Additional Comments Summary Response to Additional Comments

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RESPONSE SUMMARY REVISED DRAFT ORDER OF APPROVAL NO. 10052 Comment Period – September 13 – October 28, 2010 Commenter Comment Synopsis we don’t even know the health impacts. There are many other Mirrormont residents that feel strongly about this but most likely don’t know how or where to communicate their frustrations. Sherry Partridge (Written 10/28/2010) Jerry Bartlett (Written 10/28/2010) This area smells bad alot of the time, and because of that it will make it very hard to sell our house. People don't want to live in an area that smells like this. It can make you sick to your stomach. Our guests have compalined as well. Cedar Grove Composting, Inc. ("Cedar Grove") submits the following comments on the revised draft order of approval ("Draft Order") for Cedar Grove's notice of construction ("NOC") application no. 10052 for consideration by Puget Sound Clean Air Agency ("PSCAA"). This is the second comment period PSCAA has held on this NOC application. Cedar Grove's comments submitted during that first comment period remain relevant to the revised draft order and so are incorporated by reference in these comments. General Comments Cedar Grove committed, in a 2008 settlement agreement with PSCAA (the "2008 AOC"), to submit an NOC that would consolidate the conditions of various Approval Orders that have been issued over the years for the Maple Valley facility and incorporate conditions agreed to as part of the 2008 AOC settlement. Cedar Grove initially proposed to incorporate some operational changes into the NOC, but withdrew that request when it became clear that it was complicating what should have been a fairly simple administrative exercise. As the NOC was intended to consolidate existing requirements, and not to evaluate any proposed changes to the facility, no public notice should have been required. Nevertheless, PSCAA opted to provide an opportunity for public comment, and held a public hearing in June. The resulting public comments generally did not relate to the proposed order. Instead, PSCAA received complaints about nuisance odors, and a number of comments expressing frustration that the proposed order did not contain new requirements. In retrospect, the reaction to the proposed order should not be surprising, since it was never intended to impose new requirements, but rather to consolidate existing requirements. All of the physical changes occurred under the 2008 AOC two years earlier i.e. installation of grinding building and expansion of the receiving building. PSCAA understandably wants to respond to the comments it received, even though this Draft Order is not the appropriate vehicle for doing so. As explained below, the proposed conditions are not justified,
RESPONSE SUMMARY REVISED DRAFT ORDER OF APPROVAL NO. 10052 Comment Period – September 13 – October 28, 2010 Commenter Comment Synopsis and are unlikely to respond to the concerns PSCAA heard from the community. Cedar Grove remains willing to work with PSCAA, but urges the Agency to not proceed with unilateral changes to the permits for the Maple Valley facility. In 2008, Cedar Grove committed to PSCAA that it would make several changes to the Maple Valley facility to improve the capture of odors in several parts of the operation. Cedar Grove then proceeded to expand the size of the tipping building, and construct an adjacent building to house sorting and grinding operations. These buildings are equipped with ventilation systems that pull the air from these buildings into a collection system and routes the air through a biofilter, which breaks down potentially odorous gases before the air is emitted to the atmosphere. Cedar Grove also committed to perform regular smoke tests on the performance of the ventilation system. Cedar Grove also agreed, as part of the 2008 settlement, to contract for third party evaluations of the emission capture system serving the tipping building, the grinding building, and Zone 7, as well as biofilter operation, to be performed every six months. Those evaluations have been conducted every six months since then, and when issues have been identified in the evaluation reports Cedar Grove has made the necessary corrections. The proposed permit would increase the frequency of those third-party evaluations to quarterly. Nothing in the past reports suggests this increase in frequency is necessary. Cedar Grove has continued to look for ways to improve odor controls at the Maple Valley facility. Earlier this year, Cedar Grove conducted a pilot project placing tarps over finished compost piles at another facility. The tarps were originally designed for use on landfills, as an alternative to using dirt as interim cover on the working face of the landfill at the end of each day. In their landfill application, the tarps control odors and vector access to the waste in the working face. Air sampling conducted by CH2M Hill showed that, when the tarps were placed on finished compost piles, they reduced odors from the pile by approximately 50 percent. Cedar Grove has ordered more of the tarps, and plans to place them on the finished compost piles at Maple Valley. Based on our experience, this should help reduce the potential for odors from the finished compost. Cedar Grove identified the potential use of tarps on its own, without input from PSCAA, and is undertaking the step of covering the finished compost piles voluntarily, independently of any order or direction from PSCAA. After seeing the potential benefits from use of the tarps in Everett, Cedar Grove also considered other uses for them. The primary ASP zones at Maple Valley (zones 1-6) currently are not covered, since air is drawn through the piles to capture odorous gases and break them down in a biofilter. The fact these zones are uncovered has led to some concerns from the Health Department about vector control, since some residential yard waste collection now contains some residential food waste (in Cedar Grove's experience, the food waste is 5 percent or less of the volume of residential collections). Use of the tarps on these primary zones would resolve the Health
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