Mulch Facility Temperature Monitoring Logs Required as Part of Solid Waste Annual Report

REMINDER: Temperature monitoring logs for mulch material windrows/piles are now required to be submitted for mulch processing and storage solid waste management facility (SWMF) annual reports in accord with 6 NYCRR (New York Codes, Rules, and Regulations) Part 360 and Part 361-4.

For any mulch processing and storage facility (exempt, registered, or permitted), Section 3 of the mulch facility annual report form requires the submission of mulch windrow/pile temperature monitoring data. Annual reporting for the 2024 year for such facilities is due to the New York State Department of Environmental Conservation (NYSDEC) by March 1, 2025.

What are the monitoring requirements?

• For all piles of double or finely ground mulch, the temperature in the windrows/piles must be monitored at least twice per week.
• For all other windrows/piles, the temperature in the piles must be monitored twice per month, as per Part 361-4.3(b)(6).
• Multiple points in the piles should be monitored, particularly in areas that appear to be the hottest, such as vents and areas of fungal growth.
• Temperature probes should be inserted into the mulch material windrows/piles carefully to avoid introducing air into a hot spot, resulting in a flash fire.
• If the temperature read is above 140°F or a portion of the pile shows an increasing trend in temperature, the affected material must be immediately broken down and cooled.

What else do I need to consider?

With regard to mulch material storage, keep in mind that unprocessed material cannot remain at the facility for more than 12 months and that mulch product cannot be stored at the facility for more than 180 days, as per Part 361-4.3(b)(3) and (5), respectively. These requirements are as per the most recent regulatory updates and differ from the previous Part 361-4 regulations published in 2017. Under the 2017 regulations, while primary grind mulch could not be stored for more than 180 days, double or finely ground mulch could not be stored for more than only 90 days.

Also be sure to remember that all temperature monitoring records should be attached to the annual report submission.

Need help?

If you need assistance in maintaining and submitting annual reporting documentation before the March 1 deadline, please contact Walden at 516-604-5684. Our experienced solid waste engineers will ensure that your SWMF is in compliance with all applicable regulatory requirements.