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We also believe that the ADC regulations do not prohibit minimal amounts of food waste <br />contamination in ADC. Therefore, we contend that our permit controls the levels of <br />contamination in our ADC and our permit specifically allows up to 5% contaminants <br />(SWFP Condition 17.t) in green material used for ADC. A more detailed discussion of <br />this issue follows and includes a proposal to "minimize" contaminants in the green <br />materials used for ADC. <br />Prior to the adoption of the ADC regulations, Title 27, Section 20690 (a) (3) (A) included <br />the phrase: "Processed green material shall be green material as defined in Title 14, <br />California Code of Regulations, §17852(u) with the exclusion of manure..." However, <br />the final version of the ADC regulations deleted "...shall be green material as defined in <br />Title 14, California Code of Regulations, §1785�a2(u) with the exclusion of manure". <br />Thus eliminating a possible cross - reference to the composting regulations. <br />The composting `regulations contained in Title 14, Chapter 3.1 include a definition of <br />green material in section 17852. (a)(21) That in part requires less than 1% contamination <br />and specifically excludes mixed solid waste from the definition. However, Section 17852 <br />is preceded by restrictive language stating " (a) For the purposes of this Chapter:" <br />meaning that the definitions contained in Section 17852 are applicable only to the <br />composting regulations and cannot be applied to ADC regulation since those regulations <br />are contained in a different Chapter and in a different Title of the OCR's. <br />Now, the ADC Regulations contained in Title 27,include a definition of "processed green <br />material" (Section 20690 (a) (3) (A)). That definition does not include either the 1% <br />restriction on contamination nor does it include the very restrictive prohibition on mixed <br />solid waste. That definition states that: "... processed green material means any plant <br />material that is either separated at the point of generation, or separated at a centralized <br />facility that employs methods to minimize contamination." The definition even states <br />that green material includes but is not just limited to "...yard waste, wood waste, paper <br />products and natural fiber products." Thus, leaving the door open for other materials. <br />Some materials are specifically excluded from the definition of "green material", such as <br />" ... treated wood waste, mixed demolition or mixed construction debris, manure and <br />plant waste from the food processing industry". The City of Stockton's curbside program <br />does not include any of those excluded materials! <br />Therefore, it would seem that the ADC regulations contain no specific limitation on some <br />food materials in green waste destined for ADC, as long as the resulting processed <br />material meets the grain size specifications and performance standards specified in the <br />regulations. In fact, the curbside greenwaste collected in the City of Stockton is <br />separated at the point of generation and in addition, it is sorted at the .site to remove <br />contaminants and is processed through a grinder prior to applying to the working face. <br />Finally, our SWFP Condition 17.t specifically authorizes the use of shredded green <br />material for ADC as long as a dozer is used for spreading and compacting and the green <br />material contains no more than 5% contamination. The City of Stockton curbside <br />greenwaste program meets both of those requirements. <br />