ORANGE COUNTY SANITATION DISTRICT MASTER PLAN

TECHNICAL MEMORANDUM 5: HIGH STRENGTH ORGANIC CO‐DIGESTION EVALUATION

OCSD PROJECT NO. PS15‐01 reserved. rights

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TM‐5: High Strength Organic Waste Co‐Digestion Evaluation | Orange County Sanitation District

Table of Contents Acronym and Abbreviations List ...... vi Executive Summary ...... ES‐1 1.0 Introduction ...... 1‐1 1.1 Purpose and Scope ...... 1‐1 1.2 Background Information ...... 1‐2 1.3 Terminology Used In This Memorandum ...... 1‐2 2.0 Regulatory and Market Drivers ...... 2‐1 2.1 Permitting Requirements ...... 2‐1 2.1.1 CalRecycle Composting Regulations ...... 2‐1 2.1.2 Air Quality ...... 2‐1 2.2 Regulatory Framework ...... 2‐3 2.2.1 California Solid Waste Law and Organics Diversion ...... 2‐3 2.2.2 Impact of Air Quality Regulations ...... 2‐4 2.2.3 Renewable Energy Incentives and Regulations ...... 2‐4 2.2.3.1 Self‐Generation Incentive Program ...... 2‐5 2.2.3.2 Renewables Portfolio Standard ...... 2‐5 2.2.3.3 Low Carbon Fuel Standard Program ...... 2‐6 2.2.3.4 Cap and Trade Funding...... 2‐6 2.2.3.5 CalRecycle Greenhouse Gas Reduction Grant and Loan Programs ...... 2‐7 2.2.3.6 Orange County Regional and Waste Reduction Grant ...... 2‐7 2.3 Market Trends ...... 2‐8 3.0 High Strength Organic Waste Characteristics and Sources ...... 3‐1 3.1 General Characteristics ...... 3‐1 3.2 Pre‐Processed SSO Design Assumptions ...... 3‐1 4.0 Orange County’s Organic Waste Stakeholders ...... 4‐1 4.1 Orange County Solid Waste Overview ...... 4‐1 4.2 Republic Services ...... 4‐2 4.3 ...... 4‐3 4.4 CR&R Incorporated ...... 4‐3 4.5 Findings ...... 4‐3 5.0 Capacity and Constraints ...... 5‐1 5.1 OCSD Co‐Digestion Goals ...... 5‐1 5.2 General Co‐Digestion Process Limitations ...... 5‐1 5.2.1 LACSD Co‐Digestion ...... 5‐2 5.2.2 EBMUD Co‐Digestion ...... 5‐2 5.3 Data and Assumptions ...... 5‐2 5.3.1 Evaluation Conditions and Solids Projections ...... 5‐2 5.3.1.1 Sludge from MWRP ...... 5‐3 5.3.1.2 Sludge Diversion from Plant No. 1 to Plant No. 2 ...... 5‐4

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5.3.1.3 Solids Flows and Loads Used for Digester Capacity Analysis ...... 5‐5 5.3.1.4 Digester Loading Rates Used for Digester Capacity Analysis ...... 5‐5 5.4 Plant No. 1 Capacity Analysis ...... 5‐7 5.5 Plant No. 2 Capacity Analysis ...... 5‐7 5.5.1 Plant 2 Digester Capacity Evaluation Conditions under Mesophilic Operation with Existing Digesters ...... 5‐7 5.5.2 Plant 2 Digester Capacity Evaluation Conditions under TPAD Operation with New Digesters ...... 5‐9 5.6 Digester Gas Production with Food Waste ...... 5‐10 5.7 Ammonia Limitations ...... 5‐16 5.8 Capacity Analysis Conclusions ...... 5‐18 6.0 Co‐Digestion Benefits and Cost Analysis ...... 6‐1 6.1 General Benefits ...... 6‐1 6.2 Economic Payback Period Calculations ...... 6‐1 7.0 Project Implementation, Scope and Partnerships ...... 7‐1 7.1 Implementation Overview ...... 7‐1 7.2 Potential Partnerships ...... 7‐2 7.3 Contractual Arrangements ...... 7‐2 7.4 Interim Receiving Station Equipment ...... 7‐2 7.5 Ultimate Receiving Station and Ancillary Equipment ...... 7‐4 7.6 Interim Receiving Facility Location ...... 7‐8 7.7 Ultimate Receiving Facility Location ...... 7‐9 8.0 Conclusions and Next Steps ...... 8‐1 9.0 List of References ...... 9‐1

See Enclosed Flash Drive for Appendices Appendix A – Materials from Vendor Workshop ...... A‐1 Appendix B – Detailed Capacity Calculations ...... B‐1 Appendix C – Meeting Minutes for Task 5 Meetings ...... C‐1 Appendix D – Title 14 Chapter 3.2 Regulations ...... D‐1 Appendix E – Pre‐Processed SSO Characteristics ...... E‐1 Appendix F – Example SSO and HSW Contracts from Other Facilities ...... F‐1 Appendix G – QC Review Affidavits ...... G‐1

Select Published Appendices Appendix B – Detailed Capacity Calculations ...... B‐1

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LIST OF FIGURES Figure 1‐1. Task Flow for BMP ...... 1‐2 Figure 2‐1. Regulatory Triggers for Organic Waste Diversion under AB 1826 ...... 2‐4 Figure 2‐2. Pathways/Markets for Organics Resulting from AB 1826 and SB 1383 for Low‐ Solids ...... 2‐8 Figure 2‐3. Digesters at EBMUD’s Main WWTP Used for Co‐Digestion of HSW ...... 2‐9 Figure 2‐4. A Map of Facilities Accepting Food Waste in California ...... 2‐10 Figure 4‐1. Waste Haulers Serving Orange County and Their Approximate Service Areas ...... 4‐2 Figure 5‐1. Projected Peak 15‐day Digester Gas Flows for Plant No. 2 in 2045 ...... 5‐15 Figure 6‐1. Interim Pre‐Processed SSO Receiving Facility Tipping Fee Summary ...... 6‐2 Figure 6‐2. Permanent Pre‐Processed SSO Tipping Fee and Resultant Return on Investment Summary ...... 6‐3 Figure 7‐1. Interim Food Waste Receiving Schematic ...... 7‐4 Figure 7‐2. Ultimate Food Waste Receiving Schematic ...... 7‐7 Figure 7‐3. A Schematic of the Proposed Interim Receiving Facility Location ...... 7‐8 Figure 7‐4. A Schematic of the Proposed Ultimate Receiving Facility Location ...... 7‐9

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LIST OF TABLES Table 3‐1. General Characteristics of Pre‐Processed SSO Used for OCSD Planning ...... 3‐2 Table 5‐1. TSS and BOD Loads of MWRP Sludge Discharged to Plant No. 1 in 2016 at Annual Average Condition ...... 5‐4 Table 5‐2. Liquid Treatment Process Performance at Plant No. 1 ...... 5‐4 Table 5‐3. TSS and BOD Loads of Plant No. 1 Sludge Diversion to Plant No. 2 at Annual Average Conditions ...... 5‐4 Table 5‐4. Liquid Treatment Process Performance at Plant No. 2 ...... 5‐5 Table 5‐5. Summary of Solids Flows and Loads for Digester Capacity Analysis at Annual Average Conditions ...... 5‐5 Table 5‐6. Summary of Key Assumptions for Each Scenario1 ...... 5‐6 Table 5‐7. Assumed Characteristics of Pre‐Processed SSO ...... 5‐6 Table 5‐8. Summary of Pre‐Processed SSO Quantities that can be Co‐digested at Plant No. 2 under Mesophilic Operation under Condition 1, wtpd1 ...... 5‐8 Table 5‐9. Summary of Pre‐Processed SSO Quantities that can be Co‐digested at Plant No. 2 under Mesophilic Operation under Condition 2, wtpd1 ...... 5‐8 Table 5‐10. Summary of Pre‐Processed SSO Quantities that can be Co‐digested at Plant No. 2 under TPAD Operation under Condition 1, wtpd1 ...... 5‐9 Table 5‐11. Summary of Pre‐Processed SSO Quantities that can be Co‐digested at Plant No. 2 under TPAD Operation under Condition 2, wtpd1 ...... 5‐10 Table 5‐12. Digester Gas Productions from Plant No. 1 and Plant No. 2 with Interim Facility under Condition 1 in 20281 ...... 5‐12 Table 5‐13. Digester Gas Productions from Plant No. 1 and Plant No. 2 with Interim Facility under Condition 2 in 20281 ...... 5‐12 Table 5‐14. Digester Gas Productions from Plant No. 1 and Plant No. 2 with Ultimate Facility under Condition 1 in 20451 ...... 5‐13 Table 5‐15. Digester Gas Productions from Plant No. 1 and Plant No. 2 with Ultimate Facility under Condition 2 in 20451 ...... 5‐14 Table 5‐16. CenGen Digester Gas Utilization Capacity ...... 5‐15 Table 5‐17. Project J‐124 Digester Gas Design Capacities ...... 5‐16 Table 5‐18. Ammonia Toxicity Levels Recorded in Digestion Literature ...... 5‐16 Table 5‐19. A Summary of Results for Total Ammonia Concentrations for Co‐Digestion at

Plant No. 2, mg NH3‐N/L ...... 5 ‐ 1 7 Table 5‐20. A Summary of Digester Capacity Evaluation for Plant No. 2 ...... 5‐18 Table 6‐1. Tipping Fee Required for Given Payback Period ...... 6‐3

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Acronym and Abbreviations List The following acronyms and abbreviations are used in this document.

% Percent AB Assembly Bill ADC Alternate daily cover BACT Best Available Control Technology BC Brown and Caldwell BMP Biosolids Master Plan BOD Biochemical oxygen demand BV Black & Veatch BV/BC team Black & Veatch Corporation and Brown and Caldwell team CalEPA California Environmental Protection Agency CARB California Air Resources Board CDFA California Department of Food and Agriculture CEC California Energy Commission CenGen Central Power Generation Systems cf/lb Cubic feet per pound CHP Combined heat and power CI Carbon intensity CNG Compressed natural gas COD Chemical Oxygen Demand CPUC California Public Utilities Commission cy Cubic yards cy/wk Cubic yards per week DFFP Department of Forestry and Fire Protection DWR Department of Water Resources EBMUD East Bay Municipal Utilities District EPA United States Environmental Protection Agency ERC Emission Reduction Credits FOG Fats, oil, and grease FTE Full‐time employee GGRF Greenhouse Gas Reduction Fund GHG Green House Gas gpd Gallons per day gpm Gallons per minute H2S Hydrogen sulfide HRT Hydraulic retention time HSW High‐strength waste IOU Investor Owned Utility IRWD Irvine Ranch Water District IWMA Integrated Waste Management Act JWPCP Joint Water Pollution Control Plant

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LACSD Sanitation Districts of Los Angeles County LAER Lowest achievable emission rate lb Pound(s) lb‐FW Pounds food waste lb‐N Pounds nitrogen lb‐TS Pounds total solids lb‐VS Pounds volatile solids lbs/cf Pounds for cubic feet LCFS Low Carbon Fuel Standard LNG Liquid Nitrogen Gas M Million mg/L Milligrams per liter mg‐N/L Milligrams Nitrogen per liter N/A Not Applicable

NH3 Ammonia

NH3‐N/L Ammonia Nitrogen per liter + NH4 Ionized ammonium NPDES National Pollutant Discharge Elimination System OCSD Orange County Sanitation District OCWR Orange County Waste and Recycling OLR Organic loading rate pH Potential of hydrogen pKa Ionization Constant PLC Programmable Logic Controller POTW Publicly Owned Treatment Works POU Publicly Owned Utility RFP Request for Proposals REC Renewable Energy Certificate RPS Renewable Portfolio Standard SB Senate Bill SCAQMD South Coast Air Quality Management District SCE Southern California Edison Scfm Standard cubic feet per minute scf Standard cubic feet SGIP Self‐Generation Incentive Program SLCP Short‐Lived Climate Pollutants SSO Source Separated Organics SWEET Solids‐Water‐Energy‐Evaluation Tool T‐BACT Toxic Best Available Control Technology TKN Total Kjeldahl Nitrogen TM Technical memorandum TMs Technical memoranda TPAD Temperature phased anaerobic digestion

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TPODS Treatment Plant Operational Data Summary TS Total solids TSS Total suspended solids VS Volatile solids

VSd Volatile solids destructed VSR Volatile Solids Reduction WAS Waste activated sludge WM Waste Management WWTP Wastewater treatment plant wtpd Wet tons per day

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Executive Summary This Technical Memorandum (TM) 5 High Strength Organic Waste Co‐Digestion Evaluation presents the feasibility of implementing a high strength organic waste receiving program. This work was conducted under Task 5 of Orange County Sanitation District (OCSD) Project No. PS15‐ 01, Biosolids Master Plan (BMP). This task includes identifying regulatory, legislative, financial, and environmental drivers and constraints; identifying high strength organic waste types, characteristics and sources; identifying the benefits of co‐digestion; evaluating OCSD’s capacity and operational constraints; and quantifying the availability of co‐digestion feedstocks and project success models through public‐private partnerships.

This document is organized to include the following sections:  Section 1: Introduction  Section 2: Regulatory and Market Drivers  Section 3: High Strength Organic Waste Types, Characteristics and Sources  Section 4: Orange County’s Organic Waste Stakeholders  Section 5: Capacity and Constraints  Section 6: Co‐Digestion Benefits and Cost Analysis  Section 7: Project Implementation Schedule, Scope and Partnerships  Section 8: Conclusions and Recommendations

The following are highlights of the sections in TM‐5.

Section 1 (Introduction) and Section 2 (Regulatory and Market Drivers)

This TM addresses the inclusion of a co‐digestion program at one or both of OCSD’s wastewater treatment plants (WWTPs). The co‐digestion analysis performed under Task 5 followed the selection of on‐site technologies under Task 4. The selection of temperature phased anaerobic digestion (TPAD) within Task 4 provides the basis of this task, as does background information collected and documented in TM‐1 and TM‐2.

As documented in TM‐2 and TM‐3, a significant change in the regulatory landscape in California has occurred around the diversion of organics from . Currently, much of the state’s diverted organics are being composted or used as alternative daily cover (ADC) on landfills. With the phase‐ out of organics as ADC, TM‐2 noted that the regulatory shift around organics in California was expected to generally benefit the wastewater sector by making organic feedstocks available for co‐ digestion, as well as generating funding opportunities for WWTPs (cap and trade and other programs). In particular, Assembly Bill AB 1826 (2014) sets organic diversion targets over the next four years under, which commercial waste generators will need to identify alternative disposition sites for organics. SB 1383 (2016) sets organics diversion goals which will require waste generators and haulers to seek alternatives to disposal.

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Section 3 (High Strength Waste Types, Characteristics and Sources) and Section 4 (Orange County’s Organic Waste Stakeholders)

For the purposes of this task, high strength organic waste received at OCSD’s WWTPs was assumed to largely comprise of pre‐processed commercial and/or residential source separated organics (SSO). Pre‐processed SSO is generated when SSO is collected by waste haulers, screened nearly free of contaminants, and then pulped, extruded and/or slurried into a pumpable liquid. This liquid is expected to range in solids concentration from 12‐15 percent and have a pH around 5.0, though it could be anywhere between 3.0 and 7.0. The pre‐processed SSO is readily digestible with an expected volatile fraction of at least 85 percent of the total solids, or possibly greater.

Several large haulers within Orange County have the ability to provide pre‐ processed SSO to OCSD. Of these, Republic Services and Waste Management, two of the largest entities, have expressed a willingness to partner with OCSD. Waste Management has developed its own methodology for processing SSO and within the region, has teamed with the Los Angeles County Sanitation District (LACSD) to receive and digest the pre‐processed SSO from commercial sources. Republic Services is in the process of developing its own SSO pretreatment process. Another important partner for OCSD is Orange County Waste and Recycling (OCWR). OCWR does not directly collect or haul waste, but does serve as the intermediary between the waste haulers and the county‐owned landfills. In addition, OCWR is in the process of exploring the development of a site within Orange County.

Section 5 (Capacity and Constraints)

Available capacity to receive pre‐processed SSO was examined from two perspectives. The first was OCSD‐specific requirements and the second was process limitations. From OCSD’s standpoint, the receipt of pre‐processed SSO should not compromise the ability of the digestion system to achieve pathogen reduction or any other metrics of quality for beneficial use of biosolids. In addition, the system should not generate more biogas than what the onsite combined heat and power system can manage. From a process standpoint, there is no consensus within the current literature as to an upper cap on the loading rate for co‐digestion. One consideration, however, is that of ammonia toxicity. The BV/BC team examined the potential for ammonia levels in the digester to rise and found that while the addition of pre‐processed SSO would cause an increase in ammonia, this increase is still below literature values for toxicity.

A capacity analysis for Plant No. 1 indicates that a co‐digestion program there is not feasible. At Plant No. 2, however, firm capacity exists today to accommodate pre‐processed SSO up to 800 wet tons per day in 2045. Thus, OCSD could opt to build a temporary pre‐processed SSO receiving station immediately and then construct a more permanent facility in the future, in conjunction with the larger digester project. Based on capacity estimates, an interim receiving facility could be constructed immediately and designed to receive up to 250 wptd of pre‐processed SSO. Following construction of the TPAD digestion process in 2028, an ultimate food waste receiving facility could be constructed and designed to receive approximately 500 wtpd of pre‐processed SSO. It’s recommended the contracts with waste haulers should allow OCSD to receive less pre‐processed SSO than the maximum capacity of the receiving facilities. This would provide OCSD with operation flexibility to handle high solids flows and loads conditions.

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Section 6 (Co‐Digestion Project Justification), Section 7 (Project Implementation Schedule, Scope and Partnerships), and Section 8 (Conclusions and Next Steps)

The BV/BC team took a preliminary look at the feasibility of constructing both a temporary and a permanent receiving station for pre‐processed SSO. Using preliminary construction costs and a payback period of 5 years, at 150 wet tons per day for the interim receiving facility, OCSD would need a tipping fee of $41 per wet ton. Whereas for a 5‐year payback period at 500 wet tons per day for the ultimate facility would require a tipping fee of $30 per wet ton. Preliminary layouts and locations were also reviewed for the receiving station. Adequate space is available at the Plant No. 2 site to accommodate a receiving station. Costs, specific siting of the receiving station and associated piping, as well as a more detailed implementation schedule will all be developed under Task 6.

Final ‐ May 9, 2017 ES‐3 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

1.0 Introduction Orange County Sanitation District (OCSD) is implementing Project No. PS15‐01, Biosolids Master Plan (BMP), to provide a roadmap and framework for sustainable and cost‐effective biosolids management options. OCSD authorized Black & Veatch Corporation and its teaming partner Brown and Caldwell (BV/BC team) to develop a BMP Report to evaluate existing OCSD solids handling facilities, study solids treatment alternatives, and recommend future capital facilities improvements. The BMP Report will be comprised of eight technical memoranda and supporting information. This document presents Technical Memorandum (TM) 5 ‐ High Strength Organic Waste Co‐Digestion Evaluation. 1.1 PURPOSE AND SCOPE Anaerobic digestion is currently at the nexus of two important State of California goals: organics diversion from landfill and increased renewable energy and fuels generation. Organics diversion from landfill is the primary initiative in the State’s 75 % solid waste recycling goal and is backed up by new regulations, which require source separation and collection of organics (Assembly Bill 1826 and Senate Bill (SB) 1383). The goal of SB 1383 is to reduce methane emissions from landfill and further promote/require organics diversion (Short‐Lived Climate Pollutants Act, California Air Resources Board). The primary alternatives for organics management are anaerobic digestion and composting – of which anaerobic digestion is the only process that offers energy recovery potential. Over the next few years, California’s municipal solid waste haulers, material recovery facilities, and landfills will need to develop collections, processing, and energy recovery infrastructure to address these state legislations and goals.

Existing wastewater treatment plants (WWTPs) are uniquely positioned to play a role in the new organics marketplace. Whereas waste management facilities do not typically have anaerobic digesters, most WWTPs already operate digesters (with energy recovery facilities) and may have additional capacity for organic beyond municipal wastewater solids. In addition, WWTPs are generally able to effectively manage the digestate and nutrient rich residuals in a beneficial way. Many WWTPs are already using available digestion and energy capacity for co‐digestion of fats, oil and grease (FOG) and liquid high strength organic waste (HSW) from industry. Tipping fees for waste acceptance and increased digester gas production for energy generation make co‐digestion economically viable and potentially attractive to public agencies operating WWTPs. Acceptance of organics diverted from landfill would follow the same model, but perhaps with improved economies of scale due to the large and steady demand created by the landfill/organics regulations.

The purpose of this TM is to identify the regulatory and market drivers for potential organic waste diversion to OCSD WWTPs; assessment of available organics volumes, sources, and characteristics; evaluation of capacity to accept and feed organics to Plant No. 1 and/or Plant No. 2 digesters; review potential financial incentives; and develop conceptual design for the receiving facilities.

This TM covers the following topics:  Regulatory and Market Drivers  Capacity and Constraints for High Strength Organic Waste Co‐Digestion  Identification of Potential Projects and Partnerships

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 Financial analysis  Conceptual design for pre‐processed SSO receiving facilities 1.2 BACKGROUND INFORMATION OCSD previously commissioned a bench‐scale study by Bucknell University and Kennedy/Jenks Consultants entitled “Food Waste Co‐Digestion Effects on Digester Performance and Biosolids Characteristics (A Technical, Economic and Regulatory Analysis)”. This effort included bench‐scale digestion of source‐separated food waste with OCSD’s municipal sludge. The study confirmed the digestability of pre‐processed food waste provided by Waste Management when digested with OCSD’s sludge. Suitable loading rates and gas production for OCSD’s application were also established. In essence, the work confirmed what many WWTPs, regulators and solid waste stakeholders already know – that co‐digestion of high‐strength organic waste is a viable process.

In addition, this TM is preceded by four TMs:  TM‐1 OCSD Solids Facilities Summary and Design Basis,  TM‐2 Review OCSD’s Biosolids Program and Summarize the Current State, Trends, and Outlook for Biosolids Management,  TM‐3 Biosolids Management Alternatives Evaluation, and  TM‐4 Plant No. 2 Digestion and Post‐Dewatering Technologies Evaluation.

TM‐1 and TM‐2 constitute the project baseline (see Figure 1‐1, below), and information regarding projected biosolids quantities contained in TM‐1 was used in calculations in this TM. TM‐3 and TM‐4 together screened and selected the digestion and post‐dewatering technologies to be installed at Plant No. 2. This TM builds on those by evaluating the possibility of implementing co‐digestion at Plant No. 1 and/or Plant No. 2 and the impacts such a decision might have on the ultimate capital program (Tasks 6 and 7).

Figure 1‐1. Task Flow for BMP

1.3 TERMINOLOGY USED IN THIS MEMORANDUM This TM discusses co‐digestion, which for OCSD, is focusing on the digestion of food waste. Other feedstocks typically co‐digested include FOG and industrial food wastes. Industrial food wastes are the byproducts of food processing, such as fluid dairy products or brewery waste. These have not

Final ‐ May 9, 2017 1‐2 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation been the focus of this study. FOG, also known as “brown grease”, is collected from grease traps and interceptors. Source separated organics describes food that have been diverted at the point of generation (such as households, restaurants, cafeterias) for dedicated collection. SSO requires pre‐processing before co‐digestion due to its typically heterogenous nature and presence of contaminants, such as plastics. Within this TM, the term “pre‐processed SSO” is used to describe the waste that is primarily being considered for co‐digestion at OCSD’s WWTP. Pre‐processed SSO has been conditioned (e.g. screened and slurried) to be relatively homogenous and pumpable. Several processes can generate this quality of material, and it will be at the discretion of the waste hauler which process or processes are used to pretreat the waste. The terms food waste slurry and pre‐ processed SSO are used interchangeably.

HSW is any digestion feedstock that is trucked to a wastewater treatment plant (WWTP) and generally has a higher volatile suspended solids concentration, total suspended solids concentration, or methane potential than municipal wastewater solids. FOG and SSO are encompassed by HSW; therefore, the term “HSW” is used when FOG and SSO are referred to together or when FOG and SSO are combined. The terms “FOG” and “SSO” are used when either type of waste is specifically referenced without the other term. Other organics discussed in this TM are and woody waste. Green waste is typically collected curbside and generally consists of lawn clippings, leaves, and small branches. Woody waste tends to consist of marginal quality wood as well as larger limbs and branches, typically received at a landfill or other solid waste receiving facility where it is likely to be chipped and ground for other uses.

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2.0 Regulatory and Market Drivers As identified in TM‐2, one of the largest regulatory shifts in California has occurred around organics diversion. This section describes the regulatory framework around organics in California and its impact on the market for organics. In this context, organics comprise of green waste, FOG, SSO, and industrial food waste. CalRecycle, the state agency responsible for implementation of much of the organics regulations, has yet to define whether or not biosolids are part of the state definition of organics.

Currently, much of the state’s diverted organics are being composted or used as alternative daily cover (ADC) on landfills. With the phase‐out of organics as ADC, TM‐2 noted that the regulatory shift around organics in California was expected to generally benefit the wastewater sector by presenting co‐digestion opportunities and other opportunities to access state funding, such as the cap and trade program. 2.1 PERMITTING REQUIREMENTS Potential permitting requirements impacting pre‐processed SSO receiving at OCSD include the following.

2.1.1 CalRecycle Composting Regulations In 2015, CalRecycle promulgated new compost regulations dictating general standards and permitting requirements for new and existing composting facilities. The applicability of these regulations has set out specific definitions for composting facilities to include “facilities that receive, store, handle, recover, transfer, or process solid waste”. In crafting the regulations, CalRecycle created an exemption from this applicability clause specifically WWTPs incorporating a co‐ digestion program into their operations. As codified in Title 14, Chapter 3, Section 6 of the California Code of Regulations, the exemption sates that, “A Publicly Owned Treatment Works Treatment Plant (POTW Treatment Plant), as defined in section 403.3(r) of Title 40 of the Code of Federal Regulations, that receives vehicle‐transported solid waste that is an anaerobically digestible material for the purpose of anaerobic co‐digestion with POTW Treatment Plant wastewater” is exempted from the compost regulations. To obtain this exemption, OCSD would need to (1) augment their existing permit with a standard provision and (2) create standard operating procedures for all aspects of handling the received food waste. In addition, the food waste must be received in leak‐proof, covered containers. In creating this exemption, CalRecycle acknowledged that those WWTPs whose activities are already regulated by, at a minimum, an NPDES discharge permit, is a regulated entity. It is important to note that WWTPs wishing to engage in food waste only digestion would not fall under this exemption; it is only applicable to co‐ digestion. Refer to Appendix D for the full exemption regulations.

2.1.2 Air Quality South Coast Air Quality Management District (SCAQMD) regulations allow increases in hours of operation or production rates of permitted stationary sources as long as such increases do not violate the terms and limitations of a facility’s air permit. As such, if the increased utilization of the Central Power Generation System (CenGen) engines due to importation of pre‐processed SSO does not result in a violation of the currently permitted heat output or emission limitations, then no

Final ‐ May 9, 2017 2‐1 Biosolids Master Plan TM‐5: High Strength Organic Waste Co‐Digestion Evaluation | Orange County Sanitation District permitting action would be required. In such a case, OCSD would only be required to obtain a permit for the proposed odor control units.

Otherwise, if the CenGen engines will surpass their current permitted limits on hourly heat output and/or emissions, the increased utilization of the CenGen engines made possible by the increased digester gas production due to the importation of pre‐processed SSO will constitute a modification to existing emission sources. Additionally, the odor control units proposed to be installed as part of the food waste slurry receiving facilities will be considered new emissions sources at an existing stationary emission source. Collectively, the aforementioned undertakings would meet the definition of a modification to a Major Polluting Facility as defined in SCAQMD Rule 1302. In such a case OCSD will be required to apply for and obtain a permit to construct from SCAQMD in order to authorize construction of the project.

The permit to construct application may require the implementation of a number of requirements and/or analyses, depending on the magnitude of the emissions increases attributable to the project relative to various thresholds prescribed in the SCAQMD regulations. These requirements and/or analyses could include one or more of the following:

 Air Dispersion Modeling – May be required to analyze the effects of the project’s emissions and possibly the entire facility’s emissions on ambient air quality. The modeled predicted impacts are compared to applicable SCAQMD and/or federal thresholds to determine if the project will result in acceptable impacts to ambient air quality.  Emission Reduction Credits (ERCs) – Unless exempt pursuant to SCAQMD Rule 1304, ERCs are required to be obtained by OCSD prior to construction in order to offset applicable

increases in emissions of volatile organic compounds (VOC), nitrogen oxides (NOX), sulfur

dioxide (SO2), particulate matter 10 (PM10), and carbon monoxide (CO). However, it should be noted that Rule 1304 (c)(3) provides exemptions to and Energy Conservation Projects. As such, discussions should be had with SCAQMD to determine if the conversion of food waste to digester gas fuel for the CenGen engines qualifies for this exemption.  Best Available Control Technology (BACT) – SCAQMD Rule 1303 requires that BACT be implemented for any project that results in an emission increase of greater than 1 pound

per day of VOC, NOX, SO2, PM10, CO, lead, ammonia, and ozone depleting compounds. For sources located at Major Polluting Facilities, BACT is required to be at least as stringent as lowest achievable emission rate (LAER) as defined in the federal Clean Air Act Section 171(3). The BV/BC team notes that the current digester gas cleanup systems and post‐ combustion emissions controls installed on the CenGen engines are consistent with current SCAQMD BACT guidelines. Additionally, ammonia emissions are limited to 10 parts per million by volume, dry basis at 15% oxygen, which is consistent with BACT guidelines for ammonia slip. Lastly, it is anticipated that the engines will remain in compliance with SCAQMD Rule 1110.2.  Air Toxics Analysis – SCAQMD Rule 1401 requires an analysis of a proposed source’s toxic air contaminant emissions to ensure emissions do not result in unhealthy levels of toxics in areas surrounding a facility that emits toxics. The regulations prescribe a tiered health risk analysis (HRA), which begins with a spreadsheet exercise, but can require extensive air

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dispersion modeling. Additionally, SCAQMD toxics regulations can require the implementation of BACT for toxics (T‐BACT). Given that the CenGen engines are currently fitted with an oxidation catalyst and that odor control units can control hydrogen sulfide emissions at an efficiency of near 99 percent, it is anticipated that T‐BACT requirements would be satisfied without any additional design considerations. The terms and conditions of the permit to construct will eventually be required to be incorporated into the facilities Title V operating permit via a permit revision. The type of permit revision (i.e., minor permit revision, De Minimis significant permit revision, significant permit revision) depends on the characteristics of the particular project. 2.2 REGULATORY FRAMEWORK The regulatory framework around organics is driven by State regulations, which have gradually evolved over the last 20 years. These are described below.

2.2.1 California Solid Waste Law and Organics Diversion California’s solid waste management framework generally stems from the Integrated Waste Management Act (IWMA) of 1989, also known as Assembly Bill (AB) 939, and its subsequent amendments. The original IWMA set statewide solid diversion goals at 25% by 1995 and 50% by 2000. The IWMA established the Integrated Waste Management Board, now called CalRecycle, as a state agency within California Environmental Protection Agency (CalEPA) with the authority to administer and provide oversight for all of California’s state‐managed solid waste management and recycling programs.

In 2011, AB 341 set a new statewide recycling goal of 75 percent by 2020. This goal is only achievable with significant diversion of organics from landfills. CalRecycle, in determining how to implement this rule, has indicated that many organics will be banned from landfills. In 2014, additional legislation, AB 1826 and AB 1594, further augmented the IWMA. AB 1826, which will be extremely impactful for local jurisdictions, establishes organics diversion triggers for entities above a certain size (Figure 2‐1). Commercial entities falling above the limits set by AB 1826 are required to establish a recycling program for organic wastes. The timeline begins in 2016, with entities generating 8 cubic yards (cy) per week or more of organic waste must implement a diversion program. The final trigger occurs in January 2020, when entities generating 2 cy/week or more of municipal solid waste must establish an organics recycling program. Note that under AB 1826, commercial entities include businesses, such as restaurants and office buildings, as well as multi‐ family dwellings. For the purposes of implementing a program, AB 1826 references the definition of organic waste specified in Chapter 12.9 of Part 3 of Division 30 of the Public Resources Code, which is “food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food‐ soiled paper waste that is mixed in with food waste”.

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Figure 2‐1. Regulatory Triggers for Organic Waste Diversion under AB 1826

AB 1594 changes certain ADC diversion credits under the original IWMA. ADC is defined under the original IWMA and has been considered landfill diversion since the IWMA’s passage. AB 1594 mandates that beginning on January 1, 2020, the use of green waste material for ADC will be counted towards disposal. AB 1594 is relevant, as it has largely been considered the first step toward an outright organics ban. CalRecycle, in coordination with the California Air Resources Board (CARB), are permitted to enact further regulations if existing incentives do not achieve statewide goals.

2.2.2 Impact of Air Quality Regulations CARB indirectly regulates organics and biosolids management through the California Global Warming Solutions Act of 2006 (AB 32). AB 32 required CARB to develop a Scoping Plan to reduce California’s greenhouse gas (GHG) emissions to 1990 levels by 2020. In 2008, CARB created a Scoping Plan that outlines measures to reduce methane emissions from landfills by diverting organic waste away from landfills. SB 32, passed in 2016, expands on AB 32 by requiring CARB to ensure that statewide GHG emissions are reduced to 40% below 1990 levels by 2030. In 201, the State legislature also passed SB 605, directing CARB to develop a comprehensive strategy to combat short‐lived climate pollutants (SLCP). The draft SLCP strategy addresses organics diversion from landfills without specifying whether biosolids are included in this category. The strategy also references WWTPs as part of the solution due in large part to the potential for co‐digestion.

The most recently passed legislation, SB 1383, seeks to reduce SLCPs including methane emissions from landfills. The established goals under SB 1383 are 50% reduction in the level of statewide landfill disposal of organics (from 2014 levels) by 2020 and a 75% reduction by 2025. SB 1383 also encourages state agencies to consider and adopt policies and incentives to increase production and use of renewable gas (i.e., biogas), which could benefit WWTPs co‐digesting organics with sludge.

Following the passage of SB 1383, CARB published a revised draft SLCP Strategy and initiated a public comment period ending November 2016. The final SLCP Strategy will be released in 2017.

2.2.3 Renewable Energy Incentives and Regulations AB 32 set the goals of 33 percent renewable energy by 2020 and reduction of GHG emissions to 1990 levels by 2020. Governor Brown updated these goals in April 2015, issuing an executive order to establish a target of 40 percent below 1990 levels by 2030. Pursuant to these goals, CARB was

Final ‐ May 9, 2017 2‐4 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation directed to develop action plans. These action plans are discussed in detail in CARB’s Scoping Plan (CARB, 2014). Some of the most pertinent renewable energy incentives programs in California are now geared toward achieving stated goals and are as follows and further described below:

 Self‐generation Incentive Program (SGIP)  Renewables Portfolio Standard (RPS)  Low Carbon Fuel Standard (LCFS) Program  Cap and Trade Funding

Note that many of the incentive programs listed above stipulate that qualifying projects must work through investor‐owned utilities (IOUs) in order to gain access to funds. While the California Public Utilities Commission (CPUC) does not require participants to be customers, the utility itself will have every incentive to restrict awards to customers in its own service area in order to apply the resulting benefits to the IOU’s renewable energy production and efficiency commitments under state regulation.

2.2.3.1 Self‐Generation Incentive Program The CPUC established the Self‐Generation Incentive Program (SGIP) in 2001 to promote adoption of existing, new, and emerging distributed generation and combined heat and power (CHP) systems specifically to off‐set energy usage. SGIP is not intended to result in the net‐exportation of energy. From 2008 through September 2011, the only eligible technologies were fuel cells, wind turbines, and energy storage systems; however, on September 8, 2011, the CPUC modified the SGIP, including eligibility criteria and incentive amounts and payment structures for eligible technologies. Per the September 2011 modifications, eligibility for participation in the SGIP is based on GHG emissions reductions. Electric or gas customers of any of the major IOUs, including OCSD’s provider, Southern California Gas and Electric (SCE) are eligible.

2.2.3.2 Renewables Portfolio Standard Established in 2002 by the CPUC and the California Energy Commission (CEC), the Renewable Portfolio Standards (RPS) program was accelerated in 2006 by requiring that 20 percent of electricity retail sales be served by renewable energy resources by 2010. In 2009, CARB was directed to enact regulations to achieve the established goal of 33 percent renewable energy by 2020. The final codified regulation SB 2 (1X) of California State Senate, signed in 2011, preempts CARB’s 33 percent RPS by expanding the program to all electricity retailers in the state. The final RPS regulations require the publicly owned utilities (POUs), investor‐owned utilities (IOUs), electricity service providers, and community choice aggregators to adopt the new RPS goals of 20 percent of retail sales from renewable energy by the end of 2013, 25 percent by the end of 2016, and 33 percent by the end of 2020.

The electricity retailers may comply with RPS by owning a renewable energy facility, purchase of renewable energy credits (RECs), or purchase of electricity from a renewable‐energy‐generating facility. A facility using biogas to generate onsite electricity or production of biomethane for injection into a natural gas pipeline is eligible for California’s RPS; however, facilities with such systems are subject to additional resource‐ or fuel‐specific eligibility requirements.

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RECs represent renewable and environmental attributes associated with renewable energy production. Bundling RECs is a means of tethering renewably generated electricity to its environmental attributes so that the renewable energy can be tracked after it is commingled with other conventionally generated power on the grid. When RECs are sold or procured separately from the energy associated with them, they become “unbundled” RECs. Specifically, for WWTPs, unbundled RECs can be claimed for renewable generation that is consumed onsite at the treatment plant. For California RPS, a REC is a certificate of proof issued through the accounting system established by the CEC that one unit (1 MWh) of renewable energy was generated and delivered by an eligible renewable energy resource. A renewable energy facility must be certified as “RPS‐ eligible” by CEC for procurement from the facility to be counted towards an energy retailer’s RPS obligation.

2.2.3.3 Low Carbon Fuel Standard Program Pursuant to AB 32, the Low Carbon Fuel Program (LCFS) was implemented to achieve greenhouse gas emission reductions by reducing the full fuel‐cycle, carbon intensity1 (CI) of the transportation fuel pool used in California, by at least 10 percent by 2020. The lifecycle of a fuel includes the emissions associated with producing, transporting, distributing, and using the fuel. The regulation reduces lifecycle greenhouse gas emissions by assessing a CI score to each transportation fuel based on that fuel’s lifecycle assessment. Transportation fuels subject to the LCFS requirements include gasoline, diesel, and their substitutes and blends; this includes biogas compressed natural gas or biogas liquid natural gas.

CARB has developed separate pathways for anaerobic digestion of food waste and municipal sludge to low carbon transportation fuels (CARB 2014). Through these pathways, anaerobic digestion projects that result in the creation of biomethane fuel have a CI that could potentially be traded.

2.2.3.4 Cap and Trade Funding Part of California’s efforts to reduce GHG levels is the establishment of a cap and trade program. Covered entities are allotted a GHG budget, and may trade credits in the established marketplace in order to meet that budget. Funds from carbon credit sales are then used to support projects and programs that further state goals. Funding allocations vary from year to year, thus, OCSD’s ability to get funding support for co‐digestion efforts is expected to change over time. Cap and trade allocations to date, however, provide some indication of where POTWs may find funding. As of

1 Carbon intensity is the amount of lifecycle greenhouse gas emissions, per unit of energy of fuel delivered, expressed in grams of carbon dioxide equivalent per megajoule (gCO2E/MJ).

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September 2016, CARB has reported cumulative allocations in a few categories where funds could be accessed by WWTPs. Agencies charged with administering the funds, as well as the quantity allocated, have also been identified:  Transportation: CARB has allocated $325 million to support low carbon transportation and Caltrans has allocated $145 million for their low carbon transit operations program.  Clean energy and Energy Efficiency Funding: The California Department of Food and Agriculture (CDFA) has allocated $75 million to support the State Water Efficiency and Enhancement Program and the Department of Water Resources (DWR) has allocated $70 million for water and energy efficiency programs.  Natural Resources and Waste Diversion: CalRecycle has allocated $31 million for waste diversion programs and the Department of Forestry and Fire Prevention (DFFP) has allocated $42 million for urban forestry, forest health restoration and reforestation.

In the 2016/2017 fiscal year budget, Governor Brown has allocated cap and trade funds in the following key areas for WWTPs:  Transportation: ARB has been allocated $150 million to support low carbon transportation.  Natural Resources and Waste Diversion Funding: CalRecycle has been allocated $40 million for waste diversion programs and the DFFP has been allocated $42 million for urban forestry, forest health restoration and reforestation. The California Natural Resources Agency has been allocated $80 million towards urban greening programs.  General Agricultural Activities: CDFA has been allocated funds to support programs in three key areas: 1) methane reduction ($50 million), 2) Healthy Soils ($7.5 million), and 3) State Water Efficiency and Enhancement Program ($7.5 million).

2.2.3.5 CalRecycle Greenhouse Gas Reduction Grant and Loan Programs The Greenhouse Gas Reduction Fund (GGRF) was established in 2012 to receive Cap‐and‐Trade auction proceeds appropriated by the Legislature and Governor for projects that support the goals of AB 32. CalRecycle established the Greenhouse Gas Reduction Grant and Loan Programs to provide financial incentives for capital investments in infrastructure for anaerobic composting, anaerobic digestion and recycling and manufacturing facilities that will reduce greenhouse gas emissions. These grants promote California infrastructure developments that achieve greenhouse gas emissions reductions by diverting more materials from landfills and producing beneficial products such as soil amendments, renewable fuels or recycled‐content products.

2.2.3.6 Orange County Regional Recycling and Waste Reduction Grant Orange County Waste & Recycling partners with Orange County cities, special districts, non‐profit organizations and private entities to achieve statewide waste diversion goals. On September 27, 2016, the Board of Supervisors approved to release the Fourth Cycle of the Regional Recycling and Waste Reduction Grant. This competitive grant program provides potential partners with grant funding to develop sustainable programs that support compliance with state mandated diversion goals and promote increased regional recycling and diversion efforts.

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2.3 MARKET TRENDS Overall, the impact of the evolving state regulations on organics collection and recycling is significant. By 2020, a significant percentage of the organics in the state will be diverted from landfills under AB 1826 and SB 1383. The bulk of any remaining organics will be diverted from landfills further through SB 1383 by 2025. Furthermore, CalRecycle and CARB have the ability to enact more stringent regulations if it is apparent that goals are not being met. While much of the currently diverted organics are being accommodated in existing composting infrastructure, it is clear that additional composting capacity as well as other outlets will need to be developed to receive these diverted organics. In effect, California has created an organics marketplace, with the opportunity for low‐solids anaerobic digestion as found at WWTPs to play a significant role, as shown in Figure 2‐2.

Figure 2‐2. Pathways/Markets for Organics Resulting from AB 1826 and SB 1383 for Low‐Solids Anaerobic Digestion

Currently green waste and woody waste are generally being diverted to existing or converted compost infrastructure. The shuttering of several waste‐to‐energy plants that accepted woody waste has increased the amount of this waste in the marketplace, making it abundantly available to composters. Food waste/SSO is more difficult to incorporate into existing composting infrastructure, and anaerobic digestion is a proven, reliable, and effective technology for co‐ digestion of organic wastes. There are significant potential benefits with anaerobic digestion in terms of additional digester gas production, onsite power production, and generation while maintaining a quality end product for beneficial reuse. /management

Final ‐ May 9, 2017 2‐8 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation partners were identified through an outreach effort conducted under this task. Major partners in the region are discussed in Section 4.

Several WWTPs have been accepting HSW for a number of years, most notably the East Bay Municipal Utility District (EBMUD), which accepts all forms of HSW and largely powers their treatment plant on the additional biogas derived from co‐digestion. A photo of digesters at EBMUD is given in Figure 2‐3. More locally, Los Angeles County Sanitation District (LACSD) has been running a successful pilot program in partnership with Waste Management. Increased biogas yields and continued stable digestion have led LACSD to examine an expansion of the co‐digestion program. A number of FOG‐for‐co‐digestion programs are well established throughout the state as well, and the model for food waste acceptance is expected to develop similarly. Currently, tip fees associated with waste acceptance range from $21‐$98/wet ton for pre‐processed food waste. Figure 2‐4 illustrates the facilities in California that currently accept food waste and their associated tipping fees. As noted in the figure, most of the facilities are located in Northern California’s Bay Area. Each wet ton of pre‐processed SSO accepted can generally be said to generate an additional 3,000 standard cubic feet (scf) of digester gas for beneficial use.

The market for food waste is still in its infancy, but is expected to develop rapidly as regulatory restrictions on landfill disposal are triggered. Generally, WWTPs can be said to have an important role in landfill diversion of organics, as SSO is generally too wet and volatile for immediate composting. Challenges can reasonably be expected from lack of knowledge on the part of the solid waste industry regarding the wastewater treatment process, and vice versa.

Figure 2‐3. Digesters at EBMUD’s Main WWTP Used for Co‐Digestion of HSW

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Figure 2‐4. A Map of Facilities Accepting Food Waste in California

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3.0 High Strength Organic Waste Characteristics and Sources There are three general categories of co‐digestion feedstocks: 1) liquid high strength waste and FOG, 2) SSO/food waste, and 3) the organic fraction of municipal solid waste (not SSO). FOG is already being received by OCSD; a quantity of approximately 600,000 gallons per month. FOG enters the headworks of Plant No. 1, and then is skimmed from clarifiers, co‐mingled with sludge, and digested in Plant No. 2. During the course of this task, the BV/BC team discussed the possibility of moving the FOG receiving point to the proposed food waste receiving facility. Such a move would have the benefit of providing additional material for digestion, and the change would be an easy division from the existing septage and FOG receiving facility. However, FOG typically occupies more of the available organic loading capacity and would mean that multiple types of haulers would be accessing the facility. It was thus decided to preserve the receiving facility as a pre‐processed SSO receiving facility and continue the FOG receiving program as is. 3.1 GENERAL CHARACTERISTICS As discussed previously, the focus of this study was on SSO (food waste). Early on in the planning process, OCSD identified this as a partnership opportunity that could provide sufficient and reliable quantities of pre‐processed SSO feedstock to generate biogas on a long‐term basis. This section describes the characteristics of the pre‐processed food waste that would be anticipated for OCSD’s facilities. It is possible that OCSD may choose to receive minor amounts of FOG in the future; those characteristics are discussed briefly, but FOG is not the focus of this study.

The HSW is expected to comprise of slurried food waste, hereafter called pre‐processed SSO, and incidental quantities of FOG. The pre‐processed SSO is expected to range in solids concentration from 12‐15 percent, and may vary in pH ranging from 3.0 to 7.0, with the expected pH value being around 5.0. As part of the development of the pre‐processed SSO receiving program, it is assumed that OCSD will develop standards for quality related to minimum screen size, debris removal rates, and presence/absence of manufactured inerts. Generation of the pre‐processed SSO will be accomplished by a third party, off‐site. Raw SSO will be processed into an organic feedstock, nearly free of contaminants, pulped, extruded, and/or slurried into a pumpable liquid. Appendix E summarizes the SSO requirements that the LACSD has developed for its pre‐processed SSO receiving program. Other pertinent requirements include OCSD’s heavy metals limitations that were developed for receipt of outside wastes under its pretreatment program. Finally, recent requirements developed by CalRecycle under its new composting regulations (CCR Title 14, Chapter 3.1 Section 17868) is included to provide some guidance on physical contamination requirements which OCSD may wish to incorporate (Appendix E). Viewed as a whole, these can be used as a guide for the desired feedstock quality for the partners that will provide OCSD with pre‐ processed SSO. 3.2 PRE‐PROCESSED SSO DESIGN ASSUMPTIONS OCSD has recently completed a laboratory food waste study to better understand the characteristics and digestibility of pre‐processed SSO (OCSD 2013). These data, in addition to data collected from other food waste projects, were used to define the general pre‐processed SSO characteristics presented in Table 3‐1. These characteristics were used in the capacity calculations discussed in Section 5.

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Table 3‐1. General Characteristics of Pre‐Processed SSO Used for OCSD Planning PARAMETER UNITS EXPECTED VALUE pH 5.0 Specific gravity 1.05 ‐ 1.20 Gallons of pre‐processed gal/wet tons 200 – 230 SSO to wet tons delivered Total solids % 12 – 15 concentration Volatile fraction lb‐VS/lb‐TS 0.85 mg‐N/L 2,541 Total Kjeldahl Nitrogen lb‐N/lb‐TS 0.021

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4.0 Orange County’s Organic Waste Stakeholders Several large waste management companies are responsible for the collection and hauling of solid waste within Orange County and the greater Southern California region. As part of Task 5, OCSD held a workshop on June 14, 2016 to identify organic waste stakeholders and receive feedback on a proposed co‐digestion program. The attendee list, presentation slides, and other documentation for this workshop have been provided as Appendix A. 4.1 ORANGE COUNTY SOLID WASTE OVERVIEW The Orange County Waste and Recycling (OCWR) operates landfills within the County and coordinates waste collection with the designated haulers for the communities within Orange County. The Prima Deshecha landfill is used by OCSD for biosolids disposal as needed, and OCWR operates two additional active landfills, Frank R Bowerman Landfill in Irvine and Olinda Landfill in Brea. Santiago Canyon is an inactive landfill which Orange County may use for a proposed compost facility. While OCWR does not control the solids waste stream, it does have agreements with the five major waste haulers in the county, and is an important partner for OCSD’s overall biosolids management now and in the future.

The five major haulers with whom OCWR contracts are:

 Republic Services,  CR&R Incorporated,  Waste Management (WM),  Rainbow Environmental Services, and  Valley Vista Services.

OCSD has met with each of these haulers to discuss potential partnerships. The approximate service areas of each are shown in Figure 4‐1. Of these, the largest with respect to population served and hence, solid waste volume, are Republic Services, WM, and CR&R. These are discussed below.

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Figure 4‐1. Waste Haulers Serving Orange County and Their Approximate Service Areas

4.2 REPUBLIC SERVICES Republic Services has an approximate 40% market share in Orange County. They are in the process of developing a pre‐processing facility, but are currently hauling SSO to WM’s transfer facility in Orange, which ultimately feeds the LACSD food waste system. Quantities of organic waste available for co‐digestion at OCSD from Republic Services may range from 100 to 500 wet tons per day (wtpd), and they have indicated a willingness to partner with OCSD. Depending on the equipment used to pre‐process SSO, the pre‐processed SSO can be in form of paste (with higher solids content) or slurry (with lower solids content). Note that the SSO collected is of a higher total solids (TS) content than the processed slurry, to which water is added. Thus the paste or slurry output, which is what would be received by OCSD, has a greater mass than the SSO input. Republic Services has indicated the intention of proceeding with development of pre‐processed SSO as a paste; however, additional infrastructure would be required to adequately receive and slurry the paste product into a pumpable form. This evaluation assumes that the pre‐processed SSO being delivered to OCSD is in slurry. Estimated volumes of pre‐processed SSO from Republic Services are approximately 380 wet

Final ‐ May 9, 2017 4‐2 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation tons (as received by OCSD) per day; it is anticipated that these would be available in January 2019 based on AB 1826 triggers. 4.3 WASTE MANAGEMENT Within Orange County, WM has a slightly smaller market share than Republic Services. WM has, however, invested in the development of a pre‐processing solution called CORe, which stands for “Centralized Organics Recycle and Energy”. CORe generates an “engineered BioSlurry”, with a TS content between 13‐16%. This slurry is what is currently being received at LACSD’s WWTP. WM estimates volumes of pre‐processed SSO that could be diverted to OCSD at between 100 to 250 wtpd and has indicated a willingness to partner with OCSD on a co‐digestion project. 4.4 CR&R INCORPORATED CR&R Incorporated, like WM, has developed its own pre‐processing solution. The company has constructed a high solids anaerobic digestion facility in Perris, California with the purpose of digesting primarily green waste but co‐mingled with pre‐processed SSO. Digester gas generated at the facility will be cleaned and compressed for use as fuel. CR&R has indicated that they are not interested in partnering with OCSD at this time for pre‐processed SSO, but is interested in other opportunities. 4.5 FINDINGS OCWR is an important partner with OCSD, providing a logical link between waste haulers and OCSD. In addition, OCWR is about to issue a Request for Proposals (RFP) for the development of a compost site at the Santiago Canyon Landfill, located in Santiago Canyon. OCSD has met with OCWR to discuss the possibility of sending biosolids to this potential compost option. Of the major waste haulers, WM and Republic Services appear to be likely co‐digestion partners, generating between 200‐700 wtpd of pre‐processed SSO.

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5.0 Capacity and Constraints The acceptance of supplemental organics for co‐digestion for the purposes of energy generation is a relatively new practice to the wastewater industry. In the last 10 years, in California specifically, this practice has greatly expanded, especially in the acceptance of food waste. Much of this effort has been taken on by pioneering utilities that have developed programs organically, through incremental and targeted acceptance of additional supplemental feedstocks. As such, industry‐wide understanding of process loading limits, process impacts, and biosolids changes remains relatively undefined, limiting guidance to engineers and practitioners. 5.1 OCSD CO‐DIGESTION GOALS OCSD has set clear goals for the co‐digestion analysis. Essentially, OCSD would like to utilize any spare digester capacity without exceeding acceptable hydraulic or organic loading rates. OCSD’s second stated goal is to utilize any spare capacity at the CenGen facility to maximize energy recovery from digester gas. Thus, OCSD would not wish to receive quantities of pre‐processed SSO that would generate biogas in excess of what can be managed at CenGen. These two goals set upper bounds for the quantities of pre‐processed SSO that can potentially be received at OCSD’s two WWTPs. 5.2 GENERAL CO‐DIGESTION PROCESS LIMITATIONS While controlled full‐scale research and testing is still very limited, an overview of the current industry literature can demonstrate the potential of the co‐digestion of supplemental feedstocks. Bench‐scale studies by EBMUD demonstrated that food waste could be digested at more than double typical loading rates for mesophilic digestion (Gray et al. 2008). Others have reported maximum stable digestion at 75% of the volatile solids (VS) load as food waste (Park 2014). Carucci et al. (2005) reported that when fruit and vegetable wastes were mixed with cooked meat waste, digestion improved over digestion of the components alone, further complicating the issue of loading rates to anaerobic digesters.

The addition of food waste and other organics has a growing body of evidence that synergistic benefits to co‐digestion are real. Aichinger et al. (2015) reported synergistic enhancement of sludge digestion with the addition of food waste at loads up to 20% of the volatile solids load, reducing overall sludge production from two full‐scale facilities. The influence of synergy on overall process performance needs further research but once defined, effectively could provide another metric to evaluate the overall scope of a co‐digestion program. The avoidance of additional solids through synergistic digestion enhancement could increase the margin between accepted tip fee and cost to treat.

OCSD sponsored research conducted through Bucknell (OCSD 2013) which evaluated loading rates, gas production, and odors from co‐digestion. Food waste was co‐digested with OCSD sludge in pilot scale digesters at 25%, 45%, and 65% of the COD loading rate. Stable digestion was observed, along with increased gas production rates that appeared to indicate a modest synergistic effect from the addition of food waste. Due to limited information available in the industry, this study assumed that no synergistic enhancement of digestion with the addition of food waste would occur, and it is recommended that investigation into digestion performance continue.

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5.2.1 LACSD Co‐Digestion LACSD entered into a two‐year agreement with WM to demonstrate co‐digestion of pre‐processed SSO in an existing digester at their Joint Water Pollution Control Plant (JWPCP) at a target importation rate of 20,000 gallons per day (87 wtpd). The design pre‐processed SSO loading rate to the digester for the demonstration project represented up to 10% of the total digester load on a hydraulic basis and up to 30% of the total load to the digester on a solids basis. The demonstration project was successful and no process or operational problems were encountered. Based on the results of the demonstration project, LACSD estimated that adding 10‐12% pre‐processed SSO (food waste slurry) to their digester on a hydraulic (pre‐processed SSO volume to total volume) basis may double biogas production.

5.2.2 EBMUD Co‐Digestion EBMUD has been at the forefront of co‐digestion since beginning their Resource Recovery (R2) program in the early 2000’s. The R2 program was initially very successful – bringing in FOG and other high‐strength liquid wastes from all over the San Francisco Bay Area. EBMUD research and operational experience suggested that FOG loading was limited to less than 50% of overall VS loading for stable digestion. As other WWTPs in the Bay Area constructed FOG receiving facilities and began accepting loads, EBMUD turned to other sources of high strength waste such as food waste and green waste, while still accepting FOG and various liquid high‐strength wastes. Green waste proved to be the less desirable co‐digestion feedstock, whereas food waste has significant potential due to gas production and market drivers.

Co‐digestion feedstocks typically account for about 50% of EBMUD’s digester VS loading. Digester gas production has more‐than‐doubled, allowing EBMUD to regularly generate more power than is required to operate the WWTP. EBMUD operates a two‐stage, thermophilic digestion process with hydraulic retention time (HRT) regularly below 20 days. EBMUD has piloted the same process at a 10‐day HRT and demonstrated Class B equivalency. 5.3 DATA AND ASSUMPTIONS Digester capacities for pre‐processed SSO co‐digestion were evaluated for both Plant No. 1 and 2. This involved examining available digestion processing capacity and CenGen capacity (to accommodate additional biogas) at both plants, per OCSD’s stated goals. The detailed calculations are given in Appendix B (enclosed Flash Drive) and published as hard copies at the end of TM‐5. This assessment is described in the subsections that follow.

5.3.1 Evaluation Conditions and Solids Projections Digesters at Plant No. 1 will continue to operate at mesophilic conditions while the new temperature phased anaerobic digestion (TPAD) facility will be built and commenced by the end of 2028 at Plant No. 2. Therefore, solids loadings to the digesters were evaluated for design years 2018 through 2045 for Plant No. 1. Digester capacity evaluations at plant No. 2 were conducted for two separate periods: before and after the TPAD operation. From 2018 to 2028, the existing digesters will operate at mesophilic condition, and from 2029 to 2045 the new digesters will operate in TPAD operation. Solids projections for each year during the evaluation periods were estimated assuming linear growth rates from current conditions to future design conditions.

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For future solids loadings, three different projected conditions were assessed inTM‐1 and further examined during this task.

 Condition 1 assumes a flow split between Plant No. 1 and Plant No. 2 that will allow Plant No. 1 to maximize reclaimed water production. Accordingly, the 2035 flow to Plant No. 1 is 125 mgd, thus allowing Plant No. 1 to maximize reclaimed water production. The remaining flow, 75 mgd, is diverted to Plant No. 2.  Condition 2 assumes the total OCSD influent flow is split equally between the two plants. By 2035, each plant will receive approximately 100 mgd flow.  Condition 3 assumes the solids flows and loads produced from the Plant No. 2 primary and secondary process assuming the liquid stream processes are operated at their design capacity.

Condition 3 represents the maximum solids loading condition, and in order to prevent the solids process capacity from limiting the flows the plant can treat, this condition was used for solids process sizing. Conditions 1 and 2 were used to assess digester capacity of pre‐processed SSO co‐ digestion.

Plant No. 1 currently receives wastewater and sludge from the Michaelson Water Reclamation Plant (MWRP). Plant No. 1 also diverts a portion of its primary sludge to Plant No. 2 for processing during the construction of a new co‐thickening facility. MWRP sludge acceptance at Plant No. 1 and sludge diversion to Plant No. 2 are planned to stop in 2018 as MWRP will begin to processing the solids and the co‐thickening facility will be on‐line at Plant No. 1. Therefore, sludge productions for current conditions were adjusted accordingly to reflect the results of planned operation changes.

Solids flows and loads for current condition at Plant No. 1 were based on Treatment Plant Operational Data Summary (TPODs) 2016 values assuming incoming sludge from MWRP sludge and diversion to Plant No. 2 has stopped. For Plant No. 2, plant influent flows, solids productions, and sludge diversion from Plant No. 1 have changed significantly over the past years. After discussions with OCSD staff, 2016 values without sludge diversion from Plant No. 1 were used as current condition for solids projection under Condition 1; while 2014 values without sludge diversion from Plant No. 1 were used as current condition for solids projection under Condition 2.

Solids flows and loads from current condition to 2035 were interpolated assuming linear growth rate. Solids flows and load from 2035 to 2045 were extrapolated assuming the same growth rate with the exception for Plant No. 2 under Condition 1, where solids flows and loads beyond 2035 were assumed to remain the same as 2035, because the plant would have reached the design capacity.

5.3.1.1 Sludge from MWRP Currently, the MWRP discharges part of their flows, including their primary and secondary sludge to the headwork of Plant No. 1, which is planned to stop by 2018. Once the sludge discharge from MWRP enters the headwork, a portion of it is removed from the primary clarifiers as primary sludge. Most of the reminder total suspended solids (TSS), volatile suspended solids (VSS), and biochemical oxygen demand (BOD) will be removed in the secondary process as WAS. Therefore,

Final ‐ May 9, 2017 5‐3 Biosolids Master Plan TM‐5: High Strength Organic Waste Co‐Digestion Evaluation | Orange County Sanitation District both primary sludge and waste activated sludge (WAS) productions Plant No. 1 will be impacted after the MWRP sludge discharge stop.

Current MWRP sludge TSS BOD loads to Plant No. 1 at annual average condition are shown in Table 5‐1.

Table 5‐1. TSS and BOD Loads of MWRP Sludge Discharged to Plant No. 1 in 2016 at Annual Average Condition PARAMETER UNIT VALUE TSS ppd 67,800

BOD ppd 36,800

The following liquid process performance parameters (Table 5‐2) were used to analyze the impact of MWRP sludge discharge on Plant No. 1 solids production. These parameters were based on annual average TOPDs data.

Table 5‐2. Liquid Treatment Process Performance at Plant No. 1 PARAMETER UNIT VALUE Primary Clarifier Removal Efficiency TSS % 75 BOD % 50 WAS Yield Coefficient g VSS/g BOD removed 0.85 WAS VSS/TSS % 80 Note: Based on TPODs data.

5.3.1.2 Sludge Diversion from Plant No. 1 to Plant No. 2 Currently, Plant No. 1 diverts a portion of its primary sludge to the headwork of Plant No. 2, which is planned to stop by the end of 2018. Similar approaches were used to estimated its impacts on Plant No. 2 sludge production.

BOD and TSS loads of Plant No. 1 sludge diversion to Plant No. 2 at annual average condition are summarized in Table 5‐3.

Table 5‐3. TSS and BOD Loads of Plant No. 1 Sludge Diversion to Plant No. 2 at Annual Average Conditions PARAMETER UNIT 2014 2016 TSS ppd 27,400 124,300 BOD ppd 14,800 67,300

The liquid process performance parameters used to analyze the impacts of sludge diversion on Plant No. 2 solids production were summarized in Table 5‐4. These parameters are based on TPODS data and the White Paper at annual average condition.

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Table 5‐4. Liquid Treatment Process Performance at Plant No. 2 PARAMETER UNIT VALUE Primary Clarifier Removal Efficiency TSS % 75 BOD % 60 WAS Yield Coefficient g VSS/g BOD removed 1.1 WAS VSS/TSS % 85 Note: Based on White Paper.

5.3.1.3 Solids Flows and Loads Used for Digester Capacity Analysis With the data and assumptions described previously in this section, solids flows and loads used for digester capacity analysis at annual average conditions are summarized in Table 5‐5. Solids flows and loads for current conditions were estimated assuming sludge discharge from MWRP and sludge diversion from Plant No. 1 to Plant No. 2 have stopped.

Table 5‐5. Summary of Solids Flows and Loads for Digester Capacity Analysis at Annual Average Conditions PLANT NO. 1 PLANT NO. 2 CONDITION PARAMETER CONDITION 1 CONDITION 2 CONDITION 1 CONDITION 2 Total Solids, ppd 304,000 304,000 212,000 290,000 Current1,2,3 Volatile solids, ppd 243,000 243,000 158,000 218,000 Solids Flow, gpd 607,000 607,000 551,000 736,000 Total Solids, ppd 387,000 307,000 259,000 334,000 Future, Volatile solids, ppd 310,000 246,000 197,000 254,000 2035 Solids Flow, gpd 774,000 614,000 655,000 843,000 Total Solids, ppd 387,000 310,000 272,000 339,000 Future, Volatile solids, ppd 310,000 248,000 218,000 271,000 20455 Solids Flow, gpd 774,000 618,000 710,000 894,000 Notes: 1. Current solids flows and loads for Plant No. 1 were estimated assuming MWRP stops discharging sludge to Plant No. 2. Current solids flows and loads for Plant No. 2 were estimated assuming Plant No. 1 stops diverting sludge to Plant No. 3. Current condition solids flows and loads at Plant No. 2 for Condition 1 were based on 2016 data since the plant influent split for 2014 represents that of Condition 1. 4. Current condition solids flows and loads at Plant No. 2 for Condition 2 were based on 2014 data since the plant influent split for 2014 represents that of Condition 2. 5. 2045 solids flows and loads were extrapolated assuming the same growth rates as those from current condition to 2035 except for Plant No. 1 Condition 1, which is assumed to reach the maximum plant capacity in 2035.

5.3.1.4 Digester Loading Rates Used for Digester Capacity Analysis Each of the scenarios described above was evaluated on a HRT and organic loading rate (OLR) basis; the more restrictive of these two loading conditions determines available digestion capacity.

Final ‐ May 9, 2017 5‐5 Biosolids Master Plan TM‐5: High Strength Organic Waste Co‐Digestion Evaluation | Orange County Sanitation District

Flows and loads at the peak 15‐day conditions were used to assess digester capacity for co‐ digestion.

The design criteria used for minimum HRT and maximum OLR at the peak 15‐day conditions are summarized in Table 5‐6. Table 5‐7 presents the assumed food waste characteristics used for the capacity assessment. Further details, assumptions, and calculations are presented in Appendix B for each scenario.

Table 5‐6. Summary of Key Assumptions for Each Scenario1 PLANT NO. 2, PLANT NO. 2, PLANT NO. 2, TPAD – PLANT NO. 1, MESOPHILIC TPAD – MESO DESIGN CRITERIA THERMO MESOPHILIC2 (BEFORE DIGESTERS DIGESTERS 2028)3 (AFTER 2028)4 (AFTER 2028)4 Typical Minimum 18 18 Condition HRT (days)

Maximum OLR 0.15 0.15 (lbs/cf/day)

Service Minimum 16 16 8 7 Condition HRT (days)

Maximum OLR 0.15 0.15 0.35 N/A (lbs/cf/day) Notes: 1. Peak 15‐day solids flows and loads for all conditions. 2. One large digester out of service for typical condition. Two large digesters out of service for service condition. 3. Two large digesters out of service for typical condition. Two large and one small digesters out of service for service condition. 4. One thermophilic digester out of service for typical condition. Two thermophilic and one large mesophilic digesters out of service for service condition.

Table 5‐7. Assumed Characteristics of Pre‐Processed SSO ASSUMED VALUE, PARAMETER PRE‐PROCESSED SSO % TS1 12%

% VS 85%

% VSR 80%

SG 1.2 Note: 1. Solids content of pre‐processed SSO may vary. 12% TS is based on the reported value for pre‐processed SSO from Republic Services and represents a more conservative hydraulic loading impact.

Final ‐ May 9, 2017 5‐6 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

5.4 PLANT NO. 1 CAPACITY ANALYSIS A major rehabilitation of digesters at Plant No. 1 was completed in 2016 under project P1‐100. The project included replacement of aging sludge pumping, heating, and other structural, mechanical, electrical and control systems to improve reliability, increase existing treatment capacity and restore lost digester capacity. However, even with the restored additional capacity, some primary sludge from Plant No. 1 is diverted to Plant No. 2 due to inadequate HRT capacity. Therefore, Plant No. 1 does not currently have digester capacity for pre‐processed SSO co‐digestion.

New WAS thickening facilities under project P1‐101 are scheduled for completion and startup in 2018. Upon completion of P1‐101, sludge diversion to Plant No. 2 will stop and the total solids content of digester feed sludge will increase to 6 percent in 2018. Calculations indicate that both the HRT and the OLR of the digesters will be at or close to the design loading rates at Plant No. 1 after 2018. Detailed calculation for Plant No. 1 digester capacity evaluation can be found in Appendix B.3.1. Therefore, there will be no excess digester capacity at Plant No. 1 for pre‐processed SSO co‐digestion in the future without adding digester capacity. 5.5 PLANT NO. 2 CAPACITY ANALYSIS At Plant No. 2, it is assumed that the digestion operation will convert from mesophilic digestion to TPAD and that the new digesters will be in operation by the end of 2028. Therefore, evaluations for available digester capacities for Plant No. 2 were conducted for both mesophilic operation and TPAD operation under both Condition 1 and Condition 2 solids flows and loads. Using the design criteria in Table 5‐6, the results show that Plant No. 2 has excess digester capacity for pre‐ processed SSO co‐digestion for both mesophilic and TPAD operations.

Digester capacities at both typical condition and service condition were evaluated on a HRT and organic loading rate (OLR) basis; the more restrictive condition determines available digester capacity for co‐digestion. Flows and loads at the peak 15‐day conditions were used to assess digester capacity for co‐digestion.

5.5.1 Plant 2 Digester Capacity Evaluation Conditions under Mesophilic Operation with Existing Digesters The amounts of pre‐processed SSO that can be co‐digested from 2019 to 2028 under mesophilic operation are shown in Table 5‐8Error! Reference source not found. for Condition 1 and Table 5‐ 9 for Condition 2. The OLR at the service condition is the limiting factor for Condition 1. For Condition 2, the OLR at the service condition is the limiting factor until 2023; then the HRT at the typical condition becomes the limiting factor.

By 2028, the available digester capacity can accommodate approximately 137 (Condition 2) to 582 (Condition 1) wtpd of pre‐processed SSO under mesophilic digestion operation. Detailed calculation for Plant No. 2 digester capacity evaluation under mesophilic digestion can be found in Appendix B.3.2.

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Table 5‐8. Summary of Pre‐Processed SSO Quantities that can be Co‐digested at Plant No. 2 under Mesophilic Operation under Condition 1, wtpd1 PRE‐PROCESSED SSO YEAR TYPICAL CONDITION2 SERVICE CONDITION3 FOR CO‐DIGESTION HRT Based OLR Based HRT Based OLR Based 2019 1,578 800 1,860 693 693 2020 1,545 787 1,827 680 680 2021 1,512 775 1,794 668 668 2020 1,479 763 1,761 656 656 2023 1,446 751 1,728 644 644 2324 1,413 738 1,695 631 631 2025 1,381 726 1,663 619 619 2026 1,348 714 1,630 607 607 2027 1,315 702 1,597 595 595 2028 1,282 690 1,564 582 582 Notes: 1. Refer to Appendix B.3.2 for detailed calculations. 2. Two large digesters out of service for typical condition. 3. Two large and one small digesters out of service for service condition.

Table 5‐9. Summary of Pre‐Processed SSO Quantities that can be Co‐digested at Plant No. 2 under Mesophilic Operation under Condition 2, wtpd1 PRE‐PROCESSED SSO YEAR TYPICAL CONDITION2 SERVICE CONDITION3 FOR CO‐DIGESTION HRT Based OLR Based HRT Based OLR Based 2019 413 431 695 324 324 2020 382 421 664 314 314 2021 351 411 633 304 304 2020 321 401 603 294 294 2023 290 391 572 283 283 2324 260 380 542 273 260 2025 229 370 511 263 229 2026 198 360 480 253 198 2027 168 350 450 243 168 2028 137 340 419 233 137 Notes: 1. Refer to Appendix B.3.2 for detailed calculations. 2. Two large digesters out of service for typical condition. 3. Two large and one small digesters out of service for service condition.

Final ‐ May 9, 2017 5‐8 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

5.5.2 Plant 2 Digester Capacity Evaluation Conditions under TPAD Operation with New Digesters The amounts of pre‐processed SSO that can be co‐digested from 2029 to 2045 under TPAD operation are shown in Table 5‐10 for Condition 1 and Table 5‐12 for Condition 2. Since most volatile solids reduction occurs at the thermophilic phase, only the HRT was checked against the mesophilic phase digesters. The OLR at the service condition for the thermophilic phase digesters is the limiting factor under Condition 1, while the OLR at the typical condition for the thermophilic phase digesters is the limiting factor for Condition 2 until 2036, when the HRT at the typical condition for the thermophilic phase digesters becomes the limiting factor.

By 2045, the available digester capacity can accommodate approximately 320 (Condition 2) to 810 (Condition 1) wtpd of pre‐processed SSO under TPAD operation. Detailed calculation for Plant No. 2 digester capacity evaluation under TPAD operation can be found in Appendix B.3.4.

Table 5‐10. Summary of Pre‐Processed SSO Quantities that can be Co‐digested at Plant No. 2 under TPAD Operation under Condition 1, wtpd1 YEAR THERMOPHILIC THERMOPHILIC MESOPHILIC DIGESTER4 PRE‐PROCESSED DIGESTER TYPICAL DIGESTER SERVICE SSO FOR CO‐ CONDITION2 CONDITION3 DIGESTION HRT Based OLR Based HRT OLR Typical Service Based Based Condition5 Condition6 2029 2,588 1,523 1,955 1,002 2,955 2,429 1,002 2030 2,555 1,511 1,923 989 2,922 2,396 989 2031 2,522 1,499 1,890 977 2,889 2,363 977 2032 2,489 1,487 1,857 965 2,856 2,331 965 2033 2,456 1,474 1,824 953 2,823 2,298 953 2334 2,423 1,462 1,791 940 2,791 2,265 940 2035 2,391 1,450 1,758 928 2,758 2,232 928 2036 2,358 1,438 1,725 916 2,725 2,199 916 2037 2,325 1,425 1,692 904 2,692 2,166 904 2038 2,292 1,413 1,660 891 2,659 2,133 891 2039 2,259 1,401 1,627 879 2,626 2,100 879 2040 2,226 1,389 1,594 867 2,593 2,068 867 2041 2,193 1,376 1,561 855 2,560 2,035 855 2042 2,160 1,364 1,528 843 2,528 2,002 843 2043 2,128 1,352 1,495 830 2,495 1,969 830 2044 2,095 1,340 1,462 818 2,462 1,936 818 2045 2,062 1,328 1,429 806 2,429 1,903 806 Notes: 1. Refer to Appendix B.3.4 for detailed calculations. 2. One thermophilic digester out of service for typical condition. 3. Two thermophilic digesters out of service for service condition. 4. Only HRT was evaluated for mesophilic digesters. 5. All mesophilic digesters in service for typical condition. 6. One large mesophilic digester out of service for service condition.

Final ‐ May 9, 2017 5‐9 Biosolids Master Plan TM‐5: High Strength Organic Waste Co‐Digestion Evaluation | Orange County Sanitation District

Table 5‐11. Summary of Pre‐Processed SSO Quantities that can be Co‐digested at Plant No. 2 under TPAD Operation under Condition 2, wtpd1 YEAR THERMOPHILIC THERMOPHILIC MESOPHILIC DIGESTER4 PRE‐PROCESSED DIGESTER TYPICAL DIGESTER SERVICE SSO FOR CO‐ CONDITION2 CONDITION3 DIGESTION HRT Based OLR Based HRT OLR Typical Service Based Based Condition5 Condition6 2029 1,445 1,176 813 654 1,812 1,287 654 2030 1,415 1,165 782 644 1,782 1,256 644 2031 1,384 1,155 752 634 1,751 1,225 634 2032 1,353 1,145 721 623 1,721 1,195 623 2033 1,323 1,135 691 613 1,690 1,164 613 2334 1,292 1,125 660 603 1,659 1,134 603 2035 1,262 1,115 629 593 1,629 1,103 593 2036 1,231 1,104 599 583 1,598 1,072 583 2037 1,200 1,094 568 573 1,568 1,042 568 2038 1,170 1,084 537 562 1,537 1,011 537 2039 1,139 1,074 507 552 1,506 981 507 2040 1,109 1,064 476 542 1,476 950 476 2041 1,078 1,054 446 532 1,445 919 446 2042 1,047 1,043 415 522 1,415 889 415 2043 1,017 1,033 384 512 1,384 858 384 2044 986 1,023 354 501 1,353 828 354 2045 956 1,013 323 491 1,323 797 323 Notes: 1. Refer to Appendix B.3.4 for detailed calculations. 2. One thermophilic digester out of service for typical condition. 3. Two thermophilic digesters out of service for service condition. 4. Only HRT was evaluated for mesophilic digesters. 5. All mesophilic digesters in service for typical condition. 6. One large mesophilic digester out of service for service condition.

5.6 DIGESTER GAS PRODUCTION WITH FOOD WASTE In accordance with OCSD’s second goal of CenGen utilization, the amount of biogas produced from the increased solids loads and pre‐processed SSO co‐digestion was evaluated to determine potential impacts to future digester gas facilities under J‐124 and to assess whether the CenGen system can accommodate the increased biogas production.

Final ‐ May 9, 2017 5‐10 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

The following assumptions were made for digester gas estimation:

 Digester operation will convert from mesophilic digestion to TPAD in 2028 after new digesters are in service for Plant No. 2.  Sludge volatile solids reduction (VSR) are 57% for mesophilic and 61% for TPAD operation.  All pre‐processed SSO (food waste) imports go to Plant No. 2.  Pre‐processed SSO VSR is 80% regardless of digester operating conditions.

 Digester gas yield rate is 15 cubic feet per pound of volatile solids destructed (cf/lb VSd) during digestion.  This study assumed that no synergistic enhancement of digestion with the addition of food waste would occur.  An interim pre‐processed SSO receiving facility will be built to get OCSD start the cod‐ digestion program with existing mesophilic digestion. The designed capacity for the receiving facility will be 250 wtpd, while initially contracting to receive no more than 150 wtpd.

 An ultimate pre‐processed SSO receiving facility will be built after the digestion operation is converted to TPAD. The designed capacity of the receiving facility will be 500 wtpd, while the contract should allow OCSD to take less pre‐processed SSO under certain conditions.

Based on the above assumptions, it was estimated that each gallon of pre‐processed SSO will produce approximately 12 scfm digester gas. Digester gas productions from Plant No. 1 and Plant No. 2 are estimated. Digester gas productions at 2028 (mesophilic digestion at Plant No. 2 with the interim pre‐processed SSO receiving facility) and 2045 (TPAD digestion at Plant No. 2 with the ultimate pre‐processed SSO receiving facility) are presented in the following sections. Detailed calculations can be found in Appendix B.3.2 and Appendix B.3.4.

For the interim facility, two conditions were evaluated to project digester gas production for both Plant No. 1 and Plant No. 2 in 2028, as follows:

 Digester gas production for Plant No. 1 and Plant No. 2 under TM‐1 Loading Condition 1. For Condition 1, the food waste imported to Plant No. 2 is 250 wtpd based on the maximum capacity for the interim pre‐processed SSO receiving facility. This pre‐processed SSO quantity is less than the maximum allowable pre‐processed SSO for Plant No. 2 digesters shown in Table 5‐8. The results for Condition 1 are given in Table 5‐12. Detailed calculations can be found in Appendix B.3.2.  Digester gas production for Plant No. 1 and Plant No. 2 under TM‐1 Loading Condition 2. For Condition 2, the pre‐processed SSO imported to Plant No. 2 is 137 wtpd based on the maximum allowable pre‐processed SSO for Plant No. 2 digesters in Year 2045 shown in Table 5‐8. The results for Condition 2 are given in Table 5‐13. Detailed calculations can be found in Appendix B.3.2.

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Table 5‐12. Digester Gas Productions from Plant No. 1 and Plant No. 2 with Interim Facility under Condition 1 in 20281 COMBINED LOADING LOAD TO PLANT NO. 1 PLANT NO. 2 PLANT NO. 1 AND CONDITION DIGESTERS (SCFM)2 (SCFM)3 PLANT NO. 2 (SCFM) Annual Average Sludge 1,690 1,080 2,770 SSO N/A5 425 425 Combined 1,840 1,510 3,350 Peak 15‐Day Sludge 2,030 1,300 3,330 SSO N/A5 425 425 Combined 2,030 1,730 3,760 Peak Hour4 Sludge 2,540 1,620 4,160 SSO N/A5 640 640 Combined 2,510 2,260 4,770 Notes: 1. Refer to Appendix B.3.2 for detailed calculations. 2. Plant No. 1 gas production based on 2028 solids flows and loads under Condition 1. 3. Plant No. 2 gas production based on 2028 solids flows and loads under Condition 1 and 250 wtpd pre‐processed SSO. 4. Peak hour gas flow equals 1.5 times annual average gas flow. 5. N/A = not applicable.

Table 5‐13. Digester Gas Productions from Plant No. 1 and Plant No. 2 with Interim Facility under Condition 2 in 20281

COMBINED PLANT LOADING LOAD TO PLANT NO. 1 PLANT NO. 2 NO. 1 AND PLANT CONDITION DIGESTERS (SCFM)2 (SCFM)3 NO. 2 (SCFM) Annual Sludge 1,450 1,440 2,890 Average 5 SSO N/A 230 230 Combined 1,450 1,670 3,120 Peak 15‐Day Sludge 1,740 1,720 3,460 SSO N/A5 230 230 Combined 1,740 1,950 3,690 Peak Hour4 Sludge 2,180 2,150 4,330 SSO N/A5 350 350 Combined 2,180 2,500 4,680 Notes: 1. Refer to Appendix B.3.2 for detailed calculations. 2. Plant No. 1 gas production based on 2028 solids flows and loads under Condition 2. 3. Plant No. 2 gas production based on 2028 solids flows and loads under Condition 2 and 137 wtpd pre‐processed SSO. 4. Peak hour gas flow equals 1.5 times annual average gas flow. 5. N/A = not applicable.

Final ‐ May 9, 2017 5‐12 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

Two conditions were evaluated to project digester gas production for both Plant No. 1 and Plant No. 2 in 2045, as follows:

 Digester gas production for Plant No. 1 and Plant No. 2 under TM‐1 Loading Condition 1. For Condition 1, the food waste imported to Plant No. 2 is 500 wtpd is based on the maximum capacity for the ultimate pre‐processed SSO receiving facility. This pre‐processed SSO quantity is less than the maximum allowable pre‐processed SSO for Plant No. 2 digesters shown in Table 5‐9. The results for Condition 1 are given in Table 5‐12. Detailed calculations can be found in Appendix B.3.4.  Digester gas production for Plant No. 1 and Plant No. 2 under TM‐1 Loading Condition 2. For Condition 2, the pre‐processed SSO imported to Plant No. 2 is 320 wtpd is based on the maximum allowable pre‐processed SSO for Plant No. 2 digesters in Year 2045 shown in Table 5‐14. The results for Condition 2 are given in Table 5‐15. Detailed calculations can be found in Appendix B.3.4.

Table 5‐14. Digester Gas Productions from Plant No. 1 and Plant No. 2 with Ultimate Facility under Condition 1 in 20451 COMBINED LOADING LOAD TO PLANT NO. 1 PLANT NO. 2 PLANT NO. 1 AND CONDITION DIGESTERS (SCFM)2 (SCFM)3 PLANT NO. 2 (SCFM) Annual Average Sludge 1,840 1,380 3,220 SSO N/A5 850 850 Combined 1,840 2,230 4,070 Peak 15‐Day Sludge 2,210 1,660 3,870 SSO N/A5 850 850 Combined 2,210 2,510 4,720 Peak Hour4 Sludge 2,760 2,070 4,830 SSO N/A5 1,280 1,280 Combined 2,760 3,350 6,110

Notes: 1. Refer to Appendix B.3.2 for detailed calculations. 2. Plant No. 1 gas production based on 2045 solids flows and loads under Condition 1. 3. Plant No. 2 gas production based on 2045 solids flows and loads under Condition 1 and 500 wtpd pre‐processed SSO. 4. Peak hour gas flow equals 1.5 times annual average gas flow. 5. N/A = not applicable.

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Table 5‐15. Digester Gas Productions from Plant No. 1 and Plant No. 2 with Ultimate Facility under Condition 2 in 20451

COMBINED PLANT LOADING LOAD TO PLANT NO. 1 PLANT NO. 2 NO. 1 AND PLANT CONDITION DIGESTERS (SCFM)2 (SCFM)3 NO. 2 (SCFM)

Annual Sludge 1,470 1,720 3,190 Average SSO N/A5 540 540 Combined 1,470 2,260 3,730 Peak 15‐Day Sludge 1,770 2,070 3,840 SSO N/A5 540 540 Combined 1,770 2,610 4,380 Peak Hour4 Sludge 2,200 2,580 4,800 SSO N/A5 810 810 Combined 2,200 3,390 5,590

Notes: 1. Refer to Appendix B.3.2 for detailed calculations. 2. Plant No. 1 gas production based on 2045 solids flows and loads under Condition 2. 3. Plant No. 2 gas production based on 2045 solids flows and loads under Condition 2 and 320 wtpd pre‐processed SSO. 4. Peak hour gas flow equals 1.5 times annual average gas flow. 5. N/A = not applicable.

For Plant No. 1 and combined Plant No. 1 and Plant No. 2, the maximum digester gas production is under Condition 1 (Table 5‐14). For Plant No. 2, the maximum digester gas production is under Condition 2 (Table 5‐15).

The CenGen facilities need to handle the peak 15‐day digester gas flow for both plants (4,720 scfm from Table 5‐12). Table 5‐16 below shows the capacity of the CenGen facilities at both plants. There is a combined capacity of 6,565 scfm with all CenGen units in service. With one largest sized CenGen unit out of service, the total CenGen capacity for digester gas is 5,690 scfm, which exceeds the combined 15‐day peak gas flow under Conditions 1 and 2 (4,720 scfm) and the combined peak hour gas flow for Condition 2 (5,590 scfm). With two largest size CenGen units out of service, the total CenGen capacity for digester gas is 4,815 scfm which is slightly larger than the combined maximum gas production of 4,720 scfm. This analysis excludes digester gas utilization for sludge heating. Given the capacity of CenGen, it is anticipated that OCSD will have sufficient capacity to accommodate gas production from pre‐processed SSO and projected solids loading with minimal flaring. OCSD should assess the impacts of pre‐processed SSO addition on digester gas production over time with the interim pre‐processed SSO receiving facility to determine how much pre‐ processed SSO may be imported without exceeding the CenGen capacity.

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Table 5‐16. CenGen Digester Gas Utilization Capacity GAS CAPACITY PER GAS UTILIZATION EQUIPMENT TOTAL GAS CAPACITY UNIT Plant 1 CenGen – 3 units 730 scfm 2,190 scfm

Plant No. 2 CenGen – 5 units 875 scfm 4,375 scfm

Combined CenGen capacity with 2 N/A 4,815 scfm largest units out of service

The projected peak 15‐day digester gas flows for Plant No. 2 in 2045 are shown in Figure 5‐5 under Condition 2 over a range of food waste imports (100 – 300 wtpd). The maximum gas flow rate for Plant No. 2 is 2,610 scfm under these conditions.

Figure 5‐1. Projected Peak 15‐day Digester Gas Flows for Plant No. 2 in 2045

The recommended future gas handling capacities from Study SP‐141, to be designed under Project J‐124, are given in Table 5‐17. In each case, the planned capacity will handle the peak hour flow rate for both Plant No. 1 and Plant No. 2 when compared with Tables 5‐10 and 5‐11. The recent siloxane removal facilities installed under Project J‐111 have a firm design capacity of 3,500 scfm and are also adequate for peak hour flows at either Plant No. 1 or Plant No. 2 in Tables 5‐12 and 5‐ 13. However, it is noted that the moisture content of the digester gas will increase significantly when TPAD is implemented for sludge stabilization and should be evaluated under Project J‐124.

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Table 5‐17. Project J‐124 Digester Gas Design Capacities PLANT NO. 1 PLANT NO. 2 EQUIPMENT FIRM DESIGN CAPACITY FIRM DESIGN CAPACITY (SCFM) (SCFM) Gas Compressors 1 3,500 scfm 3,500 scfm

Waste Gas Flares 1 3,600 scfm 3,600 scfm

Gas Dryer 1 3,500 scfm 3,500 scfm

Note: 1. Gas flow capacity is adequate; however, the moisture content in the digester gas will increase due to future TPAD facilities.

5.7 AMMONIA LIMITATIONS One specific potential concern in co‐digestion is an increase in ammonia concentrations in the digesters. Ammonia is released during digestion through ammonification/protein degradation. Ammonia is critical to the process as it is needed as an essential nutrient and is a critical component in the generation of alkalinity in the digester (Speece 2008). However, too much ammonia in the digester can be toxic, and studies have found that total Ammonia‐N concentrations between 1,500 and 3,000 mg NH3‐N/L are inhibitory at pH levels above 7.4 and that those above 3,000 mg/L are toxic regardless of pH (Gerardi 2003).

+ Ammonia exists as either free ammonia (NH3) or ionized ammonium (NH4 ), with the former being the much more toxic. The ammonia/ammonium speciation is centered on a pKa of 9.3. The pKa is the point where 50% of the ammonia is ionized (free ammonia) and 50% is unionized. As the pH in the digester increases towards 9.3 the amount of free ammonia in solution increases as the protonated ammonium converts to ammonia. Also, as the temperature rises, there is a reduction in pKa, meaning that more of the total ammonia will be in the more toxic, unionized (free ammonia) form at a neutral pH.

Table 5‐18. Ammonia Toxicity Levels Recorded in Digestion Literature FREE AMMONIA TOTAL AMMONIA SOURCE NOTES TOXICITY CONC. TOXICITY CONC. McCarty and 150 NH ‐N/L McKinney (1961) 3 pH 7, optimal Parkin et al (1981) 84 mg NH ‐N/L 8,500 mg NH ‐N/L 3 3 conditions

Gerardi (2003) > 50 NH3‐N/L Un‐acclimated

Despite the highly variable results in the literature (Table 5‐18), acclimation can be achieved in a digester with high total ammonia content. However, the biogas production may be lower than the original biogas production rates due to the inhibitory presence of ammonia. In co‐digestion applications, organic wastes generally have a higher ammonia content than wastewater sludge. Based on this, it is important to evaluate current ammonia levels and potential levels in a co‐ digestion application.

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Some assumptions were made to perform the evaluation. The key assumptions include:  Sludge quantities in 2028 were used as the basis for ammonia toxicity evaluation under mesophilic digestion condition.  Sludge quantities in 2045 were used as the basis for ammonia toxicity evaluation under TPAD condition.  Pre‐processed SSO quantities were based on the maximum allowable quantities for each condition as described in Section 5.8.  Ammonia‐N concentration in digester feed sludge is very low and is negligible; ammonia generation derives from the degradation of organic nitrogen during digestion.  The digester total Ammonia‐N for the current operation was estimated at 1,140 mg/L, based on ammonia levels in dewatered cake.  Total Kjeldahl Nitrogen (TKN) levels in WAS is approximately twice as high as those in primary sludge.  Digester pH values were set to 7.2 for mesophilic digestion and 7.5 for thermophilic (TPAD) digestion based on the BV/BC team’s experience with other municipal plants.  pH is relatively constant between average and peak loading conditions.  Ammonia release is proportional to the VSR during digestion. VSRs for conventional mesophilic anaerobic digestion and TPAD were 57% and 61%, respectively.  The VSR for pre‐processed SSO is 80%, based on established literature values.

The results are summarized in Table 5‐19. As noted in Table 5‐19, total ammonia concentrations are higher for thermophilic digestion due to higher VSR. Free ammonia concentration is also higher for thermophilic digestion due to higher pH. Co‐digestion of pre‐processed SSO will increase the total ammonia concentration by 40 – 210 mg NH3‐N/L. The free ammonia concentrations are less than 35 mg NH3‐N/L for all cases. Based on these results, co‐digestion of pre‐processed SSO will impact total and free ammonia concentrations, but the free ammonia and total ammonia levels will be below the digestion toxicity limit, 50 mg NH3‐N/L and 3,000 mg NH3‐N/L respectively.

Table 5‐19. A Summary of Results for Total Ammonia Concentrations for Co‐Digestion at Plant No. 2, mg NH3‐N/L MESOPHILIC (2028) THERMOPHILIC (2045)

PARAMETER Condition 1 Condition 2 Condition 1 Condition 2 Average Peak Average Peak Average Peak Average Peak Annual 15‐Day Annual 15‐Day Annual 15‐Day Annual 15‐Day Total 1,234 1,218 1,203 1,196 1,505 1,475 1,358 1,346 Ammonia Free Ammonia 10 10 10 10 35 34 32 31 Note: The total ammonia toxicity limit is 3,000 mg NH3‐N/L. The free ammonia toxicity limit is 50 mg NH3‐N/L based on Gerardi (2003).

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It is worth noting that this ammonia toxicity evaluation assumed the worst‐case scenario that the max amount of pre‐processed SSO will be added for co‐digestion to use up all available digester capacity. In some cases, pre‐processed SSO quantity is as high as 810 wtpd.

In reality, pre‐processed SSO for co‐digestion will likely be at a lower rate, which would result in even lower Ammonia‐N increase in the digesters, supporting the conclusion that co‐digestion will not cause ammonia toxicity issues in the digesters. 5.8 CAPACITY ANALYSIS CONCLUSIONS While a co‐digestion program at Plant No. 1 is not feasible due digester capacity issues, adding pre‐ processed SSO to the Plant No. 2 digester is both a current and long‐term opportunity for OCSD. Although new digesters will not be constructed at Plant No. 2 for at least 10 years, OCSD could decide to build a smaller interim receiving facility at Plant No.2 to receive pre‐processed SSO near‐ term to help meet demand for pre‐processed SSO resulting from AB 1826. An interim facility would allow OCSD to better understand pre‐processed SSO characteristics, handling issues, and digestibility in a full‐scale operation. If successful, the program could be expanded with a new or expanded receiving station to be constructed in conjunction with digestion upgrades at Plant No. 2. The concept of an interim facility also allows OCSD to begin to build partnerships with entities such as OCWR, WM, and Republic Services at a time when demand for co‐digestion capacity is expected to be high. Early entry into the organics marketplace has, for example, allowed EBMUD to secure a competitive advantage in securing co‐digestion feedstocks within the San Francisco Bay Area. This concept is explored further in Sections 6 and 7.

The limiting conditions and the quantities of pre‐processed SSO can be co‐digested under different conditions are summarized in Table 5‐20.

Table 5‐20. A Summary of Digester Capacity Evaluation for Plant No. 2 PARAMETER INTERIM FACILITY (2028) ULTIMATE FACILITY (2045) Digester Operation Mesophilic TPAD Flows and Loads 1 Condition 1 Condition 2 Condition 1 Condition 2 Condition Limiting Design Service condition Typical condition Service condition Service condition Condition2 No. of Digesters Two large Two large and one Two thermophilic Two thermophilic OOS digesters OOS small digesters OOS and one large and one large mesophilic mesophilic digesters digesters OOS OOS Max Pre‐Processed 582 137 806 323 SSO Quantity, wtpd3 Notes: 1. Flows and loads conditions are discussed in Section 5.3.1. 2. Design conditions are discussed in Table 5‐6. 3. Based on pre‐processed SSO characteristics shown in Table 5‐7.

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Based on the digester capacity evaluation results and understanding of the Plant No. 2 facility, the BV/BC team recommended the interim receiving facility to be designed using two standard 12,000 gallon tanks. This translates to acapacity of 250 wtpd, although the BV/BC team has recommended that OCSD contract to receive no more than 150 wtpd to allow for operational flexibility during peak loading periods. For the ultimate pre‐processed SSO receiving facility, the BV/BC team and OCSD jointly selected a capacity of 500 wtpd for the following reasons:

 Limit truck traffic to approximately 20 trucks per day (assuming 6,000 gallon trucks).  Limit the number of pre‐processed SSO storage tanks required to four units and avoid the need for larger concrete storage tanks.  Limit the risk of exceeding the CenGen capacity.

As shown in Table 5‐20, the amounts of pre‐processed SSO can be co‐digested can be less than the recommended design capacities of the receiving facility under Condition 2. Therefore, the contract with the haulers should allow OCSD to accept less pre‐processed SSO than the maximum capacity of the receiving facility under certain conditions. This would provide OCSD with operation flexibility to handle high solids flows and loads conditions.

Depending on the solids flows and loads conditions and the quantities of pre‐processed SSO to be co‐digested, volatile solids contributions from pre‐processed SSO can range from less than 10 percent to up to 42 percent of the total VS loading to the digesters. This is well within the ranges typically seen in the industry, as described in Section 5.2. The digester ammonia toxicity evaluation indicates the total ammonia‐N and free ammonia‐N concentrations with co‐digestion of pre‐ processed SSO will be well below the toxicity thresholds. Therefore, it can be concluded that co‐ digestion of pre‐processed SSO at Plant No. 2 is feasible from a process control standpoint.

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6.0 Co‐Digestion Benefits and Cost Analysis Given that co‐digestion of pre‐processed SSO at Plant No. 2 is viable for both the short‐ and long‐ term conditions, this section reviews the potential benefits for this alternative. 6.1 GENERAL BENEFITS As previously stated, anaerobic digestion is at the nexus of two important State of California goals: (1) organics diversion from landfills to reduce greenhouse gas emissions and (2) increased renewable energy and fuels generation. These state goals are also compatible with OCSD goals for biosolids management and OCSD energy policies. Pre‐processed SSO co‐digestion at Plant No. 2 represents an important contribution towards these goals by OCSD.

Overall, the impact of the evolving state regulations on organics collection and recycling is significant. By 2020, a significant percentage of the organics in the state will be diverted from landfills under AB 1826 and SB 1383. The bulk of any remaining organics will be diverted from landfills through SB 1383 by 2025. Therefore, there is a significant public need that OCSD can meet and an emerging marketplace that OCSD can capitalize on. There are a number of potential public/private partnerships that may be explored to implement co‐digestion.

Co‐digestion of pre‐processed SSO will boost digester gas production and may have synergistic effects on overall anaerobic digestion that may lead to an overall reduction in the pounds of solids hauled from the site. Digester gas production will increase and this will result in greater onsite power production. 6.2 ECONOMIC PAYBACK PERIOD CALCULATIONS As discussed, Plant No. 2 has a range of capacity for pre‐processed SSO digestion. Based on the analysis in Section 5 and in consultation with OCSD staff, an interim pre‐processed SSO receiving facility will be designed for a capacity of 250 wtpd, while initially contracting to receive 150 wtpd. The ultimate pre‐processed SSO receiving facility will be designed for a capacity of 500 wtpd.

Typically, co‐digestion projects are justified through the inclusion of tipping fees which help to recover, in part or in whole, the project costs. The BV/BC team examined a simple, preliminary tipping fee structure for OCSD. This analysis included the following assumptions:

 Trucks deliver pre‐processed SSO only 250 days per year (no weekend or holiday hauling).  One additional full‐time employee (FTE) is required to operate the receiving station at an hourly rate of $70.87 (2080 hours per year).  Additional maintenance costs for the receiving station are estimated at $100,000 per year.  Capital costs for the temporary facility are estimated at $2.6 million (M).  Capital costs for the permanent facility are estimated at $5.9M.  All other operations and maintenance costs are based on inputs used in the SWEET (Solids‐ Water‐Energy‐Evaluation‐Tool) model under Task 4 (as documented in TM‐4). This includes the associated maintenance costs for operation of CenGen, but does not include the value of power produced from CenGen with digester gas production.

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 For the interim facility, the SWEET model was evaluated for operation and maintenance from 2019‐2028, at 50, 100, 150, and 200 wtpd.  For the permanent facility, the SWEET model was evaluated for operation and maintenance from 2029‐2045, at food waste ranging from 100 to 500 wtpd in 100 wtpd increments.  Two end use scenarios were evaluated to determine the higher operation and maintenance costs, which was then used as worst case scenario for cost analysis. The end use included hauling and handling costs.

Note that while capital costs will be further refined under Task 6, the initial calculation of return on investment allows OCSD to better understand the feasibility of constructing interim and/or ultimate (permanent) receiving facilities. These are estimates based on modeling from SWEET. The payback period analysis looks at the revenue from food waste tipping fees, the capital cost of the facilities, and the average annual operations and maintenance cost over the specified time period. To provide a more accurate operation and maintenance cost, SWEET was evaluated for at least four pre‐processed SSO tonnage scenarios. A linear equation was then determined and used to derive an operation and maintenance cost at different received tonnages. The resulting information is displayed in Figures 6‐1 and 6‐2 for the interim and ultimate facilities, respectively. These figures highlight the estimated tipping fees versus received wet tons to obtain a payback period of 5, 10, and 20 years. Table 6‐1 summarizes the tipping fees to achieve the same payback periods. As noted, for the interim facility, if 100 wtpd of pre‐processed SSO are received, OCSD would need to charge a tipping fee of $52/wet ton to achieve a payback of five years. However, if OCSD receives 150 wtpd, the tipping fee can be lowered to $41/wet ton to achieve a five‐year payback. For the ultimate facility if OCSD received 100 wtpd the tipping fee would need to be $80/ wet ton to achieve a 5‐year payback period. If the quantity of pre‐processed SSO were to increase to 300 wtpd or 500 wtpd, then the tipping fees decrease to $38/wet ton and $30/ wet ton, respectively. These tipping fees are in line with tipping fees for other co‐digestion facilities in California. As shown previously in Figure 2‐4 (Section 2.3), the range of tipping fees charged is $21.40 ‐ $98, with a median fee of $44/ wet ton.

Figure 6‐1. Interim Pre‐Processed SSO Receiving Facility Tipping Fee Summary

Final ‐ May 9, 2017 6‐2 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

Figure 6‐2. Permanent Pre‐Processed SSO Tipping Fee and Resultant Return on Investment Summary

Table 6‐1. Tipping Fee Required for Given Payback Period PAYBACK INTERIM FACILITY PERMANENT FACILITY PERIOD Years 100 150 250 100 300 500 wet tons wet tons wet tons wet tons wet tons wet tons

5 $52 $41 $32 $80 $38 $30

10 $42 $35 $28 $58 $31 $25

20 $38 $31 $26 $46 $27 $23

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7.0 Project Implementation, Scope and Partnerships A number of entities are currently contracting for pre‐processed SSO or HSW deliveries for co‐ digestion. Three specific entities are briefly identified below and a copy of the existing contracts is provided in Appendix G.

LACSD entered into a two‐year agreement with WM to demonstrate co‐digestion of pre‐processed SSO in an existing digester at their JWPCP at a target importation rate of 20,000 gallons per day. WM designed the receiving station and LACSD designed the feed piping system to their existing digester. WM provided the equipment and materials for the pre‐processed SSO receiving station while LACSD provided the equipment and materials for the pre‐processed SSO piping feed system. Installation of the equipment and materials was by a separate contractor. WM operated and maintained the receiving and pumping facilities and LACSD maintained the pre‐processed SSO digester piping facilities. The demonstration project was successful and no process or operational problems were encountered. A copy of the agreement between LACSD and WM is included in Appendix G. LACSD is now in the process of planning and contract negotiations with WM for a permanent pre‐processed SSO delivery agreement.

EBMUD receives waste from a variety of haulers and high‐strength waste generators. EBMUD leverages its size, central location, and 24‐7 receiving facility operation to be the convenient, “open door” outlet for its customers. EBMUD operates two receiving facilities: one for liquid waste and another for food waste. The liquid waste facility serves pumpable waste streams (12% TS or less). The food waste facility receives material via end dump into below‐grade tanks. EBMUD dilutes the food waste and screens the material. Food waste material is provided through contract agreements with local haulers. A copy of EBMUD’s Resource Recovery Permit Application and wastewater discharge permit are provided in Appendix G.

Central Marin Sanitation Agency (CMSA) and Marin Sanitation Service (MSS) entered a public‐ private partnership to divert food waste from the landfill. MSS collects and processes source separated food waste from restaurants, markets and other food waste generators. This food waste is then received by CMSA and mixed with FOG, another source of high‐strength waste received, which is then digested with sludge. The food waste provided is contracted solely with MSS. A copy of their contract is in Appendix G. 7.1 IMPLEMENTATION OVERVIEW Based on digestion capacity after completion of P1‐101 and the end of primary sludge diversions to Plant No. 2 in 2018, an interim pre‐processed SSO receiving facility capacity of 250 wtpd is recommended through 2028 (equivalent to approximately eleven (11) trucks per day). The facility would be operated at 150 wtpd (equivalent to approximately six (6) trucks per day) and would allow operational flexibility due to the larger tank sizes. Such a project allows OCSD to build partnerships and gain familiarity with the co‐digestion process at a lower initial capital investment. A larger capacity receiving facility could then be constructed at a later date to better accommodate regional tonnages of pre‐processed SSO and reflect lessons learned and advances in the industry relating to food waste digestion and management. OCSD could opt to pursue traditional design, bid, build for implementation of the program. Alternatively, several utilities have opted to have the waste haulers or other entities design, bid, and build the receiving facilities. Specific aspects of implementation are discussed below.

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7.2 POTENTIAL PARTNERSHIPS As discussed in Section 4, WM, Republic Services, and OCWR have all expressed interest in partnerships with OCSD. One potential arrangement for a permanent program would be to allow OCWR to serve in a logical role as facilitator between the waste haulers, with whom it has relationships, and OCSD. Should OCSD choose to pursue a smaller initial program, it could partner with one or more of the waste haulers individually, similar to LACSD’s program. 7.3 CONTRACTUAL ARRANGEMENTS Separate and apart from the considerations associated with the design and construction of the receiving facilities are the agreements with the waste haulers, often called “off‐take agreements”. These agreements delineate roles and responsibilities for the hauler and OCSD. Under such an agreement, OCSD would establish a minimum capacity for the receipt of pre‐processed SSO, as well as a tip fee. In turn, the waste hauler would be required to guarantee pre‐processed SSO quality, typically in easily identified terms such as percent TS, percent VS, and maximum contamination levels. The off‐take agreement would also need to specify which entity controls any environmental or energy credits that results from the project (or whether they are to be shared). 7.4 INTERIM RECEIVING STATION EQUIPMENT There are multiple equipment/facility approaches available for the design of an interim pre‐ processed SSO receiving facility, as noted below.  Tank type and volume considerations o Recommended tank materials of construction include fiberglass reinforced plastic (FRP) and stainless steel; however, alternatives may be considered during detailed design. The tank will be circular with either a flat bottom or a cone bottom (cone bottom preferred). o The practical limit for a tank diameter is approximately 12 feet diameter in order to haul the tank to the site without special provisions. Tank diameters up to about 13.75 feet may be hauled if special truck escorts are provided front and back. The tank height should be limited to the approximate height of the existing digesters. o One of the potential private partners, WM, recommends providing at least two days of storage so that pre‐processed SSO may be fed to the digesters at a continuous rate even if truck deliveries are on during week days. Based on the site space available, this will be very challenging (see Section 7.6). It appears that only two tanks will fit on the plant site alternative locations and that total storage will be limited to approximately 17.5 hours (assuming 215 gallons of pre‐processed SSO per wet ton of slurry). o The volume of a single tank has a practical limit based on maximum diameter, maximum height, and the tank geometry. This limit is approximately 20,000 gallons per tank.  Pump type and service considerations o Both chopper‐type centrifugal pumps and progressing cavity pumps have been used for pre‐processed SSO pumping. Due to the high viscosity of food waste slurry at 12‐15% solids concentration, progressing cavity are preferred to avoid plugging or flow rate impacts.

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o Pump service for receiving mixing pre‐processed SSO require relatively high flow rates, whereas feeding pre‐processed SSO at a continuous rate 24/7 requires a relatively low flow rate. Therefore, it is ideal to have separate pumps for these functions to prevent slug loading conditions. At some facilities one pump is used for all functions and pre‐ processed SSO is pumped to the digesters on a time basis to avoid over loading the digester.  Odor control o Interim pre‐processed SSO receiving facilities typically have a passive carbon odor canister for tank ventilation, without any forced air ventilation. This is considered appropriate for this facility.  Spill containment o Typically, spill containment for an interim facility contains only nuisance spills, not a major tank rupture.

As stated in Section 6, a capacity of 250 wtpd of capacity for pre‐processed SSO is recommended for the preliminary design and cost estimate of the interim pre‐processed SSO receiving station. As discussed above, the drivers for the interim facility are to capitalize on early opportunities for the developing pre‐processed SSO market while also providing flexibility in testing and optimizing pre‐ processed SSO addition to the Plant No. 2 digesters.

As discussed in Section 4, SSO will be processed offsite by the haulers and diluted to a pumpable slurry with a TS content of 12‐15%. (55,000 gallons per day) As a result, the receiving station will not have screening, grit removal, grinders, or onsite dilution facilities. However, the following is a list of the major equipment recommended for the interim receiving station:  Two storage tanks (20,000 gallons each)  Three receiving/recirculation pumps (300 gpm each), two operating and one standby  Two feed pumps at 15‐50 gpm each, one operating and one standby  Two carbon canisters for odor control

The facility will be designed to receive up to 55,000 gallons per day (250 wtpd at 12‐15% TS). This volume equates to 11 trucks per day at 5,000 gallons per truck. The receiving pump capacity is designed to allow a 17‐minute unloading time. The BV/BC team estimates that trucks will deliver processed food waste over 6‐8 hours per day, while feeding the digesters 24 hours per day. Two tanks at a total storage volume of 40,000 gallons, equates to approximately 17.5 hours of storage.

The tanks will be operated in a fill, mix, feed, and empty mode for optimal operation. A receiving/mixing pump will be dedicated to each receiving tank and the pump function between receiving and mixing will be accomplished with a simple manual valve change during the truck delivery process. The feed pump will draw from each tank in turn through a simple manual valve change when the active tank experiences low tank level. Alternately, this valve change may be automated to avoid operator action. The pre‐processed SSO feed rate will be set by plant staff based on the anticipated daily volume to be received. All controls for this system can be furnished via a local programmable logic controller (PLC) and control panel. OCSD may consider whether or

Final ‐ May 9, 2017 7‐3 Biosolids Master Plan TM‐5: High Strength Organic Waste Co‐Digestion Evaluation | Orange County Sanitation District not to link the system to the plant distributed control system (DCS) for monitoring or control purposes.

The feed of pre‐processed SSO to the existing digesters may be accomplished by: (1) feeding to adjacent 1‐2 digesters with minimal piping and valves, (2) feeding pre‐processed SSO to the existing feed piping loops that currently exist, thus feeding a group of digesters, or (3) feeding to the existing primary sludge blending tank allowing pre‐processed SSO feed to all the existing digesters. These alternatives are further discussed in Section 7.6 in the evaluation of potential site locations for the facility. Figure 7‐1 is a preliminary schematic for the Interim Food Waste Receiving Facility.

20,000 GAL 20,000 GAL TANK TANK

Figure 7‐1. Interim Food Waste Receiving Schematic

It is recommended that food waste hauling be performed at least six (6) days per week to maximize pre‐processed SSO deliveries and digester utilization. However, the actual delivery schedule will be negotiated with the selected food waste vendor(s). A tapered food waste feed will be required on weekends if there are no truck deliveries. 7.5 ULTIMATE RECEIVING STATION AND ANCILLARY EQUIPMENT The following equipment and materials are discussed for the Ultimate Food Waste Receiving Facility.  Tank type and volume considerations o Recommended tank materials of construction include FRP and stainless steel; however, alternatives may be considered during detailed design. The tank will be circular and a

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cone bottom is recommended. Alternately, below grade concrete tank construction may considered to provide additional storage volume – see discussion in Section 7.7. o The practical limit for a tank diameter is approximately 12 feet diameter in order to haul the tank to the site without special provisions. Tank diameters up to about 13.75 feet may be hauled if special truck escorts are provided front and back. The tank height should be limited to the approximate height of the existing digesters. o One of the potential private partners, Waste Management, recommends providing at least two days of storage so that pre‐processed SSO may be fed to the digesters at a continuous rate even if truck deliveries are on during week days. Based on the site space available, this will be very challenging (see Section 7.7). It appears that only four tanks will fit on the plant site location and that total storage will be limited to approximately 16 hours. o The volume of a single tank has a practical limit based on maximum diameter, maximum height, and the tank geometry. This limit is approximately 20,000 gallons per tank.  Pump type and service considerations o Progressing cavity pumps are recommended for pre‐processed SSO pumping due to the high viscosity of food waste slurry at 12‐15% solids concentration to avoid plugging or flow rate impacts. o Pump service for receiving and mixing pre‐processed SSO require relatively high flow rates, whereas feeding pre‐processed SSO at a continuous rate 24/7 requires a relatively low flow rate. Therefore, it is ideal to have separate pumps for these functions to prevent slug loading conditions. OCSD may consider whether to combine the pumping functions of receiving and mixing with a single pump, or to provide separate pumps that are designed for a specific function (flow rate). For the purposes of preliminary design, separate pumps are shown for each function.  Odor control o For the Ultimate Food Waste Receiving Facility, forced air ventilation of the receiving tanks is recommended. Ideally, a combined odor control system for the new Digested Sludge Feed Facility and the Ultimate Food Waste Receiving Station will be furnished. If the location of these two facilities precludes a combined system, either a new chemical wet scrubber or bio‐scrubber is recommended for the receiving station.  Spill containment o For the Ultimate Food Waste Receiving Station, complete containment of a single major tank rupture is recommended.

Based on the Plant No. 2 digester capacity assessment, as discussed in Section 5, a pre‐processed SSO receiving capacity of 500 wtpd is recommended for preliminary design and cost estimation of the receiving station. This quantity of pre‐processed SSO represents 21 percent of the total VS loading. As previously mentioned, there is no consensus in the industry regarding upper limits for food waste co‐digestion. Proposed loading rates listed in Section 5 are as high as 75% and up to 30% of VS loading rate was considered acceptable for the BMP; therefore, the amount of food waste determined for OCSD is within acceptable range.

Final ‐ May 9, 2017 7‐5 Biosolids Master Plan TM‐5: High Strength Organic Waste Co‐Digestion Evaluation | Orange County Sanitation District

SSO will be processed offsite by the haulers and diluted to a pumpable slurry with a TS content of 12‐15%. As a result, the receiving station will not have screening, grit removal, grinders, or onsite dilution facilities. However, the following is a list of the major equipment needed at the receiving station:

 Four storage tanks (20,000 gallons each)  Four receiving pumps (300 gpm each), two operating and two standby  Five mixing pumps (500 gpm each), four operating and one standby  Two feed pumps at 30‐100 gpm each, one operating and one standby  Two odor control ventilation fans ventilating to odor control facilities at the new digester feed facility

The facility will be designed to receive up to 110,000 gallons per day (500 wtpd at 12‐15% TS). This volume equates to 22 trucks per day at 5,000 gallons per truck. The receiving pump capacity is designed to allow a 17‐minute unloading time. The BV/BC team estimates that trucks will deliver processed food waste at an even rate for 6‐8 hours per day, while feeding the digesters 24 hours per day. With this in mind, the total tank storage of 80,000 gallons will provide approximately 17.5 hours of storage.

It is recommended that the tanks be operated in a fill, mix, feed, empty mode for optimal operation. Separate receiving and mixing pumps will be dedicated to each operational function eliminating any valve changes during the truck delivery process. The feed pump will draw from each tank in turn through automated valve changes when the “active” tank experiences low tank level. The pre‐ processed SSO feed rate will be set by plant staff based on the anticipated daily volume to be received. All controls for this system can be furnished via a local PLC and control panel and it is recommended that OCSD link the system to the plant DCS for monitoring and control purposes.

The feed of pre‐processed SSO to the existing digesters may be accomplished by: (1) feeding to the new digester feed facility (refer to TM 6) or (2) feeding to the individual new thermophilic digesters. For either feeding strategy, the food waste should be fed continuously for optimal digester operation and consistent gas production. These feed strategy alternatives are further discussed in Section 7.7 in the evaluation of potential site locations for the facility. Figure 7‐2 is a preliminary schematic for the Ultimate Food Waste Receiving Facility.

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Figure 7‐2. Ultimate Food Waste Receiving Schematic

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7.6 INTERIM RECEIVING FACILITY LOCATION The BV/BC Team and OCSD staff visited the site on December 12, 2016 and January 18, 2017 for the purpose of identifying potential sites for the Interim Food Waste Receiving Facility. On that basis, four potential sites were identified and subsequently evaluated. Figure 7‐3 shows these potential locations and they are described as follows:  Site A is located adjacent to existing Digester C on the southwest side. There is an existing scum receiving station in this location consisting of two receiving tanks and two receiving/mixing/feed pumps. The existing tanks are approximately 7‐8 foot diameter and they are deemed not usable due to the observed condition assessment (tops are collapsing). It is possible to replace these tanks and pumps with a new facility; however, the site is very space constrained relative to current food waste receiving facility requirements. It may not provide enough space for a 250 wtpd facility.  Site B is located adjacent to existing Digester M on the southwest side. There are no existing facilities at this location that can be observed above grade. However, the site is very space constrained relative to current food waste receiving facility requirements. It may not provide enough space for a 250 wtpd facility.  Site C is located adjacent to the existing ferric chloride feed facilities and near Digester P, at the south perimeter of the plant site (near Talbert Marsh). There are no existing facilities at this location that can be observed above grade. However, the site is very space constrained relative to current food waste receiving facility requirements. It may not provide enough space for a 250 wtpd facility.  Site D is located adjacent to Digester S on the east side. Additional space is available at this site compared with Sites A, B, and C. Therefore, Site D is recommended for building the interim pre‐processed SSO receiving facility.

Figure 7‐3. A Schematic of the Proposed Interim Receiving Facility Location

Final ‐ May 9, 2017 7‐8 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

The feed of pre‐processed SSO to the existing digesters may be accomplished by: (1) feeding to adjacent 1‐2 digesters with minimal piping and valves, (2) feeding pre‐processed SSO to the existing feed piping loops that currently exist, thus feeding a larger group of digesters, or (3) feeding to the existing primary sludge blending tank allowing pre‐processed SSO feed to all the existing digesters. There are a number of tradeoffs associated with these alternatives, as follows:  If pre‐processed SSO is fed only to an individual digester or small group of digesters, this will limit the amount of piping and valves required for operation. However, gas production increases will be localized to a limited number of digesters and this will require checking the digester gas conveyance system for capacity.  If pre‐processed SSO is fed to the existing primary sludge blending facility, the pre‐ processed SSO will be distributed to all digesters and gas production increases will be spread throughout. However, there will be increased cost and complexity associated with additional piping and valves.  If piping and valves are included for each of these operating scenarios (feeding either individual digesters, digester groups or the existing blending facility) the operations staff will have the maximum operational flexibility. However, this will result in maximum capital costs and increased operational complexity that may not be necessary for an interim facility. 7.7 ULTIMATE RECEIVING FACILITY LOCATION The site location for the permanent food waste facility was developed primarily under Task 6 which will provide more detailed information. The proposed site of the permanent pre‐processed SSO receiving facility will be next to the new digester feed facility, where Digesters M and L are currently located. Figure 7‐4 indicates the flow of trucks through the facility. This location should minimize congestion and driving through the interior of the Plant.

Figure 7‐4. A Schematic of the Proposed Ultimate Receiving Facility Location

Final ‐ May 9, 2017 7‐9 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

8.0 Conclusions and Next Steps A financial justification exists to pursue a co‐digestion program at Plant No. 2. Details associated with the temporary and permanent pre‐processed SSO receiving station capacity, cost, and location, will be established under Task 6 and documented in TM‐6. OCSD has several partners to choose from in creating a co‐digestion program and further discussion on the ideal partnering arrangement(s) will be conducted and documented in the final BMP.

An expedited delivery of an interim pre‐processed SSO receiving facility is recommended. This temporary facility should target operational completion in January 2019 to coincide with a significant increase in AB1826 SSO diversion requirements. With the interim facility receiving up to 250 wet tons/day of pre‐processed SSO, it will greatly help in the organics from landfill diversion effort. This interim facility will operate until the ultimate facility is complete (estimated to be 2028). The increase in pre‐processed SSO to 500 wtpd for the permanent facility will significantly aid OCSD’s partners in meeting AB1826 requirements.

The following summarizes additional conclusions of this evaluation:

 Quantities of pre‐processed SSO can be co‐digested at Plant No. 2 vary depending on solids flows and loads.

 Although the recommended capacity of the interim receiving facility is 250 wtpd, the BV/BC team has recommended that OCSD contract to receive no more than 150 wtpd initially to get familiarized with the co‐digestion program and allow for operational flexibility during peak loading periods.

 Quantities of pre‐processed SSO can be co‐digested can be less than the recommended design capacities of the receiving facility under Condition 2. Therefore, the contract with the haulers should allow OCSD to accept less pre‐processed SSO than the maximum capacity of the receiving facility under certain conditions. This would provide OCSD with operation flexibility to handle high solids flows and loads conditions.

 The digester ammonia toxicity evaluation results indicate the total ammonia‐N and free ammonia‐N concentrations with co‐digestion of pre‐processed SSO will be well below the toxicity thresholds. Ammonia toxicity with pre‐processed SSO co‐digestion is unlikely.

 With one largest sized CenGen unit out of service, the total CenGen capacity for digester gas (5,690 scfm) exceeds the combined 15‐day peak gas flow under Conditions 1 and 2 (4,720 scfm) and the combined peak hour gas flow for Condition 2 (5,590 scfm).

 With two largest size CenGen units out of service, the total CenGen capacity for digester gas (4,815 scfm) exceeds the combined 15‐day peak gas flow under Conditions 1 and 2 (4,720 scfm).

 OCSD should assess the impacts of pre‐processed SSO addition on digester gas production over time with the interim pre‐processed SSO receiving facility to determine how much pre‐ processed SSO may be imported without exceeding the CenGen capacity.

Final ‐ May 9, 2016 8‐1 Biosolids Master Plan TM‐5: High Strength Organic Waste Co‐Digestion Evaluation | Orange County Sanitation District

 The recommended future gas handling capacities from Study SP‐141, to be designed under Project J‐124, are adequate for peak hour flows at either Plant No. 1 or Plant No. 2. However, it is noted that the moisture content of the digester gas will increase significantly when TPAD is implemented for sludge stabilization and should be evaluated under Project J‐124.

DRAFT – February 14, 2017 8‐2 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

9.0 List of References Aichinger, P., T. Wadhawan, M. Kuprian, M. Higgins, C. Ebner, C. Fimml, S. Murthy, B. Wett (2015) “Synergistic co‐digestion of solid‐organic‐waste and municipal‐‐sludge: 1 plus 1 equals more than 2 in terms of biogas production and solids reduction” Water Research, 87, 416‐423. Bhattacharya, S., & Parkin, G. (1989). The Effect of Ammonia on Methane Fermentation Processes. Journal (Water Pollution Control Federation), 61(1), 55‐59. California Air Resources Board. “First Update to the Climate Change Scoping Plan”. CARB, May 2014. California Air Resources Board. “LCFS Pathway for the Production of Biomethane from Mesophilic Anaerobic Digestion of Wastewater Sludge at a Publicly Owned Treatment Works”. CARB, August 2014. Carucci, G. F. Carrasco, K. Trifoni, M. Majone, M. Beccari. “Anaerobic Digestion of Food Industry Wastes: Effect of Co‐digestion on Methane Yield”, Journal of Environmental Engineering (2005) 131, 7, 1037. Gray, D.M.D, P. Suto, C. Peck, (2008) Final Report: Anaerobic Digestion of Food Waste. U.S. Environmental Protection Agency Region 9, EPA‐R9‐WST‐06‐004. McCarty, P. L., & McKinney, R. E. (1961). Salt toxicity in anaerobic digestion. Journal (Water Pollution Control Federation), 399‐415. OCSD (2013). Food Waste Co‐Digestion Effects on Digester Performance and Biosolids Characteristics; A Technical, Economic and Regulatory Analysis. June, 2013. Park, C (2014) Personal Communication, Food Waste Digestion Limits, Fall 2014. Speece, R. E. (2008). Anaerobic Biotechnology and Odor/Corrosion Control for Municipalities and Industries. Archae Press.

Final ‐ May 9, 2017 9‐1 Biosolids Master Plan Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

Appendix A – Materials from Vendor Workshop

May 9, 2017 A‐1 Master Plan Biosolids

Biosolids Master Plan Project No. PS15-01

High Strength Organic Waste Co-Digestion Workshop Tuesday, June 14, 2016

Biosolids Ad -

The Orange County Sanitation District (OCSD) is preparing a Biosolids Master Plan which will recommend future biosolids management options and solids treatment facility improvements for a 20-year planning period. The Biosolids Master Plan will include an evaluation of sludge digestion technologies and recommendations for new onsite facilities. Preparation of the master plan will also include an evaluation for co-digestion of preprocessed high-strength organic waste. OCSD will conduct a High Strength Organic Waste Co-Digestion Public Workshop for all interested parties. Attendees will be given the chance to ask questions and submit information to OCSD after the workshop regarding potential opportunities to partner with OCSD.

WHAT: OCSD Biosolids Master Plan - High Strength Organic Waste Co-Digestion Workshop

WHEN: Tuesday, June 14, 2016, 3:00-5:00 p.m.

WHERE: Orange County Sanitation District Administration Building Board Room 10844 Ellis Avenue Fountain Valley, CA 92708

Please RSVP to Marisa Unvert at (949) 458-1114, extension 6 by June 7, 2016. For questions about the Biosolids Master Plan, please contact Sharon Yin, Senior Engineer, at [email protected]. OCSD Biosolids Master Plan Task 5 Vendor Workshop List of Vendor to Invite

Manufacturer Distributor/Provider Contact RSVP Austep Austep Daniele Chiodini ; +(704) 421-4140 (cell) BTA International CCI Bioenergy Kevin Matthews ; (416) 230-9391 (cell) GE Energy, Monsal GE Energy, Monsal Bob Holt (GE Power) ; 925 890-4555 (cell) Cesaro Mac Imports Ecoverse William Kish ; (919)628-9831 (cell) Haarslev Haarslev? Keith Hamilton ; (205) 275-5201 (cell) DODA DODA USA Philip Wessels - 507-375-5577 MARTIN LOHSE FEED Resource Recovery info@feedresources

Scott Equipment Company Scott Equipment Company Kevin Pedretti ; (952) 758-0429 (direct) Anaergia (DB Technologies David Schneider ; (310) 994-0272 & VM Press) JBI and Anaergia Simon Morris ; (916) 642-5500 Yes NA Waste Management Daniel North - 925-518-0859 - [email protected] NO LONGER w/WM Contact: Chrystal Denning 1800 S. Grand Avenue Santa Ana, CA 92705 NA Waste Management Phone: (714) 480-2315 Email: [email protected] NO LONGER W/WM Waste Management Elmer Heath Referred by Chrystal, but no longer at WM Waste Management Tom Koutroulis, 714-920-0184, [email protected] Yes

Orange County Waste and Lisa Keating Manager Waste Disposal Contracts & Recycling Programs 714-834- Recycling 5513 [email protected] Orange County Waste and Recycling Dylan Wright, Director (714) 834-4122 [email protected] Orange County Waste and Recycling Mike Kashani [email protected] Yes

Synagro Layne Baroldi (562) 690-6303 [email protected] Yes Ecology Alvardo Marquez (562) 601-8105 [email protected] Federal Disposal Don Shubin (714) 444-3303 [email protected] Republic Services Dave Ault (714) 238-3324 [email protected] Retired Republic Services Mark McGee [email protected] NA Robert’s Waste & Recycling Jesus Roberto (714) 557-2533 [email protected] Contact: Jay Ware P.O. Box 8026 Newport Beach, CA 92658 Ware Disposal Phone: (714) 664-0677 Email: [email protected]

Ware Disposal Jason Rush [email protected] Yes Jennifer Wallin, Manager Materials, Markets, and Local Assistance Division South Branch 2929 E. Willow Street CalRecycle Long Beach, CA 90806 Phone: (562) 492-9685 E-Fax: (916) 319-7531 Email: [email protected]

Liquid Environmental NA Solutions NA Burrtec Chuck Tobin - 909-429-4200 - [email protected] NA Athens Services NA Brighan NA Wade Disposal Now Waste Industries, Raleigh, NC? Rainbow Environmental NA Services Jerry Moffat - 714-847-3581 - [email protected] Contact: Jeff Snow 17121 Nichols Street Rainbow Environmental Huntington Beach, CA 92647 Services Phone: (714) 847-3581 Email: [email protected]

Contact: Dean Ruffridge 11292 Western Avenue Stanton, CA 90680 CR&R Phone: (714) 826-9049 Email: [email protected]

NA CR&R David Fahrion - 951-943-1991, ext. 1312 - [email protected] CR&R Mike Silva, [email protected] Yes Southern California NA Disposal Recycling Co. Mike Matosian - 310-828-6444 - [email protected] City of San Diego Christina Paddack 858-292-6454 [email protected] Yes Agri Service Mary Matava [email protected] Yes High Strength Organic Waste Co-Digestion Workshop

Attendee List - June 14, 2016

Company/Facility Name Contact Email Phone CR&R Environmental Svcs Mike Silva [email protected] 714-883-3777

Brown and Caldwell Adam Ross [email protected]

Orange County Waste and Mike Kashani [email protected] Recycling

Synagro Layne Baroldi [email protected] 714-299-2943

OCSD Tom Meregillano [email protected] 714-593-7457

Anaergia David Schneider [email protected] 310-994-0272

City of San Diego Christina Paddack [email protected] 858-292-6454

Ware Disposal Jason Rush [email protected] 714-664-0159

Waste Management Tom Koutrouly [email protected]

Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

Appendix B – Detailed Capacity Calculations

May 9, 2017 B‐1 Master Plan Biosolids

Plant 1 TPODS 2016 2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 1 WASTEWATER TREATMENT PROCESSES

Plant Influent BOD-T, mg/L 310 303 302 307 315 324 328 322 315 321 318 316 320 BOD-C, mg/L 215 204 217 213 215 222 219 218 207 210 207 213 213 TSS, mg/L 370 356 344 341 359 366 354 350 336 344 357 358 353 VSS, mg/L 312 303 300 296 304 313 309 305 292 297 310 312 304 Ammonia-N, mg/L 38.0 33.0 34.0 37.0 38.0 37.0 36.0 35.0 37.0 37.0 37.0 36 36.3 Grease and Oil, mg/L 55.4 49.8 53.4 55.2 49.9 40.9 45.1 51.8 52.7 22.9 47.6 66.6 49.3 pH 7.8 7.8 7.7 7.8 7.7 7.8 7.8 7.8 7.7 7.8 7.8 7.8 7.8

H 2O2, gal/day 1000 1011 1653 2120 1695 1671 1633 1625 1628 1633 1630 1630 1,577

Primary Effluent (basins 1-5) BOD-T, mg/L 171 148 154 165 167 157 134 143 174 163 146 141 155 TSS, mg/L 97 74 83 93 95 101 79 85 102 87 77 77 88 Basins in Service,# 3 3 3 3 3 3 3 3 3 3 3 3 3

Primary Effluent (P1-33E) O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S BOD-T, mg/L TSS, mg/L Basins in Service,#

Primary Effluent (P1-33W) O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S BOD-T, mg/L TSS, mg/L Basins in Service,#

Primary Effluent (P1-37 East) BOD-T, mg/L 213 164 177 163 146 138 160 165 176 177 168 173 168 TSS, mg/L 128 65 75 58 48 45 66 62 68 64 65 78 69 Basins in Service,# 6 6 6 6 6 6 6 6 6 6 6 6 6

Primary Effluent (P1-37 West) BOD-T, mg/L 193 144 163 157 147 145 148 150 153 151 163 166 157 TSS, mg/L 111 57 69 65 53 60 67 63 60 58 63 77 67 Basins in Service,# 6 6 6 6 6 6 6 6 6 6 6 6 6

Primary Effluent (All Basins) Hyd. Loading, gal/day/ft 2 669 663 771 763 621 620 645 655 663 683 649 742 680

Trickling Filter Effluent Flow, mgd T.F.#1 14.5 15.3 14.7 15.3 12.4 9.8 11.1 12.7 13.4 13.5 13.4 12.7 13.2 Flow, mgd T.F.#2 14.5 15.3 14.8 15.3 12.0 9.6 11.1 12.7 13.3 13.6 13.4 12.8 13.2 BOD-T, mg/L 13.6 13.3 14.1 16.1 16.2 19.8 20.8 21.3 17.6 18.1 18.3 18.3 17.3 BOD-C, mg/L 7.5 6.6 6.8 7.9 7.6 9.5 8.4 10.6 8.7 8.0 9.1 10.2 8.4 TSS, mg/L 16.8 14.0 14.8 15.7 14.7 20.0 18.5 19.0 15.9 15.4 15.5 16.8 16.4 Ammonia-N, mg/L 5.7 12.3 10.5 13.9 6.5 6.1 7.8 11.6 15.1 13.4 15.2 11.6 10.8 Turbidity NTU 8.8 7.2 7.2 7.7 6.4 7.9 7.6 9.0 7.8 7.5 7.7 8.3 7.8

2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 1 WASTEWATER TREATMENT PROCESSES (cont'd)

Activated Sludge Influent AS1 BOD-T, mg/L 136 105 115 116 114 115 104 111 129 131 124 111 118 TSS, mg/L 79 57 61 67 64 64 64 62 70 64 63 61 65 VSS, mg/L 62 46 50 56 53 54 54 51 57 53 53 52 53 COD, mg/L 289 250 257 265 252 254 243 254 284 283 273 251 260 Ammonia-N, mg/L 29 25 25 28 25 28 27 27 28 27 27 23 27

Activated Sludge Effluent AS1 (E & W)* BOD-T, mg/L 4.0 4.2 4.0 4.0 4.4 4.1 4.9 7.2 4.1 4.6 4.1 4.0 4.5 BOD-C, mg/L 4.0 4.0 4.0 4.0 4.0 4.0 4.1 4.6 4.0 4.0 4.0 4.0 4.1 TSS, mg/L 3.6 4.3 4.6 4.1 4.6 5.6 6.4 5.4 5.0 5.0 4.6 4.1 4.8 COD, mg/L 26 29 31 30 33 32 33 34 30 30 31 30 31 Ammonia-N, mg/L 0.9 0.9 1 0.9 0.9 0.8 0.8 0.7 0.3 0.3 0.2 0.3 0.7 Turbidity, NTU 1.5 2.0 2.1 2.1 2.1 2.1 2.2 2.2 1.8 1.9 1.8 1.8 2.0 Flow, mgd 45.1 54.3 57.5 53.4 55.8 56.6 55.4 54.0 49.0 50.9 48.8 52.5 53 Reactors in Service,# #DIV/0! MCRT, days ** 5.86 5.86 6.13 6.19 6.47 5.72 5.26 5.40 5.76 5.46 5.57 5.56 5.77 F/M,#BOD/#MLVSS 0.26 0.23 0.25 0.22 0.25 0.20 0.20 0.23 0.24 0.25 0.24 0.22 0.23 MLSS, mg/L 3209 2991 3302 3092 2830 3578 3271 2950 3031 2949 2754 2942 3070 MLVSS, mg/L 2529 2446 2719 2538 2380 3002 2752 2397 2450 2397 2243 2386 2520 SVI, mL/g 77 77 77 78 78 86 92 89 93 80 81 83 83 RAS TSS, mg/L 10130 9547 10355 9386 8565 10685 9651 8791 8680 9190 8183 8771 9,330 RAS VSS, mg/L 7771 7527 8235 7649 7069 8919 8109 7252 7035 7282 6703 7159 7,560 RAS, Flow, mgd 23.0 26.6 28.2 26.5 28.2 30.9 29.8 29.2 26.4 27.5 26.2 28.4 27.6 Air Use, cf/#BODc rmvd 1120 1322 1234 1137 1218 1218 1264 1264 1036 1046 1241 1325 1200 Finals in Service, # #DIV/0! Sludge yield#WAS/#BODrmvd 0.71 0.73 0.73 0.72 0.67 1.1 1.3 1.16 0.9 0.88 0.94 1.18 0.92 Sludge yield#WAS/#CODrmvd 0.36 0.34 0.35 0.36 0.34 0.58 0.60 0.52 0.47 0.48 0.47 0.51 0.45 WAS AS1 flow, mgd 0.54 0.52 0.52 0.58 0.56 0.64 0.68 0.67 0.65 0.65 0.65 0.65 0.61

Activated Sludge Influent AS2 BOD-T, mg/L 183 137 150 156 139 140 140 153 144 153 161 161

Page 1 of 4 Plant 1 TPODS 2016 TSS, mg/L 88 52 55 51 47 58 61 65 53 61 65 74 VSS, mg/L 68 42 45 42 38 48 50 54 43 51 54 61 COD, mg/L 357 288 304 305 279 280 285 303 296 314 312 332 Ammonia-N, mg/L 36 32 32 34 34 32 31 31 34 34 33 32

Activated Sludge Effluent AS2 (e & w) Flow, mgd 51.0 53.0 54.0 54.0 52.0 51.0 51.0 52.0 51.0 50.0 52.0 52.0 51.9 MCRT, days ** 6.6 7.7 9.1 7.7 8.1 6.9 6.6 6.3 6.9 6.4 6.7 6.6 7.1 F/M,#BOD/#MLVSS 0.30 0.25 0.23 0.25 0.24 0.24 0.22 0.27 0.25 0.26 0.26 0.25 0.25 MLSS, mg/L 3715 3227 3756 3778 3158 2916 3397 3326 3111 3308 3316 3542 3380 MLVSS, mg/L 2995 2680 3154 3181 2693 2522 2907 2780 2636 2827 2811 2957 2850 SVI, mL/g 74 66 79 76 82 83 89 100 114 105 103 93 89 RAS TSS, mg/L 11390 9018 10237 10562 8028 7906 9482 9641 8998 9501 9271 9761 9,480 RAS VSS, mg/L 9248 7506 8563 8923 6814 6816 8131 8157 7686 8160 7900 8212 8,010 RAS, Flow, mgd 28.1 31.6 32.6 32.3 30.9 30.3 30.3 31.1 30.4 30.1 30.7 31.2 30.8 Air Use, cf/#BOD rmvd 590 817 842 724 665 654 687 626 599 632 650 758 690 Finals in Service, # #DIV/0! MLR Flow, mgd 40.0 46.6 47.7 46.4 42.3 35.2 36.8 43.9 41.3 38.9 45.7 42.1 42.2 Sludge yield#WAS/#BODrmvd 0.74 0.71 0.64 0.75 0.72 0.79 0.89 0.89 0.79 0.74 0.79 0.91 0.78 Sludge yield#WAS/#CODrmvd 0.34 0.31 0.29 0.35 0.33 0.36 0.49 0.45 0.41 0.41 0.42 0.43 0.38 WAS AS2 flow, mgd 0.59 0.53 0.47 0.55 0.58 0.62 0.63 0.63 0.6 0.6 0.64 0.66 0.59

2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 1 WASTEWATER TREATMENT PROCESSES (cont'd)

DAF Thickeners Flow, mgd 1.10 1.00 0.80 1.00 1.20 1.30 1.30 1.30 1.30 1.30 1.30 1.3 1.18 Float, TSS% 4.8 4.8 4.7 4.6 4.6 4.5 4.3 4.5 4.6 4.6 4.5 4.6 4.6 Float, VSS% 3.7 3.8 3.7 3.8 3.8 3.8 3.6 3.7 3.7 3.7 3.7 3.8 3.7 Underflow TSS, mg/L 27 23 34 25 27 36 21 23 23 23 25 21 26 Recovery, % 100 100 100 100 100 100 100 100 100 100 100 100 100 Polymer dose, lb/ton dry 17.2 16.8 18.2 18.1 15.4 13.4 14.4 14.7 15.8 13.8 14.4 14.5 15.6 Units in Service, # 6 5 5 6 6 6 6 6 6 6 5 6 6 Float Flow, cu ft/ day 35641 24394 28825 29992 26903 33366 34681 34420 30821 31321 32342 35718 31,500

Primary Sludge Pumped from basins,** ft 3/d 86989 79194 95854 102972 107468 107703 102800 108760 107470 105245 110314 122295 103,100 Flow to Digstrs.,*** ft 3/d 57899 64698 68207 66555 62227 61185 56811 67789 64729 62709 64100 74100 64,300 Total Solids, % 3.70 3.85 3.96 4.06 4.10 4.07 4.40 4.35 4.43 4.60 4.60 4.21 4.19 Volatile Solids, % 2.82 3.00 3.14 3.22 3.25 3.25 3.55 3.51 3.56 3.69 3.57 3.38 3.33 Sludge Diversion to Plant 2, ft 3/d 39,972 24,224 37,680 45,349 49,468 50,048 49,455 49,612 52,141 53,412 59,076 59,076 47,500

Digested Sludge Total Solids, % 2.24 2.27 2.25 2.37 2.26 2.20 2.19 2.20 2.15 2.23 2.24 2.29 2.24 Volatile Solids, % 1.46 1.46 1.50 1.63 1.53 1.48 1.51 1.49 1.47 1.51 1.53 1.55 1.51 VS Reduction, % 54 58 57 53 54 58 60 58 57 59 58 55 57

PLANT NO. 1 DIGESTERS

Digesters 5 & 6 (holding) N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Digester 7 (comixed) Volatile Acids, mg/L 107 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 TS, % 2.15 2.19 2.26 2.34 2.24 2.24 2.15 2.17 2.25 2.29 2.31 2.31 2.24 VS, % 1.43 1.40 1.49 1.61 1.52 1.52 1.52 1.49 1.54 1.58 1.61 1.58 1.52 Volatile Matter, % 67 64 66 69 68 68 71 69 68 69 70 68 68 Detention Time, days 21 22 20 20 21 20 19 18 19 19 18 17 19 Temperature, ºF 98 98 98 98 98 99 99 98 98 99 99 99.00 98 Load rate, lbVS/day/cuft 0.10 0.09 0.11 0.11 0.10 0.11 0.12 0.12 0.12 0.12 0.13 0.13 0.11

Digester 8 (comixed) Volatile Acids, mg/L 128 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 TS, % 2.21 2.2 2.33 2.31 2.21 2.18 2.19 2.17 2.21 2.28 2.26 2.28 2.24 VS, % 1.45 1.41 1.52 1.57 1.46 1.44 1.52 1.49 1.51 1.56 1.56 1.55 1.50 Volatile Matter, % 66 64 65 68 66 66 69 69 68 68 69 68 67 Detention Time, days 21 22 19 19 22.8 19.7 18.5 18.4 18 19 18 17 19 Temperature, ºF 98 98 98 98 98 99 99 98 98 99 99 99 98 Load rate, lbVS/day/cuft 0.10 0.09 0.11 0.11 0.10 0.11 0.12 0.12 0.12 0.12 0.13 0.13 0.11

Digester 9 (comixed) Volatile Acids, mg/L 126 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 TS, % 2.28 2.31 2.33 2.35 2.27 2.25 2.45 2.34 2.34 2.37 2.40 2.37 2.34 VS, % 1.47 1.44 1.54 1.62 1.55 1.50 1.59 1.54 1.55 1.59 1.65 1.60 1.55 Volatile Matter, % 64 62 66 69 68 67 65 66 66 67 69 68 66 Detention Time, days 21 22 20 21 22 20 19 19 19 19 19 18 20 Temperature, ºF 98 98 98 98 98 99 99 98 98 99 99 99 98 Load rate, lbVS/day/cuft 0.09 0.09 0.10 0.10 0.10 0.11 0.12 0.12 0.12 0.12 0.12 0.12 0.11

* Detention time is adjusted to take into account the cone volume and digester cleaning ** Based on solids in aeration basin. *** The primary sludge to digesters does not include the scum pumping or sludge diversion to Plant No. 2 page 6 of 15 2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

Digester 10 (comixed) Volatile Acids, mg/L 131 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 TS, % 2.28 2.33 2.34 2.44 2.33 2.27 2.22 2.27 2.28 2.33 2.38 2.39 2.32 VS, % 1.46 1.51 1.53 1.64 1.55 1.54 1.52 1.53 1.61 1.59 1.61 1.60 1.56 Volatile Matter, % 64 65 65 67 67 68 68 67 71 68 68 67 67 Detention Time, days 21 22 20 21 22 20 19 19 19 19 19 18 20 Temperature, ºF 98 98 98 98 98 99 99 98 98 99 99 99 98 Load rate, lbVS/day/cuft 0.09 0.09 0.10 0.10 0.10 0.11 0.12 0.12 0.12 0.12 0.12 0.12 0.11

Digester 11 (comixed) O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S

Page 2 of 4 Plant 1 TPODS 2016 Volatile Acids, mg/L TS, % #DIV/0! VS, % #DIV/0! Volatile Matter, % #DIV/0! Detention Time, days #DIV/0! Temperature, ºF #DIV/0! Load rate, lbVS/day/cuft #DIV/0!

Digester 12 (comixed) O/S Volatile Acids, mg/L 137 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 TS, % 2.32 2.37 2.32 2.47 2.28 2.19 2.09 2.19 2.22 2.29 2.30 2.28 VS, % 1.55 1.52 1.55 1.66 1.53 1.47 1.48 1.47 1.49 1.56 1.61 1.54 Volatile Matter, % 67 64 67 67 67 67 71 67 67 68 70 67 Detention Time, days 20 21 19 19 20 20 19 18 18 18 19 19 Temperature, ºF 99 98 98 98 98 98 98 98 98 99 99 98 Load rate, lbVS/day/cuft 0.10 0.10 0.11 0.11 0.11 0.11 0.12 0.12 0.12 0.12 0.09 0.11

Digester 13 (comixed) O/S O/S O/S Volatile Acids, mg/L 122 <100 <100 <100 <100 <100 <100 <100 <100 TS, % 2.05 2.09 2.05 2.21 2.16 2.06 2.03 2.08 2.10 2.09 VS, % 1.31 1.37 1.39 1.56 1.49 1.37 1.45 1.44 1.46 1.43 Volatile Matter, % 64 66 68 71 69 67 71 69 70 68 Detention Time, days 21 22 22 21 23 21 20 19 21 21 Temperature, ºF 98 98 98 98 98 98 98 98 99 98 Load rate, lbVS/day/cuft 0.09 0.09 0.10 0.10 0.09 0.10 0.11 0.12 0.11 0.10

Digester 14 (comixed) Volatile Acids, mg/L 132 <100 100 <100 <100 <100 <100 <100 <100 <100 <100 <100 TS, % 2.28 2.25 2.23 2.40 2.25 2.23 2.18 2.14 2.24 2.26 2.26 2.32 2.25 VS, % 1.53 1.46 1.49 1.68 1.55 1.53 1.52 1.47 1.53 1.57 1.57 1.60 1.54 Volatile Matter, % 67 65 67 70 69 69 70 69 68 69 69 69 68 Detention Time, days 20 22 19 19 21 20 20 19 19 19 18 17 19 Temperature, ºF 98 98 98 98 98 98 99 98 98 99 99 99 98 Load rate, lbVS/day/cuft 0.10 0.10 0.11 0.11 0.10 0.11 0.12 0.12 0.12 0.12 0.13 0.13 0.11

Digester 15 (comixed) O/S O/S O/S O/S O/S O/S O/S O/S Volatile Acids, mg/L <100 <100 <100 <100 TS, % 1.73 1.90 2.15 2.23 2.00 VS, % 1.15 1.25 1.45 1.54 1.35 Volatile Matter, % 66 66 67 69 67 Detention Time, days 257 39 20 18 84 Temperature, ºF 99 99 99 99 99 Load rate, lbVS/day/cuft 0.01 0.07 0.12 0.12 0.08

* Detention time is adjusted to take into account the cone volume and digester cleaning

2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 1 DIGESTERS (cont'd)

Digester 16 (comixed) O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S Volatile Acids, mg/L <100 <100 TS, % 1.97 2.13 2.05 VS, % 1.28 1.41 1.35 Volatile Matter, % 65 66 66 Detention Time, days 146 19 82 Temperature, ºF 99 99 99 Load rate, lbVS/day/cuft 0.04 0.11 0.08

Digester Gas, Mcf/month 43 47 53 53 52 56 54 52 46 46 44 46 49 Detention Time, days 20 22 20 20 21 21 19 20 19 20 20 18 20

H2S, Field ppmv 18 14 24 26 17 21 21 22 23 22 25 26 22

H2S, Lab ppmv 19 15 24 27 17 21 21 22 24 23 26 26 22

PLANT NO. 1 SLUDGE DEWATERING

Belt Presses Feed, MG/month 27.9 25.0 28.0 28.5 26.8 28.7 27.4 25.7 25.1 23.0 21.4 23.4 25.9 Feed, % TS 2.19 2.25 2.29 2.32 2.15 2.07 2.12 2.11 2.20 2.31 2.34 2.22 2.21 Cake, % TS 18.38 18.36 18.91 18.43 18.74 17.62 17.84 17.39 17.76 17.67 17.71 17.29 18.01 Filtrate, % TSS 0.03 0.03 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 Cake, wet tons/month 12607 12607 12724 12507 11830 13102 12551 12508 12698 11111 10929 11199 12,198 Truck Loads, No. 497 497 502 493 467 520 498 496 504 440 433 445 483 Capture, % 98 97 98 98 98 98 98 98 98 98 96 98 98 Polymer Dose, lb/Ton 11 10 11 11 13 13 11.0 11.0 11.0 10.0 10.0 11.0 11.1 Polymer Usage, lb 24106 21690 26523 28130 28472 27926 23363 21311 22401 19110 19188 20345 23,500

PLANT NO. 1 ODOR CONTROL

Scrubbers, Headworks

H 2S In, ppm 2.25 2.88 7.00 2.75 1.88 2.18 2.41 1.84 2.75 4.47 6.16 8.85 3.79

H 2S Out, ppm 0.08 0.13 0.23 0.09 0.08 0.06 0.08 0.10 0.13 0.16 0.24 0.26 0.14 Unit Efficiency, % 96 95 97 97 96 97 97 95 95 96 96 97 96 pH 8.4 8.4 9.1 9.2 7.8 8.3 7.6 7.6 7.3 7.1 7.5 7.0 7.9 Units in Service 4 4 4 4 4 4 4 4 4 4 4 4 4

Scrubbers, Primary

H 2S In, ppm 1.84 3.28 3.21 2.53 2.70 2.13 1.73 2.20 2.41 2.62 3.14 2.76 2.55

H 2S Out, ppm 0.27 0.32 0.24 0.21 0.18 0.18 0.13 0.14 0.18 0.24 0.21 0.14 0.20 Unit Efficiency, % 85 90 93 92 93 92 92 94 93 91 93 95 92

Page 3 of 4 Plant 1 TPODS 2016 pH 7.5 7.7 8.1 8.6 7.7 7.5 7.4 7.3 7.3 7.5 7.4 7.5 7.6 Units in Service 4 4 4 4 4 4 4 4 4 4 4 4 4

Odor Complaints (OCSD related) (total) Plant No. 1 1 2 2 12 28 8 1 2 1 1 2 1 61 Collections 3 0 3 5 6 4 0 1 1 0 0 0 23

* Detention time is adjusted to take into account the cone volume and digester cleaning

Page 4 of 4

Plant 2 TPODS 2016 2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 2 WASTEWATER TREATMENT PROCESSES

Plant Influent BOD-T, mg/L 293 328 285 292 329 336 353 344 349 363 361 340 330 BOD-C, mg/L 185 199 185 184 207 221 222 222 224 232 231 221 210 BOD-C, mg/L -corrected* 128 163 123 109 125 140 140 137 146 146 131 124 130 TSS, mg/L 512 598 538 560 524 552 605 578 628 647 638 666 587 TSS, mg/L -corrected* 358 488 378 361 300 332 367 333 395 382 353 389 370 VSS, mg/L 421 490 446 469 433 460 512 483 529 549 538 563 491 Ammonia, mg/L 42 35 32 34 36 35.0 35.0 35.0 39.0 38 36 38 36.3 Grease and Oil, mg/L 81.0 66.1 95.5 103.7 79.8 58.8 42.7 119.0 66 95.2 161 79.5 87.4 pH 7.9 7.9 7.9 7.9 8.0 7.9 7.9 7.9 7.9 7.9 7.9 7.9 7.9

Primary Effluent

"A" Side (A.S. Influent) BOD-T, mg/L 86 100 59 57 62 72 83 79 76 87 91 79 78 TSS, mg/L 84 118 63 52 52 52 63 58 54 57 62 48 64 Ammonia, mg/L 36 33 28 29 30 33 35 36 38 39 37 37 34 Basins in service, # 4 4 4 3 3 2 2 2 2 2 2 3 3 Flow, mgd 41.6 34.2 27.7 25.0 24.7 19.9 17.8 18.7 20.77 19.8 19.6 28.48 25 Hyd. Load, gal/d/sqft 677 556 490 541 708 585 550 607 675 643 637 626 608

"B & C" Sides (TF influent) BOD-T, mg/L 88 103 63 55 65 75 79 81 81 85 85 74 78 TSS, mg/L 88 128 83 58 66 66 67 71 63 66 65 61 74 Basins in service, # 4 4 4 6 6 6 7 7 7 7 7 6 6 Flow, mgd ** 44 40 41 44 44 50 51 48 54 51 50 40 46 Hyd. Load, gal/d/sqft 684 589 447 478 478 504 467 429 492 449 448 307 480

P2 Activated Sludge Effluent BOD-C, mg/L 6.5 4.0 3.8 3.7 5.2 5.0 6.4 5.8 6.7 4.6 3.8 4.2 5.0 TSS, mg/L 13.0 10.0 8.0 9.0 7.0 9.0 11.0 9 10.0 10 6.0 6.0 9.0 VSS, mg/L 9.0 7.0 6.0 6.0 5.0 7.0 8.0 7.0 7.0 7.0 5.0 5.0 6.6 Ammonia, mg/L 28 34 26 20 13 11 20 16 19 34 38 38 25 Flow, mgd 31 34 32 19 19 18 20 23 23 25 24 24 24 Reactors in Service,# 3 4 4 4 2 2 2 2 2 2 2 2 3 Finals in Service,# 12 12 12 12 12 12 12 12 12 12 12 12 12 MCRT, days*** 1.23 0.91 2.48 1.74 1.60 1.57 1.77 1.37 1.40 1.13 1.04 1.10 1.45 F/M,#BOD/#MLVSS 0.72 0.90 0.59 0.64 0.74 0.78 0.84 0.89 0.94 1.13 1.14 1.01 0.86 MLTSS, mg/L 1369 1196 923 757 862 843 1012 1085 1043 1104 1134 1008 1,030 MLVSS, mg/L 1139 970 783 659 765 755 879 905 866 925 940 852 870 SVI, mL/g 92 103 108 47 82 86 73 106 77 154 118 237 107 RAS TSS, mg/L 2981 3039 2656 2071 2152 2136 2556 2987 2868 3210 3415 2689 2,730 RAS VSS, mg/L 2475 2462 2201 1747 1841 1857 2178 2485 2407 2709 2840 2271 2,290 RAS, Flow, mgd 15.5 15.2 15.2 10.2 10.3 9.8 10.3 11.1 11.4 12.7 12.1 12.6 12.2

* P2 influent TSS mg/L corrected for the contribution from basin maintenance, belt press filtrate (including P1 dewatering filtrate) ** "C" distribution box receives recycled flow from A.S. Plant *** based on solids in aeration basins

Page 1 of 7 Plant 2 TPODS 2016 2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 2 WASTEWATER TREATMENT PROCESSES (continued)

Trickling Filter Influent BOD-T, mg/L 88 103 63 55 65 75 79 81 81 85 85 74 78 TSS, mg/L 88 128 83 58 66 66 67 71 63 66 65 61 74 TSS, klb/day 235 259 154 147 162 167 162 156 158 146 145 137 169 Ammonia-N, mg/L 35 38 37 33 38 39 40 43 40 47 45 45 40 Flow, mgd 56 43 40 53 52 54 52 46 54 47 47.2 47.2 49 Units in Service,# 3 3 3 3 3 3 3 3 3 3 3 3 3

TF/Solids Contact Influent BOD-T, mg/L 50 120 298 205 224 219 221 261 263 258 305 271 225 TSS, mg/L 84 219 516 256 256 268 277 316 250 258 480 360 295 MLTSS, mg/L 2516 2338 2190 2213 2279 2196 2276 2319 2086 2137 2330 2092 2,248 SRT 1.83 1.85 1.98 1.99 1.95 1.92 1.93 2.01 1.89 2.16 2.18 2.1 1.98 Total Air, Mcuft/day 15.8 13.3 15.9 17.1 15.9 13.7 13.0 14.5 14.5 16.4 17.3 18.03 15.4

Clarifier Effluent BOD-C, mg/L 5 3 4.0 4.0 5 4 3.0 5.0 4 5 5 4.0 4.3 TSS, mg/L 9 10 11 10 12 9 11 12 10 9 10 10.0 10.3 Ammonia-N, mg/L 22 26 20 21 28 31 31 30 27 30 27 24 26 RSS Flow, mgd 39.5 34.9 33.3 38.6 38.6 39.7 38.9 36.2 39.4 36.9 37 35.43 37 RSS TSS, mg/L 5116 4262 3829 4456 4366 4417 4244 4118 4167 3955 4283 3805 4,252

P2 DAF Thickeners WAS Flow-AS, Mgd 1.10 1.46 0.92 0.47 0.47 0.46 0.4 0.47 0.47 0.58 0.67 0.66 0.68 WSS Flow-TF/SC, Mgd 0.80 0.86 0.84 0.75 0.79 0.78 0.8 0.8 0.79 0.72 0.72 0.74 0.78

Float, %TSS 6.33 6.43 6.87 6.73 5.47 5.53 5.50 5.59 6.67 6.45 6.16 6.17 6.16 Float, %VSS 5.04 4.97 5.31 5.27 4.41 4.56 4.45 4.42 5.31 5.25 4.90 5.02 4.91 Underflow, mg/L 32 36 23 25 47 43 56 57 37 41 60 23.00 40 Recovery, % 98 98 98 98 98 98 98 98 98 98 98 98 98 Polymer dose, lb/ton dry 3.2 3.2 3.4 3.1 3.2 3.1 3.1 3.1 3.0 2.4 2.7 3.28 3.1 Units in Service, # 2 2 2 2 1 1 1 1 1 1 1 1 1 Float Flow, cu ft/day 19492 22658 14766 10561 13939 13794 14178 15210 12122 12031 13258 11989 14,500

PLANT NO. 2 SLUDGE CHARACTERISTICS

Sludge Pumped from Sludge Blending Facility TOTAL, cuft/day 106053 112226 108308 105204 108641 103977 109698 112408 107957 104905 103622 107516 107,500 SBF, % TS 4.32 3.92 4.13 4.48 4.43 4.43 4.30 4.09 4.83 1.96 4.91 4.93 4.23 SBF, % VS 3.11 2.72 2.88 3.26 3.28 3.29 3.24 3.09 3.70 3.82 3.74 3.68 3.32

Digested sludge Total Solids, % 2.82 2.69 2.52 2.41 2.42 2.46 2.34 2.29 2.40 2.61 2.55 2.63 2.51 Volatile Solids, % 1.59 1.62 1.50 1.31 1.46 1.51 1.47 1.16 2.59 1.66 1.62 1.67 1.60 VS Reduction, % 53 46 53 65 58 58 58 51 60 58 61 58 57

Page 2 of 7 Plant 2 TPODS 2016 2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 2 DIGESTERS

Digester A O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S Volatile Acids,mg/L TS, % VS, % Volatile Matter, % Detention Time, days Temperature, ºF Load rate,lbVS/d/cuft

Digester B O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S Volatile Acids,mg/L TS, % VS, % Volatile Matter, % Detention Time, days Temperature, ºF Load rate,lbVS/d/cuft

Digester C Volatile Acids,mg/L TS, % 2.64 2.88 2.69 2.62 2.55 2.65 2.53 2.41 2.58 2.73 2.73 2.80 2.65 VS, % 1.43 1.54 1.47 1.25 1.39 1.47 1.44 1.39 1.49 1.60 1.57 1.60 1.47 Volatile Matter, % 54 54 55 48 55 56 57 58 58 58 57 57 56 Detention Time, days 50 18 23 23 21 22 21 20 22 21 23 23 24 Temperature, ºF 33 99 102 102 100 98 97 100 100 100 100 101 94 Load rate,lbVS/d/cuft 0.10 0.09 0.09 0.10 0.10 0.10 0.10 0.11 0.12 0.11 0.10 0.10

Digester D Volatile Acids,mg/L TS, % 2.60 2.59 2.63 2.53 2.56 2.62 2.48 2.38 2.56 2.72 2.75 2.80 2.60 VS, % 1.49 1.46 1.45 1.25 1.41 1.51 1.41 1.39 1.50 1.59 1.59 1.61 1.47 Volatile Matter, % 57 56 55 49 55 58 57 58 59 58 58 57 56 Detention Time, days 20.3 19.1 24.0 22.6 21.1 22.0 20.7 20.4 21.5 20.9 23.0 22.9 21.5 Temperature, ºF 102 101 102 102 101 99 98 100 99 101 100 102 101 Load rate,lbVS/d/cuft 0.10 0.10 0.09 0.09 0.10 0.10 0.10 0.10 0.11 0.12 0.11 0.10 0.10

Digester E Volatile Acids,mg/L TS, % 2.68 2.57 2.61 2.56 2.59 2.68 2.54 2.41 2.68 2.83 2.80 2.80 2.65 VS, % 1.57 1.45 1.45 1.25 1.44 1.52 1.46 1.42 1.59 1.68 1.65 1.65 1.51 Volatile Matter, % 58 56 55 49 56 57 58 59 59 59 59 59 57 Detention Time, days 17.9 17.9 24.1 21.2 19.9 20.9 19.4 20.2 20.4 20.0 21.9 21.6 20.5 Temperature, ºF 100 101 101 102 100 100 99 100 100 100 100 101 100 Load rate,lbVS/d/cuft 0.11 0.10 0.09 0.10 0.11 0.10 0.11 0.10 0.12 0.12 0.11 0.11 0.11

Digester F Volatile Acids,mg/L TS, % 2.79 2.74 2.66 2.59 2.60 2.66 2.55 2.44 2.68 2.81 2.74 2.77 2.67 VS, % 1.62 1.58 1.47 1.32 1.46 1.49 1.47 1.44 1.59 1.69 1.63 1.64 1.53 Volatile Matter, % 58 58 55 51 56 56 58 59 59 60 59 59 57 Detention Time, days 19.6 21.2 23.7 22.0 20.5 21.4 19.9 19.4 20.9 20.4 22.5 22.4 21.2 Temperature, ºF 102 102 102 102 100 99 98 99 101 101 101 101 101 Load rate,lbVS/d/cuft 0.10 0.09 0.09 0.10 0.10 0.10 0.10 0.10 0.12 0.12 0.11 0.11 0.10

Page 3 of 7 Plant 2 TPODS 2016 2014 2015 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 2 DIGESTERS (cont'd.)

Digester G Volatile Acids,mg/L TS, % 2.80 3.48 2.77 2.7 2.70 2.79 2.57 2.46 2.65 2.82 2.85 2.98 2.80 VS, % 1.64 1.83 1.53 1.36 1.50 1.54 1.46 1.43 1.55 1.66 1.65 1.74 1.57 Volatile Matter, % 58 54 55 50 56 55 57 58 58 59 58 58 56 Detention Time, days 19.7 21.5 24.0 22.5 20.7 21.5 20.0 19.9 21.1 20.7 22.7 22.6 21.4 Temperature, ºF 102 102 101 102 101 100 100 101 101 101 102 102 101 Load rate,lbVS/d/cuft 0.10 0.09 0.09 0.10 0.10 0.10 0.10 0.10 0.11 0.12 0.11 0.11 0.10

Digester H O/S O/S Volatile Acids,mg/L TS, % 3.54 3.64 2.90 2.49 2.59 2.68 2.55 2.47 2.71 2.80 2.84 VS, % 2.07 2.01 1.61 1.22 1.43 1.51 1.48 1.46 1.60 1.67 1.61 Volatile Matter, % 58 55 56 49 55 56 58 59 59 60 57 Detention Time, days 19.7 21.4 26.2 25.9 20.8 21.8 20.3 20.1 21.3 26.6 22.4 Temperature, ºF 100 102 102 102 101 101 99 100 100 71 98 Load rate,lbVS/d/cuft 0.10 0.09 0.09 0.08 0.10 0.10 0.10 0.10 0.11 0.11 0.10

Digester I Volatile Acids,mg/L TS, % 2.4 2.49 2.57 2.69 2.58 2.50 2.60 2.79 2.81 2.87 2.63 VS, % 1 1.22 1.44 1.53 1.51 1.45 1.53 1.66 1.65 1.68 1.50 Volatile Matter, % 55 49 56 57 59 58 59 59 59 59 57 Detention Time, days 56.0 0 23.0 21.6 21.7 21.1 20.1 21.3 21.4 22.5 23.0 22.9 Temperature, ºF 92 99 100 100 100 100 100 100 100 100 100 99 Load rate,lbVS/d/cuft 0.06 0.08 0.10 0.10 0.10 0.10 0.10 0.11 0.12 0.11 0.10 0.10

Digester J O/S O/S O/S O/S O/S O/S O/S O/S O/S O/S Volatile Acids,mg/L TS, % #DIV/0! VS, % #DIV/0! Volatile Matter, % #DIV/0! Detention Time, days 33.9 33.9 Temperature, ºF 97 97 Load rate,lbVS/d/cuft 0.06 0.06

Digester K (Holding)

Digester L (Comixed) Volatile Acids,mg/L TS, % 2.79 2.79 2.81 2.72 2.66 2.71 2.50 2.47 2.66 2.82 2.79 2.86 2.72 VS, % 1.66 1.59 1.55 1.41 1.48 1.54 1.45 1.46 1.57 1.68 1.63 1.68 1.56 Volatile Matter, % 59 57 55 52 56 57 58 59 59 59 59 59 57 Detention Time, days 18.0 17.0 21.4 23.0 21.1 22.0 20.5 20.4 21.6 21.1 23.1 23.3 21.0 Temperature, ºF 100 100 100 100 100 100 100 100 100 100 100 100 100 Load rate,lbVS/d/cuft 0.11 0.11 0.10 0.09 0.10 0.10 0.10 0.10 0.11 0.12 0.10 0.10 0.10

Page 4 of 7 Plant 2 TPODS 2016 Digester M (Comixed) O/S O/S O/S O/S O/S O/S O/S Volatile Acids,mg/L TS, % 2.36 3.21 2.69 2.61 2.58 VS, % 1.38 1.80 1.48 1.33 1.42 Volatile Matter, % 58 56 55 51 55 Detention Time, days 23 22 22 23 28 Temperature, ºF 98 96 97 97 97 Load rate,lbVS/d/cuft 0.09 0.09 0.09 0.09 0.08

Digester N (Comixed) Volatile Acids,mg/L TS, % 2.76 3.00 2.76 2.59 2.67 2.68 2.52 2.42 2.54 2.72 2.67 2.70 2.67 VS, % 1.62 1.69 1.51 1.32 1.49 1.51 1.43 1.41 1.48 1.59 1.56 1.58 1.52 Volatile Matter, % 58 56 55 51 56 56 57 58 58 58 58 59 57 Detention Time, days 18.4 0.0 22.5 22.5 20.9 21.8 20.3 20.1 21.4 20.7 22.7 22.7 19.5 Temperature, ºF 100 95 99 99 100 99 99 99 100 100 100 100 99 Load rate,lbVS/d/cuft 0.11 0.09 0.09 0.10 0.10 0.10 0.10 0.10 0.11 0.12 0.11 0.11 0.10

Page 5 of 7 Plant 2 TPODS 2016 page 12 of 15 2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 2 DIGESTERS (cont'd.) Digester O (Comixed) Volatile Acids,mg/L TS, % 2.74 2.8 2.84 2.67 2.72 2.71 2.61 2.53 2.6 2.79 2.81 2.88 2.73 VS, % 1.59 1.60 1.55 1.34 1.50 1.52 1.47 1.46 1.53 1.62 1.63 1.69 1.54 Volatile Matter, % 58 57 55 50 55 56 56 58 59 58 58 59 57 Detention Time, days 18.9 20.2 22.4 22.5 20.7 21.7 20.2 20.0 21.2 20.8 22.9 22.8 21.2 Temperature, ºF 100 99 99 99 99 99 99 99 99 99 99 100 99 Load rate,lbVS/d/cuft 0.11 0.10 0.09 0.10 0.10 0.10 0.10 0.10 0.11 0.12 0.11 0.11 0.10

Digester P (Comixed) Volatile Acids,mg/L TS, % 2.82 2.95 2.77 2.64 2.70 2.70 2.53 2.47 2.60 3.40 3.10 3.18 2.82 VS, % 1.65 1.69 1.53 1.33 1.52 1.52 1.44 1.45 1.53 1.85 1.77 1.83 1.59 Volatile Matter, % 59 57 55 51 56 56 57 59 59 55 57 57 57 Detention Time, days 19.4 20.0 23.1 23.6 20.8 21.8 20.3 20.1 21.3 24.2 22.8 22.7 21.7 Temperature, ºF 101 100 101 102 101 100 100 101 99 101 100 102 101 Load rate,lbVS/d/cuft 0.11 0.10 0.09 0.09 0.10 0.10 0.10 0.10 0.11 0.10 0.11 0.11 0.10

Digester Q (Comixed) O/S O/S O/S O/S O/S O/S O/S O/S O/S Volatile Acids,mg/L TS, % 2.75 2.34 2.74 2.61 VS, % 1.61 1.33 1.59 1.51 Volatile Matter, % 59 57 58 58 Detention Time, days 22.9 22.8 22.9 Temperature, ºF 42 103 102 82 Load rate,lbVS/d/cuft 0.09 0.09 0.10 0.10

Digester R (Comixed) Volatile Acids,mg/L TS, % 2.71 2.76 2.70 2.57 2.71 2.63 2.53 2.70 2.58 2.8 2.86 2.93 2.71 VS, % 1.58 1.58 1.50 1.29 1.51 1.49 1.46 1.58 1.51 1.63 1.65 1.69 1.54 Volatile Matter, % 58 57 55 50 56 56 58 58 59 58 58 58 57 Detention Time, days 20.2 21.4 24.6 24.0 20.8 21.8 20.3 20.1 21.3 20.5 22.4 22.3 21.6 Temperature, ºF 101 101 101 101 102 101 101 101 100 102 102 102 101 Load rate,lbVS/d/cuft 0.10 0.09 0.09 0.09 0.10 0.10 0.10 0.10 0.11 0.12 0.11 0.11 0.10

Digester S (Comixed) Volatile Acids,mg/L TS, % 2.70 2.81 2.70 2.83 2.63 2.61 2.63 2.67 2.59 2.80 2.90 2.94 2.73 VS, % 1.61 1.62 1.49 1.39 1.45 1.47 1.51 1.56 1.52 1.64 1.68 1.71 1.55 Volatile Matter, % 59 58 55 50 55 56 57 58 59 58 58 58 57 Detention Time, days 19.9 21.7 24.8 24.0 21.1 22.1 20.5 20.2 21.6 20.6 22.8 22.7 21.8 Temperature, ºF 100 101 101 101 101 101 100 101 100 101 101 102 101 Load rate,lbVS/d/cuft 0.10 0.09 0.08 0.09 0.10 0.10 0.10 0.10 0.11 0.12 0.11 0.11 0.10

Digester T (Comixed) Volatile Acids,mg/L TS, % 2.87 2.83 2.81 2.64 2.72 2.75 2.64 2.55 2.59 2.81 2.81 2.87 2.74 VS, % 1.73 1.64 1.58 1.32 1.52 1.56 1.53 1.49 1.52 1.67 1.64 1.70 1.58 Volatile Matter, % 60 58 56 50 56 57 58 58 59 59 58 59 57 Detention Time, days 18.1 20.1 22.0 22.7 21.1 22.1 20.6 20.4 21.7 21.1 23.1 23.0 21.3 Temperature, ºF 101 101 101 102 101 101 99 100 100 101 102 102 101 Load rate,lbVS/d/cuft 0.11 0.10 0.09 0.10 0.10 0.10 0.10 0.10 0.11 0.12 0.11 0.10 0.10

Digesters, combined Digester Gas, Mcf/mth 74 66 63 67 71 83 85 78 84 80 80 76 76 Detention Time, days 20.3 21.2 23.7 24.5 21.4 21.9 20.8 20 21 21 24 23 22 Hydrogen sulfide, ppmv 20 21 27 24 17 17 16 19 21 21 23 23 21

Page 6 of 7 Plant 2 TPODS 2016 2015 2016 Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Avg.

PLANT NO. 2 SLUDGE DEWATERING

Belt Presses Feed, Mcf/month 3.62 4.07 3.56 3.43 3.79 3.69 3.89 3.75 3.71 3.43 3.85 3.67 3.71 Feed, % TS 2.96 2.64 2.65 2.68 2.58 2.51 2.52 2.49 2.56 2.68 2.61 2.77 2.64 Cake, % TS 22.03 21.65 21.29 21.88 22.23 21.81 21.71 21.66 20.98 20.94 21.19 21.49 21.57 Filtrate, % TSS 0.04 0.04 0.03 0.03 0.03 0.03 0.04 0.04 0.03 0.05 0.04 0.03 0.04 Cake, wet tons/month 10695 12972 11587 10361 11245 10813 11468 10199 11883 11752 12923 12362 11522 Truckloads, No. 414 504 451 403 438 420 447 394 461 457 505 485 448 Capture, % 99 99 99 99 99 99 99 99 99 98 98 99 99 Polymer Dose, lb/Ton 4.2 1.7 4.6 4.4 4.4 4.3 4.5 4.4 4.3 4.3 4.5 4.8 4.2 Polymer Usage, Tons 7.3 8.6 7.6 6.9 7.3 6.9 7.6 7.0 7.0 6.8 7.8 8.5 7.4

PLANT NO. 2 ODOR CONTROL

Scrubbers, Chemical

H 2S in, ppm 0.8 1.6 2.5 2.6 0.8 0.7 0.6 0.8 0.6 0.9 0.9 0.9 1.1

H 2S out, ppm 0.11 0.10 0.13 0.08 0.08 0.06 0.04 0.08 0.12 0.07 0.11 0.13 0.09 Unit efficiency, % 87 94 95 97 90 90 94 89 82 92 87 86 90 Units in Service 18 17 20 18 17 17 19 17 20 15 16 15 17

Scrubbers Biotrickling

H 2S in, ppm 12 12 38 44 8 9 12 15 16 20 13 10 17

H 2S out, ppm 2.0 1.7 9.2 9.7 1.3 1.6 2.2 1.0 1.1 1.3 2.0 2.43 2.9 Unit efficiency, % 83 85 76 78 85 84 81 93 93 87 85 75 84 Units in Service 13 13 13 13 13 13 13 13 13 13 13 13 13

Scrubbers Carbon

H 2S out, ppm 0.07 0 0.1 0 0 0 0 0.01 0 0.01 0.04 0.01 0.02 Units in Service 4 4 5 4 4 4 4 4 4 4 4 4 4

Odor Complaints (OCSD related) (total) Plant No. 2 0 3 2 4 0 2 0 2 0 1 3 2 19

Page 7 of 7

Current Plant 1 Solids Flows and Loads w/o Sludge from MWRP

Purpose: Estimate current and future Plant 1 sludge flows and loads w/o sludge from MWRP. Approach: 1. Plant 1 current solids flows and loads for 2016 are calculated from TPOD data. 2. MWRP solids flows and loads to OCSD are from the White Paper (Table 2 and Table 3). MWRP will stop sending sludge to OCSD Plant 1 by the end of 2018. MWRP solids TSS and BOD loads are measured and documented in the White Paper (Tables 11 -1 4). These are the basis for calculating contributions of IRWD. 3. Primary clarifier removal efficiency and WAS yield rate at Plant 1 are based on TPOD data. 4. Assumes all primary effluent goes to the activated sludge treatment system. 5. MWRP contributions are calculated based on primary clarifier removal rate (for primary sludge) and WAS yield coefficient (for WAS). 6. MWRP contributions are then deducted from Plant 1 flows and loads in Step 1.

Plant 1 TPODs solids flows and loads (w/ MWRP contribution) 2016 PS ppd 269,757 Before diversion to Plant 2 WAS ppd 90,230 TF ppd 13,777 TF data based on 2014 in the White Paper.

MWRP Sludge Flows and Loads to Plant 1 White paper Table 2 and Table 3; Pages 13 and 14. 2016 2017 2018 2019 MWRP Sludge TSS to OCSD ppd 67,760 62,000 31,000 0 MWRP Sludge BOD to OCSD ppd 36,790 37,000 18,000 0

Page 1 of 4 Current Plant 1 Solids Flows and Loads w/o Sludge from MWRP

Process Performance at Plant 1 Primary Clarifier Removal Efficiency TSS % 75 TPOD BOD % 50 TPOD WAS yield coefficient g VSS/g BOD 0.85 TPOD WAS VSS/TSS % 80 TPOD

Sludge Characteristics Current Future Primary Sludge TS % 4.1 6.00 Primary Sludge VS % 80 79 TWAS TS % 4.6 6.00 includes WAS and TF TWAS VS % 80 81 includes WAS and TF

MWRP's contribution to OCSD Plant 1 sludge production 2016 2017 2018 2019 Primary Sludge ppd 50,820 46,500 23,250 0 WAS ppd 19,545 19,656 9,563 0

OCSD Plant 1 Solids Flows and Loads excluding MWRP sludge Plant 1 2016 2016 Current Assume Co-thickening Primary Sludge ppd 218,937 218,937 Primary Sludge VS ppd 175,149 173,740 Primary Sludge Flow gpd 640,278 437,523 TWAS ppd 70,685 70,685 TF ppd 13,777 13,777 Combined Secondary Sludge VS ppd 67,569 68,673 TWAS Flow gpd 220,159 168,789 includes WAS and TF

Digester Feed TS ppd 303,398 303,398 Digester Feed VS ppd 242,719 242,413 Digester Feed Flow gpd 860,437 606,312

Page 2 of 4 Current Plant 2 Solids Flows and Loads w/o Diversion from Plant 1.

Purpose: Estimate current Plant 2 solids flows and loads w/o diversions from Plant 1. Approach: 1. Plant 2 current solids flows and loads for 2014 are based on White Paper mass balance; 2016 are based on TPOD data. 2. Plant 1 diversion to Plant 2 for 2014 are based on White Paper mass balance; 2016 are based on TPOD data. 3. Primary and secondary treatment process performances are based on the White Paper 2014 mass balance. 4. P1 contributions are calculated based on primary clarifier removal rate (for primary sludge) and WAS yield coefficient (for WAS). 5. MWRP contributions are then deducted from Plant 2 solids flows and loads in Step 1. 6. 2016 sludge flows and loads are used for digester capacity assessment under Condition 1. 7. 2014 sludge flows and loads are used for digester capacity assessment under Condition 2.

Plant 2 flows and loads w/ diversion from Plant 1. Plant 2 2014 2016 PS ppd 247,327 283,504 WAS ppd 70,227 55,706

Plant 1 Diversion Flows and Loads to Plant 2 2014 2016 White Paper TPOD TSS ppd 27,355 124,282 BOD ppd 14,806 67,268

Process Performance at Plant 2 White Paper 2014 Mass Balance Primary Clarifier Removal Efficiency TSS % 75 BOD % 60 WAS yield coefficient g VSS/g BOD 1.1 WAS VSS/TSS % 85

Page 3 of 4 Current Plant 2 Solids Flows and Loads w/o Diversion from Plant 1. Sludge Characteristics Primary Sludge TS % 4.5 White Paper Primary Sludge VS % 74 White Paper TWAS TS % 5.7 White Paper TWAS VS % 80 White Paper

Plant 1's contribution to Plant 2 sludge production 2014 2016 Primary Sludge ppd 20,516 93,211 WAS ppd 7,664 34,821

Plant 2 Sludge flows and loads excluding Plant 1 sludge diversion Plant 2 Sludge flows and loads excluding Plant 1 sludge diversion 2014 2016 Primary Sludge ppd 226,811 190,293 Primary Sludge VS ppd 167,840 140,817 Primary Sludge Flow gpd 604,345 507,043 WAS ppd 62,563 20,885 WAS VS ppd 49,872 16,648 TWAS Flow gpd 131,606 43,932

Digester Feed TS ppd 289,373 211,178 Dieter Feed VS ppd 217,712 157,465 Digester Feed Flow gpd 735,951 550,975

Page 4 of 4

2035 Digester Feed Flows and Loads Projections for Plant 1 and Plant 2

Approach 1. Solids Loadings Projections are based on White Paper Table 16 Condition 1 and Condition 2. 2. Solids characteristics are based on White Paper mass balance sheets.

2035 Projections Condition 1 Condition 2 AA AA PS ppd 291,000 233,000 WAS ppd 102,000 76,000 Plant 1 TF ppd 15,000 14,000 AA AA PS ppd 196,000 250,000 WAS ppd 31,000 47,000 Plant 2 TF ppd 33,000 39,000

Page 1 of 2 2035 Digester Feed Flows and Loads Projections for Plant 1 and Plant 2

Assumptions Condition 1 Condition 2 TPS TS % 6.0 6 White Paper PS VS % 80 80 White Paper PS Thickening Solids Capture Rate % 95 95 White Paper TWAS TS % 6.0 6 White Paper WAS VS % 80 80 White Paper Plant 1 TWAS Solids Capture Rate % 95 95 White Paper TPS TS % 4.5 4.5 White Paper PS VS % 74 74 White Paper PS Thickening Solids Capture Rate % 100 100 White Paper TWAS TS % 5.7 5.7 White Paper WAS VS % 82.5 82.5 White Paper Plant 2 TWAS Solids Capture Rate % 98 98 White Paper

2035 Digester Feed Condition 1 Condition 2 AA AA Calculated Primary Sludge TS ppd 276,000 221,000 Primary Sludge VS ppd 221,000 177,000 Primary Sludge Flow gpd 552,000 442,000 Combined Secondary Sludge TS ppd 111,000 86,000 Combined Secondary Sludge VS ppd 89,000 69,000 Combined Secondary Sludge Flow gpd 222,000 172,000 TS ppd 387,000 307,000 Calculated TS % 6.0 6.0 Calculated Flow gpd 774,000 614,000 Calculated VS ppd 310,000 246,000 Calculated Plant 1 VS % 80 80 Calculated AA AA Primary Sludge TS ppd 196,000 250,000 Primary Sludge VS ppd 145,000 185,000 Primary Sludge Flow gpd 522,000 666,000 Combined Secondary Sludge TS ppd 63,000 84,000 Combined Secondary Sludge VS ppd 52,000 69,000 Combined Secondary Sludge Flow gpd 133,000 177,000 TS ppd 259,000 334,000 Calculated TS % 4.7 4.8 Calculated Flow gpd 655,000 843,000 Calculated VS ppd 197,000 254,000 Calculated Plant 2 VS % 76 76 Calculated

Page 2 of 2

Plant 1 Digester Capacity Evaluation

Purpose: Calculate digester capacity available for co-digestion at Plant 1. Approach: 1. 2016 solids flows and loads w/o MWRP contribution and w/o diversion to Plant 2, assuming co-thickening, are used as the start point for future solids projection. This is for future solids projection purpose and does not reflect real digester feed flows and loads for 2016 - 2018. MWRP contribution and diversion to Plant 2 are expected to stop by the end of 2018. New co-thickening facility is also planned to be in service by the end of 2018. 2. Future solids flows and loads calculated based on 2016 (in Step 1) and 2035 data assuming linear growth.

Results: There will no excess digester capacity for co-digestion at Plant No. 1.

Recommendation: Co-digestion of FW at Plan 1 is not recommended.

Typical Condition Service Condition Sludge and Food Waste Characteristics Existing Digesters Sludge Diameter ft 110 110 VSR-Meso % 57 Design Criteria SWD ft 29 29 VSR-Thermo% 61 Digestion design Typical Active Capacity MG 2.06 2.06 Biogas Productioncf/lb VSR Rate 15 Service Condition (B) parameter Condition (A) Total No. of Digesters 8 8 Food Waste OLR, lb/cf- Units HRT, days OLR, lb/cf-day HRT, days day No. of Digester out of Service 1 2 TS (%) 12 Conventional Mesophilic 0.15 18 0.15 16 (CMAD) Diameter ft 90 90 VS (%) 85 SWD ft 29 29 SG 1.2 Active Capacity MG 1.38 1.38 FW VSR (%) 80 A – One large digester out of service at peak 15-day loads Total No. of Digesters 2 2 Biogas Productioncf/lb VSR Rate 15 B – Two large digesters out of service at peak 15-day loads No. of Digester out of Service 0 0 C – Class B process Future Digesters CenGen Capacity Diameter ft Unit Capacityscfm 730 SWD ft No. of EQ # 3 Assumptions Active Capacity MG 1. Peak 15-D : AA Peaking Factor 1.2 Total No. of Digesters 2. Growth of solids flows and loads is linear. No. of Digester out of Service Total Available Digester Capacity MG 17.2 15.1

Page 1 of 6 Plant 1 Digester Capacity Evaluation

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Page 2 of 6 Plant 1 Digester Capacity Evaluation Condition 1 FW AA Peak 15-Day Typical Condition Service Condition Typical Condition Service Condition HRT Potential HRT Based OLR Based Based OLR Based HRT FW for Co- Flow VS Loads Flow VS Loads Capacity Capacity Capacity Capacity HRT Based OLR Based Based OLR Based digestion Year gpd ppd gpd ppd MG MG MG MG wtpd wtpd wtpd wtpd wtpd 2019 632,789 253,085 759,347 303,702 13.7 15.1 12.1 15.1 979 168 457 0 0 2020 641,614 256,642 769,937 307,970 13.9 15.4 12.3 15.4 926 150 397 0 0 2021 650,440 260,199 780,528 312,239 14.0 15.6 12.5 15.6 873 133 338 0 0 2022 659,266 263,756 791,119 316,507 14.2 15.8 12.7 15.8 820 115 278 0 0 2023 668,092 267,313 801,710 320,776 14.4 16.0 12.8 16.0 767 98 218 0 0 2024 676,917 270,871 812,301 325,045 14.6 16.2 13.0 16.2 714 80 159 0 0 2025 685,743 274,428 822,892 329,313 14.8 16.4 13.2 16.4 661 63 99 0 0 2026 694,569 277,985 833,482 333,582 15.0 16.6 13.3 16.6 608 46 39 0 0 2027 703,394 281,542 844,073 337,851 15.2 16.8 13.5 16.8 555 28 0 0 0 2028 712,220 285,100 854,664 342,119 15.4 17.1 13.7 17.1 502 11 0 0 0 2029 721,046 288,657 865,255 346,388 15.6 17.3 13.8 17.3 449 0 0 0 0 2030 729,871 292,214 875,846 350,657 15.8 17.5 14.0 17.5 396 0 0 0 0 2031 738,697 295,771 886,437 354,925 16.0 17.7 14.2 17.7 343 0 0 0 0 2032 747,523 299,328 897,027 359,194 16.1 17.9 14.4 17.9 290 0 0 0 0 2033 756,349 302,886 907,618 363,463 16.3 18.1 14.5 18.1 237 0 0 0 0 2034 765,174 306,443 918,209 367,731 16.5 18.3 14.7 18.3 184 0 0 0 0 2035 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2036 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2037 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2038 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2039 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2040 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2041 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2042 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2043 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2044 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0 2045 774,000 310,000 928,800 372,000 16.7 18.6 14.9 18.6 131 0 0 0 0

Notes: 1. 2016 solids flows and loads w/o MWRP contribution and w/o diversion to Plant 2, assuming co-thickening, are used as the start point for future solids projection. This is for future solids projection purpose and does not reflect real digester feed flows and loads for 2016 - 2018. MWRP contribution and diversion to Plant 2 are expected to stop by the end of 2018. New co-thickening facility is also planned to be in service by the end of 2018. 2. Currently digester feed TS% at Plant 1 is approximately 4.2%, resulting in no excess digester capacity for food waste co-digestion. 3. After co-thickening come online in 2019, the digester feed TS% will increase to 6%. There will be very little excess digester capacity for food waste co-digestion in 2019. 4. As solids flows and loads increase, there will be no excess digester capacity by 2022.

Page 3 of 6 Plant 1 Digester Capacity Evaluation Condition 1 Digester Gas Production CenGen Capacity AA Peak 15-Day

1 Unit All in Sludge FW Total Sludge FW Total OOS Service scfm scfm scfm scfm scfm scfm scfm scfm 1,503 0 1,503 1,803 0 1,803 1460 2190 1,524 0 1,524 1,829 0 1,829 1460 2190 1,545 0 1,545 1,854 0 1,854 1460 2190 1,566 0 1,566 1,879 0 1,879 1460 2190 1,587 0 1,587 1,905 0 1,905 1460 2190 1,608 0 1,608 1,930 0 1,930 1460 2190 1,629 0 1,629 1,955 0 1,955 1460 2190 1,651 0 1,651 1,981 0 1,981 1460 2190 1,672 0 1,672 2,006 0 2,006 1460 2190 1,693 0 1,693 2,031 0 2,031 1460 2190 1,714 0 1,714 2,057 0 2,057 1460 2190 1,735 0 1,735 2,082 0 2,082 1460 2190 1,756 0 1,756 2,107 0 2,107 1460 2190 1,777 0 1,777 2,133 0 2,133 1460 2190 1,798 0 1,798 2,158 0 2,158 1460 2190 1,820 0 1,820 2,183 0 2,183 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190 1,841 0 1,841 2,209 0 2,209 1460 2190

Notes: 1. Assumes no FW co-digestion at Plan 1.

Page 4 of 6 Plant 1 Digester Capacity Evaluation

Condition 2 FW AA Peak 15-Day Typical Condition Service Condition Typical Condition Service Condition

HRT Potential HRT Based OLR Based Based OLR Based HRT FW for Co- Flow VS Loads Flow VS Loads Capacity Capacity Capacity Capacity HRT Based OLR Based Based OLR Based digestion Year gpd ppd gpd ppd MG MG MG MG wtpd wtpd wtpd wtpd wtpd 2019 607,526 242,979 729,031 291,575 13.1 14.5 11.7 14.5 1,131 217 627 48 48 2020 607,930 243,168 729,516 291,802 13.1 14.6 11.7 14.6 1,128 216 625 47 47 2021 608,335 243,357 730,002 292,028 13.1 14.6 11.7 14.6 1,126 215 622 46 46 2022 608,740 243,546 730,487 292,255 13.1 14.6 11.7 14.6 1,124 214 619 45 45 2023 609,144 243,735 730,973 292,481 13.2 14.6 11.7 14.6 1,121 213 616 45 45 2024 609,549 243,923 731,459 292,708 13.2 14.6 11.7 14.6 1,119 212 614 44 44 2025 609,954 244,112 731,944 292,935 13.2 14.6 11.7 14.6 1,116 212 611 43 43 2026 610,358 244,301 732,430 293,161 13.2 14.6 11.7 14.6 1,114 211 608 42 42 2027 610,763 244,490 732,915 293,388 13.2 14.6 11.7 14.6 1,111 210 606 41 41 2028 611,167 244,678 733,401 293,614 13.2 14.6 11.7 14.6 1,109 209 603 40 40 2029 611,572 244,867 733,887 293,841 13.2 14.7 11.7 14.7 1,107 208 600 39 39 2030 611,977 245,056 734,372 294,067 13.2 14.7 11.7 14.7 1,104 207 597 38 38 2031 612,381 245,245 734,858 294,294 13.2 14.7 11.8 14.7 1,102 206 595 37 37 2032 612,786 245,434 735,343 294,520 13.2 14.7 11.8 14.7 1,099 205 592 36 36 2033 613,191 245,622 735,829 294,747 13.2 14.7 11.8 14.7 1,097 204 589 35 35 2034 613,595 245,811 736,314 294,973 13.3 14.7 11.8 14.7 1,094 203 586 34 34 2035 614,000 246,000 736,800 295,200 13.3 14.7 11.8 14.7 1,092 202 584 33 33 2036 614,405 246,189 737,286 295,427 13.3 14.7 11.8 14.7 1,089 201 581 33 33 2037 614,809 246,378 737,771 295,653 13.3 14.7 11.8 14.7 1,087 200 578 32 32 2038 615,214 246,566 738,257 295,880 13.3 14.8 11.8 14.8 1,085 200 575 31 31 2039 615,619 246,755 738,742 296,106 13.3 14.8 11.8 14.8 1,082 199 573 30 30 2040 616,023 246,944 739,228 296,333 13.3 14.8 11.8 14.8 1,080 198 570 29 29 2041 616,428 247,133 739,713 296,559 13.3 14.8 11.8 14.8 1,077 197 567 28 28 2042 616,833 247,322 740,199 296,786 13.3 14.8 11.8 14.8 1,075 196 565 27 27 2043 617,237 247,510 740,685 297,012 13.3 14.8 11.9 14.8 1,072 195 562 26 26 2044 617,642 247,699 741,170 297,239 13.3 14.8 11.9 14.8 1,070 194 559 25 25 2045 618,046 247,888 741,656 297,465 13.3 14.8 11.9 14.8 1,068 193 556 24 24

Notes: 1. 2016 solids flows and loads w/o MWRP contribution and w/o diversion to Plant 2, assuming co-thickening, are used as the start point for future solids projection. This is for future solids projection purpose and does not reflect real digester feed flows and loads for 2016 - 2018. MWRP contribution and diversion to Plant 2 are expected to stop by the end of 2018. New co-thickening facility is also planned to be in service by the end of 2018. 2. Currently digester feed TS% at Plant 1 is approximately 4.2%, resulting in no excess digester capacity for food waste co-digestion. 3. After co-thickening come online in 2019, the digester feed TS% will increase to 6%. There will be very little excess digester capacity for food waste co-digestion in 2019. 4. As solids flows and loads increase, there will be no excess digester capacity by 2022.

Page 5 of 6 Plant 1 Digester Capacity Evaluation

Digester Gas Production CenGen Capacity AA Peak 15-Day

1 Unit All in Sludge FW Total Sludge FW Total OOS Service scfm scfm scfm scfm scfm scfm scfm scfm 1,443 0 1,443 1,731 0 1,731 1460 2190 1,444 0 1,444 1,733 0 1,733 1460 2190 1,445 0 1,445 1,734 0 1,734 1460 2190 1,446 0 1,446 1,735 0 1,735 1460 2190 1,447 0 1,447 1,737 0 1,737 1460 2190 1,448 0 1,448 1,738 0 1,738 1460 2190 1,449 0 1,449 1,739 0 1,739 1460 2190 1,451 0 1,451 1,741 0 1,741 1460 2190 1,452 0 1,452 1,742 0 1,742 1460 2190 1,453 0 1,453 1,743 0 1,743 1460 2190 1,454 0 1,454 1,745 0 1,745 1460 2190 1,455 0 1,455 1,746 0 1,746 1460 2190 1,456 0 1,456 1,747 0 1,747 1460 2190 1,457 0 1,457 1,749 0 1,749 1460 2190 1,458 0 1,458 1,750 0 1,750 1460 2190 1,460 0 1,460 1,751 0 1,751 1460 2190 1,461 0 1,461 1,753 0 1,753 1460 2190 1,462 0 1,462 1,754 0 1,754 1460 2190 1,463 0 1,463 1,755 0 1,755 1460 2190 1,464 0 1,464 1,757 0 1,757 1460 2190 1,465 0 1,465 1,758 0 1,758 1460 2190 1,466 0 1,466 1,759 0 1,759 1460 2190 1,467 0 1,467 1,761 0 1,761 1460 2190 1,468 0 1,468 1,762 0 1,762 1460 2190 1,470 0 1,470 1,764 0 1,764 1460 2190 1,471 0 1,471 1,765 0 1,765 1460 2190 1,472 0 1,472 1,766 0 1,766 1460 2190

Notes: 1. Assumes no FW co-digestion at Plan 1.

Page 6 of 6

Plant 2 Digester Capacity Evaluation - Interim Facility

Purpose: Calculate digester capacity available for co-digestion at Plant 2 interim facility. Approach: 1. Two solids flows and loads conditions (Condition 1 and Condition 2) are evaluated. 2. Current solids flows and loads w/o sludge diversion from Plant 1 are used as the start point for future solids projection. 3. 2016 solids flows and loads w/o Plant 1 diversion are used to represent current condition for Condition 1. 2014 solids flows and loads w/o Plant 1 diversion are used to represent current condition for Condition 2. This is for future solids projection purpose and does not reflect real digester feed flows and loads for 2016 - 2018. Sludge diversion from Plant 1 to Plant 2 is expected to stop by the end of 2018. 4. Future solids flows and loads calculated based on current (in Step 3) and 2035 data assuming linear growth. 5. The TPAD facility is planned to be in operation by the end of 2028. Therefore, the digester capacity evaluation for the interim facility is from 2019 to 2028.

Results: There are excess digesters capacities for FW co-digestion at Plant 2 for the interim facility. The amount of FW can be co-digested ranges from 137 wtpd (Condition 2) to 582 wtpd Condition 1) depending on future solids flows and loads.

Recommendation: It's recommended that the initital contract with waste haulders to be around 150 wtpd. Typical Condition Service Condition Sludge and Food Waste Characteristics Existing Digesters Sludge Design Criteria Diameter ft 105 105 VSR-Meso % 57 SWD ft 29 29 VSR-Thermo% 61 digestion design Active Capacity MG 1.88 1.88 Biogas Productioncf/lb VSR Rate 15 Typical Condition (A) Service Condition (B) parameter Total No. of Digesters 4 4 Food Waste OLR, lb/cf- OLR, lb/cf- Units HRT, days HRT, days day day No. of Digester out of Service 2 2 TS (%) 12 Conventional 0.15 18 0.15 16 Mesophilic (CMAD) Diameter ft 80 80 VS (%) 85 SWD ft 29 29 SG 1.2 Active Capacity MG 1.09 1.09 FW VSR (%) 80 A – Two large digester out of service at peak 15-day loads Total No. of Digesters 13 13 Biogas Productioncf/lb VSR Rate 15 B – Two large and one small digesters out of service at peak 15-day loads No. of Digester out of Service 0 1 C – Class B process Future Digesters CenGen Capacity Diameter ft Unit Capacityscfm 875 SWD ft No. of EQ # 5 Assumptions Active Capacity MG 1. Peak 15-D : AA Peaking Factor 1.2 Total No. of Digesters 2. Growth of solids flows and loads is linear. No. of Digester out of Service Total Available Digester Capacity MG 17.9 16.8

Page 1 of 6 Plant 2 Digester Capacity Evaluation - Interim Facility

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Page 2 of 6 Plant 2 Digester Capacity Evaluation - Interim Facility Condition 1 FW

AA Peak 15-Day Typical Condition Service Condition Typical Condition Service Condition HRT Potential HRT Based OLR Based Based OLR Based HRT FW for Co- Flow VS Loads Flow VS Loads Capacity Capacity Capacity Capacity HRT Based OLR Based Based OLR Based digestion Year gpd ppd gpd ppd MG MG MG MG wtpd wtpd wtpd wtpd wtpd 2019 567,400 163,708 680,880 196,449 12.3 9.8 10.9 9.8 1577.78 799.68 1859.88 692.50 693 2020 572,875 165,788 687,450 198,946 12.4 9.9 11.0 9.9 1544.90 787.44 1827.00 680.26 680 2021 578,350 167,869 694,020 201,443 12.5 10.0 11.1 10.0 1512.02 775.20 1794.13 668.02 668 2022 583,825 169,950 700,590 203,940 12.6 10.2 11.2 10.2 1479.15 762.97 1761.25 655.78 656 2023 589,300 172,031 707,160 206,437 12.7 10.3 11.3 10.3 1446.27 750.73 1728.37 643.54 644 2024 594,775 174,111 713,730 208,934 12.8 10.4 11.4 10.4 1413.39 738.49 1695.50 631.30 631 2025 600,250 176,192 720,300 211,431 13.0 10.5 11.5 10.5 1380.52 726.25 1662.62 619.06 619 2026 605,725 178,273 726,870 213,928 13.1 10.7 11.6 10.7 1347.64 714.01 1629.74 606.82 607 2027 611,200 180,354 733,440 216,425 13.2 10.8 11.7 10.8 1314.77 701.77 1596.87 594.58 595 2028 616,675 182,435 740,010 218,921 13.3 10.9 11.8 10.9 1281.89 689.53 1563.99 582.34 582

Notes: 1. 2016 solids flows and loads w/o Plant 1 diversion are used to represent current condition for Condition 1. This is for future solids projection purpose and does not reflect real digester feed flows and loads for 2016 - 2018. Sludge diversion from Plant 1 to Plant 2 is expected to stop by the end of 2018. 2. The TPAD facility is planned to be in operation by the end of 2028. Therefore, the digester capacity evaluation for the interim facility is from 2019 to 2028.

Page 3 of 6 Plant 2 Digester Capacity Evaluation - Interim Facility Condition 1 Digester Gas Production CenGen Capacity

AA Peak 15-Day

1 Unit All in Sludge FW Total Sludge FW Total OOS Service scfm scfm scfm scfm scfm scfm scfm scfm 972 425 1,397 1,166 425 1,591 3,500 4,375 984 425 1,409 1,181 425 1,606 3,500 4,375 997 425 1,422 1,196 425 1,621 3,500 4,375 1,009 425 1,434 1,211 425 1,636 3,500 4,375 1,021 425 1,446 1,226 425 1,651 3,500 4,375 1,034 425 1,459 1,241 425 1,666 3,500 4,375 1,046 425 1,471 1,255 425 1,680 3,500 4,375 1,058 425 1,483 1,270 425 1,695 3,500 4,375 1,071 425 1,496 1,285 425 1,710 3,500 4,375 1,083 425 1,508 1,300 425 1,725 3,500 4,375

Notes: 1. Assumes 250 wtpd FW for co-digestion.

Page 4 of 6 Plant 2 Digester Capacity Evaluation - Interim Facility Condition 2 FW

AA Peak 15-Day Typical Condition Service Condition Typical Condition Service Condition

HRT Potential HRT Based OLR Based Based OLR Based HRT FW for Co- Flow VS Loads Flow VS Loads Capacity Capacity Capacity Capacity HRT Based OLR Based Based OLR Based digestion Year gpd ppd gpd ppd MG MG MG MG wtpd wtpd wtpd wtpd wtpd 2019 761,439 226,352 913,727 271,623 16.4 13.5 14.6 13.5 412.61 431.19 694.71 324.00 324 2020 766,536 228,080 919,844 273,696 16.6 13.6 14.7 13.6 382.00 421.02 664.10 313.84 314 2021 771,634 229,808 925,961 275,770 16.7 13.8 14.8 13.8 351.39 410.86 633.49 303.67 304 2022 776,732 231,536 932,078 277,843 16.8 13.9 14.9 13.9 320.78 400.69 602.88 293.51 294 2023 781,829 233,264 938,195 279,917 16.9 14.0 15.0 14.0 290.17 390.53 572.27 283.34 283 2024 786,927 234,992 944,312 281,991 17.0 14.1 15.1 14.1 259.56 380.36 541.66 273.18 260 2025 792,024 236,720 950,429 284,064 17.1 14.2 15.2 14.2 228.95 370.20 511.05 263.01 229 2026 797,122 238,448 956,546 286,138 17.2 14.3 15.3 14.3 198.34 360.03 480.44 252.85 198 2027 802,219 240,176 962,663 288,211 17.3 14.4 15.4 14.4 167.73 349.87 449.83 242.69 168 2028 807,317 241,904 968,780 290,285 17.4 14.5 15.5 14.5 137.12 339.70 419.22 232.52 137

Notes: 1. 2014 solids flows and loads w/o Plant 1 diversion are used to represent current condition for Condition 2. This is for future solids projection purpose and does not reflect real digester feed flows and loads for 2014 - 2018. Sludge diversion from Plant 1 to Plant 2 is expected to stop by the end of 2018. 2. The TPAD facility is planned to be in operation by the end of 2028. Therefore, the digester capacity evaluation for the interim facility is from 2019 to 2028.

Page 5 of 6 Plant 2 Digester Capacity Evaluation - Interim Facility Condition 2 Digester Gas Production CenGen Capacity

AA Peak 15-Day

1 Unit All in Sludge FW Total Sludge FW Total OOS Service scfm scfm scfm scfm scfm scfm scfm scfm 1,344 233 1,577 1,613 233 1,846 3,500 4,375 1,354 233 1,587 1,625 233 1,858 3,500 4,375 1,364 233 1,597 1,637 233 1,870 3,500 4,375 1,375 233 1,608 1,650 233 1,883 3,500 4,375 1,385 233 1,618 1,662 233 1,895 3,500 4,375 1,395 233 1,628 1,674 233 1,907 3,500 4,375 1,406 233 1,638 1,687 233 1,920 3,500 4,375 1,416 233 1,649 1,699 233 1,932 3,500 4,375 1,426 233 1,659 1,711 233 1,944 3,500 4,375 1,436 233 1,669 1,724 233 1,956 3,500 4,375

Notes: 1. Assumes 137 wtpd FW for co-digestion.

Page 6 of 6

Digester Capacity Evaluation - Plant No. 2 Condition 1 Mesophilic Operation 400,000

350,000

300,000

250,000

200,000

Digester Capacity Based on Organic Load 150,000 Sludge Organic Load Organic Load Capacity, ppd Capacity, Load Organic Available Capacity for SSO 100,000

50,000

0 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 Digester Capacity Evaluation - Plant No. 2 Condition 2 Mesophilic Operation

1,000,000

800,000

600,000

Digester Capacity Based on Hydraulic Load 400,000 Sludge Hydraulic Load

Hydraulic Load Capacity, ppd Capacity, Load Hydraulic Available Capacity for SSO

200,000

0 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029

Plant 2 Digester Capacity Evaluation - TPAD Operation

Purpose: Calculate digester capacity available for co-digestion at Plant 2 under TPAD operation condition. Approach: 1. Two solids flows and loads conditions (Condition 1 and Condition 2) are evaluated. 2. Current solids flows and loads w/o sludge diversion from Plant 1 are used as the start point for future solids projection. 3. 2016 solids flows and loads w/o Plant 1 diversion are used to represent current condition for Condition 1. 2014 solids flows and loads w/o Plant 1 diversion are used to represent current condition for Condition 2. This is for future solids projection purpose and does not reflect real digester feed flows and loads for 2016 - 2018. Sludge diversion from Plant 1 to Plant 2 is expected to stop by the end of 2018. 4. Future solids flows and loads calculated based on current (in Step 3) and 2035 data assuming linear growth. 5. The TPAD facility is planned to be in operation by the end of 2028. Therefore, the digester capacity evaluation for the TPAD operation is from 2029 to 2045.

Results: There are excess digesters capacities for FW co-digestion at Plant 2 under TPAD operation. The amount of FW can be co-digested ranges from 323 wtpd (Condition 2) to 806 wtpd Condition 1) depending on future solids flows and loads. Recommendation: A food waste receiving facility with a capacity of 500 - 700 wtpd is recommended. Typical Condition Service Condition Sludge and Food Waste Characteristics Thermo Phase Digesters Sludge Design Criteria Diameter ft 110 110 VSR-Meso % 57 SWD ft 32 32 VSR-Thermo % 61 Digestion design Typical Active Capacity MG 2.27 2.27 Biogas Productioncf/lb VSR Rate 15 Service Condition (B) parameter Condition (A) Total No. of Digesters 6 6 Food Waste OLR, lb/cf- Units HRT, days OLR, lb/cf-day HRT, days day No. of Digester out of Service 1 2 TS (%) 12 Meso Phase Digesters VS (%) 85 Temperature Thermo 0.35 9 0.35 8 Diameter ft 105 105 SG 1.2 Phased Phase Meso (TPAD) C n/a 8 n/a 7 Phase SWD ft 32 32 FW VSR (%) 80 A – One thermo digester out of service at peak 15-day loads Active Capacity MG 2.07 2.07 Biogas Productioncf/lb VSR Rate 15 B – Two thermo digester and one large meso digester out of service at peak 15-day loads Total No. of Digesters 4 4 C – Class B process No. of Digester out of Service 0 1 CenGen Capacity Diameter ft 80 80 Unit Capacityscfm 875 SWD ft 32 32 No. of EQ # 5 Assumptions Active Capacity MG 1.20 1.20 1. Peak 15-D : AA Peaking Factor 1.2 Total No. of Digesters 2 2 2. Growth of solids flows and loads is linear. No. of Digester out of Service 0 0 Total Available Digester Capacity (Thermo) MG 11.4 9.1 Total Available Digester Capacity (Meso) MG 10.7 8.6

Page 1 of 6 Plant 2 Digester Capacity Evaluation - TPAD Operation

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Page 2 of 6 Plant 2 Digester Capacity Evaluation - TPAD Operation Condition 1

Thermo Phase Digesters Meso Phase Digesters Typical Service Typical AA Peak 15-Day Typical Condition Service Condition Condition Condition Condition Service Condition Excess HRT Based OLR Based HRT Based OLR Based HRT Based HRT Based Digester Excess Digester Excess Digester Flow VS Loads Flow VS Loads Capacity Capacity Capacity Capacity Capacity Capacity Capacity Capacity Capacity Year gpd ppd gpd ppd MG MG MG MG MG MG MG MG MG 2029 622,150 184,515 746,580 221,418 6.7 4.7 6.0 4.7 6.0 5.2 4.72 3.40 3.40 2030 627,625 186,596 753,150 223,915 6.8 4.8 6.0 4.8 6.0 5.3 4.67 3.35 3.35 2031 633,100 188,677 759,720 226,412 6.8 4.8 6.1 4.8 6.1 5.3 4.62 3.31 3.31 2032 638,575 190,758 766,290 228,909 6.9 4.9 6.1 4.9 6.1 5.4 4.57 3.26 3.26 2033 644,050 192,838 772,860 231,406 7.0 4.9 6.2 4.9 6.2 5.4 4.51 3.21 3.21 2034 649,525 194,919 779,430 233,903 7.0 5.0 6.2 5.0 6.2 5.5 4.46 3.17 3.17 2035 655,000 197,000 786,000 236,400 7.1 5.1 6.3 5.1 6.3 5.5 4.41 3.12 3.12 2036 660,475 199,081 792,570 238,897 7.1 5.1 6.3 5.1 6.3 5.5 4.36 3.08 3.08 2037 665,950 201,162 799,140 241,394 7.2 5.2 6.4 5.2 6.4 5.6 4.30 3.03 3.03 2038 671,425 203,242 805,710 243,891 7.3 5.2 6.4 5.2 6.4 5.6 4.25 2.98 2.98 2039 676,900 205,323 812,280 246,388 7.3 5.3 6.5 5.3 6.5 5.7 4.20 2.94 2.94 2040 682,375 207,404 818,850 248,885 7.4 5.3 6.6 5.3 6.6 5.7 4.15 2.89 2.89 2041 687,850 209,485 825,420 251,382 7.4 5.4 6.6 5.4 6.6 5.8 4.09 2.85 2.85 2042 693,325 211,565 831,990 253,879 7.5 5.4 6.7 5.4 6.7 5.8 4.04 2.80 2.80 2043 698,800 213,646 838,560 256,375 7.5 5.5 6.7 5.5 6.7 5.9 3.99 2.75 2.75 2044 704,275 215,727 845,130 258,872 7.6 5.5 6.8 5.5 6.8 5.9 3.94 2.71 2.71 2045 709,750 217,808 851,700 261,369 7.7 5.6 6.8 5.6 6.8 6.0 3.88 2.66 2.66

Notes: 1. 2016 solids flows and loads w/o Plant 1 diversion are used to represent current condition for Condition 1. This is for future solids projection purpose and does not reflect real digester feed flows and loads for 2016 - 2018. Sludge diversion from Plant 1 to Plant 2 is expected to stop by the end of 2018. 2. The TPAD facility is planned to be in operation by the end of 2028. Therefore, the digester capacity evaluation for the TPAD operation is from 2029 to 2045.

Page 3 of 6 Plant 2 Digester Capacity Evaluation - TPAD Operation Condition 1

FW Digester Gas Production CenGen Capacity Thermo Digeser Thermo Digester Typical Condition Service Condition Meso Phase Digester AA Peak 15-Day Potential FW HRT Based HRT Based for Co- 1 Unit All in HRT Based OLR Based HRT Based OLR Based TYP Service digestion Sludge FW Total Sludge FW Total OOS Service wtpd wtpd wtpd wtpd wtpd wtpd wtpd scfm scfm scfm scfm scfm scfm scfm scfm 2,588 1,523 1,955 1,002 2,955 2,429 1,002 1,172 850 2,022 1,407 850 2,257 3,500 4,375 2,555 1,511 1,923 989 2,922 2,396 989 1,186 850 2,036 1,423 850 2,273 3,500 4,375 2,522 1,499 1,890 977 2,889 2,363 977 1,199 850 2,049 1,439 850 2,289 3,500 4,375 2,489 1,487 1,857 965 2,856 2,331 965 1,212 850 2,062 1,455 850 2,305 3,500 4,375 2,456 1,474 1,824 953 2,823 2,298 953 1,225 850 2,075 1,470 850 2,320 3,500 4,375 2,423 1,462 1,791 940 2,791 2,265 940 1,239 850 2,089 1,486 850 2,336 3,500 4,375 2,391 1,450 1,758 928 2,758 2,232 928 1,252 850 2,102 1,502 850 2,352 3,500 4,375 2,358 1,438 1,725 916 2,725 2,199 916 1,265 850 2,115 1,518 850 2,368 3,500 4,375 2,325 1,425 1,692 904 2,692 2,166 904 1,278 850 2,128 1,534 850 2,384 3,500 4,375 2,292 1,413 1,660 891 2,659 2,133 891 1,291 850 2,141 1,550 850 2,400 3,500 4,375 2,259 1,401 1,627 879 2,626 2,100 879 1,305 850 2,155 1,566 850 2,416 3,500 4,375 2,226 1,389 1,594 867 2,593 2,068 867 1,318 850 2,168 1,581 850 2,431 3,500 4,375 2,193 1,376 1,561 855 2,560 2,035 855 1,331 850 2,181 1,597 850 2,447 3,500 4,375 2,160 1,364 1,528 843 2,528 2,002 843 1,344 850 2,194 1,613 850 2,463 3,500 4,375 2,128 1,352 1,495 830 2,495 1,969 830 1,358 850 2,208 1,629 850 2,479 3,500 4,375 2,095 1,340 1,462 818 2,462 1,936 818 1,371 850 2,221 1,645 850 2,495 3,500 4,375 2,062 1,328 1,429 806 2,429 1,903 806 1,384 850 2,234 1,661 850 2,511 3,500 4,375

Notes: 1. Assumes 500 wtpd FW for co-digestion.

Page 4 of 6 Plant 2 Digester Capacity Evaluation - TPAD Operation Condition 2

Thermo Phase Digesters Meso Phase Digesters Typical Service Typical AA Peak 15-Day Typical Condition Service Condition Condition Condition Condition Service Condition

Excess HRT Based OLR Based HRT Based OLR Based HRT Based HRT Based Digester Excess Digester Excess Digester Flow VS Loads Flow VS Loads Capacity Capacity Capacity Capacity Capacity Capacity Capacity Capacity Capacity Year gpd ppd gpd ppd MG MG MG MG MG MG MG MG MG 2029 812,415 243,632 974,897 292,359 8.8 6.2 7.8 6.2 7.8 6.8 2.90 1.80 1.80 2030 817,512 245,360 981,015 294,432 8.8 6.3 7.8 6.3 7.8 6.9 2.85 1.76 1.76 2031 822,610 247,088 987,132 296,506 8.9 6.3 7.9 6.3 7.9 6.9 2.80 1.71 1.71 2032 827,707 248,816 993,249 298,579 8.9 6.4 7.9 6.4 7.9 7.0 2.75 1.67 1.67 2033 832,805 250,544 999,366 300,653 9.0 6.4 8.0 6.4 8.0 7.0 2.70 1.63 1.63 2034 837,902 252,272 1,005,483 302,726 9.0 6.5 8.0 6.5 8.0 7.0 2.65 1.59 1.59 2035 843,000 254,000 1,011,600 304,800 9.1 6.5 8.1 6.5 8.1 7.1 2.60 1.54 1.54 2036 848,098 255,728 1,017,717 306,874 9.2 6.6 8.1 6.6 8.1 7.1 2.56 1.50 1.50 2037 853,195 257,456 1,023,834 308,947 9.2 6.6 8.2 6.6 8.2 7.2 2.51 1.46 1.46 2038 858,293 259,184 1,029,951 311,021 9.3 6.6 8.2 6.6 8.2 7.2 2.46 1.41 1.41 2039 863,390 260,912 1,036,068 313,094 9.3 6.7 8.3 6.7 8.3 7.3 2.41 1.37 1.37 2040 868,488 262,640 1,042,185 315,168 9.4 6.7 8.3 6.7 8.3 7.3 2.36 1.33 1.33 2041 873,585 264,368 1,048,303 317,241 9.4 6.8 8.4 6.8 8.4 7.3 2.31 1.29 1.29 2042 878,683 266,096 1,054,420 319,315 9.5 6.8 8.4 6.8 8.4 7.4 2.26 1.24 1.24 2043 883,781 267,824 1,060,537 321,389 9.5 6.9 8.5 6.9 8.5 7.4 2.21 1.20 1.20 2044 888,878 269,552 1,066,654 323,462 9.6 6.9 8.5 6.9 8.5 7.5 2.16 1.16 1.16 2045 893,976 271,280 1,072,771 325,536 9.7 7.0 8.6 7.0 8.6 7.5 2.11 1.11 1.11

Notes: 1. 2016 solids flows and loads w/o Plant 1 diversion are used to represent current condition for Condition 1. This is for future solids projection purpose and does not reflect real digester feed flows and loads for 2016 - 2018. Sludge diversion from Plant 1 to Plant 2 is expected to stop by the end of 2018. 2. The TPAD facility is planned to be in operation by the end of 2028. Therefore, the digester capacity evaluation for the TPAD operation is from 2029 to 2045.

Page 5 of 6 Plant 2 Digester Capacity Evaluation - TPAD Operation Condition 2

FW Digester Gas Production CenGen Capacity Thermo Digeser Thermo Digester Typical Condition Service Condition Meso Phase Digester AA Peak 15-Day

Potential FW HRT Based HRT Based for Co- 1 Unit All in HRT Based OLR Based HRT Based OLR Based TYP Service digestion Sludge FW Total Sludge FW Total OOS Service wtpd wtpd wtpd wtpd wtpd wtpd wtpd scfm scfm scfm scfm scfm scfm scfm scfm 1,445 1,176 813 654 1,812 1,287 654 1,548 544 2,092 1,858 544 2,402 3,500 4,375 1,415 1,165 782 644 1,782 1,256 644 1,559 544 2,103 1,871 544 2,415 3,500 4,375 1,384 1,155 752 634 1,751 1,225 634 1,570 544 2,114 1,884 544 2,428 3,500 4,375 1,353 1,145 721 623 1,721 1,195 623 1,581 544 2,125 1,897 544 2,441 3,500 4,375 1,323 1,135 691 613 1,690 1,164 613 1,592 544 2,136 1,910 544 2,454 3,500 4,375 1,292 1,125 660 603 1,659 1,134 603 1,603 544 2,147 1,924 544 2,468 3,500 4,375 1,262 1,115 629 593 1,629 1,103 593 1,614 544 2,158 1,937 544 2,481 3,500 4,375 1,231 1,104 599 583 1,598 1,072 583 1,625 544 2,169 1,950 544 2,494 3,500 4,375 1,200 1,094 568 573 1,568 1,042 568 1,636 544 2,180 1,963 544 2,507 3,500 4,375 1,170 1,084 537 562 1,537 1,011 537 1,647 544 2,191 1,976 544 2,520 3,500 4,375 1,139 1,074 507 552 1,506 981 507 1,658 544 2,202 1,989 544 2,533 3,500 4,375 1,109 1,064 476 542 1,476 950 476 1,669 544 2,213 2,003 544 2,547 3,500 4,375 1,078 1,054 446 532 1,445 919 446 1,680 544 2,224 2,016 544 2,560 3,500 4,375 1,047 1,043 415 522 1,415 889 415 1,691 544 2,235 2,029 544 2,573 3,500 4,375 1,017 1,033 384 512 1,384 858 384 1,702 544 2,246 2,042 544 2,586 3,500 4,375 986 1,023 354 501 1,353 828 354 1,713 544 2,257 2,055 544 2,599 3,500 4,375 956 1,013 323 491 1,323 797 323 1,724 544 2,268 2,069 544 2,613 3,500 4,375

Notes: 1. Assumes 320 wtpd FW for co-digestion.

Page 6 of 6

Digester Capacity Evaluation - Plant No. 2 Condition 1 TPAD Operation 450,000

400,000

350,000

300,000

250,000

200,000 Digester Capacity Based on Organic Load 150,000 Sludge Organic Load Organic Load Capacity, ppd Capacity, Load Organic Available Capacity for SSO

100,000

50,000

0 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046 Digester Capacity Evaluation - Plant No. 2 Condition 2 TPAD Operation 1,200,000

1,000,000

800,000

600,000

Digester Capacity Based on Organic Load 400,000 Sludge Organic Load

Hydraulic Load Capacity, gpd Capacity, Load Hydraulic Available Capacity for SSO

200,000

0 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046

Purpose: Estimate ammonia-N concentration in digesters at current operating condition.

Data: P2 ammonia-N concentration in dewatered cake (Ref 1. see reference tab). Average ammonia-N in cake is 5,200 mg/kg as N.

Assumptions: 1 Dewatered cake TS is 22% based on 2015 plant data. 2 Ammonia-N concentration in cake is the same as that in digested sludge. a. There is no further conversion of organic nitrogen to ammonia after digestion. b. Volatilization of ammonia-N after digestion is negligible.

Calculations: Ammonia-N in cake 5200 mg/kg dry basis Ammonia-N in cake 5200 ppm dry basis Cake TS 22 % Ammonia-N in cake 1144 ppm wet basis 1144 mg/L

It is assumed that total ammonia-N concentration in the digester is the same as that of the cake. Purpose: Evaluate digester ammonia toxicity for food waste co-digestion at Plant 2. Approach:

1. Current sludge ammonia concentrations are based on measured data for dewatered cake. 2. Digester ammonia concentrations are calculated for the interim facility in 2028 and the TPAD facility in 2045. 3. Food waste quantities for co-digestion (wtpd): Condition 1 Condition 2 Interim Facilty 2028 250 150 TPAD Facility 2045 806 323

Assumptions:

Peak 15-Day to AA Peaking Factor 1.2

Sludge TKN Content Parameter Units Value Primary Sludge lb-N/lb-TS 0.038 Adjusted to yield 1144 mg/L N WAS lb-N/lb-TS 0.075 Adjusted to yield 1144 mg/L N Primary Sludge mg-N/kg-TS 37600 WAS mg-N/kg-TS 75200

FW Characteristics Parameter Units Mean Value Specific Gravity 1.2 Total Solids Concentration lb-TS/lb-FW 0.12 Volatile Fraction lb-VS/lb-TS 0.85 Total Kjeldahl Nitrogen mg-N/L 2541 Reference 2 TKN/DS mg-N/mg-TS 0.0212 TKN/DS mg-N/kg-TS 21175

N Conversion Factors mg-N to molar conv factor mg-N/mol 14.0067 Molecular Weight Ammonia g-NH3/mol 17.0358

Other Assumptions: 1. TKN in primary sludge and WAS were adjusted to yield a total ammonia-N of 1144 mg/L as N (see calculations in "Current Digester Ammonia-N" tab. 2. Ammonia release is proportional to the VSR, assuming VSR degrades all materials equally. 3. It is assumed that the background NH3 and NH4 levels in digester feed sludge are negligible, and therefore any ammonia generation will come from the degradation of organics and released TKN. 4. Assumes pH is relatively constant between peak and average loading conditions. pH values for mesophilic and thermophilic digestion are 7.2 and 7.5, respectively. These values are based on data from other WWTPs. pH does not affect TAN concentration in this calculation. pH does affect FAN cocentration. Higher pH will lead to higher FAN concentration. 5. Assume total ammonia nitrogen of 3,000 mg/L is toxic to the biomass. 6. Assumes 84 mg/L ammonia is toxic to the biomass, based on Speece book values reported by Parkin and Owen. 7. Assumes VSR for WAS is approximately 50% of that of PS under mesophilic temperature. VSRs at thermophilic temperature are adjusted to match those used for process calculations. 8. Food waste characteristics are based on results of previous study (Ref 1, see reference tab).

Results: Co-digestion of food waste will increase digester ammonium-N concentration by upto 200 mg/L. The resulting digester ammonium-N concentrations range from 1,200 to 1,500 mg/L depending on the solids and food waste loads.

Conclusion: Both total ammonium-N and free ammonia concentrations with food waste co-digestion are well below the threshold values. Digester ammonia toxicity is very unlikely. Ammonia Toxicity Analysis Interim Facility 2028 TPAD Facility 2045 Condition 1 Condition 2 Condition 1 Condition 2 Average Peak 15- Average Peak 15- Average Peak 15- Average Annual Day Annual Day Annual Day Annual Peak 15-Day Digester Operating Condition Digester Temperature (oC) 37 37 37 37 55 55 55 55 Digester pH 7.2 7.2 7.2 7.2 7.5 7.5 7.5 7.5 Ammonia/Ammonium -pKa 9.28 9.28 9.28 9.28 9.12 9.12 9.12 9.12 Volatile Solids Reduction Primary Sludge (lb-VSR/lb-VS) 0.65 0.65 0.66 0.66 0.68 0.68 0.69 0.69 Waste Activated Sludge (lb-VSR/lb-VS) 0.31 0.31 0.32 0.32 0.4 0.4 0.4 0.4 Food Waste (lb-VSR/lb-VS) 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8 Primary Sludge Total Solids Load (lb-TS/day) 193597 232317 241166 289399 199004 238804 261043 313251 Volatile Solids Load (lb-VS/day) 143239 171886 178463 214155 147202 176642 193171 231806 Nitrogen Content (lb-N/lb-VS) 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 Ammonium-N Load (lb-N/day) 4732 5678 5985 7182 5088 6106 6772 8127 Flow to Digester (MGD) 0.52 0.62 0.65 0.78 0.53 0.64 0.70 0.84 Total Solids (lb-TS/lb-Sludge) 0.045 0.045 0.045 0.045 0.045 0.045 0.045 0.045 Volatile Solids (lb-VS/lb-TS) 0.74 0.74 0.74 0.74 0.74 0.74 0.74 0.74 Waste Activated Sludge Total Solids Load (lb-TS/day) 45267 54321 75833 91000 85166 102199 94208 113050 Volatile Solids Load (lb-VS/day) 37115 44538 61713 74056 70606 84727 78108 93730 Nitrogen Content (lb-N/lb-VS) 0.092 0.092 0.092 0.092 0.091 0.091 0.091 0.091 Ammonium-N Load (lb-N/day) 1055 1266 1825 2190 2562 3074 2834 3401 Flow to Digester (MGD) 0.10 0.11 0.16 0.20 0.18 0.22 0.20 0.24 Total Solids (lb-TS/lb-Sludge) 0.057 0.057 0.056 0.056 0.057 0.057 0.056 0.056 Volatile Solids (lb-VS/lb-TS) 0.82 0.82 0.81 0.81 0.83 0.83 0.83 0.83 Co-digestion Substrate 1 - Food Waste Total Solids Load (lb-TS/day) 60,000 60,000 36,000 36,000 193,440 193,440 77,520 77,520 Volatile Solids Load (lb-VS/day) 51,000 51,000 30,600 30,600 164,424 164,424 65,892 65,892 Nitrogen Content (lb-N/lb-VS) 0.025 0.025 0.025 0.025 0.025 0.025 0.025 0.025 Ammonium-N Load (lb-N/day) 1016 1016 610 610 3277 3277 1313 1313 Flow to Digester (MGD) 0.05 0.05 0.03 0.03 0.16 0.16 0.06 0.06 Total Solids (lb-TS/lb-Sludge) 0.120 0.120 0.120 0.120 0.120 0.120 0.120 0.120 Volatile Solids (lb-VS/lb-TS) 0.85 0.85 0.85 0.85 0.85 0.85 0.85 0.85 Co-digestion Substrate 2-Not Used at this time Total Solids Load (lb-TS/day) Volatile Solids Load (lb-VS/day) Nitrogen Content (lb-N/lb-VS) Ammonium-N Load (lb-N/day) Flow to Digester (MGD) Total Solids (lb-TS/lb-Sludge) Volatile Solids (lb-VS/lb-TS) Digester Ammonium Concentration Ammonium-N Load (lb-N/day) 6803 7961 8419 9981 10927 12457 10919 12841 Flow to Digester (MGD) 0.6612 0.7834 0.8392 1.0010 0.8708 1.0128 0.9639 1.1438 Ammonium-N Conc. (mg-N/L) 1,234 1,218 1,203 1,196 1,505 1,475 1,358 1,346 Ammonium-N (molar) 0.088 0.087 0.086 0.085 0.107 0.105 0.097 0.096 Log Ammonia-N -3.14E+00 -3.15E+00 -3.15E+00 -3.15E+00 -2.60E+00 -2.61E+00 -2.65E+00 -2.65E+00

Ammonia Concentration (mg-NH3-N/L) 10 10 10 10 35 34 32 31

Ammonia Concentration (mg-NH3/L) 12.3 12.2 12.0 12.0 42.5 41.7 38.4 38.0 Total Ammonia Exceedance ok ok ok ok ok ok ok ok

Sludge VSR Check Primary Sludge (lb-VSR/day) 93,105 111,726 117,785 141,343 100,097 120,117 133,288 159,946 Waste Activated Sludge (lb-VSR/day) 11,506 13,807 19,748 23,698 28,242 33,891 31,243 37,492 Combined Sludge (lb-VSR/day) 104,611 125,533 137,534 165,040 128,340 154,007 164,532 197,438 Overall Sludge VSR (lb-VSR/lb-VS) 0.58 0.58 0.57 0.57 0.59 0.59 0.61 0.61

Sludge only Ammonia-N (mg-N/L) 1,135 1,135 1,157 1,157 1,292 1,292 1,281 1,281 FW only Ammonia-N (mg-N/L) 2,439 2,439 2,439 2,439 2,439 2,439 2,439 2,439 FW only Ammonia-N (lb/day) 1,016 1,016 610 610 3,277 3,277 1,313 1,313 Ref 1: Ammonia concentration in dewatered cake. Table 3-1 TM3.

ConstituenUnits Average Value, 2015 Plant 1 Plant 2 Total Nitrogemg/kg 51,000 43,000 Ammonia-N mg/kg 6,300 5,200 Total Phosphmg/kg 26,000 27,000 Total Potass mg/kg 1,100 1,100 Iron mg/kg 60,000 67,000

Ref 2: Food waste characteristics: Attachment 9 - Final Report _OCSD Anaerobic co-digestion of food waste _June 2013. page 16 Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

Appendix C – Meeting Minutes for Task 5 Meetings

May 9, 2017 C‐1 Master Plan Biosolids

B&V Job 190875 PS15-01 No . OCSD BIOSOLIDS MASTER PLAN Date: October 11, 2016

DRAFT MEETING MINUTES Page: 1 of 3

Meeting Location: OCSD Administration Building - Conference Room C Meeting Date: October 11, 2016 Meeting Time: 1:00 PM to 3:00 PM Meeting Topic: Task 5.1 High Strength Waste Co-Digestion Evaluation Revision Date: Authored By: Tom Chapman, Adam Ross, and Dan Buhrmaster

Attendees: OCSD Team______Black & Veatch/Brown and Caldwell Team Jeff Mohr Tony Lee Jim Clark – Black & Veatch Sharon Yin Michelle Hetherington Joerg Blischke – Black & Veatch Tom Meregillano Jim Colston Tom Chapman – Brown and Caldwell Eros Yong Kathleen Millea Dan Bunce – Brown and Caldwell Eddie Baker Martin Dix Adam Ross – Brown and Caldwell Jon Bradley Rob Thompson Ed Torres Jim Spears Dierdre Bingman Lisa Frigo Robert Bell

Handouts:

The key points that were discussed in the meeting are summarized below and follow the order of the meeting agenda. Some points may not be recorded in the same sequence as actually discussed. Action items are noted below and included in the Action Item Log attached to these minutes.

No. Item Action By Due Date 1 MEETING PURPOSE & OUTCOMES • Reviewed the meeting purpose and outcomes.

2 SAFETY MOMENT • Led by Jim Clark 3 OVERVIEW OF SOURCE SEPARATED ORGANICS (SSO) FEEDSTOCK FOR CO-DIGESTION • Co-digestion should be considered an option • Critical to establish right level of organics, the right level will results in the best scenario for rate-payers, operations, etc. • AB1826 requires source separation of organics and creates a new organics feedstock for anaerobic digestion • Pre-processed source separated organics (SSO) defined as “Organic Slurry”

The above represents the author’s understanding of the items discussed and the decisions made during the context of the meeting. All items are assumed to be correct if the author is not contacted with clarifications.

B&V Job 190875 PS15-01 No . OCSD BIOSOLIDS MASTER PLAN Date: October 11, 2016

DRAFT MEETING MINUTES Page: 2 of 3

No. Item Action By Due Date • Benefits are tipping-fees for waste accepted and increased digester gas production • Recommend pre-processing of SSOs done offsite by third party

4 ORANGE COUNTY SSO STAKEHOLDERS AND PARTNERS • Waste Management’s market is approx. 200 tpd • Republic Services interested in producing 386 tpd organic slurry o Delivered to the WWTP is approximately 100,000 gpd at approximately 12% solids • CR&R already developed a pre-processing solution involving a closed loop system in Perris, CA. The group elaborated on the potential challenges associated with a high solids anaerobic digestion. • Other stakeholders include OCW&R and Anaergia; however, they do not control SSO in the same manner as Republic and WM 5 COMPARE MARKET DEMAND TO OCSD’S CAPACITY AND CONSTRAINTS • Three conclusions: o Food waste facility NOT recommended at Plant 1 o Food waste facility IS recommended at Plant 2 o CenGen is not limiting factor for how much gas can be produced • The conceptual economic analysis suggests a payback in less than 5 years for the receiving facility. • CEQA on BMP need to be completed prior to entering a binding agreement with Solid Waste Haulers for accepting their Organics. • DECISIONS: o Build new digesters to handle the needed capacity and don’t build more solely for food waste. o Prepare the new gas handling system to handle increase of gas (Gas collection and discharge to CenGen), while providing space for the compressors in a right sized compressor building.

The above represents the author’s understanding of the items discussed and the decisions made during the context of the meeting. All items are assumed to be correct if the author is not contacted with clarifications.

B&V Job 190875 PS15-01 No . OCSD BIOSOLIDS MASTER PLAN Date: October 11, 2016

DRAFT MEETING MINUTES Page: 3 of 3

No. Item Action By Due Date

6 TASK 5 LOOK AHEAD SCHEDULE • Need to look at the energy/heat balance at plant 2 and potential to convey gas to Plant 1. • Layout the capital facilities • Consider reaction to digester upsets and digesters out of service • Need to evaluate the impact to the centrate related to the increase of ammonia from TPAD and food waste • Need to evaluate ammonia toxicity related to TPAD and food waste addition • Develop an interim strategy and capacicty to receive food waste between 2018 and 2025, when the new digesters will be built. • Develop a chart showing food waste receiving capacity over time (2018 through 2035)

The above represents the author’s understanding of the items discussed and the decisions made during the context of the meeting. All items are assumed to be correct if the author is not contacted with clarifications.

B&V Job 190875 PS15-01 No . November 29, OCSD BIOSOLIDS MASTER PLAN Date: 2016 DRAFT MEETING MINUTES Page: 1 of 4

Meeting Location: OCSD Administration Building - Conference Room B Meeting Date: November 8, 2016 Meeting Time: 2:00 PM to 3:30 PM Meeting Topic: Task 5.2 – Food Waste Co-Digestion Revision Date: Authored By: Dan Buhrmaster and Adam Ross

Attendees: OCSD Team______Black & Veatch/Brown and Caldwell Team Sharon Yin Jim Clark – Black & Veatch Jeff Mohr Dan Buhrmaster – Black & Veatch Eros Yong Adam Ross – Brown and Caldwell Tony Lee Tom Chapman – Brown and Caldwell Tom Meregillano Dan Bunce – Brown and Caldwell Michelle Hetherington Rich ten Bosch – Black & Veatch Jeff Brown

Handouts: See attached

The key points that were discussed in the meeting are summarized below and follow the order of the meeting agenda. Some points may not be recorded in the same sequence as actually discussed. Action items are noted below and will be included in the Action Item Log.

No. Item Action By Due Date 1 SAFETY MOMENT • A safety moment was presented.

2 MEETING PURPOSE • Review action items from Task 5.1 Workshop. • Discuss receiving food waste as paste. • Review food waste receiving locations. • Review preliminary concept design features.

3 REVIEW ACTION ITEMS FROM TASK 5.1 WORKSHOP • The capacity for receiving food waste was reviewed and current results were shared. Over the planning period at Plant 2, OCSD can accept up to 300 wet tons per day assuming a peak 15-day, Condition 2 loading and assuming 2 thermophilic digesters are out of service. • At the Task 5.1 Workshop, the question of ammonia concentration in the digesters and potential toxicity was posed and the B&V/BC team responded to this issue at the meeting.

The above represents the author’s understanding of the items discussed and the decisions made during the context of the meeting. All items are assumed to be correct if the author is not contacted with clarifications.

B&V Job 190875 PS15-01 No . November 29, OCSD BIOSOLIDS MASTER PLAN Date: 2016 DRAFT MEETING MINUTES Page: 2 of 4

No. Item Action By Due Date • The chemistry of ammonia formation in anaerobic digesters was reviewed for background information, including impacts of pH and temperature. • Ammonia toxicity generally occurs around 2,500 to 3,500 mg-N/L but can vary considerably. • The projected ammonia concentration for the TPAD digesters is approximately 1,300 mg-N/L. Therefore, ammonia toxicity does not appear to be a problem within the digesters.

4 PROS AND CONS OF RECEIVING FOOD WASTE AS A PASTE • B&V/BC discussed what traditional food waste receiving facilities consist of when receiving pumpable food waste feed stock – approximately 12-15% solids concentration. • Receiving food waste paste (approximately 30% solids) would result in fewer trucks for hauling to the site but this would require onsite dilution in order to have a pumpable food waste slurry to feed to the digesters. o Dilution required additional process equipment, tanks, and dilution water o EBMUD currently receives paste o Food waste paste would require end dumping into below grade tanks prior to dilution resulting in greater potential for odor releases. It may also require a grit removal step after dilution and would result in increased onsite O&M requirements. o The CalRecycle exemption is less certain with the food waste paste alternative. Decision • B&V/BC also shared the experience of other utilities with food waste feed stocks. • The OCSD and B&V/BC team made a decision to accept only pulped food waste slurry (12-15% solids) and not to accept food waste paste (30% solids). • The LA County food waste spec can be used as a starting point for developing a food waste spec at OCSD for a food waste slurry.

5 DISCUSS AVAILABLE FOOD WASTE RECEIVING FACILITY LOCATIONS • It was recommended that OCSD should build an interim

The above represents the author’s understanding of the items discussed and the decisions made during the context of the meeting. All items are assumed to be correct if the author is not contacted with clarifications.

B&V Job 190875 PS15-01 No . November 29, OCSD BIOSOLIDS MASTER PLAN Date: 2016 DRAFT MEETING MINUTES Page: 3 of 4

No. Item Action By Due Date food waste receiving facility as soon as practical in order to establish a position in the marketplace. • A permanent food waste receiving facility can then be designed and constructed along with TPAD – this project will take several years to design, build, startup, and commission. • Preliminary site plans were presented to OCSD showing potential locations for both an interim food waste receiving facility and permanent food waste receiving facility. • Representatives from B&V/BDC had walked the plant site with operations staff to look for locations for a temporary facility. There is a suitable location adjacent to Digester C, and there is actually an old citrus waste receiving facility at this location. The citrus receiving tanks appear to be in good condition and it was recommended that the tanks be inspected to see if they can be re-used for a temporary food waste facility. • There is also a suitable location adjacent to Digester M that may be considered. • B&V/BC shared pros and cons regarding these two alternatives. Both potential locations will be carried forward at this time. • Further site layout development will be conducted during Task 6 to confirm this location.

6 FOOD WASTE DESIGN FEATURES • B&V/BC shared preliminary concept design information and a preliminary layout with OCSD for discussion. • Currently, the preliminary concept design shows separate pumps for the three functions needed: (1) receiving pumps, (2) mixing pumps, and (3) feed pumps. This results in a conservative footprint for planning purposes. Combining pump functions can be reviewed at the design stage to see if economies and reduced footprint can be achieved. • As stated above, design to move forward assuming a 12% food waste

7 REVIEW OF ACTIONS ITEMS • No action items were noted.

The above represents the author’s understanding of the items discussed and the decisions made during the context of the meeting. All items are assumed to be correct if the author is not contacted with clarifications.

B&V Job 190875 PS15-01 No . November 29, OCSD BIOSOLIDS MASTER PLAN Date: 2016 DRAFT MEETING MINUTES Page: 4 of 4

The above represents the author’s understanding of the items discussed and the decisions made during the context of the meeting. All items are assumed to be correct if the author is not contacted with clarifications. Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

Appendix D – Title 14 Chapter 3.2 Regulations

May 9, 2017 D‐1 Master Plan Biosolids

Title 14 CCR, Division 7, Chapter 3.2, Articles 1-4 (California Code of Regulations) Page 1 of 12

Regulations: Title 14, Natural Resources--Division 7 Chapter 3.2. In-Vessel Digestion Operations and Facilities Regulatory Requirements

Article 1. In-Vessel Digestion Operations and Facilities Regulatory Requirements

Section: 17896.1 17896.2 17896.3 17896.4 17896.5 17896.6 17896.7 17896.8 17896.9 17896.10 17896.11 17896.12 17896.13 17896.14 17896.15 17896.16

Section 17896.1. Authority and Scope. (a) This Chapter sets forth permitting requirements and minimum operating standards for in-vessel digestion operations and facilities that receive and process by means of in-vessel digestion solid wastes that are subject to the requirements of this Chapter. The regulatory tier requirements of sections 17896.3 through 17896.15 are not applicable to operations and facilities that are subject to regulations elsewhere in this Division. Activities placed within the excluded tier in other chapters of this Division, may still be subject to the regulatory requirements specified in this Chapter.

(b) This Chapter is adopted pursuant to and for the purpose of implementing the California Integrated Waste Management Act of 1989 (Act) commencing with section 40000 of the Public Resources Code, as amended. These regulations should be read together with the Act.

(c) Digestion of organic material can be a naturally occurring or an artificially controlled process. This Chapter establishes standards and regulatory requirements for the intentional processing of organic material by means of in- vessel digestion.

(d) This Chapter implements and interprets those provisions of the Act relating to receipt, storage, handling, recovery, transfer, or processing of solid waste at in-vessel digestion operations and facilities. Nothing in this Chapter limits or restricts the power of any federal, state, or local agency to enforce any provision of law that it is authorized or required to enforce or administer, nor limits or restricts cities and counties from promulgating and enforcing laws which are as strict or stricter than the regulations contained in this Chapter. However, no city or county may promulgate or enforce laws which otherwise conflict with the provisions of this Chapter.

(e) No provision in this Chapter shall be construed as relieving any owner, operator, or designee from obtaining all required permits, licenses, or other clearances and complying with all orders, laws, regulations, or reports, or other requirements of other regulatory or enforcement agencies, including but not limited to, local health agencies, regional water quality control boards, Department of Toxic Substances Control, California Department of Industrial Relations, Division of Occupational Safety and Health, air quality management districts or air pollution control districts, local land use authorities, and fire authorities.

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Section 17896.2. Definitions. (a) For the purposes of this Chapter:

(1) “Agricultural Material” means waste material of plant or animal origin, which results directly from the conduct of agriculture, animal husbandry, horticulture, aquaculture, vermiculture, viticulture and similar activities undertaken for the production of food or fiber for human or animal consumption or use, which is separated at

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the point of generation, and which contains no other solid waste. With the exception of grape pomace, agricultural material has not been processed except at its point of generation and has not been processed in a way that alters its essential character as a waste resulting from the production of food or fiber for human or animal consumption or use. Material that is defined in this section 17852 as “food material” or “vegetative food material” is not agricultural material. Agricultural material includes, but is not limited to, manures, orchard and vineyard prunings, grape pomace, and crop residues.

(2) “Agricultural Site” means activities located on land that is zoned for agricultural uses.

(3) “Biogas” is a gas resulting from the operation of an in-vessel digester at an in-vessel digestion operation or facility that is composed primarily of carbon dioxide, hydrogen, and methane.

(4) “Compost” means the product resulting from the controlled biological decomposition of organic solid wastes that are source separated from the municipal solid waste stream, or which are separated at a centralized facility.

(5) “Contact Water” means water that has come in contact with waste and may include leachate.

(6) “Digestate” means the solid and/or liquid residual material remaining after organic material has been processed in an in-vessel digester.

(7) “Digestion” means, pursuant to PRC 40116.1, the controlled biological decomposition, of organic solid wastes. Digestion includes:

(A) Aerobic digestion - the controlled biological decomposition of organic material in the presence of oxygen.

(B) Anaerobic digestion - the controlled biological decomposition of organic material in the absence of oxygen or in an oxygen-starved environment. Anaerobic digestion produces biogas and a residual digestate.

(C) Other controlled biological decomposition processes.

(8) “Dairy In-vessel Digestion Operation” means, except as otherwise specified in section 17896.6(a)(3), a dairy that receives imported solid waste feedstock for purposes of co-digestion, with manure in an in-vessel digester, in accordance with Waste Discharge Requirements issued by a Regional Water Quality Control Board. The Dairy In-vessel Digestion Operation may also co-digest agricultural material.

(9)"Distribution Center In-vessel Digestion Operation" means a site that receives, for the purpose of digestion in an in-vessel digester, unsold products from retail stores to which the products were originally sent. All unsold products shall be collected and processed in covered, leak-proof containers, and remain in the custody of the owner at all times. All unsold products that are putrescible shall be refrigerated at the retail store and shall be maintained at a core temperature of 13 degrees Celsius (55 degrees Fahrenheit) or less during transport to the operation.

(10) “EA” means enforcement agency as defined in PRC section 40130.

(11) “Film plastic” means sheet plastic 10 mil or less in thickness.

(12) “Food Material” means a waste material of plant or animal origin that results from the preparation or processing of food for animal or human consumption and that is separated from the municipal solid waste stream. Food material includes, but is not limited to, food waste from food facilities as defined in Health and Safety Code section 113789 (such as restaurants), food processing establishments as defined in Health and Safety Code section 111955, grocery stores, institutional cafeterias (such as prisons, schools and hospitals), and residential food collection. Food material does not include any material that is required to be handled only pursuant to the California Food and Agricultural Code and regulations adopted pursuant thereto.

(A) “Vegetative Food Material" means that fraction of food material, defined above, that is a plant material and is separated from other food material and the municipal solid waste stream. Vegetative food material may be processed or cooked but must otherwise retain its essential natural character and no salts, preservatives, fats or oils, or adulterants shall have been added. Vegetative food material includes,

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but is not limited to, fruits and vegetables, edible flowers and plants, outdated and spoiled produce, and coffee grounds. Vegetative food material contains no greater than 1.0 of percent physical contaminants by dry weight, and meets the requirements of section 17896.61.

(13) “Hazardous Wastes” means any waste which meets the definitions set forth in Title 22, section 66261.3, et seq.

(14) “In-vessel Digester” means the sealed container(s) or sealed structure in which the entire digestion process occurs.

(15) “Large Volume In-vessel Digestion Facility” means a facility that receives an average greater than 100 tons of solid waste per operating day or greater than 700 tons (2,800 cubic yards) per week of solid waste for digestion in an in-vessel digester.

(16) “Limited Volume In-vessel Digestion Operation” means an operation that receives less than an average of 15 tons (or 60 cubic yards) of solid waste per operating day but shall not exceed 105 tons (or 420 cubic yards) per week of solid waste for digestion in an in-vessel digester. Additionally, the operation shall not exceed solid waste storage capacity limitations of the general design of the operation.

(17) “” means all solid waste which has been improperly discarded or which has migrated by wind or equipment away from the operations area. Litter includes, but is not limited to, convenience food, beverage, and other product packages or containers constructed of steel, aluminum, glass, paper, plastic, and other natural and synthetic materials, thrown or deposited on the lands and waters of the state.

(18) “Manure” is an agricultural material and means accumulated herbivore or avian excrement. This definition shall include feces and urine, and any bedding material, spilled feed, or soil that is mixed with feces or urine.

(19) “Medium Volume In-vessel Digestion Facility” means a facility that receives an average of between 15 tons (or 60 cubic yards) and 100 tons of solid waste per operating day but shall not exceed 700 tons (or 2,800 cubic yards) per week of solid waste for digestion in an in-vessel digester. Additionally, the facility shall not exceed solid waste storage capacity limitations of the general design of the facility.

(20) “Nuisance” includes anything which:

(A) is injurious to human health or is indecent or offensive to the senses and interferes with the comfortable enjoyment of life or property, and

(B) affects at the same time an entire community, neighborhood or any considerable number of persons. The extent of annoyance or damage inflicted upon an individual may be unequal.

(21) “On-site” means located within the boundary of the operation or facility.

(22) “Operating Day” means the daily hours of operation for a facility or operation as set forth in the application, Enforcement Agency Notification or solid waste facilities permit.

(23) “Operating Record” means an easily accessible collection of records of an operation's or facility's activities and compliance with required state minimum standards under Title 14. The Record may include the In-vessel Digestion Facility Plan or In-vessel Digestion Report for facilities, and shall contain but is not limited to containing: agency approvals, tonnage and load checking records, facility contacts and training history. The record may be reviewed by state and local authorities and shall be available during normal business hours. If records are too voluminous to place in the main operating record or if the integrity of the records could be compromised by on-site storage, such as exposure to weather, they may be maintained at an alternative site, as long as that site is easily accessible to the EA.

(24) “Operations Area” means:

(A) the following areas within the boundary of an operation or facility as described in the permit application or Enforcement Agency Notification:

1. equipment management area, including cleaning, maintenance, and storage areas; and

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2. material and/or solid waste management area, including unloading, handling, transfer, processing, and storage areas.

(B) the boundary of the operations area is the same as the permitted boundary of the operation or facility but may or may not be the same as the property boundary on which the operation or facility is located.

(25) “Operator” means the owner, or other person who through a lease, franchise agreement or other arrangement with the owner, that is listed in the permit application or Enforcement Agency Notification and is legally responsible for all of the following:

(A) complying with regulatory requirements set forth in these Articles;

(B) complying with all applicable federal, state and local requirements;

(C) the design, construction, and physical operation of the operations area;

(D) controlling the activities at an operation or facility as listed on the permit application or Enforcement Agency Notification.

(26) “Owner” means the person or persons who own, in whole or in part, an operation or facility and the land on which it is located. If the ownership of the operation or facility is not the same as the ownership of the land on which it is located, the owner of the land shall be identified as the “Land Owner” and the owner of the operation or facility shall be identified as the “Facility Owner.”

(27) “Physical Contamination” or “Contaminants” means human-made inert material contained within compostable material, digestate, or compost, including, but not limited to, glass, metal, and plastic.

(28) “Putrescible Wastes” include wastes that are capable of being decomposed by micro-organisms with sufficient rapidity as to cause nuisances because of odors, vectors, gases or other offensive conditions, and include materials such as, but not limited to food wastes, offal and dead animals. The EA shall determine on a case-by-case basis whether or not a site is handling putrescible wastes.

(29) “Rendering” means all recycling, processing, and conversion of animal and fish materials and carcasses and inedible kitchen grease into fats, oils, proteins, and other products that are used in the animal, poultry, and pet food industries and other industries, as defined in Food and Agricultural Code section 19213.

(30) “Salvaging” means the controlled separation of solid waste material which do not require further processing, for reuse or recycling prior to in-vessel digestion activities.

(31) “Scavenging” means the uncontrolled and/or unauthorized removal of solid waste materials.

(32) “Sealed Container” means a tank, vessel, or similar apparatus capable of containing liquids and air-borne emissions during the entire digestion process to control odors or other nuisance conditions.

(33) “Sealed Structure” means a fully enclosed building capable of containing liquids and controlling air-borne emissions (e.g., negative air pressure) that could contribute to odors or other nuisance conditions.

(34) “Special Waste” includes but is not limited to:

(A) waste requiring special collection, treatment, handling, storage, or transfer techniques as defined in Title 22, section 66260.10.

(B) waste tires and appliances requiring the removal of mercury switches or chlorofluorocarbons.

(35) “Spotter” means an employee who conducts activities that include, but are not limited to, traffic control, recognition and removal for proper handling, storage and transport or disposal, and protection of the public from health and/or safety hazards.

(36) “Store” means to stockpile or accumulate for later use.

Note:

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Authority cited: Section 40502, 43020 and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Section 17896.3. Pre-Existing Permits and Notifications (a) If a facility had previously obtained a permit in accordance with regulations in effect prior to January 1, 2016, that facility may continue to operate in accordance with its permit until the EA conducts a permit review pursuant to Title 14, California Code of Regulations, sections 18104.7 and 18105.9 and determines that regulation under this Chapter is required. If the EA makes such a determination, the operator shall comply with this Chapter within two years of that determination.

(b) If an operation had previously been operating pursuant to an EA Notification in accordance with regulations in effect prior to January 1, 2016, that operation may continue to operate in accordance with its EA Notification or regulatory authorization until the EA determines that regulation under this Chapter is required. The EA shall make this determination no sooner than 120 days and no later than two years from January 1, 2016. If the EA determines that regulation under this Chapter is required, the operator shall comply with this Chapter within two years of that determination.

(c) If an activity had previously been excluded from regulations in effect prior to January 1, 2016, that activity may continue to operate in accordance with its regulatory exclusion until the EA determines that regulation under this Chapter is required. The EA shall make this determination no sooner than 120 days and no later than two years from January 1, 2016. If the EA determines that regulation under this Chapter is required, the operator shall comply with this Chapter within two years of that determination.

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 43020 and 43021, Public Resources Code.

Section 17896.4. Permit Name Any permit issued pursuant to this Article, except for one issued pursuant to section 17896.12 shall be entitled: "In- vessel Digestion Facility Permit."

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 43020 and 43021, Public Resources Code.

Section 17896.5. Regulatory Tier Requirements for In-Vessel Digestion Operations and Facilities. Sections 17896.6 through 17896.13 set forth the regulatory tier requirements (Title 14, Division 7, Chapter 5. Article 3.0, commencing with section 18100 or Title 27, Division 2, Subdivision 1, Chapter 4, Subchapter 3, Articles 2, 3 and 3.1 (commencing with section 21570) of the California Code of Regulations) that apply to specified types of In-vessel Digestion Operations and Facilities. These requirements are summarized in Table 1.

Table 1 In-Vessel Digestion Operations and Facilities Placement into the Regulatory Tiers Enforcement Agency Full Solid Waste Facility Excluded Tier Notification Tier Registration Permit Tier Permit Refer to Research In-Vessel Digestion Medium Volume Large Volume Section Operations In-Vessel Digestion Facilities In-Vessel Digestion 17896.6 Section 17896.8 [average between 15 tpd (60 yd3 and Facilities 100 tpd, not to exceed 700 tpw (2,800 [average > 100 tpd, yd3)] average > 700 tpw (2,800 Section 17896.12 yd3)] Section 17896.13 Dairy In-Vessel Digestion Operations Section 17896.9

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Distribution Center In-Vessel Digestion Operations Section 17896.10 Limited Volume In-Vessel Digestion Operations [average < 15 tpd (60 yd3 not to exceed 105 tpw (420 yd3)] Section 17896.11 [Note: There are no in-vessel digestion operations or facilities placed within the Standardized tier.]

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Section 17896.6. Excluded Activities. (a)The activities listed in this section are not subject to the in-vessel digestion requirements set forth in this Chapter. Nothing in this section precludes the EA or the Department from inspecting an excluded activity to verify that the activity is being conducted in a manner that qualifies as an excluded activity or from taking any appropriate enforcement action.

(1) A Publicly Owned Treatment Works Treatment Plant (POTW Treatment Plant), as defined in section 403.3(r) of Title 40 of the Code of Federal Regulations, that receives vehicle-transported solid waste that is an anaerobically digestible material for the purpose of anaerobic co-digestion with POTW Treatment Plant wastewater, is excluded under the following conditions:

(A) Anaerobically digestible materials must be trucked or hauled into a POTW Treatment Plant. Once on- site, the anaerobically digestible material must be pumped or off-loaded directly into a covered, leak- proof container and then pumped, or diluted or slurried and then pumped, and co-digested in an anaerobic digester(s) at the POTW Treatment Plant. The pumped material may be screened, otherwise separated or treated prior to anaerobic digestion, but must be processed and conveyed in a contained system. Any separated material at the POTW that is not suitable for anaerobic digestion and has no beneficial use shall be further managed as a solid waste.

(B) The POTW Treatment Plant has developed Standard Operating Procedures for the acceptance of anaerobically digestible material, the POTW Treatment Plant has notified the Regional Water Quality Control Board that those Standard Operating Procedures are being implemented, and a Standard Provision (permit condition) that reflects the acceptance of anaerobically digestible material:

1. has been incorporated into the POTW Treatment Plant’s Waste Discharge Requirements or National Pollutant Discharge Elimination System permit; or 2. will be incorporated into the POTW Treatment Plant’s Waste Discharge Requirements or National Pollutant Discharge Elimination System permit no later than the next permit renewal.

(C) For the purpose of this exclusion, “anaerobically digestible material” means: inedible kitchen grease as defined in section 19216 of the Food and Agricultural Code, food material as defined in Title 14, CCR, section 17896.2(a)(12) and vegetative food material as defined in Title 14, CCR, section 17896.2(a)(12) (A).

(D) For the purpose of this exclusion, the Department, in consultation with the State Water Resources Control Board and the California Department of Food and Agriculture, will on a case-by-case basis, review and consider approval of additional types of organic materials as potential “anaerobically digestible material” beyond those specified in section 17896.6(a)(1)(C) in accordance with the following:

1. Receipt of a written request to the Department from the General Manager or designee of a POTW Treatment Plant.

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a. The written request must contain the following information:

i. The purpose of the request. ii. Identification of the POTW Treatment Plant proposing to anaerobically co-digest the organic waste material with the POTW wastewater. iii. Types of organic material requested for classification as an anaerobically digestible material. iv. The source(s) of the waste material. v. A description of how the waste material will be handled, processed, stored and transported (before and after receipt at the POTW Treatment Plant). vi. A map identifying all proposed physical changes proposed at the POTW Treatment Plant to accommodate the new waste materials. vii. Available laboratory test results, engineering reports, research or study to support the request. viii. Data and/or reports if this waste material has been used without incident at a different POTW Treatment Plant. ix. The name, addresses and phone numbers for the General Manager and designee of the POTW Treatment Plant. b. Upon receipt of the written request, the Department will communicate and coordinate the request with and between the State Water Resources Control Board and the California Department of Food and Agriculture and will complete the following actions:

i. Within 10 days of receipt, send written confirmation to the General Manager and designee of the POTW Treatment Plant indicating receipt of the letter and distribute the letter to appropriate Department staff, as well as to the State Water Resources Control Board and California Department of Food and Agriculture staff contacts for review; ii. Within 15 days of receipt, schedule a meeting with State Water Resources Control Board and California Department of Food and Agriculture staff contacts; iii. Prior to the meeting, Department staff will review the letter and identify questions and/or issues with the request and make a list of recommendations; iv. Within 40 days of receipt, conduct a meeting on the request. If an agency representative does not attend the meeting, comments will be accepted by the Department up to close of business on the 45th day after receipt; v. Within 60 days of receipt, the Department will provide a written decision to the General Manager and designee of the POTW Treatment Plant stating one of the following:

I. The waste type has or has not been determined to be an anaerobically digestible material excluded from both the In-Vessel Digestion Operations and Facilities Regulatory Requirements (pursuant to section 17896.6(a)(1)(C) and the Transfer/Processing Operations and Facility Regulatory Requirements (pursuant to section 17403.1(a)(8));

II. The agencies, based on the information provided, were unable to reach a determination and additional information is required before a determination can be made; or

III. The agencies have determined that additional research or study will need to be conducted and the results analyzed prior to a determination made by the agencies.

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IV. If additional information, research or study is necessary, the Department will consult with the General Manager or designee of the POTW, the State Water Resources Control Board and California Department of Food and Agriculture contacts, for the purpose of developing a timeline for either reviewing the additional information or for reviewing a proposed scope of work and timeline for additional research or study. 2. For the purpose of this exclusion, if an organic waste material is determined by the Department to be an anaerobically digestible material for the purpose of co-digestion with the POTW wastewater, the POTW Treatment Plant must comply with section 17896.6(a)(1)(A) prior to receipt of the material at the POTW Treatment Plant.

(2) In-vessel digestion of agricultural material derived from an agricultural site and the digestate or compost produced from digestate is returned to that same agricultural site, or an agricultural site owned or leased by the owner, parent, or subsidiary of the agricultural site on which the in-vessel digester is located. No more than an incidental amount of up to 1,000 cubic yards of compost produced from digestate may be given away or sold annually. Digestate that is not composted may not be given away or sold.

(3) In-vessel digestion at a dairy involving the co-digestion of manure with agricultural material derived on-site, imported agricultural material, and/or imported vegetative food material in accordance with Waste Discharge Requirements issued by a Regional Water Quality Control Board.

(A) Any imported materials delivered to the dairy must be pumped or off-loaded directly into a covered, leak-proof container and then pumped, or diluted or slurried and then pumped, and co-digested in an in- vessel digester at a dairy. The pumped material may be screened, otherwise separated or treated prior to in-vessel digestion, but must be processed and conveyed in a contained system. Any separated material at the dairy that is not suitable for in-vessel digestion and has no beneficial use shall be further managed as a solid waste.

(B) No more than an incidental amount of up to 1,000 cubic yards of compost produced from digestate may be given away or sold annually. Digestate that is not composted may not be given away or sold.

(4) In-vessel digestion activities with less than a total of 100 cubic yards of solid waste, feedstock, and digestate on-site are excluded. [Note: Persons handling solid waste under the above exclusion are obligated to obtain all permits, licenses, or other clearances that may be required by other regulatory agencies including, but not limited to local health entities and local land use authorities.]

(5) Rendering activities, authorized by the California Department of Food and Agriculture pursuant to section 19300 of the Food and Agricultural Code, in which no solid waste feedstock bypasses the rendering process.

(6) Other discrete handling activities that are already subject to more stringent handling requirements under Federal or State law, as determined by the EA in consultation with the Department, are excluded.

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 43020 and 43021, Public Resources Code.

Section 17896.7. Prohibitions. The following activities are prohibited at all in-vessel digestion operations and facilities and at all sites where in-vessel digestion activities that are excluded from regulation under this Chapter occur:

(a) The in-vessel digestion of unprocessed mammalian tissue, including but not limited to, flesh, organs, hide, blood, bone and marrow, except when received:

(1) from a food facility as defined in Health and Safety Code section 113789, grocery store; or residential food scrap collection; or

(2) as part of a research activity for the purpose of obtaining data on pathogen reduction or other public health, animal health, safety, or environmental concerns in accordance with section 17896.8; or

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(3) from a source and processed by a facility approved by the Department in consultation with the State Water Resources Control Board and the California Department of Food and Agriculture, on a case-by- case basis.

(b) The in-vessel digestion of treated or untreated medical waste.

(c) The in-vessel digestion of hazardous waste.

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Section 17896.8. Research In-Vessel Digestion Operations (a) An operator conducting research in-vessel digestion operations shall comply with the EA Notification requirements set forth in Title 14, California Code of Regulations, Division 7, Chapter 5.0, Article 3.0 (commencing with section 18100), except as otherwise provided by this Chapter.

(b) In addition to the EA Notification requirements set forth in Title 14, California Code of Regulations, Division 7, Chapter 5.0, Article 3.0, section 18103.1(a)(3), the operator shall provide a description of the research to be performed, research objectives, methodology/protocol to be employed, data to be gathered, analysis to be performed, how the requirements of this subchapter will be met, and the projected timeframe for completion of the research operation.

(c) After no more than a two year period of operation, the operator of a research in-vessel digestion operation shall submit to the EA a report that includes the results and conclusions drawn from the research. If the EA determines, based on the report, that there are further research objectives to be met or data to be gathered, the EA may extend the research for a specified time period not to exceed two years. If the EA determines based on the report that there are no further research objectives to be met or data to be gathered, the operator shall conduct site restoration at the facility pursuant to section 17896.41, or obtain other appropriate authorization pursuant to Article 1 of this Chapter prior to continuing operations.

(d) Research in-vessel digestion operations that will be using unprocessed mammalian tissue as a feedstock for the purpose of obtaining data on pathogen reduction or other public health, animal health, safety, or environmental protection concern, shall satisfy the following additional requirements:

(1) Unprocessed mammalian tissue used as feedstock shall be generated from on-site agricultural operations, and all products derived from unprocessed mammalian tissue shall be beneficially used on-site.

(2) The operator shall prepare, implement and maintain a site-specific, research in-vessel digestion operation site security plan. The research in-vessel digestion site security plan shall include a description of the methods and facilities to be employed for the purpose of limiting site access and preventing the movement of unauthorized material on to or off of the site.

(3) After no more than a six-month period of operation the operator of a research in-vessel digestion operation using unprocessed mammalian tissue as feedstock shall submit to the EA a report that includes the results and conclusions drawn from the research and documentation of additional requirements of this section. If the EA determines based on the report that there are further research objectives to be met or data to be gathered, the EA may extend the research for a specified time period not to exceed two years. If the EA determines based on the report that there are no further research objectives to be met or data to be gathered, the operator shall conduct site restoration at the facility pursuant to section 17896.41, or obtain other appropriate authorization pursuant to Article 1 of this Chapter prior to continuing operations.

(e) The operator shall submit all additional documentation required by subdivisions (b) and (d)(2). to the EA with the Notification and prior to the digestion of any feedstock. The EA shall determine that the EA Notification for research in- vessel digestion operations is complete and correct only if the additional documentation requirements of this section have been met.

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(f) These operations shall be inspected by the EA at least once every three (3) months unless the EA approves, with Department concurrence, a reduced inspection frequency. The EA may approve a reduced inspection frequency only if it will not pose an additional risk to public health and safety or the environment but in no case shall the frequency be less than once per calendar year. [Note: See section 18083(a)(3) for additional EA and Department requirements regarding the approval or denial of requests for reducing the frequency of inspections.]

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 43020 and 43021, Public Resources Code.

Section 17896.9. Dairy In-Vessel Digestion Operations (a) All dairy in-vessel digestion operations shall comply with the EA Notification requirements set forth in Title 14, California Code of Regulations, Division 7, Chapter 5.0, Article 3.0 (commencing with section 18100).

(1) These operations shall be inspected by the EA at least once a month for the first 12 months of operation. After the first 12 months of operation the EA may approve, with Department concurrence, a reduced inspection frequency of once every three months. After the first 24 months of operation the EA may approve, with Department concurrence, a reduced inspection frequency of once per calendar year. The EA may approve a reduced inspection frequency only if it will not pose an additional risk to public health and safety or the environment. [Note: See section 18083(a)(3) for additional EA and Department requirements regarding the approval or denial of requests for reducing the frequency of inspections.]

(2) Any imported materials delivered to the dairy must be pumped or off-loaded directly into a covered, leak- proof container and then pumped, or diluted or slurried and then pumped, and co-digested in an in-vessel digester at a dairy. The pumped material may be screened, otherwise separated or treated prior to in-vessel digestion, but must be processed and conveyed in a contained system. Any separated material at the dairy that is not suitable for in-vessel digestion and has no beneficial use shall be further managed as a solid waste.

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 43020 and 43021, Public Resources Code.

Section 17896.10. Distribution Center In-Vessel Digestion Operations. (a) All distribution center in-vessel digestion operations shall comply with the EA Notification requirements set forth in Title 14, California Code of Regulations, Division 7, Chapter 5.0, Article 3.0 (commencing with section 18100).

(1) These operations shall be inspected by the EA at least once every three (3) months unless the EA approves, with Department concurrence, a reduced inspection frequency. The EA shall approve a lesser inspection frequency if it will not pose an additional risk to public health and safety and the environment but in no case shall the frequency be less than annual. The EA shall submit, for concurrence, a copy of the operator request and EA-proposed approval to the Department. [Note: See section 18083(a)(3) for additional EA and Department requirements regarding the approval or denial of requests for reducing the frequency of inspections.]

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 43020 and 43021, Public Resources Code.

Section 17896.11. Limited Volume In-Vessel Digestion Operations. All limited volume in-vessel digestion operations shall comply with the Enforcement Agency Notification requirements set forth in Title 14, Division 7, Chapter 5.0, Article 3.0 of the California Code of Regulations (commencing with section 18100).

(1) These operations shall be inspected by the EA at least once every three (3) months unless the EA approves, with Department concurrence, a reduced inspection frequency. The EA shall approve a lesser

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inspection frequency if it will not pose an additional risk to public health and safety and the environment but in no case shall the frequency be less than annual. The EA shall submit, for concurrence, a copy of the operator request and EA-proposed approval to the Department. [Note: See section 18083(a)(3) for additional EA and Department requirements regarding the approval or denial of requests for reducing the frequency of inspections.]

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Section 17896.12. Medium Volume In-Vessel Digestion Facilities All medium volume in-vessel digestion facilities shall comply with the Registration Permit requirements set forth in Title 14, Division 7, Chapter 5.0, Article 3.0 of the California Code of Regulations (commencing with section 18104).

(1) These facilities shall be inspected monthly by the EA in accordance with PRC section 43218.

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Section 17896.13. Large Volume In-Vessel Digestion Facilities All large volume in-vessel digestion facilities shall obtain a Full Solid Waste Facilities Permit, in accordance with the procedures set forth in Title 27, Division 2, Subdivision 1, Chapter 4, Subchapter 3, Articles 2, 3, and 3.1 of the California Code of Regulations (commencing with section 21570). The In-vessel Digestion Report required by section 17896.15 shall constitute the Report of Facility Information required by section 21570(f)(2) of Title 27.

(1) These facilities shall be inspected monthly by the EA in accordance with PRC section 43218.

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Section 17896.14. In-Vessel Digestion Facility Plan. Each operator of a Medium Volume In-vessel Digestion Facility, as defined in section 17896.2(a)(19) shall file with the EA an “In-vessel Digestion Facility Plan” (as specified in section 18221.5.1). The information contained in the Plan shall be reviewed by the EA to determine whether it is complete and correct as defined in Title 14, Division 7, Chapter 5.0, Article 3.0, section 18101.

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Section 17896.15. In-Vessel Digestion Report. (a) Each operator of a Large Volume In-vessel Digestion Facility, as defined in section 17896.2(a)(15) shall file with the EA an “In-Vessel Digestion Report” (as specified in section 18221.6.1). An operator of an existing facility who submits an application package to the EA, pursuant to Title 27, section 21570, which proposes to change the facility's operations, or to change the solid waste facility permit shall do one of the following:

(1) submit the updated information as an amendment to the existing In-vessel Digestion Report; or

(2) submit a complete In-vessel Digestion Report as described in section 18221.6.1.

Note:

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Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Section 17896.16. Applicability of State Minimum Standards (a) Articles 1, 2, 3, 4, and 6. of this Chapter set forth the minimum standards that apply to all in-vessel digestion operations and facilities, except as noted in section 17896.1.(a).

(b) Article 5 of this Chapter sets forth additional minimum standards that will apply only to in-vessel digestion facilities.

(c) Approvals, determinations and other requirements that the EA is authorized to make under Articles 1, 3, 4, 5, and 6 of this Chapter shall be provided in writing by the EA to the operator. The operator shall place a copy of each approval, determination and other requirement in the operating record together with those records identified in sections 17896.45 and 17896.46.

(d) Some of the standards contained in this Chapter authorize the EA to approve an alternative method of compliance with the standard. These provisions are not intended to allow the EA to change the particular standard, but are intended to allow the EA flexibility to approve, in advance, an alternative method of meeting the existing standard which provides equivalent protection of the public health and safety and the environment as the existing standard. For facilities that require a full solid waste facility permit, the EA may choose to include the approved alternative method of compliance as a term and condition of the solid waste facility permit, rather than in the manner authorized by subdivision (c) of this section. If the method is included in the solid waste facility permit, a change to the method may require a revision to the solid waste facility permit in accordance with the procedures set forth in Title 27, Division 2, Subdivision 1, Chapter 4, Subchapter 3, Articles 2, 3, and 3.1 (commencing with section 21570).

Note:

Authority cited: Sections 40502, 43020, and 43021, Public Resources Code. Reference: Sections 40053, 43020 and 43021, Public Resources Code.

Title 14 Home

Last updated: CalRecycle regulations are updated continuously as changes are made and approved by the Office of Administrative Law. Regulations http://www.calrecycle.ca.gov/Laws/Regulations/ Legal Office: [email protected] (916) 341-0089

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http://www.calrecycle.ca.gov/Laws/Regulations/Title14/ch32a1.htm 2/2/2017 Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

Appendix E – SSO Pre‐processed Characteristics

May 9, 2017 E‐1 Master Plan Biosolids

Detailed Summary of food waste characteristics ITEM VALUE REFERENCE pH 3.0 – 7.0 LACSD SSO SPECIFICATION Volatile Acids (Acetic Acid Less than 8,000 mg/L LACSD SSO SPECIFICATION Equivalents) Total Solids 12.0 – 15.0% LACSD SSO SPECIFICATION Volatile Solids (% of Total 85 – 95% LACSD SSO SPECIFICATION Solids) Total COD Greater than 180,000 mg/L LACSD SSO SPECIFICATION Total BOD Greater than 80,000 mg/L LACSD SSO SPECIFICATION Specific Gravity@25 degC 0.95 – 1.10 LACSD SSO SPECIFICATION Kinematic Viscosity@25 Less than 200 cps LACSD SSO SPECIFICATION degC Ammonia as Nitrogen (NH3- Less than 600 mg/L LACSD SSO SPECIFICATION N) Total Kjeldahl Nitrogen (TKN) Less than 7,500 mg/L LACSD SSO SPECIFICATION

Total Carbon Greater than 9,000 mg/L LACSD SSO SPECIFICATION Electrical Conductivity Less than 15 millimho/cm LACSD SSO SPECIFICATION Arsenic Less than 1 mg/L LACSD SSO SPECIFICATION Calcium Less than 3,000 mg/L LACSD SSO SPECIFICATION Chloride Less than 3,000 mg/L LACSD SSO SPECIFICATION Chromium Less than 2 mg/L LACSD SSO SPECIFICATION Magnesium Less than 500 mg/L LACSD SSO SPECIFICATION Mercury Less than 1 mg/L LACSD SSO SPECIFICATION Nickel Less than 5 mg/L LACSD SSO SPECIFICATION Potassium Less than 3,000 mg/L LACSD SSO SPECIFICATION Sodium Less than 3,000 mg/L LACSD SSO SPECIFICATION Total Heavy Metals (Ag, As, Less than 50 mg/L LACSD SSO SPECIFICATION Ba, Cd, Co, Cr, Cu, Hg, Mo, Ni, Pb, Sb, Se, Ti Sr, Sn, V, and Zn) Specific Heavy Metal Limits Cadmium (Cd) 1 mg/L Ordinance OCSD-48 Chromium (Cr) 35 mg/L Ordinance OCSD-48 Copper (Cu) 25 mg/L Ordinance OCSD-48 Lead (Pb) 10 mg/L Ordinance OCSD-48 Nickel (Ni) 10 mg/L Ordinance OCSD-48 ITEM VALUE REFERENCE Zinc (Zn) 50 mg/L Ordinance OCSD-48 Physical Contamination (1) 0.5% by dry weight Title 14 -Section 17868.3.1 – Physical (greater than 4 millimeters) Contamination Limits Film Plastic 20% by dry weight of Physical Title 14 -Section 17868.3.1 – Physical (greater than 4 millimeters) Contamination Contamination Limits Note: 1. "Physical Contaminants" means human-made inert products contained within feedstocks, including, but not limited to, glass, metal, and plastic (Title 14 Section 17381).

Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

Appendix F – Example SSO and HSW Contracts from Other Facilities

May 9, 2017 F‐1 Master Plan Biosolids

EBMUD's Resource Recovery: Trucked Waste Program provides an environmentally friendly and economical disposal alternative. EBMUD treats a variety of liquid and solid wastes, and offers competitive rates and a convenient disposal location 24 hours a day, seven days a week, 365 days a year. Permitting There are two main avenues to permit your waste: 1) Generator of waste obtains base Permit and has it hauled, or 2) Generator hires an approved hauler to obtain a Permit and haul waste.

1. If your company already has a base Permit, fill out the Material Acceptance Agreement (MAA) below. The MAA should only be submitted by a company with an existing base Permit or is in the process of applying for one. Send the form along with appropriate lab data and Material Safety Data Sheets to [email protected]. 2. If necessary, email [email protected] to obtain a list of Approved Permitted Haulers who can profile your wastestream, or use the Base Permit Application packet below to apply for your own Permit. 3. Use the Supplemental Wastestream Information Form if the process generating the waste is more complex than space allows on the MAA. Currently Accepted Waste Streams

 Animal Processing Waste  Animal Blood (Beef, Poultry, Sheep, Swine/Pig)  Beverage Processing Waste (Beer, Dairy, Juice, Spirits)  Brine Waste / Gray Water (Reverse Osmosis (RO) Reject, Boiler Blowdown, Cooling Towers)  Dairy DAF (Dissolved Air Flotation)  Domestic Septage / Septic Tank Cleanouts  Equipment Rinsate (Clean-in-Place (CIP)  Fats, Oils, and Grease (FOG) / Inedible Kitchen Grease / Grease Traps  Food Processing (Liquids and Solids) Waste and Expired or Off- Specification Product  Groundwater / Stormwater  Industrial / Commerical Process Waste  Liquid Organic  Municipal Water and Wastewater Sludge  Pharmaceutical  Portable Toilets / Chemical Toilets  Rendering Facility Waste  Winery Waste (Lagoon/Pond, Lees, Juice/Product, Barrel/Tank Rinsate) (see Winery Waste Management Program Brochure below)  Not sure? Contact [email protected] to profile your waste.

Food scraps is the largest category of municipal solid waste currently sent to landfills. When disposed of in landfills, food waste breaks down and releases methane, a potent greenhouse gas. EBMUD's wastewater treatment plant at the base of the Bay Bridge in Oakland not only treats sewage, but takes discarded materials like food scraps from restaurants and supermarkets that usually go to the landfill and converts them into renewable energy.

For the past seven years, EBMUD has been perfecting a process to efficiently convert food scraps to renewable energy. This pilot facility has converted 20 to 40 tons a day of restaurant food scraps to electrical power. Based on the success of the pilot project, EBMUD plans to grow this recycling program. Recycling food scraps at EBMUD supports local and landfill reduction goals and mandates. EBMUD uses natural microbial activity, called anaerobic digestion, to convert these food scraps into renewable energy called biogas. Benefits of EBMUD's food scraps processing facility:

 Food scraps are converted to methane gas, and used as a renewable green fuel.  Greenhouse gas emissions are reduced. The energy is used to power EBMUD's wastewater plant and the excess energy is sold back to the grid or used as carbon credits.  The Oakland location provides an innovative local solution with local benefits -with no need to transport wastes over long distances.  No combustion, or other thermal conversion is used to convert the food scraps into biogas.  EBMUD's existing anaerobic digesters can be used for the food scraps recycling project.  The project supports local and regional efforts towards green house gas reduction (climate change), oil independence, zero waste and landfill reduction.

Resource Recovery Program RESOURCE RECOVERY PERMIT P. O. Box 24055, MS 702 Oakland, CA 94623-1055 (510) 287-1336 Fax (510) 287-1530 [email protected]

RE: EBMUD Resource Recovery Permit (Non-Hazardous)

Dear Prospective Customer:

East Bay Municipal Utility District (EBMUD) appreciates the opportunity to assist you with your waste disposal needs. Attached is an application for a Resource Recovery Permit for delivery of non-hazardous materials and related documents required to set up an account for material disposal at EBMUD. Please complete the permit application packet and return it to the Resource Recovery Program at the address above.

Permit Application The checklist below lists the forms required to be completed to start the permitting process.

REQUIRED FOR ALL COMPANIES Permit Application (two pages) Material Acceptance Agreement(s) (Addendum A), required for each separate type of material to be delivered Insurance: General Liability (Addendum B) Insurance Certificate, Auto/Trucking (Addendum C), and Worker’s Compensation (Addendum D) Insurance Certificates (optional) Resource Recovery Third Party Billing Agreement (Addendum A1), required to establish third-party billing for each material to be delivered

Additional Information  No material may be delivered until an EBMUD Gate Pass is provided for that material.  Annual fee of $300 will be invoiced to your company. Please do not send a check at this time.  Disposal fees are based on a full tanker capacity for each delivery.  The receiving stations are available 24-hours per day, 7 days per week for routine deliveries, and located at 2020 Wake Avenue, Oakland, CA.  Non-routine deliveries requiring staff involvement (e.g. issuance of a new tanker decal, driver site orientation, and first-load sampling for all new materials) are required to have an appointment during regular business hours with the Senior Environmental Health and Safety Specialist, (510) 986-7835.  All vehicles entering the EBMUD facility for waste disposal must be equipped with: . Back-up alarm . Tanker equipped with a four-inch male camlock fitting adaptor to connect to the EBMUD receiving station.

If you have any questions about the permit process or information required, please contact the Wastewater Control Representative at (510) 287-1336.

Attachments

Revised 7/7/2014

RESOURCE RECOVERY PROGRAM RESOURCE RECOVERY PERMIT P. O. BOX 24055, MS 702 APPLICATION INSTRUCTIONS Oakland, CA 94623-1055 (510) 287-1336 Fax (510) 287-1530 [email protected]

Instructions For Completing the Resource Recovery Permit Application

Please Type or Print the Requested Information

Permit Application Business Name – Enter the name of the business that is accepting legal responsibility for material discharge, including responsibility for any enforcement actions and/or penalties imposed by EBMUD. Upon approval of the permit, this will be the permitted party. This party will also provide insurance certificates for General Liability (Addendum B) Auto/Trucking (Addendum C) and Workers Compensation (Addendums D). Each proposed waste stream must have a Material Acceptance Agreement (Addendum A).

EBMUD Permit Number and Expiration Date – completed by EBMUD.

Permit Holder Applicant Contract Information - Enter the applicant’s business contact information.

Billing Contact Information – Enter the billing contact information.

Reference is made to the Wastewater Control Ordinance. The Ordinance may be obtained from our website: http://www.ebmud.com/our-water/wastewater-treatment/wastewater-treatment-mandate/control-ordinance/wastewater-control-ord

Permit Applicant Signature – Enter the name and title of the person signing the application. The person signing the application must be authorized to sign under 40 CFR 403.12(l), and Title V, Section 3 of the Wastewater Control Ordinance. Authorized signatories may include:

1) A responsible corporate officer, such as: a. a president, vice-president, secretary, treasurer, or other person performing similar policy or decision making functions or; b. a manager of one or more manufacturing, production, or operating facilities, if authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures and the manager is authorized to make management decisions which govern the operation of the regulated facility.

2) A general partner or sole proprietor, if the applicant is a partnership or sole proprietorship.

3) A duly authorized representative. The duly authorized representative must be: a. an individual having responsibility for the overall operation of the facility from which the wastewater discharge originates. Examples include plant manager, field superintendent, or environmental manager; and b. authorized in writing by a person described in paragraph (1) or (2). The written authorization must be submitted to the District.

Return the signed original application to:

East Bay Municipal Utility District Resource Recovery Program P.O. Box 24055, MS 702 Oakland, CA 94623-1055

Revised 9/1/2013 Resource Recovery Program RESOURCE RECOVERY PERMIT (NON-HAZARDOUS) P. O. Box 24055, MS 702 Oakland, CA 94623-1055 Page 1 of 2 (510) 287-1336 [email protected] Application Business Name (“Permit Holder”) EBMUD Permit Number Expiration Date EBMUD USE ONLY EBMUD USE ONLY EBMUD USE ONLY Permit Holder-Applicant Contact Information

Contact Name / Title Company

Mailing Address Street Address

City Zip Code Telephone E-Mail Billing Contact Information

Contact Name / Title Company

Mailing Address Street Address

City Zip Code Telephone E-Mail This Non-Hazardous Resource Recovery Permit (“Permit”) is issued to the Permit Holder described above for the delivery of non- hazardous materials to EBMUD’s Main Wastewater Treatment Plant (“WWTP”). The Permit includes all Addenda hereto. MATERIAL ACCEPTANCE Permit Holder must submit a Material Acceptance Agreement (“MAA”, Addendum A) and wastestream-specific analytical results for each proposed wastestream. EBMUD Resource Recovery Program will review the submittal and either approve or not approve the wastestream for receipt at the WWTP. Disposal may not proceed without prior approval from EBMUD. CONDITIONS OF DISCHARGE Permit Holder must comply, and must require its haulers, generators, brokers and contractors to comply, with all of the following conditions at all times: 1. Discharge ONLY material for which the Permit Holder has submitted an MAA, approved by EBMUD. 2. Not dispose of any regulated , regulated PCBs, materials regulated by Toxic Substances Control Act, or hazardous waste as defined by Section 25117 of the California Health and Safety Code or by any other federal, state, or local statute or regulation, to the WWTP. 3. Not dispose of any material that may interfere with WWTP operations. 4. Allow EBMUD staff to conduct random inspections and collect samples at the place of generation and on the truck. 5. Maintain all appropriate and valid county and state permit(s) for hauling material to EBMUD. 6. FOG haulers must maintain current Inedible Kitchen Grease (IKG) registration from California Dept. of Food & Agriculture. 7. Comply with all applicable Cal OSHA requirements, including but not limited to California Code of Regulations, title 8, section 3210(b) relating to driver fall protection. 8. Supply equipment to properly dispose of material (e.g., backup horn alarm safety device and 4-inch male camlock fittings). 9. Dispose of all material at the designated disposal locations as printed on EBMUD-issued receipt. 10. Pay all required fees and charges and comply with all orders issued by the Director of Wastewater. 11. Comply with all other provisions of this Permit and EBMUD’s Wastewater Control Ordinance at all times. INSURANCE REQUIREMENTS Throughout the life of the Permit, Permit Holder must maintain, and must require its haulers, generators, brokers and contractors to maintain, commercial general liability insurance, commercial auto/trucking liability insurance, and workers’ compensation insurance to the extent specified within Addenda B, C, and D hereto. Permit Holder must provide evidence of insurance coverage by completing and submitting the EBMUD certificate forms attached as Addenda B, C and D hereto. Each EBMUD certificate form must be completed and signed by the Permit Holder’s insurance company representative. All changes to insurance coverage must be submitted in writing to, and approved in advance by, EBMUD. DISPOSAL CHARGES The disposal charge for each load is based upon (a) the applicable disposal rate for the material type delivered, and (b) tanker capacity. The disposal rate for each material type is provided within the Wastewater System Schedule of Rates and Charges and Fees adopted by EBMUD’s Board of Directors. All deliveries are charged on the basis of total tanker capacity.

Revised 9/1/2013 Resource Recovery Program RESOURCE RECOVERY PERMIT (NON-HAZARDOUS) P. O. Box 24055, MS 702 Oakland, CA 94623-1055 Page 2 of 2 (510) 287-1336 [email protected] REPORTING REQUIREMENTS Permit Holder must provide, and must require its haulers, generators, brokers and contractors to provide, the following to EBMUD upon request: records, pumping logs, manifests, or analytical results pertaining to the disposal of materials at WWTP. Permit Holder must immediately report, and must require its haulers, generators, brokers and contractors to immediately report, any deviation from the information reported on this Permit or any MAA to the EBMUD Resource Recovery Program, including but not limited to changes to truck size, significant temporary or ongoing changes to the anticipated volume of delivered material, changes to wastewater generation that may affect the characteristics of the delivered material, and changes concerning the presence of constituents of concern or known pollutants in the delivered material. ENFORCEMENT AND PENALTIES Permit Holder is subject to enforcement remedies and penalties in accordance with the EBMUD Wastewater Control Ordinance. EBMUD reserves the right to suspend or revoke a Permit for cause, including past due payments. INDEMNIFICATION I agree to defend, indemnify, and hold harmless EBMUD and its Directors, officers, agents and employees from and against any and all loss, liability, expense, claims, suits, and damages, including attorneys’ fees, arising out of or resulting from Permit Holder’s, its generators’, haulers’, brokers’, associates’, employees’, sub-consultants’, or other agents’ operation or performance under this Permit. WAIVER OF SUBROGATION RIGHTS I agree to waive any and all rights of recovery against EBMUD regardless of the applicability of any insurance proceeds and to require all indemnifying parties to do likewise. All insurance coverage maintained or procured by Permit Holder shall be endorsed to delete the subrogation condition as to EBMUD or must specifically allow all the named insured to waive subrogation prior to a loss. CERTIFICATION I, Permit Holder, acknowledge that I have received and had an opportunity to review this Resource Recovery Permit and its Addenda. I understand that all Addenda hereto are part of this Permit and that their terms are incorporated by reference herein. I understand I am legally responsible for the disposal of material and for complying with EBMUD’s Wastewater Control Ordinance and with all provisions of this Permit. I understand that noncompliance with the Permit or the Wastewater Control Ordinance may subject me to enforcement remedies and penalties, including suspension or revocation of this Permit, in accordance with applicable provisions of the Wastewater Control Ordinance and this Permit. I hereby certify that I will not deliver, or cause to be delivered, any regulated radioactive waste, regulated PCBs, materials regulated by Toxic Substances Control Act, or hazardous waste as defined by Section 25117 of the California Health and Safety Code or by any other federal, state, or local statute or regulation. I understand that EBMUD may refuse to accept deliveries at any time if determined by EBMUD to be necessary to avoid interference with WWTP operations or EBMUD’s compliance with legal requirements. I further understand that I must submit information for EBMUD’s review and approval on a Material Acceptance Agreement (Addendum A) regarding each wastestream I propose to deliver, or cause to be delivered, before any load is delivered to EBMUD. I also agree to maintain insurance coverage at the levels required by the Certificate of Commercial General Liability Insurance (Addendum B), Certificate of Commercial Auto/Trucking Liability (Addendum C) and the Certificate of Workers’ Compensation Insurance (Addendum D) and upon any changes to or expiration of that insurance, to notify the EBMUD Resource Recovery Program. I certify under penalty of law that this document and all attachments hereto were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for known violations. I understand and accept that the Permit may be suspended or revoked if any provision of this Permit is not complied with. I understand and acknowledge that EBMUD may amend this Permit from time to time and that the Permit as amended will supersede this Permit and shall be binding and enforceable against the Permit Holder.

______NAME TITLE ______PERMIT HOLDER - SIGNATURE DATE (TO BE SIGNED BY CHIEF EXECUTIVE OFFICER OR DULY AUTHORIZED REPRESENTATIVE. SEE INSTRUCTIONS.)

AUTHORIZATION The above-named Permit Holder is hereby authorized to dispose non-hazardous material as provided by this Permit, subject to Permit Holder’s compliance with EBMUD’s Wastewater Control Ordinance and with all provisions of this Permit.

______Bennett K. Horenstein, Director of Wastewater Date

Revised 9/1/2013 Resource Recovery Program RESOURCE RECOVERY PERMIT (NON-HAZARDOUS) P. O. Box 24055, MS 702 Addendum A Oakland, CA 94623-1055 (510) 287-1336 [email protected] Material Acceptance Agreement A Material Acceptance Agreement must be completed for each material. Include a complete description of the process generating the material. If applicable, include analytical data and MSDS, along with percentage concentration of constituents of concern within the material. If your Material Acceptance Agreement is approved, a Gate Pass will be sent to you. You may only deliver materials for which you have received a Gate Pass; each delivery must be accompanied by an EBMUD Gate Pass.

I certify that the description of the waste below is a true and accurate representation of the wastewater and any changes to the wastewater described below will be disclosed to the EBMUD Resource Recovery Program for further review of material acceptability.

To be completed by CUSTOMER To be completed by EBMUD

______1) Permit Holder (Company Name) Permit Number

______2) Generator / Site Name Material Description

______3) Site Address Material Type

______4) Material Composition (Ex: liquid, sludge, etc) 5) Estimated Volume (gallons or pounds)

______6) Estimated Delivery Dates (Ex: April 8-16, 2013, or on-going) 7) Delivery Frequency (Ex: M, W, F (3) loads/day)

8) Describe wastewater generation and its known and potential pollutants.

9) Is the wastewater generation subject to Federal Categorical Pretreatment Standards? Yes No  If yes, indicate Federal Categorical regulation 40 CFR ______ If yes, is the wastewater fully compliant with the applicable federal categorical regulations? Yes No

10) P.O. or job number (if desired for your tracking purposes):______

11) Permit Holder Signature (or duly authorized representative):

Print Name and Title Date

Signature of Permit Holder Email Address

Recommendation by R2 Program Manager: ______(For EBMUD Use Only)

COMMENTS (such as volume capacity):

EBMUD Resource Recovery Program Permit Decision: Approved Rejected Expiration Date:

Division Manager Signature: Date:

Revised 9/1/2013 Resource Recovery Program RESOURCE RECOVERY PERMIT P. O. Box 24055, MS 702 Insurance Requirements Oakland, CA 94623-1055 (510) 287-1336 Fax (510) 287-0621 [email protected]

INSURANCE REQUIREMENTS

Listed below are EBMUD’s insurance requirements for the holder of Resource Recovery Permits. The requirements of the insurance program must be maintained by the Permit Holder at all times in order to be in permit compliance. All changes in the Permit Holder’s insurance coverage must be reported to EBMUD in advance of any further load deliveries.

The Permit Holder’s insurance company representatives must complete each of the required forms in their entirety:

Certification of Commercial General Liability Insurance (Addendum B), including the endorsement number and Additional Insured supporting document

Certification of Commercial Auto/Trucking Liability Insurance (Addendum C)

Certification of Worker’s Compensation Insurance (Addendum D)* * Not required if there are no employees; indicate on the form that you are an “owner/operator” or “employee-owned company.”

Revised 9/1/2013 Resource Recovery Program NON-HAZARDOUS RESOURCE RECOVERY PERMIT P. O. Box 24055, MS 702 Oakland, CA 94623-1055 Addendum B (510) 287-1336 Fax (510) 287-1530 [email protected] CERTIFICATE OF COMMERCIAL GENERAL LIABILITY INSURANCE

THIS IS TO CERTIFY TO: East Bay Municipal Utility District (EBMUD) Department: Environmental Services Division Street Address: 375 11th Street, MS 702 Mailing Address: P.O. Box 24055 City, State, Zip: Oakland, CA 94623-0155

THE FOLLOWING DESCRIBED POLICY HAS BEEN ISSUED TO: District Permit Number: (Completed by EBMUD): Insured: Address:

LOCATION AND DESCRIPTION OF PROJECT/AGREEMENT: Trucked non-hazardous waste permitted for disposal at designated EBMUD Wastewater Treatment facilities

TYPE OF INSURANCE: Commercial General Liability Coverage/Endorsements as required by agreement. LIMITS OF LIABILITY: (MINIMUM) $1,000,000/Occurrence, Bodily Injury, Property Damage-General Liability

SELF INSURED RETENTION ($): Aggregate Limits: INSURANCE COMPANY(IES): POLICY NUMBER(S): POLICY TERM: From: To:

THE FOLLOWING COVERAGES OR ENDORSEMENTS ARE INCLUDED IN THE POLICY(IES):

1. The District, its Directors, Officers and Employees are Additional Insureds in the policy(ies) as to work being performed under this agreement. ENDORSEMENT NO.

2. The coverage is Primary and non-contributory to any other applicable insurance carried by the District.

3. The policy(ies) covers waiver of subrogation by the Carrier(s) against the District and its Directors, officers, agents, and employees.

4. The policy(ies) covers contractual liability.

5. The policy(ies) is written on an occurrence basis.

6. The policy(ies) covers District Property in the care, custody, and control of the Contractor.

7. The policy(ies) covers personal injury (libel, slander, and wrongful entry and eviction) liability.

8. The policy(ies) covers products and completed operations.

9. The policy(ies) shall cover pollution liability for claims related to the release or the threatened release of pollutants into the environment arising out of or resulting from Consultant’s performance under this agreement.

10. The policy(ies) will not be canceled nor reduced without 30 days written notice to East Bay Municipal Utility District at the address above.

IT IS HEREBY CERTIFIED that the above policies provide liability insurance as required by the agreement between the East

Bay Municipal Utility District and the insured.

Signed Firm

Address Date Phone

E-mail “This certificate or verification of insurance is not an insurance policy and does not amend, extend, or alter the coverage afforded by the policies listed herein. Notwithstanding any requirement, term or conditions of any contract or other document with respect to which this certificate or verification or insurance may be issued or may pertain, the insurance afforded by the policies described herein is subject to all the terms, exclusions, and conditions of the policies.”

RM 015 • 7/1/13 UF020-30.doc Resource Recovery Program NON-HAZARDOUS RESOURCE RECOVERY PERMIT P. O. Box 24055, MS 702 Addendum C Oakland, CA 94623-1055 (510) 287-1336 Fax (510) 287-1530 [email protected] CERTIFICATE OF COMMERCIAL

AUTO/TRUCKING LIABILITY INSURANCE

THIS IS TO CERTIFY TO: East Bay Municipal Utility District (EBMUD) Department: Environmental Services Division Street Address: 375 11th Street, MS 702 Mailing Address: P.O. Box 24055 City, State, Zip: Oakland, CA 94623-1055

THE FOLLOWING DESCRIBED POLICY HAS BEEN ISSUED TO: District Permit Number: (Completed by EBMUD): Insured: Address:

LOCATION AND DESCRIPTION OF PROJECT/AGREEMENT:

Trucked non-hazardous waste permitted for disposal at designated EBMUD Wastewater Treatment facilities

TYPE OF INSURANCE: Automobile/Trucking Liability: Coverage/Endorsements as required by agreement. LIMITS OF LIABILITY: (MINIMUM) $1,000,000/Occurrence, Bodily Injury, Property Damage- Auto Liability

SELF INSURED RETENTION ($): Aggregate Limits: INSURANCE COMPANY(IES): POLICY NUMBER(S): POLICY TERM: From: To:

THE FOLLOWING COVERAGES OR ENDORSEMENTS ARE INCLUDED IN THE POLICY(IES):

1. The coverage is Primary and non-contributory to any other applicable insurance carried by the District.

2. The policy(ies) covers contractual liability.

3. The policy(ies) covers the use of owned, non-owned, and hired automobiles and trucks.

4. The policy(ies) will not be canceled nor the above coverages/endorsements reduced without 30 days written notice to East Bay Municipal Utility District at the address above.

IT IS HEREBY CERTIFIED that the above policies provide liability insurance as required by the agreement between the East Bay Municipal Utility District and the insured.

Signed Firm

Address Date

Phone

E-mail

“This certificate or verification of insurance is not an insurance policy and does not amend, extend, or alter the coverage afforded by the policies listed herein. Notwithstanding any requirement, term or conditions of any contract or other document with respect to which this certificate or verification or insurance may be issued or may pertain, the insurance afforded by the policies described herein is subject to all the terms, exclusions, and conditions of the policies.”

RM 015 7/1/13 UF020-30.doc Resource Recovery Program NON-HAZARDOUS RESOURCE RECOVERY PERMIT P. O. Box 24055, MS 702 Oakland, CA 94623-1055 Addendum D (510) 287-1336 Fax (510) 287-1530 [email protected] CERTIFICATE OF WORKERS’ COMPENSATION INSURANCE

East Bay Municipal Utility District (EBMUD) THIS IS TO CERTIFY TO: Department: Environmental Services Division Street Address: 375 11th Street, MS 702 Mailing Address: P.O. Box 24055 City, State, Zip: Oakland, CA 94623-0155

THE FOLLOWING DESCRIBED POLICY HAS BEEN ISSUED TO:

District Permit Number: (Completed by EBMUD)

Insured:

Address:

LOCATION AND DESCRIPTION OF PROJECT/AGREEMENT:

Non-hazardous material permitted for disposal at designated EBMUD Wastewater Treatment facilities

TYPE OF INSURANCE: Workers’ Compensation Insurance as required by California State Law.

The Workers’ Compensation Carrier agrees to waive rights of recovery against District regardless of the applicability of any insurance proceeds, and to require all indemnifying parties to do likewise. All Workers’ Compensation coverage maintained or procured by permit Holder shall be endorsed to delete the subrogation condition as to District, or must specifically allow the named insured to waive subrogation prior to a loss.

INSURANCE COMPANY:

POLICY NUMBER:

POLICY TERM: From: To:

The policy will not be canceled nor the above coverage reduced without 30 days written notice to East Bay Municipal Utility District at the address above.

IT IS HEREBY CERTIFIED that the above policies provide liability insurance as required by the agreement between the East Bay Municipal Utility District and the insured.

Date Signed

E-mail: Firm

Phone Address

“This certificate or verification of insurance is not an insurance policy and does not amend, extend, or alter the coverage afforded by the policies listed herein. Notwithstanding any requirement, term or conditions of any contract or other document with respect to which this certificate or verification or insurance may be issued or may pertain, the insurance afforded by the policies described herein is subject to all the terms, exclusions, and conditions of the policies.”

RM-017 • 7/1/13 UF020-29.doc NON-HAZARDOUS RESOURCE RECOVERY PERMIT Addendum E

Resource Recovery Materials Delivery Procedures GENERAL INFORMATION The EBMUD Wastewater Treatment Plant is located at 2020 Wake Avenue, Oakland. The Plant is open 24 hours/day, 7 days/week for routine transactions. Appointments must be scheduled in advance with the Senior Environmental Health and Safety Specialist at 510-986-7835 for non-routine transactions such as receiving an EBMUD-issued truck decal, driver Site Orientation, and submitting a first-load confirmation sample for each new waste stream. HAULING COMPANY, DRIVER AND TANKER REQUIREMENTS 1. All hauling company contact information, driver names, and required insurance certifications must be current and on-file before any deliveries may be made. 2. Charges are based on full tanker capacity. EBMUD staff will affix a decal to each tanker, and that decal number must be presented at the time of the load check-in. 3. Each driver must receive a Site Orientation for each applicable discharge location within the treatment plant; schedule with Staff as above. 4. Tanker discharge line must have a 4-inch male cam lock adaptor and a back-up horn alarm safety device. PLANT HAZARDS 1. The Plant entrance is crossed by a live railroad line. Do not wait or park on the tracks at any time. 2. NO SMOKING. No smoking allowed while on the Plant, as it is a safety hazard due to presence of flammable gases (such as oxygen and methane). 3. During transportation, degradation of the waste material may occur inside the tanker and build up gases that may have immediately dangerous to life and health concentrations present when the driver vents the tanker. Be cautious when venting the tanker for discharge. 4. Infectious materials are present at the Plant and managed in the wastewater treatment process. 5. If the emergency alarm (6 long tones) sounds while at the Plant, call the supervisor at 510-287-1522 (site phone, dial 1522), or contact EBMUD staff for further instructions. 6. Construction activities. When overhead activities are occurring hard hats (available) are required. RULES OF CONDUCT 1. Speed Limit is 10 miles per hour unless otherwise posted. 2. If you find a spill upon arrival, before off-loading report it to EBMUD staff. If no one is at the location, call the supervisor at 510-287-1522 (site phone, dial 1522). Driver is responsible for wash down of own spills. 3. Driver must be in compliance with all OSHA regulations, including fall protection per title 8 CA Code Regulations sections 3210(b) and 5155. Driver must not break the plane of the trailer (i.e., do not put your head inside hatch). Do not stand on tanker without OSHA-specific fall protection. 4. Driver must lock brakes before commencing discharge. 5. Driver must stay with truck/tanker during discharge unless instructed otherwise by District Staff. 6. All waste must be discharged through hose directly to pipe. Do not disconnect site discharge hose from discharge pipe. Do not discharge from the trailer directly to the wash down trench. 7. No exterior truck or trailer washing is permitted. 8. Do not leave any trash or debris at the discharge area. 9. Do not drink or wash hands with wash down water as it is non-potable! 10. Firearms and weapons, as defined in the California Penal Code, are not permitted on EBMUD property except by law enforcement officers. DISCHARGE INSTRUCTIONS 1. Each delivery must be accompanied with the appropriate EBMUD-issued documentation (Gate Pass). 2. Review your ticket issued by the guard to verify all items are correct, sign the ticket, and proceed to the appropriate discharge location (see map printed on ticket). 3. Specifics of receiving location discharge instructions are detailed in the Site Orientation, which is scheduled in advance with the Senior Environmental Health and Safety Specialist. Revised 9/1/2013 Wastewater Control Ordinance

EBMUD's Wastewater Control Ordinance provides legal authority for EBMUD to implement the pretreatment program. The ordinance establishes regulations and charges for the collection, treatment, and disposal of wastewater, as well as penalties for violations. Wastewater Discharge Limits

Some industrial customers of EBMUD may also be subject to federal regulations for specific categories of businesses. These "categorical industries" are subject to additional regulations that include discharge limits (pretreatment standards) for pollutants specific to the category. If a pollutant has both a local limit and federal limit, the more stringent limit is applied. The federal regulations can be viewed on the U.S. EPA website by scrolling down to "Subchapter N - Effluent Guidelines and Standards" and selecting "Parts 400 - 424" or "Parts 425 - 471". EBMUD Local Limits

Arsenic 2 mg/L

Cadmium 1 mg/L

Total Identifiable Chlorinated hydrocarbons (TICH) 0.5 mg/L

Chromium (total) 2 mg/L

Copper 5 mg/L

Cyanide 5 mg/L

Iron 100 mg/L Lead 2 mg/L

Mercury 0.05 mg/L

Nickel 5 mg/L

Oil and Grease 100 mg/L pH not less than 5.5 S.U.

Phenolic compounds 100 mg/L

Silver 1 mg/L

Temperature 150°F

Zinc 5 mg/L mg/L - milligrams per liter S.U. - standard units Total Identifiable Chlorinated Hydrocarbons (TICH) - The sum of the concentrations of all quantifiable values equal to or greater than the detection limit for all chlorinated hydrocarbons identified by EPA Method 624.

EBMUD WASTEWATER DISCHARGE PERMIT STANDARD TERMS AND CONDITIONS

TABLE OF CONTENTS SECTION A. GENERAL PROVISIONS ...... 1 I. DUTY TO COMPLY ...... 1 II. DISCHARGE LOCATION AND PROCESS ...... 1 III. PERMIT RENEWAL ...... 1 IV. PROHIBITED DISCHARGES ...... 1 V. LIMITATIONS ON DISCHARGES ...... 3 VI. DISPOSAL OF HAZARDOUS WASTE ...... 4 VII. CLOSURE PLAN ...... 4 VIII. AVAILABILITY OF PERMIT ...... 5 IX. PAYMENT OF PERMIT FEES AND CHARGES ...... 5 X. CONTINUATION OF EXPIRED PERMITS ...... 5 XI. PERMIT TERMINATION ...... 5 XII. TRANSFER OF PERMIT PROHIBITION ...... 5 XIII. SEVERABILITY ...... 5 XIV. PROPERTY RIGHTS ...... 5 SECTION B. REPORTING AND RECORD KEEPING ...... 5 I. SPILL OR SLUG DISCHARGE NOTIFICATION ...... 5 II. TWENTY-FOUR HOUR VIOLATION REPORTING ...... 6 III. CHANGES IN QUANTITY AND QUALITY OF WASTEWATER ...... 6 IV. UPSET PROVISION ...... 7 V. HAZARDOUS WASTE NOTIFICATION ...... 7 VI. SIGNATURE REQUIREMENT ...... 8 VII. RETENTION OF RECORDS ...... 9 VIII. FALSIFYING INFORMATION ...... 9 SECTION C. MONITORING AND SAMPLING...... 9 I. REPRESENTATIVE SAMPLING ...... 9 II. CHAIN OF CUSTODY ...... 10 III. SAMPLE PRESERVATION AND ANALYTICAL METHODS ...... 10 IV. LABORATORY REPORTS ...... 10 V. ADDITIONAL MONITORING ...... 11 VI. CALIBRATION AND MAINTENANCE OF EQUIPMENT ...... 11 VII. FLOW MEASUREMENTS ...... 11 VIII. TAMPERING WITH EQUIPMENT ...... 11 IX. ACCESS TO FACILITIES ...... 11 SECTION D. ENFORCEMENT AND PENALTIES ...... 11 I. PUBLIC NOTIFICATION OF PERMIT HOLDERS IN SIGNIFICANT NON-COMPLIANCE ...... 11 II. VIOLATIONS OF PERMIT TERMS AND CONDITIONS ...... 11 III. SCHEDULE OF REMEDIAL OR PREVENTIVE MEASURES (COMPLIANCE SCHEDULE) ...... 12 IV. CRIMINAL PENALTIES...... 12 V. CIVIL ENFORCEMENT PENALTIES...... 12 VI. PAYMENT OF FINES AND VIOLATION FEES ...... 12 SECTION E. DEFINITIONS ...... 12

March 2014 Edition 1

SECTION A. GENERAL PROVISIONS

I. Duty to Comply The Permit Holder shall comply with all terms and conditions of the Wastewater Discharge Permit (Permit).

II. Discharge Location and Process The Permit Holder shall discharge wastewater only from the location(s) and process(es) described in the Permit.

III. Permit Renewal The Permit Holder shall submit an application for Permit renewal at least 60 days prior to expiration of the existing Permit.

IV. Prohibited Discharges a. General Prohibition: No Permit Holder shall discharge wastewater into a community sewer which will result in contamination, pollution, or a nuisance.

b. Prohibited Effects: No Permit Holder shall discharge wastewater into a community sewer if it contains substances or has characteristics which, either alone or by interaction with other wastewaters, cause or threaten to cause: (1) Damage to District facilities.

(2) Interference with or impairment of the operation or maintenance of District facilities.

(3) Obstruction of flow in sewers or interceptors.

(4) Danger to life or safety of any person.

(5) Interference with, or overloading of, treatment or disposal processes.

(6) Flammable or explosive conditions at or near District facilities.

(7) Wastewater or any other by-products of the treatment process to be unsuitable for reclamation and reuse, or interfere with any processes for reclamation.

(8) Noxious or malodorous gases or odors at or near District facilities.

(9) Discoloration or any other condition in the quality of the District's treatment plant effluent in such a manner that receiving water quality requirements established by law cannot be met by the District.

March 2014 Edition 1 (10) Conditions at or near District facilities which violate any statute or any rule, regulation, or ordinance of any public agency or State or Federal regulatory body, including the general prohibitions contained in Federal General Pretreatment Regulations.

(11) The presence of toxic gases, fumes, or vapors in quantities injurious to the health and safety of District personnel.

(12) Pass-through of the District’s treatment plant, causing a violation of any requirement of the District’s NPDES permit.

c. Prohibited Substances: No Permit Holder shall discharge the following to a community sewer: (1) Wastewater which is not polluted and meets requirements for and is acceptable for discharge to storm sewers or to receiving waters of the State; provided that the Director may grant permission for the discharge of unpolluted wastewaters which comply with regulations of the public agency owning the community sewer.

(2) Wastewater which creates a fire or explosion hazard including, but not limited to, discharges with a closed cup flashpoint of less than 140° F (60° C) using the test methods specified in 40 CFR 261.21.

(3) Garbage, except ground garbage from residential and commercial premises where food is prepared and consumed.

d. Prohibited Locations: Except for sewer construction and maintenance by public agencies and contractors, no Permit Holder shall discharge any wastewater directly into a manhole or other opening in a community sewer system other than through side sewers approved by the public agency owning the system; provided that the Director may grant permission for such direct discharges, upon written application, at locations approved by the public agency and upon payment of applicable sewage disposal charges to the District.

e. Prohibition on Use of Dilution: Except where expressly authorized to do so by an applicable pretreatment standard or requirement, no Permit Holder shall increase the use of process water, or in any other way attempt to dilute a discharge as a partial or complete substitute for adequate pretreatment to achieve compliance with a pretreatment standard, requirement or discharge limitation. The District may impose mass limitations on Permit Holders which are using dilution to meet applicable Pretreatment Standards or requirements, or in other cases where the imposition of mass limitations is appropriate.

f. Prohibition on Slug Discharges: No Permit Holder shall discharge any pollutant, including oxygen-demanding pollutants, at a flow rate and/or pollutant concentration which causes or threatens to cause interference with the wastewater treatment process. For the purposes of this section, any discharge at a flow rate or concentration which could cause a violation of the prohibited discharge standards or limitations in Sections A.IV and A.V. of this document shall be deemed a slug discharge.

March 2014 Edition 2

g. Bypass Prohibited (1) Bypass of pretreatment equipment and/or discharge points is prohibited and the District may take enforcement action against any Permit Holder for bypass unless:

(i) bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;

(ii) there were no feasible alternatives to the bypass, as described in 40 CFR 403.17(d) and the Permit Holder submits the notifications required in 40 CFR 403.17(c).

(2) The District may approve an anticipated bypass, after considering its adverse effects, if the District determines that it will meet the conditions specified in part g(i) of this prohibition.

h. Discharge of Petroleum or Mineral Oil Causing Pass-through or Interference Prohibited: Notwithstanding the provisions of Section A.V.a., no Permit Holder may discharge petroleum oil, non-biodegradable cutting oil or other products of mineral origin in any amount that causes interference or pass-through.

i. Discharge of Trucked or Hauled Wastes Prohibited: No Permit Holder shall discharge any trucked or otherwise hauled wastes to the community sewer or to any District facilities unless a permit has been issued by the District.

V. Limitations on Discharges a. Wastewater Strength Limits: No Permit Holder shall discharge wastewater from a side sewer into a community sewer if the strength of the wastewater exceeds the following: Arsenic 2 mg/L Cadmium 1 mg/L Chlorinated Hydrocarbons (total identifiable) 0.5 mg/L Chromium (total) 2 mg/L Copper 5 mg/L Cyanide 5 mg/L Iron 100 mg/L Lead 2 mg/L Mercury 0.05 mg/L Nickel 5 mg/L Oil and Grease 100 mg/L pH not less than 5.5 S.U. Phenolic compounds 100 mg/L Silver 1 mg/L Temperature 150(1) ºF Zinc 5 mg/L

(1) 150°F (65.5°C), or any thermal discharge which as a result of temperature and/or volume causes the influent of the wastewater treatment plant to exceed 104°F (40°C)

March 2014 Edition 3

b. Additional Wastewater Strength Limits: Wastewater strength limits for constituents not listed in Section A.V.a. may be established in a wastewater discharge permit based on available treatment technology, existing wastewater conditions in the District's facilities or other factors as determined by the Director. The Director may also establish wastewater strength limits on the wastewater discharge permits at locations within a premises whenever non-process water may dilute the wastewater discharging from side sewers.

c. Best Management Practices. The District may require best management practices (BMPs) as an alternative to numeric limits that are developed to protect the POTW, water quality, and sewage sludge.

d. Quantity and Rate of Flow Limits: No Permit Holder shall discharge wastewater into a community sewer in quantities or at rates of flow which may have an adverse or harmful effect on or overload District facilities or cause excessive or additional District treatment costs. The Director may establish mass discharge limits in wastewater discharge permits to control the quantity and rate of flow of wastewater discharges.

e. Radioactive Limits: No Permit Holder shall discharge or cause to be discharged any radioactive wastewater into a community sewer except when the Permit Holder is authorized to use radioactive material by the Nuclear Regulatory Commission or other governmental agency empowered to regulate the use of radioactive materials and when the wastewater is discharged in strict conformity with current Nuclear Regulatory Commission regulations and recommendations for safe, disposal and in compliance with all rules and regulations of State and local regulatory agencies.

f. Deny or Condition New or Increased Contributions: The Director may deny or condition new or increased contributions of pollutants, or changes in the nature of pollutants, to the District’s wastewater treatment facility by Permit Holders where such contributions do not meet applicable Pretreatment Standards and Requirements or where such contributions would cause the District to violate its NPDES permit.

VI. Disposal of Hazardous Waste The Permit Holder shall handle and dispose of hazardous waste in accordance with all local, state, and federal laws and regulations.

VII. Closure Plan The District may require a Permit Holder who intends to close or cease a regulated process to provide a written Closure Plan. The plan shall include the following four items: a. date of proposed work or production stoppage b. date of proposed final closure (after cleaning and demobilizing activities are complete) c. description of cleaning activities, and d. description of disposal of inventoried process material and waste

March 2014 Edition 4 VIII. Availability of Permit The Permit Holder shall maintain a copy of the current Permit at the permitted site and make the Permit available to both facility and District staff at all times.

IX. Payment of Permit Fees and Charges The Permit Holder shall pay all Permit fees, monitoring and testing charges, and wastewater treatment charges.

X. Continuation of Expired Permits The District may continue the Permit terms and conditions if the Permit expires, until a new Permit is issued.

XI. Permit Termination The District may terminate the Permit for violation of the Permit terms and conditions or for violation of the provisions of EBMUD Wastewater Control Ordinance, unless waived by the Permit.

XII. Transfer of Permit Prohibition The Permit Holder shall not assign or transfer the Permit.

XIII. Severability If any provision of the Permit, EBMUD Wastewater Control Ordinance, or the application thereof to any person or circumstance, is held invalid, the remainder of the Permit or EBMUD Wastewater Control Ordinance, or the application of such provision to other persons or circumstances, shall not be affected thereby.

XIV. Property Rights The issuance of the Permit does not convey to the Permit Holder any property rights of any sort or any exclusive privileges.

SECTION B. REPORTING AND RECORD KEEPING

I. Spill or Slug Discharge Notification Immediately upon discovering any spill or slug discharge to the sanitary sewer, the Permit Holder shall notify EBMUD Environmental Services Division at 510-287-1651 during business hours or 866-403-2683 during non-business hours. The Permit Holder shall submit to the District within five days of the occurrence a formal written notification describing: a. the circumstances of discharge b. what was discharged c. volume of discharge d. duration of discharge including beginning and end times and dates e. corrective actions to prevent recurrence

March 2014 Edition 5 f. whether discharge violates the terms and conditions of the Permit

II. Twenty-Four Hour Violation Reporting a. The Permit Holder shall notify the District within 24 hours of becoming aware of any of the following violations: (1) discharges prohibited by EBMUD Wastewater Control Ordinance, Title II, except where authorized by the Permit (2) exceedence of Categorical Pretreatment Standards (3) exceedence of wastewater discharge limits as established in the Permit (4) bypass of any part of a required pretreatment system b. The Permit Holder shall submit a written report to the District within five days of becoming aware of a violation. The report shall include the following information: (1) the date and time of the violation (2) the cause of the violation (3) a description of the violation, including what was discharged (4) the volume of the discharge (5) the duration of the discharge violation including start and end times and dates (6) analytical results, if available, with chain of custody and other pertinent documentation (7) measures taken to correct the violation (8) measures taken to prevent recurrence c. If analytical results of a sample collected by the Permit Holder indicate a violation, the Permit Holder shall repeat the sampling and analysis, and submit the results to the District within 30 days of becoming aware of the violation, unless: (1) the District samples for the same parameter between the time the Permit Holder performs its initial sampling and the time when the Permit Holder receives the results of the sampling or (2) the District samples the permitted discharge at a frequency of at least once per month Such notification shall not relieve the Permit Holder of any expense, loss, damage, or other liability which may be incurred as a result of damage to the POTW, natural resources, or any other damage to person or property; nor shall such notification relieve the Permit Holder of any fines, penalties, or other liability which may be imposed pursuant to EBMUD Wastewater Control Ordinance.

III. Changes in Quantity and Quality of Wastewater The Permit Holder shall promptly notify the District in advance of any significant change to the quality or volume of the wastewater discharge or any deviation from the Permit terms and conditions.

March 2014 Edition 6 IV. Upset Provision

The Permit Holder can be granted an affirmative defense to an action brought for noncompliance with categorical Pretreatment Standards if the requirements of paragraph (a) are met.

a. Conditions necessary for a demonstration of upset: A Permit Holder who wishes to establish the affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant evidence that:

(1) An Upset occurred and the Permit Holder can identify the cause(s) of the upset;

(2) The facility was at the time being operated in a prudent and workman-like manner and in compliance with applicable operation and maintenance procedures;

(3) The Permit Holder has submitted the following information to the District within 24 hours of becoming aware of the upset (if this information is provided orally, a written submission must be provided within five days):

(i) A description of the discharge and cause of noncompliance;

(ii) The period of noncompliance, including exact dates and times or, if not corrected, the anticipated time the noncompliance is expected to continue;

(iii) Steps being taken and/or planned to reduce, eliminate and prevent recurrence of the noncompliance.

b. Burden of proof: In any enforcement proceeding the Permit Holder seeking to establish the occurrence of an upset shall have the burden of proof.

c. Reviewability of District’s consideration of claims of upset. In the usual exercise of prosecutorial discretion, District staff will review any claims that non-compliance was caused by an Upset. No determinations made in the course of the review constitute final District action subject to judicial review. The Permit Holder will have the opportunity for a judicial determination on any claim of upset only in an enforcement action brought for noncompliance with categorical Pretreatment Standards.

d. Permit Holder responsibility in case of upset. The Permit Holder shall control production or all Discharges to the extent necessary to maintain compliance with categorical Pretreatment Standards upon reduction, loss, or failure of its treatment facility until the facility is restored or an alternative method of treatment is provided. This requirement applies in the situation where, among other things, the primary source of power of the treatment facility is reduced, lost or fails.

V. Hazardous Waste Notification The Permit Holder shall submit to the District a written notification in accordance with 40 CFR 403.12(p)(1) and (3), unless exempted under the provisions of 40 CFR 403.12(p)(2), of

March 2014 Edition 7 any discharge, which, if otherwise disposed of, would be a hazardous waste under 40 CFR 261. Pollutants reported as part of the Self-Monitoring Reporting Requirements are not subject to this notification requirement.

VI. Signature Requirement a. All required reports, permit applications, self-monitoring reports, violation response reports, and periodic reports on continued compliance, shall be signed: (1) by a responsible corporate officer, if the Permit Holder submitting the reports is a corporation. For the purpose of this paragraph, a responsible corporate officer means: (i) a president, secretary, treasurer, or vice president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision-making functions for the corporation; or (ii) the manager of one or more manufacturing, production, or operation facilities employing more than 250 persons or having gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars), if authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures. (2) by a general partner or proprietor if the Permit Holder submitting the reports is a partnership or sole proprietorship, respectively; (3) by a duly authorized representative of the individual designated in paragraph (1) or (2) of this section if: (i) The authorization is made in writing by the individual designated in paragraph (1) or (2); (ii) The authorization specifies either an individual or a position having responsibility for the overall operation of the facility from which the industrial discharge originates, such as the position of plant manager, operator of a well, or well field superintendent, or a position of equivalent responsibility, or having overall responsibility for environmental matters for the company; and (iii) The written authorization is submitted to the District. (4) If an authorization under paragraph (a)(3) of this section is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, or overall responsibility for environmental matters for the company, a new authorization satisfying the requirements of paragraph (a)(3) of this section must be submitted to the District prior to or together with any reports to be signed by an authorized representative. b. Reports and applications must include the following certification statement: "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly

March 2014 Edition 8 responsible for gathering information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.”

VII. Retention of Records a. The Permit Holder shall retain all records and relevant correspondence, including but not limited to: (1) all records used to complete the Permit Application (2) all information resulting from any monitoring activities (3) discharge reports (4) self-monitoring data (5) pretreatment system process control logs, including calibration and maintenance records, and original strip chart recordings of continuous monitoring instrumentation (6) documentation of compliance with BMP requirements b. The Permit Holder shall make all retained records available for inspection and copying by a duly authorized representative of the District or any other governmental entity having jurisdiction. c. The Permit Holder shall retain all records for a minimum of 3 years.

VIII. Falsifying Information Knowingly making any false statement on any report or other document required by the Permit or knowingly rendering any monitoring device or method inaccurate, is a crime, and may result in administrative, civil and criminal enforcement action.

SECTION C. MONITORING AND SAMPLING

I. Representative Sampling Samples and measurements taken, as required in the Permit or those submitted with the application, shall be representative of the volume and nature of the monitored discharge. The Permit may require that a sample be representative of certain, specific, discharge periods. All data submitted in reports or applications shall be representative of conditions during the reporting period. Detection limits shall be sufficient to determine compliance with the Permit terms and conditions.

March 2014 Edition 9 II. Chain of Custody a. The Permit Holder shall submit a Chain of Custody record for each sample that documents the following: (1) the location, the type of sample(s) (grab or composite), the date(s) and time, or span of time the sample was taken (2) the number of containers, and type (glass, plastic, vial, etc.) (3) preservation techniques (ice, refrigeration at 4oC, chemicals added, etc.) (4) sample collector’s name, legibly written (5) sample ID number (to cross-reference with the sample ID number on the Laboratory results) (6) all persons handling the sample and the individual receiving the sample at the laboratory, including their signature, printed name, company, date and time the sample was relinquished and accepted b. The Permit Holder shall ensure that samples transported or handled by a courier, delivery service (public or private) or shipper shall include the company or individual's name, and the method of packaging the samples, on the Chain of Custody record. c. The Permit Holder shall show all sample analyses performed in the field on the Chain of Custody record (e.g. pH - field test). d. The District may require resampling of the wastewater for an incomplete or incorrect Chain of Custody record.

III. Sample Preservation and Analytical Methods Unless the Permit requires otherwise, the Permit Holder shall use sampling methods, sample preservation, and analytical methods for each parameter in accordance with applicable sections of: a. EBMUD Table of Approved Test Methods (see Appendix) b. Standard Methods of Water and Wastewater Analysis, Edition used in the EBMUD Table of Approved Test Methods (see Appendix) c. EPA 40 CFR Part 136, Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean Water Act, latest edition

IV. Laboratory Reports The Permit Holder shall use a laboratory certified by the California Department of Health Services for each sample analysis required by the Permit. The laboratory report for each sample shall include: a. the name and address of the laboratory performing the analyses b. sample ID number (to cross reference with the sample ID number on the Chain of Custody) c. the analytical result(s) d. the date of sampling, the date the sample(s) was received at the laboratory, and the date of analysis

March 2014 Edition 10 e. the Standard Method or EPA Method used for analyses f. the detection limit g. the signature and title of an authorized representative of the Laboratory, who reviewed the laboratory results

V. Additional Monitoring If the Permit Holder monitors any pollutant at the appropriate sampling location (compliance point) more frequently than required by the Permit, using procedures and test methods specified in the Permit, the results of such monitoring shall be included in the subsequent self-monitoring report.

VI. Calibration and Maintenance of Equipment The Permit Holder shall calibrate, inspect, and maintain all flow measuring, discharge sampling, monitoring, and pretreatment equipment to ensure the equipment accuracy and reliability.

VII. Flow Measurements The Permit Holder shall use appropriate flow measurement devices and methods when required by the District. Flow measurement devices and methods are subject to approval by the District.

VIII. Tampering with Equipment The Permit Holder shall not tamper with monitoring equipment or treatment units.

IX. Access to Facilities The Permit Holder shall provide access to facilities by District staff in order to ascertain compliance with EBMUD Wastewater Control Ordinance and Permit.

SECTION D. ENFORCEMENT AND PENALTIES

I. Public Notification of Permit Holders in Significant Non-Compliance At an interval of not less than once per year, the District will publish the identities of any Permit Holder(s) which is (are) found to be in significant non-compliance of any national pretreatment standard, discharge limitation or prohibition, Permit terms and conditions, or any other requirement of these regulations. The definition of significant non-compliance shall be as specified in Section E. The publication shall occur in a newspaper of general circulation that provides meaningful public notice within the service area of the District.

II. Violations of Permit Terms and Conditions The Permit Holder shall be subject to District actions for failure to comply with the Permit terms and conditions. The actions may include violation follow-up inspections and fees, issuance of Cease and Desist Orders, Administrative Civil Liability penalties, and other actions as authorized by EBMUD Wastewater Control Ordinance, Title VI.

March 2014 Edition 11 III. Schedule of Remedial or Preventive Measures (Compliance Schedule) When the District finds that a discharge of wastewater is taking place or threatening to take place that violates or will violate prohibitions or limits prescribed by EBMUD Wastewater Control Ordinance, or wastewater source control requirements or the provisions of a wastewater discharge permit, the District may require the Permit Holder to submit for approval, a detailed time schedule of specific actions the Permit Holder shall take in order to correct or prevent a violation of requirements. Such schedule shall not extend the compliance date beyond applicable federal deadlines.

IV. Criminal Penalties. a. A Permit Holder who intentionally discharges wastewater in any manner, in violation of any order issued by the Director, which results in contamination, pollution, or a nuisance, as defined in EBMUD Wastewater Control Ordinance, is guilty of a misdemeanor and may be subject to criminal penalties of not more than $1,000 per day for each such violation, including, but not limited to, any violation of pretreatment standards or requirements. b. A Permit Holder who knowingly makes any false statement or representation in any record, report, plan, or other document filed with the District, or who falsifies, tampers with, or knowingly renders inaccurate any monitoring device or method required by the District, shall be punished by a fine of not more than twenty-five thousand dollars ($25,000) or by imprisonment in the county jail for not more than six months, or by both.

V. Civil Enforcement Penalties. a. A Permit Holder who fails to comply with any order issued by the District, including orders related to pretreatment standards or requirements, shall be subject to a civil penalty not to exceed ten thousand dollars ($10,000) for each day in which the discharge, violation, or refusal occurs. b. A Permit Holder who intentionally or negligently violates any order issued by the District for violation of rules regulating or prohibiting discharge of wastewater which causes or threatens to cause a condition of contamination, pollution or nuisance, as defined in this article, may be liable civilly in a sum not to exceed twenty-five thousand dollars ($25,000) for each day in which the violation occurs. The attorney of the District, upon request of the Board of Directors of the District, shall petition the Superior Court to impose, assess, and recover such sums.

VI. Payment of Fines and Violation Fees The Permit Holder shall pay the District any fines and violation fees that are assessed.

SECTION E. DEFINITIONS

BMPs - Best Management Practices are guidelines and procedures that reduce the generation of pollutants or hazardous wastes, and prevent them from being released to the environment. BMPs can include a schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to implement the prohibitions listed in Title II, Section 2 of EBMUD Wastewater Control Ordinance. BMPs also include treatment requirements, operating

March 2014 Edition 12 procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal , or drainage from raw materials storage. Bypass - The intentional diversion of wastestreams from any portion of a treatment facility. Chain of Custody - A Chain-of-Custody is a legal record of each person who had possession of a sample. It is included with an analytical report. Combined Wastestream Formula - Formula defined in 40 CFR 403.6(e) Director - Director of the Wastewater Department of the East Bay Municipal Utility District, or his/her designated representative. Discharge Minimization Permit - Mandatory permit that includes monitoring and reporting requirements. District - East Bay Municipal Utility District. Hazardous Waste - Listed and characterized wastes under Section 3001 of the Resource Conservation and Recovery Act, as described in the Code of Federal Regulations (40 CFR Part 261) or as defined in California Health and Safety Code Section 25117. VII. Permit Holder - Any individual, partnership, firm, association, corporation, or public agency issued a Wastewater Discharge Permit. Pollution Prevention Permits - Mandatory permits that contain best management practices to reduce or eliminate pollutants discharged to the sanitary sewer. POTW - Publicly Owned Treatment Works, e.g., EBMUD SD-1. A treatment works owned by a state or municipality. This includes any devices, and systems used in the storage, treatment, recycling, and reclamation of municipal sewage or industrial wastes of a liquid nature. [Ref. 40 Code of Federal Regulations, 403.3(o)]. It includes the District’s main wastewater treatment plant and wet-weather treatment facilities, and also includes interceptors and associated pump stations that convey wastewater to the main wastewater treatment plant and wet-weather treatment facilities. Pretreatment Program - A program administered by a POTW that meets the criteria established in EPA 40 CFR Part 403.8, 403.9 and 403.11. Prohibition - Prohibited wastewater discharges as defined in EPA 40 CFR Part 403.5 or EBMUD Wastewater Control Ordinance, Title I, Section 5, and Title II, Section 2. Regional Water Quality Control Board - The California Regional Water Quality Control Board, San Francisco Bay Region, is the approval authority for the District’s Pretreatment Program. Sample - A portion of wastewater that is representative of a larger volume of wastewater being discharged. The two types of samples are: a. Grab - an individual sample collected in a short period of time not exceeding fifteen minutes. b. Composite - a sample consisting of a number of discrete aliquots combined into a single sample, representative of a period of time. SD-1 - EBMUD Special District No. 1, a district established to provide treatment of wastewater from the following East Bay Communities: Alameda, Albany, Berkeley, Emeryville, Oakland,

March 2014 Edition 13 Piedmont, and the Stege Sanitary District that includes the City of El Cerrito, the Richmond Annex, and the Kensington area. [Ref. MUD Act, Division 6, Chapter 8, Section 13451]. Significant Noncompliance - A significant industrial user (or any IU which violates paragraphs c, d or h below) is in significant noncompliance with applicable pretreatment requirements if any violation meets one or more of the following criteria: a. Chronic violations of wastewater discharge limits, defined as those in which sixty-six percent or more of all of the measurements taken during a six-month period exceed (by any magnitude) a numeric pretreatment standard or requirement, including instantaneous limits, as defined by 40 CFR 403.3(1) b. Technical Review Criteria (TRC) violations, defined as those in which thirty-three percent or more of all of the measurements for each pollutant parameter taken during a six-month period are equal to or exceed the product numeric pretreatment standard ore requirement including instantaneous limits, as defined by 40 CFR 403.3(1) multiplied by the applicable TRC. (1) TRC = 1.4 for BOD, TSS, fats, oil and grease (2) TRC = 1.2 for all other pollutants (except pH) c. Any other violations of a pretreatment standard or requirement as defined by 40 CFR 403.3(1) (daily maximum, long-term average, instantaneous limit, or narrative standard) that the District determines has caused, alone or in combination with other discharges, interference or pass through (including endangering the health of POTW personnel or the general public). d. Any discharge of a pollutant that has caused imminent endangerment to human health, welfare or to the environment or has resulted in the POTW’s exercise of emergency authority to halt or prevent such a discharge. e. Failure to meet, within 90 days after the due date, a compliance schedule milestone contained in this Permit or Manager's order for starting construction, completing construction, or attaining final compliance. f. Failure to provide, within 45 days after the due date, required reports such as baseline monitoring reports, 90-day compliance reports, self-monitoring reports, and reports on compliance with compliance schedules. g. Failure to accurately report noncompliance. h. Any other violation or group of violations, which the District determines, will adversely affect the operation or implementation of the local pretreatment program. Slug Load or Slug Discharge - Any discharge at a flow rate or concentration, which could cause a violation of the prohibited discharge standards in Section 2.2 of EBMUD Wastewater Control Ordinance. A slug discharge is any discharge of a non-routine, episodic nature, including but not limited to an accidental spill or non-customary batch discharge which has a reasonable potential to cause interference or pass through, or in any other way violate the District’s regulations, local limits or permit conditions. Spill - An accidental discharge of a substance that may pose an environmental, public health, or wastewater quality concern.

March 2014 Edition 14 Total Identifiable Chlorinated Hydrocarbons (TICH) - The sum of the concentrations of all quantifiable values equal to or greater than the detection limit for all chlorinated hydrocarbons identified by EPA Method 624. Total Metals - The sum of the concentrations of copper, chromium, nickel, and zinc (40 CFR 413.02,e) Total Toxic Organics (TTO) - The sum of the concentrations of specific toxic organic compounds found in the wastewater discharge at a concentration greater than 10 ug/L. Each categorical standard (40 CFR 405 - 471) lists the specific toxic organic compounds that are to be included in the summation.

Upset - An exceptional incident in which there is unintentional and temporary noncompliance with categorical Pretreatment Standards because of factors beyond the reasonable control of the Permit Holder. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation, as defined in 40 CFR 403.16.

Wastewater Discharge Limits - A wastewater discharge limit is the maximum concentration of a pollutant allowed to be discharged during a specific period of time. Wastewater discharge limits may be of three types: Monthly Average, 4-day Average, and Maximum. Monthly Average - The maximum arithmetic average value of all samples taken in a calendar month. 4-day Average - The maximum arithmetic average value of four consecutive samples taken on different days. Maximum - The maximum concentration of a pollutant allowed to be discharged at any time, as determined from the analysis of a grab or composite sample.

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March 2014 Edition 15 APPENDIX -- EBMUD Table of Approved Test Methods

The District has approved the following test methods for wastewater analysis. These methods are generally used for District and self-monitoring. Other methods not listed in this table may be required. Refer to the self-monitoring section of your wastewater discharge permit for required specific test methods. Deviations from Approved Test Methods: (1) Equivalent EPA methods for water and wastewater may also be acceptable; however, the permit holder should contact their EBMUD Representative for approval. Also, any alternative methods should have detection limits that are lower than the corresponding wastewater strength limits listed in EBMUD’s Wastewater Control Ordinance (2) In case listed analytical methods change and no longer approved, the permit holder should contact their EBMUD Representative for updated information regarding approved methods.

Parameter Preservative Maximum Hold EPA Method STD Methods1 Time 206.5 3114 B Arsenic (Total) HNO3 to pH<2 6 months Cool to 4oC 200.7 3120 B 200.8 200.7 3113 B Cadmium (Total) HNO3 to pH<2 6 months Cool to 4oC 200.8 3120 B

CODF, using a Whatman Preserve with H2SO4 to pH 28 days 410.4 v2.0 5220 D 934AH Glass Microfiber <2 filter, or equivalent Cool to 4oC 200.7 3113 B Chromium (Total) HNO3 to pH<2 6 months Cool to 4oC 200.8 3120 B 200.7 3113 B Copper (Total) HNO3 to pH<2 6 months Cool to 4oC 200.8 3120 B Cyanide (Amenable) NaOH to pH>12 14 days NA 4500-CN G Ascorbic acid if Cl2 present Cool to 4oC Cyanide (Total) NaOH to pH>12, ascorbic 14 days 335.4 4500-CN B-E acid if Cl2 present Cool to 4oC 200.7 3113 B Iron (Total) HNO3 to pH<2 6 months Cool to 4oC 3120 B 200.7 3113 B Lead (Total) HNO3 to pH<2 6 months Cool to 4oC 200.8 3120 B

Mercury (Total) HNO3 to pH<2 28 days 245.1 3112 B Cool to 4oC 245.2 245.7 200.7 3113 B Nickel (Total) HNO3 to pH<2 6 months Cool to 4oC 200.8 3120 B

Oil & Grease (Total) HCl or H2SO4 to pH<2 28 days 1664 HEM Oil & Grease (HC) Cool to 4oC 1664 HEM- SGT

Phenolic Compounds H2SO4 to pH<2 28 days 420.1 5530-D

March 2014 Edition i Parameter Preservative Maximum Hold EPA Method STD Methods1 Time o Cool to 4 C 420.4

pH, Hydrogen Ion None Analyze NA 4500-H+ B Immediately 200.7 3113 B Silver (Total) HNO3 to pH<2 6 months Cool to 4oC 200.8 3120 B Temperature (oC) None Analyze NA 2550 B immediately Total Suspended Solids Cool to 4oC 7 days NA 2540D TSS, filtered with Whatman 934 AH Glass Microfiber filter, or equivalent 289.2 Zinc (Total) HNO3 to pH<2 6 months Cool to 4oC 200.7 200.8 Organochlorine Pesticides Cool to 4oC 7 days until 608 6630B & C & Poly Chlorinated extraction; 40 Biphenyls (PCBs) days after extraction 2 Purgeable Organics HCI to pH <2, add 14 days 624 (BTEX) ascorbic acid if Cl2 is 8021 B present. VOA vials, No 8260 B headspace. Cool to 4oC Semi-Volatile Organics Cool to 4oC 7 days until 625 (BNA's) extraction; 40 days after extraction Total Identifiable HCl to pH<2, add ascorbic 14 days 624 Chlorinated Hydrocarbon acid if Cl2 is present. 8260 B (Volatile Organics) VOA vials, no headspace. Cool to 4oC

Notes 1 Standard Methods for the Examination of Water and Wastewater, American Water Works Association 2 EPA Method 624 table in 40CFR Part 136 does not list xylenes; however, EBMUD may accept xylenes detected by this method.

March 2014 Edition ii Wastewater Rate Schedule - Effective July 1, 2016 EBMUD provides wastewater treatment services for Alameda, Albany, Berkeley, El Cerrito, Emeryville, Kensington, Oakland, Piedmont, and parts of Richmond. The wastewater treatment charges are detailed below and are based on the type of customer, and on wastewater strength and volume.

 Single-family Charges  Multiple Dwelling Charges  Non-Residential Charges  Permit Program Fees  Resource Recovery Fees  Wastewater Capacity Fee  Wet Weather Facilities Charge  SF Bay Commercial Pollution Prevention Fee  SF Bay Residential Pollution Prevention Fee

Estimate your monthly wastewater bill using our wastewater rate calculator. Single Family Monthly Charges (BCC 8800)

A. Service charge $5.55

B. SF Bay Residential Pollution Prevention Fee $0.20

C. Strength charge $7.64

D. Flow charge of $1.09 per unit* of flow up to a maximum of 9 units of wastewater discharge per month. Maximum Flow Charge $9.81 E. Total Single Family Charge (A+B+C+D) Maximum Monthly Charge $23.20

*1 flow unit = 1 Ccf = 100 cubic feet = 748 gallons Multiple Dwelling (2-4 Units) Monthly Charges (BCC 6514)

A. Service charge (per account) $5.55

B. SF Bay Residential Pollution Prevention Fee (per dwelling unit) $0.20

C. Strength charge (per dwelling unit) $7.64

D. Flow charge of $1.09 per unit* of flow per month up to a maximum of 9 units per dwelling unit Maximum Flow Charge (Duplex) $19.62 Maximum Flow Charge (Triplex) $29.43 Maximum Flow Charge (Fourplex) $39.24

E. Total Multiple Dwelling Charge (A+B+C+D) Maximum Monthly Charge (Duplex) $40.85 Maximum Monthly Charge (Triplex) $58.50 Maximum Monthly Charge (Fourplex) $76.15

*1 flow unit = 1 Ccf = 100 cubic feet = 748 gallons

Non-Residential Treatment Charges Non-residential users are assigned typical waste strengths by business classification code (BCC) for Chemical Oxygen Demand, Filtered (CODF) and Total Suspended Solids (TSS).

Flow $1.085 per unit of flow*

CODF $0.321 per pound

TSS $0.469 per pound

The table below presents the BCC rates. Users whose wastewater strengths exceed the assigned strengths are required to obtain wastewater discharge permits under EBMUD's permit program.

A. Monthly service charge per meter $5.55

B. Monthly SF Bay Commercial Pollution Prevention $5.48 Fee ** (Monthly P2 Fee for BCC 6513 is $1.00)

C. Strength Charge

BCC Business Classification Rate Per Strength Unit*

CODF TSS (mg/l) (mg/l)

2010 Meat Products $7.12 2,400 420

2011 Slaughterhouses $7.19 1,000 1,400

2020 Dairy Product Processing $5.64 1,700 390

2030 Fruit and Vegetable Processing $4.58 1,200 370

2040 Grain Mills $4.70 680 770

2050 Bakeries (including pastries) $8.00 1,700 1,200

2060 Sugar Processing $4.38 1,600 30

2077 Rendering Tallow $14.34 1,500 3,500

2080 Beverage Manufacturing and Bottling $3.38 960 130

2090 Specialty Foods Manufacturing $14.50 4,800 1,300

2600 Pulp and Paper Products $4.04 540 640

2810 Inorganic Chemicals Manufacturing $5.38 100 1,400 2820 Synthetic Material Manufacturing $1.24 30 30

2830 Drug Manufacturing $2.52 620 70

2840 Cleaning and Sanitation Products $5.11 1,400 420

2850 Paint Manufacturing $9.99 2,400 1,400

2893 Ink and Pigment Manufacturing $3.52 1,100 80

3110 Leather Tanning and Finishing $13.66 3,800 1,700

3200 Earthenware Manufacturing $2.93 120 550

3300 Primary Metals Manufacturing $2.33 90 360

3400 Metal Products Fabricating $1.33 80 30

3410 Drum and Barrel Manufacturing $13.80 4,300 1,400

3470 Metal Coating $1.45 80 70

4500 Air Transportation $1.88 250 100

5812*** Food Service Establishments $4.95 560 940

6513** Apartment Buildings $2.48 190 270 (5 or more units) 7000 Hotels, Motels with Food Service $3.59 260 680

7210 Commercial Laundries $3.13 570 310

7215 Coin-Operated Laundromats $2.36 360 190

7218 Industrial Laundries $8.65 2,700 740

7300 Laboratories $1.70 190 80

7542 Automobile Washing and Polishing $2.26 290 200

8060 Hospitals $2.19 160 270

8200 Schools $1.60 140 80

All Other BCCs $2.48 190 270

Minimum Monthly Treatment Charge

6513** Apartment Buildings (5 or more units) $43.75

All Other BCCs $5.55

D. Total Non-Residential Charge = A +B**+C***

* Treatment charge per unit of flow: 1 flow unit = 1 Ccf = 100 cubic feet = 748 gallons ** BCC 6513 is assessed the monthly SF Bay Residential Pollution Prevention Fee Multi-Use Facility Rates effective July 1, 2016 For any accounts coded with an SD rate 5, if a Multi-Use or MT code is present, then the account will be billed at the metered rate effective 7/1/16 for the MT code as follows:

MT Code Charge per CCUFT

A $2.48

B $2.73

C $2.97

D $3.22

E $3.47

F $3.72

G $3.96

H $4.21

I $4.46

J $4.70

K $2.48 MT Code Charge per CCUFT

L $3.03

M $3.58

N $4.14

O $4.69

P $5.24

Q $5.79

R $6.34

S $6.90

T $7.45

Minimum strength and service charges still apply for multi-use facility accounts.

Wastewater Discharge Permit Program Fees The following fees apply to new and existing permit holders under the provisions of the EBMUD Wastewater Control Ordinance.

A. Discharge Minimization Permit (i.e. industrial, groundwater, gas station remediation, etc.)

Annual Permit Fee $2,450

Monitoring Fee $1,300

Laboratory Testing Fees based on analysis

B. Flow Estimation Annual Permit Fee $920

C. Special Discharge Permit Fee $995

FY16-17 Rates for Resource Recovery Material Treatment(1)

Material Type Rate(2)

Septage $0.07/gal

Fats, Oil and Grease $0.08/gal

Process Water $0.05/gal Material Type Rate(2)

Gray Water Variable with Total Dissolved Solids (TDS) $0.04/gal 0-100,000 mg/L TDS $0.08/gal > 100,000 mg/L TDS

Sludge Variable with % Total Solids (TS) $0.05/gal up to 3% TS plus $0.005/gal per % TS for TS between 3% to 20%

Liquid Organic Material $0.04/gal

Protein Material $0.08/gal

Solid Organic Material $30/ton - $65/ton(3)

Permit Fee $300 (per year)

(1) Payment collection for all Resource Recovery accounts shall follow the payment collection provisions contained in Section 13, Payment of Bills in the Regulations Governing Water Service to the Customers of EBMUD and Items C and K, Returned Payment Charges and Late Payment Penalty and Interest, in Schedule C of the Water System Rates and Charges.

(2)For special accommodations, additional charges for actual personnel costs, equipment costs, and lab costs associated with the special accommodation will apply. Special accommodations include services provided by the District above and beyond what is typical, such as evaluation and testing of a unique material stream, special equipment to receive and process material, accommodations for large volumes, special off-hour deliveries that require additional staff support, or special treatment requirements.

(3)Based on treatment costs (residual solids dewatering and disposal), gas production, volumes and other costs or benefits to the District.

Wastewater Capacity Fee A capacity fee is assessed to each new customer or each existing customer who increases demand for treatment processing on or after July 1, 1984, measured in wastewater volume and strength. The capacity fee is a one-time charge based on the maximum monthly wastewater volume and average strength calculated at the following rates. The Wastewater Capacity Fee for a Single Family residence (BCC 8800) is $2,150. The fees for 2-4 units (BCC 6514) are $2,150 times the number of dwelling units.

Flow (volume) $159.07/unit*/month

CODF $46.88/pound/month

TSS $63.10/pound/month

*1 flow unit = 1 Ccf = 100 cubic feet = 748 gallons Wet Weather Facilities Charge The Wet Weather Facilities charge is to help pay for the $240 million Wet Weather Program mandated by the U.S. Environmental Protection Agency to improve the District's capacity to collect and treat all sewer flows during rainy weather. The charge is not a tax but is being collected on property tax bills to separate the special Wet Weather Facilities Charge from regular charges. For public agencies - who do not receive tax bills - the charge appears as an additional line item on their EBMUD water bill.

Small Lot (0-5,000 sq ft) $94.10/year

Medium Lot (5,001-10,000 sq ft) $147.00/year

Large Lot (>10,000 sq ft) $336.00/year

SF Bay Commercial Pollution Prevention Fee All non-residential customers in EBMUD's Wastewater System are billed a monthly SF Bay Commercial Pollution Prevention fee to fund the EBMUD Pollution Prevention Program. The monthly fee is $5.48. A separate fee is applicable to BCC 8800, BCC 6513, and BCC 6514, the residential BCCs, as noted below. SF Bay Residential Pollution Prevention Fee All residential customers in EBMUD's Wastewater System, including BCC 8800, BCC 6513 and BCC 6514, are billed a monthly SF Bay Residential Pollution Prevention fee to fund programs to reduce residential pollutant loadings to the treatment plant and San Francisco Bay. The monthly fee is $0.20/month per dwelling unit up to five dwelling units.

Exhibit A MSS Participant Assessment & Contamination Control Procedures for Food Waste Delivered to CMSA

Participant Assessment: 1) Potential participants for the food waste program include restaurants, assisted living facilities, grocery stores, schools, hospitals, and any other business or institutional facility that has food service. 2) Participants will be prescreened by MSS staff prior to enrollment. Management control over kitchen staff will be assessed and is key to the success of the program. Program Requirements: 1) Source separation is required. Program participants will be required to separate acceptable food waste from non-acceptable materials and place the acceptable materials in designated containers. The ideal candidate for the program will have significant pre-served food waste available for collection and may be permitted to include post consumer food waste if adequate practices are established to control contamination. a. Acceptable food waste includes: Fruits, Vegetables, Meat, Seafood, Small Bones, Dairy, Eggs, Breads, Pastas, Sauces, Cooking Oil, Grease, Tea Bags, Coffee Grounds and Paper Filters. 2) Zero Tolerance Rule for Contamination. The program will clearly establish zero tolerance for any unacceptable waste materials. Unacceptable waste materials considered contamination by this program includes:, Styrofoam, all plastics including bags, glass, metal, liquids, paper, cardboard, wood, yard waste, and all other non-food waste materials. 3) Once the commercial entity has proven its ability to consistently deliver clean pre- consumer food scraps, the method of handling post-served/post-consumer food scraps will be reviewed to determine if this material can be included in the collection program..

Training: Training will be conducted for all kitchen staff describing participation procedures, acceptable food scrap materials, and zero tolerance for contamination. 1) Training will be conducted in the predominant language spoken by kitchen staff. 2) Once participation has started, follow-up visits will be scheduled at regular intervals to fewer than three per year. 3) If deficiencies are noted, retraining of kitchen and management staff will be conducted by MSS.

Containers/Signage and Training Materials: Each participant will receive the following program materials and services: 1) An appropriate number of 23 gallon “Slim Jim” collection containers for indoor use.

Agreement Between Marin Sanitary Service, Inc. and the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services: Exhibit A

2) Clearly labeled curbside collection containers (32 and/or 64 gallon carts or 1-2 yard boxes) for outdoor storage of food scraps. 3) Outreach and training materials to instruct staff in proper participation procedures and maintain awareness: a. 11" x 17" posters displaying approved and prohibited food scraps for placement on walls. b. 8" x 11" signs displaying approved and prohibited food scraps for placement on walls or collection containers. c. 5" x 10" “bumper sticker” signage for differentiating food collection containers from refuse containers. d. Participation decal to display for public awareness. Signs will be distributed in sufficient numbers to serve needs of new participants. Additional posters and signs will be provided upon request.

Oversight: 1) MSS Driver may check contents of collection carts regularly. In instances where contaminants are detected, food scraps will be left uncollected and a notice of non- collection left on the cart. The restaurant name and date will be recorded for follow-up by route supervisor/outreach coordinator. 2) Outreach staff may conduct spot checks of participants to assess participation, sufficient number of collection containers, fill levels of containers, and contamination. Outreach staff may use these spot check opportunities to update restaurants on procedural changes or other important information. 3) Repeated contamination incidents and/or or inability by management to correct the identified problem(s) may result in removal from program and a charge to have the contaminated materials removed.

Agreement Between Marin Sanitary Service, Inc. and the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services: Exhibit A

Exhibit B Food Waste Participant Agreement

Thank you for your interest in participating in the Commercial Food to Energy (F2E) Program. Participation in this program requires consistent effort and a dedicated team. You must meet the following criteria to participate in this program.

Program Requirements: 1. Source separation of food waste is required. Program participants will be required to separate acceptable food waste from non-acceptable materials and place the acceptable materials in designated containers. a. Acceptable food waste includes: Fruits, Vegetables, Meat, Seafood, Small Bones, Dairy, Eggs, Breads, Pastas, Sauces, Cooking Oil, Grease, Tea Bags, Coffee Grounds and Paper Filters. 2. Zero Tolerance Rule for Contamination. Curbside F2E containers must be free of ALL contamination. a. Unacceptable waste materials considered contamination by this program includes:, Styrofoam, all plastics including bags, glass, metal, liquids, paper, cardboard, wood, yard waste, and all other non food waste materials. 3. Training of all kitchen staff and others who handle food waste trained on collection policies and procedures.

Marin Sanitary Service will provide the following: 1. Green carts and/or dumpsters to meet your food waste volume needs. 2. Education and training of staff. 3. Outreach materials including signs, posters, stickers, etc. 4. On-site assessment of your food waste and recycling practices. 5. Feedback to improve your program including recommendations for service levels and cart needs.

The undersigned has read, understands and agrees to the terms and conditions in this program as detailed in this agreement and in the attached Participant Assessment and Contamination Controls procedure.

______Name of participating entity For Marin Sanitary Service, Inc.

Printed name of person responsible for the program Contact information: Email and Phone#

Signature Date

Please mail, fax or scan and email this agreement to: Kim Scheibly: Contracts and Communications Manager Marin Sanitary Service, Inc. 1050 Andersen Drive,San Rafael, CA 94901 Fax: (415) 451-4741 Email: [email protected]

Agreement Between Marin Sanitary Service, Inc. and the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services: Exhibit B

AGREEMENT BETWEEN

THE CENTRAL MARIN SANITATION AGENCY

AND

MARIN SANITARY SERVICE, INC.

FOR

COMMERICAL FOOD WASTE PROCESSING AND DISPOSAL SERVICES

MAY 2013 TABLE OF CONTENTS

RECITALS ...... 1

ARTICLE 1. DEFINITIONS ...... 3

ARTICLE 2. REPRESENTATIONS AND WARRANTIES ...... 9 2.01 Of the Agency ...... 9 2.02 Of MSS ...... 10

ARTICLE 3. THE PARTIES ...... 11 3.01 The Agency Is Independent Contractor ...... 11 3.02 Parties in Interest ...... 11 3.03 Binding on Successors...... 11 3.04 Confidentiality of Information ...... 11 3.05 Sole Responsibility...... 11

ARTICLE 4. TERM OF AGREEMENT ...... 12 4.01 Term ...... 12 4.02 Term Extensions ...... 12 4.03 Survival of Certain Provisions ...... 12

ARTICLE 5. PREPARATION, DELIVERY AND ACCEPTANCE OF FOOD WASTE ...... 13 5.01 Delivered Food Waste ...... 13 5.02 Acceptance of Food Waste ...... 13

ARTICLE 6. OTHER PROGRAM COMMITMENTS ...... 15 6.01 Facility Operations ...... 15 6.02 MSS Program Guarantee ...... 16 6.03 General Operations ...... 16 6.04 Pomace and Residual of Digested Food Solids ...... 16 6.05 Records and Reports ...... 17 6.06 MSS Ability to Tour and Inspect AgencyFacility ...... 18 6.07 CMSA Right to Tour, Inspect and Monitor Transfer Station ...... 18 6.08 Ongoing Evolution of Program ...... 19

ARTICLE 7. COMPENSATION ...... 20 7.01 General ...... 20 7.02 Disposal Fee and Fee Escalation ...... 20 7.03 Revenue Sharing ...... 20

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services

ARTICLE 8. INSURANCE ...... 22 8.01 Insurance Requirements ...... 22

ARTICLE 9. INDEMNITY ...... 24 9.01 MSS Indemnification...... 24 9.02 CMSA Indemnification…………………………………………………………… ...... 24

ARTICLE 10. BREACHES AND DEFAULTS ...... 25 10.01 Breaches ...... 25 10.02 Default ...... 26 10.03 Request to Meet and Confer ...... 26 10.04 Remedy of Breach, Other Remedies ...... 26 10.05 Substitute Services ...... 27 10.06 Waiver ...... 28 10.07 Determination of Remedy or Cure of Breach or Default ...... 28 10.08 Uncontrollable Circumstances ...... 28

ARTICLE 11. TERMINATION ...... 29 11.01 Parties’ Right to Suspend or Terminate ...... 29

ARTICLE 12. OTHER PROVISIONS ...... 31 12.01 Notices ...... 31 12.02 Authorized Representatives ...... 32 12.03 Assignment ...... 32 12.04 Conflicting Provisions ...... 32 12.05 Governing Law ...... 32 12.06 Amendments ...... 32 12.07 Venue ...... 32 12.08 Entire Agreement ...... 32 12.09 Savings Clause ...... 33

EXHIBITS Exhibit A: MSS Participant Assessment & Contamination Control Procedures for Food Waste Delivered to CMSA Exhibit B: Food Waste Program Participant Agreement Exhibit C: Marin Sanitary Service and CMSA Service Area

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services

AGREEMENT BETWEEN THE CENTRAL MARIN SANITATION AGENCY AND MARIN SANITARY SERVICE, INC. FOR COMMERCIAL FOOD WASTE PROCESSING AND DISPOSAL SERVICES

This Agreement is entered into and executed as of the ___ day of ___, 2013 (the “Effective Date”), by and between the Central Marin Sanitation Agency (“CMSA”) a joint powers authority, and Marin Sanitary Service, Inc. (“MSS”), a corporation formed under the laws in the State of California, (together referred to as the “Parties” or “Party”).

RECITALS

WHEREAS, the State of California (“State”) through enactment of the California Integrated Waste Management Act of 1989, has directed all local agencies to promote recycling and to maximize the use of feasible source reduction, recycling and composting options in order to reduce the amount of municipal solid waste that must be disposed of by landfill; and

WHEREAS, organic food waste is one of the largest components of landfilled material; and

WHEREAS, CMSA is a regional wastewater treatment agency located in San Rafael that provides wastewater and biosolids treatment and other environmental services to the residents in San Rafael, Larkspur, Corte Madera, Ross, Fairfax, San Anselmo, and unincorporated areas in the Central Marin County, including San Quentin State Prison; and

WHEREAS, MSS is the solid waste company that serves many residents and businesses in Central Marin County, and has a similar service area as CMSA; and

WHEREAS, CMSA has two existing anaerobic digesters that produce biogas for use as renewable fuel and a cogeneration engine to produce electricity to power CMSA’s facilities and treatment plant; and

WHEREAS, CMSA and MSS partnered with the City of San Rafael in 2008 to conduct a Methane Capture Feasibility Study that showed MSS can collect up to 15 tons of commercial food waste per day in its Service Area (as defined below), and that food waste can be processed in the CMSA digesters to produce additional biogas; and

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 1 of 33 WHEREAS, CMSA completed a Food-to-Energy (F2E) predesign study in 2009 that indicated that its digesters have unutilized capacity to treat over 100 tons/day of food waste, and its cogeneration engine has the capacity to generate additional energy from biogas produced by 57 tons of food waste; and

WHEREAS, CMSA and MSS have identified many benefits of a commercial F2E program for their organizations, customers, and the environment, including reduced greenhouse gas emissions, reduced use of landfill volume, and saving electricity and natural gas resources within Central Marin County; and

WHEREAS, CMSA wishes to accept, and CMSA’s Facility has the capacity to accept, up to 15 tons of commercially generated food waste a day from MSS’ service area; and

WHEREAS, MSS wishes to deliver up to 15 tons of commercially generated food waste a day from its service area to CMSA’s Facility and engage CMSA’s food waste processing and disposal services; and

WHEREAS, the Parties agree that a number of the terms and conditions of this Agreement may have to be modified over time based on new information learned as a result of the evolution of the Central Marin Commercial Food Waste Program; and

WHEREAS, the Parties agree to cooperate with each other in good faith to implement or amend this Agreement.

NOW, THEREFORE, in consideration of the mutual promises, covenants, guarantees and conditions contained in this Agreement and for other good and valuable consideration, CMSA and MSS agree as follows:

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 2 of 33 ARTICLE 1. DEFINITIONS

Accept (or Acceptance or other variations thereof) is the transfer of ownership of Food Waste from MSS to CMSA.

Agreement means this Agreement, including all exhibits and attachments that are incorporated herein by reference. This Agreement may be amended and supplemented pursuant to Section 12.06.

Applicable Law means all statutes, rules, regulations, permits, orders, or requirements of the Federal, State, County, and local government authorities and agencies having applicable jurisdiction, that apply to or govern the Facility, the Site or the performance of the Parties’ respective obligations hereunder in effect as of the Execution Date and as amended and/or enacted hereinafter.

Collectors means MSS and those business entities engaged by MSS to collect Food Waste from commercial food waste generators.

Change in Law means the occurrence of any event or change in Applicable Law as follows: (1) the adoption, promulgation, amendment, modification, rescission, revision or revocation of any Applicable Law or change in judicial or administrative interpretation thereof occurring after the Execution Date hereof; or

(2) any order or judgment of any Federal, State or local court, administrative agency or governmental body issued after the Execution Date hereof if:

(i) such order or judgment is not the result of the willful misconduct or negligent action or inaction of the Party relying thereon or of any third party for whom the Party relying thereon is directly responsible; and

(ii) the Party relying thereon, unless excused in writing from so doing by the other Party, shall make or have made, or shall cause or have caused to be made, Reasonable Business Efforts in good faith to contest such order or judgment (it being understood that the contesting in good faith of such an order or judgment shall not constitute or be construed as willful misconduct or negligent action of such Party); or

(3) the imposition by a governmental authority or agency of any new or different material conditions in connection with the issuance, renewal, or modification of any permit or approval after the Execution Date; or

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 3 of 33 (4) the failure of a governmental authority or agency to issue, or the suspension, termination or rejection of, any permit or approval after the Execution Date hereof.

Commercial Food Waste Generator means those restaurants and food processing businesses participating in MSS’ Food Waste program.

Contract Year means CMSA’s fiscal year of July 1 of one year to June 30 of the following year.

Delivery (Deliver or Delivered or other variations thereof) means arrival of MSS at the Site entrance during Facility Receiving Hours for the purposes of delivering Food Waste to CMSA.

Disposal means depositing of Pomace or Residual of Digested Food Solids for beneficial use such as compost, land application, or alternative daily cover at authorized landfills, or dumping at an authorized landfill.

Facility means the CMSA’s wastewater treatment plant located at 1301 Andersen Drive, San Rafael, California.

Facility Receiving Hours are hours when the CMSA will be open to Accept Food Waste at the Facility as defined in Section 6.03.

Food Waste means organic consumer food materials acceptable for Pre-processing that is collected from Commercial Food Waste Generators within MSS’ Service Area, or within the respective service areas of other Marin County solid waste haulers that contract with MSS for Food Waste Pre-processing services. Food Waste includes fruits, vegetables, meat, seafood, small bones, dairy, eggs, breads, pastas, sauces, cooking oil, grease, tea bags, coffee grounds and filters, and other related food waste materials.

Force Majeure event includes but is not limited to floods, earthquakes, other extraordinary acts of nature, war or insurrection, riots, or other similar catastrophic events, not caused or maintained by the Party seeking relief, which event is not reasonably within the ability of that Party to intervene in or control to the extent that such event has a materially adverse effect on the ability of that Party to perform its obligations hereunder. No event, the effects of which could have been prevented by reasonable precautions, including compliance with Applicable Laws, shall be a Force Majeure event. No failure of performance by CMSA, MSS, their respective contractors or other Collectors shall be a Force Majeure event unless such failure is itself caused by a Force Majeure event as to CMSA, MSS, their respective contractors and/or other Collectors.

Hazardous Waste means materials that are hazardous, including but not limited to: (1) “Hazardous Waste” pursuant to Section 40141 of the California Public Resources Code; all substances defined as Hazardous Waste, acutely Hazardous Waste, or extremely Hazardous Waste by Sections 25110.02, 25115, and 25117 of the California Health and Safety

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 4 of 33 Code (the California Hazardous Waste Control Act), California Health and Safety Code Section 25100 et seq., and future amendments to or recodification of such statutes or regulations promulgated thereunder, including 23 California Code of Regulations Sections 2521 and 2522; and

(2) materials regulated under the Resource Conservation and Recovery Act, 42 U.S.C. Section 6901 et seq., as amended (including, but not limited to, amendments thereto made by the Solid Waste Disposal Act Amendments of 1980), and related Federal, State and local laws and regulations;

(3) materials regulated under the Toxic Substances Control Act, 15 U.S.C. Section 2601 et seq., as amended, and related Federal, State of California, and local laws and regulations, including the California Toxic Substances Account Act, California Health and Safety Code Section 25300 et seq.;

(4) materials regulated under the Comprehensive Environmental Response, Compensation and Liability Act, 42 USC 9601, et seq., as amended, and regulations promulgated thereunder; and

(5) materials regulated under any future additional or substitute Federal, State or local laws and regulations pertaining to the identification, transportation, treatment, storage or disposal of toxic substances or Hazardous Waste; with the exception that Hazardous Waste, for the purpose of this Agreement, shall specifically exclude Household Hazardous Waste.

If two or more governmental agencies having concurrent or overlapping jurisdiction over Hazardous Waste adopt conflicting definitions of “Hazardous Waste,” for purposes of collection, transportation, processing and/or disposal, the more restrictive definition shall be employed for purposes of this Agreement.

Holidays are New Year’s Day, Martin Luther King’s Birthday, President’s Day, Memorial Day, Independence Day, Labor Day, Veteran’s Day, Thanksgiving Day, the day after Thanksgiving Day, and Christmas Day or any other day that CMSA gives MSS seventy-two (72) hours prior written notice that the Facility will not be in operation that day.

Household Hazardous Waste are those wastes resulting from products used by the general public for household purposes which, because of their quantity, concentration, or physical or chemical characteristics, may pose a substantial known or potential hazard to human health or the environment when improperly treated, disposed, or otherwise managed.

Labor Action means labor unrest, including strike, work stoppage, lock-out, slowdown, sick-out, picketing, industrial disturbance and any other concerted job action.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 5 of 33 Notice (or Notify or other variation thereof) means written notice given by one Party to the other Party in relation to the execution of the various obligations of both Parties under this Agreement.

Permits means all Federal, State and local, statutory or regulatory approvals, or other measures or mechanisms necessary for either Party to be in full legal compliance in the performance of all their obligations, as renewed or amended from time to time.

Person includes any individual, firm, association, organization, partnership, corporation, trust, joint venture, the United States, the State, a county, a municipality or special district or any other entity whatsoever.

Pomace means rejected material resulting from processing the Food Waste through the Facility’s paddle finisher, after acceptance and prior to digestion, that requires recycling or Disposal.

Pre-process means the handling, removal of Unacceptable Materials, and grinding of the Food Waste by MSS at its Transfer Station prior to delivery to the Facility.

Process (or Processing or any other variation thereof) means the handling, digestion and Disposal of Food Waste and Pomace and Residual of Digested Food Solids by CMSA at the Facility after Acceptance.

Reasonable Business Efforts means those efforts a reasonably prudent business Person would expend under the same or similar circumstances in the exercise of such Person’s business judgment, intending in good faith to take steps calculated to satisfy the obligation that such Person has undertaken to satisfy.

Residual of Digested Food Solids means material remaining after digestion and dewatering of Food Waste that requires recycling or Disposal.

Service Area means the geographical area where the residents and businesses that MSS serves are located as of the date this Agreement is executed by CMSA as set forth on Exhibit C attached hereto.

Site means the parcel of land on which the Facility is situated.

Ton means a unit of measure for weight equivalent to two thousand (2,000) standard pounds (where each pound contains 16 ounces).

Transfer Station means MSS’ transfer station at 1050 Andersen Drive, San Rafael, at which the Food Waste is Pre-processed before it is transported to the Facility.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 6 of 33 Unacceptable Material(s) means wastes or other materials that CMSA cannot Process as part of the Food Waste and is considered contamination, including but not limited to plastic, styrofoam, glass, metal, paper, cardboard, wood, yard waste, cans, straps, ropes, cords, wires, bottles or any other material in quantities that would impact CMSA’s ability to process Food Waste or meet regulatory compliance. De minimis quantities of these wastes which under typical operating circumstances would not disrupt Facility operations (e.g., by clogging pipelines or damaging equipment) will not be considered Unacceptable Materials. This definition may evolve over time by mutual agreement of the Parties to reflect new methods that allow processing of additional materials.

Uncontrollable Circumstance(s) means any act, event, or condition outside either Party’s control and not the result of willful or negligent action or inaction on the part of such Party, whether affecting the Facility, the Transfer Station or either Party, which materially and adversely affects the ability of either Party to perform any of its obligations under this Agreement, including: (1) The failure of any appropriate Federal, State, or local public agency or private utility having operational jurisdiction in the area in which the Facility or the Transfer Station is located, to provide and maintain utilities, services, water, sewer or power transmission lines to the Facility or the Transfer Station which are required for Facility operations or Transfer Station operations; or

(2) A Change in Law; or

(3) The suspension or interruption of either Party’s operations as a result of any release, spill, power outage, contamination, migration or presence of any Hazardous Waste, petroleum and petroleum products or as a result of any release, spill, contamination of toxic materials where the Party is not liable for the release, spill or contamination, or a potentially responsible party. The suspension of operations due to a release, spill or contamination where the Party’s liability for the release, spill or contamination arises solely from Party’s status as the operator of the facility or owner of the property will be considered an Uncontrollable Circumstance; or

(4) A process upset to the Facility or the Transfer Station due to a toxic load or similar event not related to Food Waste processing and that prevents the use of the digesters; or

(5) A Force Majeure event that temporarily or permanently interrupts Facility operations or Transfer Station operations; or

(6) A Facility equipment or control system failure that constitutes a Force Majeure event and that interrupts the ability of the Facility to receive and process, the Food Waste; or

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 7 of 33 (7) A Transfer Station equipment failure that constitutes a Force Majeure event and that interrupts the ability of the Transfer Station to receive, preprocess, or transport Food Waste; or The following are excluded from Uncontrollable Circumstances, without limitation, unless caused by an Uncontrollable Circumstance listed above:

(1) Adverse changes in the financial condition of either Party or any Change in Law with respect to any taxes based on or measured by net income, or any unincorporated business, payroll, franchise or employment taxes;

(2) The consequences of errors on the part of either Party, its employees, agents, subcontractors or affiliates, including errors in plans and specifications that should reasonably have been identified;

(3) The failure of either Party to secure patents, technical licenses, trademarks, and the like necessary for delivery and processing of Food Waste;

(4) The lack of fitness for use, or the failure to comply with the plans and specifications, of any materials, equipment or parts constituting any portion of the Facility or the Transfer Station; and

(5) Labor Actions of or affecting the employees or contractors (including, in the case of MSS, other Collectors) of the Party that is asserting Uncontrollable Circumstances.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 8 of 33 ARTICLE 2. REPRESENTATIONS AND WARRANTIES

2.01 Of CMSA. CMSA represents and warrants as of the date hereof: a. Status. CMSA is a publicly owned utility formed under the California Joint Exercise of Powers Act

b. Authority and Authorization. CMSA has full legal right, power and authority to Execute this Agreement and perform its obligations hereunder. This Agreement has been duly Executed by CMSA and constitutes a legal, valid and binding obligation of CMSA enforceable against CMSA in accordance with its terms.

c. No Conflicts. The execution by the CMSA of this Agreement, the performance by the CMSA of its obligations under, and the fulfillment by the CMSA of the terms and conditions of, this Agreement does not knowingly (1) conflict with, violate or result in a breach of any Applicable Law; or (2) conflict with, violate or result in a breach of any term or condition of any judgment, order or decree of any court, administrative agency or other governmental authority, or any agreement or instrument to which CMSA is a Party or by which CMSA or any of its properties or assets are bound, or constitute a Default thereunder.

d. No Approvals. CMSA warrants that all legally required Permits, qualifications and approvals of whatsoever nature will be secured for CMSA to provide services hereunder and meet CMSA’s obligations, and CMSA further warrants that it shall, at its sole cost and expense, keep in effect or obtain at all times during the Term all permits, and approvals which are legally required for CMSA to provide such services and meet its obligations.

e. No Litigation. There is no action, suit, proceeding or investigation, at law or in equity, before or by any court or governmental authority, commission, board, agency or instrumentality pending or, to the best of CMSA’s knowledge, threatened, against CMSA wherein an unfavorable decision, ruling or finding, in any single case or in the aggregate, would materially adversely affect the performance by CMSA of its obligations hereunder or in connection with the transactions contemplated hereby, or which, in any way, would adversely affect the validity of, or the ability to enforce, this Agreement or any other agreement or instrument entered into by CMSA in connection with the transactions contemplated hereby.

f. Public Works. The services requested by CMSA under this Agreement do not constitute a “public work” and are not subject to any of the provisions of the Public Works law, Labor Code Sections 1720-1901, nor of the regulations promulgated thereunder.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 9 of 33 2.02 Of MSS. MSS represents and warrants as of the date hereof: a. Status. MSS is a corporation, duly organized and validly existing under the laws of the State of California.

b. Authority and Authorization. MSS has full legal right, power and authority to Execute this Agreement, and perform its obligations hereunder. This Agreement has been duly executed by MSS and upon execution constitutes a legal, valid and binding obligation of MSS enforceable against MSS in accordance with its terms and in accordance with MSS’ corporate resolution. MSS has complied with Applicable Law in entering into this Agreement. Notwithstanding the foregoing, MSS does not have the authority to act for, or to waive any rights of, any of the jurisdictions in its Service Area with respect to the Food Waste delivered to the Facility.

c. No Conflicts. Neither the execution by MSS of this Agreement, the performance by MSS of its obligations hereunder, nor the fulfillment by MSS of the terms and conditions hereof: (1) conflicts with, violates or results in a breach of Applicable Law; or (2) conflicts with, violates or results in a breach of any term or condition of any judgment, order or decree of any court, administrative agency or other governmental authority, or any agreement or instrument to which MSS is a Party or by which MSS or any of its properties or assets are bound, or constitutes a Default thereunder.

d. No Approvals. No approval, authorization, license, permit, order or consent of, or declaration, registration or filing with any governmental or administrative authority, commission, board, agency or instrumentality is required for the valid execution and delivery of this Agreement by MSS.

f. No Litigation. There is no action, suit, proceeding or investigation, at law or in equity, before or by any court or governmental authority, commission, board, agency or instrumentality pending or, to the best of MSS’s knowledge, threatened, against MSS that would materially adversely affect the performance by MSS of its obligations hereunder or in connection with the transactions contemplated hereby, or which, in any way, would adversely affect the validity of, or the ability to enforce this Agreement or any other agreement or instrument entered into by MSS in connection with the transactions contemplated hereby.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 10 of 33 ARTICLE 3. THE PARTIES

3.01 Independent Contractor. The Parties intend that each will perform its obligations as an independent contractor and neither as a partner of or joint venturer with the other. No agents, employees, contractors, consultants, licensees, agents or invitees of a Party will be deemed to be employees, contractors, licensees, agents or invitees or agents of the other Party.

3.02 Parties in Interest. Nothing in this Agreement, whether express or implied, is intended to confer any rights on any Persons other than the Parties and their respective representatives, successors and permitted assigns.

3.03 Binding on Successors. Subject to Section 12.03 below, the provisions of this Agreement shall inure to the benefit of and be binding on the successors and permitted assigns of the Parties.

3.04 Confidentiality of Information. The Parties acknowledge and agree that information submitted by either Party pursuant to this Agreement may be subject to compulsory disclosure upon request from a member of the public under the California Public Records Act, Government Code Section 6250 et seq.

3.05 Sole Responsibility. Each Party shall be solely responsible for the acts and omissions of its officers, employees, subcontractors and agents.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 11 of 33 ARTICLE 4. TERM OF AGREEMENT

4.01 Term. This Agreement shall become effective on the Effective Date and continue in effect for three (3) years thereafter unless terminated earlier by either Party in accordance with Article 7 or 11. The first year of this Agreement will begin on the Effective Date and the third year of this Agreement will end on ______, 2016.

4.02 Term Extensions. a. Agreement to Extend. The Parties may mutually agree in writing to extend this Agreement after the end of the first 3-year term. Each extension will be of at least 12 months in duration. The Parties shall endeavor to commit to an extension at least ninety (90) days before the expiration of the then-current term.

b. Agreement in Full Effect.

All provisions of this Agreement shall remain in effect during any extension.

4.03 Survival of Certain Provisions. All indemnifications provided for herein and any other rights and obligations of the Parties expressly stated to survive the termination of this Agreement, shall survive such termination including, but not limited to, the following provisions: Section 6.05 (Records and Reports), Article 8 (Insurance) and Article 9 (Indemnity).

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 12 of 33 ARTICLE 5. PREPARATION, DELIVERY AND ACCEPTANCE OF FOOD WASTE

5.01 Delivered Food Waste. MSS will use Reasonable Business Efforts and will employ specified procedures to ensure that all Food Waste Delivered to CMSA’s Facility has been Pre-processed, is free of Unacceptable Materials and is acceptable based on CMSA’s requirements for its Food Waste processes and its Facility processes as set forth in this Agreement.

a. Grinding of Food Waste. Before Delivery, the Food Waste must be ground into pieces approximately one inch square in size or smaller, through a hammermill or like equipment.

b. Preventing Contamination of Loads. MSS will use Reasonable Business Efforts to prevent Unacceptable Materials from being included in Food Waste Delivered to CMSA, including but not limited to the education of those Collectors and Commercial Food Waste Generators who utilize MSS’ services to the termination of the Delivery to the Facility of Food Waste collected from Commercial Food Waste Generators who fail to comply with the Unacceptable Waste requirements of this Agreement. MSS will require its Commercial Food Waste Generators to sign a Food Waste Program Participation Agreement (Exhibit B) that acknowledges both the requirements of this Agreement, as well as the Participant Assessment and Contamination Controls procedures which are attached to this Agreement as Exhibit A.

5.02 Acceptance of Food Waste. a. Acceptance and Ownership of Food Waste. CMSA shall accept an aggregate of up to 15 tons per day, or 75 tons per week, of Food Waste from MSS during the term of this Agreement. CMSA and MSS agree to discuss adjusting these maximum amounts based on actual program performance as the Food Waste program matures.

Notwithstanding the above, CMSA shall have the right but not the obligation to inspect each and every load of Food Waste to confirm that no Unacceptable Materials are contained therein. Food Waste will be deemed Accepted unless CMSA rejects the materials as they are being dumped or immediately after dumping at the Facility. If the Food Waste is contaminated in a manner that could not be ascertained upon visual inspection during dumping but CMSA Notifies MSS prior to completion of processing that the Food Waste contains Unacceptable Materials, it shall have the right to reject that load or loads of Food Waste.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 13 of 33 b. Rejection of Unacceptable Material.

(1) Inspection. CMSA may use Reasonable Business Efforts to detect and discover Unacceptable Material.

(2) Rejection of Contaminated Loads. CMSA may reject any loads containing Unacceptable Materials, if a qualified CMSA representative observes Unacceptable Materials discharged into the Food Waste receiving tank and believes, using his/her professional judgment, that the Unacceptable Materials are of a type or quantity that will disrupt Facility operations (e.g., by clogging pipelines or damaging equipment). Prior to receiving Food Waste at the Facility, CMSA will develop a standard operating procedure for receiving MSS deliveries that provides guidance to CMSA and MSS staff on the types and quantities of Unacceptable Materials that have the potential to disrupt Facility operations.

Should the CMSA reject any Delivered loads of Food Waste at the Facility due to the presence of Unacceptable Materials, CMSA shall immediately upon discovery notify the delivery truck driver and the MSS designated representative verbally, identifying CMSA’s reason for rejection of the Delivered Food Waste and identifying the specific MSS truck that Delivered the rejected Food Waste, if possible. If CMSA rejects Food Waste Delivered to the Facility per Section 5.02.a, MSS will promptly remove the rejected Food Waste from the Facility at its own expense.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 14 of 33 ARTICLE 6. OTHER PROGRAM COMMITMENTS

6.01 Facility Operations. a. Operating Throughput Commitment. CMSA acknowledges that MSS will need approximately 3 years, beginning in the Spring of 2013, to complete the process of identifying and contracting with Commercial Food Waste Generators, who qualify for inclusion in the Food Waste program. MSS estimates a maximum of fifteen (15) tons of Food Waste per day or seventy-five (75) tons of Food Waste per week (after the required pre-process) once the Food Waste program has been fully implemented.

b. Vehicle Turnaround. CMSA will use Reasonable Best Efforts to allow MSS’ vehicles to enter, position their vehicles for dumping, dump their load of Food Waste (including Facility clean up), turnaround and exit the Facility within an average of sixty (60) minutes or less after arriving at the Facility absent vehicle breakdown, driver negligence, lack of cooperation on the part of the driver, or driver parking to use restrooms, telephone or other driver or truck- related issues, and provided that the truck arrives at the Facility during Facility Receiving Hours.

c. Facility Clean-up. MSS will clean and wash down the Facility’s Food Waste receiving area after each load of Food Waste is dumped into its underground receiving tank. Upon completion of the dumping and cleaning, all debris and liquid waste that may have spilled during the dumping operation shall be removed and the area left in a clean and orderly state. Washdown water, hoses, brooms, and a dumpster are located at the Facility’s Food Waste receiving area and may be used by MSS for Facility clean-up. If MSS fails to clean up its debris and/or liquid waste, CMSA shall be entitled to charge MSS the sum of Fifty Dollars ($50.00) for each delivery that MSS fails to clean-up.

6.02 MSS Program Guarantee. a. Quantity. MSS shall make Reasonable Business Efforts to deliver to CMSA one hundred percent (100%) of the Food Waste collected from Collectors and Commercial Food Waste Generators, not including loads which may have to be rejected due to the presence of Unacceptable Materials. MSS will not materially reduce the scope of the Food Waste program without the prior written agreement of CMSA, which agreement shall not be unreasonably withheld. The Parties acknowledge that some restaurants or food processors in MSS’ Service Area will not participate in the Food Waste program because they are either not interested in participating or are unable to provide Food Waste that meets the required quality specifications.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 15 of 33 b. Expansion of Program. MSS further commits to expand its Food Waste collection program by encouraging other Marin County solid waste haulers to collect commercial food waste from their service areas, sharing education materials, and offering to Pre-process their collected Food Waste at the Transfer Station for MSS’ Pre-processing and Delivery to the Facility.

c. Permits. MSS will be responsible at its own expense for any and all permits required for the collection, Pre-processing, and delivery of Food Waste to the Facility as well as the disposal of rejected Food Waste and debris and liquid waste spilled during loading into the vehicles, transportation to and dumping at the Facility.

6.03 General Operations. a. Facility Receiving Hours. Unless otherwise agreed upon by the Parties in advance, CMSA shall receive Food Waste from MSS at the Facility between the hours of 6:00 a.m. and 4:00 p.m. each Monday through Friday, and between the hours of 9:00 a.m. and 12:00 p.m. on Saturdays, excluding Holidays.

b. Notification in Emergency. It is the responsibility of MSS to Notify CMSA of emergencies, and changes in scheduling of the delivery of Food Waste.

c. Scale Operation. The MSS Transfer Station operator will weigh each Food Waste delivery vehicle before and after loading (1) for CMSA billing purposes and (2) to determine the amount of materials received. The scale weight information for each delivery vehicle will be provided to CMSA at the time of each Delivery to the Facility. Upon request, MSS will provide verification that the scales are routinely calibrated and certified by Marin County.

d. Continuous Operations. CMSA shall keep open and operate the Facility continuously and uninterruptedly, during Facility Receiving Hours, except when CMSA is prevented from doing so by any Uncontrollable Circumstance, rejection of Unacceptable Material, performing scheduled maintenance of the Food Waste processing equipment, or if a CMSA digester is out-of-service or has a processing disruption.

e. Traffic Flow. CMSA shall direct traffic upon entry to the Site so that MSS’ vehicles travel, queue, unload and exit in a safe manner.

6.04 Pomace and Residual of Digested Food Solids. a. Pomace. So long as MSS is the only supplier of Food Waste to the Facility, MSS will legally dispose of all Pomace from the Facility processing at its own expense unless otherwise mutually agreed to in writing. CMSA will verbally notify the appropriate MSS

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 16 of 33 representative that the Facility’s Pomace storage container needs to be emptied along with a written reminder sent to the MSS’ email address set forth below in Section 12.01.

b. Residual of Digested Food Solids. CMSA at its own expense will dispose of the Residual of Digested Food Solids through compost, alternative daily cover at landfills, land application, landfill direct disposal, or any other disposal/reuse method consistent with CalRecycle guidelines.

6.05 Records and Reports. a. General Record Keeping. CMSA and MSS shall each maintain such accounting, statistical and other records related to their individual performances under this Agreement as shall be reasonably necessary to develop the reports required by this Agreement. CMSA and MSS agree to receive input from the other if necessary on data collection, information and record keeping, and reporting activities required to comply with Applicable Laws and to meet their reporting and Food Waste program management needs and Applicable Laws.

CMSA and MSS shall maintain records required to conduct their own operations, to support requests either may make of the other, and to respond to reasonable requests for information necessary to conduct of their respective businesses. Adequate record security shall be maintained to preserve records from events that can be reasonably anticipated such as fire, water damage, theft and earthquake. Electronically maintained data/records shall be protected and backed up in order to ensure complete and accurate retrieval of information.

b. Retention of Records. Unless otherwise herein required, CMSA and MSS shall retain all documents required to be maintained by this Agreement for at least five (5) years after the expiration or earlier termination of this Agreement. Alternatively, either Party may send its records and data to the other Party after the normal retention period has expired. Records and data that are specifically directed to be retained shall be made available to either Party upon receipt of a written request.

c. CERCLA Disposal Records. MSS shall maintain, retain and preserve records that can establish where all Pomace was Disposed. This provision shall survive the expiration or earlier termination of this Agreement. MSS shall maintain these records for a minimum of ten (10) years beyond expiration or earlier termination of the Agreement, in an organized and indexed manner, and either in physical (e.g. weigh tickets) and/or electronic form and provide these records to CMSA on a regular basis. Alternatively, MSS shall send these records to CMSA after MSS’s normal retention period has expired.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 17 of 33 d. Monthly Reports. CMSA will prepare monthly reports that include summaries of dates and tonnage of Food Waste received at the Facility. MSS has the right to receive copies of the Monthly reports as well as monthly information on the location and Disposal of Residual of Digested Food Solids.

e. Annual Report. CMSA shall prepare an Annual Report which shall include the content of the monthly reports and provide summaries as follows: dates and tonnage of Food Waste received at the Facility; records related to energy production; greenhouse gas credit information. MSS shall have the right to request copies of the Annual Report as well as annual information on the location and Disposal of Residual of Digested Food Solids.

f. Report Submittal.

All reports shall be submitted to:

Central Marin Sanitation Agency Attn: General Manager 1301 Andersen Drive San Rafael, California 94901

Marin Sanitary Service, Inc. Attn: Municipal Contracts and Communications Manager 1050 Anderson Drive San Rafael, CA 94901

6.06 MSS Right to Tour and Inspect Facility. MSS and its designated representative(s) have the right, to enter, observe and tour the Facility on reasonable notice during Facility Receiving Hours. MSS can also be accompanied on such tours by city council members, regulators, representatives from educational organizations, and public relations or media representatives. MSS and its representatives or guests will comply with CMSA’s safety and security rules at all times while on the Facility site.

6.07 CMSA Right to Tour, Inspect and Monitor Transfer Station. CMSA and its designated representative(s) have the right, to enter, observe, tour, inspect and monitor the Transfer Station and its operations on reasonable notice to MSS Monday through Friday during normal operating hours with legal holidays and weekends excluded. CMSA and its representatives will comply with MSS’ safety and security rules at all times while on the Transfer Station site.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 18 of 33 6.08 Ongoing Evolution of Program. Periodically and when necessary during the Term of this Agreement, the Parties will meet to discuss the ongoing evolution of the food waste processing and disposal program. The Parties agree to use good faith efforts to resolve issues that arise based on concerns or impacts identified during the Term of this Agreement.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 19 of 33 ARTICLE 7. COMPENSATION

7.01 General. CMSA’s compensation provided for in this Article will be the full, entire and complete compensation due to CMSA pursuant to this Agreement for all labor, equipment, material and supplies, taxes, insurance, bonds, overhead, transport, Acceptance, Processing, Residual of Digested Food Solids Disposal, and all other things necessary to perform the services required by this Agreement in the manner and at the time prescribed. MSS is not obligated to reimburse CMSA for any losses that CMSA may incur due to fluctuations in the costs of processing Food Waste.

7.02 Disposal Fee and Fee Escalation. Both sides agree to set the Delivery fee at the Facility at $20 per ton of Food Waste for the first year of the term of this Agreement. Such fee shall be subject to adjustment on each anniversary of the Effective Date by the amount of the annual percentage change in the Consumer Price Index, All Urban Consumers, San Francisco-Oakland-San Jose, CA, All Items (1982-1984=100), published by the United States Department of Labor, Bureau of Labor Statistics (the “CPI”) for the previous year (using the CPI for the month most recently published for the immediately preceding year as compared with the CPI for the same month of the second preceding year.

7.03 Revenue Sharing. The Parties agree that CMSA will retain all revenue realized from the sale of electricity generated by the digestion of Food Waste. The Parties acknowledge that a potential revenue stream exists in the sale of both Green House Gas Offsets (Credits) and Renewable Energy Certificates (RECs), or other future instruments that attach monetary value to the capture of Green House Gas, or the generation of renewable energy, as a result of the digestion of Food Waste. The Parties also acknowledge that there will be costs associated with pursuing Credits, RECs, or other future instruments. The Parties' intent is to find a way to equitably share revenue created from the processing of the Food Waste received from MSS. CMSA reserves the right to determine whether to pursue Credits, RECs or future instruments associated with that Food Waste and agrees to notify MSS in writing at the time it initiates actions to pursue those Credits, RECs, or future instruments. At that time, the Parties will meet to: a. Determine revenue potential for Credits, RECs, or future instruments, based on factors such as current market value and market trends; and

b. Agree on cost factors, such as validation, administration, operating, and other potential costs.

c. Agree on allocation of costs and potential revenue.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 20 of 33 These meetings will be held in a spirit of cooperation. At the time that these actions are completed, this Section 7.03 will be revised. Once the Parties agree on revenue potential and cost and revenue allocation, the allocation will retroactively apply to any applicable revenue received and costs incurred by CMSA from the date CMSA first notifies MSS that it is initiating the pursuit of Credits, RECs or future instruments associated with Food Waste received from MSS. If the Parties are unable to reach agreement on (a) through (c), the Parties agree to mediate the dispute. If the Parties are unable to reach agreement after mediation, either Party may terminate this Agreement upon ninety (90) days’ written notice to the other Party. MSS acknowledges that by entering into this Agreement, it does not obtain any right to or interest in any Credits, RECs or future instruments created from anything other than Food Waste delivered, received and processed by CMSA pursuant to this Agreement.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 21 of 33 ARTICLE 8. INSURANCE

8.01 Insurance Requirements. a. Insurance. Each Party shall purchase and maintain, in full force and effect during the term of this Agreement adequate insurance that shall be no less than the types and amounts of insurance coverage listed below. Each Party’s insurers must provide the other Party with thirty (30) calendar days' Notice of any cancellation or reduction in coverage and name the other Party, and its Board of Commissioners or Directors and its employees as additional insureds. Each Party, for itself and its Collectors and contractors, shall supply certificates of insurance and additional insured endorsement to the other Party showing compliance with this Article 8 prior to the delivery of any Food Waste to the Facility. The terms and obligations of this Article shall survive termination of this Agreement.

b. Workers’ Compensation Insurance. Each Party shall purchase and maintain during the term of this Agreement, Workers’ Compensation and Employer’s Liability insurance policy for all of its employees working on this project. Each Party shall ensure that its Collectors and contractors performing any work pursuant to this Agreement for such Party shall procure and maintain at all times during this Agreement, Workers’ Compensation and Employer’s Liability insurance.

c. Comprehensive General Liability Insurance. Each Party shall purchase and maintain during the term of this Agreement Comprehensive General Liability insurance policy in the amount of one million dollars ($1,000,000) for combined single limit coverage for bodily injury, personal injury and property damage. Each Party shall ensure that its Collectors and contractors performing any work pursuant to this Agreement for such Party shall procure and maintain at all times during the term of this Agreement, General Liability insurance that meets or exceeds the requirements of this Agreement.

The following coverages or endorsements must be indicated on the certificate:

(1) The other Party, its Commissioners or Directors, officers and employees are named as additional insureds in the policy;

(2) The coverage is primary to any other insurance carried by the other Party;

(3) The policy covers contractual liability for the assumption of liability of others;

(4) The policy is written on an occurrence basis;

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 22 of 33 (5) The policy covers broad form property damage liability

(6) The policy covers personal injury (libel, slander, and trespass) liability;

(7) The policy will not be canceled nor reduced without thirty (30) days’ written notice to the other Party.

(8) The policy(ies) cover(s) products and completed operations.

e. Automobile Liability Insurance. Each Party shall purchase and maintain Automobile Liability insurance policy shall apply to all owned, hired and non-owned autos, vehicles and trailers. The limits of liability shall not be less than $1,000,000 combined single limit each accident for bodily injury and property damage. Each Party shall ensure that its Collectors and contractors performing any work pursuant to this Agreement for such Party shall procure and maintain at all times during the term of this Agreement, Automobile Liability insurance that meets or exceeds the requirements of this Agreement.

f. Pollution Liability Insurance. Each Party shall purchase and maintain a Pollution Liability insurance policy with limits not less than $1,000,000 per occurrence and in the aggregate for bodily injury and property damage. Each Party shall ensure that its Collectors and contractors performing any work pursuant to this Agreement for such Party shall procure and maintain at all times during the term of this Agreement, Pollution Liability insurance that meets or exceeds the requirements of this Agreement.

g. Amounts of Insurance. The amounts of insurance shall not be less than the following:

General Liability – one million dollars ($1,000,000) per occurrence

Auto Liability – one million dollars ($1,000,000) per occurrence

Worker’s Compensation – State statutory limit

Pollution Liability – one million dollars ($1,000,000) per occurrence

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 23 of 33 ARTICLE 9. INDEMNITY

9.01 MSS Indemnification. MSS, to the greatest extent allowed by Applicable Law, will protect, hold free and harmless, defend and indemnify CMSA, including its Board of Commissioners, individual commissioners, employees, consultants and agents (collectively “indemnitees” or individually “indemnitee”) from all liabilities, penalties, costs, losses, damages, expenses, causes of action, claims or judgments, including reasonable attorney's fees, resulting from injury to or death sustained by any person (including MSS’ or its subcontractors’ employees) or damage to property of any kind, which injury, death or damage arises out of or is in any way connected with MSS’, its Collectors’ or its contractors’ performance of any part of this Agreement. MSS’ aforesaid indemnity, defense and save harmless agreement shall apply to any acts or omissions, or negligent conduct, whether active or passive, on the part of one or more of the indemnitees, except that said obligation of indemnity and hold harmless of an indemnitee shall not be applicable to injury, death or damage to property arising from the sole negligence or willful misconduct of that specific indemnitee. This indemnification, defense and hold harmless obligation shall extend to claims asserted after expiration or earlier termination, for whatever reason, of this Agreement.

9.02 CMSA Indemnification. CMSA, to the greatest extent allowed by Applicable Law, will protect, hold free and harmless, defend and indemnify MSS, its Board of Directors, individual Directors, officers and employees (collectively “indemnitees” or individually “indemnitee”) from all liabilities, penalties, costs, losses, damages, expenses, causes of action, claims or judgments, including reasonable attorney's fees, resulting from injury to or death sustained by any person (including CMSA’s employees) or damage to property of any kind, which injury, death or damage arises out of or is in any way connected with CMSA’s or its contractors’ performance of any part of this Agreement. CMSA’s aforesaid indemnity, defense and save harmless agreement shall apply to any acts or omissions, or negligent conduct, whether active or passive, on the part of one or more of the indemnitees,except that said obligation of indemnity and hold harmless of an indemnitee shall not be applicable to injury, death or damage to property arising from the sole negligence or willful misconduct of that specific indemnitee. This indemnification, defense and hold harmless obligation shall extend to claims asserted after expiration or earlier termination, for whatever reason, of this Agreement.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 24 of 33 ARTICLE 10. BREACHES, DEFAULTS, MEET AND CONFER

10.01 Breaches. a. Definition. A breach is a material failure to perform any of the material obligations set forth in this Agreement.

b. Notice of Breach. Either Party shall promptly Notify the other Party regarding the occurrence of a breach as soon as such breach becomes known to the Noticing Party. Such Notice shall be given in writing.

c. Cure of Breach. Each of MSS and CMSA shall begin cure of any breach that it commits as soon as possible after it becomes aware of its breach. Upon receiving written Notice of a breach, the breaching Party shall proceed to cure such breach as follows:

(1) Immediately, if the breach is such that in the determination of either CMSA or MSS, the health, welfare or safety of the public is endangered thereby, unless immediate cure is impossible, in which event the Party required to cure shall Notify the other Party, and the other Party may seek substitute services.

(2) Within thirty (30) calendar days of receiving Notice of the breach; provided that if the nature of the breach is such that it will reasonably require more than thirty (30) calendar days to cure, the breaching Party shall not be in default so long as it promptly commences to cure its breach, secures written agreement from the other Party to extend the thirty (30) calendar day cure period (which the other Party shall not unreasonably refuse), and provides the other Party, no less than weekly, written status of progress in curing such breach, and diligently proceeds to complete same.

10.02 Default. a. Events of CMSA Default. Each of the following shall constitute an event of default by CMSA.

(1) Uncured Breach of Agreement. CMSA fails to cure any breach as specified in Section 10.01.

(2) Repeated Pattern of the same Breaches. CMSA commits the same breach at least three (3) times during any twelve-month period during the term of this Agreement.

b. Notice of Default. CMSA shall be in default from the date of receipt of a Notice from the MSS identifying such default.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 25 of 33 c. Events of MSS Default. Each of the following shall constitute an event of default by MSS.

(1) Uncured Breach of Agreement. MSS fails to cure any breach as specified in Section 10.01.

(2) Repeated Pattern of Breaches. MSS commits the same breach at least three (3) times during any twelve-month period during the term of this Agreement.

d. Notice of Default. MSS shall be in default from the date of receipt of a Notice from CMSA identifying such default.

10.03 Request to Meet and Confer. If any breach occurs that materially affects this Agreement or a Party’s ability to perform under this Agreement or a change in Applicable law that affects either Party’s ability to receive diversion credits under AB 939, either Party shall send Notice to the other Party describing the problem and requesting a meet and confer meeting. The Parties may choose to meet in person or by teleconference. The meet and confer process is intended to be a prerequisite to sending a Notice of Breach.

If either Party does not agree to meet and confer, does not appear at the meet and confer meeting, or if the Parties are not able to correct the breach or solve the problem resulting from a change in the Applicable Law within a reasonable period of time not to exceed thirty (30) days after the meet and confer, unless the time period is extended by mutual agreement, the aggrieved Party may send a Notice of Breach. Notwithstanding the above, there is no requirement that the meet and confer process be used for a failure to pay, or for emergencies or urgent matters of public health.

10.04. Remedy for Breach, Other Remedies. The Parties shall be entitled to all available monetary or equitable remedies, including specific performance and injunctive relief.

a. MSS Remedies in the Event of CMSA Default. Upon CMSA’s failure to cure a breach pursuant to Section 10.01 or default pursuant to Section 10.02, MSS shall, in addition to its right to collect monetary damages, have the following rights:

(1) Waive Default. To, at its sole discretion, waive the CMSA breach or default in writing.

(2) Termination. Terminate the Agreement in accordance with Article 11, provided that no termination shall be effective until MSS has given written Notice to CMSA of its decision to terminate the Agreement.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 26 of 33 (3) All Other Available Remedies. In addition to, or in lieu of termination, to exercise all of its remedies in accordance with this Article and any other remedies at law and in equity, to which MSS shall be entitled, according to proof.

(4) Damages Survive. If CMSA owes any damages upon MSS’s termination of this Agreement, CMSA’s liability under this Section 10.03 shall survive termination.

b. CMSA Remedies in the Event of MSS Default. Upon MSS’ failure to cure a = breach pursuant to Section 10.01 or default pursuant to Section 10.02, CMSA shall, in addition to its right to collect monetary damages, have the following rights:

(1) Waive Default. To, at its sole discretion, waive the MSS breach or default in writing.

(2) Termination. Terminate the Agreement in accordance with Article 11, provided that no termination shall be effective until CMSA shall have given written Notice to MSS of its decision to terminate the Agreement.

(3) All Other Available Remedies. In addition to, or in lieu of termination, to exercise all of its remedies in accordance with this Article and any other remedies at law and in equity, to which CMSA shall be entitled, according to proof.

(4) Damages Survive. If MSS owes any damages upon CMSA’s termination of this Agreement, MSS’s liability under this Section 10.03 shall survive termination.

10.05 Substitute Services. In addition to exercising any or all remedies specified in Section 10.04 with regard to the other Party’s failure to cure its breach or its default, or due to an Uncontrollable Circumstance, the first Party may at its sole discretion seek substitute services.

10.06 Waiver. A waiver by one Party of one breach or default by the other Party shall not be deemed to be a waiver of any other breach or default by that Party, including ones with respect to the same obligations hereunder, and including new incidents of the same breach or default. The subsequent acceptance of any damages or other money paid hereunder shall not be deemed to be a waiver of any pre-existing or concurrent breach or default.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 27 of 33 10.07 Determination of Remedy or Cure of Breach or Default. Upon request of either Party, an event of breach or default shall be considered remedied or cured upon signature by both Parties of a written agreement specifying the event and stating that remedy and/or cure of such event has been completed.

10.08 Uncontrollable Circumstances. a. Performance Excused. Neither Party shall be in breach of its obligations hereunder in the event, and for so long as, it is impossible or extremely impracticable for it to perform such obligations due to an Uncontrollable Circumstance if such Party exerted Reasonable Business Efforts to prevent such Uncontrollable Circumstance, and such Party expeditiously takes all actions within its control to end, or to ameliorate the effects of such Uncontrollable Circumstance as soon as possible.

b. Notice. The Party claiming excuse from performance of its obligations based on an Uncontrollable Circumstance shall Notify the other Party as soon as is reasonably possible, but in no event later than three (3) working days after the occurrence of the event constituting the Uncontrollable Circumstance. The Notice shall include a description of the event, the nature of the obligations for which the Party claiming Uncontrollable Circumstance seeks excuse from performance, the expected duration of the inability to perform and proposed mitigation measures.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 28 of 33 ARTICLE 11. TERMINATION

11.01 Parties’ Right to Suspend or Terminate. a. Suspension. Either Party shall have the right to suspend this Agreement, in whole or in part, upon the occurrence of a default under Article 10 regarding an occurrence that endangers public health, welfare or safety, provided such suspension is for no longer than forty-five (45) calendar days.

b. Termination. The Parties shall have the rights to terminate this Agreement if one or more of the following events occur:

(1) Default. Occurrence of a default, or a breach which is not cured within the time frame specified, as set forth in Article 10.

(2) Criminal Activity. Either Party may terminate this Agreement if the other Party is found guilty of criminal conduct. The term "found guilty" shall be deemed to include any judicial determination that the Party or any of the Party’s officers, directors, commissioners or employees is guilty, including any admission of guilt, including, but not limited to, the pleas of “guilty,” “nolo contendere,” “no contest,” or “guilty to a lesser crime” entered as part of any plea bargain.

(3) Facility Damage or Destruction. Either Party may terminate this Agreement in the event the Facility or the Transfer Station is totally destroyed or is materially damaged and CMSA or MSS, as the case may be, either is unable to reconstruct or repair the Facility or Transfer Station or its Board of Commissioners or Directors decides it is not financially feasible to reconstruct or repair the Facility or Transfer Station.

(4) Exceedance of Disposal Fee Cap. CMSA shall have the right to terminate this Agreement if it determines after the third year of this Agreement that a Delivery fee greater than the then current fee is warranted and MSS is unwilling to pay that amount (per Section 7.02), subject only to CMSA’s submitting the dispute over the Delivery fee increase to mediation prior to termination.

(5) Failure to Agree on Revenue Sharing. If the Parties do not come to agreement regarding the sharing of revenue as discussed in Section 7.03, either Party may terminate this Agreement. Notice of termination shall be effective thirty (30) calendar days thereafter; provided that such Notice shall be effective immediately if the public health or welfare is threatened.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 29 of 33 c. Payments Upon Termination. Upon termination, CMSA shall accept as full payment for services rendered to the date of termination any payments required based on the portion of work actually performed. If MSS has made any payment for services that have not been performed, then CMSA shall promptly repay to MSS that amount.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 30 of 33 ARTICLE 12. OTHER PROVISIONS

12.01 Notices. Except as otherwise specified in this Agreement, all Notices, requests, acknowledgements, approvals, and other communications made hereunder to be sent pursuant to this Agreement shall be made in writing, and sent to the Parties at their respective addresses specified below or to such other address as a Party may designate by written notice delivered to the other parties in accordance with this Section. All such notices shall be sent by either: (i) personal delivery, in which case notice is effective upon delivery; (ii) certified or registered mail, return receipt requested, in which case notice shall be deemed delivered on receipt if delivery is confirmed by a return receipt; (iii) nationally recognized overnight courier, with charges prepaid or charged to the sender’s account, in which case notice is effective on delivery if delivery is confirmed by the delivery service; (iv) facsimile transmission, in which case notice shall be deemed delivered upon transmittal, provided that (a) a duplicate copy of the notice is promptly delivered by first- class or certified mail or by overnight delivery, or (b) a transmission report is generated reflecting the accurate transmission thereof. Any notice given by facsimile shall be considered to have been received on the next business day if it is received after 5:00 p.m. or on a non- business day.

If to MSS:

MSS President Attn: Patty Garbarino 1050 Anderson Drive San Rafael, California 94901 Telephone: (415) Fax: (415) Email: [email protected]

If to CMSA:

CMSA General Manager Attn: Jason Dow 1301 Andersen Drive San Rafael, California 94901 Telephone: (415) 459-1455 Fax: (415) 459-3971 Email: [email protected]

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 31 of 33 12.02 Authorized Representatives. a. MSS. For purposes of this Agreement, the MSS authorized representative will be its Compliance Manager or her/his designee.

b. CMSA. For purposes of this Agreement, CMSA’s authorized representative will be its General Manager or her/his designee.

12.03 Assignment. Neither Party may assign its rights or responsibilities under this Agreement to any other Person without the consent of the other Party, which consent will not be unreasonably withheld.

12.04 Conflicting Provisions. In the event the provisions of this Agreement herein conflict with those of the Exhibits hereto, the provisions of this Agreement shall prevail.

12.05 Governing Law. This Agreement shall be governed by, and construed and enforced in accordance with, the internal laws of the State of California, irrespective of choice of law principles.

12.06 Amendments. The Parties may change, modify, supplement, or amend this Agreement only upon mutual written agreement duly authorized and executed by both Parties.

12.07 Venue; Attorneys’ Fees. The exclusive venue for any legal proceedings shall be Marin County, or, in case of federal jurisdiction, Federal District Court, Northern District. The prevailing Party in any dispute arising under or in connection with this Agreement shall be entitled to recover its reasonable attorneys’ fees and costs from the other Party.

12.08 Entire Agreement. This Agreement contains the entire Agreement between the Parties with respect to the transactions contemplated hereby. All Exhibits are hereby incorporated into this Agreement by reference. This Agreement shall completely and fully supersede all prior understandings and agreements between the Parties with respect to such transactions. However, nothing in this paragraph shall supersede or diminish the representations and warranties as contained in Article 2. This Agreement shall not be interpreted for or against either Party, it having been prepared with the participation of both Parties.

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 32 of 33 12.09 Savings Clause. If any phrase, clause, section, subsection, paragraph, subdivision, sentence, term, or provision of this Agreement, or the application of any term or provision of this Agreement to a particular situation, is finally found to be void, invalid, illegal, or unenforceable by a court of competent jurisdiction, then notwithstanding such determination, such term or provision will remain in force and effect to the extent allowed by such ruling and all other terms and provisions of this Agreement or the application of this Agreement to other situations will remain in full force and effect.

IN WITNESS WHEREOF, the PARTIES hereto have Executed this Agreement on the date first above written.

Marin Sanitary Service, Inc. Central Marin Sanitation Agency

MSS President CMSA Board Chair

Date Date

ATTEST: ATTEST:

MSS Secretary CMSA Board Secretary

Date Date

Agreement Between Marin Sanitary Service, Inc. And the Central Marin Sanitation Agency For Food Waste Processing and Disposal Services Page 33 of 33 Orange County Sanitation District | TM‐5: High Strength Organic Waste Co‐Digestion Evaluation

Appendix G – QC Review Affidavits

May 9, 2017 G‐1 Master Plan Biosolids