Do I Want to Operate an Inert Waste Disposal Facility in California? - by Kristen Davis

For decades mining operations have accepted inert debris waste such as asphalt and concrete at their facilities to be recycled or used as a convenient, inexpensive place to dump construction related debris rather than taking it to a licensed landfill. In recent years waste diversion has become a codified goal throughout the state of California with accompanying regulations and required permits for disposal of inert debris waste. With these additional disposal requirements, new opportunities for mining operations are available that can extend product lines and provide new revenue streams.

What is inert debris and how can it benefit a mining operation in California? Inert debris can simply be defined as a material that is non-hazardous and does not contain putrescible wastes. Inert debris consists of material such as broken concrete, asphalt, glass, metals, clay products, wood, etc.

There are three types of inert waste disposal facilities: Inert Debris Engineered Fill Operation (IDEFO), Inert Debris Type A Disposal Facility and Construction and Demolition and Inert Debris Disposal Facility (also accepts construction and demolition debris). The differences in these three types of facilities are the specific types of material that can be accepted at each facility, compaction requirements, and the permitting process for each facility type. More detailed information for these types of facilities and permit requirements can be found at https://www.calrecycle.ca.gov/SWFacilities/CDI/

Benefits for accepting these materials at a mine operation can be explained by examples of how existing facilities currently use these inert debris materials. These benefits include:

• Charge tipping fees for acceptance of material at the operation.

• Create developable land.

• Provide a disposal location for company’s associated construction projects.

• The operation can continue after the SMARA Reclamation Plan has been closed, if an IDEFO or inert debris disposal facility is identified as an end-use; and

• Extend aggregate products rather than using 100 percent freshly mined sand or rock, such as in asphalt mixes or road base.

The operation of an IDEFO or inert debris disposal facility can also have its challenges. The operation will need to be a use that is allowed in the site’s zoning and additional permitting may be required. The mine operation would require the space for the IDEFO or inert debris disposal facility as well as material stockpiles and areas for material processing. Specialized equipment may be necessary to handle and compact material. Waste discharge requirements, load monitoring, and testing programs may need to be established and reported. These are challenges that may occur and should be identified prior to pursuing an IDEFO or inert debris disposal facility.

For assistance in answering your questions and permitting please contact Kristen Davis of EnviroMINE at kristen@enviromineinc.com or 619-952-9619.