Status of DEQ Permit

Oregon Department of Environmental Quality issued their modified solid waste permit to Grimm's Fuel on May 1, 2019. This new permit does not meet the needs of the community.

Response to DEQ Proposed Permit

We appreciate the efforts that DEQ has made to bring Grimm’s Fuel into compliance with existing regulations. We are thankful that the DEQ permit is requiring the facility to upgrade to an aerobic system, however, there are a number of areas where the proposed permit does not meet our needs:

Offsite Odor: Considering that DEQ has declined the opportunity to put any measurable odor standard in the permit, we request that the permit require no offsite odor. We will not tolerate nuisance odors in our homes and on our private property. We respectfully request that DEQ replace the vague language of “controls and minimizes odors” with an odor standard that is clear, meaningful, and measurable.

Public Health: We have serious concerns over the potential health impacts from living downwind from this composting operation, and we demand a comprehensive air quality study be performed to determine which airborne contaminants are present in the air. We have a right to know what is in the air that we are breathing. We are concerned about herbicides and pesticides that may be present in the feed stocks. We believe that the regulator and the operator both have a moral and ethical responsibility to prove that the air around the facility is safe to breathe. We request that automated air quality monitoring equipment be installed and operated 24/7.

Dust Monitoring: We request that the permit require the installation of offsite sampling equipment to capture dust and particulates for analysis and measurement. Dust and particulates pose a threat to both health and private property. We request that the DEQ permit require continuous dust monitoring, with special attention paid during turning events.

Air Permit: Based on calculations of yearly VOC emissions, we respectfully request that DEQ require an Air Contaminant Discharge Permit (ACDP) for this facility.

Active Composting: We request that the permit define the difference between active compost piles, curing compost piles, and finished compost piles. We ask that the permit include a stability test that uses clear, objective, measurable criteria.

Impact Study: Although the transition to ASP composting may take 18 months, the proposed permit term is 5 years. Therefore, we request that DEQ require a comprehensive impact study to be performed after the facility has completed the transition to ASP composting.

Verification and Audit: We request that the permit describe the process that DEQ will use to double check and confirm the veracity of all parameters measured by the operator. Self regulation is not a feasible solution when it creates a conflict of interest. We request that all test equipment be calibrated and all test procedures be audited.

Flow Rate: Considering that air flow is crucial to maintaining proper temperature and oxygen levels in the active piles, we request that the permit require the operator to monitor, track, and record the air flow rate and pressure drop on all air blowers at the facility.

Input Limit: We request that the permit require an engineering study be performed to determine the maximum throughput capacity of the compost system. We request the permit to require that the operator never exceed the maximum throughput capacity of the system.

Water Quality: We request monthly sampling of groundwater and stormwater for herbicides, pesticides, and all other potential waterborne contaminants. We request that sample wells be used for monitoring groundwater. Contaminated leachate must never be discharged into our local creeks and rivers, and we request monthly testing of nearby creeks and ponds for contamination.

Third Party Testing: Considering the high value of neighborhood livability, private property, public health, and the natural environment, it is imperative that all testing and monitoring be performed with the highest level of veracity and accountability. Self regulation is not feasible when it creates a conflict of interest, therefore, we are demanding that all environmental testing and monitoring be performed by an impartial third party.

Transparency: We request that citizen representatives be included in any and all meetings between DEQ and Grimm’s. We request that no last-minute changes be made to the proposed DEQ permit without informing the citizen representatives as to the substance of such changes prior to issuance.

Indoor Composting: In order to protect the health, safety, and property of the people who live and work near the facility, and considering the adverse conditions that we have lived under for the past many years, plus the fact that we are being asked to endure even more dust and odor conditions going forward, we respectfully request that the parties take a serious look at indoor composting. We seek a long-term solution, and we believe that indoor composting is the only solution that can meet the needs of all stakeholders.

February 25, 2019