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TWRTS Expansion ALVD IR December 22, 1-011 Page 2 of 3 CALRECYCLE STAFF COMMENTS Permitting The San Joaquin County Environmental Health Department provided comments in a letter dated September 13, 2011, acting as the Local Enforcement Agency (LEA). This letter from CalRecycle staff is in support of the comments made by the LEA. In particular,there is a concern about permitting the full build-out proposal in the MND until at such time that the project proponent can accommodate the increase in operations to full build-out. SWFPs are expected to analyze for projects projecting at least five years of activities that can be accommodated by the facility's permit. At the end of each five year period, the LEA will do a five-year permit review to determine whether the facility throughput can be accommodated by the existing permit. Phase 1 is projected for a 10 year planning horizon and is recommended by CalRecycle to be proposed in the revised SWFP which can be revisited in five years. Odor Impact Minimization Page 16 of the Composting Project Description(0423 10)under the title "Compost Facility Information" it states that"[t]he operator will utilize three methods to process and compost feedstocks...". These methods include: 1. "windrow, elongated, for"green waste only" 2. windrow, elongated, for co-composting green waste and food waste feedstocks (up to 20%food waste) 3. pile, enclosed aerated static ("CTI in-vessel system"), for food waste feedstock(green waste or other bulking agent may be added 4. pile, covered aerated static. For food waste feedstock(green waste or other bulking agent may be added)." Page 10 in the Odor Impact Minimization Plan(GIMP) under the title of"Operations Plan for the proposed composting operations" states that"[i]ncoming food waste material will be processed and loaded into composting bags within 48 hours of receipt. Processed materials may be combined with process liquid, which may be collected during initial composting phase, from existing filled composting bags. Once processed and mixed, materials will be loaded into composting bags within 48 hours; materials not bagged immediately after mixing may be tarped to minimize any potential odors." CalRecycle's experience with food wastes has proved to be very high in moisture content. If the food wastes are liquid(not spade able)then the materials should not be accepted at the project site. In addition,the amount of time between the food materials being discarded,picked up, transported to the site and placed in a pile in the processing area is unknown and can lead to receipt of a putrescible mixture that is already undergoing decomposition adding to the odor that discarded food waste already has. CalRecycle staff recommends that the statement in the OIMP "[o]nce processed and mixed, materials will be loaded into composting bags within 48 hours;materials not bagged immediately after mixing may be tarped to minimize any potential odors"be changed to read"[o]nce processed and mixed, materials will be loaded into composting bags within 24 hours; materials not bagged immediately after mixing will be tarped to minimize any potential odors."