Treated Wood Waste Disposal - Local Government Letter to CalEPA

By Alyssa Silhi posted 12-03-2020 01:08 PM

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CSDA signed onto a letter to CalEPA with a variety of local groups and the solid waste industry in regard to the Governor's veto of SB 68 (Galgiani) which would have repealed the sunset date for management and disposal of Treated Wood Waste (TWW) in a composite-lined portion of a solid waste landfill. As a result of the veto, all hazardous treated wood waste managed in California will have to be stored and manifested as hazardous waste and transported to class I hazardous waste landfills for disposal and is subject to the full range of standards for management and disposal of hazardous waste. These include a limit that the material cannot remain on the generator’s site longer than 90 days, cumbersome storage and labeling requirements, required shipment on a hazardous waste manifest, and disposal at a full hazardous waste facility.

The costs involved with treated wood waste will have impacts on any district that disposes of wood waste or treated woods from general operations and will significantly increase the cost of disposal and complicate a district's ability to arrange the transport of TWW products. The average cost to dispose TWW in a hazardous waste Class I landfill is over eight times the cost of disposal in a Class II or Class III landfill and there are no more than three Class I landfills, and all are located in remote areas that are considerable distances from where TWW is generated.

The letter’s intent is to highlight concerns with TWW management and disposal beginning January 1. Just as important, it is asking the Administration to work quickly to develop a short-term fix until we can collectively try to craft another legislative solution. CSDA will continue to update on this issue as developments occur.
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