HomeMy WebLinkAbout016Er La
2940 Limited Lane NW
Olympia, WA 98502
OtvEpk n gb. CL.r Air &actORCAA
October tl,20L9
Tncy Williamson
2005 NW Petercon Road
Poulsbo, WA 98370
Repraenting Cklkm, Gray Harbor, Jfferun,
Mason, Paci/ic, and Thunun Counies
I i\\
tul
lt[
1-800-422-s623 . (360) 539-7610
t'-IL
l-i G trIVE'*"1
ocT I 6 2019
SUBJECT: Odor Control Plan for CASE #: MI-A18-00102 - ORCAA Comments
DearJvG. Mlliamson:
At ycur request, I reviewed the 'Additional Information" sent to me on 70/2/2019 to ycur Odor
Control Plan (Odor Plan) for your proposed marijuana production/processingfacitty at 860 Old
Coyl. Road inJeffenon Counry(parcel #: 501105013). The additional information pu sent
addressed myprevious concems with your original Odor Plan, which were communicated in myJuly
5,2079 lecer. Your current Odor Plan incoryoftrtes what Olympic Region Clean Air Agency
(ORCAA) considers Best Available Control Technology (BACI) for controlling odors and,
provided adequatelyoperated and maintained, will eliminate nuisance odors.
My undentanding and expectations or ycur Odor Plan are as follows:
o Yourproduction of marijuana will be contained completelyindoon within the wo
proposed buildings - No outdoor producdon or processing within greenhouses or other
structures.
. The grow and production buildings are situated as far awayfrom neighbors as possible to
lessen the likelihood of odor impacts.
o All exhaust from areas vrhere odors are genented within the buildings will be controlled
using glanular activated carbon (GAg.
. Building exhaust/ventilation $6terns will be sized bya professional and certified industrial
hygienist or other qualified expen on building ventilation sFtems to:
1,. Provide adequate exhaust/ventilation at all times that maintains negative pressure
within the buildings whenever odors are genented, therebyminimizing the
likelihood for fugitive leals.
2. trzleet AITtrSI/ASHRAE ventilation standards for acceptable indoor air qualiry
(ANSI/ASHRAE Standards 62.1-20 L3).
3 . Jv{eet the \Washington State Ventilation and Indoor Ai. Q*lity C-ode (Chapter 51-
1.3, t997).
4. Filter all exhaust through appropriatelysized GAC fihration sptern
5. Exhaust to the outdoor atmosphere at least six feet above the highest point of the
structure roofline.
. The GAC unia will be properly operated and maintained to prevent breakhrcugh of
odon.
. Replacement GAC should be on-hand at all times.
www.orcaa.org I
South Bend Field Office: 1216W Robert Bush Drive, South Bend, W,{ 98586 r t36O)942-2137
cc:
2940 Limited Lane NW
Olympia, WA 98502
Olmpk Rrgion Cla Air fucneORCAA Represenring Clallam, Gray Harbor, JSercon,
Mason, Pacifc, and Thunnn Counties
1-800-422-5623 . (360) 539-7610
o Doors, windows and other openings should be closed except for entering or exiting the
buildings.
. Exrra measures will be taken to provide air-trght buildings in orderto prevent odors from
escaping or circumventing the GAC control system such as caulking searu in the building
skin.
o 'Waste materials will be enclosed in air-tight containers to prevent escape of odon priorto
removing them from the production building.
Please give a call if you have anyquestions.
IvlarkV. Goodin, P.E.
David \Wayne Johnson, Jefferson C-ounty Associate Planner
Fran McNair, ORCAA Executive Director
South Berrd Field Office: 1216W Robert Bush Drive, South Bend, WA 98586 o (360\942'2137
$incerely,
LIkilt
David W. Johnson
From:
Sent:
To:
Cc:
Subject:
Attachments:
Mark Goodin <mark.goodin@orcaa.org>
Friday, October LL,20L91:54 PM
Tracy Williamson; David W. Johnson
Fran McNair; Robert Moody; Pinky Mingo
Odor Control Plan for CASE #: MLALS-00102- ORCAA Comments
Odor Control Plan Assessment.pdf
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments
or clicking links, especially from unknown senders.
The odor control plan proposed the marijuana production facility at 860 Old Coyle Road in Jefferson County
will adequately control and prevent nuisance odors. Please see my attached response and call if you have any
question.
Mark Goodin, Senior Engineer
Olympic Region Clean Air Agency - "Cleon Air is Everyone's Business!"
2940 Limited Lane NW . Olympia WA 98502
t-800-422-5623 . (360) 539-7610 ext. 108 ryly.ole@4lg
Please take notice that any records or communications with ORCAA are subject to public
disclosure under the Public Records Act, (RCW 42.56) unless exempt under applicable law.
Please consider the environment before printing this emoil. Thank you'
1
David W. Johnson
Sent:
To:
Cc:
From:Mark Goodin < mark.goodin@orcaa.org >
Friday, September 27,20L9 3:49 PM
Tracy Williamson
David W. Johnson; Fran McNair; Robert Moody
Re:OBC Odor Mitigation Plan
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments
or clicking links, especially from unknown senders.
Your updated odor control plan is in the right direction. For me to complete my odor assessment, I need the
following information :
1. Scaled site map showing location of the buildings relative to property lines
2. Distance from building exhaust points to residential neighbor across Coyle road
3. Building footprint in square feet and interior air-space volume in cubic feet
4. Exhaust ventilation rate in acfm
5. Fan sizes
6. Mechanical diagram of ventilation system indicating duct diameters, intakes, and locations of in-line
GAC canisters
7. Make an model of in-line GAC canisters
Thanks
Mark Goodin, Senior Engineer
Olympic Region Clean Air Agency - "Cleon Air is Everyone's Business!"
2940 Limited Lane NW . Olympia WA 98502
L8A0-422-5623 .(350) 539-7610 ext. 108 www.orcaa.ors
Please take notice that any records or communications with ORCAA are subject to public
disclosure under the Public Records Act, (RCW 42.56) unless exempt under applicable law
Please consider the environment before printing this emoil. Thonk you,
On Fri, Sep 27,2019 at ll:37 AM Tracy Williamson <tracywilliamson2 wrote:
Hello Mr. Goodwin,
Would you please review our odor mitigation plan and CC Mr. David Johnson at Jefferson County Community
Development with your final response. If you have any questions or recommendations we will be happy to
adjust our plan as suggested. We can be reached at 360-535-9482.
Subject:
1
d iolrnsonr.i2co. ie \,v4. us
Thank you very much,
Tracy Williamson
360 535-9482
2
David W. Johnson
From:
Sent:
To:
Cc:
Subject:
David W. Johnson
Friday, August 16,20L9 11:03 AM
Tracy Williamson
David W. Johnson
RE: Odor control recommendations for proposed marijuana grow - Case 3:
MLA18-00102
Thanks. No I don't have any comment
From: Tracy Williamson <tracywilliamson2013@gmail.com>
Sent: Friday, August L6,2OLg 10:58 AM
To: David W. Johnson <djohnson@co.jefferson.wa.us>
Subject: Re: Odor control recommendations for proposed marijuana grow - Case 3: MLA18-00102
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments
or clicking links, especially from unknown senders.
Hello David,
Thank you,
Tracy
On Fri, Aug 16, 2019,10:34 AM David W. Johnson <djohnson@coiefferso wrote:
Tracy,
When willthis be finaled?
From : Tracy Wil liamson <tracvwi I I ia mso n201.3 @gma il.com>
Sent: Thursday, August t5,2Ot9 11:16 AM
To: Mark Goodin <mark.goodin@orcaa.org>
Cc: David W. Joh nson <d ioh nson @co. iefferso n.wa. us>
Subject: Re: Odor control recommendations for proposed marijuana grow - Case 3: MLA18-00102
1
We recieved it yesterday and forwarded it over to ORCAA. We are waiting for ORCAA to respond before we
frnalize it, in case they have any further recommendations. Do you have any recommendations before it is
finalized?
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments
or clicking links, especially from unknown senders.
Hello Mark,
We have asked the Green Busch Group to help us evaluate the proper size of fans to support our exhaust
system/ odor mitigation system, that will be adequate for the size of our buildings as well as evaluate the noise
output by the fansto support a mechanical system within the allowed sound levels to not disturb neighbors at
adjoining properties. I have attached a draft of the report below and a rough sketch of the proposed ventilation
ry.t.-. pi"uie do not share this information with anyone except David Johnson until the report is finalized.
The system designed has two filters which will be changed out in accordance with manufactures guidelines.
The report also states the type and size of fans to be used and how often the fans will be turned on and
off. Both filters are inline the first filter is a can granular activated carbon filter and the second filter is a
pleated carbon filter.
We believe this design will provide adequate exhaust/ventilation at all times and will maintain negative
pressue within the building as well as support ventilation standards for acceptable air quality for occupants. If
you have any question please give me a call at 360-731-7721.
Thank you for taking the time to review our proposal
Respectfully,
Tracy Williamson
Outback Bud Company
360-73r-772r
On Fri, Jul 5, 2019 at 1:30 PM Mark Goodin <mark.soodin@orcaa wrote:
Tracy,
Nice talking with you on the phone earlier this week. I reviewed your proposed odor control plan and have a
few recommendations, which are described in the attached letter.
2
Please feel free to call me with questions at any time.
Mark Goodin, Senior Engineer
Olympic Region Clean Air Agency - "Cleon Air is Everyone's Business!"
2940 Limited Lane NW . Olympia WA 98502
t-8OO-422-5623 . (360) 539-7510 ext. 108 www.orcaa.ors
Please take notice that any records or communications with ORCAA are subject to public
disclosure under the Public Records Act, (RCW 42.56) unless exempt under applicable law
Pleose consider the environment before printing this email. Thonk you,
**'r'Email may be considered a public record subject to public disclosure under RCW 42.56'k*ti
3
,a^
O!.mpt R.don Cld rir tlrnd
ORCAA
2940 Limited Lane NS/
Olympia. WA 98502
r-8cc-422-5623 . (360) 539"7610R.?resilttng Chll,tm, Gnry Harbor, Jcfersou.
,l[*on, Ptciic, and T]ntrsron Coancies
July 5, 2019
Tracy Williamson
2005 NW Peterson Road
Poulsbo, WA 98370
Jt",,L 0 5 209
t:
.l
JEFFERSO{ COUNWDCD =
SUBJECT: Odor Control Requirements and Recommendations fot CASE #: MLA18-00102
Dear ltrk. \Yy'rlliamson:
David Wayne Johnson, fusociate Planner with Jefferson Counry requested Olympic Region Clean
Ai Agency (ORCAA) review your plans for establishing a rnarijuana production/processing facilby
ar 860 Old Co1'le Road inJeffenon Counry (parcel # : 601105013) wirh respecr ro odor control.
ORCAA is the agency *ith primary responsibiliry for implementing and enforchg laws and
regulations under the Washington Clean Air Act forJeffenon Counry. Although marijuana
production and processing facilities are not subject to an air permining process prior to establishing
or registration with ORCAA,, they are subject to nlrisance odor prohibitions and control
requirements, which ORCAA enforces.
Yotrr proposed Odor Mitigation and Management Plan (lt/03/ 18) identified desirable features for
control of odon but lacls sufficient deuil to evaluate adequacyof the plan in achieving the desired
objective of eliminating nuisance odors on an ongoing basis.
The objecrive of any odor control plan is to capture and conrol emissions of odorous gases to levels
that eliminare any lilielihood of nuisance odon ar the property line and beycnd. This objective can
be reasonably achieved for indoor marijuana production facilities by eliminating all fugitive leala in
che growing and processing buildings and capturing all odorous gases and sending them through a
granular activared carton (GAg control s)6tem. Properly sizing, operating and maintaining the
GAC sratem are all critical to meeting the objective of no nuisance odors on an ongoing basis.
ORCAA recommends the following for designing lour marijuana grow operation:
o Maximize Setbacks. The grow and production buildings should be situated as far away
from neighbors as possible to lessen the likelihood of odor impacts.
o Buitding Exhaust/Ventilation System Design. The exhaust/ventilation system for any
building where growing, dryng, or processing takes place should be sized and designed by
a qualified professional and cenified to:
1. Provide adequate exhaust/ventiladon at all times that rnaintains negative pressure
within the buildings whenever odors are generated, thereby minimizing the
likelihood for fugitive leals.
2. Uleet ANSI/ASHRAE ventilation standards for accepable indoor air qualiry
(ANISI/ ASHRAE Standards 62.1' 2a B).
.,.,,,i'1,6-- ,,,:t.'
.1-,;:f ,11:y11-1 f;rl1iil r.lfiir:ir: i.iltrtV ilohi,rl Srt:trr )r1,.". :,r,,11', !Er-,.i. .,''.': :.]iiiir r lii.),'.111'lli:
&ol,ilpkR:3ro6oailrrs6<.' Rcpraentin.(Cklltm,Gn1VsHmbor,Jeferson,
O RCAA -' ,it,*n,'ioii1;r, tnrl itunmn Coi,iics
2940 Limited Lane NS/
Olympia. WA 98502
1-800-422-5623 . (360) 539-7610
' 3. h[eer the'Washington State Ventilation and Indoor Air QraliryC.ode (Chapter 51-
13i1Ee7).
4. Filter all exhaust through apprcPriatelysized GAC filtration systern
5., Exliaust ro rhe outdooi atmosphere at least six feet above the highest point of the
structure roofline.
o GAC Filtration Systems. The GAC filtration sFtems should be designed and sized to:
1. Effectivelycontrol odors during highesr odor generation periods (pre-bud and budding
period$. Two filter brands with proven success at a large indoor grow in ORCAA's
region are Blackops Filten (hup:.','rvrvu,'.blackopsi-rlters.conv.'shop, producvblack-elps-carbon-
tilrers ) and Can- Filters ( http :,/canfi lters.com,''l qeo ip-countrv:US. ).
2. Provide conrinuous odor control. This can be achieved by using dual GAC canisters
in series where the secondary canister provides control after breakhrough of the
primaryuntil the saturated canister can be replaced.
o Tight Building. Extra measures should be taken to provide air-tight buildings in order to
prevent odors from escaping or circumventing the GAC control system.
o Vaste Materials. \Waste materials should be enclosed in air-dght containers to prevent
escape of odon priorto removing them from the production building'
Once you have a comprehensive design completed which incorporates the above considerations and
measures, ORCAA would be happyto review it. Please give a call if yo, have anyquestions.
]vlark V P.E.
David \X/ayne Johnson, Jeffenon Countyfusociate Plarurer
Fran McNair, ORCAA Executive Director
cc:
ir:rrttr $encl f:i,:ir{ i)rice: ll:i) !'v l}":bert 3i:sh }r:v,: liorrtlt :lertrl. i:,'\,'!3;i{i r i,';t)r 1;.' .'l il
I have a question related to cannabis production. Would the ORCAA registration by a cannabis producer be
considered by ORCAA a "license governing emissions to air that is not exempt under RCW 43.21C.0381 or
WAC 197-l l-800 (7) of (8)?"
Thanks!
David Wayne Johnson - LEED AP - Neighborhood Development
Associate Planner - Port Ludlow Lead Planner
Department of Community Development
Jefferson County
360.379.4465
lvlissiort: To preserve ctnd enhqnce rhe qualit.,- oJ-li/b in,lffirson Oounty hy promotinq7 a vibruttl acrtnoml:,
,sound cotttra.mities and a healtln'e nvironmenl.
5fi SnVe PAPER - Pleqse do not prinl this e-mqil unless obsolutely necessory
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David W. Johnson
From:
Sent:
To:
Subject:
Aaron Manley < aaron.manley@orcaa.org >
Wednesday, April L7, 2019 8:28 AM
David W. Johnson
Re:ORCAA registration
Hi, David. No, ORCAA registration would not be considered a license goveming emissions to air.
On a related note: ORCAA recently ceased registering cannabis producers and processors, unless the facility
has equipment or processes that would otherwise require permitting or registration through ORCAA (e.g. an
emergency engine of sufficient size). We had a lawsuit, which we won, but it demonstrated some deficiencies in
our regulations we need to shore up. We plan to require registration aeain in the future. but are not doing so at
this time.
Therefore, we request that you not include any ORCAA registration requirements for cannabis producers or
processors at this time. I thought we had reached out to cities and counties with this information. If you were
missed, I do apologize Jefferson County was definitely one of the most proactive and helpful counties to work
with, and I appreciate your
Let me know if you have any questions.
Sincerely,
Aaron Manley, P.E
Engineer ll
Olympic Region Clean Air Agency
2940 limited Lane NW
Olvmpia. WA 98502
(360) 539-7610 x 104
\4/W'W.OrCaaorg8^
Ol/Dpic R*ton (!.! &r A$n.,ORCAA
Please take notice that any records or commLrnications with ORCAA are subject to public disclosure under the
Public Records Act (RCW 42.56) unless exempt under applicable law.
Please atnsider the environrnent belbre pririirtg lhis enuil.
On Tue, Apr 16, 2019 at4:16 PM David W. Johnson <djohnson@coiefferso wrote
1
Aaron,
David W. Johnson
From:
Sent:
To:
Subject:
Emma Bolin
Friday, March 22,20L9 1L:30 AM
David W. Johnson
SEPA citation for 1502
David,
Here is the SEPA citation we discussed yesterday. Check with Pinky. She may have the appropriate contact for ORCAA to
determine if registration constitutes a license to discharge to air.
(1) Minor new construction - Flexible thresholds.
(a) The exemptions in this subsection apply to all licenses required to undertake the construction in question. To
be exempt under this subsection, the project must be equal to or smaller than the exempt level. For a specific proposal,
the exempt level in (b)of this subsection shallcontrol, unless the city/county in which the project is located establishes
an exempt level under (c) of this subsection. lf the proposal is located in more than one city/county, the lower of the
agencies' adopted levels shall control, regardless of which agency is the lead agency. The exemptions in this subsection
apply except when the project:
(i) ls undertaken wholly or partly on lands covered by water;
(ii) Requires a license governing discharges to water that is not exempt under RCW 43.21C.0383;
(iii) Requires a license governing emissions to air that is not exempt under RCW 43.21C.0381 or WAC 197-11-800
(7) or (8); or
(iv) Requires a land use decision that is not exempt under WAC 197-11-800(6).
(b) The following types of construction shall be exempt:
(i) The construction or location of four detached single family residential units.
(ii) The construction or location of four multifamily residential units.
(iii) The construction of a barn, loafing shed, farm equipment storage building, produce storage or packing
structure, or similar agricultural structure, covering 10,000 square feet, and to be used only by the property owner or his
or her agent in the conduct of farming the property. This exemption shall not apply to feed lots.
(iv) The construction of an office, school, commercial, recreational, service or storage building with 4,000 square
feet of gross floor area, and with associated parking facilities designed for twenty automobiles. This exemption includes
parking lots for twenty or fewer automobiles not associated with a structure.
(v) Any fill or excavation of 100 cubic yards throughout the total lifetime of the fill or excavation and any
excavation, fill or grading necessary for an exempt project in (i), (ii), (iii), or (iv) of this subsection shall be exempt.
(c) Cities, towns or counties may raise the exempt levels up to the maximum specified in (d) of this subsection by
implementing ordinance or resolution. Such levels shall be specified in the agency's SEPA procedures (WAC 197-11-904).
Separate maximum optionalthresholds are established in (d)of this subsection applying to both incorporated areas and
unincorporated urban growth areas in fully planning jurisdictions under RCW 36.70A.040; other unincorporated areas in
fully planning counties; and jurisdictions in all other counties. Agencies may adopt the maximum level or a level between
the minimum and maximum level. An agency may adopt a system of several exempt levels, such as different levels for
different geographic areas, and mixed use projects.
Emma Bolin
Planning Supervisor
Jefferson County Department of Communiry Development
62I Sheridan Screet
Port Townsend" WA 98368
Phone 360-379-4484
1
Fax360-379-4451
ebolin(s)c cl j effcrso n. r.r, a. us
All e-mail sent to this address has been received by the Jefferson County e-mail systenr and is therefore subject to the Public Recorcls Act, a state law
tbun{ at RCIW 42.56. Under the Public Records law the County must release this e-mail and its contents to any person rvho asks to obtain a copy (or tbr
inspection) of this e-mail unless it is also exempt fi'orn procluction to the requester according to state law, inclucling RCW 42.56 and other state laws.
2
Fully planning GMA counties All other counties
Project types
lncorporated and
unincorporated UGA Other unincorporated areas
Incorporated and
unincorporated areas
Bam, loafing shed, farm
equipment storage, produce
storage or packing structure
40,000 square feet 40,000 square feet 40,000 square feet
Offi ce, school, commercial,
recreational, service, storage
building, parking facilities
30,000 square feet and 90
parking spaces
12,000 square feet and 40
parking spaces
12,000
pr
square feet and 40
arking spaces
((tand*ll)) Fillor
excavation
1,000 cubic yards 1,000 cubic yards 1,000 cubic yards
(2) Other minor new construction. ( (
sErueEion shal} be exempE exeepE rshere underEaken wholllr or in parE on
lands eevered by watser (unless speeifiea]Iy exempted in Ehis subsee
(a)The exemptions in this subsection applv to a II Iicenses re-
rrrli red lo rndprla lro 1-ho f al I nr^r'i ncr lrznos of nrooosa I q ovnonl r^rhon lho
proj ect :(i) f s undertaken whol]v or pa tl-v on l-ands covered bv water;(ii) Requires a ficense governin discharqes to water that is not
exempt under RCW 43.21C.0383;
/iii\ Daarrirac r 'l inanca anrzorni h^ ami coi anc l-A :'i r ihal i q nn1-
/irr) Rccvuircs e I rnd rrqo dani qi nn lhaf is no1- c wamnl rrnrlar I^lAf-
197*r-1-800 (5) .(b) The construction or designation of bus stops, Ioading zones,
shelters, access facilities and pull-out l-anes for taxicabs, transit
and school- vehicl-es.
( ({bl) ) (c) The construction and/or installat. j-on of commercial
on-premise signs, and Public siqns and signals.
( ({€+) ) (d) The construction or instal-Iation of minor road and
st.reet improvements
f o1l-owing:(i) Safety structures and equipment: Such as pavement marking,
freeway surveil-Iance and control systems, railroad protective devices
(not including grade-separated crossings), grooving, glare screen,
safety barriers, energy attenuators ( (z) );(ii) Transportation corridor landscaping (including the applica-
tion of state of Washington ( ( ) ) ap-
proved herbicides by Iicensed personnel for right of way weed control-
as long as this is not within watersheds controffed for the purpose of
drinking water quality in accordance with WAC 248-54-660 ) ( (;-) ) i(iii) Temporary traf fic conLrol-s and detours ((z-) )-(iv) Correction of substandard curves and inLersections within
existing rights of wdy, widening of a highway by l-ess than a single
l-ane width where capacity is not signi-ficantly j-ncreased and no new
right of way is reguired((z) )-(v) Adding auxil-iary lanes for l-ocalized purposes, (weaving,
climbing, speed change, etc.), where capacity is not significantly in-
creased and no new right of way is reguired((z))-(vi) Channelization and el-iminatj-on of sight restrictions at in-
tersections, street lighting, guard rails and barricade install-a-
tion ( (;-) )-
l-rrr ,an\/ ,aaranr.\, ar nri rzal-c n:r1-rz th:f innlrrrlo fha
10 ors-5 934 .6