Comprehensive Analysis of Republic Services’ Proposed Food Waste Collection Rates and Operations Plan
October 9, 2020
2 This analysis was conducted by Hidden Resources, under contract by the City of Chula Vista, Economic Development Department – Office of Sustainability.
Researchers:
Rich Flammer, Ellyn Hae, Tyla Montgomery Soylu, Hidden Resources (619) 758-0726
[email protected]
www.compostingconsultant.com
City of Chula Vista contacts:
Manuel Medrano, Environmental Services Manager, City of Chula Vista Economic Development Department – Office of Sustainability (619) 585-5766
[email protected]
David DiDonato
Sustainability Specialist, City of Chula Vista
Economic Development Department – Office of Sustainability (619) 476-2409
[email protected]
Draft Report, V5 October 9, 2020
Disclaimer: This report to the City of Chula Vista was produced under contract by Hidden Resources. The statements and conclusions contained in this report are those of the contractor and not necessarily those of the City of Chula Vista employees. Any mention of commercial products or processes shall not be construed as an endorsement of such products or processes by either Hidden Resources or the City of Chula Vista.
3 Contents
Background ................................................................................................................................................... 4 Determination of Volume of Organic Materials ........................................................................................... 4 Analysis of the City Solid Waste Rates and Associated Recycling Fees ........................................................ 5 Analysis of Proposed Plan and Residential Organics Collection Rates ......................................................... 7 Analysis and Recommendations ................................................................................................................... 7 Residential Rate Comparison with other Jurisdictions ................................................................................. 9 Multi Family Dwellings ................................................................................................................................ 10 Self-Haul, Local Education Agencies and Non-local Entities ....................................................................... 10 Analysis of Solid Waste Collection Rates .................................................................................................... 10 Analysis of Republic’s Proposed Commercial Food Waste Processing and Operations Plan ..................... 13 Existing Operation ....................................................................................................................................... 13 Utilization of the Grinder ............................................................................................................................ 13 LEA Inspection Reports ............................................................................................................................... 14 Document Review ....................................................................................................................................... 14 Plan and RCSI Review .................................................................................................................................. 15 Recommendations ...................................................................................................................................... 16 Analysis of Republic’s Proposed Commercial Food Waste Processing and Operations Plan as it Pertains to Zero Waste Principles ................................................................................................................................. 16 Attachment 1: Chula Vista Estimated Compost Procurement Targets, Cost and Retail Value .................. 17
4 Background
A number of state laws mandate the diversion of organics from landfills throughout California . AB 341 requires each jurisdiction reach a 75% recycling rate, and AB 1826 requires phasing in collection of organics from generators. Now under S B 1383 (Lara), jurisdictions are required to provide organics collection to all residential and commercial entities by January 2022.1 SB 1383 requires that each jurisdiction arrange recycling services for the following types of organic material:
• Food
• Green material
• Landscape and pruning waste
• Lumber and wood
• Organic textiles and carpets
• Paper products, printing and writing paper
• Manure
• Biosolids, digestate, and sludges
Unlike AB 939, S B 1383 carries fines for both the generator and the municipality. In January 2020 , the Department of Resources Recycling and Recovery (CalRecycl e) disseminated letters to all recycling coordinators, stating it will exercise its existing statutory authority to formally review jurisdictions’ mandatory commercial recycling and mandatory commercial organics recycling programs at an y time to ensure cities are demonstrating compliance.
The City of Chula Vista (City) has implemented a variety of recycling programs to meet these laws, including a pilot food recovery program. With the advent of mandatory collection of organics for all businesses. City staff approached its franchised hauler Republic Services (Republic) for a pricing change agreement for the expanded collection and processing of organics required under the laws (Attachment 1).
In April 2020, the City engaged Hidden Resources (Consultant) to review proposed rate changes and the SB 1383 Implementation Plan submitted by Republic. Consultant was tasked to e valuate the plan in context of SB 1383 and AB 341 to ensure that the services to be provided comply with state laws as well as provide an equitable value for each level of service.
Determination of Volume of Organic Materials
Analyzing previous studies conducted, Consultant calculated the potential recovery levels of organics for the City (Table 1). This table indicates that a system to process 80,4 66 tons per year of compostable material is required for the City to meet the requirements of S B 1383. It also shows that almost 60% of
1 A waiver process for small generators is discussed later in this report.
5 the c ompostable material will be derived from small quantity generators, with the remaining portion emanating from the commercial and industrial sector.
Table 1: City of Chula Vista Tons Compostable by Sector Totals % Waste
Disposed* % Compostable** Disposal Tons
Compostable*
Total
Compostable*
(Yard Waste
Included)
% Compostable by
Sector*
Trash Tons
Small Quantity
Generators (Carts) 58,552 39.2% 47.4% 27,753 46,971 58.4% Commercial (Front
Load) 70,001 60.8% 42.4% 29,680 33,495 41.6%
Industrial
(RO/Compactors) 20,772
Total 149,325
Yard Waste Tons
Small Quantity
Generators (Carts) 19,217
Commercial (Front
Load) 1,690
Industrial
(RO/Compactors) 2,125
Total 23,032 80,466
* Commercial and industrial tonnages are combined.
** See pages 35 and 38 of 2016 City of Chula Vista SCS Waste Characterization Study for compostable materials.
Analysis of the City Solid Waste Rates and Associated Recycling Fees In discussions with staff it was determined that the most efficient way to equate value for services would be to conduct a comparative analysis with other jurisdictions in California.
With the waste disposed by sector data included in Table 1, Consultant collected both population and waste sector disposal data on more than 20 cities using a combination of direct contact and review of databases availa ble on the CalRecycle website. Although numerous cities match Chula Vista’s waste demographics, many cities have not finalized their rates for addition of organics in their re sidential collection programs. But rather than excluding those cities completely, if commercial data was available, it was included for review.
Table 2 presents the jurisdictions reviewed.
6 Table 2: Comparable California Jurisdictions by Population and Waste Sector Percentage City
Commercial
Tons
Residential
Tons
Total
Tons Population SFH MFD
Franchised
Hauler Notes:
Chula Vista 90,773 61% 58,552 39% 149,325 263,466 56,306 23,767 Republic Santa Clarita 70,693 62% 43,094 38% 113,787 218,201 52,310 16,970 Burrtec/Waste Management
Has not completed
residential rate review to
add organics.
Oceanside 45,913 59% 32,559 41% 78,472 175,012 44,495 16,322 Waste Management
Has not completed
residential rate review to
add organics.
Fremont 90,755 67% 44,321 33% 135,076 227,673 55,017 18,576 Republic Implemented Phase 2 in 2012.
San Bernardino 85,802 68% 40,263 32% 126,065 208,498 42,315 17,452 Burrtec
Escondido 51,883 67% 25,484 33% 77,367 148,551 29,681 16,765 EDCO
El Cajon 41,122 75% 13,732 25% 54,854 99,855 18,357 15,865 EDCO
Glendale 111,898 83% 22,955 17% 134,853 200,239 36,334 38,010 Some city collection, RFP
out to potentially change
due Oct 23, 2019.
Modesto 75,519 63% 45,035 37% 120,554 208,967 45,038 8,249 Gilton/Bertolotti Uses a two cart/one truck
system for
trash/organics; operates
a composting facility.
Irvine Rates not complete. 241,918
Fontana N/A. 209,451
Mixed processing. Cost
will move from $49.90 to
$84.24.
City of Riverside Rates not complete. 312,361
R3 conducting study.
Also, city collection of
residential.
Santa Ana Rates not complete. 338,320
Extending existing
franchise until July 2022
w/ increase of $3.40 (no
CPI) to re-bid services.
Data sources:
https://www2.calrecycle.ca.gov/WasteCharacterization.
Chula Vista data provided by City of Chula Vista. Excludes self-haul, non-franchised material.
7 Table 2 includes a variety of jurisdictions from both Northern and S outhern California. Due to the fact many jurisdictions have not completed their rate changes and that landfill tipping fees are higher in most areas of the state, cities in San Diego County were deemed to be preferable. When reviewing population and waste sector percentages and cities that had completed rates that include the collection of organics in all sectors, three cities rose to the top of the list: City of San Bernardino, City of Escondido and the City of El Cajon.
Rates were reviewed in context of S B 1383 and AB 18 26 to ensure that services provided comply with regulations and ensure the City is obtaining an equitable value for each level of service from Republic. The following sections compare the rates by service type.2
Analysis of Proposed Plan and Residential Organics Collection Rates3 Chula Vista residents currently have the option of using up to five of their own containers for yard waste collection or renting a cart from Republic for $1.50/month. About 30,300 single family homes pay $1.50 per month for the collection of yard waste in either a 64-gallon or 96-gallon cart. To ensure every home has an organics collection cart, the Republic plan estimates that about 26,000 carts will need to be purchased. A cost per home rate of $3.32 is needed to collect and process the organics (Table 3). Increases allow Republic to develop a strong program to educate and provide positive enforcement of the mandate to collect organics from residential households. At the same time, it represents only a 7% increase in total collection for the 30,3 00 households that currently pay the cart rental fee for yard waste collection.
Residents currently using their own container for yard waste collection service will see an increase of 12%.
The overall increase will be 9% citywide.
Table 3: Chula Vista Residential Rate Increase SB 1383* Pre 1383 Post 1383 Rate Increase
Increase for residents with yard waste rental
cart $27.60 $29.42 7%
Increase for residents who use their own
yard waste cans $27.60 $30.92 12%
Net City residential Increase $27.60 $30.11 9%
*Rate increase includes collection of trash, mixed recycling, and mixed organics.
Analysis and Recommendations
The Republic plan speaks to the use of compostable bags for the storage of food scraps in between collection days. In our experience compostable bags cause problems in composting programs for many reasons. Foremost is the fact that customers often purchase the incorrect type of bag (such as those labelled “biodegradable”) and cause contamination issues for the processing oper ation. Consultant recommends that the program promote the use of a reusable container. Often called a “kitchen caddy,”
2 As SB 1383 and AB 341 concentrate on organics and recycling, this analysis will be provided before solid waste. 3 Residential refers to small quantity generators. Small businesses can take advantage this bundle as well.
8 these containers can be stored in the freezer between collection days or on a counter top. Republic should distribute the caddies free of charge to each household with educational materials included.
The Republic plan does contain an outreach plan to educate using billing inserts, community presentation, social media and other means of comm unication. At one time, bill inserts were a fantas tic method of education, but as more customers move to paperless billing, this avenue is less effective now. Therefore, a direct mail piece and electronic messaging to all customers would be far more impactful approaches.4 The City and Republic partnership presently includes an “oops” tag approach, which Consultant applauds.
When contamination is spotted at the point of collection, the address is noted and a report delivered to the City. This is a mandated function of SB 1383 that will be required on an ongoing basis with the minimum of a monthly report delivered to the City by Republic.
Several important elements are not addressed in the present Republic implementation Plan. Consultant recommends the City pursue the following for inclusion based on the increased rate of $3.32 per household.
• Labeling of existing carts presently in service.
• Provide education plan to ensure compliance with SB 1383. • Delivery of one kitchen caddy per household for storage of food in the freezer or countertop. • Additional route monitoring using best available technology including but not limited to truck- mounted cameras.
The present Republic plan also does not address the cost for additional bins, and other requirements for SB 1383. Consultant recommends that Republic allow a small generator to obtain an additional bin at no cost.
SB 1383’s container contamination minimization section requires a route review for prohibited container contaminants that results in all hauler routes being reviewed annually or performing a waste composition study at least twice per year and in two distinct seasons of the year.
Under a route review approach, containers may be randomly selected along a hauler route. Upon finding prohibited container contaminants, the generator shall be notified. The notice must include information regarding the generator’s requirement to properly separate materials into the appropriate container and may include photographic evidence of the violation. The notice may be left on the container and/or mailed or emailed to the generator. If the generator’s containers contain contamination on more than three consecutive occasions, the jurisdiction may impose additional contamination processing fees on the generator and may impose penalties. As Republic presently conducts this type of observation, Consultant recommends the City make Republic its designee and require them to provide, in writing each month, the address of the generators and the date the contaminated container was observed.
4Note: Section 7295 of the Government Code requires translations of educational materials into any non -English language spoken by a substantial number of the public provided organic waste collection servic es.
9 After successful implementation of the citywide residential and commercial organics collection system, the City may choose to move to a performance -based source separated collection service.5 In that case the City shall notify CalRecycle within 30 days of conducting two consecutive quarterly trash container samplings that each demonstrate meeting the requirements of Article 17 of the SLCP regulations. At that time, a representative of CalRecycle will oversee the next quarterly sampling.
Residential Rate Comparison with other Jurisdictions
Fifteen jurisdictions were contacted for residential and other organic collection plans. All of these jurisdictions will combine the food and other organics in their existing yard waste collection programs. All 15 cities use 96 -gallon bi ns and many will provide additional bins for free or for a nominal charge.
Compared to the three cities selected for analysis, Republic´s rate was higher . However, the largest gap was 18%, and if Republic will commit to the recommendations above, Consultant supports this rate.
Table 4: Residential Rate Comparison
Chula Vista
Rate*
Compared
City**
Compared
City Rate % Difference CV Additional Bins
$3.32 Escondido $3.00 10% (over 3 and up to 8 max) $3.41 each
$30.92 San Bernardino $25.23 18% $12.34
$30.92 El Cajon $25.89 16% Up to 3 recycling and 3 organics carts free.
*Chula Vista’s prices reflects the net rate.
**San Bernardino and El Cajon could not breakout the organics cost. Thus, the total rate for 96-gallon trash, recycling, and organics, respectively, were compared. All cities will collect mixed organics (green waste/food waste), provide a 96-gallon cart for all, including labeling of existing carts, education, oops tags, monthly report and route monitoring.
Analysis of Proposed Commercial Organics Collection Rates SB 1383 mandates that all businesses that generate organics must arrange for collection. Businesses that generate less than two cubic yards of solid waste and can prove that they generate less than 10 gallons of organics per week can seek a wa iver from the City. Businesses that generate more than two cubic yards of solid waste but can prove that they generate less than 20 gallons of organic waste per week, can also seek a waiver.
Commercial businesses will be required to provide containers for the collection for organics and non - organic recyclables in all areas where disposal containers are provided (except restrooms). The lids should comply with the color system chosen and include a label that identifies primary materials for inclusion, as
5 “Performance-based source separated collection service” means a solid waste collection service that meets the requirements of Section 18998.1(a), which includes providing a three -container organic waste collection service to at least 90 percent of the commercial businesses residential sector and ensures “that the presence of organic waste in the gray container collection stream does not exceed an annual average aggregate of 25 percent by weight.” For full text, see Article 17 of the Proposed SLCP Regulations, October 2, 2019.
10 well as those prohibited. Commercial generators are instructed to prohibit their employees from placing organic waste in a container not designated to receive this material. Generators are also required to inspect their containers for contamination and inform employees of any contamination issues.
Generators must provide information to employees a minimum of one time per year about proper sorting of organic wastes. Commercial businesses are not required to replace functional containers purchased before January 1 , 2022 that do not comply with the requirements, however, by January 1, 2036 all containers must comply. It should be noted that if a business does not generate any of the materials that would be collected in one type of container , the business does not have to provide that container in all areas where disposal containers are provided for customers.
SB 1383 includes penalties for violations of the requirements. The penalty levels are as follows:
• For a first violation the amount of the base penalty shall be $50 - $100 per offense. • For the second violation the amount of the base penalty shall be $100 - $200 per offense. • For a third or subsequent violation the amount of the base penalty shall be $250 - $500 per offense.
• Penalties to jurisdictions can reach up to $10,000 per day for major violators.
Multi Family Dwellings
Multi Family Dwellings (MFD) regulations primarily mirror those of the commercial sector. However, MFD owners are required to provide information to new tenants before or within 14 days of occupation of the premises. MFD owners will also need to allow inspections of the premises to ensure compliance with the requirements of SB 1383.
Self-Haul, Local Education Agencies and Non-local Entities The City and/or its designee is required to educate businesses that self -haul. Information regarding self- haul requirements shall be included in education and outreach materials. The City may comply with these requirements through print or electronic media or direct contact with generators through workshops, meetings, or on -site visits. In essence, self -haulers, local education agencies and non -local entities are required to fulfill the same requirements as commercial businesses.
They are required to provide containers for the collection of organic waste and non-organic recyclables in all areas where disposal containers are located (except restrooms). These generators are also required to maintain records of the amount of materials hauled for inspection by the City.
Analysis of Solid Waste Collection Rates
As the City is only looking at a pricing change in the area of organics, the solid waste collection rates will remain the same. However, it is useful to compare rates of collection with other jurisdictions to ensure rates remain equitable.
Table 8 illustrates the City rates with other chosen jurisdictions. Although the City does not maintain the lowest rate for collection of solid waste, it is a close second behind Escondido.
11 Table 8: Comparison of Solid Waste Collection Rates by Jurisdiction Chula Vista San Bernardino Escondido El Cajon El Cajon* 1 x 1cy x 1x/wk N/A $138.83 $152.37 $169.30
1 x 1.5cy x 1x/wk $85.88 N/A $75.46 $160.39 $178.21
1 x 2cy x 1x/wk $98.21 $139.46 N/A $171.08 $190.09
1 x 3cy x 1x/wk $133.19 $148.82 $111.56 $213.85 $237.61 1 x 4cy x 1x/wk $212.11 $163.99 $145.57 $256.63 $285.14 1 x 5cy x 1x/wk $265.07 N/A N/A N/A N/A
1 x 6cy x 1x/wk $318.08 $238.00 N/A $352.85 $392.06
*Bundled rate in which includes 1x/wk 96-gallon recyclable collection and 1x/wk 96-gallon organics collection.
Bold denotes lowest rate.
As SB 1383 basically requires any generator of organics to arrange for collection, this law will affect all businesses within the City.6 The intent of the law is to reduce greenhouse emissions by removing organics from landfills and reach a 75% recycling rate. It is useful to review all materials to ensure the City is pursuing a methodology in which customers are able to maximize equitable rates as they become more environmentally friendly.
For this reason , Consultant compared Chula Vista´s bundled rate with El Cajon´s bundled rate. The City allows small businesses to participate in the small quantity generator program. Hence, small commercial business will see very little cost increase. And this works as an incentive for other to reduce wastes generated. As Table 9 indicates, Chula Vista’s bundled rate is on par with El Cajon and even less expensive for the smaller generators.
Table 9: Comparison of El Cajon Bundled Rate with Chula Vista* CV Trash CV Recycling CV Organics
CV
Total** El Cajon
%
Difference
1 x 96g x 1x/wk $27.60 Included $3.32 $30.92 N/A N/A
1 x 1cy x 1x/wk N/A N/A N/A N/A $169.30 N/A
1 x 1.5cy x 1x/wk $85.88 $72.07 $20.01 $177.96 $178.21 -0.1% 1 x 2cy x 1x/wk $98.21 $72.07 $20.01 $190.29 $190.09 0% 1 x 3cy x 1x/wk $133.19 $72.07 $20.01 $225.27 $237.61 -5% 1 x 4cy x 1x/wk $212.11 $72.07 $25.90 $310.08 $285.14 +8% 1 x 5cy x 1x/wk $265.07 $72.07 $25.90 $363.04 N/A
1 x 6cy x 1x/wk $318.08 $72.07 $25.90 $416.05 $392.06 +6% *Bundled small quantity generator rate which includes 1x/wk 96-gallon trash, recyclable, and organics collection. **Bold denotes lowest rate per service level.
6A waiver can be obtained for any entity generating less than two cubic yards of solid waste per week and 10 gallons of organics, or generating two or more cubic yards per week and no more than 20 gallons of organics.
12 Programmatic Actions for the City of Chula Vista
This section summarizes the actions that will be required of the City to meet the tenets of SB 1383.
SB 1383 attempts to support edible food recovery. Therefore, it requires that before February 1, 2022 that the City develop the following:
• A list of food recovery organizations that is updated annually and maintained on the City’s website.
• Annually provide commercial edible food generators with information about the City’s program, how to set up a program, how to prevent the creation of food waste, and a list of food recovery organizations. This information may be included with regularly scheduled notices to commercial businesses.
• SB 1383 requires Tier One commercial edible food generators to maximize the amount of edible food recovery by January 1, 2 022, and Tier Two generators by January 1, 2024. Generators are required to maintain records on the quantity of food collected or self -hauled to a service or organization for food recovery.
• Labels on all containers must clearly indicate the primary materials that are accepted and the primary materials prohibited in each container. CalRecycle has model labels which can be utilized to fulfill this requirement.
• SB 1383 contains recordkeeping requirements that the City will be required to submit the CalRecycle. An initial Jurisdiction Compliance Report will be due to CalRecycle by April 1, 2022 and an annual report will be required in August 2022 for the period of January 1, 2022 through June 30, 2022.
The following provides a condensed list of the actions that must be taken before the February 1, 2022 deadline. In most of the regulations it is referred to as an Implementation Record that must be stored in one central location. Upon request the City will provide access to the Implementation Record within 10 business days.
• Identify programmatic funding mechanisms for the edible food recovery program. • Adopt a CALGreen Building Standards and Model Water Efficient Landscape Ordinance. • Procure or give away recovered organic waste products in a ratio of 0.08 tons organic waste to the City’s total population (see Attachment 1).
• Procure recycled content paper products.
• A description of which collection method(s) it will use. • A description of the strategy to address, fund and implement programs for self -haul (non - franchised) generators.
• An enforcement and inspection program by January 1, 2022. • Adopt ordinances, contracts, franchise agreements, policies, procedures or programs.7 • A description of the City’s process for determining the level of container contamination. • A description of the process for issuing waivers and the frequency of inspections to verif y the validity of the waivers. Retention of all copies of waivers issued.
7 CalRecycle is developing SB 1383 model ordinances that Consultant recommends the City adopt upon completion.
13 • A record of the amount of solid waste removed from homeless encampments and illegal disposal sites if the amount of material removed is more than 100 tons. • Copies of all educational outreach including but not limited to flyers, brochures, n ewsletters, invoice messages, website and social media postings, bill inserts (including the date, as well as the type and number of accounts receiving the information). • Documentation of route reviews or waste composition studies. • Copies of all notices and enforcement orders issued to generators with prohibited container contaminants.
• Documentation of the number of containers disposed due to contamination. • The geographical area for each collection method.
• A list of all organic waste processing facilities utilized. • Copies of quarterly and annual average mixed waste organic content recovery rates for those facilities utilized.
• A list of all approved haulers allowed to use the organic processing facilities. • The geographical areas the hauler serves.
Analysis of Republic’s Proposed Commercial Food Waste Processing and Operations Plan
Existing Operation
The Research Compost Operation (RCO) ends in October 2020, after beginning in 2012 with an open windrow system, and starting with the GORE® Covered Co mposting System in 2018. Republic staff is pleased with the results of the GORE® System employed, and during a site tour on July 23, 2020, Consultant found it satisfactory for the trial volumes of material being handled. A review of LEA inspections found no Areas of Violation during the eight-year research period.
Upon the same site tour on July 23, 2020, Consultant reviewed the green waste grinding area, operated by a third-party entity, Recycle-X, as well as the Plant’s Choice composting operation. Recy cle-X handles grinding for all green waste processing and composting operations onsite, and Plant’s Choice composts and markets end-products not designated for ADC or beneficial reuse, and clean enough for sale.
The grinder was down and being repaired du ring Consultant’s visit, and there were substantial volumes of both ground and unground green waste onsite. There was also a large pile of unprocessed lumber, pallets and wood onsite. Based on Consultant’s observations, and review of LEA inspection records , Recycle-X is challenged with keeping up with the incoming flow of materials that require grinding, and the footprint of the area is too small to allow for spreading and sorting out contaminants prior to grinding.
This phase of operations is critical to p roduction of market suitable products , as well as the expanded program Republic has proposed.
Utilization of the Grinder
The grinder used is fitted with 6” screens - a size and grind suitable for ADC, marginal for beneficial reuse, but not appropriate for use in compost feedstock or finished product marketing. Consultant observed significant plastic and other contaminants in ground material piles designated for onsite use, as well as finished products designated for sale. This coarsely ground material is also used for beneficial reuse, such
14 as stabilizing slopes, but those slopes are in the active footprint of the landfill, and will eventually be covered with solid waste material, rendering this activity counterproductive to the City of Chula Vista and CalRecycle’s goals of diverting compostable materials from the landfill. Further, material spread on slopes is not fully composted, and a potential source of odors.
LEA Inspection Reports
Per the most recent LEA inspection online, conducted on July 28, 2020:
“The amount of unprocessed green waste and wood waste at the Recycle-X chip and grind operation had not changed and the grinder continues to experience down times for repairs. According to site records, the grinder was down from July 1 to July 7, 2020. A maintenance and monitoring program shall be established to include the tub grinder and other equipment that is relied upon for site operations.”8 Per the LEA inspection conducted on June 26, 2020:
“The amount of unprocessed green waste and wood waste at the subcontractor Recycle-X chip and grind operation has continued to increase in size since the previous inspection. The grinder was not in operation at the time of the inspection but down for repairs. The shared equipment from the local Sycamore Landfill was also down for repairs.” 9
And per the LEA inspection conducted on May 21, 2020:
“The amount of unprocessed green waste and wood waste at the Recycle-X chip and grind operation had tripled since the previous inspection. The grinder was observed in operation at the time of the inspection and had not been documented down for repairs to account of the increase.”10
Per the LEA inspection conducted on June 26, 2020:
“A significant amount of processed green material had been stockpiled in vario us locations around the landfill for use as erosion controls. Some of the processed green material had been spread out along the side slope for erosion controls was measured for temperatures and observed up to four feet deep near the top slope of Canyon 3. Ensure the processed green material stockpiled along the side slopes are spread out in a timely manner to prevent composting temperatures that can contribute to odors and applied to a maximum thickness up to 12 inches after compaction for erosion controls to minimize the excess use.”11
Document Review
Consultant reviewed the following documents:
“Republic Services Proposed Commercial and Residential Organic Food Scraps Recycling Program, ” undated
“Amendment 1 – Republic Services Proposed Commercial and Residential Organic Food Waste Scraps Recycling Program,” dated April 15, 2020
8https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/315982?siteID=2863 9https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/306825?siteID=2863 10https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/291646?siteID=2863 11https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/306825?siteID=2863
15 “Amendment 2 – Republic Services Proposed Commercial and Residential Organic Food Waste Scraps Recycling Program (Compost Marketing),” dated June 2, 2020
“Amended and Restated Solid Waste Collection and Recycling Franchise Agreement, ” signed October 1, 2014
CHULA VISTA FRANCHISE - 2019/2020 RATE SCHEDULE FOR SQG, LQG AND INDUSTRIAL SERVICES, revised September 9, 2019
OTAY LANDFILL, INC. COMPOSTING OPERATION, REPORT OF COMPOSTING SITE INFORMATION (RCSI), dated April 2020
OTAY LANDFILL, INC. COMPOSTING OPERATION, REPORT OF COMPOSTING SITE INFORMATION (RCSI), dated June 2020
CalRecycle SWIS Facility/Site Inspections, Otay Landfill [Chipping and Grinding Facility/Operation] (37-AA- 0010), multiple dates ranging from April 14, 2017 to June 6, 2020
CalRecycle SWIS Facility/Site Inspections, Otay Landfill Research Composting Op. (37 -AA-0984), multiple dates ranging from September 20, 2012 to April 21, 2020
Note: Consultant has not received nor reviewed the permit submittal for the Transfer Station Building.
Plan and RCSI Review
Consultant found discrepancies between the plan submitted to the City of Chula Vista entitled, “Republic Services Proposed Commercial and Residential Organic Food Scraps Recycling Program (Plan),” and the OTAY LANDFILL, INC. COMPOSTING OPERATION, REPORT OF COMPOSTING SITE INFORMATION (RCSI), dated June 2020.
For example, the Plan states: “At the end of the first 30 days [Phase I] the composted material will have reached a stable level and the chance of odor release will be greatly diminished. The GORE® Cover is pulled back and the material will be moved by loader for a second phase. Oxygen demand is greatly reduced, so the piles are allowed to aerate by natural convection (rather than active aeration) and to age.” The RCSI States: “GORE® Covers are used only in Phase I and II of the composting process.”
The Plan lacks the same narrative contained in the RCSI addressing feedstock volumes and handling, measures to minimize contamination and malodor generation, as well as processing detail using the Gore Cover System at the Otay Landfill location.
The intent is not to nitpick, but rather exemplify an apparent lack of common understanding of the system planned to be used to handle Chula Vista’s material. While the RCSI is important for permitting, it is not a planning document, and coordination between the division of Republic responsible for permitting and that of planning and implementation of the system is critical to its success. The City received a five -page plan that encompasses both collection and processing. Two amendments to the plan have also been submitted.
16 Given the existing green waste processing program has challenges with grinding, capacity and end product quality, adequate planning for the transition and ongoing operation of a facility accepting food waste at scale is crucial, with many details to be worked out and absent from submitted planning documents.
Recommendations
The Plan should be revised and resubmitted to contain:
A site map clearly defining where commingled food waste/green waste will be tipped, sorted (cleaned of contaminants), and ground; process flow from grinding area to GORE heaps; orientation of GORE heaps; and process f low from GORE heap phases to designated cure, screening and finished product staging areas. It is understood that the system will be moveable and moved per landfill operation requirements, but the initial location of the system represents a strong factor in operational efficiency, contamination removal, finished product quality and dust and odor control. Per the RCSI, nearly the entire footprint of the landfill is delineated for composting.
Amendments 1 and 2 incorporated into a final document , which also corresponds with and has operational protocols that match the RCSI and Transfer Station Building permit document submitted to the LEA.
A description of how contaminants will be removed from curbside, commingled food and green waste, as well as the system and area for doing so. This is a key el ement to producing a marketable end product, and the Transfer Station Building and Scott Equipment Turbo Separator is designated for handling commercial food waste (per discussions with Republic staff), and not for residential material. The current designated grinding area is too small to allow for spreading material and removing contaminants.
A more detailed description of how compost and mulch quality will be maximized and marketed.
Republic’s Amendment 2 discusses the company’s success marketing compost in Northern California, and replicating “many learned strategies and best practices for the Chula Vista/San Diego market.” This is a sound foundation and excellent experience for development of a local marketing campaign. But as this is an exceptionall y competitive marketplace for compost and mulch 12, it is unclear why Republic isn’t including in planning the current marketing arm for finished material produced at Otay, Plant’s Choice. In addition to having a CalRecycle Notification tier permit and the permitted capacity to accept 200 tons per day of green waste - which could assist Republic with overflow once operating at full scale - Plant’s Choice already has a strong foothold in the San Diego County market, selling some 50,000 -60,000 cubic yards of mulch and 10,000 - 15,000 cubic yards of compost regionwide annually.
Analysis of Republic’s Proposed Commercial Food Waste Processing and Operations Plan as it Pertains to Zero Waste Principles
As noted above, producing coarsely ground material and substandard compost for the primary purpose of beneficial reuse, such as stabilizing slopes in the active footprint of the landfill that will eventually be
12https://www.sandiegocounty.gov/content/dam/sdc/dpw/SOLID_WAST E_PLANNING_and_RECYCLING/Files/Com postMulchMarketStudy_052020.pdf
17 covered with solid waste material, is counter to removing organics from the landfill and the City’s Zero Waste goals. Organic materials planning should include methods for maximizing the quality of end products, removing contaminants prior to grinding, screening at sizes appropriate for the successful production of marketable composts and mulches, and robust outreach to ensure participation rates are high within both the residential and commercial sectors.
Zero Waste is “the conservation of all resources by means of responsible production, consumption, reuse, and recovery of products, packaging, and materials without burning and with no discharges to land, water, or air that threaten the environment or human health.”13 As compostable materials produce methane and other atmospheric-trapping greenhouse gasses when buried in a landfill, they should be kept from this practice, including ADC and beneficial reuse on slopes that will be covered with landfilled materials in the future. “Compost should be used locally to grow food and restore the soils to enhance food security, local self-reliance and sustainability. By sequestering carbon in soils and decreasing use of irrigation, pesticides and fertilizers, composting further helps to reduce the emission of global warming gases.”14
Attachment 1: Chula Vista Estimated Compost Procurement Targets, Cost and Retail Value
Procurement target of organic waste as required by Article 12, Proposed SLCP Regulations dated October 2, 2019 (Population: 263,466 X .08 tons/resident = 160 lbs/resident):
13 http://zwia.org/zero-waste-community-principles/
14 http://zwia.org/zero-waste-community-principles/
18 • 21,077 tons year
Procurement target of processed compost (using the following SB 1383 Compost Conversion Factors:
0.58 tons per ton recovered organic product or 1.45 cubic yards (cy) per ton recovered organic product)
• 12,225 tons/year compost or
• 30,562 cy/year compost
Estimated cost to produce compost: $152,810 (based on $5/cy) Estimated retail value: $305,620 (based on market value of $10/cy)