Additional Comments Summary Response to Additional Comments
Additional Comments Summary Response to Additional Comments
Additional Comments Summary Response to Additional Comments
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RESPONSE SUMMARY<br />
REVISED DRAFT ORDER OF APPROVAL NO. 10052<br />
Comment Period – September 13 – Oc<strong>to</strong>ber 28, 2010<br />
Commenter<br />
Evan Lur<strong>to</strong>n<br />
(Written 10/26/2010)<br />
Samuel Taylor<br />
(Received US Post<br />
10/26/2010)<br />
Comment Synopsis<br />
I have a strong feeling that the adage, “where there’s smoke, there’s<br />
fire” also applies <strong>to</strong> the situation at the Cedar Grove Compost facility.<br />
In this instance, I strongly believe that where there is CGC odor, there<br />
are also inordinately large concentrations of mold and fungi allergens.<br />
These organisms, which thrive in decaying vegetation, can give people<br />
headaches, malaise, and flu-like symp<strong>to</strong>ms. Of course, this process<br />
occurs naturally all around; however, CGC’s operation without doubt<br />
greatly concentrates the occurrence of these molds and fungi, and since<br />
the operation is mostly uncovered, probably sends large quantities aloft<br />
with the air currents. The odor, as bad as it can be sometimes, is likely<br />
the “red flag”, <strong>to</strong> those allergic <strong>to</strong> molds that they are in for another<br />
allergic reaction. It is no surprise <strong>to</strong> me that after a lifetime of being<br />
allergy-free, and having lived here 12 years prior <strong>to</strong> CGC’s arrival, I<br />
developed allergies <strong>to</strong> mold in the late 90’s. Coincidentally, right about<br />
when CGC’s operations (and odor) really started ramping up. My<br />
allergies have been particularly bad this year, and so has the odor.<br />
His<strong>to</strong>ry has shown that a variety of seemingly innocuous substances<br />
have ultimately proven <strong>to</strong> be quite detrimental <strong>to</strong> public health (e.g.<br />
asbes<strong>to</strong>s, lead). I think it would be very prudent for the Puget Sound<br />
Clean Air Agency and the King County Department of Health <strong>to</strong><br />
consider the possibility that operations such as CGC’s may need <strong>to</strong> be<br />
scrutinized much more thoroughly <strong>to</strong> ensure public health. Potentially,<br />
much of their outdoor and exposed operation needs <strong>to</strong> be contained in<br />
negative pressure facilities.<br />
After the public meeting held last Thursday evening Oc<strong>to</strong>ber 20th and<br />
looking at the information posted on your web site, I have the following<br />
comments about your order of approval for Cedar Grove Composting.<br />
Has there ever been an allowance in a previous order of approval by<br />
your agency that give Cedar Grove permission <strong>to</strong> process food waste in<br />
any of the primary compost pads? What reasoning is behind this<br />
changed language especially because of the increase in foul odor/stink<br />
<strong>to</strong> our neighborhoods from Cedar Grove Composting? How would a<br />
reportable deviation under this order result in a fine being issued by<br />
your agency? Where in the order, agency rule or state law does it say a<br />
reportable deviation will result in a fine?<br />
In number 8, will any biofiltration clause that is <strong>to</strong> be watched and<br />
recorded establish circumstances which can’t be violated? If so, what<br />
would be the fine be <strong>to</strong> Cedar Grove in the order? If no, why?<br />
In number 15, what would be fine <strong>to</strong> Cedar Grove in the order if they<br />
did not meet your agencies requirement <strong>to</strong> change an earlier OK'd test<br />
procedure? In the approval, Cedar Grove has test procedures which<br />
must be OK'd by your agency. Some test procedures give your agency