RESPONSE SUMMARY - Puget Sound Clean Air Agency

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RESPONSE SUMMARY ORIGINAL DRAFT ORDER OF APPROVAL NO. 10052 Comment Period – April 29 - June 15, 2010 Commenter Comment Synopsis #16. is INCORRECT and needs to be changed. It states that secondary zones can accept compost for second phase treatment from primary Zones 1-7. Zone 7 has post-consumer foodwaste commingled with yard waste and should ONLY go into Gore for treatment. This statement needs to say, "...only from Zones 1-6. NOTE: On page 5 of NOC Worksheet, I.1.b. states that no postconsumer foodwaste would be in the primary or secondary zones, which is accurate and contradicts what is stated in the Order of Approval on page 4. Clean Air Agency This Agency appreciates the clarification by the Department of Health Response regarding their interpretation of Ecology’s rule regarding odors from composting operations. The worksheet identified it as a solid waste rule and not enforceable under the statutory authorities provided to this Agency. The Agency disagrees with the additional comments regarding post-consumer foowaste and the Zone 7 operations. The Agency believes that its records indicate post-consumer food waste has been approved in Zone 7 and that it would include use of the secondary zones to complete that composting for Zone 7 materials. The comment regarding the comments on pages 4 and 5 is referring to a historical summary of permit actions taken by this Agency over the life of this facility. The permit history reflects changes in the site development and operation and cannot be taken out of context. No changes made based on these comments. Seattle-King County Dept of Health – Bill Lasby, Supervisor Solid Waste & Vector Nuisance Program (Written, June 15) Page 6: 4.c.(1)ii, seems to imply that loss of electricity is only associated with a storm event. Consider inserting umbrella wording to cover other scenarios (e.g. "and for periods when electricity is lost after a storm event or other circumstance causing a power outage"). Clean Air Agency Response This comment refers to condition language derived from a previous SEPA review and determination which reflects mitigation terms which were previously approved. This proposed Order of Approval was published on the conclusion that the previous SEPA determinations were adequate for this proposed action and that a new SEPA determination was not being made at this time. Thus, editing previously approved SEPA mitigation language would necessitate a new SEPA review, which is not proposed at this time. No changes made based on these comments. Page 2 of 27
RESPONSE SUMMARY ORIGINAL DRAFT ORDER OF APPROVAL NO. 10052 Comment Period – April 29 - June 15, 2010 Seattle-King County Dept of Health – Bill Lasby, Supervisor Solid Waste & Vector Nuisance Program (Written, June 15) Page 8: The item 7 text contains two occurrences of upper case letters “IS”. Do these represent a typographic errors? In the last sentence of #7., the word "this" is missing after the last comma. In the first sentence of #9., the word "by" is missing after the word, "required". Clean Air Agency These observations were typographical errors and have been fixed. Response Additionally, the original proposed Condition No. 9 had a reference to the “Settlement Agreement”, which has been changed to the “Order”. Changes made based on these comments. See Summary Response at the End of this Document for the rest these Comments (starts on p. 22) Cedar Grove Composting, Inc Comments on Public Notice for Draft Order of Approval No. 10052 (Written, June 14) Cedar Grove’s Commitment to Maple Valley: · Cedar Grove has spent at least $1 million in upgrades each year during the past 10 years at the Maple Valley facility. In one year, the company spent $5 million on upgrades. · Cedar Grove employs a full time odor specialist working in downwind locations from our facility, tracking and observing not only the Cedar Grove facility’s odor but odors from other sources. · Over the last two years, Cedar Grove developed and expanded upon an odor investigation protocol that allows us to thoroughly research information surrounding an odor complaint. Using three computer-controlled weather stations, we are able to match meteorological data with the time of complaint and location of the complaint to help us identify odor sources. With this real time information we have concluded that up to 75% of the complaints can not be substantiated due to meteorological conditions making the complaint impossible. While it is possible that people are smelling something, it cannot be attributed to our composting activity. Secondly, when odors are encountered, they are for a brief period of time and clearly are not inundating the neighborhood for hours on end and day after day as some resident have claimed. Most complaints come from less than 30 residents and many will not even consider the fact that the wind is blowing in the wrong direction for Cedar Grove to be the source. They have already made up their mind that what they are smelling comes from Cedar Grove and they do not want to acknowledge the possibility that they may be wrong. Page 3 of 27
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RESPONSE SUMMARY - Puget Sound Clean Air Agency

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