Status of Metro License

After granting our request for a 60-day extension, Metro issued their solid waste facility license for Grimm's Fuel on February 26, 2019. This new license does not meet the needs of the community.

Response to Metro Proposed License

• We do not support Metro issuing this license as written.
• We have concerns that are not addressed in this license.
• The license lacks adequate protections for public health, air quality, stormwater, and groundwater.
• The license is too permissive of contaminated leachate, air pollution, and odor emissions.

The proposed license does not adequately address the following concerns:

• Public Health, Human Health Risks, Public Safety
• Leachate Contamination of Stormwater and Groundwater
• Air Pollution and Air Quality Monitoring
• Particulates, Bioaerosols, Odorous Compounds
• Gasses, Air Emissions, VOC’s
• Air Quality and Environmental Damage

At an absolute minimum, the license should include all of the performance goals stipulated in Chapter 5 of the Metro Code section 5.01.090(c) specifically (1) Environment (2) Health and Safety and (3) Nuisances. We are unable to find any reference to “groundwater” or “public health” in the proposed license, and we believe that this license is not in compliance with Metro Code. We ask that Metro not issue the license as currently written.

Additional input or specific license changes to suggest:

We appreciate the efforts that Metro has made to improve operations at Grimm’s Fuel, however, there are a number of areas where the proposed license should be improved:

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

Public Health: We have serious concerns over the potential health impacts from living downwind from this composting operation, and we request a better understanding of all the airborne emissions from the facility. We request that a 24/7 automated air quality monitoring station be setup. We have a right to know what is in the air that we are breathing. We believe that both the regulator and the operator have a moral and ethical responsibility to the community to make sure that the air around the facility is safe to breathe. We live here.

Pile Size: In consideration of the fact that Metro does not have the authority to enforce the fire code, we ask Metro to include a maximum length and width in their pile size limit.

License Term: Although the transition to ASP composting may take 18 months, the proposed license term is 5 years. Unless Metro is willing to shorten the term of the license to match the length of the transition period, we request that Metro put a condition into the license that will require an impact study to be performed after the facility has completed the transition to ASP composting.

Offsite Dust: The dust protections in the proposed license are inadequate. We request that the license require the installation of dust monitoring and sampling equipment in the surrounding neighborhoods and properties.

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

Verification: We request that the license describe the process that Metro will use to double check and confirm the veracity of all measurements taken by the operator. Self regulation is not a feasible solution when it creates a conflict of interest.

Groundwater: We demand strong protections for groundwater and stormwater. Contaminated leachate must never be discharged into our local creeks and rivers.

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

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.

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

February 1, 2019