Alternative Measurement Protocols

The SB 1383 regulations added new state minimum standards to Title 14 of the California Code of Regulations (CCR). These new standards require organic waste measurement protocols for transfer/processing facilities and operations, compostable material handling facilities and operations, and in-vessel digestion facilities and operations. If an operator proposes a different sampling frequency or to use a different measurement protocol than those outlined in Title 14, the operator must submit a site-specific alternative measurement protocol (AMP) proposal to their EA for approval and CalRecycle for concurrence. Once the AMP is approved, the operator can begin implementing their approved alternative.

The types of AMP proposals an operator could consider are:

  1. Alternatives to measurements that are as accurate as the measurement requirements (i.e., different sampling frequency, different sampling weight, etc.).
  2. For transfer/processing facilities and operations only: Substitutions to requirements to sample and measure specific types of organic waste designated for recovery if those waste outputs have a quality standard required by a receiving entity.

What would be helpful to include in an AMP proposal?

The regulations do not outline requirements for what must be submitted in an AMP proposal. Information that could be useful to help EAs and CalRecycle assess whether an alternative or substitute will yield “as accurate” results as the otherwise required measurements under sections 17409.5.2 – 17409.5.8:

  1. A clear description of what alternatives/substitutions are being proposed, including what regulatory section the alternative pertains to;
  2. A clear description of how the alternative measurements meet the required quality standards (if substituting for an existing quality standard);
  3. Diagrams/ flow charts depicting the movement of material streams at the facility;
  4. Description of methodology of proposed alternatives (if applicable);
  5. Any applicable data collected from any similar measurements or waste studies; and/or
  6. Any additional documentation that supports any statements regarding amount of incompatibles in recovered organic material streams or amount of organics in material destined for disposal.

Can a facility test an AMP before submitting a proposal?

An operator may conduct a study to gather data on the effectiveness of a potential AMP. The operator should request permission from the EA to do a study, as there may be some operational changes which could trigger a permit action. In the request, the operator may include information such as: a list of responsible parties for the study and chain of command, a time frame of the study, and any operational changes required during the study.

If the study shows the AMP is effective, then the study and any data can be submitted to EA for consideration with the AMP proposal. Then after CalRecycle concurrence, the AMP may be fully implemented. Note that conducting a study to determine effectiveness of the AMP does not relieve the operator from complying with the applicable measurement(s) requirements in the meantime.

Submission, Approval, and Implementation of AMP

Upon receipt of a draft or final AMP proposal, the EA will determine whether the proposed AMP is as accurate as the otherwise required measurements. EAs are encouraged to contact CalRecycle to request consultation during the review of an AMP. EAs can also use the Alternative Measurement Protocol Rubric shared in the Resources section below to assist in their review.

If the EA approves the AMP, then the approved AMP should be forwarded to the CalRecycle permitting point of contact staff with a request for concurrence. Before the EA allows implementation of the AMP, the EA must be in receipt of CalRecycle’s concurrence. The operator of a solid waste facility or operation shall keep a record of their approval of alternatives in their operating document, as described in Title 14 for transfer/processing facilities and operations, compostable material handling facilities and operations, and in-vessel digestion facilities and operations.

For a list of approved AMPs, please see the table below.

Changes to a Facility’s Design and/or Operation to Implement an AMP

The approval of an AMP does not constitute approval for any change in design or operation at a facility. Accordingly, the operator of a fully permitted solid waste facility should refer to 27 CCR section 21620 to initiate the process of making a proposed change to the design or operation as a result of the approved AMP. The proposed change may or may not qualify as a minor change.

EA Approved Alternative Measurement Protocols

Below is a list of AMP proposals that have been approved by an LEA with concurrence by CalRecycle. This list is not comprehensive but shows different categories of AMPs approved. For more information about a specific AMP, please reach out to the Local Enforcement Agency.

FacilitySWIS NumberSection(s) AffectedSummary of Alternative Measurement ProposedDocuments
Bradley East Processing/ Transfer Station19-AR-123717409.5.2, 17409.5.3, 17409.5.4, 17409.5.8The facility will measure the inbound mixed waste organic stream and some source separated organics material (separately) and outbound materials from both streams sent for disposal. Using a mass balance calculation, the facility will determine the amount of organics sent for recovery from those streams. The facility will use laboratory analysis to determine incompatibles in material sent to an anaerobic digestion facility for recovery.CalRecycle Concurrence Letter; LEA Approval Letter
Tehama County/City of Red Bluff MRF52-AA-002717409.5.4Old Corrugated Cardboard (OCC) and Old Newsprint (ONP) will be sampled following the methods described in the regulations, but it will happen prior to being baled.CalRecycle Concurrence Letter; LEA Approval Letter
Auburn Placer Disposal Transfer Station31-AA-060117409.5.4, 17409.5.8The facility will consolidate and store all samples collected during the 10 consecutive day period. On the 10th (or final) day of the measurement period, the facility will sort the samples for incompatible material.CalRecycle Concurrence Letter; LEA Approval Letter
HZIU Kompogas SLO, Inc.40-AA-005117896.44.1The operator will collect a 10-pound sample each day from the material destined for disposal during the 10-day measurement period. At the end of the measurement period, the operator will combine the samples and send one 10-pound sample to a laboratory for analysis to determine the organic fraction. The organic fraction (percentage) will be applied to all material destined for disposal during the measurement period.CalRecycle Concurrence Letter
Marin Sanitary Service Transfer Station21-AA-000517409.5.4The operator will sample their green waste, food waste and chipped wood for three consecutive days instead of ten consecutive days. Using the sampling data from the three days, the operator will calculate the amount of incompatible materials and organic waste recovered for the remaining consecutive operating days of the measurement period. A condition was set to revert to sampling for ten (10) consecutive operating days if at any time during the sampling period the level of incompatible materials exceeds 5% in any of the recovered organics. CalRecycle Concurrence Letter;
LEA Approval Letter;
AMP Request
Puente Hills Material Recovery Facility19-AA-104317409.5.4, 17409.5.8The facility will determine weight of organic waste recovered for each sampling day with a mass balance equation of inbound food waste, outbound food waste send for disposal and amount of incompatible materials in recovered food waste that is slurried. The facility will use laboratory analysis to determine incompatibles in slurried food material. CalRecycle Concurrence Letter;
LEA Approval Letter;
AMP Request

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