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Harprit S. Mattu [EH] From: Robert McClellon [EH] Sent: Wednesday, December 7, 2016 2:10 PM To: Michael Kith [EH]; Harprit S. Mattu [EH] Subject: FW: Limiting Commercial Food Scraps at Harvest - Lathrop FYI From: Matthew Cotton [mailto:matt@mattcotton.com] Sent: Wednesday, December 07, 2016 1:31 PM To: Robert McClellon [EH] Cc: Sam Monaco Subject: Limiting Commercial Food Scraps at Harvest - Lathrop Robert - Thanks for the productive call this morning. I appreciate your willingness to work through this challenge. In the spirit of starting small and trying to understand the potential for off-site odor impacts of accepting commercial food scraps, before going to larger quantities, Harvest could voluntarily limit it's incoming volume of commercial food scraps to 50 tons per day. This is estimated to be two deliveries per day. Although annually, this will add 13,000 tons to the facility, the most food on-site, being composted at any one time, would be 3,250 tons (because the facility makes 4 "batches" a year). Food scraps are heavy (compared to green waste) so the 3,250 tons would be roughly 3,250 cubic yards (or less). And remember, all food waste delivered will be on a concrete pad, will get mixed with ground green material and put into a windrow, which will be capped within 24 hours with 8 inches of compost or overs. The "Research Notification" allows for "not more than 5,000 cubic yards of feedstock, etc" (see below). 17862. Research Composting Operations. (a) An operator conducting research composting operations shall not have more than 5, 000 cubic -yards of feedstock, chipped and ground material, amendments, additives, active compost, and stabilized compost on-site at any one time, and shall comply with the EA Notification requirements set forth in Title 14, California Code of Regulations, Division 7, Chapter 5. 0, Article 3.0 (commencing with section 18100), except as otherwise provided by this Chapter. So depending on how one interprets 5,000 cubic yards (does this include all feedstock, or just food?), this might work. I believe Harvest would prefer to include food scraps in the Full permit (since the facility already gets a minimal amount of food delivered co -mingled with yard trimmings). Don't want to push too much of a square peg into a round hole. So, maybe we could say (via a condition in the Solid Waste Facility Permit): "The facility is limited to two loads per day of commercial food scraps (a total of 50 tons per day) until such time as the LEA makes a finding that exceeding that volume will not pose an additional odor risk." Let me know what you think. I am around the rest of the week if you want to discuss. 1 SCANIVED