Environmental Protection Division Rules for Solid Waste Management Composting, Mulching, and Anaerobic Digestion Facilities

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1 Environmental Protection Division Rules for Solid Waste Management Composting, Mulching, and Anaerobic Digestion Facilities March, 2015 Chad Hall, EPD

2 Rule New rules for Composting, Mulching, and Anaerobic Digestion Adopted by DNR Board on May 20, 2014 Effective July 15, 2014 Require existing composting facility compliance by March 31, 2015

3 Rule Outline 1) Existing Facilities 2) Definitions 3) Exemptions 4) Feedstock Categories 5) Design and Operating Standards 6) Criteria for Siting 7) Permit Modifications 8) Testing

4 Existing Facilities Permitted Facilities Composting facilities are regulated either through a notification process (Permit-by-Rule) or an individual Solid Waste Handling Permit Permitted Composting Facilities 33 Permit-by-Rule Facilities (blue markers) 5 individual Solid Waste Handling Permitted Facilities (red markers) For updated lists, check:

5 (1) Existing Facilities Required to meet operating standards of this rule by 3/31/2015 Exempt from siting requirements No exemptions from compost testing requirements Major modification requires facility to fully comply with the Rules

6 (2) Definitions Terms defined within the context of this Rule section Example: Agricultural Residuals only has meaning within , and has no meaning at, for example, a disposal facility or materials recovery facility

7 (3) Exemptions 1. Backyard composting 2. Composting/mulching only Category A feedstock 3. Less than 40 tons / yr of food residuals generated on site, composted in leak-proof containers etc. 4. Composting of on-site food residuals & yard trimmings at a K-12 school for educational purposes

8 (3) Exemptions 5. Composting of biosolids under NPDES, LAS, or other permit 6. Composting of dead animals in accordance with O.C.G.A. 4-5 and Georgia Dept. of Ag. Rules 7. Anaerobic digestion facilities permitted for Water Quality Control compliance 8. Manures managed in accordance with Water Quality Control

9 (4) Composting Feedstock Categories Category C: Biosolids Category A: Yard Trimmings Category B: Food Waste Categories are not all-inclusive. Unclassified feedstocks require analysis of metals and proof of compostability of the potential feedstock, including C:N ratio and soluble salts. Category D: DAF Skimmings

10 (4) Prohibited Feedstocks 1. Asbestos-containing wastes 2. Biomedical wastes 3. Painted and treated wood 4. Any other prohibited wastes from (6) 1. lead acid batteries 2. liquid waste* 3. regulated hazardous waste 4. radioactive waste 5. polychorinated biphenyls (PCB)

11 (5) Design & Operating Standards: Facility Class Based on Feedstocks Proposed amendment addresses the barriers identified during the stakeholder process, adds and amends definitions, and adds new section for exemptions Creates four feedstock categories (A, B, C, and D): Feedstocks Class Permit Required Category A Yard trimmings, land-clearing debris, agricultural residuals from on site Category B Source-separated organics and agricultural residuals from off site Category C Sewage sludge and biosolids Category D Dewatered septage and dissolved air flotation (DAF) skimmings Class 1 N ü Class 2 Permit by Rule ü ü (limited to 500 tons/month) (>75% from on-site) Class 3 Y ü ü Class 4 Y ü ü ü Class 5 Y ü ü ü ü Class 6 Y ü ü ü ü

12 (5)(a) Class 1 Facilities Process only Category A feedstocks Stand-alone facilities are exempt from permitting requirements Materials recovery rules on speculative accumulation apply At a permitted landfill, MRF, etc., a Class 1 facility can be added via minor modification Image from WSB/ajc

13 (5)(b) Class 2 Facilities Process Category A feedstock Category B feedstock limits: >75 % from on-site < 500 tons / month Operate under Permit-by- Rule Ex. UGA s Bioconversion Facility (right)

14 (5)(c) Class 3 Facilities Process Category A & B feedstocks Design standards (i) The composting facility shall be designed by a professional engineer licensed to practice in Georgia. (v) Required to have a PE to 1. design the facility 2. certify the facility is built in accordance with the permit (vii) include as-built survey prepared by surveyor

15 Class 3 Pad Requirements (ii) An all-weather compost pad shall be designed, constructed, and maintained to Largely performance based Promote run-off & limit infiltration of contact water Graded to direct contact water to containment (e.g, pond) Support vehicular traffic without degrading (iii) slope between 2% and 6%

16 Pad Degradation

17 Class 3 Grading Requirement (iv) Site graded to prevent the flow of water from active composting areas into curing or finished compost Case A Which is correctly designed? A or B? Case B Active Row Cured/Finished Cured/Finished Active Row

18 Financial Assurance (vi) Before any feedstocks can be received, owner/ operator must satisfy financial responsibility requirements* Financial assurance mechanism updates required: Annually for inflation Modifications to plan * The Act actually requires demonstration of financial responsibility prior to permit issuance in OCGA

19 Contact Water: Definition Contact Water has passed through or emerged from raw feedstocks and materials that are being processed (i.e. actively composting), cured, or finished; liquid that has come into contact with equipment that is dedicated to the composting or anaerobic digestion process (e.g., vehicular wash-water) condensate from gases resulting from the composting and the anaerobic digestion processes

20 Contact Water Management (viii) Contact water collection and removal systems shall be designed for incorporating the liquid back into the compost piles or for removal and treatment in a manner approved by the Division. Contact water is wastewater Collection system could mean any combination of ditches, pipes, ponds, tanks, etc. treatment could be handled by on-site treatment system, haul-and-treat, or as a permitted discharge

21 Contact Water Ponds Contact water ponds could be separated from ponds designed to manage stormwater runoff (example below)

22 Contact Water: on-site reuse (viii, cont.) Contact water may be used in the composting operation for moisture addition only in active compost piles that have not completed the process to further reduce pathogens. Adding contact water to compost resets the pathogen reduction process

23 Row sizing and spacing (ix) The maximum composting process windrow size and minimum composting process windrow spacing shall match the capability and requirements of the equipment used at the facility. All parts of active windrows or piles should be easily accessible for monitoring or turning (unlike at right) Image from radionb.com

24 Odor Minimization Plan (x) The composting facility shall submit a site-specific odor minimization plan that includes, at a minimum, the following: (I) A complaint response protocol. (II) A description of operating procedures for minimizing odor. (III) A description of the processes and technologies used to control odors. (IV) A description of procedures to monitor odor, including sampling frequencies and method(s) used to measure odors. Complaint response Operating record: time, address, nature of complaint Resolution and recommended action

25 (x)(ii) Odor Minimization: Operating Procedures (II) A description of operating procedures for minimizing odor. Minimize delays from receipt to composting Maintaining aerobic conditions Porosity Moisture Monitoring Turning schedules adjusted to minimize impact Recipe adjustment or reject troublesome feedstock

26 (x)(iii) Odor Minimization: Technologies & Processes (III) A description of the processes and technologies used to control odors. Forced aeration Filtration Masking agents

27 (x)(iv) Odor Minimization: Monitoring (IV) A description of procedures to monitor odor, including sampling frequencies and method(s) used to measure odors. Range of possible measures Qualitative survey of surroundings Installation of quantitative, real-time monitoring

28 Contingencies Plan (xi) The composting facility shall submit a contingency plan detailing corrective or remedial actions to be taken in the event of equipment breakdown; odors; unacceptable waste delivered to the facility; spills; and other undesirable conditions such as fire, dust, noise, vectors, unusual traffic conditions, and litter. The plan shall also include the proposed emergency provisions for equipment breakdown or power failure. Rental equipment Alternate providers of bulking agents Ability to transport excess material for disposal

29 Class 3 Operating Standards i. Operations managers with documented training ii. Manage storm water iii. Control vectors iv. Prevent, control, and extinguish fires Soil stockpiles may provide the most effective fire suppression

30 Feedstock Receipt (v) By the end of each operating day, all incoming Category B feedstock shall be processed into the active composting area, transferred to leak-proof containment, or mixed with bulking material and covered in a manner that minimizes nuisance odors and scavenging by vectors. Prior to being incorporated into the active composting area, feedstocks with free liquid shall be mixed with drier feedstocks, bulking material, or compost so that the liquid is promptly absorbed and not allowed to flow from the mixing area. Prefer that composting begins immediately on receipt Alternatives are possible as long as vector attraction and odor do not become issues Feedstocks (other than Category A) in storage/staging areas count toward the amount of waste on site à potential violations re: adequate financial assurance

31 Liquids Receipt and Handling (v) Prior to being incorporated into the active composting area, feedstocks with free liquid shall be mixed with drier feedstocks, bulking material, or compost so that the liquid is promptly absorbed Materials must pass the paint filter test prior to transport to the compost pad

32 Liquids Site is dry overall (top) but contact water is freely flowing from one windrow (right)

33 Process to Further Reduce Pathogens (PFRP) (vi)(i) Windrow composting: The compost material shall be maintained at a minimum average temperature of 55 C or higher for 15 days or longer. During the period when the compost is maintained at 55 C or higher, there shall be a minimum of five turnings of the windrow. The 15 or more days at or above 55 C do not have to be continuous. Document PFRP supporting tests in operating record Time-Temp. basis for pathogen destruction ( t >3 days, T >55 C) In windrows, T > 55 C only in an interior pile core (right) Five turnings sufficient that all material spends 3 or more days in pile core EPA (2003): Control of Pathogens & Vector Attraction in Sewage Sludge

34 Process to Further Reduce Pathogens (PFRP) (II) Aerated static pile or in-vessel composting: The compost material shall be maintained at a minimum average temperature of 55 C or higher for three consecutive days, followed by at least 14 days at over 40 C with an average temperature of over 45 C. (vii) Facilities using aerated static piles shall insulate piles to ensure that all parts of the decomposing material reach and maintain temperatures at or above 55 C for a minimum of three days. Document PFRP supporting tests in operating record EPA (2003): Control of Pathogens & Vector Attraction in Sewage Sludge

35 Class 3 Operating Standards (viii) The all-weather compost pad must be maintained to its specified slope and resist deformation that would cause ponding or increase infiltration of contact water. (ix) Storage of finished compost on site is limited to 12 months, unless approved by the Division on a case-by-case basis. (x) Non-compostable material and solid waste generated on site shall be stored in a waste container and then either recycled or disposed of at a permitted solid waste facility.

36 Class 3 Records / Reporting (xi) Records shall be maintained to track incoming feedstocks and finished compost. By September 1 of each year, operators shall submit a report to the Division that includes the weight or volume (in tons or cubic yards) of the feedstocks accepted, total compost produced, and any amount sold or used in the previous fiscal year (July 1 - June 30). (xii) Records documenting compliance of the composting facility with these Rules shall be kept for a minimum of three years in a form suitable for submission to or inspection by the Division. Records shall be retained at the composting facility unless an off-site storage location is approved by the Division.

37 (xiii) Updating Odor Minimization Revise if applying for a major modification Review annually: -If revisions needed, submit as minor modification (xiii)(iii) The odor impact minimization plan and results of the odor monitoring shall be used by the Division to determine whether the facility is following the procedures approved in its permit and its design and operational plan.

38 Facility Signage (xiv) The composting facility shall have a sign at its entrance that lists the name of the facility, permit number, days and hours of operation, feedstocks accepted, and emergency contact information.

39 Facility Closure (xv) The composting facility shall be closed in accordance with Rule Closure plans reviewed to determine costs for a third party contractor to: Remove all solid waste and dispose at MSWL Remove and treat all liquid waste Remove pad and/or assure soils are not contaminated Remove equipment

40 (5)(d) Class 4 Facilities Process Category A, B, & C feedstocks Must follow all design standards and operating standards of class 3 facilities plus: Additional design and operating standards for class 4

41 Class 4 Pad Requirements (I) The compost pad shall contain a layer to limit infiltration. This layer shall either be one foot in thickness with a hydraulic conductivity not exceeding 1x10-5 cm/sec or an approved alternative which meets or exceed this specification for the purpose of limiting infiltration. A minimum separation of five feet is required between the bottom of the infiltration layer and the seasonal high water table. Infiltration layer analogous to the compacted soil component of a landfill liner Determination of the seasonal high water table typically requires at least year of monitoring

42 Class 4: Contact Water Management (II) Contact water shall be contained in a tank with secondary containment or in an impoundment with a liner system consisting of a one-foot layer of compacted soil with a hydraulic conductivity of no more than 1x10-7 cm/sec. The liner shall be overlain by a protective marker layer of sand or stone no less than one foot in thickness. An alternate liner system with the equivalent ability to limit infiltration may be approved by the Division. This alternate ( grandfathered ) pond liner system (right) shows an infiltration layer and a protective marker layer

43 Class 4 Operating Standards I. Pad must be maintained and repaired Repairs must be certified by a PE May remain in operation as long as materials are kept off damaged areas and Run-on is diverted from these areas

44 Operating around Pad Damage Do not place compost or allow contact water to flow on a damaged pad Reconstruct pad following plan for original pad construction Pad Damage! Submit PE s certification for pad repair

45 Class 4: Biosolids regulations II. Facilities that compost biosolids or sewage sludge shall comply with all applicable federal regulations regarding sludge management at 40 CFR 501; 40 CFR 503; and 40 CFR 503, Subpart B.

46 Class 4: Groundwater monitoring (III) Groundwater monitoring systems shall be designed and installed in accordance with Monitoring parameters based on type of feedstocks accepted and waste characterization analyses Frequency: semi-annually, at a minimum

47 Class 4 Feedstock Receipt (IV) By the end of each operating day, all incoming Category B and C feedstocks shall be processed into the active composting pile, transferred to leak-proof containment, or mixed with bulking material and covered in a manner that minimizes nuisance odors and scavenging by vectors. Prefer that composting begins immediately on receipt

48 (5)(e) Class 5 Facilities Process Category A, B, C, & D feedstocks Must follow all design standards and operating standards of class 3 and 4 facilities plus Additional design and operating standards for class 5

49 Class 5 Operating Standards (I) The feedstock receiving and mixing areas shall be in an enclosed structure. The receiving area of the composting operation shall be constructed of asphalt, concrete, or a composite liner system. Receiving entrances shall be closed and under negative pressure during receipt and processing of Category D feedstocks. Floor designed to handle wet feedstocks and limit infiltration Minimize odors by limiting ventilation from this enclosure

50 Class 5 Feedstock Receipt (II) By the end of each operating day, all incoming Category B, C, and D feedstocks shall be processed into the active composting pile, transferred to leak-proof containment, or mixed with bulking material to minimize nuisance odors and scavenging by vectors. Prefer that composting begins immediately on receipt

51 (5)(f) Class 6 Facilities Process Category A, B, C, & D feedstocks Not covered in this presentation

52 Additional Rule Sections (6) Criteria for Siting Composting Facilities (7) Permit Modifications for Class 3-6 Facilities. Major Modifications Add new category of feedstocks Add new process (aeration, digestion, etc.) Add liquid solidification facility Expansion of the facility

53 (8) Testing Finished compost from Class 3-6 facilities must be tested Tests required for Stability Pathogen reduction Certain metals Testing frequency depends on amount produced

54 Questions and Comments For the official version of the Rules referred to in this presentation, see Send questions, comments, or corrections to me at Application forms, laws, and rules are online at