What Regulators Look For In Composting Facilities

BioCycle May 2004, Vol. 45, No. 5, p 45

A "veteran" shares ten years of lessons learned while regulating Washington state composting sites.

Holly Wescott

AN INVITATION from BioCycle to speak at its 2004 West Coast Conference this past March in Portland, Oregon included the following request: "We were hoping you might be interested in tackling the topic of what you, as a veteran composting regulator, have learned over the years with regard to oversight of composting operations." After mulling over the requested topic, I decided to "tackle the topic." After brainstorming with colleagues, I identified the following key lessons learned after ten years as a regulator with the Washington State Department of Ecology:

Lesson #1 - "Balancing oppositions" is the key to regulating compost facilities.
Composting is a dynamic process and it is best regulated by taking the "middle path." As regulators, our challenge is to promote composting while protecting human health and the environment. We want to encourage systems that recycle as much organic material as possible, with enough flexibility in design and operating requirements to account for site-specific conditions. At the same time, we want systems that protect streams and groundwater from leachate, and prevent dust and odors from affecting neighbors.

Lesson #2 – "Exemptions" promote composting
Allowing people to compost limited quantities of materials without a solid waste handling permit is one way to create the balanced regulatory approach described in Lesson #1. Washington state’s new composting standards (adopted in February 2003) have several categories of exemptions based on volume, feedstock type and location of composting activities.

For example, one exemption category allows up to 250 cubic yards of yard debris and/or manure to be composted without a permit as long as the composter notifies the local health department and the state Department of Ecology (DOE). All exempt activities must follow terms and conditions that protect water and air quality. (For a complete description of composting exemptions in the rule, see subsection 220 of Chapter 173-350 Washington Administrative Code (WAC), Solid Waste Handling Standards, at http://www.ecy.wa.gov/programs/swfa/facilities/350.html)

Lesson #3 – Guidance and regulations work together
Looking back over a decade of developing rules for composting facilities, the value of using guidance is clear. In fact, DOE used two guidance documents to "pilot" the composting standards in the new solid waste handling rule. The "Interim Guidelines for Compost Quality" published in 1994, and the "Compost Facility Resource Handbook," published in 1998, laid the groundwork for Composting Facility Standards (WAC 173-350-220).

Lesson #4 – Advisory committees play an important role
Whether developing guidance documents or formal regulations, input from a diverse audience through advisory committees is very helpful. Group discussions work to focus attention on the most important aspects of the composting industry.

Lesson #5 – Training is crucial for successful composting
Composting facility operators must understand the biology of decomposition. Formal training is important (and is offered across the country), but doesn’t take the place of learning how to manage feedstocks at your own facility. Operators need to learn the art of composting at their facilities, paying careful attention to feedstock mixes, moisture and equipment on site.

Lesson #6 – Protect water quality
As the composting industry has evolved in Washington state, so has managing water at these facilities. We no longer call all water landing on a facility "runoff." Instead, we recognize the need to address clean storm water and leachate differently.

Leachate is water that carries nutrients, suspended solids and pathogens from contact with feedstock and composting materials. It needs to be contained. Leachate should not be allowed to enter surface water or ground water. Clean storm water, however, can be absorbed into the ground. The design standards for composting facilities need to allow flexibility for protecting water quality. Composters should choose the best designs depending on the climate, technology and scale of the operation. The bottom line for water quality is "zero discharge" for leachate from composting facilities.

Lesson #7 – Managing odors equals survival
In Washington state, odor problems are still the leading cause of failure at composting facilities. The best strategy for new facilities is to develop an active odor management plan from the start. Such a plan outlines clear steps and technological improvements that will be made if odor becomes a problem. Even though some areas of the country are looking at actual air emissions from composting operations, the bottom line for air quality is still, "don’t make a stink that affects your neighbors."

Holly Wescott is a Compost Specialist with the Washington State Department of Ecology in Olympia. This article is based on her presentation at the BioCycle West Coast Conference, March 15-17, 2004 in Portland.

Copyright 2004, The JG Press, Inc.