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Options to Modify the Site Assignment Regulations. Basic Assumptions. Facilities managing MSW must go through Site Assignment Materials that are pre-sorted are not considered MSW Residuals remaining after separating recyclables from the waste is MSW - PowerPoint PPT Presentation
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Basic AssumptionsFacilities managing MSW must go through Site
AssignmentMaterials that are pre-sorted are not considered
MSWResiduals remaining after separating recyclables
from the waste is MSWPOTWs managing SSO in addition to sludge in an
AD unit are adequately regulated under BRP regulations and exempt from SW regulations
Must ensure quality of both incoming pre-sorted materials and outgoing products
Maintain standards of protectionProvide for adequate public review and comment
on permits
OptionsOption 1 - Site Assignment LiteOption 2 - Limited RevisionsOption 3 - Expand Site Assignment
Exemptions Option 3A – Include Other Conversion
Technologies
Types of OperationsExamples of operations handling pre-sorted
materials:Agricultural anaerobic digesterAdvanced windrow compostingAnaerobic digester >250 tpdAerobic digester >250 tpdGasification or other technology
Major IssuesQuality and Type of Input Materials
Source Separated Organics (SSO)Pre-sorted Materials
Size of OperationLocation of FacilityType of TechnologyQuality and Type of End Products
Option 1 - Site Assignment LiteUsing the current site assignment process,
create specific composting/recycling facility siting criteria for use by Boards of Health
Issue: Should the siting criteria be modified or should any be added?
Statutory requirements cannot be modifiedBOH timelinesPublic hearing requirementNeed for BOH to issue site assignment decision
Option 1 - Site Assignment LiteExisting Handling Facility Siting Criteria
No site is suitable where the waste handling area is: Within a Zone I of public water supply Within an IWPA or Zone II Within a Zone A of surface drinking water supply 500 feet upgradient or 250 feet of private water supply For TS <50 tpd, is fully enclosed system and 250 feet
from residence, prison, health care facility, school, etc. For TS >50 tpd, is 500 feet from residence, prison,
health care facility, school, etc. Within the Riverfront Area Maximum high groundwater is within 2 feet of ground
surface
Option 1 - Site Assignment LiteExisting General Siting Criteria
No site is suitable where the waste handling area is within: An area of designated Agricultural land Areas of Critical Environmental Concern (ACECs)
Also, these issues must be addressed: Traffic impacts and access to site Impacts to Wildlife and wildlife habitat Protection of open space Potential air quality impacts Potential for creation of nuisances Sufficiency of Size of facility Impacts of Areas previously used for solid waste disposal Preference for locations with no Existing facilities Consideration of other sources of contamination or pollution Preference for locations with no Regional participation
Option 1 - Site Assignment LitePROS
Facilities that receive site assignment get protection provided by statute on zoning
Siting criteria are tailored to specific types of facilities
CONS Limited ability to modify process established by
statuteSite assignment process can be long and
expensiveOutcome of application process not guaranteed
Option 2 – Limited ApproachLimited proposal – Clarifies/expands composting
Redefines composting to include anaerobic and aerobic digestion
Removes existing tonnage/size restrictions on composting facilities
Removes restrictions on what types of compostable materials a facility may accept
Uses existing DON criteria for review and approvalDoes not add new, more specific criteria to address
location, types of materials or technologiesEnhanced public notice procedures
Option 2 – Limited ApproachPROS
Addresses all current food waste proposalsCONS
Only addresses food waste/SSO materials and does not address other pre-sorted materials
Does not address gasification, enzymatic/chemical conversion or other types of projects using pre-sorted materials
Does not provide as much certainty to applicants because specific decision criteria not specified
Option 3 – Expand Site Assignment ExemptionsGo beyond current limitations in
definitions of composting and recyclingExpand current exemptions for recycling
and compostingEnhance public notice process
Option 3 – Expand Site Assignment ExemptionsExpand definitions of composting and
recycling (as in Option 2) to include:Anaerobic digestionAerobic digestion
Propose two levels of permits:“Permit by Rule” for facilities that pose little risk
(current conditional exemptions)Facility-specific permits for facilities that
potentially pose greater risk than those in “permit by rule” category (similar to current DON process)
Option 3 – Enhanced Permitting CriteriaExpand facility-specific permit process
(DON):Expand and clarify permit application and
decision criteria by considering: Adequacy of pre-sorting of the materials – What test
must you pass? The site Size of facility Technology or process to be used End-products, quantities and product quality
Option 3 – Expand Site Assignment ExemptionsPROS
Fits into current regulatory scheme and builds on existing exemptions
Clarifies process and criteria to be used for review
CONSDoes this option expand exemptions too much?Difficulty in developing review criteria given
interrelationship of various criteria As size goes up, concerns (impacts) potentially go up As technology improves (i.e. in-vessel systems),
concerns go down
Option 3A – Enhanced CriteriaAssumption – Start with changes from Option 3Add an exemption category for “conversion” technologies
that are neither recycling nor compostingEnzymatic/chemicalPyrolysisOther conversion technology
Based on concept of handling only presorted materials and perhaps other criteria like non-compostable or non-recyclable
Clarify the test for determining if materials are adequately pre-sorted If materials fail the test then they are MSW and facility
requires site assignmentEnhance public notice process
Option 3A – Enhanced Permitting CriteriaPROS
Provides category for reviewing/permitting future /unforeseen technologies
CONSDoes this option expand exemptions too much?
Other Options, Technologies or Activities?Consider picking and choosing
Combine best of each option into new option What are we missing?Are there other options we should consider?
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