RESPONSE SUMMARY - Puget Sound Clean Air Agency

More documents

Recommendations

Info

RESPONSE SUMMARY ORIGINAL DRAFT ORDER OF APPROVAL NO. 10052 Comment Period – April 29 - June 15, 2010 order to supplement the incomplete emission data available for this site (both for odorous emissions and toxic air contaminants), the Agency intends to issue a Regulatory Order requiring Cedar Grove to collect and submit the emission information for specified operations and emission parameters. This order would likely be issued before the end of this calendar year, with the intention to have the specified emission data collected during the spring peak grass season in 2011. This emission information may be useful to determine potential compliance with Regulation I, Section 9.11 and would also support a health impact analysis as defined in Regulation III, Section 2.05 (Sources of Toxic Air Contaminants). The health impact analysis defined in Regulation III is based on an evaluation of predicted emission impacts offsite in comparison to the Acceptable Source Impact Levels (ASILs) identified in WAC 173-460. 6. Complaint record does not accurately reflect the level of impacts The Agency agrees with this general comment, but recognizes that the complaint history is just one form of data and most of it is anecdotal. The comments with respect to this topic indicated that the level of impacts on the community are understated because some residents either don’t know who to call, choose not to call even though they experience the odor impact, or have given up filing complaints because they do not see that it is making a difference. Cedar Grove believes that the complaints are not indicative of what is really happening in the community and that there are other sources of odors in the vicinity. The Agency is unable to verify and complete a full investigation of every complaint received. However, when we are able to respond, our investigation process does allow the impact to be documented and the source of odors to be identified. 7. Odors have gotten worse in the last 2 years, especially during night, early morning, & weekends The Agency agrees with these comments and believes that there are multiple contributing factors. Over the past five years, the amount of waste material separated for composting in the region continues to increase and Cedar Grove receives most of that material. The amount of food waste in the compostable waste stream has also increased. The market for selling finished compost fluctuates, but the recent economic conditions have slowed construction and the sale of compost, leading to more finished product being stored onsite. Another factor which can affect odorous emissions is the ability of the site staff to manage this increased quantity and diversity of materials in an efficient and effective manner. All of this can contribute to potential increases in odorous emissions. Cedar Grove’s comments support this conclusion. Cedar Grove believes their competitors get the benefit of “lower population densities, much lower tonnage being processed, smaller foot print, lack of finished compost storage on site, and wind directions that blow to agricultural areas instead of housing areas”. Another aspect of these comments was a concern that Cedar Grove was doing something in the evening or at night which may contribute to the odors the neighborhoods experienced at night or in the early morning. The Agency does not have reason to Page 24 of 27
RESPONSE SUMMARY ORIGINAL DRAFT ORDER OF APPROVAL NO. 10052 Comment Period – April 29 - June 15, 2010 believe that Cedar Grove processes material at night. Normal staffing is for regular working days to address the receipt of wastes and processing in coordination with those receipts. Some weekend day or early evening work may be completed to address immediate demands, but the site does not handle or process materials around the clock. The Agency believes that the night and early morning related observations may be attributable to periods of calm meteorological conditions in which emissions from the facility may not be rising or dispersing in a typical dispersion modeling assumption. This assumption is consistent with the recognition that complaints have been received in all directions around the facility and are not consistently affected by prevailing wind directions. 8. Limit the operational level of Cedar Grove until they can perform Many of the comments suggested that Cedar Grove should be limited operationally until it can perform acceptably with respect to impacts on the community. These comments ranged from a desire for complete shutdown to an interest in Cedar Grove being fully successful with the composting policy direction while being a better neighbor. Cedar Grove has expressed the view that they “utilize state of the art composting technology that has been determined to be Best Available Control Technology by PSCAA”, and has challenges that other commercial composting facilities do not have to overcome. This view may suggest that there is nothing more Cedar Grove can do to minimize their impacts in the community and that a certain amount of Level 2 odors in the community are unavoidable. The Agency does not agree with Cedar Grove’s view and has not reached a conclusion that there is nothing more Cedar Grove could do to minimize its impacts. The fact that the known emission profile for composting operations nationally is continuing to develop at this time illustrates how past permit decisions are not a shield when the information those decisions were based on is changing. As an example, a recent study in California indicated that the VOC emissions from a grass recycling compost operation could double with the addition of food to the waste stream. Also, operational practices onsite can have a significant effect on the odor emission performance for the site and compliance with the permit conditions alone is not sufficient to control all odors. Additional provisions could be added to the Cedar Grove permit conditions, but the performance the public seeks is not just onsite. They want to see results in their community. The Agency has considered a range of limitations to be included in the permit and is proposing to add a permit condition which prohibits Level 2 odors (or greater) beyond the facility property boundaries. This condition is consistent with the Agency view that a source which can routinely produce Level 2 (or greater) odor impacts offsite is not meeting Reasonably Available Control Technology (RACT) as defined in Regulation I, Section 9.11. The Agency considered other alternative conditions. However, neither a limitation on short-term capacity waste rates nor a requirement to limit the quantity of finished product onsite would assure acceptable impacts. One commenter specifically stated that the Page 25 of 27
Page 1 and 2: RESPONSE SUMMARY ORIGINAL DRAFT ORD
Page 13 and 14: Ken Naito (Written, June 9) RESPONS
Page 19 and 20: Sharon Schimke (Written June 9) RES
Page 23: RESPONSE SUMMARY ORIGINAL DRAFT ORD
Page 27: RESPONSE SUMMARY ORIGINAL DRAFT ORD

RESPONSE SUMMARY - Puget Sound Clean Air Agency

Create successful ePaper yourself

Delete template?

Save as template?