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4d - CR&R Diversion Estimation Report Protecting our community's health and the environment by providing solid waste and sewer collection services. www.cmsdca.gov Costa Mesa Sanitary District ….an Independent Special District Memorandum To: Board of Directors Via: Scott Carroll, General Manager From: Javier Ochiqui, Management Analyst Date: November 12, 2013 Subject: CR&R Diversion Estimation Report Summary On May 23, 2013, the Board of Directors received the CR&R, Inc., Environmental Services (CR&R) performance audit results and directed staff to implement the recommendations that were cited in the final audit report. One of the recommendations was to establish a more defensible waste diversion methodology. While the CRT Material Recovery Facility (MRF) has substantiated all diversion claims, the consultant believed that improvements to the “front-end” characterization model were needed. Staff is providing the Board of Directors with the improved methodology for estimating the diversion of waste from CMSD and processed by CR&R. Staff Recommendation That the Board of Directors accept the new diversion methodology and require CR&R to use this method in all future sorts. Analysis During the process of auditing CR&R, the consultant noted several potential deficiencies in the methodology employed by CR&R in developing waste diversion estimates. However, there were many valuable components with the previous methodology, so this revised methodology was performed to fine-tune the areas that may potentially be deemed deficient by future or State auditors. The following areas were deemed problematic with regard to the current diversion estimates: Board of Directors November 12, 2013 Page 2 of 4 • Justification of route areas chosen for sampling has not been supported by any demographic data. • Existing methodology only established recycled material composition and did not address how facility diversion capabilities were incorporated into establishing what is recycled versus what is disposed. • No characterization was performed on non-recycled material thus the composition of disposed wastes is unknown. • Sample sizes (average of approximately 250 pounds) of 1% to 2% of full vehicle loads may be too small to provide an accurate representation of material composition. In order to address these areas, the following steps in the methodology process were implemented (Attachment 1): 1. Validation of Sample Collection Areas 2. Diversion Estimation Methodology 3. Sample Sorting Results 4. Recommended Procedures Validation of Sample Collection Areas The current 57.84% diversion rate was based on a January 2011 sampling. The first step is to select collection routes that provide a representative sample of that day’s overall collection activity. We used census data to establish and examine “quadrants” within each service-day area to access the reasonableness and accuracy of CR&R’s previous selections. The consultant was able to access detailed demographic data that breaks down each area into 15 to 25 smaller areas to reflect their own unique demographic mix. Diversion Estimation Methodology The previous waste diversion methodology did not provide a clear approach on how to approximate the effectiveness of actual sorting operations. This “approximation” is believed to be required should a third-party (such as CalRecycle) attempt to verify diversion rate claims. The consultant also believed that a 1.17% sample size of the total waste collected could be considered inadequate by a third-party auditor. Since then, CR&R, CMSD, and the consultant yielded a new methodology that is more detailed and defensible. The new method consisted of two sample sorts. For the first sort, we utilized a large bucket-loader to mix an entire truckload (sample route for Tuesday collection) and to subsequently “scoop” the portion to be sorted. The total weight collected was 9.36 tons or 18,720 pounds. The sample separated weighed 3,913 pounds and represented 20.9% of the truckload (Attachment 1, pg. 14). This provided a sample size approximately 18 times larger than the previous methodology. Board of Directors November 12, 2013 Page 3 of 4 The second sort occurred on a Thursday using the same process but with a smaller bucket-loader truck. A scoop was taken from the mixed pile and sorted. The smaller scoop weighing 1,249.66 pounds. This represented 6.26% of the 19,960 pounds collected on the sample route. This provided a sample size that was approximately 5 times larger than the previous methodology of approximately 1%. Sample Sorting Results Two detailed sample sorts from material collected from CMSD were conducted. The two days that were selected that most represented the District waste characterization as a whole was the Tuesday and Thursday residential routes. Day one took approximately 2 ½ hours for set-up and instruction, and 4 ½ hours for sorting. The diversion rate for the first sort was 57.21% (Attachment 1, pg. 20). Day two produced a similar diversion rate form a much smaller sample size. However, sort two produced significantly more grass clippings. The diversion rate for the second sort was 56.95% (Attachment 1, pg. 23). Based upon the sample sorts, we believe that a 57% diversion rate is likely for the route areas sampled. Recommended Procedures This study provides a better waste diversion estimation methodology than the previous approach and CMSD should consider requiring its use by CR&R in all future sorts. Regarding route selection for sampling, we believe establishing unit-type percentages (single-family vs. multi-family) is needed to definitively establish the appropriateness of sample route selection. The system we used herein is an acceptable alternate, which suggests that the continued use of historic sample areas is accurate. Regarding sample sizes we recommend a minimum of 1,000 pounds, which was easily exceeded by the small bucket-loader. As discussed, a larger sample size provides better substantiation so use of the large bucket-loader would be preferred to obtain a better representative sampling of material types. The methodology used for this sort is considered an improvement over the historical sorting methodology with regard to substantiating what is diverted and tying those estimates to facility capabilities. The only improvement we suggest is to perform a waste characterization on post-sort disposal at the MRF. The resulting waste composition would be compared to material manifest data to fine-tune the diversion assumptions for mechanical sorting contained in our methodology. Strategic Plan Element & Goal This item complies the with objective and strategy of Strategic Element 2.0, Solid Waste, which states: “Objective: Our objective is to manage the collection and recycling of residential trash in the most economical and environmentally friendly way.” Board of Directors November 12, 2013 Page 4 of 4 “Strategy: We will do this by looking for ways to improve efficiencies, achieve high customer satisfaction, and considering prudent new recycling methods.” Legal Review Not applicable at this time. Environmental Review Subject activity is exempt from the requirements of the California Environmental Quality Act (CEQA) (Public Resources Code Section 21000 et. seq.). Section 15300.4 of CEQA allows an agency while establishing its own procedures “to list those specific activities which fall within each of the exempt classes”, and the District has adopted “CEQA Guidelines and Implementing Procedures” that state on page 6 “”Projects” does not include …. C. Continuing administrative or maintenance activities.” Financial Review Since this waste characterization study provides a better waste diversion estimation methodology than the previous approach, CMSD will most likely avoid costly waste characterization audits and/or reviews should the State challenge waste diversion claims. Public Notice Process Copies of this report are on file and will be included with the complete agenda packet for the November 12, 2013 Board of Directors Study Session meeting at District Headquarters and posted on the District’s website. Attachments 1 – CR&R Diversion Estimation Report (prepared by Michael Balliet Consulting, LLC) CR&R Diversion Estimation Report July - September 2013 September 20, 2013 Prepared for the Costa Mesa Sanitary District by Michael Balliet Consulting, LLC Attachment 1 2 TABLE OF CONTENTS Executive Summary ................................................................................................... 3 Validation of Sample Collection Areas .................................................................... 4 Diversion Estimation Methodology ......................................................................... 14 Sample Sorting Results ............................................................................................ 19 Recommended Procedures ...................................................................................... 47 Attachment 1 3 Executive Summary Michael Balliet Consulting (MBC) was retained by the Costa Mesa Sanitary District (CMSD) to establish a more comprehensive methodology for estimating the diversion of waste from CMSD franchised areas collected and processed by CR&R/Costa Mesa Disposal (CR&R). The purpose of this review was to address potential issues identified in the previous audit of CR&R and develop methodologies that are more defensible to audit by State and County enforcement agencies. Though no such third-party audits are currently utilized by State enforcement agencies the CMSD believes a pro-active approach in this area is advisable. Our previous audit of CR&R’s compliance with franchise agreement terms identified the following areas as potentially problematic with regards to current diversion estimates: • Justification of route areas chosen for sampling hasn’t been supported by any demographic data. • Existing methodology only established recycled material composition and does not address how facility diversion capabilities were incorporated into establishing what is recycled versus what is disposed. • No characterization was performed on non-recycled material thus the composition of disposed wastes is unknown. • Sample sizes (average of approximately 250 pounds) of 1% to 2% of full vehicle loads may be too small to provide an accurate representation of material composition. Within the following sections of this report we address each potentially problematic area. Therein we establish a preferred new methodology and resulting data, or suggest an alternate methodology that the CMSD and CR&R should strongly consider adopting. Based upon the methodology developed we established diversion rates of 57.21% and 56.95% for the two samples that encompassed this study. Michael Balliet Project Consultant Attachment 1 4 1. Validation of Sample Collection Areas Through discussions with CR&R staff we established that the current 57.84% diversion rate figure (City of Costa Mesa portion of CMSD franchise) is based upon a January 2011 sampling. The first step of the existing methodology is selecting collection routes that provide a representative sample of that day’s overall collection activity. Herein we use census data to examine “quadrants” within each service-day area to assess the reasonableness and appropriateness of CR&R’s historic selections. The map below shows the various collection days and corresponding collection areas. The consultant was able to access detailed demographic data that actually breaks each collection area into 15 to 25 smaller areas that reflect their own unique demographic mix. Herein we refer to those smaller areas as “quadrants”: In order to assess the appropriateness of CR&R’s selected “quadrants” we use census data and make the following assumptions: First, that single-family households with the highest median household incomes represent the “most favorable” sample area (containing a high percentage of recyclables). Second, multi-family households with the lowest median household incomes present the “least favorable” sample areas. Therefore the “ideal” or most appropriate area to be selected for sample sorting would be at or near the average of demographic levels that most closely mirror the collection area as a whole. Attachment 1 5 Both historically and currently CR&R is not required to track and report the percentages of single-family detached homes versus the multi-family properties they collect on a given route. Such detailed data could be “mined” from CR&R’s cart tracking data, but would require the purchase of Geocoding software and/or extensive man-hours to apportion carts and unit types to single versus multi-family collections on each route. Requiring CR&R to undertake this additional cost would likely require negotiation. However, as shown herein, this type of detailed route composition data would be helpful in determining the appropriateness of selected sampling areas. For our purposes herein we must establish a reasonable percentage that approximates the multi- family unit composition of residential franchise routes, since all properties with 5 or more units are part of a separate City-controlled franchise. The demographic data used herein makes no differentiation of multi-family unit types in “quadrant” totals. To account for non-franchised units we will estimate half the multi-family units established by census data as being within the City-controlled franchise. We believe this is a reasonable estimation methodology that is not likely to overstate the multi-family units collected by CR&R under the residential franchise. Attachment 1 6 Shown below is our detailed analysis of census data for the quadrants that make up Monday collections: The areas shaded in green (quadrants “A” and “I”) contain the sample route areas selected by CR&R to quantify recyclable material composition for their Monday collections. As shown above these areas contain the two highest per-capita incomes within the 18 quadrants that make up Monday’s collections. Both selected quadrants are also believed to contain a significantly higher concentration of single-family homes (91.50% and 65.90%) than is the average for the area (29.29%). Based upon our analysis quadrant “F” appears to be the most representative area for selection. This “quadrant” is an area bordered by Wilson Street to the North, Placentia Avenue to the West, Victoria Street to the South, and Harbor Boulevard to the East. This quadrant contains both single-family unit percentages and median household incomes that, in tandem, most closely mirror the area as a whole. As discussed, we would need unit type data at route and service day level to determine the actual percentages of single and multi-family units currently sampled for the “Monday” area and as a whole. While our quadrant specific data provides a strong indication, as you will see on the following page, CR&R’s actual collections encompass a service area that is smaller that a Attachment 1 7 quadrant. In some cases the area selected by CR&R contains small portions of two quadrants, so route specific data is needed to improve the accuracy of our assessment. Quadrant “A” is bordered on the East by Continental Avenue and includes areas South of Victoria. Everything East of Continental Avenue is within quadrant “I”. Therefore the sample area selected by CR&R includes collections from both quadrants. While it appears this selection includes too many higher income single-family homes, actual route data might show a more reasonable representation. The CMSD should request more detailed route data so that a final determination can be made. Based upon our analysis of the Monday service area appropriate collection area should include 40%+ multi-family units and reflect a median household income in the $55,000 to $65,000 range. Attachment 1 8 At this juncture it is important to note that quadrant designations used herein are random letters assigned by the consultant, based upon the order that map based census data (found at www.city- data.com/city/Costa-Mesa-California.html ) was extricated and input into the spreadsheet used to perform our analysis. We recommend that the CMSD and CR&R use the same map and establish a shared and uniform quadrant identification system. CR&R’s Tuesday collections show some of the largest variations with regards to the demographic data we use to assess reasonableness. Quadrants on the West-side of Newport Boulevard have some of the lowest median household incomes in the City, while the Eastside has some of the highest. The following page shows the area selected by CR&R for sampling. It is entirely contained within quadrant “F” which presents both median household incomes and occurrence of single- family homes that is above the average for Tuesday collections. Census data suggests quadrant “I” may be a more appropriate area for route sampling. Attachment 1 9 The portion of quadrant “F” selected by CR&R appears to have a high concentration of single- family homes. As discussed, we believe quadrant “I” may be more appropriate. Quadrant “I” is bordered on the West by Newport Boulevard, on the South by East 17th Street, on the East by Orange Avenue, and on the North by East 19th Street. The projected percentage breakdown of single versus multi-family units should run about 75/25 in the sampling area to account for apartment complexes that are under the City-franchise. While it appears quadrant “I” could supply a more representative sample as a whole, at the route level quadrant “F” could prove to be a reasonable selection and is acceptable for route sampling. Attachment 1 10 Thursday collections include the most affluent area in our study of collection days. It is contained by the City’s Western border and properties north of Fairview Park, the City’s golf complex, and Adams Avenue to the South. The 405 Freeway and Conway Avenue (east of Harbor Blvd.) provide the boundary to the North, and Fairview Street provides the eastern border. The demographic data provided by our review, and the area selected by CR&R for sampling is provided below: CR&R’s selection for Thursday route sampling goes well below the area’s norm for both median household income and percentage of single-family homes. When combined with their Monday and Tuesday sample areas, Thursday’s composition helps bring their historic sampling more in line with the City as a whole. If the CMSD and CR&R bring Monday and Tuesday’s sample selection quadrants more in-line with that area as a whole, then Thursday’s quadrant should be shifted to a more representative area like quadrant “C”. Shown on the following page is the portion of quadrant “G” used by CR&R for route samples. This area has a significant amount of multi-family properties. Again, we would like to see detailed unit-type data for this and all franchise collection areas so that we could definitively establish the appropriateness of route selection for waste diversion sampling. Attachment 1 11 The following section provides Wednesday and Friday collection demographic data and establishes both “Citywide” and historic CR&R sampling demographics. Attachment 1 Attachment 1 13 From our analysis of Census data the residential franchise produces a median household income of $65,541.48, which is believed to be accurate for use in targeting quadrants only. The actual median household income collected by CR&R is believed to be higher as larger multi-family units, collected under the City-controlled franchise are included in median income. With respect to single and multi-family distribution, using the methodology described we believe approximately 75% of the residential franchise as a whole is comprised of single-family units. CR&R’s route sampling quadrants and averages are shown in the table below: On the whole CR&R’s historic sampling areas can be concluded to provide a reasonable and appropriate grouping of quadrant data that is representative of the franchise area as a whole. While the single-family composition and median household incomes are slightly higher than the City average, they are not considered unreasonably high. Recommendation: As discussed throughout this section, more detailed and specific route data is needed to provide an unassailable methodology. The study provided herein is considered sufficient to address reasonably expected inquiries into route selection by third parties. While we have concluded that the existing methodology is acceptable we recommend that unit-type collection data, for the franchise as a whole and areas selected for route diversion studies, be assembled and incorporated into a new sample selection methodology report. We also recommend that the quadrant system and Census data used herein be incorporated. Attachment 1 14 2. Diversion Estimation Methodology The previous audit concluded that CR&R’s waste diversion methodology could be considered inadequate as it only established material composition and did not provide a clear approach used to approximate the effectiveness of actual sorting operations. This “approximation of sorting capabilities” is believed to be necessary should a third-party (such as CalRecycle) attempt to verify diversion rate claims. We also believed sample sizes of only 1.17% of total waste collected could be considered inadequate by a third-party reviewer. Over the course of several weeks, meetings with CR&R management and staff yielded a new methodology which the auditor believes provides the foundation for more defensible diversion numbers going forward. The components of this new methodology are discussed by area of concern below: Sample Size Adequacy Two sample sorts were approved and conducted as part of this project. For the first we utilized a large bucket-loader to mix an entire truckload (sample route for Tuesday collection) and to subsequently “scoop” the portion to be sorted. The photos below show the entire load that was dumped and the portion removed for sorting by the large bucket-loader: The total weight collected (Ticket #1865128 – Tuesday, September 10th) was 9.36 tons or 18,720 pounds. The sample size separated by the large bucket- loader weighted 3,913 pounds and represented 20.9% of that truckload. This provided a sample size that was approximately 18 times larger than the historic methodology. The resulting “sort pile” is shown on the right: Attachment 1 15 The second sorting event occurred on Tuesday, September 12th. The same process was used. An entire truckload was dumped in the sorting area (Ticket # 1866045 – 9.98 tons) then mixed by a smaller bucket-loader (shown below - left). A scoop was then taken from the mixed pile and segregated for sorting (shown below – right). The smaller bucket-loader produced a “scoop” weighing 1,249.66 pounds. This represented 6.26% of the 19,960 pounds collected on the sample route. This sample size was approximately 5 times larger than the historic methodology provides. It is our opinion that the larger the sample size the more defensible it is with regards to subsequent challenges of “estimation” accuracy. At 5 to 18 times the size of samples historically used we believe both sorts provide an improved methodology. Sample Sorting Methodology While it is difficult to approximate all diversion capabilities of the CR&R’s MRF system, the materials that are typically hand-sorted and the contamination levels that render materials non-recyclable are not. With this in mind our overall sorting methodology was to remove larger items from the sorting pile to approximate separation the internal “tommel-based” system provides. Sorting efforts began by removing “clean” cardboard, mixed paper, plastics, CA redemption value containers, and other material types that would be separated through manual sorting at the MRF. We started with “clean” materials so the auditor and CR&R staff could inspect segregated materials and remove items that were deem too contaminated. This step insures the Attachment 1 16 validity of our methodology’s “diverted” material claims. It also facilitates our ability to correctly identify material types within the “disposed” waste stream. During the process of segregating “clean materials” we also segregated contaminated or disposed items by material type. Contaminated paper products (cardboard and mixed paper) and contaminated plastics (including non-recycled plastic bags) were two such categories to be recorded under “disposal”. Due to the volume of material our separation of green waste focused on “clean” material that was greater than 6 inches in size. The photos below show our segregated materials from sort #1: The resulting containers for mixed paper and cardboard are shown above. The items contained therein represent what would be hand-sorted by CR&R personnel as a component of MRF separation. These hand-sort materials would also include all California Redemption Value (CRV) containers, HDPE plastics, mixed plastics, wood and larger green waste materials, miscellaneous ferrous and non-ferrous metals, and concrete and other inert wastes. Our segregation of larger contaminated materials also approximates the hand-sorting process as these materials are not removed and travel to the end of the sorting “belt” where they dump into a pile of materials for landfill disposal. Attachment 1 17 After our hand sorting process removed the large items the remaining material closely approximates the portion of franchise waste that is segregated by mechanical process. The photos below show the composition of this material: Of the 3,913 pounds sorted, 2,240 pounds was deemed too be processed by mechanical sorting. This material was subsequently sorted for composition and compared to facility diversion and disposal records to provide a reasonable estimate of what mechanical separation is able to divert. The need for this “facility based” diversion estimation is due to the following: 1. There is no way a hand sort can reasonably approximate a trommel that segregates and removes the majority of 2” minus material. Efforts to hand-sort materials between 2” and 6” are considered ineffective as the only material reasonably diverted in this size category is green waste. The great majority of paper and plastic items in this size “mix” are disposed, though some are recovered through “forced air” separation. 2. The preferred option of sampling post-sort materials for composition was not available to us. When this composition is compared to material manifests for the entire facility, more precise figures for material specific diversion are available. To provide some hand-sort based data for this estimation process we employed a “clean green” separation step. Sorters removed larger green waste material that would be removed by hand Attachment 1 18 separation at the MRF. This resulted in 500 pounds of material we can reasonably assume is removed from other green waste (contained in the 2,240 pounds of material deemed too small for hand sorting). Therefore for our estimation purposes herein we established that roughly 20% of the green waste processed at the MRF is manually removed larger material as shown in the photo (right). Smaller pieces of green waste were found on contaminated paper and plastic to some degree. However the majority of this material was contained in a mix of materials estimated in our 6” minus pile. Therefore our estimation methodology must account for green waste material that is greater than 2” minus which is removed for hand sorting by mechanical process at the MRF. To account for this material we took a representative sample of our post hand-sort material to determine what percentage was green waste between 2” and 6” in size. This sample sorting pile is shown below-right. From that point we segregated the material into green waste, food waste, plastic, paper, glass, metal, concrete, wood, textiles, and “undefined fines” that compose the major material types found therein. Within green waste we further segregated the material by greater or less than 2” minus, with 30% residing in the “fines” category. The resulting composition percentages were established for minus 6” materials: Attachment 1 19 3. Sample Sorting Results As discussed we were provided the opportunity to perform two detailed sorts of material collected for CMSD franchise areas. Listed below is the relative truck and route information corresponding to each sort. Also provided is the “quadrant” that was selected for sorting by CR&R: Date: 9-10-2013 Truck #: 57256 Route: Tuesday, Residential Franchise Ticket #: 1865128 Date: 9-12-2013 Truck #: 57254 Route: Thursday, Residential Franchise Ticket #: 1866045 Shown at right is a picture of truck 57256 at the scale house (top), then (right) as it prepared to dump materials for our waste-sort. The sorting area provided by CR&R and truck 57256 offloading at the sorting area is shown below: Day one sorting took approximately 2 ½ hours for set-up and instruction, and 4 ½ hours for sorting. The following table shows the results of this sort: Attachment 1 20 As shown above our sorting methodology produced an estimated diversion rate of 57.21%, which suggests the previously used methodology has provided a reasonable result. As noted the diversion rate for non-sorted materials uses a “MRF-system ” based estimator. In large part it is based upon “master manifest” data previously obtained during an audit of MRF records. Also included in this estimation is the auditor’s familiarity with similar MRF system operations and recovery capabilities, combined with my observations of proprietary systems at the Stanton MRF during my facility tour. Therefore I am reasonably confident of its accuracy as a diversion “predictor” herein. As noted there are additional steps that could increase the confidence level of diversion estimates. However those were not available for this process. Attachment 1 21 There are several things to note within Sort #1 data. First, the disposed amounts for both paper and plastics contain a significant amount of food waste and liquids. This is especially true for plastics discards and we estimate that half of your Food Waste generation is contained within the “Disposed” plastics total. Since our purpose was to establish a diversion rate, and all materials involved are considered disposed, further separation was not conducted. Based upon our observation of sorted materials we estimate that a minimum of 9% of residential disposal is Food Waste. The actual figure may be higher. The CMSD may wish to perform a more detailed sort of this material to determine the viability of proposed organics diversion programs. For hand-sorted materials the rest of the category totals are self-explanatory. As discussed, materials that were clean and reasonably marketable are listed as “Diversion” while contaminated materials and materials without current markets are listed as “Disposed”. The only exception to this is the material category for “Liquids”. The 10-pound figure listed as “Diverted” accounts for liquids found within bottles during our hand-sort. We quantify the volume of this material and credited it as diversion herein to account for “shrinkage” as noted in the CR&R master manifest. In our model we credit CR&R for approximately 0.26% diversion for liquids recovered by their MRF system. Within the mechanical separation numbers is where we utilize the master manifests, industry knowledge, and facility specific equipment to make reasonable assumptions. Let’s examine those assumptions and the resulting diversion and disposal figures for the items noted in our Sort #1 table. The table below shows the calculations performed to arrive at these figures: First, for paper and plastics the MRF employs air separators to blow lighter materials like paper and plastic from a descending stream of mixed refuse. As a result the materials included in our minus 6” material sort contained a percentage of paper and plastic that the MRF facility actually diverts. Therefore we estimate that 10% of the paper and plastic in our small material mix is diverted through mechanical separation, while 90% is disposed. For green waste we credit CR&R’s system with the capability to divert 100% of the material that is greater than 2” minus. We also credit their MRF system with diverting 70% of the smaller material. While I cannot disclose their proprietary systems and the specifics I utilized to establish Attachment 1 22 these percentages, the resulting green waste diversion (a 36.21% component of the entire Sort #1 load) matches closely with the 37.88% figure supported by their master manifest data. For mechanical diversion of glass I am giving CR&R’s MRF system credit for diverting 10% to account for intact containers missed by the hand sort and the capacity of this system to recover a percentage of glass “breakage”. Including our hand and mechanical diversion Sort #1 data matches up exactly to the master manifest percentage for glass diversion (1.81%). With respect to metals diversion the use of magnets in the mechanical separation process is an industry standard. I am estimating an 80% recovery rate by the MRF’s mechanical system for the smaller material. In combination with the 86% diversion rate credited for hand sorting I believe this provides a very reasonable diversion figure for metals. Finally a percentage of “Fines” is credited with diversion via the current “Trail Mix” program at Chiquita Canyon landfill. At 5% of the total fines identified the resulting diversion closely mirrors levels substantiated by CR&R’s master manifests. Attachment 1 23 Sort #2 produced a similar diversion rate from a much smaller sample size. As discussed previously we used a standard bucket-loader for this sort and the resulting “sort pile” was about 1/3rd the amount produced by the large-loader. The hand-sort portion of Sort #2 achieved a higher diversion rate than Sort #1 (81% to 72%). While this could be attributable to the small sample size we believe it is due to a better sample route. Supporting this assumption is the higher percentage of diverted cardboard/paper (19.0% to 10.2%) and CA redemption containers (6.7% to 2.3%) accounted for in our total sort composition. Sort #2 was definitely higher in high-value recyclable material content. The route selected for Sort #2 also produced significantly more grass clippings. However, this did not equate to a higher percentage of smaller “mechanical sort” waste (50% in sort #2 versus 57% in sort #1). The table below shows our estimation process for smaller material diversion: Attachment 1 24 We believe that the “Fines” total above includes a larger amount of green waste than Sort #1, as evidenced by the lower (33% versus 36%) percentage green waste diversion accounts for in our Sort #2 composition (more is included in disposed fines). However, the methodology used above was established by a viable methodology and reconciled to master manifest data. Therefore it is considered reasonably accurate and not appropriate to adjust from load to load. In addition we believe green waste “fines” (2” to 6”) are represented accurately herein. Green waste in the 2” minus category is where the higher percentages occur, due to a large amount of grass clippings in this load. The consultant believes difficulties in diverting this material from mixed waste is fairly approximated in the data above. Summary: Based upon our sample sorting we believe a 57% diversion rate is likely for the route areas sampled. Attachment 1 25 4. Recommended Procedures We believe this study provides a better waste diversion estimation methodology than the previous approach and the CMSD should consider requiring its use by CR&R in all future sorts. Regarding route selection for sampling we believe establishing unit-type percentages (single- family vs. multi-family) is needed to definitively establish the appropriateness of sample route selection. The system we used herein is an acceptable alternate, which suggests the continued use of historic sample areas is accurate. Regarding sample sizes we recommend a minimum of 1,000 pounds, which was easily exceeded by the small bucket-loader. As discussed a larger sample size provides better substantiation so use of the large bucket-loader would be preferred to obtain a more representative sampling of material types. The methodology used for this sort is considered an improvement over the historical sorting methodology with regards to substantiating what is diverted and tying those estimates to facility capabilities. The only improvement we suggest is to perform a waste characterization on post- sort disposal at the MRF. The resulting waste composition would be compared to material manifest data to fine-tune the diversion assumptions for mechanical sorting contained in our methodology. Attachment 1