HomeMy WebLinkAboutAGENDA REPORT 1994 0921 CC REG ITEM 11ETO:
FROM:
DATE:
SUBJECT:
AGENDA REPORT
CITY OF MOORPARK
Honorable City Council
)ORPA?K. CAL =C7?', "A
C.,y Ccunpll ME 0 t,n3
ot�� -199_
ACTION:_
By
Mary R. Lindley, Assistant to the City Manager��� 1
September 14, 1994 (CC meeting of September 21)
Worm Concern of American Inc. CUP Appeal
On August 3, 1994, the City Council directed staff to agendize the
Worm Concern's CUP appeal before the appeal's hearing date. The
appeal is scheduled to be heard by the County Environmental Report
Review Committee on September 28. If the City Council desires to
direct staff to comment on the project, the September 21 City
Council meeting would be the appropriate time to do so.
The Worm Concern is located at 1450 Tierra Rejada Road in a County
unincorporated area (the mailing address is Simi Valley) . The Worm
Concern is a vermiculture business which means that it processes
yard and wood waste with the use of earthworms. The product is
used as a soil amendment by landscapers and plant nurseries. The
cities of Simi Valley and Thousand Oaks transport their yard waste
to the Worm Concern facility. Landscapers from Moorpark and the
surrounding area also use the facility -to dispose of yard waste.
The County and the Worm Concern have spent the last two years
negotiating conditions for the vermiculture operations. Upon
conclusion, the Worm Concern submitted a revised CUP application
which includes the selling of fire wood (an original application
was submitted last year). The CUP application was distributed to
the surrounding jurisdictions for comment (see attachment "A").
Attachment "B" and "C" are comments provided by City staff for both
the original and revised Worm Concern CUP applications.
City staff raised concerns about the
could have been mitigated without an
(EIR). However, the County chose to
Worm Concerns owner, Mr. Morhar,
decision.
Recommendation
Direct staff as deemed appropriate.
project which it believed
Environmental Impact Review
rE!quire a project EIR. The
is appealing the County's
June 15, 1994
To County of Ventura Planning Department, Attention: Lynne Kada
From The Worm Concern of America, Inc. (TWC)
Subject: CUP Application
H i-LL' tv► 1'-V <<
The appended description of TWC's Integrated Organic Materials Recycling Facility and Worm
Farm near Simi Valley, including related environmental controls, is formulated for the purpose of
identifying those issues connected to obtaining a CUP under the County of Ventura Zoning Code,
and meeting requirements for a permit under the California Integrated Waste Management Board
regulations.
Information herein presented describes the intended purpose, operations, and facilities of the project
and delineates its present status. It also describes the environmental controls which shall be used to
mitigate any potential environmental concerns.
A professionally engineered plot plan is provided, which illustrates;
♦ location and space allocations for all operating activities, support functions,
roads, structures, trees, signs, and fences.
♦ both present and future uses
♦ grading contours which shall be accomplished in 1994 in order to satisfy
interconnected requirements for streambed alteration, drainage and water quality
control.
Additionally, the following appendices are attached:
Appendix A - Background of the Company and Current Site Use
Description of Vermiculture Technology, and
Environmental Justification for the Project
Appendix B - Gorian Geo- Technic Engineering Study
Appendix C - Fugro- McClelland Biologic Study -
Appendix D - Referenced Aspergillus and Yard Materials Composting Studies
and Utilization of Compost in Wetlands Restoration
Sincerely,
Richard Morhar, President
The Worm Concern of America, Inc.
1450 Tierra Rejada Road, Simi Vallev, California 93063.800- 854 - 1244.805 -520 -1150
I. PROJECT DESCRIPTION
The Worm Concern of America, Inc. (TWC) presently operates an Integrated Organic Materials
Recycling Facility and Worm Farm in an agricultural zone near Simi Valley. where it receives and
prepares organic feedstock for consumption and conversion by worms into worm castings and other
worm related soil products. At-the present time 85% of total feedstock received by the facility
consists of green materials for which a fee is charged. Most of the remainder of incoming material
is livestock manure for which no fee is charged.
TWC presently receives most of the green feedstock for its recycling facility from east Ventura
County, including ongoing source separated curbside programs in the city of Simi Valley and the
unincorporated area of Ventura County. Some material is also received from west Los Angeles
County areas. TWC presently accepts up to 100 tons per day of such feedstock and proposes to
accept up to 350 tons per day as curbside programs in Thousand Oaks, Moorpark and other
unincorporated areas of the County are implemented.
Organic materials are brought to the recycling facility by haulers, landscapers and homeowners.
Hours of operation are 7:30 -5, M -F and 8:30 -5 on Saturday. The facility is closed on Sundays.
The site is located 1.3 miles east ofHwy 23 on the south side of Tierra Rejada Road in Simi Valley,
California in an agricultural, open space zone. Adjacent development consists of horse stable
properties to the north and southwest and subdivided 10 acre ranch sites to the west. Land to the
south and east is fallow. Of the three nearest residences, the closest is over 1000 feet from the site's
recycling operations. Location of the facility was carefully screened for easy accessibility of haulers
away from residential areas to avoid urban conflicts and minimize hauling trip mileage. It is accessed
from Route 23 and Highway 118 and is appproximately 3 miles from the Simi Landfill.
There are presently 10 employees.
The facility will eventually consist of an area to stockpile feedstocks, a grinding pad for receiving and
grinding green material, a pretreatment process area, a screening area for separating and blending
materials, worm beds and windrows, a worm/worm castings harvesting and packaging area, a finished
materials inventory area, vehicle access roads, truck weighing facility, truck loading area, offices and
parking, equipment/parts storage, and a protected wetlands area. Additional facilities will include
a water tank and well.
The site encompasses 24 acres. Space allocation by use is as follows:
Present Future
♦ unprocessed feedstock storage 3 1
♦ grindingtreceiving area l 2
♦ pretreatment process area 1 1 1/2
2
♦ screening/blending area
1/2
1/2
♦ designated loading area
1/4
1/4
♦ worm beds
3
9
♦ worm/worms castings harvesting
1/4
1/4
♦ packaging
1/4
1/4
♦ finished materials inventory
2
3
♦ roads,
11/4
1 1/4
♦ structures and parking
1/4
1/4
♦ equipment storage
1/4
1/4
♦ wetlands
4 1/2
41/2
17 1/2
24
It should be noted that space allocations and/or locations for grinding, screening, loading, etc. should
not be considered binding or permanent but rather flexible and subject to change as operating needs
dilate. The grinderand screen as well as loaders, of course, are all mobile and can be easily moved
to different locations. When using company trucks for loading, for example, the trucks may be
brought to the location of the material to be loaded. Similarly, if material to be screened is distant
from the regular scrcening area, the screen may be moved to the location of the material, and at times,
incoming material may even be directed to a location where new windrows are planned. Since
material handling operations must be optimized to the greatest extent, processing equipment, on
occasion, will be moved to the material rather than the reverse.
A Few Definitions:
amendment a soil additive which stabilizes the soil, improves resistance to erosion,
increases permeability to air, aids in water retention, improves texture,
reduces surface crusting, eases cultivation or otherwise enhances
soil quality.
motherbeds a series of worm beds into which the farrns's original worms were planted,
then watered, fed, and harvested regularly to promote maximum expansion
of the worm population into worm colonies.
stabilized material organic material which has undergone active or primary composting and can
be blended or used safely as soil amendment.
windrow an elongated pile of organic material
worm castings worm manure
vernucomposting aerobic composting of organic materials prior to introducing worms.
3
vermicompost a mixture of worm castings, organic bedding material, and worms.
vermiculture the raising of earthworms and their byproducts under controlled conditions
utilizing mixtures of ground organic materials and aged livestock manure
where feedstock is introduced into existing wormbeds from static piles of
blended feedstock or worms are introduced into static windrows that have
been well watered.
Green Material Operations:
Green material presently received on the site consists of yard and tree trimmings, grass and weed
clippings, and leaves. It is brought to the facility by landscapers, homeowners, and haulers - and
includes green material collected by Conejo Enterprises, Inc. and Anderson Disposal Service, Inc. in
connection with the City of Simi Valley source separated curbside greenwaste pickup program and
material from the incorporated east Santa Rosa valley area of Ventura County collected by Rubbish
Control Co..
Upon arrival trucks are presently categorized, inspected and priced. Loads containing contaminated
material are refused. Trucks bearing acceptable loads are then directed to the current unloading site
and the load dumped and reinspected by a load inspector. Arry contaminated material identified after
the "omer leaves is placed in a roll-off box for removal from the site. Records are maintained for
all incoming loads. In the May operating period, for example, a total of 710 loads or 2490 tons
were received.
When the present unground backlog is eliminated (August/September, 1994) and the asphalt grinding
pad installed, most incoming loads will be placed directly on the grinding pad for immediate
inspection and processing. The grinding pad will thus facilitate the inspection procedure and also
serve to reduce the amount of dust which may be present. At that time, the space allocated for
unground feedstock backlog will be reduced from 3 acres to approximately 1 acre.
Presently, the facility does not have a scale so with the exception of curbside loads weighed off site,
pricing is based on truck size. When a weighing scale is installed, all trucks shall be weighed on site
and priced according to tonnage.
The grinding process. For green material to be used as worm food, it must be size reduced by
grinding into small bits and pieces. In the past TWC has relied upon contract grinders to process large
amounts of bulk material. However, this practice was recently changed when it was determined that
infrequent grinding of large amounts of material was both too costly and inefficient. Accordingly,
TWC recently purchased a #2500 Willibald grinder which will grind a minimum of 35 tonslhour or
over 200 tons per 6 hour grinding day (allowing 1 -2 hours/day for maintenance) and enable the
recycling facility to maintain a processing rate that will not only prevent accumulation of backlog
but allow for increased tonnage of material to be processed.
4
The grinder commenced operation in May, 1994 and is expected to complete processing the present
unground backlog (plus material received in the.interim period) by late August or early September,
1994. When the backlog is eliminated, the space allocated for feedstock storage vall be reduced by
approximately two acres which will then be allocated to worm farm operations. Grinding operations
will subsequently vary with the intake of green material. Full operation will again be needed when
material intake reaches 200 tons per day. When material inflow exceeds this amount, TWC will
acquire additional grinding capacity.
The screening process. The grinder is capable of feeding the ground material into windrows, piles,
or through a conveyor system directly into a trommel screen for separation of material into "fines"
and "overs." A trommel screen is a cylindrical screen of varying length, diameter, and screen sizes
which receives ground material at one end as it rotates and discharges "fines" through the screen
perforations and "overs" at the end of the screen. The ratio of "fines" to "ovens" may be adjusted by
changing the angle of screen slope or its rotational speed. (Reducing rotational speed increases the
percentage of "fines ", for example, but may slow the rate of throughput below the rate of material
inflow from the grinder) The trommel screen being purchased by TWC is a #512 Power Screen,
12'x 5', with a 48hp engine. Throughput is estimated to be 80 yards an hour or about 500 yards per
6 1/2 hour day.
Whether the grinder and screen will be operated in tandem or independently will depend normally on
location of the material to be processed and process inventory requirements. Since this recycling
facflity is not concerned with producing "overs" for the fuel market (electric power cogeneration),
it is not necessary to screen material as soon as it is ground. Some drying of material in the
pretreatment phase prior to screening will improve the percentage of "fines" for wormbeds.
Material handling of both unground and ground feedstocks is accomplished by loaders. The grinding
and screening operation requires use of two loaders, each needing an operator. One additional
individual to check incoming loads and make adjustments to the grinder or screen as necessary is also
required. (total of three persons)
Dependent on moisture content of material and presence of any dirt contamination, material will be
watered during the grinding and/or screening process.
Other Materials:
In addition to the use of processed green materials as feedstock for its wormbeds, TWC also utilizes
horse manure as an additive. This is a resource enhancement material and not considered waste.
TWC receives no fee for the material , most of which is brought to the site by homeowners and
haulers - including City of Los Angeles trucks. While in an average month receipt of horse manure
will amount to about 15% of total material inflow, in May, 1994 the volume of manure amounted
to some 560 tons (1680 cu. yards) including an additional 240 yards picked up by TWC trucks from
Fox Hills Stables in Thousand Oaks. This equated with approximately 19% of total material received.
TWC also purchases approximately 300 yard of Malibu Lake topsoil each month.
All of this incoming material receives the same inspection as each load of green material. Loads
containing trash or any identified contaminants. are refused, etc. Loads are dumped in piles in the
manure receiving/processing area where it is normally watered and turned by loader for several
weeks, after which it is blended with ground organic material for application as feedstock. Also, aged
manure may be blended with other finished products, including topsoil for specific grower
applications. Topsoil -which is normally purchased by TWC from Malibu Lake - amounts to an
average of 300 yards per month.
Vermiculture Operations: (Presently used)
Current methodology utilizes a vermiculture process in which ground materials and aged manure are
stored in static inventory piles, or placed in new wormbed windrows into which new wormbeds are
transplanted. Material from static piles is moved by loader as needed to feed existing wormbeds. In
either case the piles or windrows are watered by irrigation system and/or water truck to maintain a
high moisture content.
The first worm colonies on the site were planted in We 1992 upon completion of an irrigation system
and installation of a four inch water line from the meter at the Tierra Rejada Road Simi Valley water
main. At that time a series of 20 "Mother Beds" were planted over an acre of irrigated land.,
Worms were then transplanted into these beds which were kept well watered and supplied with
appropriate feedstock. Subsequently, the beds were harvested regularly to encourage expansion of
the worm population and provide additional worms for sale and for transplanting to new beds. An
explanation of TWC's plans to achieve production level output of worms and worm castings along
with a description of vermicuhure activity is detailed in Appendix A. It is sufficient here to point out
that given an appropriate environment (moisture, temperature, and feedstock), a worm population
will double every six to eight weeks. Worms consume their weight in food every day and also utilize
an additional amount of organic matter for bedding. For the acreage anticipated to be utilized for
worm beds, TWC estimates that ideally some 200 to 250 tons per day of processed organic matter
could be utilized to maintain its projected worm population of 150 - 200 tons. (the present worm
population is probably less than 30 tons) Accordingly TWC anticipates that at least 50% of the
useable site area will be covered with worm beds.
Feeding of "mother beds" is accomplished by using a manure spreader to spread "fines" material at
least two to three times a month. All beds are watered on a regularbasis. New beds are created
continually and worms from mother beds are transferred when the beds are wet enough.
TWC's harvesting and packaging facility is located at the westernmost location of the "mother beds"
area. Each of the "mother beds" is harvested at least monthly at which time the collected material is
fed into the harvester which separates worms, worm castings, and bedding. The bedding is then
returned to the beds along with additional food supply. As noted, the larger windrows are also fed
and harvested on a regular basis.
0
The current packaging unit is claimed to produce 500 bags per day (1 1/2 cu ft) and will be
operational upon completion of its concrete pad (10' x 10' ). This activity is assumed to be a part of
this CUP application. ,
While much of the farm's space allocation and activity to date appears to center around the receiving
and grinding/screening of material, this will change as the worm population continues to expand.
Gradually, the site will contain more and more worm beds and the amount of unprocessed material
relative to the total will be substantially diminished. (See space allocation by use table, pp 2 & 3)
Proposed Vermicomposting Operations
Ground material willl be blended with manure and placed in specially configured windrows which are
checked for moisture content to evaluate the quantity of water required to achieve a high moisture
level. Desired moisture levels will be maintained by the application of water from TWC's water
truck To provide for increased water supply TWC proposes to put in a well and install a water tank
and/or install another water meter on the City of Simi Valley water main.
Windrow turning will be accomplished by TWC's loaders. The frequency of turning is determined
by daily monitoring of internal windrow temperatures. which will be maintained between 131 degrees
and 149 degrees F for fifteen consecutive days to insure pathogen destruction and kill weed seeds.
When solids decompose and the volume of windrows shrink, two or more windrows will be
combined into one larger windrow to maintain a cross section and favorable volume -to- surface area
ratio essential for optimum pathogen destruction. After approximately nine weeks (60-63 days) the
composting process nears completion and the material enters its curing stage. This can occur while
the material is in windrows or in a curing/stabilization pile in the stabilized materials inventory area.
The finished compost can then be loaded onto trucks for transport to end users, blended with other
materials to achieve specific soil amendment mixtures and proportions, or converted into
wormcastings in the wormbeds.
As already noted the vermicomposting process described above is not presently utilized by TWC.
Other Operations:
TWC maintains a yard area of approximately 2 1/2 acres for product blending and finished product
storage. In the production of various soil products, other materials - including horse manure and top
soil - are blended with worm colonies and/or castings to achieve desired mixtures of material for
specific horticultural or agricultural purposes. These materials are then stored and shipped in bulk
by truck to customers who range from organic farmers and ranchers and municipal park and
recreation departments to back yard gardeners.
7
There are several functions which are common to the operations previously described. They are:
• Loading & Shipping
• Equipment Maintenance & Storage
• Administration & Sales
Loading /shipping of harvested materials. The farm currently has two trucks of its own for
delivery purposes, a 20 yard truck and a small 5 yard truck. Since bulk prices include free delivery
within a 10 mile radius, most sales of bulk materials are delivered by TWC trucks which make four
to five round trips per day during the growing season (April - June) in the local area. A
transportation surcharge is levied on shipments beyond the 10 mile radius. Deliveries are mainly to
landscaper project sites, residences, golf courses, farms or orchards. For occasional very large
outgoing orders (500 to 1000 yards), the farm utilizes the services of contract haulers. Average daily
total shipments at the present time (June, 1994) by TWC trucks are in the 100 yard range.
Additionally, an average of 5 - 10 private vehicles (pickups) come to the farm for material - usually
1 to 1 1/2 yards per Joad. This would account for another 8 to 15 yards per day.
It is anticipated that when development of the facility is completed and product testing in local
farming applications proves successful, the volume of bulk shipments will increase to the 200 -250
yard per day range.
Loading of outside trucks is accomplished by the farm's loaders in a designated loading area adjacent
to the bulk storage yard. Loading of farm trucks may take place here as well and also at other
locations on site where material may be stored. (See discussion on page 3)
Equipment maintenance and storage. The farm's equipment when not in use is presently stored
in an area adjacent to the bulk storage yard. Fuel and other products needed for operation and
maintenance are brought in by outside vendors. Daily maintenance is accomplished on site by the
farm's maintenance contractor. Spare parts are housed in the storage trailer.
Security of equipment is accomplished by a locked entrance gate and perimeter fencing. Lighting will
be available for the equipment yard and offices.
A current listing of farm equipment and facilities is as follows:
1. 20 yard diesel truck
2. 5 yard gasoline truck
3. 2500 gallon water truck
4. material spreader
5. 2 diesel skip loaders (3/4 yard)
6. 3 yard diesel loader (leased)
7. 4 1/4 yard diesel loader
8 4 yard diesel loader (leased until July).
8
9 electric worm harvester
10. electric bagging machine (not presently in use)
11. storage trailer
12. office trailer
13. #2500 Willibald Grinder (diesel)
14. stationary topsoil screen
15 #510 diesel Power screen (being purchased)
Planned equipment acquisitions and facilities improvements include (a) a grinding pad to ensure
operational continuity in inclement weather, facilitate inspection of incoming loads, and minimize
dust, (b) a scale for weighing loads, (c) a small pad for installing the bagging machine, (d) a water
tank, and (e) a well.
Administration. Two office trailers, one storage trailer, a small scale house trailer and a small
employee lounge trailer are planned . At the present time the farm utilizes a small trailer on the
property for its general administrative and sales activities. (to be replaced with a permitted structure)
and an equipment partstsupplies storage trailer.
Bulk product sales are made by mail, by telephone, or less frequently at the site to customers who
may come in with their own trucks. In addition to bulk sales, the farm sells and ships worms, worm
boxes (worm houses) and castings as well as books about vermiculture throughout the U. S.; and,
in Southern California, worm boxes complete with bedding and worms are sold to municipalities for
backyard recycling programs and to schools for recycling grass clippings and food. Presently, the
farm's marketing program is focusing on development of packaged castings and worm rich soil
products. This effort has a goal of limited product introduction this fall (for market testing) and a
production scale effort in time for the Spring, 1995 market (January- February, 1995 delivery)
Worm boxes and books are purchased by TWC for resale. Inventory of this merchandise is limited
at the present time and is stored in the Office and Storage trailers.
IIL ENVIRONMENTAL CONTROLS
While the latest draft of California Integrated Waste Management Board Regulations fail to mention
either vermicomposting or vermiculture, nevertheless, in their present form, the regulations suggest
that based on LEA decision "vermicomposting" facilities may be granted an exemption from
composting regulations but that they will be expected to conform to requirements of three sections
of the Title 14 Code. They are Sections 17875, 17885 and 17887.
Accordingly, in the following portion of this document, we cite these requirements, our evaluation
of their significance to the project and the means to be utilized for controlling any potential negative
effect.
0
Section 17875 of the California Integrated Waste Management Board Regulations specifies a
number of potential health, safety and nuisance hazards which must be controlled or mitigated, as well
as a number of conditions which could give rise to such hazards. These include: ,
Vector infestations, e.g. rodents, birds, insects etc.
While there is some potential for vectors when a large accumulation of unground material is present,
timely grinding of incoming material virtually eliminates their presence. In the past reliance on
contract grinders has resulted in higher than normal accumulation of unprocessed material. Despite
this condition, with the exception of flies on a seasonal basis the presence of vectors has not been
noticeable. Now, that TWC has substantial grinding capability under its direct control, there will be
no accumulation of unprocessed material once the present backlog is eliminated in the August -
September period (1994).
Additionally, baited mouse traps are used and monitored and fly traps and parasites are utilized on
a seasonal basis. No significant presence of birds on the site has been observed.
2. Aesthetic degradation
Any aesthetic degradation which may have existed at the site in the past has been due solely to its
start-up condition and the presence on two occasions of large piles of ground material. In each of
these cases the piles were effectively reduced or eliminated within 30 days.
Now that development is nearly complete, including the planting of more than 500 trees, the site is
on a steady improvement trend in its aesthetics. TWC plans to make the site a "model" facility
(See Appendix A re Company Vision) and this will become increasingly apparent within the next
eighteen months..
3. Aspergillus fiunigatus and flavus
Aspergillus fumigatus is a very common fungus often present with organic materials. Despite the
potential pathogenicity of the fimgus, there is no evidence available to suggest that it poseg a practical
health hazard to the general public. Nor is there currently available any evidence to imply that a
composting operation would threaten the physical well-being of a healthy individual. See Aspergillus
Fumigatus Problem by William Oliver P27 -31, Compost Science & Ut li ation Vol 2 No. 1 Winter
1994. Research suggested that mowing the lawn may represent the largest and most common source
of exposure of this fungus for inhabitants of residential areas. Commercial potting soils, wood chips,
natural and culturated soils all contain high levels of this fungi. Studies by Clark (1984) also showed
no trend to infection or allergic response to workers at U.S. compost sites. Both studies refer to the
possibility of danger to severely debilitated or immuno - compromised individuals and Oliver suggests
these persons should not enter the compost site or be employed at such facilities.
In some 18 years of operation no employee of The Worm Concern has experienced any sort of
infection as a consequence of his exposure to aspergillus or any other potential infection source.
10
Medical histories and the physical condition of any potential new hire will be evaluated as a matter
of standard procedure to prevent employment of individuals with a debilitated health condition.
See appended study entitled "Public Health Issues and Composting" by Eliot Epstein and Jonathan
I. Epstein, and "The Aspergillus Fumigatus Prohlem" by William M. Oliver, Jr.
4. Odors
There is a potential for odors if piles of material are allowed to become too high (above 15 feet) and
anaerobic conditions develop, or if grass is not mixed with other materials and becomes odoriferous.
Both of these conditions are prevented through appropriate material management. In November
1992, when a grinding contractor failed to remove the material he had contracted to grind and
remove, piles of ground material grew too high and became anaerobic before farm management
could obtain legal possession of the material and move it. As a result, odors developed temporarily.
Since that time TWC,has applied a number of mitigating measures beginning with an improvement
in material management practices. In 1993, despite the fact that operations were expanded and the
use of contract grinders was continued, there was no repetition of the odor problem simply because
improved material management practices had been defined and implemented. Since that time TWC
has (a) purchased its own grinder so that it is no longer dependent on outside grinding contractors,
and (b) acquired two more loaders. With this added equipment TWC operating management has
substantially improved its ability to exercise effective operating control.
Noise
Noise is generated by some 50 trucks and private vehicles entering and exiting the property each
week day and by operation of farm equipment. Both noise source types are intermittent and at a
considerable distance from the residence of the nearest farm neighbor to the southwest - at least 1,000
feet. Further, the amount of noise produced by project trucks and equipment is but a small fraction
of that produced by vehicular activity on Tierra Rejada Road,
Before Highway 23 was connected to the 118 Freeway in October 1993, traffic on Tierra Rejada
Road was more than 26,000 vehicles per day. After this connection was made, traffic was reduced
to 13,250 vehicles per day (traffic data courtesy of Bill Golubics, City of Simi Valley Traffic
Engineer)
The prevailing wind direction at the site is from the southwest and will tend to reduce noise levels in
the direction of the nearest residence which is located in a southwest direction from the site's
recycling operations. The largest diesel trucks which come to the site (about 7 -8 per day M -F) have
200 -250 hp engines that are approximately equivalent in horsepower to that of the Willibald Grinder
(250 hp) which is the largest unit of operating equipment. The engine is equipped with a standard
muffler. According to Fecon Manufacturing Company the Willibald grinder produces a noise range
as follows: 53 decibels at the equipment when idling, and total noise of 81 decibels at a distance of
50 feet, 72 db at 100 feet, 64 db at 200 feet and 57 db at 300 feet. The other large units of operating
equipment are two loaders which also are rated .at 250 hp. According to Case Equipment Co. these
loaders produce 80.5 and 81.2 decibels each at the equipment with a higher decibel reading in the cab
(84.5)
Transmission of noise may be influenced by presence of windrows, berms, rolling terrain, wind, etc.
Based on the above data and recognizing the nature of the terrain, existence of windrows and a
distance of more than 1000 feet to the nearest farm residence from the operations of this equipment
as well as the fact that prevailing winds will be in the direction away from this neighbor, it would
appear that noise from fadhty sources will be heard at non - intrusive levels by farm neighbors and will
not be significant.
Of more significance would be the impact of noise levels on equipment operators and helpers. It has
been observed that when a ten foot high windrow of ground up material is positioned as a barrier
between the observer and grinding operations. the noise can scarcely be heard on the other side.
The existence of these windrows will serve to protect all but the most exposed employees, those who
are operating the equipment. Here it should be noted that farm equipment operators and helpers are
exposed to noise levels that are less intense than those found in the vicinity of many other commercial
operations, such as machinery operation within enclosed buildings or in construction. Accordingly,
no special noise protective gear is anticipated in order to meet Cal OSHA requirements.
6. Dust
There is a potential for dust generation from grinding or screening operations where material has been
mixed with dirt or has dried significantly before grinding; from operation of loading equipment; and
from truck and passenger vehicle traffic on farm roads.
♦ It should be recognized that prevailing winds are from the southwest, the same direction as
the farm's nearest neighbors on adjacent or nearby parcels. Accordingly, the normal
movement of any airborne substance from the project would be to the northeast - where there
are presently 40 acre parcels of fallow land. The only times when airborne substances could
affect neighbors would be during Santa Ana wind conditions.
♦ All of the above potential causes of dust are intermittent in nature. Traffic on ingress roads
may amount to 50 vehicles per day Monday through Friday, but this is reduced to 10 to 20
on Saturday and the site is closed on Sundays. Also, operation of farm equipment is
intermittent. The farm's loaders are used five to six hours per day, and while grinding and/or
screening activities are also presently operative for five to six hours per week day, this activity
will slack off somewhat in August or September when the present unprocessed backlog is
completed. In fact, one of TWC's large loaders which is leased will be returned next month.
♦ When dirt contaminated yard trimmings are no longer present, the issue of dust from the
grinding operation will cease to be a problem. This margin of safety will be further reinforced
12
with the addition of a planned asphalt grinding pad which will prevent mixing of site dirt with
incoming materials (by the loaders) and also assist in incoming load inspection.
♦ Additionally, when the present backlog has been processed and the facility is able to process
material as it comes in, the material will be green and have a higher moisture content with
reduced potential for dust. Dust potential is increased when material has dried significantly.
♦ In fact, the processing of green materials and the high moisture content maintained in material
processing will virtually exclude dust from processing sources.
♦ Fugitive dust from other potential sources such as roads and loading areas have been
substantially mitigated already. The main farm roadway and primary loading areas have
already been surfaced with ground asphalt and additional layers of this material are being
applied on an ongoing basis. Also, as a matter of ongoing facilities management practice,
alternative methods for improving and stabilizing road surfaces will continue to be evaluated
by TWC. .
♦ Additionally, mulch is spread over all non - asphalted areas on the site that receive
vehicle traffic.
♦ The farm has just acquired a water truck for watering roads and maintaining proper
moisture condition in the mulch - overlaid area.
♦ A watering system is being added to the grinder and the screen.
♦ Finally, if Santa Ana wind conditions are severe enough for dust to travel across the property,
all processing operations will shut down to prevent any negative impact on TWC's neighbors.
7. Litter.
It is a part of normal operating procedures for every incoming load to be inspected to identify any
unacceptable materials, including litter. When contaminants are identified the truck is not permitted
to enter the dumping area. If after dumping any litter is identified, it is immediately separated and
placed in a bin for later removal from the site.
8. Open burning.
The farm does not engage in open burning.
9. Hazardous Wastes.
No hazardous wastes are permitted in loads delivered to the site. See Project Description, Green
Material Operations (page 4), item (7) above and item (20) following, regarding control procedures.
13
Presently, diesel fuel, the only potentially hazardous material on site, is stored only in vehicles or
equipment. Fuel is provided daily by an outside service contractor. Existing County safety and
contingency plans would be adapted and made site specific to handle risks of upset and reduce
potential impact, should an accident occur.
10. Drainage and Diversion
A drainage study, the grading plan, and the leachate control and disposal are all interconnected and
will be organized to function as a unit together. Plans are based on a 25 year 24 hour rainfall of 3.5
inches and riparian corridor setbacks based on the 100 year flood line. In accordance with the
grading and drainage plans created by A.E.S. and Brian Gentry on the site survey maps, runoff will
be managed through an array of strategies. Windrows and worm beds will be arranged along
topographical fines, maintaining mulch cover on all disturbed areas. The service road will be regraded
to duplicate the 690 contour on the site survey map and tilted toward the uphill slope. This will
create a bench terrace across the wormbed site to divert the limited runoff into a mulched French
drain- biofihers which will aid in the decomposition of any leachate. Deceleration and accumulation
of runoff will be further mitigated by a swaletterrace at the 700 contour. A system of long swales
constructed along other contour lines and filled with mulch will absorb and filter any other runoff.
The use of thick (6+ ") mulch will mitigate shortcomings in soil water retention capacity. Water that
percolates through the berms will be spread over the buffer landscaped zones using selected trees and
ground covers. Steep and erosion prone areas will be re- contoured and treated with a mulch layer _
to retard the movement of water.
NOTE: A separate drainage and grading map has not been provided. Based on conversations
between Dr. Bill Roley of A.E.S. and Brian Gentry with Tun Meyers of Ventura County Public Works
Department, Mr. Meyers indicated that since grading was to be taken back to the former grade, a
separate map would not be needed.
11. Erosion and Sedimentation
Comprehensive integration of the management of the grading, drainage, landscaping and riparian
plans will prevent erosion and sedimentation Many studies have been done by the Soil Conservation
Service (USDA) and Metro, Portland, Oregon on Using Yard Debris Compost for Erosion Control.
See final report from Solid Waste Department at Metro on the successful use of these materials.
12. Leachate
Concerns have been raised about water leaving the site or infiltration impact. The possibility of
contamination is very low according to research being completed by Judy Mitchell, Escondido
Resource Conservation District, San Diego County. Michael Cole, Uni. of Illinois, Department of
Agronomy has published an article "Assessing the Impact of Composting Yard Trimmings ", in
Biocycle April 1994, (copy appended) and comes to a similar conclusion. Much of the surface water
14
found at the compost site, is not leachate but rather water that runs off the sides of the piles without
passing through the organic material. Using the earlier mentioned water harvesting techniques, as
delineated in the grading and drainage plan, runoff containment will be maximize¢. Heavy mulch
windrows arranged along the topographical contours of the site will form interceptor biofilters to
mitigate runoff and erosion and to filter any leachate while remediating turbidity and pathogens.
Cutouts will be employed in areas likely to generate runoff and filled with wood chips which will
decelerate, absorb, and filter runoff and slowly percolate water to ground covers and landscaping
buffer strips planted below the drainage swales.
13. Leachate Control and Disposal Procedures
♦ Ground material has been placed on the soil surface to absorb any potential runoff
♦ Bench terraces/contours will be developed on the landscape which will be used to
direct the flow of water across the slope of the site so as to retard runoff into the
stream course and provide biofiltration.
♦ The exit vehicle road will be filled and cut to a consistent contour to retain any
overland flow and move the water away from the streambed. A french drain on the
inside of this road will be constructed to further channel, absorb and biologically treat
the runoff on site. _
♦ The only areas that will be covered in impervious materials are the access road and
asphaltic covered pad that will be able to receive green wastes during inclement
weather. These areas will not result in a significant increase in runoff from the 24 acre
site.
Refer to Applied Ecological Systems (A.E.S.) plans regarding water quality, drainage, and grading,
as illustrated in Brian Gentry plot plan.
Filtration through contoured swales and the interaction with the biological active soil -rdot zone of
the landscape buffer strip will mitigate to target standards worked out with EHD. Groundwater
separation on siteis fair, at c 84-94 feet at the 700 foot topo line of County well 12M3, located near
the western boundary of the parcel (Quadrant] 2), and groundwater protection is enhanced by the
overlying poorly permeable soils and geologic formations on the site.
Refer to (10), (11), and (12 above. Drainage, leachate, water quality and wetlands solution issues
are interrelated. See Calif. Dept of Fish & Game Streambed Agreement, Gorian Geotechnic
Engineering Evaluation, and A.E.S. grading plans as illustrated in Brian Gentry plot plan.
15
13. Non- compostable wastes.
See responses to (7) and (9) regarding control procedures. Also see Project Descriplion - Inspection
14. Ponding
No ponding will take place on site. A seasonal pond is expected to develop at the site of the breached
dam as a result of the two -foot berm that will be placed in the breach of the former 100 year old
earthen dam that created the former stock pond. This breach berm will be armored with Reno
mattresses for erosion protection after restoration of the streambed to the contours that existed at the
time of the breach and after the breach has been re- contoured, in accordance with the State Fish &
Game streambed agreement. Sensitive areas of the pond will be planted with Arroyo willow and the
existing cottonwoods will be protected. The pond perimeter and hundred year flood line will be
protected from runoff and leachate by adjacent upland landscaped buffer strips.
15. Roadway.
TWC is not aware of any problems with roadway design or with maintenance based on procedures
as outlined in (6) above re: road improvements.
16. Storage Capacity, windrow heights. - design of.
As previously outlined, the presence of the new Willibald grinder is enabling TWC to process the
present backlog of unground material on site. Once this backlog has been ground, TWC will be able
to grind incoming material on a current basis, which will of course substantially reduce the amount
of material to be stored. Accordingly, storage of unground material should be limited to a 30 day
supply which at current levels would amount to approximately 2500 tons. This amount would be
increased as the level of incoming green materials was increased.
Currently with proper material management policies in place including availability of sufficient
materials handling equipment (loaders), all ground mataial is being handled in a safe manner and this
condition will continue. Windrows are not allowed to exceed 10 feet in height and 10 -12 feet in
width while wormbeds are presently capped at 4 feet in height and 6 feet in width.
Section 17885 of the California Integrated Waste Management Board regulations also specifies two
concerns that deal with potential health and safety hazards:
17. End product safety concerns, non - innocuous or sharp edges.
End products are subject to process screening and additional inspection which assures elimination of
foreign materials, including any sharp objects.
16
18. End product quality standards per Title 22 CCR and Title 40 Code of Federal Regulations.
TWC is not presently aware of any deficiencies in quality standards, including pathogens. TWC will
review all appropriate regulations regarding product quality standards and initiate testing procedures
to assure continuing adherence. Since the farm is intended to be a "model" facility, fully documented
quality assurance procedures are necessary to effect the level of operating control sought by
management. Hence, in this area we are open to suggestions from the County and will appreciate
whatever assistance can be provided to help us achieve these operating and process control goals.
Section 17887 of the California Integrated Waste Management Board regulations specifies two
additional areas of concern that deal with potential health hazards:
19. Maximum Metal Concentrations.
The farm accepts only yard and tree trimmings, including grass and leaves. While there is always a
slight possibility that someone may include foreign objects, non - compostables, hazardous materials,
or substances with heavy metal contaminants in a load of material, TWC considers this risk to be less
than significant for the following reasons:
♦ All loads are inspected at entrance and again after dumping. If contaminants are identified
at the outset the load is refused. If identified after dumping, they are separated and returned
to customer or placed in a bin for removal from the site_ A report of contamination is also
made to the hauling company so that it can take appropriate remedial actions.
♦ Most incoming material is received from regular customers, including curbside pickup haulers
and landscapers who are well trained in identifying and refusing contaminated material at the
pickup point. Normally, therefore there is a minimum amount of contaminated material which
reaches the site.
♦ There are subsequent stages of inspection during the process, i.e. grinding, screening,
harvesting, or blending, where foreign substances would be identified if they had escaped
earlier detection.
♦ If all of the above measures fail to eliminate the introduction of a contaminant, the hazard
would be significantly reduced because of its dilution through mixture in large volumes of
uncontaminated material. Here, we are referring to the possible presence of pesticides.
20. Pathogen reduction.
In earlier testing it was determined and reported to the County that the presence of pathogens was
positive though unquantified. Discussions with County personnel led to the suspicion that lack of
familiarity with testing protocol on the part of the site foreman had resulted in his contaminating the
samples which were then tested. This indeed appears to have been the case.
17
Through assistance from the County and UCLA, TWC arranged for additional tests by BioScreen
Testing Services, Inc. in Torrance, CA In this procedure, the laboratory sent a technician to secure
samples on April 12, 1994, and reported results on April 26, 1994. This report shows that salmonella
presence was <0.8 MPN /4 g in all cases, and fecal coliform results were below the 1000 MPN /g
standard for all end product sampling with one exception. A later test with Soil Control Lab in
Watsonville, Ca has also produced negative results.
TWC will appreciate the County's continued input on testing and process control methods. If testing
indicates pathogens are present, TWC is prepared to utilize vermicomposting techniques and heat
material significantly to kill pathogens.
18
0
CUP 4106 - ADDENDUM TO PROJECT DESCRIPTION
"FIREWOOD OPERATIONS"
The following information relating to Firewood Operations is submitted for inclusion in the
Project Description dated June 15, 1994. The location of this operation is shown on the attached
plot map.
"Firewood Operations. Limbs or tree rounds that are too large to be ground are segregated and
stored in the unprocessed materials area or placed in a location adjacent to the loading area -
depending on the season, the weather, and the amount of material being held in firewood
inventory. If more than 50 cords of material is available, TWC may acquire an appropriate
splitter, prepare the material for sale and sell it. It the amount of material is estimated to be less
than 50 cords, TWC will sell the material "as is" to another firewood operator. —
The maximum amount of firewood the facility expects to process is 500 cords. It will not
process stumps. ".
The appended site plan entitled "Firewood Operations and Storage" shows Area "A" - an
approximate 15'x 15' area for accumulation of limb sections and tree rounds. Then, based on
expectations of 50 or more cords, this material is moved to Area "B" - an approximate 60'x 60'
site, where material will be cut, split and stacked. If more area is needed for storage of prepared
firewood, Area "B" will be enlarged by extending it in a northerly and/or westerly direction.
The Worm Concern of America, Inc.,
July 26, 1994
MOORPARK
799 Moorpark Avenue Moorpark, California 93021
FILE COPY
`�- b
(805) 529 -6864
Lynne Kada
Resource Management Agency
Planning Division
800 South Victoria Avenue
Ventura, CA 93009
SUBJECT: REQUEST FOR PROJECT REVIEW - CUP 4816 - THE WORM CONCERN
OF AMERICA, INC.
Dear Ms. Kada:
Thank you for the opportunity to review the revised project
application. Reference is made to our prior comment letter dated
September 8, 1993. The comments made in that letter are considered
applicable to the revised project. In addition, we want to express
our opposition to the latest proposal for a firewood operation. We
object to any further commercial activity at the site.
We do not believe that the applicant's submittal dated June 15,
1994, provides sufficient controls, which would mitigate all
potential environmental concerns related to land use, traffic,
visual, air quality, and health and safety impacts. The County
should request further information, studies, or mitigation
measures, as discussed below.
An issue of concern related to land use is that the Worm Concern
operation may not be an appropriate use based on the Tierra Rejada
Greenbelt Agreement. We recognize the need for such a facility for
green waste recycling purposes; however, only a short -term approval
should be given for the CUP, and alternative site locations should
continue to be investigated.
In regard to traffic and impacts, a traffic study should be
required. Both the access road and the driveway onto Tierra Rejada
Road should be paved. Trucks laden with green waste have been
observed on several occasions parked along Tierra Rejada Road in
the morning. Any such parking of trucks along Tierra Rejada Road
should be prohibited.
PAUL W. LAWRASON JR. PATRICK HUNTER JOHN E. WOZNIAK BERNARDO M. PEREZ SCOTT MONTGOMERY
Mayor Mayor Pro Tem Concilmember Councrlmember Councdmember
Pr gyred — P*CYCNO Pdy
Lynne Rada
July 26, 1994
Page 2
In regard to visual impacts, we don't dispute the applicant's
statement that over 500 trees have been planted; however, the site
is still highly visible from Tierra Rejada Road, and is
unattractive. The appearance of the site is not consistent with
other agricultural, open space, or rural residential uses in the
Tierra Rejada Greenbelt area. Our conclusion is that the screening
efforts, to date, have not been effective. Further screening
options should be investigated, including but not limited to the
planting of larger trees, use of landscaped berms, and fencing.
Further investigation of dust control, vector infestation, Valley
Fever and Aspergillus fumigatus (fungus) potential, and other
health risks should be investigated in conjunction with the
environmental clearance process.
If you have any questions regarding our prior comments, or the
comments in this letter, please contact me.
Sincerely,
e R. Aguilera
Director of Community Development
JRA /DST
September 8, 1993
MOORPARK
799 Moorpark Avenue Moorpark, California 93021 (805) 529 -6864
County of Ventura
Resource Management Agency
Planning Division
800 South Victoria Avenue
Ventura, California 93009
Attention: Lynne Kada
SUBJECT : REVIEW OF CONDITIONAL USE PERMIT NO. 4816 (THE WORM
CONCERN)
Dear Lynne:
Thank you for allowing the City of Moorpark to review the above
captioned project. After initial review of the project, staff has
the following comments:
1. It is suggested that the project be evaluated for visual
impacts from adjacent roads and any appropriate
mitigation measures be implemented to minimize any
adverse visual impact of the project.
2. The road from Tierra Rejada Road to the site should be
asphalt to reduce air particulates from being emitted
into the atmosphere.
3. The project description indicates that approximately 20
trucks per day creating a throughput up to approximately
300 tons of material per day. It does not appear that
this includes all traffic to and from the site.
Consider having the applicant provide a traffic study to
determine the amount, type, and destination of trips to
and from the site. The study should also address any
cumulative impacts on neighboring jurisdictions and
appropriate mitigation measures.
4. The site should not accept -any other waste other than
dead plant material.
5. Plant material should not be stockpiled higher than ten
(10) feet and shall be turned over at least once a day to
prevent the release of methane.
6. Retail sales of composted materials should be prohibited.
PP09:08 :9311:11pmA :\cuP1816
PAUL W. LAWRASON JR. SCOTT MONTGOMERY
Maya Mayor Pro Tom
1
PATRICK HUNTER BERNARDO M PEREZ JOHN E WOZNIAK
Counaimomber Counaimember Counalmember
7. All machinery and equipment engines used on -site shall be
maintained in good condition and improper tune as per
manufacturers' specifications.
8. Water trucks should be used to reduce on -site dust.
9. No composting of human feces should be allowed on -site.
If you need any additional information, please give me a call at
(805) 529 -6864, ext. 243. Thanks.
Sincerely yours,
Q)
Paul Porte
Senior Planner
Attachment: Project review form for CUP 4816
CC. Jaime Aguilera, Director of Community Development
Outside Agency Review File
Chroni File
PP09:08:9314:21pmA: \CUP4816 2