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?