5. Operation requirements
Subp. 3 Operation Requirements
Subp. 6. Compost classificationSubp. 7. Compost distribution & end use
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Fitting SSOM into Current Compost Rule
Acceptable materials: yard waste only
Permitting: “Permit by Rule”
Notification: __ Pad: All-weather Training: Odor controls: Stormwater: Testing:
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Yard Waste(current)
Solid Waste(current)
SSOM(to be added)
• 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: __
IdeasSource 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
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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)
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SSOM Rule Concepts - Overall
Stringency of requirements might need to reflect how broadly the materials are that a facility can accept: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?
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SSOM Rule Concepts - OverallFeedstocks beyond yard waste and food: What about industrial by products from food processing (e.g. vegetable trimmings)?
What about industrial byproducts not from food processing (e.g. paper sludge from deinking mill)?
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SSOM Rule Concepts - ContinuedStormwater management requirements - carried forward from existing rules
Existing requirementsFlexibility when storm water managed on-siteLess 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 15
SSOM Concepts - ContinuedCurrently, 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
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SSOM Concepts, ContinuedQuestion to discuss: should MPCA offer lesser requirements for “small” SSOM facilities?What materials would be acceptable?
What site evaluation process would be acceptable?
What size or input limit?
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Subp. 1. Scope Discussion
What should scope allow for SSOM?Statutory definition (broad)Use in rule (narrower)Industrial waste streams?
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Subp. 1. Scope DiscussionFeedstocks
We are considering the following prohibited materials list.:Treated woods (they introduce metals)
Demolition debris (sheet rock, insulation, etc.)
Creosote or railroad tiesWhat about manufactured wood?
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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.
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Subp. X. Location Stds. Discussion
Should there be a minimal buffer distance?
Local government role?
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Subp. 8. Design Rqmts. Discussion
Size______Large (more requirements)______Small (less requirements)
Type
Windrows (aerated)Static Piles (non-aerated)In-vessel
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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)
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Subp. 8. Design Rqmts. DiscussionPad
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)
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Subp. 9. Operation Rqmts: Odor Control
Mixing food waste with bulking agentImmediately 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 requiredIf odor complaints, plan will be required to be
modified to include increasing odor mitigation steps (guidance document?)
Sampling and Analysis plan25
Subp. 9. Operation Rqmts. Discussion
Windrows (aerated)
Static Windrows/Piles (no mechanical aeration)
Maintain aerobic conditions 55° C for at least 3 weeks
Maintain aerobic conditions 55° C for at least 7 daysTurn at least once every 3-5 days
O2 requirements
Biofilter – VOC/control: approx. 6” to “12”, first 2-4 weeks (metro, non-metro??? Based on AQ classification)
Maximum windrow height (8’, 10’,12’ with/without biofilter??) 26
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?
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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
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Subp. 10. Compost Classification
Maturity testing – Solvita
STA requirements – additional detail on methods?
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Subp. 11. Compost distribution & end use
No change to current rule languageClass I
Unrestricted distributionComply with DOA Rule 18C.005, if sold as a
fertilizer, specialty fertilizer, soil amendment or plant amendment
Class IIRestricted distribution – commissioner
approvalDocuments required for use
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Closing ThoughtsThere will be plenty of opportunity in
months to come for more public engagement
Keeping the scope focused on clarifying technical requirements suitable to SSOM composting will help this rulemaking move more quickly
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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
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Closing ThoughtsSSOM 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
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Closing Thoughts
Fixing the larger economic problem will need new action by policymakers at county level and in Legislature
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Questions?
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