Composting Compliance Challenges for the Waste Management & Recycling Industry

With more than 30 years of experience in the solid waste and recycling industry, John McNamara of CR&R Environmental Services brings hands-on knowledge of how to manage the environmental compliance challenges facing communities and municipalities. In this week’s Coffee & Compliance webinar we dove into his experience with composting operations from anaerobic digesters to California’s combined composting regulations from the Water Board and CalRecycle.

From odor issues to stormwater runoff to groundwater impacts, composting operations need to comply with a never ending list of requirements that only will grow in complexity as California looks to increase by fourfold the diversion of organics from landfills via the Short-Lived Climate Pollutants (SLCP) law.

The breakdown of organics results in methane production and California is mandating that organics be redirected to more beneficial uses, such as compost for agricultural applications or biomethane production for vehicle fleets. California Senate Bill (SB) 1383 was enacted in 2016 with specific 2020 and 2025 mandates for organics diversion. In addition, CalRecycle and the Water Board joined forces to create a more combined permit for composting operations.

The hope was that these two agencies would just have one permit, but as John shared, two permits are still necessary plus potentially ones from local agencies, cities, and air districts. However, tiered permitting was introduced with the Composting Order which has resulted in a quicker permitting process for smaller facilities and a more risk based approach. Potentially a more distributed model for composting operations, where sites closer to producers (e.g. residences), may result with a reduced permitting time frame. However, John noted that industrial scale composting operations have economies of scale that likely will still outweigh the benefits of smaller, more distributed systems.

See our conversation with John below, but here are a few key takeaways:

• Composting operations have a lengthy list of environmental requirements that should be considered when going through initial site selection to minimize long-term compliance challenges
• Consolidation of composting requirements has helped operationally, but there are a lot of regulatory agencies involved
• Staying compliant with odor, stormwater, groundwater, dust, air, etc. requirements is only getting more complex and riskier with the number of agencies involved plus citizen groups

Mapistry works with innovative companies in the waste management and recycling industries, such as Recology  to transform their environmental programs and make them resilient to the ever increasing complexity of environmental laws.