By Wendy Wert
CWEA Training Coordination Committee Chair
and Jon Hay
CWEA Biosolids Committee Chair
Black & Veatch
On January 26, 2010, the California Water Environment Association (CWEA) Biosolids Committee hosted a specialty conference “Understanding Future Regulatory Trends and Impacts on Biosolids Management in California” at the Los Angeles Sanitation Districts Joint Administration Office in Whittier. This one-day biosolids specialty conference, which trained 76 people, consisted of a series of technical presentations separated by interactive discussions between leading experts and attendees. The morning session consisted of opening remarks and a review of the Part 503 regulations presented by the conference Chair, followed by six technical presentations. The innovative networking lunch also served as a venue for an update on Assembly Bill 32 and Green House Gas emissions standards (GHGs) presented by Patrick Griffith. The afternoon session, consisted of five technical presentations, and closing remarks delivered by the conference co-chair.
A total of 12 speakers gave presentations that covered a wide range of relevant topics, including current trends in biosolids regulations, application and limitations of the general order, an overview of the biosolids composting rule, county ordinances and local issues, national regulatory trends, impacts of air quality regulations, methods of managing biosolids that generate renewable power, and several case studies that demonstrated emerging technologies and illustrated successful regional solutions. The speakers also presented on these same topics at SFPUC in San Francisco on January 27. This event trained 160 CWEA members and non-members.
The conference began with CWEA Biosolids Committee and Conference Chair, Jon Hay’s opening remarks, which highlighted the overall goal of the training: to improve knowledge of and compliance with CA regulatory requirements, promote “Best Management Practices” for beneficial use, and encourage resource stewardship and environmental protection. He also described the specific objectives of the conference as follows: understand local and national trends, encourage information exchange and networking and “raise the bar” for the biosolids industry. The conference continued with a Part 503 Regulations Refresher. This topic spurred interactive discussions regarding biosolids classifications, biosolids are considered Class A if treated in one of the processes to further reduce pathogens (PFRPs) listed in Appendix B and either the density of the fecal coliforms is less than 1,000 MPN per gram total solids (dry weight basis), or the density of Salmonella sp. bacteria is less than 3 MPN per 4 grams total solids (dry weight basis). To be considered exceptional quality (EQ) the produce must meet two additional requirements (1) metals thresholds contained in Table 3 of Section 503.13 and (2) undergo one of the first eight processes for meeting vector attraction reduction (VAR) standards. An interesting observation that was discussed is that the 503’s apply only to anthropogenic material, for example animal wastes, which are prevalent in much larger volumes are not subject to the regulations. This has historically been an obstacle to co-mingling waste materials to enhance energy production.
Speaker Jerrod Ramsey-Lewis then gave the State Water Resources Control Board’s (SWRCB) perspective with a Biosolids The General Order and Other Regulatory Issues. Jerrod reviewed the complex biosolids regulation relationships here in California and explained the efforts of the SWRCB to streamline this regulatory puzzle. For example biosolids are subject to federal regulations (Code of Federal Regulations, Title 40 (Part 503) under section 405(d) of the Clean Water Act), state regulations (Porter-Cologne Water Quality Control Act, Basin Plans, Waste Discharge Requirements, and the California Environmental Quality Act), and local regulations (county ordinances and local restrictions). In 2004 the SWRCB adopted Programmatic EIR and Statewide General Orders (GO) in an attempt to streamline biosolids regulations. The GO authorizes land application of Class B biosolids. The GO is among the most restrictive statewide permits the beneficial use of biosolids through land application under the General Order is environmentally sound and preferable to non-beneficial disposal. Jerrod explained that the Statewide General Order has limitations, such as the cap of 2,000 acres for land application projects. In addition coverage is voluntary but not automatic. The GO also does not supersede local authority to regulate. As we look toward the future Jerrod compelled the biosolids community to embrace the “Resource Cycle” way of thinking. The SWRCB is generally supportive of innovative measures to reuse resources.
Speaker Greg Kester continued the regulatory discussion with a presentation for Ken Decio of the Department of Resources, Recycling, and Recovery (CalRecycle) titled California Composting and Alternative Daily Cover Rules for Biosolids. CalRecycle regulates the following biosolids uses: compost facilities, alternative daily cover (ADC) and final cover at landfills, landfill burial, and anaerobic digestion. A full permit is required for composting biosolids and green waste on or off site. Greg then provided an overview of the primary governing regulations contained in the California Code of Regulations (CCR). Title 14 sets state minimum standards for solid waste activities including collection, transfer, composting, contaminated soil treatment, and tire recycling facilities. It establishes a tiered permitting system for these types of facilities. Title 27 of the CCR incorporates federal requirements for safe disposal of solid waste and sets state minimum standards for both active and closed landfill sites (including ADC), as well as landfill permitting criteria. Sludge and sludge-derived materials are approved ADC in CA under Title 27. Greg reported that sludge and sludge derived materials accounted for only 6.2 of the ADC used statewide in California in 2008. Greg explained strategic directive 6.1, which targets a 50% reduction in the amount of organics in the waste stream by 2020. Over 15 million tons of organics, much of it compostable, needs to be recycled annually as identified in the CIWMB’s “Organics Roadmap”. This will require growing infrastructure (composting, anaerobic digestion, etc.) to manage this organic material. Greg explained how compostable material is defined. If material will generate temperatures of at least 122 degrees Fahrenheit then it is considered compostable. If less than 122 degrees, the activity is not subject to Compostable Materials regulations, but is subject to Transfer Station/Processing regulations. If a Publically Owned Treatment Works (POTW) accepts waste, the Transfer Station or Compostable Materials requirements will apply. The local enforcement agency (LEA) will set the type of authorization depending on the quantity and type of waste intended for anaerobic digestion.
Greg also reviewed some interesting new developments related to the structure of the California Integrated Waste Management Board (CIWMB) that came into effect on January 1, 2010. Senate Bill 63 (Strickland) eliminated the California Integrated Waste Management Board. The Division moved from the Department of Conservation to the Department of Resources Recycling and Recovery (CalRecycle) in the Natural Resources Agency. These changes are primarily administrative, functions are expected to remain the same. However, it will no longer be possible to appeal decisions to the board, rather appeals will be directed to the Deputy Director.
Speaker Liz Ostoich then moved the discussion from the regulatory basis of design to a “lessons learned” presentation titled Building a Successful Regional Project. Liz explained the factors that lead to failures when siting these facilities, which include poor location, lack of outreach, ignoring the political climate, avoiding public input, and shortcutting on quality. Liz described a bad attitude as the ultimate problem. Liz provided case studies that illustrated “what went wrong” and “what went right”. For example the 500 wet tons per day Temescal Canyon open windrow composting facility resulted in dashed expectations from your customers, opposition from the community, grief from the regulators and increased costs to hold it together, which are not recoverable. Whereas, the 500 wet tons per day South Kern aerated static pile composting facility is a glowing success as demonstrated by a letter of community support from Taft College to their Senator. Liz explained the factors that lead to success when siting these facilities, which include a change in attitude, selecting a remote location, recognizing that “sustainability” comes at a price, applying high end proven technologies, and applying essential mitigation measures such as odor control, water protection, emission reduction and conservation of resources. This facility processes biosolids for between $65 and $70/wet ton processed. Liz explained that hauling represents a significant portion of the overall processing cost. The current regional rate to haul biosolids is $2.50/wet ton per mile.
Speaker Mark Lawler presented another regional success story titled Biosolids Drying and Electric Generation Facility. Mark explained that the Ventura Regional Sanitation District (VRSD), an enterprise public agency organized in 1970 has developed a cost effective regional solution for Ventura County biosolids management. Prior to this project 90% of the biosolids produced in the county were exported. Now the facility processes 160 tons per day, which represents approximately 60% of the biosolids produced in the county. The project consists of two 80 ton/day Fenton batch dryers, eleven trailers, and a gas conveyance and cleaning system. Green energy is recovered by nine microturbines with a total of 2.25 MW of power capacity. Mark reported that the cost to process biosolids at this facility is $42/wet ton or $52/wet ton including hauling costs. The total construction cost of the facility was $19 million.
Speaker Jeff Ziegenbein presented another regional success story titled Inland Empire Regional Composting Facility(IERCF). This successful regional resource recovery solution is the result of a unique partnership between the Inland Empire Utilities Agency (IEUA) and the Sanitation Districts of Los Angeles County (LACSD). The project need was established by the South Coast Air Quality Management District rule 1133.2, which requires all composting activities to be performed in “fully enclosed” buildings. Operation of the largest fully enclosed composting facility in the United States began in April of 2007. The facility receives 590 tons per day of biosolids from IEUA and LACSD. Biosolids are combined with woody amendments and composed indoors using the aerated static pile method. The fully enclosed facility encompasses an area of 10 acres. Emissions from the process are controlled through a 3.1 acre biofilter, which is the largest in the United States. Innovative energy recovery features of the facility include solar panels located on the roof that result in 1 MW capacity. Jeff emphasized the need to establish value and expand markets for the compost product. Components of this plan include the production of one composted product that is run through various screening operations to produce three different products. The golf course grade product sells for $40 per ton. In addition there are two grades of SOILPRO products one sells for $5 per cubic yard and another sells for $3.50 per cubic yard. One way to ensure that the product maintains value is to be able to store the finished compost on-site, this allows the agency to sell the compost during plantings seasons when the price is competitive.
Other presenters covered several related topics and innovative regional solutions, as follows: Kevin Hardy, Encina Biosolids Heat Dryer case study; Ray Kearney, Rialto Slurry CarbTM case study; Layne Baroldi, air quality regulations; Omar Moghaddam, City of LA Biosolids Slurry Project TIRE case study.
Matt Bao summed up the theme of the event when he stated that the key to a successful biosolids management program is Diversity, Diversity, Diversity! Overall, the conference greatly enhanced the understanding and knowledge of the complex and changing California biosolids regulatory climate, keys to success and lessons learned when siting biosolids management facilities, case studies illustrating successes and challenges for regional resource recovery solutions. This unique learning opportunity fulfilled CWEA’s mission to train and disseminate technical information to wastewater professionals.