Request for Comments Proposed Solid Waste Permit for Stateline Compost Comments due: 5 p.m., June 10, 2016

Summary DEQ proposes to issue a solid waste permit for this new composting facility. All activities would have to be performed in conformance with the requirements, limitations and conditions set out in the permit.

How do I participate? To submit your written comments for the public record send them by mail, fax, or email:
Shari Harris-Dunning DEQ Eastern Region Solid Waste Permit Writer 475 NE Bellevue Drive, Suite 110 Bend, Oregon 97701

Fax: 541-388-8283 Email: harris-dunning.shari@deq.state.or.us Phone: 541-633-2010

About the Facility The site is located about three miles south of Worden, Oregon on the east side of US highway 97. It is about ¾ of a mile from the Oregon/California border. This is a new compost operation.

It is anticipated that up to 30,000 tons per year of feedstock will be processed at the facility. This total includes the combined volume of type 1, 2 and 3 feedstocks. Anticipated sources of feedstock include; municipalities, agriculture, industry and the general public.

Type 1 feedstocks include source-separated yard and garden wastes, wood wastes, agricultural crop residues, wax-coated cardboard, vegetative food wastes and other materials DEQ determines pose a low level of risk from hazardous substances, physical contaminants and human pathogens.

Type 2 feedstocks include manure and bedding and other materials DEQ determines pose a low level of risk from hazardous substances and physical contaminants and a higher level of risk from human pathogens compared to type 1 feedstock.

Type 3 feedstocks include dead animals, meat and source-separated mixed food waste and industrially produced non-vegetative food waste. They also include other materials the department determines pose a low level of risk from hazardous substances and a higher level of risk from physical contaminants and human pathogens compared to type 1 and 2 feedstocks. Stateline Composting facility is not planning on taking dead animals, nor food waste; however they are planning on taking butcher waste. Type 3 feedstocks will make up less than 10% of the overall feedstocks received at the facility.

The primary composting method used will be “Aerated Static Piles”. A 40,000 square foot asphalt pad will be constructed on the north boundary for the composting operation. Any leachate and runoff from the pad will be directed through a bio-filter lining the pad on the north boundary. A 10 foot lined rock spillway will direct the leachate from the pad to a lined retention pond. Leachate water from the retention pond will be re-used on feedstock/compost material.

How does DEQ determine what requirements go into the permit? Various federal and state regulations apply to a facility depending on the type of industry, the type and amount of solid waste produced and the location of the facility. All applicable regulations must be contained in the permit, including the appropriate recordkeeping, monitoring and reporting requirements to ensure compliance with these rules.

Health and Environmental Impacts All new composting facilities are screened for potential environmental and human health risks. DEQ staff evaluated the Stateline Composting facility for potential environmental and human health risks to surface water, groundwater and possible odor impacts.

Surface water risk screening - poses potential risk: The facility has few neighbors and has a mean annual rainfall of 12 inches/year. The proposed composting operation will be on an impervious surface with any leachate going to a lined leachate pond. However, the proximity of this site to irrigation drainage waters and the potential for this water to reach the property, or for any uncontaminated runoff from this property to reach drainage waters elevates the potential risk level for surface water.

Groundwater screening - low risk: Depth to ground water is 58 ft and is a confined aquifer. The site is located in an arid high plateau area with average annual rainfall of 12 inches and an evapotranspiration rate of 50 inches/year which reduces the likelihood of storm water accumulating at the site. All processing will be done on an asphalt pad up until the curing stage (4-8 weeks). Any potential leachate from the compost operation will be captured and re-used on the compost windrows during the active phase of composting.

Odor risk screening- poses potential risk: Although the property is along a fairly remote section of Highway 97 near the Oregon-California border and the closest neighbor is in California approximately one quarter mile south from the proposed compost site, the concern is for potential odors generated from the type 3 feedstock entering the facility. Prior to processing, this feedstock can be odiferous. Improper management of this type of feedstock can cause odors. As this is a new facility with individuals who have never operated a composting facility, it is prudent to take a conservative approach to odor screening.

As a result of this risk screening, DEQ has drafted an individual Compost Permit. The permittee will be required to have a DEQ approved Operations Plan and Odor Minimization Plan prior to beginning composting operations.

What are the special conditions of this permit? The permittee is required to have a DEQ approved odor minimization plan that they follow. What happens after the public comment period closes? DEQ considers and responds to all comments received and may modify the proposed permit based on comments received.

Where can I get more technical information? Scroll down to view the DEQ permit review report and the draft renewal permit. If you have any technical questions, please contact: Shari Harris-Dunning Phone: 541-633-2010 or Toll-free in Oregon: 866-863-6668
Fax: 541-388-8283
Email: harris-dunning.shari@deq.state.or.us
For a review appointment of the application and related documents contact Jackie Marsh at the DEQ office in Bend, located at 475 NE Bellevue Drive, Suite 110, Bend, OR 97701, 541-388-6146. Accessibility information: DEQ is committed to accommodating people with disabilities. If you need information in another format, please contact DEQ toll free in Oregon at 800-452-4011, email at deqinfo@deq.state.or.us, or 711 for people with hearing impairments.
Facility Name: Stateline Compost Permit Number: 1576 Expiration Date: MONTH, DAY 20XX Page 1 of 12
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SOLID WASTE DISPOSAL SITE PERMIT COMPOSTING FACILITY Oregon Department of Environmental Quality 400 E. Scenic Dr., Suite 307 The Dalles, OR 97058 Telephone (Information): (503)229-5353 Issued in accordance with the provisions of Oregon Revised Statutes (ORS) Chapter 459, Oregon Administrative Rules (OAR) 340 Divisions 93, 95, 96 and 97 and ORS Chapter 468B and subject to the Land Use Compatibility Statement referenced below.
ISSUED TO: FACILITY NAME AND LOCATION: Grant Haigh Haigh Livestock, LLC PO Box 447 Merrill, OR 97633 (541) 880-8318 Stateline Compost 24600 Hwy 97 Klamath Falls, OR 97603 PROPERTY OWNER: OPERATOR: Grant Haigh PO Box 447 Merrill, OR 97633 (541) 880-8318 Grant Haigh PO Box 447 Merrill, OR 97633 (541) 880-8318
ISSUED IN RESPONSE TO: • A solid waste disposal site, composting facility permit application and associated documents, received on December 21, 2015. • A Land Use Compatibility Statement from the Klamath County Planning Department dated: December 16, 2015.
The determination to issue this permit is based on findings and technical information included in the solid waste disposal site permit application and in the permit record. ISSUED BY THE OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY
___________________________ Elizabeth Druback Date Solid and Hazardous Waste Programs Manager Eastern Region Permitted Activities Until such time as this permit expires or is modified or revoked, the permittee is authorized to establish, operate, and maintain a solid waste disposal site for composting activities and to construct, install, modify or operate stormwater and process water treatment and/or control facilities in conformance with the requirements, limitations, and conditions set forth in this document, including all attachments.
Unless specifically authorized by this permit, by a National Pollutant Discharge Elimination System (NPDES) or Water Pollution Control Facilities (WPCF) permit, or by Oregon Administrative Rule, any other direct or indirect discharge to waters of the state is prohibited.
Facility Name: Stateline Compost Permit Number: 1576 Expiration Date: MONTH, DAY 20XX Page 2 of 12
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TABLE OF CONTENTS
Introduction. This solid waste permit is issued by DEQ in accordance with Oregon Revised Statutes (ORS) 459, ORS 468B.050 and Oregon Administrative Rules (OAR), Chapter 340. This is an individual permit that is issued to owners and operators of composting facilities. Rules relating specifically to composting facilities may be found in OAR Chapter 340, Divisions 93, 95, 96 and 97.
This document contains the following sections: Page Allowable Activities ............................................................................................. 3 1.0 Authorizations ........................................................................................... 3 2.0 Prohibitions ............................................................................................... 3 Operations and Design ........................................................................................ 4 3.0 Operating Conditions ................................................................................ 4 4.0 Operations Plan ........................................................................................ 5 5.0 Recordkeeping and Reporting .................................................................. 6 6.0 Engineered Structures, Design and Management ................................... 8 General Conditions ......................................................................................... ….9 7.0 Administration ........................................................................................... 9 8.0 Permit Modification.................................................................................... 9 9.0 Site Operations ....................................................................................... 10 Compliance Schedule ........................................................................................ 12 10.0 Summary of Due Dates ........................................................................... 12 11.0 When To Notify DEQ Staff ...................................................................... 12
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ALLOWABLE ACTIVITIES
1.0 AUTHORIZATIONS
1.1 Authorization to receive specific types of feedstocks. This permit authorizes the facility to accept the following feedstocks (Note: a detailed list of authorized feedstocks is listed in the DEQ-approved Operations Plan for this site.):

• Type 1, Type 2 and Type 3. 1.2 Authorization to receive other feedstocks or amendments. Feedstocks or amendments excluded from the above authorization may not be accepted unless DEQ has approved in writing an updated Operations Plan which describes the new feedstocks or amendments. 1.3 Authorization of other activities.

 All facility activities must be conducted in accordance with the provisions of this permit. All reports and plans required by this permit become part of the permit by reference once approved by DEQ. Any conditions of report and plan approvals are also incorporated into this permit unless contested by the permittee within 30 days of the receipt of a conditional approval. 1.4 Water quality activities. The permittee is allowed to construct, install, modify, operate and maintain a composting facility leachate and/or stormwater collection and/or treatment system provided these activities are done in accordance with plans and specifications approved in writing by DEQ. No activities are to be conducted that could adversely impact groundwater quality. 2.0 PROHIBITIONS 2.1 Prohibited feedstocks or wastes. The permittee is prohibited from accepting materials for composting that are not specifically authorized in Section 1.1 of this permit, unless the materials have been approved in accordance with the requirements of Section 1.2 of this permit.

The permittee must not accept any wood waste that does not meet the definition of wood waste in OAR 340-093-0030.

The permittee must not accept unsorted, mixed domestic solid waste as a feedstock or for disposal at the composting facility.

The permittee must not accept any materials that are listed in OAR 340-093-0040, as prohibited from disposal at solid waste disposal sites, including but not limited to hazardous waste as defined in ORS 466.005 and OAR 340, Division 101. 2.2 Discovery of prohibited wastes. In the event that the permittee discovers prohibited feedstocks or wastes at the composting facility, the permittee must, within 48 hours, notify DEQ and initiate procedures to isolate or remove the prohibited feedstocks or waste.

• Non-putrescible, non-hazardous, prohibited waste must be transported to a disposal or recycling facility authorized to accept such waste within 90 days, unless otherwise approved by DEQ. • Putrescible, non-hazardous, prohibited wastes must be removed within 48 hours, unless otherwise approved in writing by DEQ. • In the event the permittee discovers wastes that are hazardous or suspected to be hazardous, the permittee must, within 48 hours, notify DEQ. • Hazardous wastes must be removed within 90 days, unless otherwise approved by DEQ.

 Temporary storage and transportation must be carried out in accordance with DEQ rules.

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2.3 Open burning. The permittee must not initiate or maintain any open burning at this site. Reference: OAR 340-264-0030 (defines open burning). 2.4 Sewage sludge (biosolids). The permittee must not accept any sewage sludge for composting at this facility, except Class A exceptional quality biosolids that have been approved by DEQ in the Operations Plan. If the permittee wishes to accept sewage sludge other than Class A exceptional quality biosolids, then the permittee must obtain the applicable water quality permit, in lieu of this solid waste permit, as required under ORS 468B and OAR 340-050.

OPERATIONS AND DESIGN
3.0 OPERATING CONDITIONS 3.1 Performance Standards. The composting facility must be operated in conformance with the performance standards identified in OAR 340-096-0070:

1) All composting facilities must be designed, constructed, and operated in a manner that does not cause a discharge of leachate, liquid digestate or stormwater from the facility to surface water, except when such discharge is in compliance with a discharge permit issued by DEQ.

2) All composting facilities that collect and dispose of leachate, liquid digestate or stormwater in engineered structures must comply with the applicable requirements of OAR 340-096-0130 Special Rules Pertaining to Composting: Biogas, Liquid Digestate, Leachate Collection Design and Management Requirements.

3) All composting facilities must be designed, constructed, and operated in a manner that does not cause a likely adverse impact to groundwater under OAR 340 Division 40. All composting facilities proposing to use infiltration in soil as a method for managing leachate, liquid digestate or stormwater must comply with OAR 340-096-0120 Special Rules Pertaining to Composting: Groundwater Protection.

4) All composting facilities must be designed, constructed, and operated in a manner that, to the greatest extent practicable, is consistent with proper facility design and operation, controls and minimizes odors that are likely to cause adverse impacts outside the boundaries of the facility.

5) All composting facilities must be designed, constructed, and operated in a manner that achieves human pathogen reduction as required by OAR 340-096-0140 Special Rules Pertaining to Composting: Pathogen Reduction.

6) All composting facilities must be designed, constructed, and operated in a manner that controls or prevents propagation, harborage, or attraction of vectors, including but not limited to rats, birds, and flies.

7) All composting facilities must comply with all other applicable laws and regulations. 3.2 Pathogen reduction. The composting facility must be operated in conformance with OAR 340-096-0140 Special Rules Pertaining to Composting: Pathogen Reduction including the following:

1) Analytical limits for anaerobic digestion facilities’ composted material and digestate:
a) For composted material or digestate produced from Type 1 or Type 3 feedstock, or a mix of Type 1 and Type 3 feedstock with less than 50% by volume of Type 2 feedstock, analysis must be performed for salmonella or fecal coliform:

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Parameter Limitations Fecal Coliform Less than 1,000 Most Probable Number (MPN) per gram of total solids (dry weight) Salmonella Less than 3 Most Probable Number (MPN) per 4 grams of total solids (dry weight)
b) For composted material or digestate produced from feedstock containing more than 50% by volume of Type 2 feedstock analysis must be performed for fecal coliform:

Parameter Limitations Fecal Coliform Less than 1,000 Most Probable Number (MPN) per gram of total solids (dry weight)

2. Testing frequency for composted material or solid digestate to determine pathogen reduction success:
Amount and Type of Compost/Solid Digestate Produced Annually
Minimum Frequency Type of Sample
Less than 2,500 tons of composted material or solid digestate from Type 1 and/or 2 feedstocks
Testing must be conducted once a year
Composite from finished compost or solid digestate
Greater than 2,500 tons of composted material or solid digestate from Type 1 and/or 2 feedstock are produced per year
Testing must be conducted every 5,000 tons of feedstock used or a maximum of once every three months
Composite from finished compost or solid digestat
Less than 2,500 tons of composted material or solid digestate from Type 3 feedstocks
Testing must be conducted once every 4 months
Composite from finished compost or solid digestate
Greater than 2,500 tons of composted material or solid digestate from Type 3 feedstocks
Testing must be conducted every 5,000 tons of feedstock used or monthly
Composite from finished compost or solid digestate
4.0 OPERATIONS PLAN
4.1 Plan compliance. The permittee must conduct all operations at the facility in accordance with the approved Operations Plan and Odor Minimization Plan, including any amendments. The DEQ approved Operations Plan is incorporated into the permit by reference.
Note: The basic elements of an Operations Plan for a composting facility are listed in OAR 340-096-0026. 4.2 Initial Operations Plan. Prior to commencing operations, the permittee must update their draft Operations Plan to incorporate any changes proposed during public comment on the permit, and receive written approval of the final document from DEQ. 4.3 Plan maintenance. The permittee must revise the Operations Plan as necessary to keep it up to date and reflective of current facility conditions and procedures.
The permittee must submit revisions of the Operations Plan to DEQ for review and written approval prior to commencing any change in operations.
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4.4 Submittal address. All submittals to the DEQ under this section must be sent to: Oregon Department of Environmental Quality Manager, Solid and Hazardous Waste Program 400 E. Scenic Dr., Suite 307 The Dalles, OR 97058 Phone: (503)229-5353
5.0 RECORDKEEPING AND REPORTING 5.1 Non-compliance reporting. In the event that any condition of this permit or of DEQ’s rules is violated, the permittee must immediately take action to correct the violation and to notify DEQ within 24 hours at: DEQ’s Eastern Region Solid Waste Program Office at (541) 388-6146.
Response: In response to a notification, DEQ may conduct an investigation to evaluate the nature and extent of the problem, and may require additional corrective actions, as necessary. 5.2 Leachate release reporting. Unauthorized leachate releases to waters of the state must be reported to DEQ within 24 hours, at the same number listed above. 5.3 Access to records. Upon request, the permittee must make all records and reports related to the permitted facility available to DEQ. 5.4 Recordkeeping procedures. The permittee must keep records and submit reports according to the following: Step 1: Establish a location for document retention at the facility, or at another location mutually agreed to with DEQ. Step 2: Collect information during facility operations on the amount of each type of feedstock received, recording "0" if none is received.

At a minimum, the following types of feedstocks must be: 1) separately identified; and 2) categorized as originating either in or out-of-state:
A. Type 1, 2 and 3 feedstocks or amendments: a. Leaves b. Yard debris – compacted and uncompacted c. Food waste – vegetative and non-vegetative d. Fats, oils and grease (animal origin) e. Animal mortality/slaughter waste f. Wood chips – dry g. Wood chips – green h. Clean wood waste i. Sawdust, wet j. Sawdust, bone dry k. Agricultural crop residue l. Industrial food processing waste and waste waters m. Manure n. Bedding
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B. Other authorized feedstocks or amendments. Submit the information on the Composting Facility Report form provided by DEQ. Date Due: January 31 of each year for the previous calendar year. Pay the Annual Permit Compliance Fee required by OAR 340-097. Invoice will be sent out by DEQ. Date Due: July 31 of each year. Step 3: Permittees accepting non-agricultural, post-consumer recyclable materials generated in Oregon must complete a Material Recovery Survey on a form provided by DEQ. Information necessary to complete this survey includes: amounts and types of recyclable materials; county of origin of the material; and, names of companies providing the material(s). The survey also asks for information about what was done with the recyclable material, such as: made compost; shipped wood waste for hogged fuel; etc. The permittee must submit this survey to the local Wasteshed Representative. The survey is then forwarded by that person to DEQ. Date Due: January 31 of each year for the previous calendar year. Step 4: Keep a written, ongoing log showing assessment of composting processing parameters required in OAR 340-096-0090(5)(i). This log must be placed in the facility file. Step 5: Retain copies of all records and reports for five years from the date created. Step 6: Update all records such that they reflect current conditions at the composting facility. 5.5 Submittal address. Submittals for step 2 (Composting Facility Report and the Annual Permit Compliance Fee) above must be sent to DEQ at: Oregon Department of Environmental Quality Land Quality Division Solid Waste Program 811 SW Sixth Ave. Portland, OR 97204 Phone: (503) 229-5913
Beginning November 1, 2016, send these submittals to: Oregon Department of Environmental Quality Materials Management Section, Environmental Solutions Division 700 NE Multnomah Street, Suite 600 Portland, OR 97232 503-229-5913
Submittals for step 3 (Material Recovery Survey) must be sent to the address on the survey form.
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6.0 ENGINEERED STRUCTURES, DESIGN AND MANAGEMENT 6.1 Facility Design and Construction Plan. Composting facilities that collect biogas, liquid digestate, leachate or stormwater in engineered structures must comply with the requirements of OAR 340-0960130 Special Rules Pertaining to Composting: Biogas, Liquid Digestate, Leachate Collection Design and Management Requirements. Structures subject to this rule include, but are not limited to:
• Biogas collection and storage system; • Liquid digestate collection and management system; • Leachate collection and storage facilities; • Stormwater collection and storage facilities; and • Constructed surfaces designed to protect groundwater
The permittee must contact DEQ prior to any site modification affecting these structures. DEQ may require the permittee to prepare and submit a modified Facility Design and Construction Plan, stamped by a registered professional engineer. The permittee must receive written approval of the modified Facility Design and Construction Plan from DEQ prior to commencing construction. 6.2 Construction requirements. The permittee must perform all construction in accordance with the approved plans and specifications, including all conditions of approval. Any amendments to those plans and specifications must be approved in writing by DEQ. 6.3 Construction documents. Prior to initiating construction, the permittee must submit and receive written DEQ approval of complete construction documents for the project to be constructed. The construction documents submitted must:
• Define the construction project team; • Include construction contract documents specifying material and workmanship, and requirements to guide how the Constructor is to furnish products and execute work; and • Include a Construction Quality Assurance (CQA) plan describing the measures that will be taken to monitor and ensure that the quality of materials and the work performed by the Constructor complies with project specifications and contract requirements. 6.4 Construction report submittal. Within 90 days of completing construction, the permittee must submit to DEQ a Construction Certification Report, prepared by a qualified independent party, to document and certify that all required components and structures have been constructed in compliance with the permit requirements and DEQ approved design specifications. This submittal must include “as constructed” facility plans which note any changes from the original approved plans. 6.5 Approval to use. The permittee must not accept feedstocks for storage, processing or composting in newly constructed facilities or areas until DEQ has accepted the Construction Certification Report. If DEQ does not respond in writing to the Construction Certification Report within 30 days of its receipt, the permittee may accept feedstock at the facility in the newly constructed facilities or areas. 6.6 Submittal address. All submittals to DEQ under this section must be sent to: Oregon Department of Environmental Quality Manager, Solid Waste Program 400 E. Scenic Dr., Suite 307 The Dalles, OR 97058 Phone: (541)298-7255 x221
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COMPOSTING FACILITY GENERAL CONDITIONS
7.0 ADMINISTRATION 7.1 Definitions. Unless otherwise specified, all terms are as defined in OAR 340-093-0030. 7.2 Property rights. The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights. 7.3 DEQ liability. DEQ, its officers, agents, or employees do not sustain any liability on account of the issuance of this permit or on account of the construction, maintenance, or operation of facilities pursuant to this permit. 7.4 Documents superseded. This document is the primary composting permit for the facility, superseding all other solid waste permits issued for this facility by DEQ. 7.5 Binding nature. Conditions of this permit are binding upon the permittee. The permittee is liable for all acts and omissions of the permittee’s contractors and agents. 7.6 Access to disposal site. The permittee must allow representatives of DEQ access to the facility at all reasonable times for the purpose of performing inspections, surveys, collecting samples, obtaining data and carrying out other necessary functions related to this permit. 7.7 Other compliance. Issuance of this permit does not relieve the permittee from the responsibility to comply with any applicable federal, state, or local laws or regulations. 7.8 Penalties. Violation of any condition of this permit or any incorporated plan may subject the permittee to civil penalties up to $25,000 for each day of each violation.
8.0 PERMIT MODIFICATION 8.1 Mid-term review. At the mid-point of the permit term, DEQ may review the permit and determine whether or not the permit should be amended. While not an exclusive list, the following factors will be used in making that determination:
• Compliance history of the facility; • Changes in volume and/or composition of feedstock(s); • Changes in operations at the facility; • Changes in state or federal rules which should be incorporated into the permit; • Release of leachate to the environment from the facility; or • Significant changes to the DEQ-approved Design Plan or Operations Plan. 8.2 Modification. At any time during the life of the permit, DEQ or the permittee may propose changes to the permit. 8.3 Modification and revocation by DEQ. The director of DEQ may, at any time before the expiration date, modify, suspend, or revoke this permit in whole or in part in accordance with Oregon Revised Statutes 459.255 for reasons including, but not limited to, the following:
• Violation of any terms or conditions of this permit or any applicable statute, rule, standard or order of the Environmental Quality Commission; • Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts;
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• A significant change in the quantity or character of feedstocks received; • Non-compliant operation of the composting site; or • A significant change in the composting process. 8.4 Modification by permittee. The permittee must apply for a modification to this permit if a significant change in facility operations is planned or there is a deviation from activities described in this document. The permittee must not implement any change in operations that requires a permit modification prior to receiving approval from DEQ. 8.5 Public participation. Significant changes in the permit will be made public by the issuance of a public notice as required by DEQ rules. 8.6 Changes in ownership or address. The permittee must report to DEQ in writing any changes in either ownership of the composting site property or of the name and address of the permittee or operator within ten (10) days of the change.
9.0 SITE OPERATIONS 9.1 Containers. The permittee must clean all containers used on-site, as needed to maintain a sanitary operating environment, and to prevent malodors, unsightliness, and attraction of insects. 9.2 Vehicles and Truck Covers. All vehicles and devices operated by the permittee, and using public roads, must be constructed, maintained, and operated so as to prevent leaking, shifting, or spilling of feedstocks and finished compost while in transit. The permittee must notify all incoming feedstock haulers that trucks containing loads that are likely to blow or fall must be covered or suitably cross-tied to prevent any load loss during shipment, in conformance with OAR 340-093-0220.
9.3 Litter control. Litter that results from the composting facility operation must be controlled such that the entire composting facility and adjacent lands are maintained virtually free of litter at all times. Any debris from the facility must be retrieved and properly disposed of as soon as possible that same operational day. 9.4 Air Quality. Dust must be controlled in accordance with DEQ’s rules on air pollution. 9.5 Drainage. The permittee must divert surface drainage around or away from feedstock handling and grinding areas and digestate storage areas. The permittee must maintain surface water diversion ditches or structures in a serviceable condition and free of obstructions and debris at all times. Any significant damage must be reported to DEQ and repairs made as soon as possible. 9.6 Leachate prevention and management. The permittee must operate the facility in a manner that deters leachate production to the maximum extent practicable. Leachate must be collected, removed and managed in a manner approved by DEQ. 9.7 Oil & Hazardous Material Spill Response. Any spill of oil or hazardous material must be cleaned up immediately as described in the facility Operations Plan. In addition to notifying the appropriate DEQ office, if the spill is of a reportable quantity the permittee must immediately report the spill to the Oregon Emergency Response System (OERS), at 1-800-452-0311.
Reportable quantities include: • Any amount of oil spilled to waters of the state; • Oil spills on land in excess of 42 gallons; • 200 pounds (25 gallons) of pesticide residue; or
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• Hazardous materials that are equal to, or greater than, the quantity listed in the Code of Federal Regulations, 40 CFR Part 302 (List of Hazardous Substances and Reportable Quantities), and amendments adopted before July 1, 2002. For a complete list of hazardous materials required to be reported, please refer to OAR 340-142-0050. 9.8 Feedstock Unloading area. The area(s) used by the public for unloading feedstocks must be clearly defined by signs, fences, barriers, or other devices. 9.9 Public Access. Public access to the facility must be controlled, as necessary, to prevent unauthorized entry and dumping. 9.10 Legal control of property. The permittee must maintain legal control of the composting site property, including maintaining a current permit, contract or agreement that allows the operation of the facility if the site is not owned by the permittee. 9.11 Fire protection. Arrangements must be made with the local fire control agency to immediately acquire their services when needed and adequate on-site fire control protection, as determined through the local fire control agency, must be provided. Unauthorized fires must be immediately extinguished and reported to DEQ within 24 hours. 9.12 Signs. The permittee must post signs at the facility which are clearly visible and legible, providing the following information: Name of composting facility, emergency telephone number, days and hours of operation, solid waste permit number; and operator’s address. 9.13 Vector Control. The permittee must provide rodent and insect control measures, as necessary, to prevent vector production and sustenance. 9.14 Complaints. The permittee must investigate and attempt to resolve all complaints it receives regarding facility operations by following their complaint response plan, or at minimum doing the following:
• Contact the complainant within 24 hours to discuss the problem; • Keep a record of the complaint, name and phone number of the complainant (when possible), date complaint was received and date of, and response by, the facility operator; and • Immediately initiate procedures at the facility, when possible, to resolve the problem identified by the complainant.
For odor, litter or dust complaints, the permittee must report to DEQ as soon as complaints are received at the facility from five (5) different businesses and/or individuals about a given event or if an odor event lasts longer than 24 hours without resolution or mitigation. 9.15 Permit display. The permittee must display this permit, or a photocopy thereof, where operating personnel can readily refer to it.
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COMPLIANCE SCHEDULE 10.0 SUMMARY OF DUE DATES. The following is a summary of event-driven reporting required by this permit. This section does not include routine reporting and submittals required by this permit.
DUE DATE ACTIVITY RULE CITATION/ SECTION IN THIS PERMIT Prior to initiating any new construction for biogas, liquid/solid digestate, leachate or stormwater collection systems or groundwater protective surfaces Submit design and construction plans and receive written DEQ approval of plans • OAR 340-096-0130 • Permit condition 6.1 Prior to initiating construction Submit construction documents, including a Construction Quality Assurance Plan and receive written DEQ approval • OAR 340-096-0130 • Permit condition 6.3 Within 90 days after completion of any major construction and prior to accepting feedstock in new construction Submit Construction Certification Report for acceptance Receive written DEQ approval of Report • OAR 340-096-0130 • Permit condition 6.4 One year prior to closure Notify DEQ in writing
11.0 WHEN TO NOTIFY DEQ. Note: Contact DEQ staff at phone number listed in section 5.1, “Noncompliance reporting.
TOPIC NOTIFICATION REQUIREMENTS
SECTION IN THIS PERMIT
Facility not able to meet requirements of this permit
Contact DEQ for assessment within 24 hours All
Prohibited or hazardous waste discovered at facility
Notify DEQ within 48 hours 2.2
Conditions of permit violated Notify DEQ within 24 hours 5.1 Leachate released from facility Notify DEQ within 24 hours 5.2 Change in ownership of facility Notify DEQ in writing within 10 days 8.6 Change in name or address of facility, name or address of permittee or name or address of operator Notify DEQ in writing within 10 days 8.6
Odor Complaints Notify DEQ after 5 complaints are received for same odor event or if odor persists unresolved after 24 hours
9.14
Litter or Dust Complaints Notify DEQ after 5 complaints are received for an event
9.14
State of Oregon Department of Environmental Quality Memorandum
PERMIT EVALUATION REPORT
To: Elizabeth Druback Manager Date: April 6, 2016 DEQ Solid Waste Program Eastern Region
From: Shari Harris-Dunning DEQ Solid Waste Program Eastern Region
Subject: Permit Evaluation Report Compost Facility Solid Waste Permit Stateline Compost DEQ SW Disposal Site Permit No. 1576 (new facility) Klamath County
INTRODUCTION DEQ received an application for a New Compost Facility Permit Application on December 21, 2015, by Grant Haigh, property owner of the Stateline Livestock Transfer Station facility. An initial review of the application by DEQ determined that it was complete.
A community meeting was held on November 16, 2015, and a pre-application conference with Klamath County Planning and DEQ staff was held prior to the community meeting. The Klamath County Planning Department issued a conditional permit for a composting facility at this property on November 19, 2015.
The proposed Stateline Compost facility desires to meet the increasing demand for the recycling of organic wastes in the region by composting type 1, 2 and 3 feedstocks.
LOCATION The site is located about three miles south of Worden, Oregon on the east side of US highway 97. It is about ¾ of a mile from the Oregon/California border.
LAND USE APPROVAL STATUS A Land Use Compatibility Statement was signed by Klamath County Planning Department on December 16, 2015.
ACCESS The site is accessed from an approach off of Highway 97 on the northwest corner of the property. The access road currently is gravel.
ACCESS CONTROL The entire acreage is currently fenced with barbed wire fencing, other than the approach which is bordered by a cattle guard.
Permit Evaluation Report Stateline Compost Facility DEQ Solid Waste Disposal Site Permit No. 1576 Klamath County Page 2 of 3
FACILITY OPERATION This is a new compost operation. It is anticipated that up to 30,000 tons per year of feedstock will be processed at the facility. This total includes the combined volume of type 1, 2 and 3 feedstocks. Anticipated sources of feedstock include; municipalities, agriculture, industry and the general public.
The primary composting method used will be “Aerated Static Piles”. A 40,000 square foot asphalt pad will be constructed on the north boundary for the composting operation. Any leachate and runoff from the pad will be directed through a bio-filter lining the pad on the north boundary. A 10 foot lined rock spillway will direct the leachate from the pad to a lined retention pond. Calculations for a 24 hr – 25 year storm as well as a 24 hr – 100 year storm in Klamath Falls were used to calculate the dimensions of the retention pond.
Leachate water from the retention pond will be re-used on feedstock/compost material. Leachate will be limited due to the proposed elevated and sloped pad. Leachate will also be minimized with process management of maintaining moisture levels at 55% at initial mixing of feedstocks. No material will leave the concrete pad until the curing stage.
Compost will be sold primarily to the general public or to the agricultural industry.

ENVIRONMENTAL CONCERNS/RISK SCREENING DEQ staff evaluated the Stateline Composting facility for potential environmental and human health risks, including risks to surface water, groundwater and possible odor impacts.

Surface water risk screening (poses potential risk): The proposed Stateline Compost site is located 3 miles south of Worden in Klamath County on the east side of Highway 97. It is approximately ¾ miles north of the Oregon-California border and is considered the High Plateau. The facility has few neighbors and has a mean annual rainfall of 12 inches/year. The proposed composting operation will be on an impervious surface with any leachate going to a lined leachate pond. However, the proximity of this site to drainage waters and potential for this water to reach the property, or for any uncontaminated runoff from this property to reach drainage waters elevates the risk level for surface water.

Groundwater screening (low risk):
Depth to ground water is 58 ft and it is a confined aquifer. Any potential leachate from the compost operation will be captured and re-used on the compost windrows during the active phase of composting.
All processing will be done on an asphalt pad up until the curing stage (4-8 weeks) at which time the material will be screened for overs and contaminants. Material may then be removed to another location for further curing or storage if more room is needed on the pad. This means it is unlikely to impact ground water on site or the residents’ wells in California.
Stateline Compost is located in an arid High Plateau area with average annual rainfall of 12 inches and an evapotranspiration rate of 50 inches/year which reduces the likelihood of storm water accumulating at the site. Infiltration rate – 0.5 to 2.0 inches/hr.
Permit Evaluation Report Stateline Compost Facility DEQ Solid Waste Disposal Site Permit No. 1576 Klamath County Page 3 of 3

Odor risk screening (poses potential risk): Although the property is along a fairly remote section of Highway 97 near the OregonCalifornia border and the closest neighbor is in California approximately one quarter mile south from the proposed compost site, the concern is for potential odors generated from the type 3 feedstock entering the facility. Prior to processing, this feedstock can be very odiferous. Improper management of this type of feedstock can cause odors. As this is a new facility with individuals who have never operated a composting facility, it is prudent to take a conservative approach to odor screening.

As a result of this risk screening, DEQ is recommending an individual Compost Permit be issued to Stateline Composting. DEQ can revisit this risk screening after Stateline has operated for a period of time and issues related to surface water and odor can be better evaluated.

COMPLIANCE HISTORY This is a new facility with no history of compliance.

PERMIT DISCUSSIONS The proposed Compost Facility Solid Waste Permit for Stateline Compost would cover a ten year period from the date of permit issuance. Under this permit, Stateline Compost would be required to meet all the conditions set forth in the permit. Conditions included in the proposed permit are summarized below:

• Allowable Activities o Authorizations o Prohibitions • Operations and Design o Operating Conditions o Operations Plan o Recordkeeping and Reporting o Engineered Structures, Design and Management o Financial Assurance • General Conditions o Administration o Permit Modification o Site Operations • Compliance Schedule o Summary of Due Dates o When To Notify DEQ RECOMMENDATION DEQ should release the draft individual Compost Facility Solid Waste Permit for Stateline Compost to the applicant and the public for review and comment.

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