SMMP Prerequisite 1: Comprehensive Sustainable Materials Management Policy and Programs

SMMP Prerequisite 1: Comprehensive Sustainable Materials Management Policy and Programs (Required)

Non-Reciprocal

Intent:

To promote the highest and best use of materials and to reduce the overall generation of waste through the adoption of government or corporate policies and programs.

Requirements:

Local Government Requirements

Design and adopt a Comprehensive Sustainable Materials Management policy that covers all of the following elements as applicable to the jurisdiction:

• Include a clear statement of waste reduction goals.

• Establish programs that minimize the generation of waste at the source.
  • Develop a roadmap that gradually diverts materials away from landfills and waste-to-energy facilities.
  • Set procurement rules for environmentally preferred products (EPP) and recycled content products, with emphasis on domestic infrastructure.
  • Define requirements for source separation of materials, depending on material management system used.
    • Includes a Disaster Debris Management Plan
  • Environmental and energy performance standards for collection vehicles

• Establish a public and Local Government employee education and information program.

• Require best available management practices for landfill operations (methane recovery, leachate treatment, odor and vector control, safety, alternative daily cover contamination minimization)
  • Provide thorough documentation of all greenhouse gas emissions from landfills and describe the use of the best available technology as approved by the US EPA to monitor greenhouse gas emissions.
    • Provide thorough documentation of emissions leakage from energy recovery system
    • Conduct a net benefit analysis that assesses whether producing energy from LFG recovery systems produces less GHGs than flaring emissions or producing energy from fossil fuels.

• Landfill facilities that utilize LFG as a renewable energy source can be managed to maximize landfill gas recovery but must not be managed to maximize landfill gas production, such as treating it like a bioreactor and/or recirculating leachate.

• Alternative Daily Cover (ADC) use should meet Federal and State regulations as well as the following:

• Use of ash and sewage sludge is prohibited unless the face of the landfill is covered by a tarp or other approved dust suppression techniques are used (foams or slurries)

• Require the use of continuous active dust suppression techniques

• Do not permit the use of materials, such as glass, that have better avenues for disposal and recycling.

• Require best available management practices for waste to energy and thermal conversion operations (minimum: meet state emissions standards; better: best available particulate and criteria air pollution control)
  • Provide thorough documentation of all greenhouse gas emissions from waste-to-energy and thermal conversion facilities and describe the use of the best available technology to monitor greenhouse gas emissions.

• Require disposal of ash in methods least harmful to the environment
  • Use of ash and sewage sludge is prohibited unless:
    • the face of the landfill is covered by a tarp or other approved dust suppression techniques are used (foams or slurries)

• Adopt specific MWBE/Veteran owned business share goals

• Include a stakeholder outreach and participation plan that:

• Establishes practices and/or programs to timely respond to any community complaints

• Includes both business and residents and is inclusive of all communities

• Is sensitive to environmental justice concerns, including accounting for:
  • Impacts on public health and quality of life
  • Impacts on the job market and communities’ employment opportunities

• Identifies plans to provide protection and ensure environmental justice to its community when stakeholders may hold conflicts of interest.

 Industry Requirements

Design and adopt corporate environmental goals and programs that cover all of the following elements as applicable to the activities of the company:

• Include a clear statement of waste reduction goals.

• Establish programs that minimize the generation of waste at the source.
  • Develop a roadmap that gradually diverts materials away from landfills and waste-to-energy facilities.
  • Set procurement rules for environmentally preferred products (EPP) and recycled content products, with emphasis on domestic infrastructure.
  • Define requirements for source separation of materials, depending on material management system used.
    • Includes a Disaster Debris Management Plan

• Environmental and energy performance standards for collection vehicles

• Establish an employee education and information program

• Require best available management practices for landfill operations (methane recovery, leachate treatment, odor and vector control, safety, alternative daily cover contamination minimization)

• Provide thorough documentation of all greenhouse gas emissions from landfills and describe the use of the best available technology as approved by the US EPA to monitor greenhouse gas emissions.

• Provide thorough documentation of emissions leakage from energy recovery system
• Conduct a net benefit analysis that assesses whether producing energy from LFG recovery systems produces less GHGs than flaring emissions or producing energy from fossil fuels.

• Landfill facilities that utilize LFG as a renewable energy source can be managed to maximize landfill gas recovery but must not be managed to maximize landfill gas production, such as treating it like a bioreactor and/or recirculating leachate.

• Alternative Daily Cover (ADC) use should meet Federal and State regulations as well as the following:

• Use of ash and sewage sludge is prohibited unless:
  • the face of the landfill is covered by a tarp or other approved dust suppression techniques are used (foams or slurries)

• Require the use of continuous active dust suppression techniques

• Do not permit the use of materials, such as glass, that have better avenues for disposal and recycling.

• Require best available management practices for waste to energy and thermal conversion operations (minimum: meet state emissions standards; better: best available particulate and criteria air pollution control)

• Provide thorough documentation of all greenhouse gas emissions from waste-to-energy and thermal conversion facilities and describe the use of the best available technology to monitor greenhouse gas emissions.

• Require disposal of ash in methods least harmful to the environment
  • If ash is used as an alternative daily cover:
    • Require tarping of the landfill or the use of foam or slurries as cover.

• Adopt specific MWBE/Veteran owned business share goals

• Include a stakeholder outreach and participation plan that:

• Establishes practices and/or programs to timely respond to any community complaints

• Includes both business and residents and is inclusive of all communities

• Is sensitive to environmental justice concerns, including accounting for:
  • Impacts on public health and quality of life
  • Impacts on the job market and communities’ employment opportunities

• Identifies plans to provide protection and ensure environmental justice to its community when stakeholders may hold conflicts of interest.

 Potential Strategies

• Look comprehensively at materials management issues.
• Require use of recycled materials so long as material is to spec, and cost is equal.
• Require best available landfill management practices, including management of methane recovery, groundwater management, leachate treatment, odor and vector control, safety, etc.
• Require best available management practices for waste to energy and thermal conversion facilities/operations (minimum: meet federal and state emissions standards; better: best available particulate and criteria air pollution control)

• Conduct a life cycle assessment of different waste management options that assess the option’s environmental components.
  • Minimally, the assessment should include:
    • All GHGs, criteria air pollutants and hazardous air pollutants emitted from waste to energy facilities, thermal conversion facilities and landfills without discounting biogenic emissions from waste to energy and thermal conversion facilities
    • The number of people impacted within a given radius and the demographics and health disparities of the impacted population
    • Jobs generated
  • Evaluate and quantify the externalized costs of:
    • The health impacts of pollution on impacted communities
    • Environmental and social impacts of waste to energy, thermal conversion and incineration from NOx and PM emissions
    • Production and disposal
  • As well as social and economic components

Note: Life cycle assessment should not account for waste diverted from landfills to waste to energy and thermal conversion facilities.