By: Dennis Fransway
New General Waste Discharge Requirements for Inert Waste Disposal Facilities Within the Santa Ana Region Affecting Inert Debris Type A Disposal Facilities (Type A Site) and Inert Debris Engineered Fill Operations (IDEFO)
Mine operators whose site also functions as an inert waste disposal facility (IWDFs), specifically and Inert Debris Type A Disposal Facility (Type A Site) or an Inert Debris Engineered Fill Operations (IDEFO) should be aware of Order No. R8-2019-0008 adopted by the Santa Ana Regional Water Quality Control Board on March 22, 2019. Under this Order, authorizations under a general waiver of, or individual, waste discharge requirements for IWDFs in the Santa Ana Region are rescinded and the new general Waste Discharge Requirements (WDRs) applied. These requirements will not affect Construction & Demolition Waste and Inert Debris Facilities (CDI Waste Disposal Facility) operate under CalRecycle Permits and corresponding Regional Boards WDRs.
Operators proposing to discharge inert wastes must submit a Notice of Intent (NOI) along with a Technical Report described by the general WDRs. Information required in the Technical Report shall include information for the general operation, site physical condition, working and operational design, site operations and monitoring, and waste acceptance procedures. Also, to be included is information on site closure, a compliance schedule for existing facilities and attachments for any optional operations. Proposed compliance schedules for implementation of the identified collection, control, and monitoring practices must ensure compliance as soon as practicable and supported with appropriate technical or economic justification. In no case may the schedule exceed two years from the date of the NOI.
The Order establishes standards for a Monitoring and Reporting Program that requires dischargers to perform regular monitoring and reporting of waste acceptance, management, and disposal activities, and to document performance and completion of necessary site monitoring, management, and maintenance activities plus fees. Reporting will be on an established schedule to include a one time reporting of the NOI and Technical report, an annual report with 28 days of the new year and Storm Event Report within 30 days after the end of a major storm event.
In summary, these new WDRs represent a significant change for the affected IWDFs and particularly for those sites authorized under a general waiver of waste discharge requirements. If your local regional board has not implemented a similar Order, an IWDF operator may want to spend some time becoming familiar with the Santa Ana Board’s Order No. R8-2019-0008 and get prepared. It is expected that other Regional Board’s will follow with a similar Order in the future.
The Santa Ana Region Staff Report and complete Order can be reviewed and downloaded at the following link:
https://www.waterboards.ca.gov/water_issues/programs/cwa401/docs/certifications/order.pdf