,tiding whether to landfill or com- post organic waste often comes

down to economics. In order to make com- posting a viable solution for large-scale diver- sion of organics, a reasonable economic advantage must exist. One potential barrier to achieving this economic advantage is reg- ulation of the_composting industry.--

Composting reguiations are designed to - -.- - protect theenvironment and piiblic h%5lth; however, regulatory requirements can also encourage or discourage composting. Ideal- ly, composting regulations will serve their protective purpose while minimizing unnec- essaiy burdens that affect business planning as well as capital and operating costs.

A first step in understanding how regula- tions affect the composting industry is a comparison of regulatory approaches. The University of Georgia's Department of Bio- logical and Agricultural Engineering (BAE) conducted a review that summarizes the com- posting regulations in nine southeastern states (Florida, Georgia, Kentucky, Louisiana, Mis-

ies the same or if

sissippi, North Carolina, South Carolina, Ten- nessee and Virginia) and four states with active composting programs (California, Maine, Oregon and Washington). Comparisons of these regulations provide the industry with the environ- an overview of regulatory approaches that may encourage or discourage compost- ing, andpotentially-can help statesiden:

~ d e ~ a t o r y approac not ody proteEt the environinent fsom-A composting activities but also protect it by diverting larger quantities of organic waste from landfills. The infoimation for this study was based on regulations as written on each state's environmental protection divi- sion Web site. We were unable to include how the written regulations are interpreted. compost facilities are

required to have the Potential barriers to composting same permit-type as new The most significant regulatory barrier municipal solid waste to the promotion of composting seemed to be (MSW) and construction and demolition whether states regulate all composting facil- (C&D) facilities. In these cases, compost

D.J. Borden, J.W. Gaskin and J. Governo are public service faculty and staff members of the University of Georgia's Department of Biological and Agricultural Engineering (Athens). They may be reached though Borden at (706) 542-6099 or dborden@engr.uga.edu.

~esource Recycling June 2003

2003 SCRAP PLASTICS MARKETS DIRECTORY

Resource Plasdu,lnc. har been agrlnderlrecycler MIXED rlnce 1994,rpedallang In procerrlnglgllndlng WC.

O Check Enclosed

O Visa, Mastercard or Amex Foreign: add $7 in U..S. funds h , - r -

I RESOURCE PLASTICS INC. I

O Directory and one-year newsletter subscription - $100 Foreign: add $19 in U.S. funds

Name Title Company

Address City State Zip

Phone ( ) Fax ( 1 E-mail

Mail to: Plastic1 D@cyclinB . P.O. BOX 42270, Portland, OR 97242-0270 (503) 233-1305 . (503) 233-1356 (fax) P

Resource Recycling June 2003

PC., ,ALE OR STATIONARY - T R ~ L ~ ~ : OR smn MnrmrTDn

ELECTRIC OR HYDRAULIC PO WERED

'LOW-SPEED,

Slow Speed Shredders for the efficient reduction of Municipal solid waste Ferrous scrap Hazardous waste 55-gallon drums

Hydraulic powered shear- fype Hot water heaters Wood Wire Refrigerators shredder processing white goods Plastic Cable Washers C & D waste, etc. using 2" thick, double-hook cuffers. Aluminum scrap Dryers

Units come with custom-made gearboxes delivering the highest shaft torques in the industry.

Varying cutter widths and hook profiles for processing different types of material. Heat-treated cutters (58-60 Rockwell C) with splined hexagonal shafts for all machines.

5540 West Park Ave. St. Louis, MO 63110 (3 14) 781-61 0(1 - , - - -, - - - - - - - l?t?icril: t r t ~ ~ e ~ i c ~ m @ ~ i c r n ~ ~ ~ ~ i / i ~ ~ r i z e t : c o i i ~ CVeh. w ?T. con1

- -

I - - I

Reader service # 16

facilities of different environmental risk are commonly being required to meet similar reg- ulatory requirements. As a result, low-risk facilities may have greater regulatory requise- ments than the level of public health and envi- ronmental risk they pose. This can be a sig- nificant deterrent for composters wishing to start lower-risk facilities.

Many states, acknowledging that compost facilities should be regulated based on the risk they pose, have developed approaches that attempt to separate regulatory requirements into categories. Some states require that all facilities obtain the same permit-type, but reg- ulatory requirements within the permit vsuy dependingon feedstock-type and facility size. Other states have less stringent requirements for yard trimmings and/or more stringent requirements for biosolids. In these cases, states commonly have a separate permit type for yard trimmings facilities, while all other facilities are required to have the same per- mit type.

Other states separate regulatory require- ments even further with more stringent reg- ulatory requirements for high-risk feedstocks -such as municipal solid waste, biosolids and industrial sludge - and less stringent require- ments for low-risk feedstocks such as food waste and yard trimmings. California, Maine, North Carolina, Oregon and Virginia, for example, separate regulatory requirements

based on feedstock type and facility size. In addition, these states often have three or four permit-types for composting activities. Since

' regulatory approaches are commensurate with the risks they pose, this method of "tiering" composting facilities simultaneously protects public health and the environment while encouraging composting.

With an understanding of the different states' regulatory and permit approaches, the next step of the regulatory review was to iden- tify which components of the regulations themselves could most significantly create barriers. The following sections describe some of these potential bsu-siers.

Infrastructure costs When composting facilities are regulated sim- ilarly, low-risk facilities may be required to implement infrastructure safeguards, such as pad or monitoring well requirements, to pro- tect public health and the environment. Such requirements create unnecessary barriers for low-risk compost facilities.

Requirements for impervious pads differ greatly from state-to-state. All states except California, Georgia, Kentucky and South Car- olina mention the need for an impervious pad for composting activities. Pad requirements vary from needing an asphalt or concrete pad for all activities (e.g., receiving, active com- posting, curing and storage) to only needing

an asphalt or alternative material (e.g., clay, compacted gravel or liner) pad for certain activities or types of feedstocks.

Some states have different regulatory requirements for pads based on feedstock type and facility size with low-risk facilities, often only requiring an alternative pad type for receiving and active composting activities. Depending on the pad type and activities requiring a pad, costs can vary significantly.

A study conducted at the University of Georgia showed that concrete and asphalt pads can cost $5.09 per square foot and $1.25 per square foot, respectively, while compact- ed clay pads cost only $0.09 per square foot. While high-risk composting facilities should be required to have highly impervious pads for most composting activities, low-risk facil- ities may not need the same level of protec- tion. Pad requirements based on the level of risk posed by a facility would be an effective way to keep impervious pad capital costs pro- portionate with public health and environ- mental risk.

Hydrological assessments and subsequent groundwater monitoring well systems pres- ent another potential barrier. Several states, including Florida, Georgia, Louisiana, Mis- sissippi, North Carolina, Maine, Oregon and Washington, require monitoring wells for some or all composting facilities. While mon- itoring wells are a likely necessity for high-

" VERVICCE I machinery imc.

Reader service # 45

~ e s o u r c e Recyclir~g June 2003

risk facilities, this requirement presents a potential barrier for some composters that do not require monitoring wells to protect pub- lic health and the environment.

Significant capital costs can be incurred when conducting a hydrological assessment because a qualified person (Professional Geologists and/or Professional Engineers) must conduct it. Additionally, the installa- tion of monitoring: wells adds cau- " ital costs that may not be neces- sary for low-risk facilities. One potential way to alleviate this problem is to only require moni- toring wells for facilities that tru- ly present a risk to groundwater. Facilities that do not pose a risk to groundwater would then become exempt from this requirement.

Permit cast Regulatory agencies charge a fee

requirements can either encourage or dis- courage composting and aid or impede busi- ness planning. A flexible permit structure, a logical organizational structure, and a clear outline of regulations required for composters is critical for effective state regulation.

User friendliness helps potential com- posters clearly understand which regulations are required and the potential capital and

ton, for example, has developed an effective handbook that guides potential composters through all the regulatory and pennit require- ments needed to open a composting facility. A handbook like this goes a long way towards alleviating confusion and additional work on the part of the regulatory agency.

Tiering systems Overall. the most critical comDonent

to process pennits for composting facilities. Conversations with individuals from various southeastern states have indicated that obtaining a permit can be cost prohibitive for low-risk facilities. States that require low- risk composting facilities have the same per- mit type as landfills or high-risk composting facilities create a barrier for low-risk com- posters due to high, disproportionate permit costs. A solution to this barrier is to provide several permit types with corresponding pro- cessing fees commensurate with the public health and environmental risk posed by the facility.

Local zoning ordinances In nearly all states, composting facilities are required to obtain a letter from the local- zoning office ensuring that the facilities are in compliance with all local-zoning ordi- nances. New compost facilities seeking a pennit may find that obtaining this letter can be difficult.

County and city officials often do not have significant experience with composting and therefore view these activities similar to land- fill activities. The negative public opinion of landfills also can make local officials reluc- tant to allow a composting operation to be located on a site, even when the property has the adequate and necessary zoning to meet land-use ordinances. Educating local offi- cials on composting basics and the potential benefits that a composting operation offers a community is one method to help resolve this problem.

User friendliness Regulatory approaches followed a common theme, but specific regulatory requirements varied widely from state-to-state in com- pleteness, organization and clarity. The lev- el of organization and guidance given to potential composters in meeting regulatory

operating costs they might incur in starting a composting facility. Guidance on the states' ' Web sites for regulations, permit require- ments and even departmental organization can be veiy helpful in understanding the reg- ulations and the steps necessary to obtain a permit.

Another useful guidance tool for potential f n r i l i t i ~ c n r ~ mmnnct hnndhnnkc Wschincr-

In addition, tiering systems also can make regulations more user friendly since these regulations are inherently more organ- ized and clearly understood.

What's needed next? This review only speculates on the potential regulatory barriers to composting. Other potential barriers may exist that we did not identify, and the barriers that we did identi-

for effective regulation of thi com- posting industry is the use of tiering systems. Such systems separate facil- ities by their level of risk to public health and the environment into spe- cific regulatory categories. A tiering system can ensure appropriate regu- latory controls on facilities while alle- viating unnecessary regulatory bur- dens that deter potential composters and therefore most effectively protect the environment by encouraging the diversion of organics from landfills.

I Y 1 "Our Allegheny baler has exceeded our expectations. It's built

- like-a-tank.-We-push-it-to-the-limit=but~it~keeps-on-p~oducing.~ -a - -- -TOM & MIKE BOEHRINGER, S H R E ~ I N G SOLUTIONS, INC. -+ - --- -: --

Reader service # 11

Resource Recyclirzg June 2003

--

California Integrated Waste Management Board www.ciwmb.ca.gov

Environmental Protection Agency. Standards for the Use or Disposal of Sewage Sludge www.access.gpo.gov/nara/cfr/ cfrhtm1~00/Title~40/40cfr503~00.html

Florida Department of Environmental Protection www.dep.state.fl.us

Georgia Environmental Protection Division www.dnr.state.ga.us/dnr/environ

Kentucky Department for Environmental Protection www.nr.state.ky.us/nrepc/dep

fy may not be noteworthy to every situation. The next step in definitively understanding the most significant regulatory barriers to composting would be to conduct an eco- nomiclrisk analysis to determine which reg- ulatory components create the most signif- icant barriers.

Louisiana Department of Environmental Quality www.deq.state.la.us

Maine Department of Environmental Protection www.state.me.us/dep/index.htm

Mississippi Department of Environmental Quality www.deq.state.ms.us/new web/homepages.nsf

North Carolina Department of Environment and Natural Resources www.enr.state.nc.us

Oregon Department of Environmental Quality www.deq.state.or.us/index.htm

Such an analysis could be conducted on several model regulatory approaches to deter- mine the potential capital and operating costs incurred by the approaches and how well the approaches protect public health and the envi- ronment. This type of analysis could help regulators and potential composters alike find

South Carolina Department of Health and Environmental Control www.scdhec.net

Tennessee Department of Environment and Conservation www.state.tn.us/environment

University of Georgia, Department ol Biological and Agricultural Engineering. Analysis of Georgia Composting Regulations. Contact Julia Gaskin (706) 542-1401.

Virginia Department of Environmental Quality www.deq.state.va.us

Washington Department of Ecology www.ecy.wa.gov

a regulatory balance that simultaneously pro- tects public health and the environment while encouraging the composting industry. RR Acknowledgements The authors of this article would like to thank the Georgia Pollution Prevention Division (P2AD) for funding this project.

-~ -- . ...-

-- - - - - ~ - - - -- - - - . ~. . .

WASTE REDUCTION AND COST SAVINGS Your Partner in

BY ON-SITE RECYCLING

The Packer 750 will grind gypsum drywall, wood, brick, con- crete block, cardboard, and asphalt roohg shingles. This materi- al can be ground into a useful size and many times re-used on the job site in a beneficial manner. The gypsum can often be mixed with topsoil as an amendment that is beneficial to plant growth. The wood can be used as mulch and as an erosion control media. Final- ly, the ground concrete block, brick, and asphalt shingles can h d use as replacements for purchased ill material under driveways.

Packer Industries, Inc. 5800 Riverview Rd., Mableton, GA 30126

For more information, contact Packer Industries, Inc, at: 800-81 8-2889, WWW.PACKER2000.COM OR

EMAll PACKERINDBAOL.COM

Reader service # 27

Resource Recycling June 2003