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Jed Phelps Valley Organics, Inc. 920 W. Frewert Rd. Lathrop, CA 95330 San Joaquin Environmental ,rt<a ealth Department :r .li East Main Street Stockton, California 95202-3029 I'4k- I'464-0138 February 20, 2012 RE: Report of Composting Site Information and Odor Impact Minimization Plan (V2) Dear Jed Phelps, ®(RECTOR Donna Heran, RENS PROGRAM COORDINATORS Robert McClellon, REHS Jeff Carruesco, RENS, RDI Kasey Foley, REHS Linda Turkatte, REHS The Environmental Health Department (EHD) has reviewed your Report of Composting Site Information (RCSI) and has the following comments: 1. The Introduction states that "All materials are combined and go through thermophillic decomposition to create used as oil conditioners and amendments." Is this correct? 2. The Incoming Material -Feedstock Processing Area states that "The temperatures of the feedstock and ground material will be taken to be sure it in compliance with the California Fire Code." Revise to include daily temperature readings. 3. The Receiving section states that "If the load had over the acceptable level of non-compostable materials, it is rejected." Title 14, California Code of Regulation (T14CCR), Section 17852 (a) (26) states that "A feedstock that is not separated or contains 1.0% or more physical contaminants by weight is mixed solid waste. Add the text from T14CCR, Section 17852 (a) (26) referenced above. 4. The Composting section states that "Once the average temperature reaches 131 degrees F..." Revise to state that "Once the minimum temperature reaches 131 degrees F...: ' 5. The Composting section states that "Once requirements are met, weekly temp monitoring is adequate." Revise to include daily temperature monitoring. 6. The Composting section states that "...Valley Organics will abide by the current California Fire Code and all related standards..." Add references to Title 14, Title 27 CCR, and the dimensional pile limits are 250 ft long x 150 ft wide x 25 ft high. 7. The Vector Control section states that "...an application of bait type control will be implemented, or a commercial vector control program employed..." Add the type(s) of possible bait type control and provide a list of vector control companies. 8. The Anticipated annual operation capacity for the facility in cubic -yards section states that "The annual operating capacity for the facility includes incoming material at 182,500 tons per year. This is approximately 365,000 cubic yards" Throughout the RCSI it is stated that peak daily volume will be 500 tons per day. However if the facility is open 6 days a week the total incoming volume would be 156,500 tons per year or approximately 313,000 cubic yards. Revise these figures throughout the RCSI. 9. The document describes provisions to handle unusual peak loading. The section states that when higher than usual volumes occur, additional equipment will be brought on site. The equipment on site should be able to -handle peak daily volumes (500 tons/day). Any volumes over 500 tons will be a violation of the Compostable Materials Handling Facility Permit.