Focused Workshop on the Informal Draft Revised Disposal Reporting System

Regulations Session #1

March 2003

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Workshop Agenda Introduction and System Overview Scales and Weighing Requirements

Thresholds for Scales Alternatives to Weighing

Determining Origin and Tracking Tonnages Surveys Allocation of Multi-Jurisdictional Loads Self-Haul Hauler Records Tracking Categories

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Workshop Purpose

Provide clarification on definitions and Disposal Reporting System (DRS)

Obtain input on specific sub-topics of the DRS regulations: Focus on solutions Discuss alternatives already submitted Consider additional alternatives to

implement Board-approved SB 2202 recommendations

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Definition Clarificationsand

System Overview

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Hauler Categories Commercial Hauler:

Person whose primary business involves collection and hauling of waste

Includes franchised or contracted haulers

Commercial Self-hauler: Person who generates waste as a result

of his/her business and who hauls the waste to a solid waste facility

Includes roofers and contractors

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Hauler Categories

Residential Self-hauler: Person who hauls waste to a solid waste

facility Includes homeowners with “small”

loads of self-hauled waste

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Hauler Categories (continued)

1st informal draft also referred to: Residential Self-Hauler as Self-

Haulers delivering waste in passenger and pickup trucks as defined in sections 465 and 471 of the Vehicle Code

Commercial Self-Hauler as Self-Haulers except those delivering waste in passenger vehicles and pickup trucks as defined in sections 465 and 471 of the Vehicle Code

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Hauler Categories (continued)

Alternative suggested by stakeholders forSelf-haul Definitions:

Rather than defining self-haul loads in terms of commercial self-hauler or residential self-hauler (pickup and car loads), define loads in terms of volume: “Large” = loads greater than or equal to 6

cubic yards, and “Small” = loads less than 6 cubic yards.

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Daily Tracking vs. Quarterly Reporting

Daily tracking means determining the origin and tonnage of each load every day of facility operation and maintaining records for audits.

Quarterly reporting means compiling the origin and tonnage data gathered through daily tracking during the quarter and reporting the quarterly totals allocated to each jurisdiction. Model Reporting Forms assist in summarizing

required quarterly data and use would be optional for agencies/facilities/haulers.

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WHO REPORTS (Current versus Proposed)

CommercialHaulers

CommercialSelf-Haulers

*Waste Origin Tracking Requirements:

(1) Commercial ("contracted") Haulers Current: Origin based on at least 1 week/quarter survey Proposed: Origin based on Daily Dispatch Records

(2) Commercial ("large") Self-Haulers Current: Origin based on at least 1 week/quarter survey Proposed: Origin based on Daily Surveys (Rurals allowed to use 1 week/quarter survey)

(3) Non-Commercial ("small") Self-Haulers Current: Origin based on at least 1 week/quarter survey Proposed: Origin based on at least 1 week/quarter survey

ResidentialSelf-Haulers

Counties andReportingAgencies

Origin & TonsDisposed, Usedon-Site, & Sent

Off-Site

TransferStations and

MaterialRecoveryFacilities

Total Tonsand OriginAllocations

Jurisdictions

OriginAllocations

Landfills andTransformation

FacilitiesCIWMB

DisposalSummary

AnnualReport

Origin & TonsExported Out

of State

Origin *(3)

Origin *(2)

Origin *(1) NEW (UponRequest)

NEW (UponRequest)

NEW(Required)

NEW (UponRequest)

HAULERS FACILITIESAGENCY/COUNTY/

JURISDICTION BOARD

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Scales and Weighing

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Tons Per Day Threshold Concern with existing system:

Tonnage data may not be accurate, since many facilities do not have scales.

SB 2202 recommendation to address the concern: Require scales and weighing of all loads at

facilities above a certain tonnage per day. Allow exemptions for rural facilities.

Clarification: Tons per day threshold is based on annual average

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Tons Per Day Threshold:LANDFILLS

1st informal draft: Landfills with scales

must weigh all loads. A landfill is required to

have scales if accepting >100 annual average tons per day.

A landfill in a rural jurisdiction is required to have scales if accepting >200 annual average tons per day.

Alternatives suggested by stakeholders:

Exempt small volume facilities from weighing all loads.

Do not require landfills to reweigh station loads when the landfill and station are operated by the same company.

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Tons Per Day Threshold:STATIONS

1st informal draft: Stations with scales

must weigh all loads.

A station is required to have scales if accepting >100 tons per day.

Alternatives suggested by stakeholders:

Make tons per day consistent with transfer station regulations.

Exempt small volume facilities from weighing all loads.

Make >200 tons for rural jurisdictions (as in landfill section)

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Alternatives to Weighing Concern with existing system:

Tonnage data may be inconsistent, since facilities throughout the state are using different conversion factors to estimate weight.

SB 2202 recommendation to address the concern: The Board should require standards for

collecting tonnage information.

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Alternatives to Weighing

1st informal draft: Use conversion

factor if facility does not have scales or when scales are not working.

Conversion factor of 1 cubic yard = 1,000 pounds

Alternatives suggested by stakeholders:

Alternative conversion factors

Flat rate by vehicle type

Conversion factors for vehicles based on actual weight surveys

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Determining Origin andTracking Tonnages

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One-Week Surveys vs. Daily Surveys

Concern with existing system: Extrapolating tonnage allocations using one week

of origin survey data per quarter reduces accuracy of quarterly tonnage allocations, particularly for smaller jurisdictions.

SB 2202 recommendation to address the concern: Require daily surveys. Exempt self-haul loads delivered in cars and

pickup trucks from daily surveys because the amount of waste is relatively small. (Self-haul waste delivered to disposal facilities in these vehicle types was estimated at only 3% of statewide disposal in 1999)

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One-Week Surveys vs. Daily Surveys

1st informal draft: Daily surveys of all loads

with the following possible exceptions: One week per quarter

surveys of some self-haul loads

Assign all waste to host jurisdiction if authorized by the host jurisdiction

Alternatives suggested by stakeholders:

Exempt self-haul from reporting requirements and from goal measurement system. (Requires statutory revision)

Allocations based on one-week surveys will skew the data. Require daily surveys of every load, every day.

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Allocation of Multi-Jurisdictional Loads: HAULERS

1st informal draft: Estimate amounts

from each jurisdiction based on a reasonable method such as: number of bins, total weight, or total capacity.

Alternatives suggested by stakeholders:

A city may create an ordinance that prevents its city’s waste from being mixed with other cities’ waste.

(This would be a local option only, not a statewide regulatory requirement.)

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Allocation of Multi-Jurisdictional Loads:FACILITIES

1st informal draft: Estimate amounts from

each jurisdiction based on either: total amount received

from each jurisdiction or

total amount received from each jurisdiction after adjusting for diversion at the facility.

Alternatives suggested by stakeholders:

No alternatives have been suggested so far.A problem some facilities have is computer software that only allows input of a limited number of jurisdictions and/or fixed percentage allocations.

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Self-Haul and Documentation Requirements

Concern with existing system: Self-haul allocations are difficult to verify. Self-haul may make up a significant

amount of an individual jurisdiction’s disposal.

SB 2202 recommendation to address the concern: Require standard information to be

collected from self-haul, cash customers

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Self-Haul Definitions and Documentation Requirements

1st informal draft: Two categories of

self-haulers: Commercial self-

hauler and Residential self-

hauler (car and pickup truck loads)

Alternative suggested by stakeholders:

Rather than defining self-haul loads in terms of commercial self-hauler or residential self-hauler, define in terms of volume: loads greater than 6

cubic yards, and loads less than 6

cubic yards.

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Self-Haul Definitions and Documentation Requirements (continued)

1st informal draft: Collect information from

commercial self-haulers on a form: hauler name, jurisdiction of waste

origin, hauler address, hauler phone number,

and whether waste is from a

business or residence.

Alternatives suggested by stakeholders:

Do not require forms and only collect jurisdiction-of-origin information

Have haulers verify the origin of their loads by pointing out the location on a map.

All self-haulers need to complete forms (every load, every day)

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Franchised Hauler Dispatch Records

Concern with existing system: Drivers are typically the ones responsible for

providing gate attendant with origin information.

Due a variety of factors, such as driver language barriers and complexities of boundaries of waste collection routes, driver reported information may be inaccurate.

SB 2202 recommendation to address the concern: Require haulers to provide origin data based

on dispatch records.

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Franchised Hauler Dispatch Records

1st informal draft: Commercial haulers

provide jurisdiction of origin to facilities based on their dispatch records.

Commercial haulers keep addresses of waste collection as back-up for verification purposes.

Alternatives suggested by stakeholders:

Keep route book and/or billing information as back-up, instead of individual addresses.

Require the city to maintain the back-up information in cases where the city, not the hauler, bills the customer.

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Jurisdiction Reports from Facilities

Concern with existing system: By the time jurisdictions get information

from the counties, it is very difficult to go back to haulers and operators to verify questionable allocation amounts.

SB 2202 recommendation to address the concern: Have facility operators send disposal

reports to jurisdictions at the same time they send them to the counties.

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Jurisdiction Reports from Facilities

1st informal draft: All facility operators

are required to send disposal reports to jurisdictions at the same time they send them to agencies.

Alternatives suggested by stakeholders:

Have facility operators send reports only to those jurisdictions that specifically request them.

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Tracking Categories Concern with existing system:

Designated wastes tracked at some landfills can be deducted from annual disposal tonnage. Creates inequity.

Large increases in annual disposal are difficult to explain and impact diversion rates (e.g. C&D projects).

SB 2202 recommendation to address the concern: Require statewide standards for collecting origin

and disposal tonnage information Have more consistency with Board of

Equalization reporting requirements.

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Tracking Categories:Disposal

1st informal draft: Facilities are required

to track and report quarterly jurisdiction allocations for designated wastes, C&D debris, inert debris, as well as MSW.

Alternatives suggested by stakeholders:

Rather than track C&D debris or inert debris loads, track loads from “special projects”

(Example: Loads directly from Cal Trans road projects)

Provide the information as requested by a jurisdiction.

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Tracking Categories: On-Site Beneficial Use

Concern with existing system: Beneficial use is sometimes

misreported as ADC.

SB 2202 recommendation to address the concern: Require statewide standards for

collecting origin and disposal tonnage information.

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Tracking Categories:On-Site Beneficial Use

1st informal draft: Facilities are required

to report the tons and types of materials from each jurisdiction that are used beneficially during the quarter, broken out by: jurisdiction of origin

and source (i.e. transfer

station, direct haul, and self-haul).

Alternatives suggested by stakeholders:

Do not require on-site beneficial tracking by source.

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Tracking Categories:Waste Sent Off-Site

1st informal draft: Facilities are required

to report the tons and types of materials that are sent off-site each quarter, broken out by: jurisdiction of origin,

and source (i.e. transfer

station, direct haul, and self-haul).

Alternatives suggested by stakeholders:

Require only total tons sent off-site.

Do not track by source or material type.

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Next Steps

Focused workshops on Transfer Stations will be held on March 24 (Sacramento) and March 25 (Diamond Bar).

Revise first informal draft regulations based on written comments and input from the December and March workshops.

Second informal draft regulations will be sent out for review and comment.

Schedule workshops on second informal draft regulations.

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Contact Information

Diane Shimizu1001 I Street, P.O. Box 4025Sacramento, CA 95812-4025tel: (916) 341-6238fax: (916) 319-7129email: dshimizu@ciwmb.ca.gov