Additional Comments Summary Response to Additional Comments

RESPONSE SUMMARY
REVISED DRAFT ORDER OF APPROVAL NO. 10052
Comment Period – September 13 – October 28, 2010
be paying for this work for Cedar Grove and the Agency believes that its involvement
throughout the testing program should ensure that quality and representative data is collected
and documented. Other technical work completed by others on behalf of Cedar Grove to
satisfy a compliance requirement is also consistent with past practices by other sources.
Again, involvement and oversight by the Agency is an important component to ensure that
work is done adequately.
5. Observation that Maple Valley is bearing the brunt of impacts from
choices made by other jurisdictions for solid waste management
The Agency acknowledges this concern. This is an issue beyond the scope of this permit
action. The siting and past approvals for composting at this location are a part of the
historical record. The proposed order of approval is one component of a combination of
several regulatory elements which apply to Cedar Grove. It has been the intention of this
Agency to improve emission performance of Cedar Grove’s operations to relieve the
community of the odor impacts.
6. Desire that the emission testing order for Cedar Grove to complete
have the testing done earlier than the anticipated schedule
The Agency is issuing a regulatory order for emission testing in conjunction with the final
action on this application. The comments saying the testing should be done earlier rather
than in the spring and summer seasons originally identified by the Agency is not feasible.
Testing earlier will also not obtain representative emission data for an operational period of
potentially maximum emissions. From the logistical standpoint, the planning and
organizational work necessary by Cedar Grove and its testing contractors will take several
months to mobilize resources to ensure the appropriate sampling and analytical work is ready
to go. From a representative emission perspective, the desirable emission testing period is
the summer (e.g. June to August timeframe). This is when the maximum throughput is
occurring at the site. It allows maximum production activity levels at each of the emission
units/activities identified for the site. Peak grass season typically starts in April/May and will
be moving through the various process steps onsite until August/September. Additionally,
the previous comments indicated that odor emissions from the site were impacting
individual’s health and this intention to order emission testing is partially driven by that
interest. Since the testing period anticipated also coincides with the typically peak offsite
impact periods, the Agency believes the representativeness and validity of this testing
direction is sound.