COMPOSTING 101

What is composting?
What can be composted?
Composting technologies
What's so good about compost?
EPA Region IV overview

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By Lynn McCracken Lucas

Backyard and on-farm composting operations processing only feedstocks generated by the family or on the farm for beneficial reuse by the entity are usually exempt from permit requirements.  (However, if you think you can run a sloppy operation, think again.  Your compost pile will still fall within the purview of a regulatory agency.)

For everyone else, the joy of regulatory permitting awaits, and while EPA 503 regulations provide the common thread running through all regulations governing composting operations, each state puts its own color on them.  Air permits, for example, are not required for composting facilities in some states, but are in others.  Some regulatory bodies have more experience with certain waste streams than others.  Where one state is very specific, another might be quite general, and vice versa. 

Historically, regulators have segregated compostable waste streams into three broad permitting categories:

·   Agricultural: manure products (liquid, semi-solid, and/or solid) and mortality.

·   Biosolids: residuals (liquid, semi-solid, and/or solid) from the treatment of wastewater from municipal and industrial sources.

·    Solid waste: everything else.

Strictly from a composting perspective, there is little reason for such multiplicity, especially when the trend is to apply EPA 503 regulations to all composting processes, regardless of the feedstock.  To composters, it’s all about biophysical characteristics, moisture levels and C:N ratios.  The generator is as irrelevant as the name folks use to describe the stuff (a stinking rose by any other name smells the same). But regulators don’t think like composters, so more than one agency may have a say in what you compost and how you do it.

Fortunately, when a facility wants to process feedstocks from multiple categories, one agency will, typically, take the lead and write one permit that incorporates restrictions and standards contributed by other jurisdictional divisions.  This saves the facility owner from the nightmare of having to secure multiple regulatory permits for one composting facility.

In addition to state requirements, you’ll also need to satisfy local jurisdictions. Zoning applications and construction permits/inspections are to be expected. The U.S. Army Corps of Engineers and other jurisdictional agencies are often involved in the permitting process to delineate wetlands, approve sediment and erosion control plans, etc.

But while wading through the paperwork and approvals that precede construction and operation of a composting facility, it’s important to remember regulators are not the enemy and regulations have not been designed to make life difficult for composters.  The job of the regulatory community is to safeguard your health and the health of your workers, the public, and the environment.  As a responsible compost manufacturer, that should be your highest priority, too.

Gird yourself in armor and walk into a regulator’s office with your sword swinging, and you’ll get a battle.  But prepare for the meeting with knowledge, information, and the desire to provide that civil servant with everything s/he needs to understand your operation and make well-informed decisions, and you’ll get an adviser for the price of a permit.  

Obtaining a permit to operate a composting facility is not as simple as walking into the local planning department with some blueprints and walking out with a permit. The length of the actual regulatory review process depends on the complexity of your application and how long it takes you to submit all of the required information. 

For regulators, the clock doesn’t start ticking until all of the information required for review has been submitted.  Since there can be a lapse of weeks or months between the day you submit the initial application and when it actually filters to the top of the stack on a harried permit writer’s desk, allow twice the length of time stated in the agency’s public propaganda.   Regulators will almost always ask for clarification or a bit of information you didn’t include. 

If the omission is minor, the review process may continue while you gather up the missing data or documents.  But a major boo-boo could send the application back to you for revision and re-submittal.   If this happens, listen carefully to the regulator’s expectations and, in your next attempt, provide exactly and completely the information s/he requires.  Otherwise, you’ll have the application thrown back on your desk again.

Regulations, and the policies and procedures that support them, are always changing.  So are composting technologies.  Fortunately, most regulations allow for innovation with language that enables the permitting of a new process if it meets goals and objectives for pathogen reduction and vector control.

Documents commonly required for composting facility applications include:

·   Local approvals

·   Flood plain and wetlands delineation

·   Endangered species and archaeological determinations

·   Site geology

·   Construction drawings, process description, operations plan including details on vector and pathogen management, marketing plan for finished compost

·   Closure plans

·   Stamp and letter from a state-certified engineer for the entire application package, not just construction documents

For copies of composting regulations for each state, application forms, contacts, and other essential information, a good starting place is www.findlaw.com where you’ll be able to search for and go directly to regulations for the various states, by-passing  the morass of websites that turn up on a typical Google™ search.

The following overview of composting in southeastern states is intended for general information only.  Contact the appropriate state agency for detailed guidelines and procedures for composting facility permitting and operation, as well as local resources and associations.

THIS NEXT SECTION IS VERY SKETCHY, FOLKS.  WE NEED HELP IN FILLING IN THE BLANKS.  PLEASE MAKE PHONE CALLS TO YOUR CONTACTS AND COLLEAGUES WITHIN STATE REGULATORY AGENCIES AND ASK THEM TO SEND UPDATED INFORMATION TO thegooddirt@yahoo.com.

A.  Alabama

          Alabama Department of Environmental Management

            1400 Coliseum Blvd.

            Montgomery, AL 36110

            TEL: 334-271-7700

            EMAIL:  webmaster@adem.state.al.us

            WEB:  http://www.adem.state.al.us

 SOLID WASTE:  everything (including mortality and offal) except household sewage and livestock and poultry wastes can be composted as solid waste and regulated by the Alabama Department of Environmental Management. 

 SEWAGE SLUDGE: 

         Alabama Department of Agriculture and Industries

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            EMAIL: 

            WEB:  slkdfjslkfjsldkfj

ON-FARM: Alabama Department of Agriculture and Industries inspections are required for composted agricultural by-products (litter, manure, mortalities) to be removed from the farm of origin.

 B.  Florida.

 C.  Georgia.

          Georgia Department of Agriculture

            Animal Industry Division

            19 M.L. King Jr. Drive, Room 106

            Atlanta, GA 30334

            TEL: _____________________

            EMAIL: ___________________

            WEB:  ____________________

ANIMAL MORTALITY:  Submit a written request for a disposal permit to the State Veterinarian.  “Well-composted” material, defined by the state as having “undergone at least two heat cycles and be devoid of flesh” can be used off-farm.

D.  Kentucky.

E.  Mississippi.

F.  North Carolina.

          t/c

G.  South Carolina.

          t/c

H.  Tennessee.

Figure 2:   EPA Region IV  permitting matrix