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Musco Olive Tracy, California JOB 95011 <br />Section 9-115.345 Agricultural Wastes states <br />"The Agricultural Wastes use type refers to the storage, <br />stockpiling, sacking and sale of waste products and by-products <br />from plant crops and animals, and organic material, including <br />composting operations, but excludes tallow rendering and similar <br />uses requiring additional processing. Typical uses include <br />establishments selling chicken manure, cattle manure, compost <br />from urban yard refuse, or removed grapevines." <br />The Musco Olive operation isnot an Agricultural Waste operation as <br />described above because <br />(1) Mulch is product, not waste. I"would expect that there could <br />be 100 retail outlets in San Joaquin County that sell Mulch in <br />various forms and quantities, from bags to truckloads. These <br />operations rarely have permits to operate as waste sites because <br />Mulch is a product. <br />(2) Mulch is an organic material used entirely on the site. <br />Musco Olive does not sell Mulch or Compost. <br />In the letter of 25 April 1996, you describe an independent operator <br />who produces green waste. That is not logically feasible. The result <br />of the independent operation isthatproduct is produced, not waste. <br />In the particular case of this site, that operation does not occur at <br />the Musco facility. The independent operator who takes in green waste <br />and produces the mulch product is not Musco Olive. That independent <br />operator has a waste facility permit. You accurately describe the way <br />that the independent operator produces his mulch from waste, starting <br />with various leaves, clippings, cuttings, etc. You did not indicate, <br />however, that when this operation is complete and the waste has been <br />fully processed to mulch, it is then trucked to the Musco site. The <br />Agricultural Waste operation to which you refer is the independent <br />operator from which Musco obtains its mulch product. To the best of <br />my knowledge, that independent operator is in full permit status as <br />you describe. <br />imm <br />