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i' <br /> The first monthly inspection conducted on August 13, 2001, noted that the temperatures in the <br /> stockpile ranged between 120-160 degrees Fahrenheit, and were noted as a violation. The <br /> following monthly inspection conducted on September 24, 2001, revealed temperatures between <br /> 140-154 Fahrenheit, and was again noted as a violation. During the September 24th inspection, <br /> the EHD staff noticed a large population of adult flies and strong odors around the feedstock <br /> stockpile. In both cases the temperatures found in the stockpile exceeded the threshold <br /> temperature (122 degrees) for composting. This type of composting does not conform to any of <br /> the known accepted forms of composting and is in conflict with the facilities RCSI. <br /> During the October 4th meeting, it was revealed that the green waste at one time was found at/or <br /> above 180 degrees. It was also revealed that the incoming temperatures were at 128 degrees that <br /> same day. The feedstock stockpile poses several issues, including a potential fire hazard. <br /> Although the facility has a 24-hour fire watch, it appeared that the 180-degree temperature was <br /> over looked until EHD staff arrived onsite. The second issue is that the temperatures allow a <br /> warm place for the flies to breed(the large void spaces in the green waste prior to processing is <br /> an ideal breeding place for flies). The third issue is the temperature and moisture from the yard <br /> waste creates odors and attracts flies. <br /> During the meeting,the Scotts Company representatives asked if the stockpiles could be placed <br /> in windrows and turned as necessary to control the temperatures. This option was considered <br /> and would be allowed by EHD if the Scotts Company would provide in writing the process they <br /> intended to use and any contingencies that would be in place to control temperatures. The EHD <br /> indicated that the Scotts Company would need to be a good steward in maintaining the feedstock. <br /> The EHD also explained that if any issues should arise from this process (fire, odor complaints, <br /> or vector concerns)the next action by the EHD would be further enforcement action. <br /> The EHD has received a proposed amendment to the RSCI that indicates that the green waste <br /> will be processed on a seven-day average. In order to facilitate this change the facility will have <br /> to make application to amend the current Solid Waste Facilities Permit(SWFP) in accordance <br /> with Public Resources Code (PRC) Section 44004 (b). The SWFP application and plan review <br /> fees of$445.00 must be received by November 22,2001. <br /> 44004. (a) No operator of a solid waste facility shall make any significant change in the design <br /> or operation of the solid waste facility not authorized by the existing permit, unless the change is <br /> approved by the enforcement agency, and conforms with this division and all regulations <br /> adapted pursuant to this division, and the terms and conditions of the solid waste facilities <br /> permit are revised to reflect the change. (b) If the operator wishes to change the design or <br /> operation of the solid waste facility in a manner that is not authorized by the existing permit, the <br /> operator shall file an application for revision of the existing solid waste facilities permit with the <br /> enforcement agency. The application shall be filed at least 150 days in advance of the date when <br /> the proposed modification is to take place unless the 150-day time period is waived by the <br /> enforcement agency. <br /> The proposed amendment indicates that the incoming temperatures have become an <br /> issue/violation. The EHD is concerned with the temperatures that are generated by the storage of <br /> the green waste at the facility. The temperatures generated by the green waste may still pose a ' <br /> Page 2 of 3 <br />