The Planning Commission will hold a public hearing on the Environmental Impact Report for Cold Creek Compost Inc. (CCCI) on April 2, 1998, at 9:00AM. Written comments should be submitted by April 1, 1998. There are serious concerns about the process and scope of this EIR. Environmental Science Associates, (ESA) went to Masonite's environmental engineer, Bob Scaglione, to find out what is in the wood ash Masonite sends to CCCI, without questioning his assertion that Masonite hasn't burned fuel oil #6 in their #4 boiler for several years. Dust from the manufacturing processes, containing 1% phenol formaldehyde resin, also burns in boiler #4. IP/Masonite says the kinds of fuels they burn for co-generation are proprietary information. We're supposed to have faith that Masonite will inform us when they use using other fuels, requiring additional tests of the scrubber ash. We are expected to accept annual tests of ash samples taken by the fox guarding the hen house. We oppose the disposal/recycling of Masonite ash at the CCCI facility and are concerned about the accumulation of heavy metals on farm lands. Once in the soil, this stuff affects all forms of life.
The EIR identifies a storage area in addition to the already permitted 10 acres. That area is for storage of discounted bulk-purchased materials. CCCI can receive up to 10,000 tons per year (TPY) of additives and amendments. Fly ash is considered an amendment. Masonite sends about 6000 tpy of ash to CCCI, paying a tipping fee. During a 6/97 site visit, the main pad appeared quite full of many poorly tarped ash piles; this added area would allow for more ash. The Draft EIR did not address storage of more than10,000 tpy on site if one year's materials are held over to the next. There should be a ban on more than10,000 tons of material on site at any time.
CCCI proposes to use sewage sludge - "biosolids" - for feedstock for the project. We oppose the use of biosolids at this facility. The EIR doesn't describe the volume or source of those biosolids. Biosolids contain a range of organic and inorganic pollutants including pathogens, heavy metals, pesticides, radioactivity and whatever shows up in drains or sewers. A mitigation measure for this project limits radioactivity to no more than1 picocurie per gram. Why should we allow radioactivity into a clean area?
Proper composting reduces biosolid pathogens substantially. but it does not remove heavy metals and radioactivity. Until the 1980s, when the government noted a cumulative adverse impact on the ocean environment, ocean dumping was the method for disposing of sewage sludge. Does not the same material have a cumulative effect on farm lands?
A November 1997 Storm Water Pollution Prevention Plan (SWPPP) is a true piece of compost. It allows for storage of additives and amendments (IP/Masonite ash) outside of the roofed area under tarps. New wording calls for winter operations under the roofed area during "periods of wet weather" instead of from "October to May". The operator can change the SWPPP if he deems there to be more economical Best Management Practices (BMP). The facility operator decides if the SWPPP can change. The facility manager sees to all required on site-testing and monitoring and deal with all regulatory agencies. Again, the fox watching the henhouse.
As stated in our DEIR comments, "Given CCCI's history of violations and their management style, we are skeptical about the firm's environmental soundness and safety. Even if the recommended mitigations were adequate (they aren't), we have little trust that CCCI would adhere to them (or any others) without close monitoring and strict enforcement." Given this project's history, with wrist-slaps for a myriad of past violations, can we expect them to do other than pursue convenience and profit, concerned with regulations only when they get caught? This project needs closer scrutiny of its environmental and social impacts than it has so far received. Environmental protection from this project is only possible with an effective, rigid monitoring and enforcement system.
Correction: In the last issue I wrongly stated that Calcium Carbonate produces acetylene gas. It is Calcium Carbide that produces this gas. Sorry. V.O.
Copyright Mendocino Environmental Center 1998
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