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0 0 Cc: Sam Monaco; Jed Phelps; Harprit S. Mattu [EH]; Michael Kith [EH]; Lorraine Paskett Subject: Re: Harvest Power Lathrop OIMP =114 STNIE I will send you the revised OIMP before the end of the day. As far as Conditions of Approval for the CUP, I think both the LEA and Harvest would be happier with very general conditions in the CUP, like "Comply with the requirements of the Solid Waste Facility Permit", or "Comply with the Odor Impact Minimization Plan process." In the same way you might include: "Comply with the Regional Water Quality Control Board requirements, rather than getting into the weeds on stormwater test results. The Odor Impact Minimization Plan process was set up by CalRecycle in 2003 as an iterative process. The OIMP is a living document and by its nature responds to changing conditions either at the facility or surrounding it. Conditions in the CUP can be both difficult and time consuming to change. Conditions in the Solid Waste Facility Permit are also difficult to change, but not nearly as much as the CUP. I would prefer to not create a subjective numerical complaint standard (i.e., "two complaints a month, eight in a year", etc.). The way the OIMP is supposed to work is: if it is working, great. If it's not adequately working to reduce off-site odor complaints, then the operator needs to implement additional management practices to manage the off-site odors. So far (at least as far as I am aware), Harvest has not generated significant off-site odors. The only way Harvest staff will know if there is an off-site odor (other than self-monitoring) is if someone complains either directly to the facility, or to the LEA. At that point (once Harvest is notified) Harvest will try to figure out exactly what it is that caused the off-site odor. Ideally it can be something that can be resolved quickly, like equipment breakdown, or it may take a few days, like correcting a C:N imbalance in the mix. The problem with a numeric odor complaint standard is it takes any judgement away from the LEA. Since we can't predict in the future what the source or cause of the odor might be, I'd hate to commit to essentially a zero tolerance threshold. Once the neighbors find out they only need to call twice on an odor and Harvest is shut down, they may start gaming the system. If there are confirmed off-site odor complaints, I would hope that Harvest and the LEA could work together to resolve them. If for example a loader breaks down and Harvest can't cover the commercial food scraps as fast as they'd like, that could possibly generate two odor complaints, even though a replacement loader could be on-site within a matter of hours? Sometimes off-site odors can be caused by weather inversions, which might last a few days before dispersing and allowing for better air movement. Ideally Harvest would recognize these conditions and prepare for them, but shutting the facility down after only two complaints in a month seems far too restrictive. Please let me know if you want to discuss. Thanks. SCANNED