Santa Barbara City Council
February 13, 2024

CITY OF SANTA BARBARA

CITY COUNCIL
Randy Rowse
Mayor
Sarah J. Knecht
Interim City Administrator
Mike Jordan
Mayor Pro Tempore
Mike Jordan
Ordinance Committee Chair
Tava Ostrenger
Acting City Attorney
Alejandra Gutierrez
Finance Committee Chair
Eric Friedman
Meagan Harmon
Oscar Gutierrez
Kristen W. Sneddon
City Hall
735 Anacapa Street
http://www.SantaBarbaraCA.gov
FEBRUARY 13, 2024, 2:00 PM
AGENDA
IN-PERSON PUBLIC COMMENT: At the beginning of each meeting of the City Council, Finance Committee, or Ordinance Committee, any member of the public may address the City Council concerning any item not on the Council's agenda. Any person wishing to make such address should first complete and deliver a "Request to Speak" form prior to the time that public comment is taken up by the City Council. Each speaker will be given a total of 3 minutes to address the Council. Pooling of time is not allowed during general public comment. The time allotted for general public comment at the beginning of the 2:00 p.m. session is 30 minutes.

Any member of the public who did not speak during the 2:00 p.m. session but who submitted a request to do so during the 2:00 p.m. 30 minute session may do so at the end of the meeting when the additional “Public Comment (If Necessary)” is announced. The City Council, upon majority vote, may decline to hear a speaker on the grounds that the subject matter is beyond their jurisdiction.

REMOTE PUBLIC COMMENT: Members of the public wishing to speak must “raise their hand” in the Zoom platform by selecting the virtual hand icon when their item is called. The keyboard shortcut for this is Alt+Y for Windows and Option+Y for Macs. City staff will activate the speaker’s microphone when the speaker’s name is called. The speaker will then need to unmute themselves. The keyboard shortcut for this is Alt+M for Windows or Command-Shift-A for Macs.

HOW TO REMOTELY OBSERVE AND/OR SPEAK LIVE AT A MEETING
• Web: https://santabarbaraca-gov.zoom.us/webinar/register/WN_JJS2kazqRyu2i83tshCkPw (Participation via Zoom)
• Telephone: Dial 1-669-900-6833, Enter Webinar ID: 894 2384 2846 (press *9 to raise/lower hand; press *6 to mute/unmute) • Online Streaming: Council meetings are streamed live at www.SantaBarbaraCA.gov/CAP • TV: Each regular City Council meeting is broadcast live in English and Spanish on City TV Channel 18 and rebroadcast in English on Wednesdays and Thursdays at 7:00 p.m. and Saturdays at 8:00 a.m., and in Spanish on Sundays at 3:00 p.m.

Each televised Council meeting is closed captioned for the hearing impaired. Check the City TV program guide at www.santabarbaraca.gov/citytv for rebroadcasts of Finance and Ordinance Committee meetings.

WRITTEN PUBLIC COMMENT: Public comments may also be submitted via email to [email protected] prior to the beginning of the Council Meeting. All public comments submitted via email will be provided to City Council and will become part of the public record.

ORDER OF BUSINESS: Regular meetings of the Finance Committee and the Ordinance Committee begin at 12:00 p.m. The regular City Council meeting begins at 2:00 p.m. in the Council Chambers at City Hall.

REPORTS: Copies of the reports relating to agenda items are available for review at http://www.SantaBarbaraCA.gov/CAP.In accordance with state law requirements, this agenda generally contains only a brief general description of each item of business to be transacted or discussed at the meeting. Should you wish more detailed information regarding any particular agenda item, you are encouraged to obtain a copy of the Council Agenda Report (a "CAR") online at the City's website (http://www.SantaBarbaraCA.gov/CAP). Materials related to an item on this agenda submitted to the City Council after distribution of the agenda packet are posted to the City’s website as soon as reasonably feasible.

CONSENT CALENDAR: The Consent Calendar is comprised of items that will not usually require discussion by the City Council. A Consent Calendar item is open for discussion by the City Council upon request of a Councilmember, City staff, or member of the public. Items on the Consent Calendar may be approved by a single motion. Should you wish to comment on an item listed on the Consent Agenda, after turning in your "Request to Speak" form, you should come forward to speak or raise your hand in Zoom at the time the Council considers the Consent Calendar.

SPANISH INTERPRETATION: If you need interpretation of your communications to Council from Spanish into English, please contact the City Clerk’s Office at 564-5309 or by email at [email protected]. If possible, notification of at least 48 hours will usually enable the City to make arrangements.

INTERPRETACIÓN EN ESPAÑOL: Si necesita una interpretación del español al inglés, para sus comunicaciones al Consejo, comuníquese con la Oficina del Secretario Municipal al 564-5309, o por correo electrónico a [email protected]. Si es posible, la notificación de al menos 48 horas generalmente permitirá a la Ciudad hacer los arreglos.

AMERICANS WITH DISABILITIES ACT: If you need auxiliary aids or services or staff assistance to attend or participate in this meeting, please contact the City Administrator's Office at 564-5305 or by email at [email protected]. If possible, notification at least 48 hours prior to the meeting will usually enable the City to make reasonable arrangements. For those who need accessibility accommodation in using the “raise hand” function and/or registering to participate in the Zoom session, please contact the Clerk’s office by 5:00 p.m. the day before the meeting for assistance. Additionally, a speaker may email [email protected] by 5:00 p.m. the day before a meeting, stating which item they wish to speak on. Specialized services, such as sign language interpretation or documents in Braille, may require additional lead time to arrange. 02/13/2024 Santa Barbara City Council Final Agenda Page 1 FEBRUARY 13, 2024 AGENDA
REGULAR CITY COUNCIL MEETING - 2:00 P.M.

CALL TO ORDER

PLEDGE OF ALLEGIANCE

ROLL CALL

CHANGES TO THE AGENDA

CONSENT CALENDAR

1. Subject: Lease Amendment with Sanbros, LLC DBA The Harbor Restaurant, Located at 210 Stearns Wharf [Ordinance Introduction] (570.03) Recommendation: That Council introduce and subsequently adopt, by reading of title only, an Ordinance of the Council of the City of Santa Barbara Approving and Authorizing the Waterfront Director to Execute the Amendment to Lease Agreement No. 20,493 with Sanbros, LLC, Deferring Three Months Base Rent with Lease Terms Ending December 31, 2028, Commencing Upon the Effective Date of the Enabling Ordinance.

2. Subject: Amend Street Improvement and Permitting Requirements [Ordinance Introduction] (530.04)
Recommendation: That Council introduce and subsequently adopt, by reading of title only, An Ordinance of the Council of the City of Santa Barbara Amending the Santa Barbara Municipal Code by Amending Chapter 22.44 Relating to Street Dedication and Improvement Requirements, Chapter 22.60 Relating to Permits for Work on Street and Sidewalks, Chapter 22.32 Relating to Building Numbering, Section 22.64.010 Relating to Gates Adjacent to Streets or Sidewalks, Section

27.08.010 Relating to Subdivision Requirements for Streets and Sidewalks, Section 10.56.010 Relating to Obstruction of Sidewalks, and by the Addition of Chapter 22.46 Relating to Acquisition of Property for Public Improvements. 02/13/2024 Santa Barbara City Council Final Agenda Page 2

3. Subject: Design and Implementation Services for the El Estero Water Resource Center SCADA Upgrades Project [Agreement] (540.13) Recommendation: That Council authorize the Public Works Director to execute a City of Santa Barbara Professional Services contract with Northern Digital, Inc., in the amount of $415,575 for design and implementation services for the El Estero Water Resource Center Supervisory Control and Data Acquisition Upgrades Project and authorize the Public Works Director to approve expenditures of up to $41,558 for extra services that may result from necessary changes in the scope of work, for a total expenditure authority of $457,133.

PUBLIC COMMENT

PULLED CONSENT ITEMS

COUNCILMEMBER COMMITTEE ASSIGNMENT REPORTS

CITY COUNCIL ADMINISTRATIVE AND ATTORNEY REPORTS

SUSTAINABILITY AND RESILIENCE

4. Subject: Update on the Management and Operation of the County’s ReSource Center at the Tajiguas Landfill (630.01)
Recommendation: That Council receive an update from the County of Santa Barbara on the management and operation of the ReSource Center at the Tajiguas landfill.

PUBLIC WORKS DEPARTMENT

5. Subject: Lower Eastside Community Connectivity Active Transportation Plan [Resolution] (670.08)
Recommendation: That Council:

A. Approve the Lower Eastside Community Connectivity Active Transportation Plan; B. Adopt, by reading of title only, a Resolution of the Council of the City of Santa Barbara Supporting the Lower Eastside Safety Enhancements Project and Pedestrian and Bicycle Overcrossing Project, and Directing Staff to Apply for a Grant to Fund Design, Environmental Review, and Construction; and C. Determine that the Lower Eastside Community Connectivity Active Transportation Plan is exempt under California Environmental Quality Act Guidelines and Public Resources Code Section 21080.20, and direct the filing of a Notice of Exemption in compliance with California Environmental Quality Act Guidelines § 15062. 02/13/2024 Santa Barbara City Council Final Agenda Page 3

COUNCIL AND STAFF COMMUNICATIONS

COUNCILMEMBER ENGAGEMENTS

PUBLIC COMMENT (IF NECESSARY)

ADJOURNMENT

CITY OF SANTA BARBARA

COUNCIL AGENDA REPORT
AGENDA DATE: February 13, 2024
TO: Mayor and Councilmembers
FROM: Business Services Division, Waterfront Department SUBJECT: Lease Amendment with Sanbros, LLC DBA The Harbor Restaurant, Located at 210 Stearns Wharf [Ordinance Introduction]
RECOMMENDATION:

That Council introduce and subsequently adopt, by reading of title only, an Ordinance of the Council of the City of Santa Barbara Approving and Authorizing the Waterfront Director to Execute the Amendment to Lease Agreement No. 20,493 with Sanbros, LLC, Deferring Three Months Base Rent with Lease Terms Ending December 31, 2028, Commencing Upon the Effective Date of the Enabling Ordinance.

BACKGROUND:

Sanbros, LLC assumed Lease No. 20,493 through a lease assignment process approved by City Council on November 3, 2021. Located at 210 Stearns Wharf, The Harbor Restaurant experienced significant water damage during the December 2023 rainstorms requiring emergency repairs. Rainwater entered the ground floor kitchen, damaging ceilings, walls, and essential equipment. While addressing this water damage, some structural damage to the building was identified, including damaged framing and floor joists. As a result, the restaurant is currently closed while building permits to complete the construction are obtained by the tenant.

DISCUSSION:

The Harbor Restaurant has diligently engaged with Waterfront staff and has committed to addressing unplanned emergency repairs related to water damage and the overall state of the building interior which is in dire need of repairs. The tenant has demonstrated a clear dedication to restoring the building interior and ensuring its long-term success.

The Harbor Restaurant has been an integral part of Stearns Wharf and the entire Santa Barbara community. The tenant's commitment to addressing the emergency repairs and pursuing further improvements is worth acknowledgment. By providing a three-month rent Agenda Item No. 1
File Code No. 570.03
Council Agenda Report
Lease Amendment with Sanbros, LLC DBA The Harbor Restaurant, Located at 210 Stearns Wharf [Ordinance Introduction]
February 13, 2024

deferment, the Waterfront Department can support the tenant in their efforts to restore and enhance the restaurant while ensuring its continued contribution to the vibrancy of Stearns Wharf.

PROPOSED AMENDMENTS:

Considering the extensive nature of the repairs and the temporary closure of the restaurant, the owners have proposed a three-month rent deferment to help manage their financial obligations during this period.

The base rent due during this period, a three-month total of $173,637.30, will not be waived but will instead be amortized starting April 2024 through the end of the lease in 2028. This arrangement will provide the tenant with financial relief during the construction period while ensuring that the Waterfront Department recovers the full rent amount over the remaining lease term.

All other lease terms remain the same.

The Harbor Commission recommended approval of the proposed amendment at their meeting of January 18, 2024.

BUDGET/FINANCIAL INFORMATION:

The lease revenue impacts have been incorporated into the Fiscal Year 2024 revenue in the Waterfront’s operating budget.

PREPARED BY: Cesar Barrios, Waterfront Business Manager SUBMITTED BY: Mike Wiltshire, Waterfront Director
APPROVED BY: City Administrator's Office
COUNCIL INTRODUCTION 02/13/2024
ORDINANCE NO._____

AN ORDINANCE OF THE COUNCIL OF THE CITY OF

SANTA BARBARA APPROVING AND AUTHORIZING THE

WATERFRONT DIRECTOR TO EXECUTE THE
AMENDMENT TO LEASE AGREEMENT NO. 20,493 WITH

SANBROS, LLC, DEFERRING THREE MONTHS BASE
RENT WITH LEASE TERMS ENDING DECEMBER 31, 2028,

COMMENCING UPON THE EFFECTIVE DATE OF THE
ENABLING ORDINANCE.

THE COUNCIL OF THE CITY OF SANTA BARBARA DOES ORDAIN AS FOLLOWS:

SECTION 1. In accordance with the provisions of Section 521 of the Charter of the City of Santa Barbara, An Ordinance of the Council of the City of Santa Barbara Approving the Amendment to Lease Agreement No. 20,493 With Sanbros LLC, upon the effective date of the enabling ordinance.

CITY OF SANTA BARBARA

COUNCIL AGENDA REPORT
AGENDA DATE: February 13, 2024
TO: Mayor and Councilmembers
FROM: Public Works Downtown Team
Engineering Division, Public Works Department
SUBJECT: Amend Street Improvement and Permitting Requirements [Ordinance Introduction]
RECOMMENDATION:

That Council introduce and subsequently adopt, by reading of title only, an Ordinance of the Council of the City of Santa Barbara Amending the Santa Barbara Municipal Code by Amending Chapter 22.44 Relating to Street Dedication and Improvement Requirements, Chapter 22.60 Relating to Permits for Work on Street and Sidewalks, Chapter 22.32 Relating to Building Numbering, Section 22.64.010 Relating to Gates Adjacent to Street or Sidewalks, Section 27.08.010 Relating to Subdivision Requirements for Streets and Sidewalks, and Section 10.56.010 Relating to Obstructions of Sidewalks, and by the Addition of Chapter 22.46 Relating to Acquisition of Property for Public Improvements.

EXECUTIVE SUMMARY:

Staff recommends updating Title 22 of the Santa Barbara Municipal Code (SBMC) to implement the Circulation Element of the City of Santa Barbara (City) General Plan, the Bicycle Master Plan (BMP), and the Pedestrian Master Plan (PMP) by establishing updated requirements for Public Right-of-Way (PROW) dedications and improvements in association with new construction on private property. Staff also recommends adding language to Section 10.56.010 to facilitate prompt removal of items obstructing pedestrian paths of travel. Proposed changes also remove antiquated language and make these code sections clearer and easier for the public, developers, and staff to understand and interpret. The ordinance amendments went before the Ordinance Committee on February 6, 2024, and the Committee recommended the amendments move forward to City Council.

DISCUSSION:

Chapter 22.44: Street Dedication and Improvement for Building Permits Chapter 22.44 of the SBMC establishes street dedication and improvement requirements for projects requiring building permits. Staff recommends revisions to Chapter 22.44 to implement the Circulation Element of the City’s General Plan, the BMP, and the PMP by Agenda Item No. 2
File Code No. 530.04
Council Agenda Report
Amend Street Improvement and Permitting Requirements [Ordinance Introduction] February 13, 2024

establishing updated requirements for dedication and improvement of the PROW in connection with the construction or reconstruction of buildings for which a building permit is required.

The recommended updates to Chapter 22.44 are summarized below:
 Addition of Section 22.44.005, Purpose and Definitions. The purpose of Chapter 22.44 is to implement the Circulation Element of the City’s General Plan, the BMP, and the PMP by establishing requirements for dedication and improvement of the PROW in connection with the construction or reconstruction of buildings for which a building permit is required. The provisions in Chapter 22.44 are supplemental to the Subdivision Ordinance (Title 27), or as a condition of a development permit or approval under Titles 28 or 30.

This section also defines “New Main Building” as any new main building, substantial redevelopment of an existing main building, or addition greater than 500 square feet to an existing main building, that requires a building permit and for which construction cost exceeds $100,000 (as determined by building permit valuation).
 Definition of the sidewalk corridor. The addition of Table 22.44.080.A defines the sidewalk corridor narratively and graphically and includes updated improvement standards consistent with the PMP. In addition to implementing the PMP, this change simplifies and clarifies public improvement standards.  Definition of projects exempt from PROW dedication and improvement requirements. Section 22.44.020 outlines which projects are exempt from dedication and improvement of the PROW. Originally, this chapter exempted single-family and two-family developments, additions, and accessory buildings.

The proposed changes to this section exempt:
o Structures other than a new main building; and
o Residential buildings located on a lot that does not adjoin a neighboring property with existing curb, gutter, and sidewalk.

This section also defines reasons for which the City Engineer may waive the requirement for construction of sidewalk improvements.
 Definition of the City Engineer’s authority for waiving requirements. Defining what requirements the City Engineer can waive for the construction of sidewalk improvements.
 Street lighting requirements. Section 22.44.010 requires new or altered streetlights in conjunction with permits issued for a new main building on a lot located at the corner of an intersection, on a lot that makes up 50% or more of the frontage of a block, or on lots with at least 100 feet of street frontage. This requirement does not apply to lots with two or fewer residential units, and may be waived if the Public Works Director determines that existing streetlights are Council Agenda Report
Amend Street Improvement and Permitting Requirements [Ordinance Introduction] February 13, 2024

adequate for public safety, or because of the circumstances of the surrounding neighborhood.

Chapters 22.32, 22.46, and 22.60
Recommended updates to the Addition of Chapter 22.46 relating to Acquisition of Property for Public Improvements, Chapter 22.60 relating to Permits for Work on Street and Sidewalks, and Chapter 22.32 relating to Building Numbering include:
o Defining staff roles and delegation of authority for reviewing and permitting street dedications and improvements, as well as processing financial transactions/securities and acquisitions.
o Removing antiquated language with the intent to make the chapters easier to understand and interpret for City staff, the public, and developers.

Chapter 10.56: Impounding Property Obstructing Streets
Chapter 10.56 addresses obstructions to sidewalks. Staff recommends updating Section

10.56.010 to allow the Public Works Department to immediately remove or impound any items interfering with the pedestrian through zone (walking area) of a sidewalk.

All new ordinance text is underlined. Non-applicable or antiquated language is in strikethrough text.

BUDGET/FINANCIAL INFORMATION:

The proposed changes will not have a significant financial impact on the City, staff resources, or maintenance budgets.

SUSTAINABILITY IMPACT:

Updates to the improvement standards to the sidewalk corridor in Chapter 22.44 are consistent with the Circulation Element of the City’s General Plan, the PMP, BMP, and City Council’s Santa Barbara Vision Zero Strategy (Vision Zero). The sidewalk improvement standards provide a sustainable mode choice for residents and visitors, which is consistent with the comprehensive goal and vision of the Circulation Element of the City’s General Plan, which states, “While sustaining or increasing economic vitality and quality of life, Santa Barbara should be a city in which alternative forms of transportation and mobility are so available and attractive that use of an automobile is a choice, not a necessity.”
The sidewalk improvement standards are consistent with the PMP’s pedestrian design guidelines, which will result in development projects providing pedestrian environments that are attractive, functional, and accessible to all people.

Council Agenda Report
Amend Street Improvement and Permitting Requirements [Ordinance Introduction] February 13, 2024

Finally, the sidewalk improvement standards are consistent with Vision Zero, which aims to eliminate severe injuries and fatalities on City streets. Providing sidewalk improvements provides a safe, predictable, and comfortable pedestrian environment.

On larger areas of the PROW, the sidewalk improvement standards provide opportunities for additional street trees. Street trees help provide character, shade, and have many environmental benefits to the City’s urban forest in reducing the heat island effect, sequestering carbon, reducing pollution, and capturing and storing storm water.

ENVIRONMENTAL REVIEW:

The Ordinance amendments related to physical changes in the right of way are considered to be exempt under Class 1: Existing Facilities (State CEQA Guidelines Section 15301), New Construction or Conversion of Small Structures (State CEQA Guidelines Section 15303), and per SBMC Section 22.100.070, List of Ministerial Projects and Categorical Exemptions.

PREPARED BY: Sarah Clark, Public Works Downtown Manager/JWG/AH/nv Brian D’Amour, P.E., City Engineer
SUBMITTED BY: Clifford M. Maurer, P.E., Public Works Director APPROVED BY: City Administrator’s Office
Council Introduction Draft
Showing Changes from Current Code
02/13/24
1 ORDINANCE NO. _________

AN ORDINANCE OF THE COUNCIL OF THE CITY OF SANTA

BARBARA AMENDING THE SANTA BARBARA MUNICIPAL
CODE BY AMENDING CHAPTER 22.44 RELATING TO STREET

DEDICATION AND IMPROVEMENT REQUIREMENTS,
CHAPTER 22.60 RELATING TO PERMITS FOR WORK ON
STREET AND SIDEWALKS, CHAPTER 22.32 RELATING TO
BUILDING NUMBERING, SECTION 22.64.010 RELATING TO

GATES ADJACENT TO STREET OR SIDEWALKS, SECTION

27.08.010 RELATING TO SUBDIVISION REQUIREMENTS FOR
STREETS AND SIDEWALKS, SECTION 10.56.010 RELATING TO

OBSTRUCTIONS OF SIDEWALKS, AND BY THE ADDITION OF
CHAPTER 22.46 RELATING TO ACQUISITION OF PROPERTY

FOR PUBLIC IMPROVEMENTS

THE CITY COUNCIL OF THE CITY OF SANTA BARBARA DOES ORDAIN AS FOLLOWS:

Section 1. Chapter 22.44 of Title 22 of the Santa Barbara Municipal Code is amended to read as follows:

Chapter 22.44

STREET DEDICATION AND IMPROVEMENT REQUIREMENTS FOR BUILDING

PERMITS

22.44.005 Purpose and Definitions

22.44.010 Dedication and Improvement Requirements Scope and Applicability.

22.44.020 Exceptions

22.44.030 Dedication Procedure.

22.44.040 Improvement Procedure.

22.44.050 Issuance of Building Permits.

22.44.060 Lots Affected by Street Widening.

22.44.070 Improvement Standards.

22.44.080 Appeal.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
2 22.44.005 Purpose and Definitions.

A. The purpose of this Chapter is to implement the Circulation Element of the General Plan, the Bicycle Master Plan, and the Pedestrian Master Plan by establishing requirements for dedication and improvement of public right of way in connection with the construction or reconstruction of buildings for which a building permit is required. The provisions of this Chapter are supplemental to the dedication and improvement requirements for the subdivision of property under Title 27 or as the condition of a development permit or approval under Title 28 or Title 30 of this Code.

B. The following definitions apply to the interpretation of this Chapter:

1. NEW MAIN BUILDING. This includes any new main building, or substantial redevelopment (as defined in paragraph 7, below) of, or addition greater than 500 square feet to an existing main building, that requires a building permit under Chapter

22.04 of this Code for which the construction cost exceeds $100,000 as determined by building permit valuation.

2. PUBLIC IMPROVEMENTS. This includes sidewalks, parkways, gutters, pavement, driveways, curbs, streets, alleys, public utilities (including relocation of existing utilities), storm drain facilities, street lighting, fire protection installation, and pavement transitions.

3. PERSON. Any person, entity, firm, partnership, association, corporation, company or organization of any kind.

4. PUBLIC WORKS DIRECTOR. The Public Works Director and any employee of the Public Works Department to whom the Public Works Director has delegated authority to enforce or implement this Chapter.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
3 5. .A person having legal or equitable title or other ownership interest to real property.

6. SIDEWALK CORRIDOR. The area from the boundary of the right-ofway and the edge of the closest curb or roadway if there is no curb. The Sidewalk Corridor contains four distinct zones: the Curb Zone, the Furnishings Zone, the Through Pedestrian Zone, and the Frontage Zone.
a. CURB ZONE defines the area between the sidewalk and the edge of the street pavement or gutter.
b. FURNISHING ZONE lies between the Curb Zone and the
Through Pedestrian Zone. All fixtures and street furniture must be contained in the Furnishing Zone to keep the Through Pedestrian Zone free for pedestrians. The Furnishing Zone may also include areas for the loading and unloading of persons or freight.
c. THROUGH PEDESTRIAN ZONE is the sidewalk area
intended for pedestrian travel and is located between the Furnishing Zone and Frontage Zone. This zone must be free of permanent and temporary objects. d. FRONTAGE ZONE is the area between the Through
Pedestrian Zone and the building. The frontage zone may exist on private property if unobstructed by buildings or by fences or walls greater than 42 inches in height.

7. SUBSTANTIAL REDEVELOPMENT. This has the meaning
described in Section 30.140.200 of this Code.

22.44.010 Dedication and Improvement Requirement.Scope and Applicability.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
4 A. This chapter shall apply in all zones other than the A, E, R-1, or R-2 zones as set forth in Ordinance No. 3710 (the Zoning Ordinance) of the City, as amended.

Except as otherwise provided in this Chapter, no building or structure shall be erected, reconstructed, structurally altered or enlarged, and no building permit shall may be issued for a new main building as defined in Section 22.44.005 B. 1. therefor on any lot , if such lot abuts a public street or right-of-way for public street purposes, unless one-half (1/2) of such the public street or dedicated street right-of-way abutting such the lot has been dedicated and improved so as to meet the objective standards, conditions, and policies of this Chapter. for such street as provided in Section 22.44.080, or the such dedication and improvement has been assured to the satisfaction of the Public Works Director. If a lot is not located on a public street, the access for the lot must be improved to meet minimum vehicle access dimensions and surfacing standards of the California Fire Code as adopted under Section 8.04.010 and amended under Section 8.04.020 of this Code, the City’s Parking Access and Design Standards, and the parking design standards established under Titles 28 or 30 of this Code.

B. As a condition to issuance of a building permit for construction of a new main building on a lot, the owner of the lot must have provided the rights-of-way necessary to meet the requirement of Subsection A of this Section by means of a deed, an irrevocable offer of dedication, or other appropriate conveyance instrument as approved by the City Attorney. Rights-of-way shall also be provided for any improvements to existing facilities, including rights-of-way for storm drains or other required public facilities. All rights-of-way dedications must be accompanied by a title examination and be free of all liens and encumbrances and a processing fee in an amount set by City Council resolution. The Council Introduction Draft
Showing Changes from Current Code
02/13/24
5 maximum area of land required to be so dedicated shall not exceed 25% of the area of the any such lot. In no event shall such dedication as required herein reduce the lot below an area of 6,000 square feet.

C. No such dedication shall be required with respect to those portions of such a lot occupied by a main building. As a condition to issuance of a building permit for a new main building on a lot, the owner of the lot must construct or cause to be constructed in accordance with city specifications upon the lot and along all street frontages adjoining the lot upon which the new main building will be constructed, unless adequate improvements already exist as determined by the Public Works Director.

D. No additional street improvements shall be required in connection with the issuance of a building permit as set forth herein where the abutting street is satisfactory in its right-of-way width including existing street pavement, curbs, curbs and gutters, and sidewalks and where such existing improvements are contiguous to the lot represented in such building permit application.

E. No building or structure shall hereafter may be erected on any such a lot within the street right-of-way, limits, area of an irrevocable offer of dedication, or within the additional widening limits of street right-of-way as required by this Chapter, except pursuant to an encroachment permit issued pursuant to this Code.

E. New or altered street lighting, in accordance with Public Works Construction Standard Details is a required improvement for lots that are located at a corner of two or more intersecting public streets, or lots having 50% or more of the frontage of a block, or lots having at least 100 feet of street frontage, unless the Public Works Director determines that new or altered street lighting is not required because existing street lights Council Introduction Draft
Showing Changes from Current Code
02/13/24
6 are adequate for public safety or because of the circumstances of the neighborhood in which the lot is located. New or altered street lighting is not required for building permits on a lot having two or fewer residential units.

F. Buildings for which a complete building permit application was filed with the Community Development Department before March 6, 2024, will be subject to the dedication and improvement requirements of this Chapter in effect on the date of the application.

22.44.020 Exceptions.

A. The provisions of Section 22.44.010 shall not apply to the following construction:

A. One single-family dwelling or duplex with customary accessory buildings when erected on a vacant lot
B. Additions and accessory buildings incidental to a residential building legally existing on the lot, provided no additional dwelling units or guest rooms are created; C. Additions and accessory buildings incidental to other than a residential building existing on the lot, provided the total accumulative floor area of all additions and accessory buildings shall not exceed 25% of the floor area of existing buildings;

1. Building permits for structures other than a new main building as defined in Section 22.44.010.

2. Building permits for single unit residential buildings located on a lot where the adjoining lots do not have an existing curb, gutter, and sidewalk.

B. The City Engineer may waive the requirement for construction of sidewalk improvements due to any of the following reasons:

Council Introduction Draft
Showing Changes from Current Code
02/13/24
7 1. It is in the City’s interest to include the sidewalk improvements in a pending street or utility construction project.

2. Construction of the sidewalk improvements would interfere with existing storm drainage or major public utility facilities and the relocation or reconstruction of the facilities is not reasonably feasible without the expenditure of public funds.

3. Construction of sidewalk improvements would require removal of a mature tree protected under Chapter 15.24.

4. Construction of sidewalk improvements would create a dangerous condition or is currently not in the public interest due to the grade, topography, or other conditions of the lot or adjacent lots.

5. Construction of the sidewalk improvements would adversely impact a historic structure or resource.

The City Engineer’s determination must be in writing stating the facts upon which the determination is made.

22.44.030 Dedication Procedure.

A.Any person required to dedicate land by the provisions of this Chapter shall make an irrevocable offer to dedicate or other appropriate conveyance instrument approved by the City Attorney and Public Works Director. for street right-of-way purposes including street right-of-way widening purposes, and such The offer or other instrument must shall be properly executed by all parties of interest including beneficiaries and trustees in deeds of trust as shown by current preliminary title report prepared by a title company, approved by the City for that purpose Such report shall be furnished by the applicant in the course of application for a building permit. Such offer shall be on a form Council Introduction Draft
Showing Changes from Current Code
02/13/24
8 approved by the City Attorney and the Public Works Director and shall be in such terms as to be binding on the owner of the lot involved, the owner’s heirs, assignees or successors in interest. and shall continue until the City Council accepts or rejects such offer or until six months from the date such offer is filed with the Public Works Director, whichever occurs first. The offer shall provide that the dedication shall be completed upon acceptance by resolution adopted by the City Council, after which the fact of such offer and acceptance shall be recorded by the City in the Office of the County Recorder. Upon recordation of the offer and acceptance of such street right-of-way, the Building Division and other City departments concerned shall proceed with the examination of the building permit application and complete the processes under such application including the issuance of such permit. Should a building permit not be issued in connection with saidan application or ansuch application be withdrawn by the applicant within six months, in either case from the date of recordation of the street right-of-way dedication and acceptance, the applicant for such building permit shall be issued a release from such dedication requirement and the right-of-way so recorded shall then be relinquished by the City to the owner of the lot involved in the application for building permit. The City will not accept the offer of dedication or conveyance by other instrument before issuance of the building permit.

B. For purposes of this section, dedication and acceptance of such right-of-way shall be considered as satisfactorily assured when the City Council accepts such dedication by resolution.

22.44.040 Improvement Procedure.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
9 A. When the estimated cost of the public improvements required under Section

22.44.010 is $25,000 or less as determined by the City Engineer, the improvements must be constructed before the issuance of a final inspection or certificate of occupancy. When the cost of the public improvements required under Section 22.44.010 is greater than $25,000 as determined by the City Engineer, the work must be completed before the issuance of a final inspection or certificate of occupancy, or the owner may enter into a secured agreement to construct all required improvements by a later date is established by the Public Works Director in the secured agreement. The secured agreement must be in a form approved by the City Attorney. All improvements must be constructed pursuant to plans approved by the City Engineer.

Any person required to make improvements by the provisions of this section shall make and complete the same to the satisfaction of the Public Works Director prior to the issuance of an occupancy permit by the Chief of Building and Zoning; provided, that where such improvements are not required to be immediately installed, such person shall file with the City Clerk a bond in such an amount as the Public Works Director shall estimate and determine to be necessary to cause the completion of such future improvements.

B. An agreement to construct must be secured by one of the following:

1. A bond or bonds by one or more duly authorized corporate sureties authorized to do business in California, in a form approved by the City Attorney.

2. A with a responsible escrow agent or trust company approved by the City, of cash or negotiable instruments of the kind approved for securing deposits of public money.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
10 3. An irrevocable letter of credit from one or more responsible financial institutions regulated by the federal or state government, pledging that the funds are guaranteed for payment on demand by the city, in a form approved by the City Attorney and from a financial institution approved by the Finance Director.

The security must be in an amount equal to the cost of the required improvements as estimated by the building permit applicant and approved by the City Engineer.

Such bond may be either a cash bond or a bond executed by a company authorized to act as a surety in the State. The bond shall be payable to the City and be conditioned upon the faithful performance of any and all work required to be done, and that should such work not be done or completed within the time specified, the City may at its option cause the same to be done or completed, and the parties executing the bond shall be firmly bound under a continuing obligation for the payment of all necessary costs and expenses incurred in the construction thereof. The bond shall be executed by the owner of the lot as principal, and if a surety bond, shall also be executed by a corporation authorized to act as a surety under the laws of the State.

C. Whenever the owner elects to deposit a cash bond, subject to the approval of the City Council, the City is authorized in the event of any default on his or her part to use any or all of the deposit money to cause the required work to be done or completed and for payment of all incidental costs and expenses therefor. Any money remaining following completion of the required street improvement shall be refunded.

DC. When a substantial proportion of the presently required improvement has been completed to the satisfaction of the City Engineer Public Works Director, and the completion of the remaining improvements is delayed due to conditions beyond the Council Introduction Draft
Showing Changes from Current Code
02/13/24
11 owner’s control, the Public Works Director may accept the completed portion and reduce the improvement security to account for the completed work; provided, however, that the security will not be reduced to less than an amount sufficient to cover the one year warranty obligation under Section 22.60.030. recommend acceptance of the completed portions and the City Council may, upon such recommendation, authorize a bond in an amount estimated and determined by the Public Works Director to be adequate to assure the completion of the required improvements required to be made.

ED. The Public Works Director is authorized to administer and enforce this Chapter and to:

1. Execute improvement agreements, subject to approval as to form by the City Attorney.

2. Administer and enforce improvement agreements.

3. Accept and release security for improvement agreements.

4. Accept completed improvements upon recommendation by the City Engineer.

5. Complete improvements upon default of an improvement agreement either through City forces or by contract. Contracts under this provision may be let to any qualified contractor without a requirement for bidding.

6. Accept, or conditionally accept subject to completion of improvements, offers of dedication and other instruments conveying rights-of-way, in a form approved by the City Attorney.

F. The terms of the bond obligation shall begin upon the deposit of cash or the filing of the surety bond and shall end upon the date of completion to the satisfaction of Council Introduction Draft
Showing Changes from Current Code
02/13/24
12 the Public Works Director and acceptance by the City Council of all improvements required to be made. The fact of such completion shall be endorsed by a statement thereof signed by the Public Works Director, and the deposit, if any shall be returned to the owner or the surety bond may be exonerated at any time thereafter.

G. For purposes of the section, improvements shall be considered as satisfactorily assured when the Public Works Director or the City Council accepts the cash or surety bond provided for herein or the improvements required to be made have been completed to his or her satisfaction. Upon acceptance of either the cash bond or surety bond and evidence of the deposit of either with the City, the Public Works Director shall notify the Chief of Building and Zoning thereof.

22.44.050 Issuance of Building Permits.

A. A person applying for a building permit must pay a fee in an amount established by City Council resolution for the reasonable costs of administration of this Chapter and inspection of improvements.

B. When all dedication and improvements required by this Chapter have been completed or satisfactorily guaranteed as to completion, a building permit may be issued, provided all structural and zoning requirements directly applicable to the building permit have been satisfactorily complied with.

C. An entity exempt from the issuance of a building permit shall comply with the requirements of this Chapter before occupancy of a new building or substantial reconstruction of an existing building.

22.44.060 Lots Affected by Street Widening.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
13 On a lot which is affected by street widening required by the provisions of this chapter, all required yards, setbacks, parking area, loading space and building locations for new buildings or structures or additions to buildings or structures shall be measured and calculated from the new lot line created by said widening; however, in applying all other provisions of this Chapter, the area of such lots shall be considered as that which existed immediately prior to such required street widening.

22.44.08070 Public Improvement Standards.

A. The following dimensional street standards and improvements shall be applicable in the requirement for dedication and improvement, as required by this Chapter, and by the street deficiency study of the City made pursuant to Section 2156 of the Streets and Highways Code, on file in the Office of the Public Works Director, and shall include proposed street right-of-way to be acquired as well as existing street rightof-way. When this Section requires measurement from a curb face, the measurement will be taken from the existing face of curb, except in the case of a new street or where street widening is part of the improvements, in which case the measurement will be based on the new face of curb.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
14 TABLE 22.44.070.A: Public Improvement Standards
Right
of
Way
Width
Standards Illustration
100
feet or
more
Each one-half of the street shall consist of not less
than 32 feet of paved section measured between
curb faces. The sidewalk corridor width shall be a
minimum of 15 feet including:
 6-inch curb,
 4 feet or more of furnishing zone,
 8 feet or more of through pedestrian zone,
and
 2.5 feet of frontage zone.

The frontage zone may be located on the lot
adjacent to the right-of-way. Where outdoor dining
seating is desired, the frontage zone may be
wider, so long as the through pedestrian zone is
maintained. The remaining right of way area may
be used as a portion of divider or median strip
width.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
15 TABLE 22.44.070.A: Public Improvement Standards
Right
of
Way
Width
Standards Illustration
80 to
99 feet
Each one-half of the street shall consist of not less
than 30 feet of paved section measured from the
center line of pavement to the curb face. The
sidewalk corridor width shall be a minimum of 15
feet including:
 6-inch curb,
 4 feet of furnishing zone,
 8 feet of through pedestrian zone, and
 2.5 feet of frontage zone.

The frontage zone may be located on the lot
adjacent to the right of way. Where outdoor
dining seating is desired, the frontage zone
may be wider, so long as the through
pedestrian zone is maintained.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
16 TABLE 22.44.070.A: Public Improvement Standards
Right
of
Way
Width
Standards Illustration
60 to
79 feet
Each half of the street shall consist of not less than
20 feet of pavement measured from the center line
of pavement to the curb face. The sidewalk
corridor width shall be a minimum of 12 feet
including:
 6-inch curb,
 4 feet of furnishing zone,
 6 feet of through pedestrian zone, and
 1.5 feet of frontage zone.

The frontage zone may be located on the lot
adjacent to the right of way.
50-59
feet
Each half of the street shall have a paved width of
not less than 17 feet measured from the center
line of pavement to the curb face. The sidewalk
corridor width shall be a minimum of 11 feet
including:
 6-inch curb,
 4 feet of furnishing zone,
 6 feet of through pedestrian zone, and
 6 inches of frontage zone.

The frontage zone may be located on the lot
adjacent to the right of way.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
17 1. STREETS HAVING A RIGHT-OF-WAY WIDTH OF NOT LESS THAN 100 FEET. Each one-half of the street shall consist of not less than 32 feet of paved section measured between curb faces and not less than 10 feet of sidewalk and parkway area of which at least five feet shall be paved. The remaining eight feet may be utilized as a portion of divider or median strip width.

2. STREETS HAVING A RIGHT-OF-WAY WIDTH OF NOT LESS THAN 80 FEET AND A PAVED ROADWAY WIDTH OF NOT LESS THAN 60 FEET. Each one-half of the street shall consist of not less than 30 feet of paved section measured from the center line of pavement to the curb face, together with a parkway and sidewalk area measuring 10 feet from the curb face to the street right-of-way line with concrete sidewalks constructed within such area to the width currently required by the Zoning Ordinance (No. 3710) and the Santa Barbara Municipal Code.

3. STREET RIGHTS-OF-WAY HAVING A RIGHT-OF-WAY WIDTH NOT LESS THAN 60 FEET WITH A PAVED ROADWAY WIDTH OF NOT LESS THAN 40 FEET WITH A SIDEWALK AREA OF 10 FEET ON EACH SIDE OF THE PAVED SECTION. Each half of the street shall consist of not less than 20 feet of pavement measured from the center line of pavement to the curb face, and 10 feet of sidewalk and parkway area with not less than five feet of sidewalk.

4. A STREET RIGHT-OF-WAY NOT LESS THAN 54 FEET WITH A PAVED WIDTH OF NOT LESS THAN 34 FEET MEASURED FROM CURB FACE TO CURB FACE. Each half of the street shall have a paved width of not less than 17 feet measured from the center line of pavement to the curb face and including 10 Council Introduction Draft
Showing Changes from Current Code
02/13/24
18 feet of sidewalk and parkway area where the minimum width of sidewalk shall be five feet or such dimension as required by the Zoning Ordinance or the Santa Barbara Municipal Code provisions as related to the zoning for the abutting property.

B. All construction of improvements required under this Chapter to be made by the provisions of this section shall be done in accordance with the applicable provisions of as set forth in the Public Works Construction Standard Details standard specifications and/or standard plans on file in the Public Works Department of the City and as set forth under the applicable sections of and pursuant to a permit issued under Chapter 22.60 of the Santa Barbara Municipal this Code.

C. The Public Works Director City Engineer may approve and allow such variations and deviations from the aforesaid requirements of this Section as he or she determines are made necessary because of by the conditions of the terrain and the existing improvements contiguous to the property involved.

22.44.09080 Appeal.

Any person may appeal any determination of the Public Works Director made in connection with the administration and enforcement of the improvement provisions of this Chapter by making such appeal to the City Council pursuant to the provisions of Section

1.30.050 of this Code.

SECTION 2. Title 22 of the Santa Barbara Municipal Code is amended by adding Chapter 22.46 to read as follows:

Chapter 22.46

ACQUISITION OF PROPERTY FOR PUBLIC WORKS PROJECTS
Council Introduction Draft
Showing Changes from Current Code
02/13/24
19 22.44.010 Delegation of Authority

22.44.020 Compliance with Laws Governing Acquisition

22.44.030 Limitation

22.44.040 Acquisition by Eminent Domain

22.44.050 Scope

22.46.010 Delegation of Authority.

The Public Works Director may acquire real property necessary or convenient for an approved City project in accordance with the procedures established by this Chapter whenever the acquisition is consistent with any approved budget and funds have been appropriated. Inclusion of a capital project in an adopted budget constitutes authorization for the Public Works Director to acquire all real property necessary or convenient to implement the project subject to appropriation. A project subject to the California Environmental Quality Act or National Environmental Policy Act will not be deemed approved for the purposes of this Subsection until after completion of applicable environmental review.

22.46.020 Compliance with Laws Governing Acquisition.

The Public Works Director shall comply with applicable state or federal laws governing the acquisition of real property, including the relocation assistance act (California Government Code Section 7260 et seq.). Acquisitions under this Chapter must be for fair market value and by voluntary negotiation.

22.46.030 Limitation.

The Public Works Director may not acquire property contaminated with hazardous materials or hazardous waste unless a remediation plan has been approved by federal, Council Introduction Draft
Showing Changes from Current Code
02/13/24
20 state or local agencies with jurisdiction and the remediation plan will be implemented at the cost and liability of the person conveying the property, or unless the acquisition has otherwise been authorized by the City Council.

22.46.040 Acquisition by Eminent Domain.

When the City Council has adopted a resolution of necessity for acquisition of property by eminent domain, the Public Works Director and City Attorney are authorized to take all actions necessary to accomplish the acquisition, subject to appropriations.

22.46.050 Scope.

Acquisition of real property includes, without limitation, purchase, license, easements, acceptance of gift, dedication, or bequest, or any other lawful means of conveyance of any estate or interest in real property. The Public Works Director may execute, subject to approval as to form by the City Attorney, any contract, lease, easement, deed, license, certificate of acceptance or other document necessary to accomplish the transfer to the City of any estate, interest, or right in land to implement the authority delegated under this Chapter. Leases of property shall not exceed 5 years unless separately approved by ordinance adopted under Charter Section 521.

SECTION 3. Chapter 22.60 of Title 22 of the Santa Barbara Municipal Code is amended to read as follows:

Chapter 22.60 STREETS AND SIDEWALKS

22.60.010 Definitions.

22.60.020 Permit Required, Issuance, Time for Completion.

22.60.024030 Permit Required for House Moving or Heavy Load Transportation.

22.60.028040 Fees for Permits.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
21 22.60.030050 Warranty of Work.

22.60.070 Contractor to Notify Public Works Department to Inspect Before Commencement.

22.60.090060 Standards of Materials and Workmanship.

22.60.100 Standards of Material and Workmanship - Use of Portland Cement.

22.60.105 Applications to Make Curb Cut Exceeding 30 Feet.

22.60.110 Width of Sidewalks - Next to Business Property.

22.60.120 Width of Sidewalks - Next to Residential Property.

22.60.130 Minimum Thickness of Sidewalks.

22.60.140 Minimum Thickness of Driveways.

22.60.180070 Acceptance of Work Curing Construction, Etc., Defects.

22.60.190080 Permittee’s Duty to Protect Work.

22.60.200090 Closing Abandoned Access Openings in Sidewalks - Generally.

22.60.210100 Abandoned Access Openings - Notice to RestoreNotice to Close Access Opening - Appeal.

22.60.220 Abandoned Access Openings - Restoration - Determination and Appeal.

22.60.230110 Barricading Street During Paving, Prohibition of Parking, Detour of Traffic - Generally.

22.60.240 Notice of Closed Streets.

22.60.280120 Replacing Pavement.

22.60.290 Conditions of Granting Building Permit Applications or Subdivisions - Generally.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
22 22.60.130300 New Lots to be Served by Public Streets - Improvements and Construction Requirements for Subdivisions.

22.60.310140 Completion of Street Construction Before Issuance of Building Permit.

22.60.320150 Permit Required for Joining Private Street to Official Street System.

22.60.330160 City Personnel to Exert No Dominion Over Private Streets, Etc. - Position of Public Works Department.

22.60.010 Definitions.

For the purpose of this Chapter the following words shall have the meaning indicated:
“Commercial or business property” means all property excepting property containing three residential units or less, which property is used solely for residential purposes whether such units be in the same or different structures.

A. CONTRACTOR.A contractor licensed in accordance with Chapter 9 of Division 3 of the Business and Professions Code (Contractors License Law) of the State of California.

B. PERMITEE.A person who has obtained a permit authorized byunder this Chapter.

C. PERSON. Any person, entity, firm, partnership, association, corporation, company or organization of any kind, except an employee or contractor of the City performing work within the scope of their employment or retained services.

D. PUBLIC WORKS DIRECTOR. means the Public Works Director of the City of Santa Barbara or a person authorized by him or her. Includes the Public Works Director and any employee of the Public Works Department to whom the Public Works Director has delegated authority to enforce or implement this Chapter.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
23 E. PUBLIC WORKS CONSTRUCTION STANDARD DETAILS. The most current plans, drawings, diagrams, specifications, and other standards for construction of public improvements approved by the City Engineer and Public Works Director and on file in the Public Works Department.
“Residential property” means all property other than commercial or business property.

F. WORKING DAY. A day that City offices are open for business.

22.60.020 Permit Required, Issuance, Time for Completion.

A. Permit. No person shall construct, reconstruct, repair, remove, or replace any pavement, sidewalk, driveway, curb, gutter, or any other improvements in any public street, alley, court, right-of-way, utility easement, or public place within the City, or commence any excavation therein, or construct any improvements on public property, easements or rights-of-way owned or to be conveyed to the City without first making application for and obtaining a written permit from the Public Works Director to perform such work. The application must be accompanied by a fee in an amount established by City Council resolution.

B. Emergency Repairs. It is unlawful for any person to commence any work for which a permit is required by provision of this chapter until a permit for the subject work has been issued by the Public Works Department, except in those cases where Notwithstanding Subsection A, emergency repairs of work by public utilities or other excavation work necessary done for the protection of the public safety may be commenced immediately; provided, however that the person must notify the Public Works Department before commencement of the work if feasible and not later than 24 hours after commencement of the work. Further, require street excavation prior to issuance of Council Introduction Draft
Showing Changes from Current Code
02/13/24
24 a permit. This exception shall not apply to any such work done for the protection of public safety unless the person who performs such repairs or work files a complete application for a permit must be filed and, including the required fees paid, and charges, with the Public Works Department within three working days after commencement of work. commencing such repairs or work and obtains the required permit. The provisions of this Subsection B do not apply to water and sewer connection work, which are subject to the requirements of Title 14 of this Code.

C. Issuance. Permits under issued pursuant to Section 22.60.020 will only be issued only to:

1. A contractor with the appropriate classification required to perform the work for which the permit is issued; or

2. The owner of a singlefamily unit residence for the construction of a concrete sidewalk, driveway, curb and gutter adjacent to the parcel upon which said residence is located.

D. Time for Completion. All work pursuant to a permit must be completed to the satisfaction of the City Engineer within The time to complete the work for which the permit is issued will be 90 days after the date the permit is issued unless otherwise stated specified in writing on the permit or extended in writing by the Public Works Director. All work must be performed according to the day, hour, and duration limits stated the permit and shall be diligently pursued from start to finish without suspension of work of more than 5 working days unless approved in writing by the Public Works Director.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
25 E. A permittee must notify the Public Works Department and request inspection not less than 24 hours in advance of the commencement of work under a permit.

22.60.024030 Permit Required for Blasting, House Moving, or Heavy Load Transportation.

No person shall commence any blasting, house moving, or heavy load transportation for which a permit is required by this code or other ordinance of the City until a permit vehicle haul route for that work has been issued approved by the Public Works DirectorDepartment. A heavy load is defined as greater than 20,000 pounds per axle or 34,000 pounds for tandem axles. A permit may also be required for vehicle haul routes for work as stated in the conditions of approval for a development project or grading permit.

22.60.028040 Fees for Permits.

Permits The fees under this Chapter for permits authorized by this chapter and inspection charges shall be established will be established by resolution of the City Council in an amount not to exceed the reasonable cost of permit issuance and enforcement of this Chapter, including inspection costs. When a person fails to obtain a permit as required by Section 22.60.020, the person must pay an additional fee in the amount of the permit established permit fee to cover the additional costs of enforcement, inspection, and permit issuance. The fees for permits authorized by this chapter that are issued after the work has commenced shall be two times the amount of the fee normally charged for such a permit, except where emergency repairs and work are performed Council Introduction Draft
Showing Changes from Current Code
02/13/24
26 pursuant to Section 22.60.020.B of this chapter and a permit application has been filed in a timely manner as set forth in said subsection B.

22.60.030050 Warranty of Work.

A. If required by the Public Works Director, performance of work under a permit must be secured in a manner provided under Section 22.44.040, Subsection B.

Guarantee. Every permit shall include a warranty that there will be no failure of any work performed under the permit. The warranty period is one year following completion and acceptance of the work. The warranty is in addition to any other guarantee or warranty provided elsewhere by law. every permittee shall by provide a guarantee and warranty that there shall be no failure of any the work performed under that is authorized by a permit for a period of issued pursuant to Section 22.60.020 of this chapter within two years after the completion of such work. The permittee shall be exonerated from this warranty when it is determined, on appeal pursuant to Subsection C of this Section, that asuch failure of an improvement did not result from work performed by the permittee.

Whenever there is any failure of such work within said twoone-year period, the Public Works Department will give the permittee notice to repair such work to the satisfaction of the Public Works Department. A new onetwo-year warranty period by the permittee shall commence to run with the completion of repairs to any work that has been reconstructed or repaired pursuant to notice by the City.

B. Failure to Repair. If the permittee fails to repair or correct the failed work within 48 hours or within a greater time that is specified in the above notice, the City will have the failed work repaired and the costs will be charged to and paid by the permittee within 30 days after receipt of a billing from the City. If the permittee does not pay said Council Introduction Draft
Showing Changes from Current Code
02/13/24
27 billing, or has not posted adequate security to guarantee payment of said billing upon determination of an appeal, the permittee shall not be entitled to a permit under this chapter.

C. Appeal. A permittee may appeal any charges made under this chapter by filing a notice of appeal pursuant to the provisions of Section 1.30.050 of this code.

D. Current Address. A permittee must Every person who obtains a permit under this chapter shall notify the Public Works Department of any change of address within onetwo year after the completion of any work under such permit so that there can be prompt notification regarding any failed work.

22.60.070 Contractor to Notify Public Works Department to Inspect Before Commencement.

Before beginning the work as authorized by a permit required by Section 22.60.020, the permittee shall notify the Public Works Department and request inspection not less than 24 hours in advance of the commencement of such work.

22.60.090060 Standards of Materials and Workmanship.

The materials and workmanship of all improvements referred to in Section

22.60.020 shall under a permit must conform to the Public Works Construction Standard Details. current standards, specifications and requirements of the City Public Works Department as approved by the Public Works Director and on file with the City Clerk.

When required by Chapter 22.44, improvements must meet the dimension requirements of Section 22.44.080.

22.60.100 Standards of Material and Workmanship - Use of Portland Cement.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
28 No material other than Portland cement concrete shall be used for the permanent construction of sidewalks, driveways, curbs or curb and gutters in or adjacent to any street, alley, court or public place within the City.

22.60.105 Applications to Make Curb Cut Exceeding 30 Feet.

Applications to make curb cuts exceeding 30 feet in length will not be issued, unless approved by the City Administrator.

22.60.110 Width of Sidewalks - Next to Business Property.

Sidewalks contiguous to commercial or business property shall begin at the curb and extend the full width as required under Section 22.60.120, so as to leave no unpaved surface between the curb and sidewalk except as may be permitted by the City Council upon petition of the majority of the property owners abutting such street on the same side thereof within the nearest two intersections.

22.60.120 Width of Sidewalks - Next to Residential Property.

Sidewalks contiguous to residential property shall have the following minimum widths; provided, that the City Council may grant permission for a lesser width where circumstances require such reduction:

A. Six feet for streets having a right-of-way width of more than 60 feet.

B. Five feet for streets having a width of 60 feet or less.

22.60.130 Minimum Thickness of Sidewalks.

No sidewalk shall be less than three and one-half inches in thickness.

22.60.140 Minimum Thickness of Driveways.

The thickness of driveways shall be as follows:

A. To residential property, not less than six inches.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
29 B. To commercial or business property, not less than eight inches.

22.60.180070 Acceptance of Work., Curing Construction, Etc., Defects All work under a permit must be inspected and approved by the Public Works Director before acceptance by the City. The When the Public Works Director may requires a permittee to remove or replace s defective construction or materials removed or replaced before acceptance of the work. The warranty period under Section 22.60.050 will not begin until the work is finally accepted. from a job authorized under Section

22.60.020, the contractor shall make satisfactory replacement before the work shall be finally accepted.

22.60.190080 Permittee’s Duty to Protect Work.

The permittee shall adequately protect the work at all times and take all necessary precautions to prevent accidents during the progress thereof up to the time of final acceptance and he or she shall hold the City, its officers and employees free and save them harmless from any and all liability arising directly or indirectly out of or on account of the prosecution of the work performed under this Chapter. Protective measures shall include furnishing and maintaining adequate barriers, lights, signs, temporary bridges, guards, watchman and the maintenance of detours as the same may be required for the safe and satisfactory execution of the work and the protection of the public up to the final acceptance of the project. Surplus materials, equipment and debris shall be removed immediately following the completion of the work.

22.60.200090 Closing Abandoned Access Openings in Sidewalks. - Generally.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
30 The Public Works Director is authorized to inspect all existing driveways, entrances, entries and other access openings through curb lines to streets in the City, and when the use of adjacent property is abandoned, or consolidated with the use of other property, or changed in nature, so as to no longer require theany driveway, entrance, entry or access for the use of thesuch property, or creates an unsafe condition and there is alternative access to the property, the Public Works Director is hereby authorized to close, or order the property owner to close, such openings by replacing such curb, gutter, sidewalk or other work as is necessary to restore normal pedestrian, parking and gutter use. The Public Works Director may require a property owner to close a driveway and restore curb, gutter, and sidewalk as a condition of issuance of a building permit for the property.

22.60.210100 Abandoned Access Openings - Notice to RestoreNotice to Close Access Opening – Appeal.

Except when closure is in connection with issuance of a building permit, In any instance in which the Public Works Director must give the owner of the property served by a driveway or other access 30 days’ written notice of the Director’s intention to take action under Section 22.60.090. The notice must be given by first class mail, postage prepaid, to the property owner as shown on the last equalized assessment roll. The Public Works Director may also post notice on the property. The notice must advise the owner of the Director’s intended action and of the date by which the property owner may submit a request for a meeting with the Director to present reasons why the intended action should not be taken. If a property owner requests a meeting with the Director and is dissatisfied with the Director’s decision, the property owner may appeal the decision to Council Introduction Draft
Showing Changes from Current Code
02/13/24
31 the City Council under Section 1.30.050 of this Code.shall cause notice by registered mail to be sent to the owners of the property adjacent to the opening in the curb, the use of which has been abandoned and to the person in possession of such property, to the address where such property is located and where the proposed replacement is to be made. Such notice shall state the proposed replacement, the determination of abandoned use and the date of commencement of work of such replacement. In no instance shall the date so stated for commencement of such work be less than 30 days from the time of mailing such notice.

22.60.220 Abandoned Access Openings - Restoration - Determination and Appeal.

The determination of abandonment of use and required replacement by the Public Works Director as outlined in Section 22.60.210 shall be final; provided, that upon application by the property owner to the City Council and upon proper showing at a regular meeting thereof, the Council may grant such relief from such proposed replacement and restoration as in its judgement the exigencies of the case may demand. Any such application to the City Council must be filed with the City Clerk not more than 10 days after the property owner received the notice provided in Section 22.60.210.

22.60.230110 Barricading Street During Paving, Prohibition of Parking, Detour of Traffic – Generally.

Whenever any street or portion of street in the City is being improved by grading, paving or other street improvement the Public Works Department may barricade and close such street or any portion of the street, prohibit parking thereon and detour traffic for such length of time as may be necessary to complete such work of improvement or allow such work of improvement to harden properly, set or become in condition for travel.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
32 22.60.240 Notice of Closed Streets.

In all cases of closing streets pursuant to Section 22.60.230 t The Public Works Department shall place, or cause to be placed, barriers, obstructions, or legible notices to indicate the closed condition of the closed area.

22.60.280120 Replacing Pavement.

No person shall remove, disturb or displace any part of the bituminous, concrete, or asphalt pavement of any street within the limits of the City for laying pipes or conduit, repairing streets, or for any other purposes, unless pursuant to the Public Works Construction Standard Details. current standards, specifications and requirements authorized under Section 22.60.090 of this code.

22.60.290 Conditions of Granting Building Permit Applications or Subdivisions - Generally.

No building permit application or subdivision shall be granted, except upon compliance with the terms and conditions contained in this code.

22.60.300130 New Lots to be Served by Public Streets - Improvements and Construction Requirements for Subdivisions.

A. GENERAL REQUIREMENT. Each lot created by a subdivision as to which a tentative map is approved after December 16, 1986 shall front upon a public street constructed according to the applicable specifications for streets, unless (i) the lot is served by a private road, lane, drive or driveway which serves no more than two lots, or (ii) the advisory body or approval authority under Title 27 of this Code Planning Commission (or City Council on appeal) waives this requirement. All public street in a subdivision must meet the standards of Chapter 22.44 and be consistent with the Council Introduction Draft
Showing Changes from Current Code
02/13/24
33 Circulation Element of the General Plan, the Bicycle Master Plan, and the Pedestrian Master Plan. Private streets must, at a minimum, be improved as determined by the Fire Marshal to fire code standards as adopted under Section 8.04.010 and amended under Section 8.04.020 of this Code.

B. APPLICATION FOR WAIVER. An application for a waiver shall be made as part of an application for a tentative parcel map or tentative map under Title 27 of this Code. A property owner may file a request for a waiver of the requirement in subsection A above with the Public Works Department. The request shall contain all necessary information required by the Public Works Department and shall be accompanied by the required fee. The Public Works Director or the person designated by the Public Works Director shall review the request and recommend to the Planning Commission that the request should be (i) approved or approved with conditions which would allow the lots to be served by a private road, lane, drive or driveway, rather than a public street or (ii) denied.

C. HEARING. The advisory body or approval authority under Title 27 of this CodePlanning Commission, or City Council on appeal, shall consider that waiver request in connection with consideration of the tentative parcel map or tentative map. conduct a public hearing to determine whether the request should be (i) approved or approved with conditions which would allow the lots to be served by a private road, lane, drive or driveway, rather than a public street, or (ii) denied.

D. NOTICE. Not less than 10 days before the date of the public hearing, notice of the date, time and place of the hearing, location of the subject property and nature of the request shall be given to owners of (i) each lot abutting the subject property; (ii) any Council Introduction Draft
Showing Changes from Current Code
02/13/24
34 private road, lane, way or driveway needed for access to the subject property; and (iii) each lot abutting any such private roads, lanes, ways and driveways. For this purpose, the last known name and address of the owners as shown upon the last assessment roll of the County of Santa Barbara shall be utilized.

DE. FINDINGS. The Planning Commission, or City Council on appeal, may grant A waiver may be granted upon a finding of if it finds all of the following:

1. The proposed roadway, lane, drive, or driveway will provide adequate access to the subject property and other properties using said roadway, lane, drive or driveway.

2. The proposed roadway, lane, drive or driveway and adjacent paved areas will provide adequate access for fire suppression vehicles as required by applicable fire regulations, including but not limited to, turnaround area, width, grade and construction.

3. There is adequate provision for maintenance of the proposed private road, lane, drive or driveway by either of the following:
a. There is a recorded agreement that provides for adequate maintenance of said road, lane, drive or driveway, or
b. The owner of the subject property has agreed to adequately maintain said private road, lane, drive or driveway and said agreement has been or will be recorded prior to recordation of the final or parcel map.

4. The waiver is in the best interests of the City and will improve the quality and reduce the impacts of the proposed development.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
35 EF. REQUIRED CONDITIONS. If a waiver is granted, the following conditions shall be imposed:

1. The owner must execute and cause to be recorded on form provided by the City, a waiver of the right to protest the formation of an assessment district proposed for the purpose of street, roadway or related improvements.

2. The private roads, lanes, drives and driveways permitted under this section shall be constructed and installed in compliance with the Subdivision Design and Improvement Standards approved by resolution of the City Council.

3. The proposed private road, lane, drive or driveway has been or will be constructed to the standard approved by the Public Works Director and if the road, lane, drive or driveway has not been constructed, adequate improvement security to guarantee such construction has been given to the City’s Public Works Department.

4. An agreement for maintenance of the proposed private road, lane, drive or driveway, subject to the review and approval of the Public Works Director and City Attorney, has been or will be recorded.

FG. ADDITIONAL CONDITIONS. The advisory body or approval authority under Title 27 of this Code Planning Commission or City Council may impose other conditions on a waiver which are consistent with the intent and purposes of this Section.

H. APPEAL TO CITY COUNCIL. Any decision of the Planning Commission concerning a waiver request under this section may be appealed in accordance with the provisions of Section 1.30.050 of this code.

22.60. 140 Completion of Street Construction Before Issuance of Building Permit.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
36 No building permit shall be granted for building construction upon new lots or parcels created by a subdivision under Title 27 of this Code subject to the terms of Section

22.60.300 until all of the construction of required streets and private roads, lanes, drives and driveways has been completed or improvement security for such completion has been filed with and accepted by the Public Works Department, and in any event before issuance of a final inspection or certificate of occupancy.

22.60.320150 Permit Required for Joining Private Street to Official Street System.

No street, lane, alley, way, road, right-of-way, passage or thoroughfare shall be connected with the official street system of the City, without a written permit therefor issued by the Public Works Department. The word “street” as used in this Section shall be defined as any lane, alley, way, road, right-of-way, passage or thoroughfare serving more than two separate lots or parcels.

22.60.330160 City Personnel to Exert No Dominion Over Private Streets., Etc. - Position of Public Works Department.

No officer, agent or employee of the City shall perform any repair, maintenance, upkeep, or take any remedial or corrective action, nor exert any dominion, control or jurisdiction, nor to do any act upon or in connection with any street, lane, alley, way, road, right-of-way, driveway, passage or thoroughfare in the City which is not an official street of the City, as designated upon the official street map of the City. This shall not be construed to prevent the Public Works Department from carrying on its service functions pursuant to its rules and regulations, or from installing mains and incidental facilities in Council Introduction Draft
Showing Changes from Current Code
02/13/24
37 any such street, lane, alley, way, road, right-of-way, driveway, passage or thoroughfare within specially granted easements for use of the subsurface thereof.

SECTION 4. Section 27.08.010 of Chapter 27.08 of Title 27 of the Santa Barbara Municipal Code is amended to read as follows:

27.08.010 General.

A. The subdivider shall provide for the construction and installation of all improvements in the subdivision.

B. The improvements shall be constructed and installed in compliance with the Subdivision Design and Improvement Standards prescribed by resolution of the City Council which standards are incorporated herein by reference. Said standards have been prepared in booklet form and are available for public use and examination in the Office of the City Clerk.

C. All public street in a subdivision must meet the standards of Chapter 22.44 and be consistent with the Circulation Element of the General Plan, the Bicycle Master Plan, and the Pedestrian Master Plan. Private streets must, at a minimum, be improved to meet minimum vehicle access and surfacing standards of the California Fire Code as adopted under Section 8.04.010 and amended under Section 8.04.020 of this Code, the City’s Parking Access and Design Standards, and the parking design standards in the established under Titles 28 or 30 of this Code as determined by the Fire Marshal to fire code standards as adopted under Section 8.04.010 and amended under Section 8.04.020 of this Code.

SECTION 5. Chapter 22.32 of Title 22 of the Santa Barbara Municipal Code is amended to read as follows:

NUMBERING BUILDINGS
Council Introduction Draft
Showing Changes from Current Code
02/13/24
38 Sections:

22.32.010 Assignment of Numbers - When City Shall Affix at Owner’s Expense.

22.32.020 Failure to Place Number Unlawful.

22.32.030 Size, Color and Location of Numbers.

22.32.040 Numbering System Generally.

22.32.010 Assignment of Numbers. - When City Shall Affix at Owner’s Expense.

The City Engineer engineer shall have charge of the matter of numbering houses, buildings, unit, and other property. similar structures and shall, upon request, give any property owner or occupant of any house or building the number of his or her premises.

It shall be his or her duty to notify, in writing, householders and others to place proper numbers where required. Such notice shall state the number required, and upon their failure to place the number on the building he or she may cause the same to be done at the expense of the City, which expense shall be collected from the person liable therefor.

The property owner is responsible for posting the number assigned by the City Engineer. The City Engineer may order a property owner to place the number for a house, building, unit, or other property as required by this Chapter. The City Engineer may give the order to the owner in writing, by first class mail, postage prepaid, to the owner at the address as shown on the last equalized assessment roll.

22.32.020 Failure to Place Number Unlawful.

It is unlawful for Any an person owner of property to failingplace a number upon a building or separately addressed unitpremises owned or occupied by him or her within 10 days from the giving of the notice under mentioned in Section 22.32.010. by the City Engineer., shall be guilty of a misdemeanor .

Council Introduction Draft
Showing Changes from Current Code
02/13/24
39 22.32.030 Size, Color and Location of Numbers.

The numbers required by this chapter shall be plain Arabic numbers at least three inches in height meet the requirements of the California Building Code and shall be so located that they are clearly visible from the street. The numbers shall be in a color contrasting to the background on which they are placed.

22.32.040 Numbering System Generally.

All houses, buildings and developed lots fronting on streets or public thoroughfares shall be numbered in the following manner:

A. Beginning at State Street the lots, houses and buildings shall be numbered consecutively to the City limits on streets extending in northeasterly, northerly and southwesterly, southerly directions respectively. The even numbers shall be on the southeast or east side of streets running in a northeasterly or northerly direction respectively from State Street and odd numbers shall be on the northwesterly or westerly sides respectively of such streets. On streets running in a southwesterly or southerly direction from State Street, even numbers shall be on the northwesterly and westerly sides and odd numbers on the southeasterly and easterly sides respectively of such streets. One hundred numbers shall be assigned to each block beginning with number one at the opposite sides of State Street.

B. Beginning at Quinientos Street, lots, houses and buildings shall be numbered consecutively to the City limits on streets extending in northwesterly and southeasterly directions respectively. On streets northwesterly of Quinientos Street and generally parallel to State Street, the numbers shall be even on the northeasterly or northerly sides and odd on the southwesterly or southerly sides. On streets southeasterly Council Introduction Draft
Showing Changes from Current Code
02/13/24
40 of Quinientos Street and generally parallel to the prolongation of the southerly end of State Street, the numbers shall be even on the southwesterly side and odd on northeasterly side. One hundred numbers shall be assigned for each block starting with the number one on opposite sides of Quinientos Street and the numbers southeasterly of Quinientos Street shall be followed by the letter S.

C. Twenty-five feet frontage shall be allowed for each number; provided, that where a block exceeds 450 feet then fractional numbers may be used in such manner that the total of the numbers in a block shall not exceed 100. All avenues, alleys or other places occupied or used for residence or business purposes shall be numbered in a like manner, and the numbers shall correspond with the numbers in the block in which such avenues, alleys or places are situated.

D. Secondary addressing for individual unit numbers or letters in a house or building and formatting shall comply with the most current Postal Addressing Standards adopted by the United States Postal Service. The use of fractional numbers and other secondary addressing items that impact the United States Postal Service sorting operations is not permitted.

E. Addresses for electrical meter pedestals in the public right-of-way may be assigned an address that is not deliverable for mail per utility company requirements.

22.32.050 Mailboxes Generally.

Mailbox installations shall follow the United States Postal Service standards.

Roadway posts are permitted only in residential zones without sidewalks, unless otherwise authorized by the City Engineer. Mailboxes are subject to local postmaster Council Introduction Draft
Showing Changes from Current Code
02/13/24
41 approval and upon assignment of an address by the City Engineer, the property owner shall perform final registration steps with the Post Office to receive mail.

SECTION 6. Section 22.64.010 of Chapter 22.64 of Title 22 of the Santa Barbara Municipal Code is amended to read as follows:

22.64.010 Generally.

Each gate on or near the line of any public street or alley of the City shall be so hung that the same shall swing inward from such street or alley; or such gate shall be provided with a spring, or other arrangement, so as to make such gate self-closing, and so that the same shall not obstruct, or be liable to obstruct, the free use in the customary manner of any such street or alley, nor be, or liable to become inconvenient, injurious or dangerous to a person walking along any such street or alley, or the sidewalk. Gates must comply with the standards for placement and operation issued by the Public Works Director and on file with the Public Works Department, and height setback limitations specified in Titles 28 or 30 as applicable.

SECTION 7. Section 10.56.010 of Chapter 10.56 of Title 10 of the Santa Barbara Municipal Code is amended to read as follows:

10.56.010 Impounding of Miscellaneous Property in Streets, Etc. Authorized - Nuisance.

A. Except when otherwise authorized by this Code or a permit issued by the Public Works Director, any item placed or left in the through pedestrian zone of a sidewalk as defined in Section 22.44.005 B. 6. c. of this Code in a manner that interferes with the unobstructed use of the sidewalk is a public nuisance subject to immediate removal or impoundment by any employee of the Public Works Department.

Council Introduction Draft
Showing Changes from Current Code
02/13/24
42 B. In the event any property of any description, except a vehicle, whether an animal or other obstruction, shall be found existing, standing, parked, erected or lying in or upon any part of any public street, avenue, alley, sidewalk, thoroughfare, parkway, park or other public place within the City in violation of and contrary to any of the rules, regulations and ordinances of the City that are in effect, it is hereby declared to be a nuisance, and may be removed and conveyed by or under the direction of the Community Development Director, Public Works Director or a member of the Police Department, or a duly constituted agent thereof, to a designated place of impounding, to be kept until redeemed or sold as provided in this Chapter.

CITY OF SANTA BARBARA

COUNCIL AGENDA REPORT
AGENDA DATE: February 13, 2024
TO: Mayor and Councilmembers
FROM: Engineering Division, Public Works Department
SUBJECT: Design and Implementation Services for the El Estero Water Resource Center SCADA Upgrades Project [Agreement]
RECOMMENDATION:

That Council authorize the Public Works Director to execute a City of Santa Barbara Professional Services contract with Northern Digital, Inc., in the amount of $415,575 for design and implementation services for the El Estero Water Resource Center Supervisory Control and Data Acquisition Upgrades Project and authorize the Public Works Director to approve expenditures of up to $41,558 for extra services that may result from necessary changes in the scope of work, for a total expenditure authority of $457,133.

DISCUSSION:

Background
The El Estero Water Resource Center (El Estero) plays an essential role in protecting public health and the environment. El Estero is responsible for treating approximately six million gallons of municipal wastewater per day from the City of Santa Barbara (City). The plant sits on 13 acres in Downtown Santa Barbara and treats water to secondary standards for discharge to the Pacific Ocean, or to Title 22 standards for distribution into the recycled water system.

The treatment system consists of many complex process units and motorized equipment such as pumps, tanks, blowers, mixers, and instrumentation. The process is monitored and controlled by a series of remote Programmable Logic Controllers (PLC) throughout the plant. The information from all the instruments captured and controlled in these PLCs is read and trended by a Supervisory Control and Data Acquisition (SCADA) system. The SCADA system is made up of a combination of software packages and hardware within the plant. SCADA allows plant operators to remotely access and control equipment, trend historical data, and send alarms when a parameter is out of its acceptable range. The remote monitoring and control greatly improves the efficiency of plant operations through precise process adjustments, and allows operators to quickly respond to dynamic process conditions. The existing SCADA system at El Estero is nearing the end of its useful life Agenda Item No. 3
File Code No. 540.13
Council Agenda Report
Design and Implementation Services for the El Estero Water Resource Center SCADA Upgrades Project [Agreement]
February 13, 2024

and needs both software and hardware upgrades to mitigate critical system failures and cybersecurity risks.

Project Description
The El Estero SCADA Upgrades Project (Project) will result in a comprehensive upgrade of the existing SCADA system’s software and hardware at El Estero. The work will start with the review of a preliminary design previously prepared by another firm, including a review of the existing SCADA system to identify any gaps or areas for improvement.

Additionally, a system inventory will be conducted to make sure the proposed configuration for the software and hardware meets the City’s current and future needs.

System redundancy and cybersecurity will also be addressed at this stage. The selected configuration will be developed into a final design package that will serve as the implementation plan. The design package will include hardware and software specifications, an implementation plan including transition sequencing, start-up testing procedures, and other necessary documentation to procure and install the new system.

Once the final design package is complete, the necessary software and hardware upgrades will be performed according to the implementation plan. The software portion of the upgrades will involve updates to the main SCADA operating software, operator control screens, alarm callout system, data trending software, and reporting software to best meet the needs of the current and future plant operations. The hardware portion of the upgrades will replace much of the existing SCADA equipment at El Estero within existing buildings and cabinets. This includes replacing the servers, operator computer stations, and any needed hardware in PLC cabinets to meet the demands of the upgraded software.

Consultant Engineering Services
Staff recommends that Council authorize the Public Works Director to execute a contract with Northern Digital, Inc., (NDI) in the amount of $415,575 for design and implementation services, and authorize $41,558 for potential extra services, for a total expenditure authority of $457,133. The budget for the implementation phase work is based on assumptions made during the design phase. Depending on the final design package, the budget for the implementation phase may be subject to a future contract amendment that will require Council approval. Due to the specialized and technical nature of this work, it is recommended to retain the same firm for both the design and implementation of the work. Consultant continuity ensures key decisions and logic processes are upheld during implementation. Both portions of the work are considered professional services.

NDI is experienced in this type of work and was selected as part of a competitive Request For Proposals process that resulted in three proposals. Following the top-rated firm’s unsuccessful Project delivery, NDI was selected to finish the remaining design tasks and perform the implementation phase of the Project.

Council Agenda Report
Design and Implementation Services for the El Estero Water Resource Center SCADA Upgrades Project [Agreement]
February 13, 2024

BUDGET/FINANCIAL INFORMATION:

The following summarizes all Project costs:

ESTIMATED TOTAL PROJECT COST
*Cents have been rounded to the nearest dollar in this table.

Preliminary Design Cost (by previous Contract) $124,637 Final Design & Implementation Cost (NDI) 415,575
Extra Services Allowance (NDI) 41,558
Contract Work Subtotal $581,770
Estimated Project Administration (by City Staff) $100,000 Estimated Hardware and Software Procurement (through City IT) 200,000 City/Other Costs Subtotal $300,000
TOTAL PROJECT COST $881,770
There are sufficient appropriations in the Wastewater Capital Fund to cover these costs.

ENVIRONMENTAL REVIEW:

The proposed Project is limited to internal hardware and software updates to industry standards and would not result in a change to the City’s wastewater operating systems, an expansion in use or capacity, nor any direct or indirect physical changes in the environment. Therefore, this Project falls outside of the definition of a “Project” under California Environmental Quality Act (CEQA) Guidelines § 15378 (b)(2) as a continuing administrative or maintenance activity and is not subject to CEQA environmental review.

WATER COMMISSION RECOMMENDATION:

This item was presented to the Water Commission at its meeting on December 21, 2023, and the Commission voted 5:0:0 in support of staff’s recommendation.

A copy of the contract may be requested from the Public Works Department for public review by contacting [email protected].

PREPARED BY: Brian D’Amour, P.E., City Engineer/CSW/rl
SUBMITTED BY: Clifford M. Maurer, P.E., Public Works Director APPROVED BY: City Administrator’s Office

CITY OF SANTA BARBARA

COUNCIL AGENDA REPORT
AGENDA DATE: February 13, 2024
TO: Mayor and Councilmembers
FROM: Environmental Services Division, Sustainability & Resilience Department
SUBJECT: Update on the Management and Operation of the County’s ReSource Center at the Tajiguas Landfill
RECOMMENDATION:

That Council receive an update from the County of Santa Barbara on the management and operation of the ReSource Center at the Tajiguas landfill.

DISCUSSION:

The City of Santa Barbara, along with other cities in the region, partnered with the County of Santa Barbara to construct a Resource Recovery Project (ReSource Center), a stateof-the-art Materials Recovery Facility (MRF) and Anaerobic Digester (AD) at the Tajiguas landfill. The County owns and operates the facility. The City of Santa Barbara and other cities in the region are contractually committed to using the ReSource Center to process and dispose of solid waste, recycling, greenwaste, and other organic materials through 2038. The County contracted with MSB Investors, LLC (MSB) for the construction and operation of the project. However, due to multiple failures to perform in accordance with provisions of the contract, the County terminated their agreement with MSB effective January 3, 2024.

Project History
Staff from the County and the Cities of Santa Barbara, Goleta, Buellton, and Solvang worked together to explore the development of the ReSource Center since 2008. The goals of the ReSource Center are to significantly increase the diversion of trash from landfill disposal, thereby extending the life of Tajiguas, and providing a long-term waste management solution for the South Coast.

On July 12, 2016, the County executed a Waste Services Contract with MSB, to design, build, and operate the ReSource Center. The project consists of a MRF that would sort the trash and recover recyclable commodities and an AD that would convert organics recovered from the MRF into compostable material and biogas. To ensure payment of Agenda Item No. 4
File Code No. 630.01
Council Agenda Report
Update on the Management and Operation of the County’s ReSource Center at the Tajiguas Landfill
February 13, 2024

construction debt and the County’s financial obligations to MSB, each jurisdiction committed to deliver its waste and provide a revenue stream through the execution of a 22-year Materials Delivery Agreement (MDA) with the County. City Council approved the MDA in December of 2016. Due to a number of delays in the spring of 2017 and several facility redesigns, construction began in December 2018 and the ReSource Center became operational in summer 2021.

Termination of Agreement
On November 6, 2023, the County gave MSB a notice of intent to terminate their agreement for the development and operation of the ReSource Center (see Attachment 1). The letter cited five primary areas supporting their determination. These include:
1) Failure to cure breach of the agreement. Specifically, the Central Coast Regional Water Quality Control Board identified violations that MSB did not satisfactorily address, requiring the County to take over the project to comply with water quality regulations.
2) Failure to ensure the health and safety of all personnel and visitors. For example, MSB did not satisfactorily rectify safety deficiencies in preventing vehicular incidents, safety infrastructure systems were not properly maintained, and inadequate safety measures resulted in a compost fire that damaged equipment and infrastructure.
3) Project development delays and failed acceptance testing. Various milestones in the Project Development schedule were not met. Additionally, the ReSource Center has still not attained Full Operations, which required MSB to pass tests of Facility Reliability, Facility Capacity, Material Recovery, and Residue. 4) Non-payment to subcontractors, regulatory agencies, and the County. Several subcontractors and agencies have reached out to the County to indicate nonpayment by MSB. 5) Interference with the County’s ability to obtain permits for County projects.

Outstanding water quality violations and ongoing odor violations are interfering with the County’s applications to obtain and modify permits required for County projects.

On December 12, 2023, the Board of Supervisors for the County of Santa Barbara unanimously voted to terminate the Agreement with MSB. The County subsequently issued Final Notice of Contract Termination Effective January 3, 2024, and Transition of Operations (see Attachment 2). The County has hired MSB’s employees to continue to operate the AD Facility and Compost Management Unit at the ReSource Center during this transition. Under the terms of the Agreement, MSB is required to provide at least 180 days of transition services, such as training of personnel designated by the County and Council Agenda Report
Update on the Management and Operation of the County’s ReSource Center at the Tajiguas Landfill
February 13, 2024

attend meetings with the next service provider and with County staff, as may reasonably be necessary to enable the County or a new contractor(s) to safely and successfully commence Project Operations.

The County has made preliminary arrangements for operation of the ReSource Center during the transition period, until final agreements with new contractors are ready to go into effect.

BUDGET/FINANCIAL INFORMATION:

Receipt of this update has no budgetary impact.

The MDA with the County is still in effect and its terms are not changing. The MDA currently has provisions which cap the allowable increases in the “tipping fee” (the rate that the City and other partnering jurisdictions pay to the County per ton of materials delivered) at 5% per year. The increased costs of operation of the ReSource Center due to these events and other inflationary factors are likely to result in the maximum 5% annual increase to the tipping fee for the foreseeable future.

SUSTAINABILITY IMPACT:

The City’s participation in the ReSource Center is integral to managing our solid waste responsibly. It is a local solution that reduces transportation-related carbon emissions while producing renewable energy from the AD facility. It also extends the useful life of the Tajiguas landfill while diverting more recyclable materials for reuse and turning organic material into an agricultural input rather than a source of landfill-generated greenhouse gas emissions. Effective operation and performance of the ReSource Center is essential to meeting the City’s sustainability goals.

ENVIRONMENTAL REVIEW:

Receipt of this update has no environmental impact.

ATTACHMENTS: 1. Notice of Intent to Terminate Agreement between MSB Investors, LLC and the County of Santa Barbara for the Development and Operation of the Tajiguas Resource Recovery Project

2. Letter to MSB - Final Notice of Contract Termination Effective January 3, 2024 & Transition of Operations
PREPARED BY: Dustin Merback, Environmental Services Specialist II SUBMITTED BY: Alelia Parenteau, Sustainability and Resilience Director APPROVED BY: City Administrator's Office
Scott D. McGolpin
Public Works Director
Jeanette Gonzales-Knight
Technical Deputy Director, Interim
Martin Wilder
Operations Deputy Director, Interim
130 E. Victoria Street, Suite 100, Santa Barbara, CA 93101 • Main Phone: (805) 882-3600 • AA/EEO Employer Email: [email protected] • facebook.com/countyofsbpublicworks • www.LessIsMore.org November 6, 2023
John Dewey, CEO & Managing Member [US mail and emailed] MSB Investors, LLC
17 Corporate Plaza, Suite 200
Newport Beach, CA 92660
Email: [email protected]
SUBJECT: Notice of Intent to Terminate Agreement between MSB Investors, LLC and the County of Santa Barbara for the Development and Operation of the Tajiguas Resource Recovery Project
Mr. John Dewey,
This letter serves as formal notification of our intent to terminate the Agreement between MSB Investors, LLC (MSB) and the County of Santa Barbara (County) for the Development and Operation of the Tajiguas Resource Recovery Project (Project), also referred to as the ReSource Center, in accordance with Section 14.4 of the Agreement. The Agreement sets forth provisions related to default, material breach, opportunities to cure, and liquidated damages if the County at any time has reasonable cause to believe that MSB is not performing in accordance with the Performance Guarantees or with any other provisions of the Contract. The Resource Recovery and Waste Management Division will seek approval from the Santa Barbara County Board of Supervisors to terminate the Agreement on December 12, 2023. Contingent upon approval of the Board of Supervisors, the termination will be effective immediately and MSB shall cooperate fully with the County and any subsequent third-party Project operator that the County designates to assure a smooth transition of Project operations and management.

The County’s determination for Agreement termination pertains to the following items:

1. Failure to cure breach of the Agreement
MSB failed to complete the actions necessary to rectify violations issued by the Central Coast Regional Water Quality Control Board (CCRWQCB) on March 17, 2023 and June 20, 2023 within the permitted time to cure these breaches of the Agreement. The County provided a description and written explanation of non-compliance based on the CCRWQCB Notice of Violations (NOV) in letters dated April 25, 2023 and June 21, 2023 (see Attachment A). The County issued MSB a formal notification of the curable breach to the Agreement on June 21, 2023, with a deadline to rectify the violations by July 6, 2023.

The County has continued to meet with and communicate with MSB to try to resolve the violations issued by the CCRWQCB, and allowed MSB additional days to cure the breach prior October 1, 2023 (a total of 102 days). A brief timeline of communication on the matter is also included in Attachment A. MSB did not cure the breach to the Agreement by DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment 1 John Dewey
November 6, 2023

October 1, 2023 revised deadline and continues to operate the Compost Management Unit (CMU) in violation of the Waste Discharge Requirements (WDR) for Commercial Composting Operations (Order WQ 2020-0012-DWQ), jeopardizing the Project’s ability to operate and process acceptable waste. On October 11, 2023, the County notified MSB of its right to take over the CMU runoff pipe replacement project under Section 14.8 of the Agreement, citing its incomplete status and MSB's inactivity onsite for over 7 days.

2. Failure to ensure the health and safety of all personnel and visitors MSB failed to ensure the health and safety of all personnel working and persons visiting the Project site in accordance with Section 5.1.C.15, Section 5.7.B.1 through 7, Section

7.1.K, and Section 11.1.A of the Agreement, which has resulted in accidents, injuries, or hazardous conditions for employees and visitors (see Attachment B). On several occasions, vehicular incidents have occurred (e.g. MSB loader struck parked manlift on August 28, 2023, MSB loader backed into refueling truck on September 19, 2023). Despite receiving prior warnings in person and in bi-weekly Operations/Compliance conference calls, and notices to rectify safety deficiencies, MSB has not taken adequate corrective actions in a timely manner to mitigate the risks and ensure a safe working environment.

For example, MSB took over a year to rectify the poor lighting conditions in the Anaerobic Digester Facility (ADF) loading hall, and repair the corroded ADF fire suppression system that leaked in four locations.

MSB continues to exhibit poor housekeeping at the ADF and CMU and has demonstrated recklessness in ensuring a safe work environment. These inadequate safety measures were the cause of the May 12, 2022 compost fire that started with dry compost left too close to the Doppstadt screener on the CMU deck and damaged nearby equipment and infrastructure both at the Project and Tajiguas Landfill. MSB has shown a consistent pattern of disregarding health and safety protocols, posing an ongoing risk to the wellbeing of employees and visitors at the Project. This disregard was more recently observed on September 19, 2023 when CMU wastewater was being transported from the CMU Runoff Storage Tank to the ADF Percolate Tank by allowing the outflow from a pipe above the ADF entrance doors to splash onto the ADF tipping area, and drain into the ADF sump. A contractor was unloading organic material onto the ADF tipping area within 5 feet of the untreated CMU wastewater and not wearing personal protective equipment that would mitigate risks from coming into contact with pathogenic bacteria.

3. Project development delays and failed Acceptance Tests MSB failed to meet milestones set in the Project Development Schedule. The original development schedule included in the 3rd amendment required project completion, including passage of Acceptance Tests, by December of 2020. The County approved extensions of the development schedule to March 2021 due to Covid-19 (5th amendment), and further to November 2021 because of Project complexities (6th amendment). On July 5, 2022, the County provided a Notice of Intent to Assess Liquidated Damages for Ongoing Development Delay beginning August 1, 2022. Following subsequent meetings with MSB, the County agreed to stay a collection of the liquidated damages until December 31, 2022, based on MSB’s commitment to pass Acceptance Tests by that time.

DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
November 6, 2023

To date, MSB has not attained Final Acceptance nor Full Operations of the Project. The County issued a failed rating on March 1, 2023, and gave MSB additional time to provide evidence supporting its passage, which MSB failed to do. Project delays have contributed to the issuance of violations from multiple regulatory agencies (see Attachment C). Due to MSB’s inaction to resolve the violations, the County has had to engage contractors to complete corrective actions, such as the CMU runoff pipe replacement project aforementioned in Item #1.

MSB is responsible for all costs of preparing and implementing a County-approved compliance plan, any additional actions required to pass the Acceptance Test, and any additional costs to the County. Because MSB failed to develop a County-approved Compliance Plan as stipulated by Section 4.8 I. of the Agreement by the May 5, 2023 deadline, the County has engaged additional contractors to address the failures for the following four Acceptance subtests; 1) Facility Reliability Test, 2) Facility Capacity Test, 3) Material Recovery Test, and 4) Residue Test.

4. Non-payment to subcontractors, regulatory agency, and County Section 4.1 A. of the Agreement stipulates that “Unless otherwise specifically identified as the responsibility of a public agency or other party, Contractor is solely responsible for conducting and paying for all activities necessary for the timely Development of the Project Site and all related Project activities in accordance with the requirements of the Contract.” Section 4.1 C.3 further specifies that MSB is responsible for “Arranging for, managing, and paying for all work conducted by Subcontractors.” At this time, several subcontractors working for MSB have reached out to the County indicating non-payment by MSB, including regulatory agencies such as the Santa Barbara County Air Pollution Control District (see Attachment D). As of the last reporting from MSB to the County on August 15, 2023, the outstanding payables from MSB to subcontractors as of June 30, 2023 was $5.4 million, up from $4.3 million as of April 30, 2023.

Section 14.1 B. provides that the “County may, in the event that the Contractor breaches any material provision of the Contract and does not promptly cure said breach within any applicable period provided in this Contract, exercise any legal rights it has under the Contract and under Applicable Law to recover damages or to secure specific performance”. Non-payment of the Project’s subcontractors jeopardizes the Project’s ability to reliabily operate, be maintained, and meet Performance Guarantees set forth in the Agreement. Due to MSB’s non-payment to Diani Building Corp and their refusal to work for MSB (see Attachment D), the County has had to directly contract with and oversee the installation of the infrastructure for the SG MOBILE® System with GORE® Covers, and for maintenance and replacement of the MRF biofilter (upon Board of Supervisor approval on November 7, 2023).

In April 2023, the County issued a Notice to Assess Liquidated Damages for failure to pass Acceptance Tests and for Water Board violations, which liquidated damages were not stayed and as of November 1, 2023 amount to $1,103,000. MSB failed to submit DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
November 6, 2023

installments of $39,500 by September 23, 2023, $290,000 by October 6, 2023, and $420,000 by October 13, 2023.

5. Interference with the County’s ability to obtain permits for County projects MSB’s outstanding violations with the CCRWQCB and CalRecycle has interfered with the County’s ability to obtain and modify permits required for County projects. On September 19, 2023, the County received confirmation from the Local Enforcement Agency (LEA) that permitting for the proposed Tajiguas Landfill Capacity Increase Project could face delays and non-concurrence from CalRecycle due to ongoing odor violations at the ReSource Center (Attachment E). The County also rescinded its application to modify the Solid Waste Facility Permit on March 12, 2023 after being notified by the LEA on June 8, 2022 that CalRecycle would not give concurrence for the proposed Solid Waste Facility Permit modification due to violations issued for the Project.

In addition to the points listed above, the County has refuted and disagreed with the assertions made in MSB’s Annual Settlement documentation, particularly the cover letter and six of the nine of the attachments. The County does not believe that the disagreements between the County and MSB can be resolved in a timely manner without negatively impacting operations of the ReSource Center. Similarly, the County has engaged in good faith negotiations with MSB regarding a proposed 7th amendment to the Agreement for over 10 months, without resolution. The County does not believe that the basic functions of the Agreement, such as the Annual Settlement Process or amendments to the Agreement can be resolved at this time, making the Agreement unworkable and termination as the only possible conclusion.

MSB has inaccurately asserted that the County has not acted in good faith to support MSB in the successful construction, commissioning and operation of the ReSource Center. The following highlights the lengths to which the County has gone to support the efficacious completion and operation of this critical community asset:
 Payment of increased capital costs
Acting in good faith, the County paid additional capital costs for the construction of the Project based on Covid-19, the Alisal Fire, and complexities of the Project. In the 5th amendment, the County paid MSB an additional $5,757,819 in capital costs, and an additional $1,870,000 in the 6th amendment, for a total capital cost increase of $7,627,819.  Extended development schedule
As previously mentioned in Item # 3, the original development schedule demonstrated completion, including passage of Acceptance Tests, by December of 2020. The County approved the extension of the development schedule to March 2021 as a result of Covid19, and further again to November 2021 because of Project complexities. The total extension, granted in good faith by the County has amounted to 34 months, as well as a stay of collection of liquidated damages that would have resulted in $5,000 per day per missed milestone, totaling approximately $2.3 million.

DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
November 6, 2023

 Excessive disposal of organics
Due to MSB’s extended development schedule, over 36,000 tons of organics were disposed in FY 21/22. The disposal capacity taken by these tons equates to a loss to the Division of at least $5,500,000 in tipping fees and loss of limited airspace remaining at the Tajiguas Landfill. The County waived these tipping fees in consideration of Covid-19, the Alisal Fire and complexities related to the Project. In FY 22/23, MSB buried over 37,000 tons of organics, causing a value loss of at least $6,300,000 in tipping fees and loss of limited airspace.
 Payment of cash flow assistance
Under the contract terms, the County provided MSB with $2,494,673 in FY 22/23 to help with financial challenges stemming from the recyclables market fluctuations. MSB requested additional cash flow assistance for FY 22/23 and FY 23/24, but failed to provide the contractually required audited financial documentation by the deadline.  Odor minimization
The Board of Supervisors approved the procurement and installation of the SG MOBILE® System with GORE® Covers to address odors related to CMU operations. The County released $4.3 million in Retained Earnings from the Resource Recovery & Waste Management Division Enterprise Fund to fund the project. In addition, the County paid $240 thousand to contractors to haul and dispose of compost from the CMU after the 2023 Storm Events, and paid $200 thousand to contractors for an odor reducing enzyme for the compost windrows.

In compliance with the provisions outlined in the Agreement, we are required to notify you of our intent to terminate the Agreement and afford you an opportunity to present your case before the Board of Supervisors. The Board of Supervisors will convene to discuss and vote on this matter on December 12, 2023 at 9:00 am, or as soon thereafter as the matter may be heard, at the County Administration Building Board Hearing Room, located at 105 East Anapamu, Santa Barbara, California. During this meeting, you will have the opportunity to present your arguments and any relevant information in defense of the Agreement. Please ensure that all relevant documentation and supporting materials are submitted to the Clerk of the Board at [email protected] no later than 5 p.m. the day prior to the Board meeting.

As discussed over the past 12 months, the County recognizes that MSB does not have the experience to operate the ReSource Center according to industry standards and permit requirements. MSB has verbally expressed an interest in selling the Operational Agreement to another party, although has never submitted to the County the required documentation and deposit of $50,000 in accordance with Section 15.5 of the Agreement. The County formally reached out to MSB in letters dated March 29, 2023 and April 13, 2023 about potential assignment or willingness to discuss a settlement arrangement, to which MSB failed to reply.

Due to the need to protect the health and safety of our community by regularly collecting and managing municipal waste materials, the County will be exploring alternative operators for the DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
November 6, 2023

ReSource Center, contingent upon approval of the Board of Supervisors for termination of the agreement with MSB.

Pursuant to Section 15.20 of the Agreement, upon termination, MSB is responsible to:
 Deliver to County all computer data, files and tapes, reports, records, documents, and all written materials related to Operations at the Project Site. Please return these items by January 12, 2024.
 Promptly turn over all keys and security codes for access to property and Operations at the Project Site.
 Leave Project Site, facilities and Project equipment clean, intact and fully operable, and deliver possession of the Project Site as directed by County.  Vacate the Project Site, removing all Contractor property not related to Project Operations.  Transfer to the County or at the County’s request to a new contractor(s), the rights to use any and all patents, licenses, trade secrets, or other intellectual property necessary for all Operations at the Project Site.
 Deliver possession of any proprietary components needed for all Operations at the Project Site to the County or at the County’s request to the new operator.  Provide at least 180 days of transition services, such as training of personnel designated by the County and attend meetings with the next service provider and with County staff, as may reasonably be necessary to enable the County or a new contractor(s) to safely and successfully commence Project Operations.
 Pay all taxes due to appropriate parties including, but not limited to, State, County, Public Participants, and other local agencies.

Your timely attention is anticipated, as well as your diligence to continue operating the ReSource Center in a safe and effective manner as we aim to resolve these matters promptly for the successful progression of the Project.

Sincerely,
Jeanette Gonzales-Knight, PE Martin Wilder, PE
Technical Deputy Director Operations Deputy Director
cc: Scott McGolpin, Santa Barbara County Public Works Department Carlyle Johnston, Santa Barbara County Public Works Department

DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
November 6, 2023

Attachments:

Attachment A – Water Board Violations Communication Timeline Attachment B – Health and Safety Incident Reports
Attachment C – Notices of Violations
Attachment D – Non-payment to Subcontractors and APCD
Attachment E – Non-compliance Impacts to County Projects DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

ATTACHMENT A
Water Board Violations Communication Timeline

DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment A
Communication Timeline for Central Coast Regional Water Quality Control Board

 March 1, 2023 – The County of Santa Barbara (County) issues a failed Acceptance Test for the Tajiguas Resource Recovery Project (also referred to as the ReSource Center) and meets with MSB to review the incomplete requirements in order to satisfy the Stormwater Discharge subtest.
 March 17, 2023 – The Central Coast Regional Water Quality Control Board (CCRWQCB) issues a Notice of Violations (NOVs) to MSB for non-compliance with Waste Discharge Requirements (WDR) for Commercial Composting Operations (Order WQ 2020-0012-DWQ).
 April 7, 2023 - The County sends MSB a letter identifying the status of the failed the Acceptance Test and Stormwater Discharge subtest, and refers to corrective actions needed to rectify the CCRWQCB March 2023 NOVs. The County also gives notice to assess liquidated damages for delays with completion of Acceptance Testing.  April 19, 2023 - County, MSB, and CCRWQCB meet to discuss MSB's schedule to address NOV. MSB commits to resolving corrective actions after wet weather; estimated completion by May 31, 2023.
 April 25, 2023 – County provides notice to assesses liquidated damages for CCRWQCB NOVs, effective on April 26, 2023 and that liquidated damages would continue to be assessed until remedied.
 April 28, 2023 - County and MSB meet to address Acceptance Test and Compliance Plan, stormwater impacted by CMU runoff is a subtest and discussed.  May 2, 2023 – The County and MSB continue to discuss MSB’s non-compliance and status on addressing CCRWQCB NOVs in the scheduled bi-weekly Operations and Compliance meetings.
 May 3, 2023 - MSB requests for additional meeting.
 May 16, 2023 – The County and MSB continue to discuss MSB’s non-compliance and status on addressing CCRWQCB NOVs in the scheduled bi-weekly Operations and Compliance meetings (i.e. July 12, July 26).
 June 20, 2023 - The CCRWQCB issues a second NOV letter to MSB and additionally names the County as a responsible party. CCRWQCB asserts none of the original violations identified in the March 17, 2023 Notice of Violation letter were remedied by MSB.
 June 21, 2023 - County issues Notice of Curable Breach with a July 6, 2023 deadline to remedy all violations issued by the CCRWQCB, and refers to accruing liquidated damages.
 July 6, 2023 – MSB provides County update on corrective actions, disputes liquidated damages, and states remaining items will be remedied prior to October 1, 2023.  July 12, 2023 - County meet with MSB to discuss MSB's progress on corrective actions.  July 15, 2023 - Rincon Consultants on behalf of MSB submits a response to the CCRWQCB with update of corrective actions.

DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment A
Communication Timeline for Central Coast Regional Water Quality Control Board

 July 18, 2023 – County inspects MSB’s corrective actions; finds them to be incomplete.  July 26, 2023 – County, MSB, MSB’s consultants, and CCRWQCB meet to discuss MSB’s completed and outstanding corrective actions.
 August 2023 - Rincon on behalf of MSB submit another iteration of the Water and Wastewater Management Plan to the CCRWQCB; the CCRWQCB provides comments and deems corrective actions remain incomplete.
 September 13, 2023 – County sends MSB a determination of curable breach items and requires payment for accruing liquidated damages in installments.  September 20, 2023 – MSB sends County a response list of curable breach items.  September 23, 2023 – MSB fails to pay first installment of liquidated damages to County in the amount of $39,500.
 October 1, 2023 – MSB fails to complete outstanding corrective actions by the revised deadline.
 October 5, 2023 – MSB’s consultant submits revised CMU Water and Wastewater Management Plan to the CCRWQCB without County approval. The County notifies MSB that all proposed changes to the Project and elements of a Compliance Plan must be reviewed and approved by the County.
 October 6, 2023 - MSB fails to pay MSB fails to pay installment of liquidated damages owed to the County in the amount $290,000 (for Acceptance Tests).  October 11, 2023 – County sends MSB official notice of County Right to Perform under Section 14.8 of the Agreement and takes over CMU runoff replacement pipe project.  October 13, 2023 - MSB fails to pay MSB fails to pay installment of liquidated damages owed to the County in the amount of $420,000.
 October 19, 2023 – MSB’s consultant submits revised CMU Water and Wastewater Management Plan to the CCRWQCB without County approval.  October 31, 2023 – The County notifies MSB again that all proposed changes to the Project and elements of a Compliance Plan must be reviewed and approved by the County prior to submittal to the CCRWQCB.

DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

Scott D. McGolpin
Public Works Director
Marty Wilder
Interim Deputy Director
April 7, 2023
John Dewey, CEO & Managing Member [US mail and emailed] MSB Investors, LLC
17 Corporate Plaza, Suite 200
Newport Beach, CA 92660
Email: [email protected]
SUBJECT: Failure to Pass Acceptance Test and Subtests at the Tajiguas Resource Recovery Project – Notice of Liquidated Damages and Required Compliance Plan
Mr. John Dewey,
The Agreement between MSB Investors, LLC (MSB) and the County of Santa Barbara (County) for the development and operation of the Tajiguas Resource Recovery Project (Project, also referred to as the ReSource Center) sets forth Acceptance Test requirements which consist of passing nine subtests as defined below. Section 4.8H of the Agreement provides that MSB’s failure to pass the Acceptance Test, including all nine subtests, requires the assessment of liquidated damages.

As summarized in the County’s presentation to MSB on March 1, 2023, MSB has failed to pass the Acceptance Test and the ReSource Center operational activities are not functioning as necessary to meet Performance Guarantees, including Permit limits, at either Full Operations or Limited Operations. The County gave MSB an additional 10 business days to submit data or evidence to support MSB’s passing of the Acceptance Test or subtests. MSB submitted additional data to the County to demonstrate the production rate of electricity at the Anerobic Digestion Facility (ADF) engines and solar photovoltaic system located at the Materials Recovery Facility (MRF), and laboratory reports for stormwater samples collected at compliance locations (CW-1, CW-2, and CW-3) during the second half of 2022.

The following is a summary on the status of the nine subtests required in Section 4.8.B.4, as well as all information provided by MSB, of which MSB has only passed 2 subtests, has failed 6 subtests, and 1 subtest is still pending regulatory review. Accordingly, as discussed in more detail below, MSB is required to submit a Compliance Plan to the County by May 5, 2023.

SUMMARY OF SUBTESTS
a) Facility Reliability Test
A test designed to show that the equipment can operate while Processing Acceptable Waste over a sustained period of time.

Status: Failed Test. The County is in receipt of performance testing performed by the supplier, Bekon, and prepared by Cypress Engineering Group. As noted in the Summary of Acceptance Tests Report for Tajiguas ADF (dated January 2023), exceptions were DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
MSB Investors, LLC
April 7, 2023

listed for the ADF and Composting Management Unit’s (CMU) ability to meet the required performance criteria. The County is also in receipt of data that summarizes the ADF’s venting of untreated biogas to the atmosphere on five occasions during the month of January 2023, the longest event occurring on January 17, 2023 for a duration of four hours and eight minutes. In addition, the County’s third-party review of ReSource Center’s reliability performed by Tetra Tech in February 2023, identified eight major issues that contributed to the ADF and CMU’s inability to pass the Facility Reliability Test. A summary of Tetra Tech’s findings was provided to MSB on March 1, 2023 and is included in Attachment A.
b) Facility Capacity Test
A test designed to show that the equipment can operate at its Rated Capacity for a short period of time.

Status: Failed Test. The County is in receipt of performance testing performed by the supplier, Bekon, and prepared by Cypress Engineering Group. As noted in the Summary of Acceptance Tests Report for Tajiguas ADF (dated January 2023), exceptions were listed for the ADF and CMU’s ability to meet the required performance criteria (e.g. compost quality test). In addition, the County’s third-party review of ReSource Center’s reliability performed by Tetra Tech in February 2023, identified eight major issues that contributed to the ADF and CMU’s inability to pass the Facility Capacity Test. A summary of Tetra Tech’s findings was provided to MSB on March 1, 2023 and is included in Attachment A
c) Environmental Compliance Test
A test designed to demonstrate that the Facility can meet air emissions compliance limits in its Permits.

Status: Pending. The County acknowledges that MSB completed the required Source Tests for the various permitted equipment and is awaiting approval of the remaining tests from the Santa Barbara County Air Pollution Control District (SBCAPCD) prior to applying for a Permit to Operate (PTO) for the Resource Center. MSB will receive a passing status once the SBCAPCD has issued a PTO, which is also dependent on Authority to Construct Permit Modification No. 10 and associated post-Alisal Fire repairs. The SBCAPCD approved temporary operation of MRF without operation of a biofilter under a Regular Variance which expires on October 14, 2023.
d) Net Electric Output Test
A test designed for those facilities that produce electricity as a product, to demonstrate the production rate of electricity.

Status: Passed Test. The County is in receipt of data from MSB demonstrating that the MRF engines (received March 1, 2023), ADF engines (received March 3, 2023), and solar photovoltaic system (received March 10, 2023) are able to produce the expected electrical value.

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
MSB Investors, LLC
April 7, 2023

e) Material Recovery Test
A test designed to demonstrate the quantity and quality of materials and Products recovered by the pre-Processing, and post-Processing facilities, as applicable.

Status: Failed Test. The County is in receipt of the performance testing performed by the supplier, Bekon, and prepared by Cypress Engineering Group. The County also reviewed the incoming quantity of materials and quantity of materials recovered at the ReSource Center during the 2022 calendar year, and found that the requirements for throughput, recovery, and commodity purity were not met.

Facility-wide diversion is currently calculated at 24.6 percent, well below the 64.8 percent projected in Exhibit W of the Agreement between MSB and the County (see Attachment B). Adjusting the diversion requirement using the December 2022 waste characterization, the Contractor is still below the recalculated diversion requirement of 47.1%. During the 2022 calendar year, 47,700 tons of organic material was received at ADF from the MRF.

Residual materials sent to the landfill from the ADF/CMU totaled 32,236 tons, and comprised of green material that would have otherwise been diverted from burial if not mixed with the ADF digestate. Only 2,097 tons of finished compost was sent to market offsite.
f) Residue Test
A test designed to demonstrate the quantity and quality of Residue generated by sorting of Acceptable Materials and anaerobic digestion of Organic Materials.

Status: Failed Test. The waste characterization study performed by Sloan Vazquez McAfee (December 2022) showed a non-organic content of 13.2 percent at the MRF.

Subsequent sampling over ten days of over 2,000 pounds of organic material sent to the ADF as required by SB 1383 was performed by MRF operations staff in March 2023 determined the non-organic content to be 28.3 percent. Both of these studies demonstrate that the MRF is able to comply with the SB 1383 High Diversion requirements.

However, the ADF was unable to meet the SB 1383 requirements during the First Quarter 2023 sampling event due to the amount of organic content in the residual material (67 percent) as reported to CalRecycle by MSB. The County acknowledges that the Tajiguas Landfill received a total of 24.0 inches of rainfall during the First Quarter 2023 (January 1 through March 31), which impacted the effectiveness of the CMU screens and densimetric table. MSB must complete a subsequent sampling event prior to April 30, 2023 to demonstrate compliance with SB 1383 requirements.
g) Ambient Noise
A test designed to demonstrate compliance with applicable noise standards.

Status: Passed Test. The County is in receipt of test results provided by MSB on February 22, 2022 that demonstrate the ReSource Center can operate in compliance.

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
MSB Investors, LLC
April 7, 2023

h) Ambient Odor Test
A test designed to demonstrate that no objectionable odors from the Facility are detectable beyond the site boundaries.

Status: Failed Test. The County is in receipt of test results performed by BioLargo Engineering, Science and Technologies, LLC dated March 21, 2022, and SCS Engineers for hydrogen sulfide sampling performed on October 3, 2022. These evaluations do not validate the full capacity or performance of the ReSource Center. The County acknowledges that MSB completed the required sampling pursuant to the SBCAPCD approved Property Boundary Sulfur Monitoring Plan, however MSB failed to evaluate additional odiferous compounds related to ADF and CMU operations. A substantial number of odor complaints from the nearby Arroyo Quemada community and ongoing violations from the Local Enforcement Agency (Santa Barbara County Environmental Health Services Division) for odor control at the ADF and CMU demonstrates the lack of compliance with this performance requirement (see Attachment C). i) Stormwater Discharge Test
A test designed to demonstrate compliance of the Facility with the Industrial Stormwater Permit for the Site.

Status: Failed Test. The County is in receipt of laboratory reports for stormwater samples collected at compliance locations CW-1 (ADF/CMU overflow discharge pipe), CW-2 (ADF storm drain outlet), and CW-3 (MRF storm drain outlet) during qualifying storm events on September 19, 2022, November 7, 2022, and December 1, 2022 (CW-3 only). The results demonstrate the ReSource Center, compliance location CW-1 in particular, has not satisfied this subtest requirement and exceed Numerical Action Levels (NALs) for Iron (annual exceedance limit of 1.0 milligrams per liter [mg/L]) and Total Suspended Solids (annual exceedance limit of 100 mg/L).

The County has not received laboratory reports for stormwater samples collected during qualifying storm events in 2023, which are overdue and required to be submitted to the Water Board’s Stormwater Multiple Application and Reporting Tracking System (SMARTS) within 30 days of obtaining results. On February 1, 2023, the County observed an unauthorized non-storm water discharge (NSWD), near leaking joints of the CMU runoff collection pipes (see Attachment D). An NSWD sample was collected by MSB on February 1, 2023 and submitted for laboratory analysis. Analytical results for the sample showed Escherichia Coli (5,200 most probably number [MPN] per 100 milliliters [mL]), Iron (2.7 mg/L), Chemical Oxygen Demand (560 mg/L), and Total Phosphorus (2.2 mg/L) were detected at concentrations above NALs (with the exception of E. Coli, there is no acceptable level). A copy of the laboratory analytical results is included in Attachment D.

In addition, the Central Coast Regional Water Quality Control Board issued a Notice of Violation to MSB on March 17, 2023 for non-compliance with eight Compost General Order requirements, mostly related to MSB not managing wastewater from the CMU in DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
MSB Investors, LLC
April 7, 2023

accordance with the Facility’s approved Water and Wastewater Management Plan (see Attachment E). The County has also noted in the ReSource Center Commissioning Operation and Compliance meetings with MSB the following concerns that need to be addressed immediately:

1. There are drain inlets that have the ability to convey liquids from the ADF percolate containment area and ADF biofilter to the North Sedimentation Basin. Stormwater runoff from the ADF percolate containment area was observed leaking into the conveyance piping.

2. The lack of capacity in the CMU runoff storage tanks has attributed to over 20 bypass events of CMU runoff water to the North Sedimentation Basin during the 2021-2022 and 2022-2023 wet seasons. Bypass events that could be evaluated in project SCADA occurred from December 24 through 31, 2021; December 2, 3, 4, 10, 11, 12, 2022; January 9, 10, 11, 2023; February 24, 2023; and March 10, 14, 21, 22, 2023.

3. The CMU runoff conveyance piping continues to leak leachate at the pipe joints.

Failure to meet the Acceptance Test requirements, as provided in Section 4.8.H, allows the County to determine what remedies to exercise based on the specific circumstances. In addition, failure to pass the Acceptance Test requires the County to assess damages in accordance with Section 14.9 and Exhibit D. Accordingly, notice is hereby provided that failure to pass the Acceptance Test will result in liquidated damages of $2,000 per day, until remedied. The County will begin assessing liquidated damages associated with these violations on April 14, 2023.

Pursuant to Section 14.9, MSB may, within ten days after receiving this Notice, request a meeting with Marty Wilder, Interim Deputy Director of Public Works, to present oral or written evidence relevant to these ongoing conditions.

MSB is also required to develop a County-approved compliance plan as stipulated in Section

4.8.I:

If the Facility fails to pass the Acceptance Test, Contractor shall develop and implement a County-approved compliance plan. The compliance plan shall consist of a clear identification by Contractor, with approval of County, of (i) what problem the compliance plan is intended to solve; (ii) all potential factors causing such problem; and (iii) Contractor’s detailed plan to remedy such problem, including a project schedule and related estimated costs. All aspects of the compliance plan shall be subject to approval of the County. The Contractor shall be responsible for all costs of preparing and implementing the compliance plan and any additional actions required to pass the Acceptance Test.

MSB shall provide the County with a compliance plan for review by May 5, 2023.

The County continues to reserve its right to assess additional liquidated damages in accordance with Exhibit D based on MSB's failure to comply with the Agreement, and to seek any other DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey
MSB Investors, LLC
April 7, 2023

remedies available to resolve said failures. In addition to the liquidated damages, MSB is responsible for all costs of preparing and implementing the County-approved compliance plan, any additional actions required to pass the Acceptance Test, and any additional costs to the County.

The County anticipates your full cooperation in implementing actions necessary to expeditiously complete and operate this very important Santa Barbara County Project.

Sincerely,
Jeanette Gonzales-Knight
Compliance Manager, Santa Barbara County Public Works Department Cc: Scott McGolpin, Santa Barbara County Public Works Department Marty Wilder, Santa Barbara County Public Works Department Travis Spier, Santa Barbara County Public Works Department Carlyle Johnston, Santa Barbara County Public Works Department Attachments:

Attachment A – Summary of Tetra Tech ADF/CMU Operational Performance Evaluation dated February 17, 2023
Attachment B – Total Material Delivered and Recovered at the ReSource Center Attachment C – Local Enforcement Agency Notice of Violation on Inspections dated March 8, 2023
Attachment D – Unauthorized Non-Storm Water Discharge Log and Laboratory Results Attachment E – Central Coast Regional Water Quality Control Board Notice of Violation Letter dated March 17, 2023
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

ATTACHMENT A
Summary of Tetra Tech ADF/CMU Operational Performance Evaluation dated February 17, 2023

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 1 SUMMARY OF TETRA TECH ADF/CMU OPERATIONAL PERFORMANCE EVALUATION FEBRUARY 17, 2023

1. Feedstock and Finished Compost Final End Use Issues

The organic waste feedstock (organics extracted at the Mixed Waste MRF) received at the ADF is highly contaminated. There is no process beyond a screen sizing for feedstock preparation.

The contamination does not produce biogas and it makes further processing of the digestate difficult. Further compounding the issue is the high usage of ground woody waste to dilute the contamination and managing the odors form the digestate. All of this is causing a negative effect on the composting operations and ability to make a sellable compost.

Finished compost is not going out to market due to the high glass content due to densimetric table (D-table) inconsistent operations. The increased volumes and contamination along with a higher moisture content further impact the refining approach. Agromin is using multiple screen steps to clean the material. This is the right approach given the circumstances, but the final yield of compost and amount of residue for disposal is not effective or sustainable.

MSB believes their major choke point in the CMU operation is the D-table. The organic material from the MRF is wet and of poor quality that the D-table cannot keep up and produces a bad end product out of the CMU.

2. Operations, Maintenance and Management of the ADF

There does not appear to be anyone experienced in anaerobic digestion (AD) at the facility. The most knowledgeable technical person lives in Florida and operates remotely through the system’s TeamViewer. The Tetra Tech Team was made aware that a previous general manager left some months back and that Agromin was being asked to takeover. We did discuss this with Dave Camarillo with Agromin at the controls. He did not agree that they were running the plant, but they were trying to help given the lack of oversight.

It is impossible to know all the operations, maintenance, and cleaning activities without an organized plan and series of checklists to validate. The Team’s overall sense was that the plant was not operated in this fashion, and instead maintenance seems very reactionary.

We understand that the CMU is operating under Agromin. They are an experienced composter, and the operations of the CMU was organized and well maintained.

3. Mass, Energy, and Water Balance of ADF and CMU

Several imbalances: The first is the actual generation of biogas compared to the expected amounts projected from the AD supplier, Bekon, based on samples of the feedstock. This would then provide a validation on energy available for CHPs, reduce flare usage and target optimal CHP usage.

There is also a high usage of water due to the low moisture content of the feedstock (organics) being lower than anticipated. Moisture in the digestate is lost to evaporation. This significant consumption of percolate must be managed. Unfortunately, the approach to digestate treatment does not reclaim any of that percolate as it must be evaporated via the CMU.

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 2 The mass balance information should validate the amount of biogas produced and overall performance of the system. We did not see any direct measurements of biogas production.

4. ADF Maintenance and Cleaning

Given the amount of time the system has been operating, there should be a routine and robust cleaning and maintenance program. We understand that no treatment for struvite was being done until very recently. Struvite is a known issue for AD plants and the build-up is quick and severe which impacts performance of the AD plant.

5. Biogas Storage

A typical design for an AD plant is to include a biogas buffer or storage so that there is a place for biogas to store and mix for consistency prior to use by CHPs or flared. The common approach is a bladder. This is a low cost and simple approach. The Tetra Tech Team would expect one (1) bladder for each eight (8) digesters or two (2) for the ADF. This would provide a steady flow of biogas to the CHPs and allow the digesters to continue to produce and hold the biogas if there are issues with the CHPs. The lack of biogas storage will lead to the venting of biogas from the digester when the pressure increases inside the system. This should not happen other than in extreme conditions. It is our understanding from MSB that there were four (4) venting events last month (Dec 2022). We have requested the alarm notices for the ADF to validate and see how many other such events have occurred. The venting of biogas is dangerous and will cause odors.

6. Digestate Treatment for Odor Control

Digestate treatment is a serious design and operations consideration for all AD plants. Fresh digestate has ammonia trapped in the solids that is released during movement or further processing. This can lead to nuisance odors. It is suspected to be the main cause of odors from the ADF. Typical treatments include the use of heat and air in an in-vessel compost tunnel to remove ammonia, complete the Process for Reduction of Pathogens per EPA 503 (PFRP), reduce moisture content, and allow for transportation or further aerobic processing. Currently untreated digestate exits the ADF facility via a conveyor belt. The digestate is open to the outside. The CMU is mitigating by covering the digestate with ground woody materials. The combined materials are placed into windrows for composting. This procedure helps mitigate the digestate odor. However, it also spreads the odor to the windrows. Each pass of the windrow turner further aerates and exposes the digestate for a release of ammonia. The heat and aeration are working to remove the ammonia. Unfortunately, this is outside with sensitive receptors downwind.

Also, the County informed the Tetra Tech Team that the odor complaints the site is receiving are coming from individuals that live south of the landfill across Highway 101/1. According to MSB, they claim ADF is not leaking biogas. However, they admitted and suspected venting of biogas is occurring and will cause odor. The County and MSB have performed numerous evaluations and implemented odor mitigation BMPs with little success.

7. Control Systems and SCADA Issues

There are multiple Control/SCADA systems in use at the ADF. This is due to the limits of supply between the AD supplier, CHP supplier and Flare supplier. The operator complains of numerous problems with each system and the inability for the systems to work together. The Tetra Tech DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 3 Team observed many system faults and an inability to operate the system in an automated mode. The operator complained of many off-hour checks and changes to keep the system running. This is not typical. There needs to be one Control system that integrates the individual systems together and there needs to be full visibility on the parameters with the Bekon controls code to insure proper operation and a priority for alarms or faults.

8. Black Smoke from Enclosed Flare at Startup

The County reported observing black smoke exiting the top of the enclosed ground flare at the ADF. The ADF is equipped with a John Zink ZTOF enclosed flare that is permitted for use during ADF purging events and if one of the ADF CHP engines is nonoperational. The flare was not operating during the Tetra Tech Team’s site visit.

Black smoke coming out of a flare can be caused by multiple operational issues. The most common cause for black smoke is the flare louvers not responding properly during the flare startup process. Typically, during startup the flare louvers should be slightly open. This will allow ambient air to mix with biogas/LFG in the flare combustion chamber and allow the air gas mixture to combust properly and allow the flare to reach the desired operating temperature.

The temperature in the enclosed ground flare is measured by multiple thermocouples located at different heights in the flare stack. The flare operational logic typically operates using one thermocouple at a time, and the selection of the correct operation thermocouple plays a major role in the proper startup of the flare. The selection of the wrong thermocouple can cause the issues with how the flare louvers respond to control the flare operating temperature.

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

ATTACHMENT B
Total Material Delivered and Recovered at the ReSource Center

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Total Material Delivered and Recovered at the ReSource Center Reporting Period: January 1, 2022 through December 31, 2022 Material
Total Material
Delivered
(tons)
Recyclables
Recovered
(tons)
Organics
Recovered
(tons)
Total Material
Recovered
(tons)
Total Materials
Recovered
(%)
Mixed Waste
Franchise Tons               133,641.00               1,508.87             10,311.51             11,820.38 8.84% Self Haul Tons                 11,345.20                   139.98                   874.77               1,014.75 8.94% TOTAL               144,986.20               1,648.85             11,186.28             12,835.13 8.85% Source Separated Recyclables (SSR)
TOTAL                 38,161.80             28,978.70 75.94% Source Separated Organics (Food Scraps)
Total                   4,365.00               4,277.70 98.00% TOTAL FACILITYWIDE              187,513.00             46,091.53 24.6% Notes:

The recovery rate for SSR is based on the December Performance and Characterization report.

The recovery rate for the SSO is based on Original Exhibit W.

The recovery rate of both the Franchise and the Self Haul tons are based on the difference of the SSR recovery rate from actual disposal.

The net amount recovered from Mixed Waste is done by comparing what was sent to the MRF and what was buried after backing out the amount buried that came from SSR.

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

ATTACHMENT C
Local Enforcement Agency Notice of Violation
on Inspections dated March 8, 2023
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Inspection Information
Inspected By: Santa Barbara County Local Inspection ID:

Inspection Date: 3/8/2023 Time In: 8:45 AM
Inspection Type: Focused Time Out: 9:15 AM
Inspector: Norma Campos Bernal Inspection Duration: 1/2 hour Operator: County Of Santa Barbara Public Works Dep
Received By: [email protected]; [email protected]
Also Present (Name):

Facility/Activity Information
Enforcement Agency: County of Santa Barbara SWIS Number: 42-AA-0015 Facility: Tajiguas Res Rec Proj & Sanitary LF
14470 Calle Real
Goleta, CA 93117
Activity: Large Volume In-Vessel Digestion Facility
Operational Status: Active Regulatory Status: Permitted Land Owners(s):

County Of Santa Barbara Public Works Dep
The above facility was inspected for compliance with applicable sections of Division 30 of the Public Resources Code (PRC) and Title 14 and Title 27, California Code of Regulations (CCR).

Violations
14 CCR 17896.32 - Odor and Nuisance Control
Operation of facility that has been and is currently creating odor and nuisance conditions off-site. Complaints received by email on March 7 and 8, 2023. No additional complaints received from Refugio Rd. neighborhood.

Operator to immediately implement procedures established in operator's OIMP, and take additional reasonable and feasible measures (such as identified in submitted Odor Best Management Practice (BMP) Feasibility Report) to minimize and control nuisance odor impact.

In-Vessel Digestion Operation and Facility Inspection Report (104) Tajiguas Res Rec Proj & Sanitary LF (42-AA-0015)
3/8/2023
CalRecycle Solid Waste Information System (SWIS) Page 1 of 3 Date Generated: March 21, 2023 10:13 AM
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 No Areas of Concern
Inspection Report Comments
Weather: Mostly sunny, 48F and northerly winds at 12 mph

Anaerobic Digestion Facility (ADF) Focused Weekly Inspection:

-Upon arrival to ADF, noted main doors were in the process of getting shut by truck transporting digestate to CMU.

-Noted piles of Source Separated Organics (SSO), Organic Fraction of Municipal Solid Waste (OFMSW) from the MRF.

-Both eye-wash stations and showers were operating adequately.

-Noted misters were not operating during today's inspection.

Notes:

1. Refer to violation for 14 CCR section 17896.32 Odor and Nuisance Control

2. Ensure misters are operating during business hours.

3. Next Five-Year Review application will be due on February 2, 2027.

On Wednesday, March 8, 2023, LEA responded to ongoing odor complaint by conducting an odor survey from Arroyo Quemada Lane in the morning before and after Tajiguas focused inspection of the ADF and CMU.

No other potential odor sources were identified except for operations at Tajiguas Sanitary Landfill and ReSource Center. During the inspection, the LEA was not made aware of any unusual operational changes or atypical feedstocks.

Upon arrival at Arroyo Quemada Lane at approximately, 8:15 am, the weather was 48F and cloudy with a wind at 12 mph in a northerly direction and LEA noticed a faint compost odor on Arroyo Quemada Lane, this odor was noticeable throughout the lane.

After periodic inspection of Tajiguas Landfill and associated facilities, LEA conducted another odor survey at Arroyo Quemada Lane at approximately 10 am and a faint compost odor remained. The weather had not changed.

The odors detected in the morning would interfere with the comfortable enjoyment of life.

Furthermore, on Wednesday, March 8 2023, LEA responded to ongoing odor complaint by conducting an odor survey from Refugio Rd.in the morning.

In-Vessel Digestion Operation and Facility Inspection Report (104) Tajiguas Res Rec Proj & Sanitary LF (42-AA-0015)
3/8/2023
CalRecycle Solid Waste Information System (SWIS) Page 2 of 3 Date Generated: March 21, 2023 10:13 AM
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 No other potential odor sources were identified except for operations at Tajiguas Sanitary Landfill and ReSource Center. During the inspection, the LEA was not made aware of any unusual operational changes or atypical feedstocks.

Upon arrival at Refugio Rd. at approximately, 10:30 am, the weather was 52F and cloudy with a wind at 10 mph in a westerly direction and LEA did not notice any compost odor in the area of the addresses provided for Refugio Rd.

No Attachments
In-Vessel Digestion Operation and Facility Inspection Report (104) Tajiguas Res Rec Proj & Sanitary LF (42-AA-0015)
3/8/2023
CalRecycle Solid Waste Information System (SWIS) Page 3 of 3 Date Generated: March 21, 2023 10:13 AM
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Inspection Information
Inspected By: Santa Barbara County Local Inspection ID:

Inspection Date: 3/8/2023 Time In: 9:15 AM
Inspection Type: Focused Time Out: 9:45 AM
Inspector: Norma Campos Bernal Inspection Duration: 1/2 hour Operator: County Of Santa Barbara Public Works Dep
Received By: [email protected]; [email protected]
Also Present (Name):

Facility/Activity Information
Enforcement Agency: County of Santa Barbara SWIS Number: 42-AA-0015 Facility: Tajiguas Res Rec Proj & Sanitary LF
14470 Calle Real
Goleta, CA 93117
Activity: Composting Facility (Mixed)
Operational Status: Active Regulatory Status: Permitted Land Owners(s):

County Of Santa Barbara Public Works Dep
The above facility was inspected for compliance with applicable sections of Division 30 of the Public Resources Code (PRC) and Title 14 and Title 27, California Code of Regulations (CCR).

Violations
14 CCR 17867(a)(2) - Odor Control
Operation of facility that has been and is currently creating odor and nuisance conditions off-site. Complaints received by email on March 7 and 8, 2023. No additional complaints received from Refugio Rd. neighborhood.

Operator to immediately implement procedures established in operator's OIMP, and take additional reasonable and feasible measures (such as identified in submitted Odor Best Management Practice (BMP) Feasibility Report) to minimize and control nuisance odor impact.

Compostable Materials Handling Operation and Facility Inspection Report (93)
Tajiguas Res Rec Proj & Sanitary LF (42-AA-0015)
3/8/2023
CalRecycle Solid Waste Information System (SWIS) Page 1 of 3 Date Generated: March 21, 2023 10:15 AM
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 No Areas of Concern
Inspection Report Comments
Weather: Mostly sunny, 48F and northerly wind at 12 mph

CMU Focused Weekly Inspection:

-Noted truck making multiple trips to deliver digestate from ADF.

-Noted 19 windrows of compost undergoing curing process on the CMU floor this day and one of them had completed pathogen reduction period.

-Noted two large piles of unscreened finished compost.

-Noted one pile of mulch in between windrows.

-Noted hills below CMU all clear of litter this day, but noted some litter on outside of CMU enclosure facing the landfill.

Notes:

1. Refer to violation from 14CCR Section 17867(a)(2)-Odor Control.

2. Collect all litter on north side enclosure.

3. Next Five-Year review Application will be due on February 2, 2027.

On Wednesday, March 8, 2023, LEA responded to ongoing odor complaint by conducting an odor survey from Arroyo Quemada Lane in the morning before and after Tajiguas focused inspection of the ADF and CMU.

No other potential odor sources were identified except for operations at Tajiguas Sanitary Landfill and ReSource Center. During the inspection, the LEA was not made aware of any unusual operational changes or atypical feedstocks.

Upon arrival at Arroyo Quemada Lane at approximately, 8:15 am, the weather was 48F and cloudy with a wind at 12 mph in a northerly direction and LEA noticed a faint compost odor on Arroyo Quemada Lane, this odor was noticeable throughout the lane.

Compostable Materials Handling Operation and Facility Inspection Report (93)
Tajiguas Res Rec Proj & Sanitary LF (42-AA-0015)
3/8/2023
CalRecycle Solid Waste Information System (SWIS) Page 2 of 3 Date Generated: March 21, 2023 10:15 AM
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 After periodic inspection of Tajiguas Landfill and associated facilities, LEA conducted another odor survey at Arroyo Quemada Lane at approximately 10 am and a faint compost odor remained. The weather had not changed.

The odors detected in the morning would interfere with the comfortable enjoyment of life.

Furthermore, on Wednesday, March 8 2023, LEA responded to ongoing odor complaint by conducting an odor survey from Refugio Rd. in the morning.

No other potential odor sources were identified except for operations at Tajiguas Sanitary Landfill and ReSource Center. During the inspection, the LEA was not made aware of any unusual operational changes or atypical feedstocks.

Upon arrival at Refugio Rd. at approximately, 10:30 am, the weather was 52F and cloudy with a wind at 10 mph in a westerly direction and LEA did not notice any compost odor in the area of the addresses provided for Refugio Rd.

Attachments
Tajiguas CMU
Compostable Materials Handling Operation and Facility Inspection Report (93)
Tajiguas Res Rec Proj & Sanitary LF (42-AA-0015)
3/8/2023
CalRecycle Solid Waste Information System (SWIS) Page 3 of 3 Date Generated: March 21, 2023 10:15 AM
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

ATTACHMENT D
Unauthorized Non-Storm Water Discharge Log and Laboratory Results DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 G:\RR&WM\ENGINEER\TAJIGUAS\129917 TAJIGUAS ENVIRONMENTAL\900 WRK\930 FIELD LOGS\STORMWATER SAMPLING FORMS\2021 SAMPLING PACKAGE\TAJIGUAS INDUSTRIAL STORMWATER FIELD LOGS.DOCX

OBSERVATIONS DURING SAMPLING

TAJIGUAS LANDFILL
Date and Time of Observation:

Inspector Information
Inspector Name: Inspector Title:

Signature: Date:

Exception Documentation
(Provide explanation if observation could not be conducted) Weather
Weather conditions: Precipitation Total:

Sampling Event Observations
Observations:

Odors Yes ☐ No ☐
Floating material Yes ☐ No ☐
Suspended Material Yes ☐ No ☐
Sheen Yes ☐ No ☐
Discolorations Yes ☐ No ☐
Turbidity Yes ☐ No ☐
Complete the following for each Yes answer from above
Location within
Drainage Area
Identify pollutant and
suspected cause of pollutant
Describe any response actions and/or SWPPP
revisions necessary
Likely a compost-related pollutant
originating from ADF or CMU
North Sedimentation
Basin
x
x
x
x
x
x
CLEAR 56° 8.99 inches January 1 thru 16 3-7-2023 Christina Wilder QISP 2-1-2023 1:30pm DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 G:\RR&WM\ENGINEER\TAJIGUAS\129917 TAJIGUAS ENVIRONMENTAL\900 WRK\930 FIELD LOGS\STORMWATER SAMPLING FORMS\2021 SAMPLING PACKAGE\TAJIGUAS INDUSTRIAL STORMWATER FIELD LOGS.DOCX

SAMPLING LOG

TAJIGUAS LANDFILL
ISW4 (WITH CMU COMPOST DISCHARGE)
Date: Sampling Start Time:

Sampler Name: Sampler Signature:

Sampling conducted within four hours of: (Check one)
☐ The start of the discharge
☐ The start of the facility operations if the QSE occurred within the previous 12-hour period Exception Documentation
(Provide explanation if sampling could not be conducted) Field Meter Calibration
pH Meter ID No. or Description:

Calibration Date/Time:

Field pH Measurement
pH: Time:

Samples Collected
Constituent Analytical Method Time
Oil and Grease EPA1664A
TSS SM 2540D
Iron EPA 200.7
COD SM 5220C
E. Coli SM 9223B
Total Phosphorus SM4500-P B+E
Nitrate + Nitrite (as N) SM 4500-NO3-E
Lead EPA 200.8
Zinc EPA 200.8
Additional Sampling Notes:

Sampling End Time:

A GRAB SAMPLE IDENTIFIED AS R.O.V.D. WAS COLLECTED BY MSB STAFF AT THE

DOWNDRAIN WHERE IT WAS DISCHARGING TO THE NORTH SEDIMENTATION BASIN.

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 #*
#*
#*
#*
#*
#*
SE-11
EC-2
SE-5
SE-5
SE-5
EC-9
EC-9
SE-5
SE-5
SE-5
TC-1
North Sedimentation Basin
South Sedimentation Basin
SE-9
TC-1
TC-2
EC-9
EC-9
SE-5
DC
TC-30 SC-11 WM-4
CS
SE-2
SE-2
2 3 8
EC-2
EC-2
SE-6
SE-6
SE-10
SE-5
SE-11
EC-2
EC-2
EC-9
SE-6
EC-9
CS
CS
CS
CS
SE-10 10
SE-10
SE-10
6 4
7 1
5 9
ISW3a
ISW4
ISW6
CW-2
CW-1
CW-3
SantaBarbara-01\\\SANTABARBARA-01\Data\GIS\County of Santa Barbara\Tajiguas\Projects\Tajiguas_SWPPP_Fig3_BMPs_2022.mxd 1/11/2022 (Author: treeder) 12:55:57 PM Tajiguas Landfill
Santa Barbara, California
Drainage and BMP Map
0 250 500 1,000
Feet
Figure
3 Santa Barbara January 2022
Legend
#* ReSource Center Compliance Monitoring
Locations (under separate IGP coverage)
#* TSL Compliance Monitoring Location
Storm drain network
IGP Drainage Area
ReSource Center IGP Drainage Area
(under separate IGP coverage)
Site Boundary
Wet weather deck for rain days
Paved Access Road
Sloped Hillsides/Former Landfill
Operations (subject to IGP)
Operational Areas
Landfill Operational Area
Resource Center Operational Area
BMPs
CS: Covered Structure
DC: Temporary coverings
EC-2: Maintain/preserve existing
vegetation
EC-9: Earth dike/drainage swale
SE-2: Sedimentation basin
SE-5: Fiber roll
SE-6: Gravel bag berm
SE-9: Straw bale barrier
SE-10: Storm drain inlet protection
SC-11: Preventative maintenance
TC-CC: Concrete channel
TC-1: Stabilized access road
TC-2: Stabilized roadway
TC-30: Bioswale
WM-4: Oil tank in secondary
containment
Operational Areas

1. Active Waste Disposal Area

2. ReSource Center: Anaerobic Digester
Facility (separate IGP coverage)

3. ReSource Center: Composting
Management Unit Area (separate IGP
coverage)

4. Green Waste

5. North Soil Stockpile

6. Storage and Vehicle Fueling

7. Staging Area

8. ReSource Center: Materials Recovery
Facility (separate IGP coverage)

9. Maintenance Area

10. Marborg Maintenance Area
³
TC-CC
Sitewide BMPs
SE-5: Fiber rolls on slopes or sufaces with potential for erosion EC-2: Maintain/preserve existing vegetation
EC-4: Trackwalk and hydroseed bare areas
EC-11: Slope drains and conveyance ditches
Note:
-Areas other than the paved access road are pervious areas that may be a source of dust in dry weather or subject to erosion in wet weather

DOWNDRAIN LOCATION

WHERE UNAUTHORIZED

NSWD WAS OBSERVED
AND SAMPLED.

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 [TOC_1]Cover Page[
Oilfield Environmental & Compliance, Inc.

Analytical Report
Project: MRPV-ADF
Goleta, CA 93117
14470 Calle Real
Mustang Renewable Power Ventures
Dylan Ellis
OEC Work Order: 2300847
Report Date: February 22, 2023 19:12
Number: R.O.V.D.
[email protected]
Meredith Sprister, Business Director
Enclosed is an analytical report for the above referenced project. The samples included in this report were received on February 02, 2023 12:10 and analyzed in accordance with the attached chain-of-custody.

Unless otherwise noted, all analytical testing was accomplished in accordance with the guidelines established in our Quality Manual, applicable standard operating procedures, and other related documentation. The results in this analytical report are limited to the samples tested and any reproduction thereof must be made in its entirety.

If you have any questions regarding this report, please do not hesitate to contact the undersigned.

Authorized for release by:

This laboratory is accredited in accordance with the recognised International Standard ISO/IEC 17025. This accreditation demonstrates technical competence for a defined scope and the operation of a laboratory quality management system (refer to joint ISOILAC-IAF CommuniquÈ dated April 2017)
307 Roemer Way, Suite 300
Santa Maria, CA 93454
client.oec.com\reports
CA-ELAP 2438, TNI 02666
TNI 2016 & ISO/IEC 17025:2017
www.oecusa.com
Fax:

Main:
(805) 925-3376
(805) 922-4772

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Project:

Project Number:

Project Manager:

Mustang Renewable Power Ventures
14470 Calle Real R.O.V.D.

Dylan Ellis

MRPV-ADF
Goleta CA, 93117 02/22/2023 19:12
Oilfield Environmental & Compliance, Inc.
2300847
WO & Reported:

Sample ID Laboratory ID Client Matrix Date Sampled
Sample Summary
Date Received
[TOC_1]Sample Summary[TOC]
Lab Matrix
R.O.V.D. 2300847-01 Water Water 02/01/2023 13:30 02/02/2023 12:10 [TOC_1]Sample Batch Preparation Summary[ Sample Batch Preparation Summary Analysis Batch ID Preparation Date/Time
Anions by IC
EPA 300.0 B3B0055 02/02/2023 14:39
Nitrate/Nitrite as N [CALC] 02/02/2023 14:39
EPA 300.0 B3B0055 02/02/2023 14:39
General Chemistry Parameters by EPA or APHA Standard Methods 9040B pH B3B0426 02/14/2023 07:05
COD, Chemical Oxygen Demand B3B0088 02/03/2023 09:16
Oil and Grease by EPA 1664 B3B0643 02/21/2023 06:34
pH Sample Temperature B3B0426 02/14/2023 07:05
Phosphorus, Total as P by SM4500-P B,E/EPA 365.3 B3B0153 02/06/2023 13:07 Solids, Total Suspended (TSS), SM2540D B3B0225 02/07/2023 19:48 Microbiological Parameters by APHA Standard Methods
E.coli QT MPN SM9223B B3B0072 02/02/2023 14:25
Total Metals by ICP
200.7 Total B3B0181 02/07/2023 08:46
The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

307 Roemer Way, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376
CA-ELAP 2438, TNI02666 Client Connect: client.oec.com\reports

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Project:

Project Number:

Project Manager:

Mustang Renewable Power Ventures
14470 Calle Real R.O.V.D.

Dylan Ellis

MRPV-ADF
Goleta CA, 93117 02/22/2023 19:12
Oilfield Environmental & Compliance, Inc.
2300847
WO & Reported:

Analytical Report for Samples
R.O.V.D. Sampled : 02/01/23 13:30
Lab ID : 2300847-01
Matrix : Water
Sample ID :

Sampled by : Dylan Ellis
Field Data : NA
[TOC_1]2300847-01 (
Analyte Result RL Units Dilution Batch Analyzed Method Notes [TOC_2]Microbiological Parameters by APHA Standard Methods[TOC] Microbiological Parameters by APHA Standard Methods
5200 MPN/100 B3B0072 02/03/23 09:56 SM 9223B
mL
E. Coli 10 10 HT-09
[TOC_2]Anions by IC[TOC]
Anions by IC
Nitrate/Nitrite as N ND 0.40 mg/L 1 [CALC] 02/02/23 23:13 Calculation Nitrate as N ND 0.40 " " B3B0055 " EPA 300.0
Nitrite as N ND 0.40 " " " " "
[TOC_2]Total Metals by ICP[TOC]
Total Metals by ICP
Iron 2.7 0.050 mg/L 1 B3B0181 02/09/23 13:18 EPA 200.7
[TOC_2]General Chemistry Parameters by EPA or APHA Standard Methods[TOC] General Chemistry Parameters by EPA or APHA Standard Methods EPA
9040B/SM4500H+ B
pH @ 25 C 7.49 0.10 pH Units 1 B3B0426 02/14/23 07:05 HT-pH pH Sample Temperature During Analysis 21 1.0 °C " " " EPA 170.1/SM 2550B Chemical Oxygen Demand 560 200 mg/L 10 B3B0088 02/03/23 13:00 SM 5220D Total Oil & Grease ND 5.0 " 1 B3B0643 02/21/23 07:15 EPA 1664A SM 4500-P B,E / EPA
365.3
Phosphorus-Total as P 2.2 0.25 " 10 B3B0153 02/06/23 13:28 Total Suspended Solids 49 10 " 1 B3B0225 02/07/23 21:30 SM 2540D The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

307 Roemer Way, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376
CA-ELAP 2438, TNI02666 Client Connect: client.oec.com\reports

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Project:

Project Number:

Project Manager:

Mustang Renewable Power Ventures
14470 Calle Real R.O.V.D.

Dylan Ellis

MRPV-ADF
Goleta CA, 93117 02/22/2023 19:12
Oilfield Environmental & Compliance, Inc.
2300847
WO & Reported:

Anions by IC - Quality Control [TOC_1]Anions by IC - Quality Control[ Result RL Units
Level
Spike
Result
Source %REC %REC
Limits

RPD RPD
Limit
Analyte Notes
[TOC_2]Batch B3B0055 - EPA 300.0/300.1 Anions Prep[TOC] Batch B3B0055 - EPA 300.0 Preparation: EPA 300.0/300.1 Anions Prep 02/02/23 09:30 Blank (B3B0055-BLK1)
[TOC_3]Blank (B3B0055-BLK1)[TOC]
Analyzed: 02/02/23 13:30
Nitrate as N ND 0.40 mg/L
Nitrite as N ND 0.40 "
LCS (B3B0055-BS1)
[TOC_3]LCS (B3B0055-BS1)[TOC]
Analyzed: 02/02/23 12:11
Nitrate as N 4.99 0.40 mg/L 5.00 100 90-110
Nitrite as N 5.03 0.40 " 5.00 101 90-110
LCS Dup (B3B0055-BSD1)
[TOC_3]LCS Dup (B3B0055-BSD1)[TOC]
Analyzed: 02/02/23 12:27
Nitrate as N 5.00 0.40 mg/L 5.00 100 90-110 0.2 20
Nitrite as N 5.08 0.40 " 5.00 102 90-110 1 20
Duplicate (B3B0055-DUP1) Source: 2300855-01
[TOC_3]Duplicate (B3B0055-DUP1)[TOC]
Analyzed: 02/02/23 17:11
Nitrate as N ND 2.0 mg/L ND 20
Nitrite as N ND 2.0 " ND 20
Matrix Spike (B3B0055-MS1) Source: 2300855-01
[TOC_3]Matrix Spike (B3B0055-MS1)[TOC]
Analyzed: 02/02/23 17:27
Nitrate as N 25.7 2.1 mg/L 26.3 ND 97 90-110
Nitrite as N 25.9 2.1 " 26.3 ND 98 90-110
The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

307 Roemer Way, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376
CA-ELAP 2438, TNI02666 Client Connect: client.oec.com\reports

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Project:

Project Number:

Project Manager:

Mustang Renewable Power Ventures
14470 Calle Real R.O.V.D.

Dylan Ellis

MRPV-ADF
Goleta CA, 93117 02/22/2023 19:12
Oilfield Environmental & Compliance, Inc.
2300847
WO & Reported:

Total Metals by ICP - Quality Control [TOC_1]
Result RL Units
Level
Spike
Result
Source %REC %REC
Limits

RPD RPD
Limit
Analyte Notes
[TOC_2]Batch B3B0181 - EPA 200.7[TOC]
Batch B3B0181 - EPA 200.7 Preparation: EPA 200.7 02/07/23 08:46 Blank (B3B0181-BLK1)
[TOC_3]Blank (B3B0181-BLK1)[TOC]
Analyzed: 02/09/23 11:38
Iron ND 0.050 mg/L
LCS (B3B0181-BS1)
[TOC_3]LCS (B3B0181-BS1)[TOC]
Analyzed: 02/09/23 11:43
Iron 10.3 0.050 mg/L 10.0 103 85-115
LCS Dup (B3B0181-BSD1)
[TOC_3]LCS Dup (B3B0181-BSD1)[TOC]
Analyzed: 02/09/23 11:45
Iron 10.5 0.050 mg/L 10.0 105 85-115 2 20
Duplicate (B3B0181-DUP1) Source: 2300930-03
[TOC_3]Duplicate (B3B0181-DUP1)[TOC]
Analyzed: 02/09/23 11:53
Iron ND 0.050 mg/L ND 20
Matrix Spike (B3B0181-MS1) Source: 2300930-03
[TOC_3]Matrix Spike (B3B0181-MS1)[TOC]
Analyzed: 02/09/23 11:48
Iron 10.7 0.050 mg/L 10.0 ND 107 70-130
Matrix Spike (B3B0181-MS2) Source: 2300935-02 Analyzed: 02/09/23 11:50 Iron 10.5 0.050 mg/L 10.0 0.0763 105 70-130
The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

307 Roemer Way, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376
CA-ELAP 2438, TNI02666 Client Connect: client.oec.com\reports

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Project:

Project Number:

Project Manager:

Mustang Renewable Power Ventures
14470 Calle Real R.O.V.D.

Dylan Ellis

MRPV-ADF
Goleta CA, 93117 02/22/2023 19:12
Oilfield Environmental & Compliance, Inc.
2300847
WO & Reported:

General Chemistry Parameters by EPA or APHA Standard Methods - Quality Control [TOC_1]General Chemistry Parameters by E Result RL Units
Level
Spike
Result
Source %REC %REC
Limits

RPD RPD
Limit
Analyte Notes
[TOC_2]Batch B3B0088 - Wetchem default method[TOC]
Batch B3B0088 - SM 5220D Preparation: Wetchem default method 02/03/23 09:16 Blank (B3B0088-BLK1)
[TOC_3]Blank (B3B0088-BLK1)[TOC]
Analyzed: 02/03/23 13:00
Chemical Oxygen Demand ND 20 mg/L
LCS (B3B0088-BS1)
[TOC_3]LCS (B3B0088-BS1)[TOC]
Analyzed: 02/03/23 13:00
Chemical Oxygen Demand 240 20 mg/L 250 97 57-134
LCS Dup (B3B0088-BSD1)
[TOC_3]LCS Dup (B3B0088-BSD1)[TOC]
Analyzed: 02/03/23 13:00
Chemical Oxygen Demand 250 20 mg/L 250 99 57-134 3 10
Duplicate (B3B0088-DUP1) Source: 2300120-11
[TOC_3]Duplicate (B3B0088-DUP1)[TOC]
Analyzed: 02/03/23 13:00
Chemical Oxygen Demand 140 20 mg/L 140 3 10
Matrix Spike (B3B0088-MS1) Source: 2300120-11
[TOC_3]Matrix Spike (B3B0088-MS1)[TOC]
Analyzed: 02/03/23 13:00
Chemical Oxygen Demand 470 27 mg/L 333 140 98 80-120
Matrix Spike Dup (B3B0088-MSD1) Source: 2300120-11
[TOC_3]Matrix Spike Dup (B3B0088-MSD1)[TOC]
Analyzed: 02/03/23 13:00
Chemical Oxygen Demand 460 27 mg/L 333 140 97 80-120 0.7 20 [TOC_2]Batch B3B0153 - NONE[TOC]
Batch B3B0153 - SM 4500-P B,E / EPA 365.3 Preparation: NONE 02/06/23 13:07 Blank (B3B0153-BLK1)
[TOC_3]Blank (B3B0153-BLK1)[TOC]
Analyzed: 02/06/23 13:28
Phosphorus-Total as P ND 0.025 mg/L
LCS (B3B0153-BS1)
[TOC_3]LCS (B3B0153-BS1)[TOC]
Analyzed: 02/06/23 13:28
Phosphorus-Total as P 0.30 0.025 mg/L 0.300 101 85-115
LCS Dup (B3B0153-BSD1)
[TOC_3]LCS Dup (B3B0153-BSD1)[TOC]
Analyzed: 02/06/23 13:28
Phosphorus-Total as P 0.28 0.025 mg/L 0.300 95 85-115 7 20 Duplicate (B3B0153-DUP1) Source: 2300120-13
[TOC_3]Duplicate (B3B0153-DUP1)[TOC]
Analyzed: 02/06/23 13:28
Phosphorus-Total as P 7.0 0.025 mg/L 7.0 0.4 20
[TOC_2]Batch B3B0225 - 2540 D TSS Prep[TOC]
Batch B3B0225 - SM 2540D Preparation: 2540 D TSS Prep 02/07/23 19:48 Duplicate (B3B0225-DUP1) Source: 2300847-01 Analyzed: 02/07/23 21:30 Total Suspended Solids 50.0 10 mg/L 49.4 1 20
Duplicate (B3B0225-DUP2) Source: 2300856-02 Analyzed: 02/07/23 21:30 Total Suspended Solids 2580 10 mg/L 2600 0.8 20
The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

307 Roemer Way, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376
CA-ELAP 2438, TNI02666 Client Connect: client.oec.com\reports

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Project:

Project Number:

Project Manager:

Mustang Renewable Power Ventures
14470 Calle Real R.O.V.D.

Dylan Ellis

MRPV-ADF
Goleta CA, 93117 02/22/2023 19:12
Oilfield Environmental & Compliance, Inc.
2300847
WO & Reported:

General Chemistry Parameters by EPA or APHA Standard Methods - Quality Control Result RL Units
Level
Spike
Result
Source %REC %REC
Limits

RPD RPD
Limit
Analyte Notes
[TOC_2]Batch B3B0426 - EPA 9040B pH Prep[TOC]
Batch B3B0426 - EPA 9040B/SM4500H+ B Preparation: EPA 9040B pH Prep 02/14/23 07:05 LCS (B3B0426-BS1)
[TOC_3]LCS (B3B0426-BS1)[TOC]
Analyzed: 02/14/23 07:05
pH @ 25 C 3.98 0.10 pH Units 4.01 99 90-110
LCS (B3B0426-BS2) Analyzed: 02/14/23 07:05
pH @ 25 C 7.02 0.10 pH Units 7.00 100 90-110
LCS (B3B0426-BS3) Analyzed: 02/14/23 07:05
pH @ 25 C 10.01 0.10 pH Units 10.0 100 90-110
Duplicate (B3B0426-DUP1) Source: 2300764-01
[TOC_3]Duplicate (B3B0426-DUP1)[TOC]
Analyzed: 02/14/23 07:05
pH @ 25 C 8.33 0.10 pH Units 8.37 0.5 10
pH Sample Temperature During Analysis 20.9 1.0 °C 20.3 3 10 Duplicate (B3B0426-DUP2) Source: 2300770-01 Analyzed: 02/14/23 07:05 pH @ 25 C 7.32 0.10 pH Units 7.37 0.7 10
pH Sample Temperature During Analysis 21.9 1.0 °C 20.6 6 10 [TOC_2]Batch B3B0643 - EPA 1664 Oil and Grease Prep[TOC] Batch B3B0643 - EPA 1664A Preparation: EPA 1664 Oil and Grease Prep 02/21/23 06:34 Blank (B3B0643-BLK1)
[TOC_3]Blank (B3B0643-BLK1)[TOC]
Analyzed: 02/21/23 07:15
Total Oil & Grease ND 5.0 mg/L
LCS (B3B0643-BS1)
[TOC_3]LCS (B3B0643-BS1)[TOC]
Analyzed: 02/21/23 07:15
Total Oil & Grease 42.1 5.0 mg/L 40.0 105 78-114
LCS Dup (B3B0643-BSD1)
[TOC_3]LCS Dup (B3B0643-BSD1)[TOC]
Analyzed: 02/21/23 07:15
Total Oil & Grease 41.3 5.0 mg/L 40.0 103 78-114 2 18
The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

307 Roemer Way, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376
CA-ELAP 2438, TNI02666 Client Connect: client.oec.com\reports

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Project:

Project Number:

Project Manager:

Mustang Renewable Power Ventures
14470 Calle Real R.O.V.D.

Dylan Ellis

MRPV-ADF
Goleta CA, 93117 02/22/2023 19:12
Oilfield Environmental & Compliance, Inc.
2300847
WO & Reported:

Sample Method Summary
Analysis Method Matrix Laboratory & Certification
Anions by IC
Nitrate as N by EPA 300.0 EPA 300.0 Water OEC, CA-ELAP,NELAP Nitrite as N by EPA 300.0 EPA 300.0 Water OEC, CA-ELAP,NELAP General Chemistry Parameters by EPA or APHA Standard Methods Oil and Grease by EPA 1664 EPA 1664A Water OEC, CA-ELAP,NELAP pH Sample Temperature EPA 170.1/SM 2550B Water OEC, Internal 9040B pH EPA 9040B/SM4500H+ B Water OEC, Internal
Solids, Total Suspended (TSS), SM 2540D OEC, CA-ELAP,NELAP SM2540D
Water
Phosphorus, Total as P by SM 4500-P B,E / EPA 365.3 OEC, Internal SM4500-P B,E/EPA 365.3
Water
COD, Chemical Oxygen Demand SM 5220D Water OEC, CA-ELAP,NELAP Microbiological Parameters by APHA Standard Methods
E.coli QT MPN SM9223B SM 9223B Water OEC, Internal
Total Metals by ICP
200.7 Total Iron EPA 200.7 Water OEC, CA-ELAP,NELAP
Notes and Definitions [TOC_1]Notes and Definitions[TOC] Qualifier Definition
MDL
RPD Relative Percent Difference
ND Analyte NOT DETECTED at or above the method limit (MDL) Method Detection Limit
RL Reporting Limit (Quantitation Limit)
HT-09 This sample was received outside of the EPA recommended holding time.

HT-pH Water pH should be analyzed within 15 minutes of sampling. Soil pH should be analyzed as soon as possible.

The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

307 Roemer Way, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376
CA-ELAP 2438, TNI02666 Client Connect: client.oec.com\reports

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Project:

Project Number:

Project Manager:

Mustang Renewable Power Ventures
14470 Calle Real R.O.V.D.

Dylan Ellis

MRPV-ADF
Goleta CA, 93117 02/22/2023 19:12
Oilfield Environmental & Compliance, Inc.
2300847
WO & Reported:
[TOC_1]Other Documents[
The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

307 Roemer Way, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376
CA-ELAP 2438, TNI02666 Client Connect: client.oec.com\reports

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 
30 BUHFHLSW
VDPSOHRHFFRPLQGH[SKS 
6DPSOH5HFHLSW
:RUN2UGHU5HYLHZLV&RPSOHWH
:RUN2UGHU
 5HIUHVK
&OLHQW1DPH 7HPSÉ& 5HIULJHUDWRU
V
&2&5HFHLYHG /RJLQ
0XVWDQJ 5HQHZDEOH 3RZHU 9HQWXUHV 

eiueiuieij


eiueiuieij 

5HFRUGHG&RUUHFWHG$FFHSWDEOH5DQJHÉ&WRÉ&
6HH([FHSWLRQ1RWHV%HORZ

6DPSOH7UDQVSRUW
2(&&RXULHU6DPSOHU $IWHU+RXUV'URS2II'HOLYHU\
2WKHUWKDQ2(&
6KLSPHQW&DUULHU 7UDFNLQJ
&XVWRG\6HDOV 1RQH3UHVHQW
&RROHU
V
3UHVHQW,QWDFW 3UHVHQW1RW,QWDFW 1RQH
6DPSOH
V
3UHVHQW,QWDFW 3UHVHQW1RW,QWDFW 1RQH
&RQGLWLRQ3UHVHUYDWLRQ <HV 1R 1$
 5HFHLYHG2Q,FH:LWKLQ5DQJH
$FFHSWDEOH
&RPSOHWHG&2&V5HFHLYHGZLWK6DPSOH
V

5HFHLYHG2XWVLGH5DQJH
$FFHSWDEOH
&RUUHFW&RQWDLQHU
V
3UHVHUYHIRU$QDO\VLV
'LUHFWIURP)LHOGRQ,FH &RQWDLQHU
V
,QWDFWDQG*RRG&RQGLWLRQ$PELHQW
$LURU)LOWHU0DWUL[ &RQWDLQHU/DEHO
V
&RQVLVWHQWZLWK&2&
5HFHLYHG$PELHQW3ODFHGRQ,FH 2(&3UHVHUYDWLRQ$GGHG

6DPSOH7HPSHUDWXUH$FFHWDEOHIRU$QDO\VLV 6DPSOH4XDQWLW\6XIILFHQW  5HFHLYHG2XWVLGH5DQJH>([FHSWLRQ@

,QVXIILFLHQW,FHRU8QNQRZQ
([FHVVLYH)UHH/LTXLG

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 
30 BUHFHLSW
VDPSOHRHFFRPLQGH[SKS 
&RQWDLQHUV&2&&KDQJHV$QG2U&RUUHFWLRQV
&RWDQLQHU,'
&2&
&RQWDLQHU'HVFULSWLRQ +RPH 0DWUL[ 3UHVHUYDWLYH S+&KORULQH 6XOIXU &RPPHQWV$ P/*ODVV $PEHU
+&O )ULGJH:DON,Q :DWHU% P/3RO\ )ULGJH:DON,Q :DWHU & P/3RO\ )ULGJH:DON,Q :DWHU
' P/3RO\+62 )ULGJH:DON,Q :DWHU
( P/3RO\+12 )ULGJH:DON,Q :DWHU
) P/3RO\+12 )ULGJH:DON,Q :DWHU
* P/%DFWL3RO\1D62 VWHULOH
P/ILOO
0LFUR%LR)ULGJH :DWHU
5HFHLSW/RJLQ%\

*65 

5HFHLSW5HYLHZHG%\

(04 


DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

ATTACHMENT E
Central Coast Regional Water Quality Control Board Notice of Violation Letter dated March 17, 2023
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Central Coast Regional Water Quality Control Board
March 17, 2023

SENT VIA ELECTRONIC AND CERTIFIED MAIL
Certified Mail No. 7020 1810 0002 0768 1810
John Dewey
Chief Executive Officer
Mustang Renewable Power Ventures, LLC
17 Corporate Plaza Drive, Suite 200
Newport Beach, CA 92660
[email protected]
Dear John Dewey,
ENFORCEMENT PROGRAM: TAJIGUAS COMPOST MANAGEMENT UNIT, SANTA BARBARA COUNTY – NOTICE OF VIOLATION
The California Regional Water Quality Control Board, Central Coast Region (Central Coast Water Board) is a state regulatory agency with the responsibility for protecting the quality of the waters of the state within its area of jurisdiction. The Central Coast Water Board has authority to require submission of information, direct action, establish regulations, levy penalties, and bring legal action when necessary to protect water quality. The purpose of this letter is to notify Mustang Renewable Power Ventures, LLC (Discharger) of alleged violations of state law at its Tajiguas Compost Management Unit (Facility) located at 14470 Calle Real in Goleta, require a written response describing the actions taken or planned to be taken to address violations and prevent future violations, and explain the potential civil administrative liability for non-compliance with state and federal laws, including unauthorized discharges of waste to waters of the state and waters of the United States.

Background
The Discharger is enrolled General Waste Discharge Requirements for Commercial Composting Operations Order 2020-0012-DWQ (Compost General Order). The Facility is also a postclosure land use at the Tajiguas Landfill, which is owned and operated by the County of Santa Barbara (County).

On June 11, 2021, the Central Coast Water Board issued the Discharger a notice of applicability (NOA) to enroll the Facility in the Compost General Order. The NOA included approval of the Discharger’s Water and Wastewater Management Plan, which is included in the Facility’s technical report. The approved Water and Wastewater Management Plan details operational procedures to prevent wastewater from DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 2 - March 17, 2023
Notice of Violation
discharging from the Facility. The Compost General Order defines wastewater as “leachate or any other liquid flowing from, or on the working surface” and leachate as “any liquid formed by the drainage of liquids from, or percolation/flow of liquids through any feedstock, additive, amendment, or compost (active, curing, or final product) pile” (Compost General Order Attachment A). Due to concerns about the discharge of wastewater from the Facility based on previous inspections on December 5, 2022, and January 25, 2023, and from conversations with the Discharger and County staff, Central Coast Water Board staff conducted a Facility inspection on March 13, 2023.

Alleged Violations
Based on information provided by Mustang Renewable Power Ventures, LLC staff and County staff and information from site inspections the Discharger has violated the following conditions of the Compost General Order at the Facility:

1. The Discharger has not managed wastewater in accordance with the Facility’s approved Water and Wastewater Management Plan, which is a violation of Compost General Order Specification 6. These violations include not implementing the following procedures included in the approved Water and Wastewater Management Plan:
a. The Water and Wastewater Management Plan indicates that before bypassing runoff from the compost working surface as clean stormwater, operators would first fully cover the compost with waterproof tarpaulins, place wattles between compost rows, and sweep the isles between windrows. During recent runoff diversion, the compost windrows and piles were not fully covered, the aisles were not fully swept to remove compost/waste from the exposed working surface areas, and wattles were not placed between all windrows. Thus, working surface runoff from the March 10, 2023, storm contacted compost/waste, which discharged from the Facility as wastewater. Mustang Renewable Power Ventures, LLC staff and County staff indicated that this water was diverted during the March 10, 2023, storm to the north sedimentation basin, which ultimately discharged to Pila Creek.
b. The approved Water and Wastewater Management Plan indicates that wattles would be placed at the stormwater drainage inlets at all times. During the March 13, 2023, inspection there were no wattles surrounding the northern drainage inlet.
c. The approved Water and Wastewater Management Plan includes requirements to sample and test each time runoff is bypassed to the Landfill north sedimentation basin instead of being captured as wastewater within the onsite tanks. Based on conversations with Mustang Renewable Power Ventures, LLC staff and County staff, samples were not taken during previous diversion events where water was discharged to the Landfill north sedimentation basin as required by the approved Water and Wastewater Management Plan, such as diversion DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 3 - March 17, 2023
Notice of Violation
during the January 9, 2023, storm event. Another diversion event, where samples were not collected, occurred during the December 27-29, 2021 storm event, which was documented in the March 2022 Annual Report. Conversations with the Mustang Renewable Power Ventures, LLC staff and County staff indicate that there may be additional bypass/discharges after work hours because there are no sensors, flow meters, or other triggers to alert operators of an overflow or bypass.

2. The Discharger has discharged waste (wastewater) to surface water (Pila Creek) without authorization from an NPDES permit. This is a violation of Compost General Order Prohibition 6. The Industrial General Permit (IGP) is a stormwater permit and does not authorize the discharge of wastewater, which is defined above. IGP requirements and potential violations are not discussed in this letter.

3. The Discharger discharged feedstock and compost outside of the designated composting operation areas that are specified in the technical report. This is a violation of Compost General Order Prohibition 1 and Specification 4. This includes compost found under the conveyer system that connects the anerobic digestion facility (ADF) to the compost Facility, as documented in the March 13, 2023, inspection report. This includes compost found on the densitometer table working surface area, which according to the approved technical report, was designed to include a berm surrounding the working surface to prevent compost impacted wastewater from discharging from the Facility. The lack of berm installation was documented by the Discharger in a February 8, 2023, report. Central Coast Water Board staff did not approve this report as an official technical report addendum and responded to the Discharger via email on February 8, 2023, indicating concerns about wastewater potentially discharging from this area. This correspondence as well as documentation of compost/waste on the densitometer table working surface, is included in the March 13, 2023, inspection report.

4. The Discharger has not maintained Facility berms in good working condition and has not prevented erosion and damage to the berms, as documented in recent inspection reports. This is a violation of Compost General Order Specification 10 and Maintenance Requirement 1.

5. The Discharger has not maintained the drainage conveyance systems to convey wastewater in a manner that prevents conditions resulting in contamination, pollution, or nuisance. The piping and connections that makes up the drainage conveyance system continues to leak wastewater to areas outside of the Facility, as documented in recent inspection reports. This is a violation of Compost General Order Specification 11.

6. The Discharger has not implemented sufficient corrective actions to address previous noncompliance, such as making timely and successful repairs or replacements to the wastewater/stormwater pipes. This is a violation of Compost General Order Additional Requirement 2.

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 4 - March 17, 2023
Notice of Violation

7. The Discharger has not adequately reported events of noncompliance or notified Central Coast Water Board of all Compost General Order violations, such as notification and reporting of wastewater discharges from the Facility, including the wastewater discharge resulting from the January 9, 2023, storm event. The Compost General Order includes reporting requirements including estimating the volume of wastewater when there is a discharge, which must be submitted in a report to Central Coast Water Board staff within 10 working days of noncompliance. This is a violation of Compost General Order Monitoring and Reporting section B.3 and Compost General Order Notification Requirement 4.

8. Facility feedstocks listed in the notice of intent and Technical Report are green material and anaerobic digestate. The Compost General Order requires that anerobic digestate be derived from allowable Tier 2 feedstocks. Additionally, the Compost General Order defines anerobic digestate as, “the solid portion of the material remaining after the anaerobic digestion of any combination of agricultural materials, biosolids, sewage sludge, food materials, green materials, manure, paper materials, or vegetative food materials. Dewatered digestate contains organic matter that may need to be further treated to stabilize it, usually through aerated composting.” The Compost General Order prohibits any feedstock, additive, or amendment other than those specifically described in the Compost General Order, unless approved by the Regional Water Board. Based on information provided by the Discharger via email on March 15, 2023, and presented in the March 13, 2023, inspection report including the March 15, 2023, email as attachment 1 and inspection photos, feedstock at the site contain significant amounts of inorganic contaminates including glass and plastics, which are not approved feedstocks, additives, or amendments, nor are these materials compostable. This is a violation of Compost General Order Prohibition 3 and 4 and Specification 7. The Discharger must comply with the Compost General Order and ensure that only approved feedstocks are stored and/or composted at the Facility. For a full list of approved Tier 1 and 2 feedstocks allowed in anerobic digestate, please see Compost General Order Table 2.”
Immediate corrective actions must be taken to address the violations listed above and actions must be taken to ensure that future operations meet the conditions of the Compost General Order and the approved Water and Wastewater Management Plan.

Requirements for Written Response to Alleged Violations The Discharger must address the alleged violations described above immediately and must submit by April 3, 2023, a written response describing the actions taken or planned to address the above alleged violations and prevent future violations. For violations that the Discharger has not addressed immediately, the response must include a time schedule for corrective actions to bring the compost Facility into compliance with the requirements of the Compost General Order.

Responses must be submitted electronically to: [email protected].

DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 5 - March 17, 2023
Notice of Violation
This notice of violation is intended to facilitate a timely remedy to address the Discharger’s alleged Compost General Order violations. Central Coast Water Board staff will determine the need to recommend further enforcement actions based upon the Discharger’s responses and future compliance with the Compost General Order.

Potential Administrative Civil Liability
The Discharger is hereby on notice that California Water Code (Water Code) section 13350 provides that any person who intentionally or negligently violates any conditions issued or amended by the Regional Water Board or State Water Board, is subject to administrative civil liability of up to $5,000 per day of violation or $10 per gallon of waste discharged. Alternatively, the superior court may impose civil liability for each violation of up to $15,000 per day or $20 per gallon of waste discharged.

The Discharger does not have a permit to discharge pollutants to waters of the United States. Unpermitted discharges of pollutants to waters of the United States are violations of federal Clean Water Act (Clean Water Act) section 301. Clean Water Act section 301 violations are subject to liability under Water Code section 13385, which authorizes the Central Coast Water Board to impose administrative civil liability of up to $10,000 per day of violation and $10 per gallon discharged but not cleaned up over 1,000 gallons. Alternatively, a court may impose civil liability of up to $25,000 for each day the violation occurs, and up to $25 per gallon of waste discharged but not cleaned up over 1,000 gallons.

Furthermore, the Central Coast Water Board reserves the right to take any enforcement action authorized by law including, but not limited to, termination of the Compost General Order coverage (Compost General Order Additional Requirement 1) which may result from any noncompliance with Compost General Order requirements, and would require the Discharge to implement a closure plan to perform site restoration as outlined in the Facility’s Technical Report.

If you have any questions, please feel free to contact Jordan Haserot by phone at (805) 542-4781 or email at [email protected], or Ryan Lodge at (805) 549- 3506.

Sincerely,
for Thea S. Tryon
Assistant Executive Officer
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 6 - March 17, 2023
Notice of Violation
cc:

John Kular, [email protected]
Jeanette Gonzales-Knight, [email protected]
Travis Spier, [email protected]
Christina Wilder, [email protected]
Norma Campos Bernal, [email protected]
Angela Schroeter, [email protected]
Ryan Lodge, [email protected]
Jordan Haserot, [email protected]
Thea Tryon, [email protected]
Tamara Anderson, [email protected]
Todd Stanley, [email protected]
Jesse Woodard, [email protected]
R:\RB3\Shared\LDU\Program\Compost\Compost Facilities\Tajiguas\NOVs\2023\Tajiguas Compost Managemenet Unit NOV.docx
GeoTracker ID: T10000017039
CIWQS Place ID: 874811
DocuSign Envelope ID: 153A11E7-C183-4DBE-9A83-2554F1983275 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

Scott D. McGolpin
Public Works Director
Marty Wilder
Interim Deputy Director
April 25, 2023
John Dewey, CEO & Managing Member [US mail and emailed] MSB Investors, LLC
17 Corporate Plaza, Suite 200
Newport Beach, CA 92660
Email: [email protected]
SUBJECT: Notice of Intent to Assess Liquidated Damages for Failure to Comply with Central Coast Regional Water Quality Control Compost General Order and Summary of Liquidated Damages
Mr. John Dewey,
The Agreement between MSB Investors, LLC (MSB) and the County of Santa Barbara (County) for the development and operation of the Tajiguas Resource Recovery Project (Project, also referred to as the ReSource Center) sets forth liquidated damages at varying amounts in Exhibit D.

Section 5.8.E of the Agreement requires that the, “Contractor shall use Good Industry Practice in managing and monitoring the water, wastewater and storm water at the Facility.” Additionally, Section 5.8.H of the Agreement states that the, “Contractor shall perform all the requirements to comply with all federal, State, City and any other governmental unit Permits, orders, licenses, approvals and CEQA mitigations required by Applicable Law for the Facility”. Per Section 5.8 of the Agreement, “the County may assess liquidated damages in accordance with Section 14.9 and Exhibit D: Liquidated Damages for failure to prevent nuisances as described in this Section 5.8”.

The Central Coast Regional Water Quality Control Board’s Notices of Violation letter dated March 17, 2023 can be found in Attachment A and lists the eight Compost General Order requirements that MSB failed to comply with at the ReSource Center.

Failure to meet these requirements, as provided in Section 5.8 and Exhibit D of the Agreement, results in liquidated damages of $500 per day per incident until resolved. The County will begin assessing liquidated damages associated with each violation effective April 26, 2023.

In accordance with Section 14.9.B of the Agreement, this Notice is hereby provided to MSB that the ongoing non-compliance with Central Coast Regional Water Quality Control Compost General Order will trigger the accrual and assessment of liquidated damages. Ongoing violations, as noted in Attachment A violations 3, 4, 5, 6, and 8 will result in daily assessments until the violation is remedied. Pursuant to Section 14.9, MSB may, within ten days after receiving this Notice, request a meeting with Jeanette Gonzales-Knight to present oral or written evidence relevant to these ongoing conditions.

DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey, CEO & Managing Member
MSB Investors, LLC
April 25, 2023

The County reserves its right to assess additional liquidated damages in accordance with Section

5.8 and Exhibit D based on MSB's failure to comply with the Agreement, and to seek any other remedies available to resolve said failures. In addition to the liquidated damages, MSB is responsible for remedying the issues and any additional costs to County.

As of April 24, 2023, the following is a summary of the liquidated damages assessed against MSB, totaling $2,967,000, and their status:
 Failure to comply with the Project’s SBCAPCD permit by bringing a diesel-powered trommel screen to the site on June 3, 2022 – effective July 5, 2022. Total liquidated damages for this violation amount $500.
 Failure to meet project milestones for ADF/Composting Management Unit (CMU) Acceptance Test by December 21, 2021 – effective August 1, 2022 and resolved on October 27, 2022. Total liquidated damages of $5,000 per day per missed milestone date amount to $435,000.
 Failure to meet project milestones for Start Up Test and Acceptance Test Requirements per Section 4.8.B of the Agreement by December 21, 2021 – effective August 1, 2022 and resolved on March 1, 2023. Total liquidated damages of $5,000 per day per missed milestone date amount to $1,060,000.
 Failure to meet project milestones for Permit to Operate applications required under Santa Barbara County Air Pollution Control District (SBCAPCD) Authority to Construct Permit Modification No. 14500-05 – effective August 1, 2022 and not resolved. Liquidated damages of $5,000 per day per missed milestone date amount to $1,330,000 as of April 24, 2023 and will continue to be assessed until resolved.  14 CCR 17863.4 – Odor Impact Minimization Plan – 9/21/22 and 10/19/22 Compostable Materials Handling Operation and Facility Inspections – effective November 18, 2022 and resolved on November 30, 2022. Total liquidated damages of $500 per day per stated violation amount to $6,000 for this violation.
 14 CCR 17896.31 - ADF - Failure to comply with OIMP – effective February 6, 2023 and not resolved. Liquidated damages of $500 per day per stated violation amount to $38,500 as of April 24, 2023 and will continue to be assessed until resolved.  14 CCR 17896.32 - ADF - Odor and Nuisance Control – effective February 6, 2023 and not resolved. Liquidated damages of $500 per day per stated violation amount to $38,500 as of April 24, 2023 and will continue to be assessed until resolved.  14 CCR 17867(a)(2) - CMU - Odor Control – effective February 6, 2023 and not resolved.

Liquidated damages of $500 per day per stated violation amount to $38,500 as of April 24, 2023.

DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey, CEO & Managing Member
MSB Investors, LLC
April 25, 2023

 Failed Acceptance Test – effective April 14, 2023 and not resolved. Liquidated damages of $2,000 per day until remedied amount to $20,000 as of April 24, 2023 and will continue to be assessed until resolved.

Thank you for your cooperation in implementing the necessary actions to comply with all regulatory requirements.

Sincerely,
Jeanette Gonzales-Knight, PE
Compliance Manager, Santa Barbara County Public Works Department cc: Scott McGolpin, Santa Barbara County Public Works Department Marty Wilder, Santa Barbara County Public Works Department Carlyle Johnston, Santa Barbara County Public Works Department Attachment A: Central Coast Regional Water Quality Control Board Notice of Violation Letter dated March 17, 2023
Attachment B: John Kular Consulting response on behalf of Mustang Renewable Power Ventures, LLC, submitted March 21, 2023 and March 30, 2023 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment A
Central Coast Regional Water Quality Control Board
Notice of Violation Letter dated March 17, 2023

DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Central Coast Regional Water Quality Control Board
March 17, 2023

SENT VIA ELECTRONIC AND CERTIFIED MAIL
Certified Mail No. 7020 1810 0002 0768 1810
John Dewey
Chief Executive Officer
Mustang Renewable Power Ventures, LLC
17 Corporate Plaza Drive, Suite 200
Newport Beach, CA 92660
[email protected]
Dear John Dewey,
ENFORCEMENT PROGRAM: TAJIGUAS COMPOST MANAGEMENT UNIT, SANTA BARBARA COUNTY – NOTICE OF VIOLATION
The California Regional Water Quality Control Board, Central Coast Region (Central Coast Water Board) is a state regulatory agency with the responsibility for protecting the quality of the waters of the state within its area of jurisdiction. The Central Coast Water Board has authority to require submission of information, direct action, establish regulations, levy penalties, and bring legal action when necessary to protect water quality. The purpose of this letter is to notify Mustang Renewable Power Ventures, LLC (Discharger) of alleged violations of state law at its Tajiguas Compost Management Unit (Facility) located at 14470 Calle Real in Goleta, require a written response describing the actions taken or planned to be taken to address violations and prevent future violations, and explain the potential civil administrative liability for non-compliance with state and federal laws, including unauthorized discharges of waste to waters of the state and waters of the United States.

Background
The Discharger is enrolled General Waste Discharge Requirements for Commercial Composting Operations Order 2020-0012-DWQ (Compost General Order). The Facility is also a postclosure land use at the Tajiguas Landfill, which is owned and operated by the County of Santa Barbara (County).

On June 11, 2021, the Central Coast Water Board issued the Discharger a notice of applicability (NOA) to enroll the Facility in the Compost General Order. The NOA included approval of the Discharger’s Water and Wastewater Management Plan, which is included in the Facility’s technical report. The approved Water and Wastewater Management Plan details operational procedures to prevent wastewater from DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 2 - March 17, 2023
Notice of Violation
discharging from the Facility. The Compost General Order defines wastewater as “leachate or any other liquid flowing from, or on the working surface” and leachate as “any liquid formed by the drainage of liquids from, or percolation/flow of liquids through any feedstock, additive, amendment, or compost (active, curing, or final product) pile” (Compost General Order Attachment A). Due to concerns about the discharge of wastewater from the Facility based on previous inspections on December 5, 2022, and January 25, 2023, and from conversations with the Discharger and County staff, Central Coast Water Board staff conducted a Facility inspection on March 13, 2023.

Alleged Violations
Based on information provided by Mustang Renewable Power Ventures, LLC staff and County staff and information from site inspections the Discharger has violated the following conditions of the Compost General Order at the Facility:

1. The Discharger has not managed wastewater in accordance with the Facility’s approved Water and Wastewater Management Plan, which is a violation of Compost General Order Specification 6. These violations include not implementing the following procedures included in the approved Water and Wastewater Management Plan:
a. The Water and Wastewater Management Plan indicates that before bypassing runoff from the compost working surface as clean stormwater, operators would first fully cover the compost with waterproof tarpaulins, place wattles between compost rows, and sweep the isles between windrows. During recent runoff diversion, the compost windrows and piles were not fully covered, the aisles were not fully swept to remove compost/waste from the exposed working surface areas, and wattles were not placed between all windrows. Thus, working surface runoff from the March 10, 2023, storm contacted compost/waste, which discharged from the Facility as wastewater. Mustang Renewable Power Ventures, LLC staff and County staff indicated that this water was diverted during the March 10, 2023, storm to the north sedimentation basin, which ultimately discharged to Pila Creek.
b. The approved Water and Wastewater Management Plan indicates that wattles would be placed at the stormwater drainage inlets at all times. During the March 13, 2023, inspection there were no wattles surrounding the northern drainage inlet.
c. The approved Water and Wastewater Management Plan includes requirements to sample and test each time runoff is bypassed to the Landfill north sedimentation basin instead of being captured as wastewater within the onsite tanks. Based on conversations with Mustang Renewable Power Ventures, LLC staff and County staff, samples were not taken during previous diversion events where water was discharged to the Landfill north sedimentation basin as required by the approved Water and Wastewater Management Plan, such as diversion DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 3 - March 17, 2023
Notice of Violation
during the January 9, 2023, storm event. Another diversion event, where samples were not collected, occurred during the December 27-29, 2021 storm event, which was documented in the March 2022 Annual Report. Conversations with the Mustang Renewable Power Ventures, LLC staff and County staff indicate that there may be additional bypass/discharges after work hours because there are no sensors, flow meters, or other triggers to alert operators of an overflow or bypass.

2. The Discharger has discharged waste (wastewater) to surface water (Pila Creek) without authorization from an NPDES permit. This is a violation of Compost General Order Prohibition 6. The Industrial General Permit (IGP) is a stormwater permit and does not authorize the discharge of wastewater, which is defined above. IGP requirements and potential violations are not discussed in this letter.

3. The Discharger discharged feedstock and compost outside of the designated composting operation areas that are specified in the technical report. This is a violation of Compost General Order Prohibition 1 and Specification 4. This includes compost found under the conveyer system that connects the anerobic digestion facility (ADF) to the compost Facility, as documented in the March 13, 2023, inspection report. This includes compost found on the densitometer table working surface area, which according to the approved technical report, was designed to include a berm surrounding the working surface to prevent compost impacted wastewater from discharging from the Facility. The lack of berm installation was documented by the Discharger in a February 8, 2023, report. Central Coast Water Board staff did not approve this report as an official technical report addendum and responded to the Discharger via email on February 8, 2023, indicating concerns about wastewater potentially discharging from this area. This correspondence as well as documentation of compost/waste on the densitometer table working surface, is included in the March 13, 2023, inspection report.

4. The Discharger has not maintained Facility berms in good working condition and has not prevented erosion and damage to the berms, as documented in recent inspection reports. This is a violation of Compost General Order Specification 10 and Maintenance Requirement 1.

5. The Discharger has not maintained the drainage conveyance systems to convey wastewater in a manner that prevents conditions resulting in contamination, pollution, or nuisance. The piping and connections that makes up the drainage conveyance system continues to leak wastewater to areas outside of the Facility, as documented in recent inspection reports. This is a violation of Compost General Order Specification 11.

6. The Discharger has not implemented sufficient corrective actions to address previous noncompliance, such as making timely and successful repairs or replacements to the wastewater/stormwater pipes. This is a violation of Compost General Order Additional Requirement 2.

DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 4 - March 17, 2023
Notice of Violation

7. The Discharger has not adequately reported events of noncompliance or notified Central Coast Water Board of all Compost General Order violations, such as notification and reporting of wastewater discharges from the Facility, including the wastewater discharge resulting from the January 9, 2023, storm event. The Compost General Order includes reporting requirements including estimating the volume of wastewater when there is a discharge, which must be submitted in a report to Central Coast Water Board staff within 10 working days of noncompliance. This is a violation of Compost General Order Monitoring and Reporting section B.3 and Compost General Order Notification Requirement 4.

8. Facility feedstocks listed in the notice of intent and Technical Report are green material and anaerobic digestate. The Compost General Order requires that anerobic digestate be derived from allowable Tier 2 feedstocks. Additionally, the Compost General Order defines anerobic digestate as, “the solid portion of the material remaining after the anaerobic digestion of any combination of agricultural materials, biosolids, sewage sludge, food materials, green materials, manure, paper materials, or vegetative food materials. Dewatered digestate contains organic matter that may need to be further treated to stabilize it, usually through aerated composting.” The Compost General Order prohibits any feedstock, additive, or amendment other than those specifically described in the Compost General Order, unless approved by the Regional Water Board. Based on information provided by the Discharger via email on March 15, 2023, and presented in the March 13, 2023, inspection report including the March 15, 2023, email as attachment 1 and inspection photos, feedstock at the site contain significant amounts of inorganic contaminates including glass and plastics, which are not approved feedstocks, additives, or amendments, nor are these materials compostable. This is a violation of Compost General Order Prohibition 3 and 4 and Specification 7. The Discharger must comply with the Compost General Order and ensure that only approved feedstocks are stored and/or composted at the Facility. For a full list of approved Tier 1 and 2 feedstocks allowed in anerobic digestate, please see Compost General Order Table 2.”
Immediate corrective actions must be taken to address the violations listed above and actions must be taken to ensure that future operations meet the conditions of the Compost General Order and the approved Water and Wastewater Management Plan.

Requirements for Written Response to Alleged Violations The Discharger must address the alleged violations described above immediately and must submit by April 3, 2023, a written response describing the actions taken or planned to address the above alleged violations and prevent future violations. For violations that the Discharger has not addressed immediately, the response must include a time schedule for corrective actions to bring the compost Facility into compliance with the requirements of the Compost General Order.

Responses must be submitted electronically to: [email protected].

DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 5 - March 17, 2023
Notice of Violation
This notice of violation is intended to facilitate a timely remedy to address the Discharger’s alleged Compost General Order violations. Central Coast Water Board staff will determine the need to recommend further enforcement actions based upon the Discharger’s responses and future compliance with the Compost General Order.

Potential Administrative Civil Liability
The Discharger is hereby on notice that California Water Code (Water Code) section 13350 provides that any person who intentionally or negligently violates any conditions issued or amended by the Regional Water Board or State Water Board, is subject to administrative civil liability of up to $5,000 per day of violation or $10 per gallon of waste discharged. Alternatively, the superior court may impose civil liability for each violation of up to $15,000 per day or $20 per gallon of waste discharged.

The Discharger does not have a permit to discharge pollutants to waters of the United States. Unpermitted discharges of pollutants to waters of the United States are violations of federal Clean Water Act (Clean Water Act) section 301. Clean Water Act section 301 violations are subject to liability under Water Code section 13385, which authorizes the Central Coast Water Board to impose administrative civil liability of up to $10,000 per day of violation and $10 per gallon discharged but not cleaned up over 1,000 gallons. Alternatively, a court may impose civil liability of up to $25,000 for each day the violation occurs, and up to $25 per gallon of waste discharged but not cleaned up over 1,000 gallons.

Furthermore, the Central Coast Water Board reserves the right to take any enforcement action authorized by law including, but not limited to, termination of the Compost General Order coverage (Compost General Order Additional Requirement 1) which may result from any noncompliance with Compost General Order requirements, and would require the Discharge to implement a closure plan to perform site restoration as outlined in the Facility’s Technical Report.

If you have any questions, please feel free to contact Jordan Haserot by phone at (805) 542-4781 or email at [email protected], or Ryan Lodge at (805) 549- 3506.

Sincerely,
for Thea S. Tryon
Assistant Executive Officer
DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 6 - March 17, 2023
Notice of Violation
cc:

John Kular, [email protected]
Jeanette Gonzales-Knight, [email protected]
Travis Spier, [email protected]
Christina Wilder, [email protected]
Norma Campos Bernal, [email protected]
Angela Schroeter, [email protected]
Ryan Lodge, [email protected]
Jordan Haserot, [email protected]
Thea Tryon, [email protected]
Tamara Anderson, [email protected]
Todd Stanley, [email protected]
Jesse Woodard, [email protected]
R:\RB3\Shared\LDU\Program\Compost\Compost Facilities\Tajiguas\NOVs\2023\Tajiguas Compost Managemenet Unit NOV.docx
GeoTracker ID: T10000017039
CIWQS Place ID: 874811
DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment B
John Kular Consulting response on behalf of Mustang Renewable Power Ventures, LLC, submitted March 21, 2023 and March 30, 2023 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: FD7CB264-C963-479E-BEF7-312442B0CEED DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

Scott D. McGolpin
Public Works Director
Jeanette Gonzales-Knight
Deputy Director, Interim
June 21, 2023
John Dewey, CEO & Managing Member [US mail and emailed] MSB Investors, LLC
17 Corporate Plaza, Suite 200
Newport Beach, CA 92660
Email: [email protected]
SUBJECT: Notice of Curable Breach to Agreement for the Tajiguas Resource Recovery Project and Ongoing Liquidated Damages
Mr. John Dewey,
This letter serves as a formal notification of a curable breach event by MSB Investors, LLC (MSB) for failure to comply with the Agreement between MSB and the County of Santa Barbara (County) for the Development and Operation of the Tajiguas Resource Recovery Project (Project), also referred to as the ReSource Center, in accordance with Sections 14.2.B.9, 10, and 11 of the Agreement.

On June 20, 2023, the County received a letter from the Central Coast Regional Water Quality Control Board (CCRWQCB) Enforcement Program regarding MSB’s continued non-compliance with state and federal laws, including among the 8 listed violations unauthorized discharges of wastewater from the Composting Management Unit (CMU). A copy of the June 20, 2023 letter is included in Attachment A. Unlike the previous Notice of Violation (NOV) issued by the CCRWQCB on March 17, 2023, which only listed MSB as a discharger/responsible party, the June 20, 2023 NOV also lists the County as a discharger/responsible party that is liable for CMU violations due to the County’s ownership of the ReSource Center. Despite numerous communications and reminders from County staff in bi-weekly Commissioning and Operations meetings with MSB, the County has not received any indication that MSB has taken the required actions to rectify the situation in a timely manner. Failure to do so constitutes a material breach of the Agreement and places the ReSource Center’s ability to operate the CMU at significant risk.

MSB must immediately resolve all violations and perform all corrective actions required by the CCRWQCB (per page 5 of Attachment A), including submitting the outstanding incident reports (per page 4 of Attachment A) and missing information for the May 2023 monitoring and maintenance reports to the CCRWQCB as defined in the June 20, 2023 letter (per page 5 of Attachment A). In accordance with Section 14.2 of the Agreement, cure of this breach of the Agreement must commence within 2 days (i.e. June 23, 2023) and be complete within 15 days (i.e. July 6, 2023). In addition, MSB must complete the site improvements agreed upon in the meeting with the CCRWQCB and County on April 19, 2023, as defined in an email dated April 20, 2023 (Attachment B), by July 6, 2023. If MSB fails to cure the aforementioned events within the permitted time, in accordance with Section 14.4. of the Agreement, the County is entitled to unilaterally terminate this Agreement or impose other such sanctions.

DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey, CEO & Managing Member
MSB Investors, LLC
June 21, 2023

We sincerely hope that it does not come to this and that MSB can resolve these corrective actions swiftly.

Please note, that the NOV from the CCRWQCB is a basis for the ongoing assessment of liquidated damages in accordance with Section 14.9 and Exhibit D of the Agreement. As the June 20, 2023 letter from the CCRWQCB states that these violations have not been remedied, the County will continue to assess liquidated damages for these violations in accordance with the prior Notice of Intention. As of June 21, 2023, a total of $170,000 in liquidated damages has been assessed against MSB for failure to comply with the CCRWQCB’s Compost General Order and ongoing violations noted in the CCRWQCB’s June 20, 2023 letter only reinforce the daily assessments until the violations are remedied.

Sincerely,
Jeanette Gonzales-Knight, PE
Interim Deputy Director
cc: Scott McGolpin, Santa Barbara County Public Works Department Marty Wilder, Santa Barbara County Public Works Department Carlyle Johnston, Santa Barbara County Public Works Department Attachment A: Central Coast Regional Water Quality Control Board Enforcement Program Letter dated June 20, 2023
Attachment B: Tajiguas Composting Management Unit Action Items, Emails dated April 20, 2023
DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment A
Central Coast Regional Water Quality Control Board
Enforcement Program Letter dated June 20, 2023

DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Central Coast Regional Water Quality Control Board
June 20, 2023

SENT VIA ELECTRONIC AND CERTIFIED MAIL
John Dewey Certified Mail No. 7019-1640-0000-7909-3224
Chief Executive Officer
Mustang Renewable Power Ventures, LLC
17 Corporate Plaza Drive, Suite 200
Newport Beach, CA 92660
[email protected]
Scott McGolpin Certified Mail No. 7019-1640-0000-7909-3251 Public Works Director
County of Santa Barbara Public Works
123 East Anapamu Street
Santa Barbara, CA 93101
[email protected]
Dear John Dewey and Scott McGolpin,
ENFORCEMENT PROGRAM: TAJIGUAS COMPOST MANAGEMENT UNIT, SANTA BARBARA COUNTY – NOTICE OF VIOLATION
The California Regional Water Quality Control Board, Central Coast Region (Central Coast Water Board) is a state regulatory agency with the responsibility for protecting the quality of the waters of the state within its area of jurisdiction. The Central Coast Water Board has authority to require submission of information, direct action, establish regulations, levy penalties, and bring legal action when necessary to protect water quality. The purpose of this letter is to notify Mustang Renewable Power Ventures, LLC and the County of Santa Barbara (Collectively referred to as Dischargers) of alleged violations of state law at its Tajiguas Compost Management Unit (Facility) located at 14470 Calle Real in Goleta, and to explain the potential civil administrative liability for non-compliance with state and federal laws, including unauthorized discharges of waste to waters of the state and waters of the United States. Unlike the previous March 17, 2023, NOV, which listed just Mustang Renewable Power Ventures, LLC as a discharger/responsible party, this NOV also lists the County of Santa Barbara as a discharger/responsible party that is liable for Facility violations due to the County of Santa Barbara, Department of Public Works ownership of the Facility, per the Notice of Intent (NOI).

DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 2 - June 20, 2023
Notice of Violation
Background
The Dischargers are enrolled in General Waste Discharge Requirements for Commercial Composting Operations Order 2020-0012-DWQ (Compost General Order).

The Facility is also a postclosure land use at the Tajiguas Landfill, which is owned and operated by the County of Santa Barbara (County).

On March 17, 2023, the Central Coast Water Board issued a notice of violation (March 17, 2023, NOV) to Mustang Renewable Power Ventures, LLC because of violations of the Compost General Order.

On May 8, 2023, the Central Coast Water Board issued an updated monitoring and reporting program (MRP) requiring the Dischargers conduct more frequent Facility inspections to inform immediate Facility repairs and corrective actions, provide additional details about Compost General Order compliance, provide Central Coast Water Board staff with more frequent and detailed Facility information about potential Compost General Order violations, and provide Facility specific requirements that more appropriately align with the site-specific operations.

On June 13, 2023, the Central Coast Water Board performed an inspection of the Facility. The June 13, 2023, Inspection Report noted that the violations outlined in the March 13, 2023, NOV had not been corrected. The continued Compost General Order violations include the following:

1. Water and wastewater have not been managed in accordance with the operational procedures within the approved Water and Wastewater Management Plan, which is required by Compost General Order Specification 6.

2. The unauthorized discharge of wastewater to surface water (Pila Creek), which violates Compost General Order Prohibition 6. During the June 13, 2023, inspection wastewater was seen leaving the Facility and entering two landfill stormwater drains that connect to landfill sediment basins. According to County staff, the basins discharged to Pila Creek on April 4.

3. The discharge of feedstock and compost outside of designated areas, including below the conveyor connecting the ADF to the CMU and the D-table area which still does not have a berm surrounding the working surface as was indicated within the Facility’s technical report, which is a violation of Compost General Order Prohibition 1 and Specification 4.

4. Facility berms continue to be damaged, which violates Compost General Order Design, Construction, and Operation Requirements – All Tiers number 10 and Maintenance Requirement 1.

5. The Facility conveyance system pipes continue to be damaged and leak wastewater to areas outside of the Facility, which violates Compost General Order Design, Construction, and Operation Requirements – All Tiers number 11.

DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 3 - June 20, 2023
Notice of Violation

6. The Dischargers have not implemented sufficient corrective actions to address previous noncompliance, which violates General Order Additional Requirement 2.

7. The Dischargers have not adequately reported events of noncompliance or notified Central Coast Water Board of all Compost General Order violations, such as notification and reporting of the continued wastewater discharges from the Facility, which violates Compost General Order Monitoring and Reporting section B.3. and Compost General Order Notification Requirement 4.

8. Use of unapproved feedstocks due to the inclusion of significant physical contaminants, including plastics and glass, which is prohibited by Compost General Order Prohibition 3 and 4 and Specification 7.

Following the June 13, 2023, inspection, the Dischargers submitted an updated Water and Wastewater Management Plan, which is still under review and has not been approved.

Alleged Violations
As indicated in the March 17, 2023, NOV, the drainage conveyance pipes were leaking wastewater outside of the Facility. The March 20, 2023, response to the March 17, 2023, Notice of Violation submitted on behalf of the Dischargers, indicated that the drainage conveyance pipes would be fixed after the rainy season. Per the Compost General Order, the “wet season” is defined as October 1 to April 30. As was noted in the June 13, 2023, inspection report, the pipes have not been repaired and the pipes continue to discharge wastewater from the Facility, even after the end of the wet season.

MRP B.3. and B.4. require that the Dischargers notify the Central Coast Water Board within 48 hours of knowledge of Compost General Order violations or within 24 hours of becoming aware of noncompliance that endangers human health or the environment.

As required by MRP B.4. the Dischargers must submit a report within 10 working days of an incident such as a wastewater discharge. No such report has been submitted for the discharge noted during the June 13, 2023, inspection. Per MRP B.4. the incident report is required to include the following information:
a. The approximate date, time, and location of the noncompliance including a description of the ultimate destination of any unauthorized discharge and the flow path of such discharge to a receiving water body;
b. A description of the noncompliance and its cause;
c. Include photographs of the working surface, compost piles, pipe inlets, and other documentation documenting site conditions during the discharge event; d. The available tank capacity (gallons) during each of the three days prior to each diversion event;
DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 4 - June 20, 2023
Notice of Violation
e. The flow rate, volume, and duration of any discharge involved in the noncompliance, and how that volume was determined (i.e., flow meter, sensor); f. The amount of precipitation (in inches) the day of any discharge and for each of the seven days preceding the discharge;
g. A description (location, date and time collected, field measurements of pH, temperature, dissolved oxygen and electrical conductivity, sample identification, date submitted to laboratory, and analyses requested, including sampling for the constituents listed in Error! Not a valid bookmark self-reference.) of noncompliance discharge samples and/or surface water samples taken; h. The period of noncompliance, including dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue;
i. A time schedule and a plan to implement corrective actions necessary to prevent the recurrence of such noncompliance; and
j. The laboratory analyses of the noncompliance discharge sample and/or upstream and downstream surface water samples shall be submitted to the Regional Water Board office within 45 days of the discharge.

During the June 13, 2023, inspection, Central Coast Water Board staff informed the Dischargers that a wastewater sample must be taken of the wastewater discharging from the Facility, that they must estimate the volume of discharge, and must immediately stop wastewater from discharging. On June 15, 2023, Rincon Consultants, Inc., on behalf of the Dischargers, verified via email that the Dischargers collected a wastewater sample from the leaking Facility runoff collection pipes on June 14, 2023.

The Facility continues to be in violation of MRP B.4. until a complete incident report is submitted and the discharge ceases. The Dischargers must also correct impacts from the discharge, such as the removal of impacted soil and wastewater that flowed offsite.

Compost General Order Monitoring Requirements 1 and 2 require that Dischargers comply with the requirements within the site specific MRP. MRP B.1. requires the submittal of monthly monitoring and maintenance reports by the 15th of each month. On June 14, 2023, Rincon Consultants, Inc. submitted the May 2023 Monthly Monitoring and Maintenance Report for the Tajiguas Compost Management Unit. The report was found to be insufficient at meeting the MRP requirements including the following:

1. The report was not properly signed and did not include the proper statement of certification in accordance with Compost General Order Report Requirement 5.

2. The report did not provide a transmittal letter explaining the essential points including identifying violations as well as actions taken or planned to correct violations, as required by MRP B.1.a.

DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 5 - June 20, 2023
Notice of Violation

3. The report did not include a map showing location of observation stations or monitoring points as required by MRP B.1.b.

4. The report did not include all information in MRP section A.1.a. as required to be reported per MRP B.1.c. including a map showing where ponding on the working surface was observed, estimated size of affected area and flow rate of wastewater leaving the facility, a map of where wastewater had affected areas outside of the facility, and photographs of observed and corrected deficiencies.

5. The report did not include all information in MRP section A.1.b. as required to be reported per MRP B.1.d. including not reporting the available capacity within storage systems and capacity contained, estimated in gallons.

6. The report did not discuss the status of Compost General Order compliance and the status of correcting violations, as required by B.1.j.

7. The report did not include information for the percent of physical contaminants (e.g., glass, metal, plastic) by dry weight of received feedstock at the compost facility within the reporting month or what the primary physical contaminates were, as required by MRP B.1.k.

Immediate corrective actions must be taken to address the new and ongoing violations listed above and actions must be taken to ensure that future operations meet the conditions of the Compost General Order and associated MRP, as well as the approved Water and Wastewater Management Plan.

Potential Administrative Civil Liability
The Dischargers are hereby on notice that California Water Code (Water Code) section 13350 provides that any person who intentionally or negligently violates any conditions issued or amended by the Regional Water Board or State Water Board, is subject to administrative civil liability of up to $5,000 per day of violation or $10 per gallon of waste discharged. Alternatively, the superior court may impose civil liability for each violation of up to $15,000 per day or $20 per gallon of waste discharged.

The Dischargers do not have a permit to discharge pollutants to waters of the United States. Unpermitted discharges of pollutants to waters of the United States are violations of federal Clean Water Act (Clean Water Act) section 301. Clean Water Act section 301 violations are subject to liability under Water Code section 13385, which authorizes the Central Coast Water Board to impose administrative civil liability of up to $10,000 per day of violation and $10 per gallon discharged but not cleaned up over 1,000 gallons. Alternatively, a court may impose civil liability of up to $25,000 for each day the violation occurs, and up to $25 per gallon of waste discharged but not cleaned up over 1,000 gallons.

Furthermore, the Central Coast Water Board reserves the right to take any enforcement action authorized by law including, but not limited to, termination of the Compost DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Compost Management Unit - 6 - June 20, 2023
Notice of Violation
General Order coverage (Compost General Order Additional Requirement 1) which may result from any noncompliance with Compost General Order requirements, and would require the Dischargers to implement a closure plan to perform site restoration as outlined in the Facility’s Technical Report.

If you have any questions, please feel free to contact Jordan Haserot by phone at (805) 542-4781 or email at [email protected], or Ryan Lodge at (805) 549- 3506.

Sincerely,
for Thea S. Tryon
Assistant Executive Officer
cc:

John Kular, [email protected]
Dylan Ellis, [email protected]
Caitlyn Teague, [email protected]
Marty Wilder, [email protected]
Travis Spier, [email protected]
Jeanette Gonzales-Knight, [email protected]
Christina Wilder, [email protected]
Kevin Brown, [email protected]
Norma Campos Bernal, [email protected]
Jacqueline Tkac, [email protected]
Angela Schroeter, [email protected]
Ryan Lodge, [email protected]
Jordan Haserot, [email protected]
Thea Tryon, [email protected]
Tamara Anderson, [email protected]
Todd Stanley, [email protected]
Jesse Woodard, [email protected]
R:\RB3\Shared\LDU\Program\Compost\Compost Facilities\Tajiguas\NOVs\2023\June 2023\June 2023 Tajiguas CMU Notice of Violation.docx
GeoTracker ID: T10000017039
CIWQS Place ID: 874811
DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment B
Tajiguas Composting Management Unit Action Items,
Emails dated April 20, 2023
DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 1 Gonzales-Knight, Jeanette
From: Brown, Kevin
Sent: Monday, April 24, 2023 11:40 AM
To: Haserot, Jordan@Waterboards; Wilder, Christina; John Dewey; John Kular; Dylan Ellis Cc: Lodge, Ryan@Waterboards; Gonzales-Knight, Jeanette
Subject: RE: Tajiguas Compost Management Unit - Draft Revised MRP All,
Based on my meeting notes, here is a breakdown of the “site improvements” noted in Jordan’s email.

Site Improvement/Repair Name Current Status
Asphalt Repairs Scheduled to start when the facility is dry. Expected to be completed by the end of May.

Windrows/Stockpile Traps Ordered. Expected to be delivered the week of April 24th.

Leaking Pipe (near Baker Tanks/D‐
Table)
Currently out for bid. Fused piping to replace the existing piping.

Let me know if this table needs any corrections, additional line items, or updates. Separate actions items regarding status updates for each of these site improvements/repairs would be helpful.

Thank you,
Kevin Brown
Senior Compliance Analyst
Santa Barbara County Public Works
Resource Recovery and Waste Management Division
130 East Victoria Street, Suite 100
Santa Barbara, CA  93101
Email: [email protected]
Office: (805) 882‐3622
Cell: (858) 776‐7045
From: Haserot, Jordan@Waterboards <[email protected]> Sent: Thursday, April 20, 2023 8:23 AM
To: Wilder, Christina <[email protected]>; John Dewey <[email protected]>; John Kular <[email protected]>; Dylan Ellis <[email protected]>; Brown, Kevin <[email protected]> Cc: Lodge, Ryan@Waterboards <[email protected]>; Gonzales‐Knight, Jeanette <[email protected]>
Subject: RE: Tajiguas Compost Management Unit ‐ Draft Revised MRP Caution: This email originated from a source outside of the County of Santa Barbara. Do not click links or open attachments unless you verify the sender and know the content is safe.

Hi All,
DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 2 Thank you for meeting yesterday to discuss the draft revised MRP for the Tajiguas Compost Management Unit, as well as to discuss ongoing violations and planned site improvements. Below is a brief summary of the meeting and resulting action items.

The County provided information for two compounds that will be used at the site for odor control. As discussed, constituents in those compounds, including cobalt, molybdenum, and PEG, will be added to the MRP to reflect this change. Additionally reference to the definition of major storm event within Compost General Order Attachment A will be added to the MRP. We will also add more consistent language between sampling required during stormwater diversion events and wastewater spill/discharge release events, such as a requirement for photographs and reference to table B-1 for wastewater sampling. This change will be made to the Priority Reporting of Significant Events section of the MRP. During the meeting, it was reiterated that a discharge of wastewater is not permitted by the Compost General Order and is a permit violation when such wastewater discharge events occur. The Discharger (John D.) indicated a commitment to preventing wastewater discharge events in the future.

Action items: Within the next week, John K. said that he will provide a copy of the revised MRP with comments. He said that he will also provide a time estimate for submitting a revised and up-to-date Water and Wastewater Management Plan, including contingency plans for wastewater management.

Please also provide updates once site improvements occur at the site so that we can track progress towards permit compliance.

Thank you,
Jordan Haserot
Water Resource Control Engineer
Land Disposal Unit
Central Coast Regional Water Quality Control Board
(805) 542-4781
From: Haserot, Jordan@Waterboards
Sent: Monday, April 10, 2023 7:43 AM
To: Wilder, Christina <[email protected]>; John Dewey <[email protected]>; John Kular <[email protected]>; Dylan Ellis <[email protected]>; Gonzales‐Knight, Jeanette <[email protected]>; Brown, Kevin <[email protected]> Cc: Lodge, Ryan@Waterboards <[email protected]> Subject: RE: Tajiguas Compost Management Unit ‐ Draft Revised MRP Hi All,
Thank you for the responses. I will send out a meeting invite for April 19 from 2-3 PM.

Thanks,
Jordan Haserot
Water Resource Control Engineer
Land Disposal Unit
Central Coast Regional Water Quality Control Board
(805) 542-4781
DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 3 From: Wilder, Christina <[email protected]>
Sent: Thursday, April 6, 2023 9:58 AM
To: John Dewey <[email protected]>; John Kular <[email protected]>; Haserot, Jordan@Waterboards <[email protected]>; Dylan Ellis <[email protected]>; Gonzales‐Knight, Jeanette <[email protected]>; Brown, Kevin <[email protected]> Cc: Lodge, Ryan@Waterboards <[email protected]> Subject: RE: Tajiguas Compost Management Unit ‐ Draft Revised MRP EXTERNAL:

Hi Jordan,
I am also available April 19 from 2‐5pm and April 20 from 3‐5pm.

Thanks,
Christina Wilder | PE, QSD/P, QISP
Civil Engineer
Santa Barbara County Department of Public Works
Resource Recovery & Waste ManagementDivision
14470 Calle Real
Goleta, CA 93117
Direct: (805) 696-1173 Cell: (805) 680-8127
Email: [email protected]
From: John Dewey <[email protected]>
Sent: Wednesday, April 5, 2023 3:36 PM
To: John Kular <[email protected]>; Haserot, Jordan@Waterboards <[email protected]>; Dylan Ellis <[email protected]>; Gonzales‐Knight, Jeanette <[email protected]>; Wilder, Christina <[email protected]>; Brown, Kevin <[email protected]> Cc: Lodge, Ryan@Waterboards <[email protected]> Subject: RE: Tajiguas Compost Management Unit ‐ Draft Revised MRP Caution: This email originated from a source outside of the County of Santa Barbara. Do not click links or open attachments unless you verify the sender and know the content is safe.

Jordan,
Dylan and I are available on the 19th from 2‐5 pm and on the 20th from 3‐5 pm.

Thanks
John Dewey
DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 4 From: John Kular <[email protected]>
Sent: Wednesday, April 5, 2023 2:26 PM
To: Haserot, Jordan@Waterboards <[email protected]>; John Dewey <[email protected]>; Dylan Ellis <[email protected]>; Gonzales‐Knight, Jeanette <[email protected]>; Wilder, Christina <[email protected]>; Brown, Kevin <[email protected]> Cc: Lodge, Ryan@Waterboards <[email protected]> Subject: RE: Tajiguas Compost Management Unit ‐ Draft Revised MRP I am not available on April 17 or18.

On the 19th I am available between 2 and 5 pm.

On the 20th I am available between 1:30 and 5 pm.

Regards,
John Kular, P.E.

John Kular Consulting
890 Lindamere Ct.

Simi Valley, CA 93065
[email protected]
661‐302‐1292
From: Haserot, Jordan@Waterboards
Sent: Wednesday, April 5, 2023 1:59 PM
To: John Dewey; John Kular PE; Dylan Ellis; Gonzales‐Knight, Jeanette; Wilder, Christina; Brown, Kevin Cc: Lodge, Ryan@Waterboards
Subject: Tajiguas Compost Management Unit ‐ Draft Revised MRP Hi All,
The Compost General Order allows the Executive Officer from Regional Water Boards to issue site specific individual monitoring and reporting programs (MRPs), when needed. Due to the recent violations documented at the Tajiguas Compost Management Unit, we have put together a sitespecific MRP for the facility. Prior to finalizing the MRP, we would like to provide an opportunity for you to review a draft copy of the revised MRP (attached), so that we can discuss any questions before the document is finalized. The biggest changes to the MRP include changes to the required inspection documentation, a requirement for more frequent monitoring reports (from annual to monthly), and new stormwater diversion and tank sampling requirements.

This is also a great opportunity to have a virtual meeting to get our teams together to discuss the violations at the facility, discuss corrective actions for future compliance, and discuss any questions related to the draft revised MRP. Please respond with your availability for April 17-20 and I will send out an hour-long meeting request for the date/time that works best for everyone.

Looking forward to further conversations.

Regards,
Jordan Haserot
Water Resource Control Engineer
Land Disposal Unit
Central Coast Regional Water Quality Control Board
DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 5 (805) 542-4781

DocuSign Envelope ID: FE7A414C-7E64-4D1C-910D-416F17CF7163 DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Scott D. McGolpin
Public Works Director
Jeanette Gonzales-Knight
Deputy Director, Interim
September 13, 2023
John Dewey, CEO & Managing Member [US mail and emailed] MSB Investors, LLC
17 Corporate Plaza, Suite 200
Newport Beach, CA 92660
Email: [email protected]
SUBJECT: Response to MSB’s Curable Breach and Ongoing Liquidated Damages based on the Water Board Notice of Violations at the Tajiguas Resource Recovery Project
Mr. John Dewey,
I am writing to follow up on the matter of the California Regional Water Quality Control Board (CCRWQCB) alleged violations for Waste Discharge Requirements (WDR) for Commercial Composting Operations (Order WQ 2020-0012-DWQ) and the corrective actions as previously outlined in letters from the County of Santa Barbara (County) dated April 25, 2023 and June 21, 2023, which included a compliance deadline of July 6, 2023. I would like to acknowledge our ReSource Center Compliance Plan meeting on April 28, 2023 and telephone conversation on July 12, 2023, during which we discussed the corrective actions MSB Investors, LLC (MSB) completed, repairs that are outstanding, and MSB’s request to not assess liquidated damages which would be further evaluated by the County. On July 15, 2023, Rincon Consultants (Rincon) on behalf of MSB submitted a response to the CCRWQCB’s alleged violations and provided photo documentation of the corrective action items completed (Attachment A). Following Rincon’s submittal, the County performed an inspection of the Composting Management Unit (CMU) on July 18, 2023 and participated in meetings with MSB and its consultants, and the CCRWQCB on July 20, 2023 to discuss the outstanding corrective actions, the revised Water and Wastewater Management Plan (WWMP), and monthly monitoring and maintenance report.

As of September 13, 2023, five permit violations remain outstanding, which is a matter of concern and an ongoing breach of our agreement. These unresolved alleged violations are as follows:

Alleged Violation #1: Water and wastewater have not been managed in accordance with the operational procedures within the approved Water and Wastewater Management Plan which is required by Compost General Order Specification 6.

As discussed in the meeting on July 20, 2023, the CCRWQCB considers the 2021 WWMP to still be in effect as MSB works on operational efficiencies to handle and manage CMU runoff, train MSB staff to improve operational procedures and housekeeping, and propose revisions to the WWMP. During follow up inspections on June 13, 2023 by the CCRWQCB and on July 18, 2023 by the County, it was noted that MSB had not swept the CMU deck consistently, nor obtained sufficient storage capacity for the 25-year, 24-inch storm event as required by the CMU WDR and WWMP. MSB has committed to restoring capacity in the CMU Runoff Collection Tank prior to October 1, 2023. It is MSB’s responsibility to sweep the CMU facility pursuant to the WWMP while working with the County to evaluate DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey, CEO & Managing Member
MSB Investors, LLC
September 13, 2023

more effective sweepers for either rental or purchase. In accordance with the County’s previous determination and as supported by the additional explanation of the ongoing violation addressed above, liquidated damages of $500 per day until remedied amount to $70,000 as of September 13, 2023 and will continue to be assessed until resolved.

Alleged Violation #2: The unauthorized discharge of wastewater to surface water (Pila Creek) which violates Compost General Order Prohibition 6.

During the June 13, 2023 inspection by the CCRWQCB, runoff was seen leaving the CMU and entering two Tajiguas Landfill stormwater drains that connect to the North Sedimentation basin. The laboratory analytical results for the CMU runoff sample collected on June 14, 2023 by MSB were submitted to the CCRWQCB on August 15, 2023, 18 days after the deadline as required by WDR monitoring and reporting requirements B.3.h within 45 days of the discharge (due July 28, 2023). Although MSB removed the runoff-impacted soil by the County’s July 6, 2023 deadline, the County observed additional areas where CMU runoff subsequently entered the drainage system and leaked onto the landfill’s intermediate cover, outside of the CMU facility limits. On July 18, 2023, MSB temporarily plugged two inlet drains on the CMU deck to prevent CMU runoff entry into the drainage system pipes, which MSB reports will be replaced by MSB’s contractor prior to October 1, 2023. On July 18, 2023, County staff witnessed MSB removing additional runoff-impacted soil from the intermediate cover to prevent the CMU runoff from entering into the nearby landfill’s stormwater drain. On a phone call that afternoon, we discussed that MSB will continue to conduct daily inspections of the CMU facility to remediate any future leaks of runoff and prevent them from entering the landfill’s stormwater drains. In accordance with the County’s previous determination and as supported by the additional explanation of the ongoing violation addressed above, liquidated damages of $500 per day until remedied amount to $70,000 as of September 13, 2023 and will continue to be assessed until resolved.

Alleged Violation #3: The discharge of feedstock and compost outside of designated areas, including below the conveyor connecting the ADF to the CMU, and the D-table area which still does not have a berm surrounding the working surface as was indicated within the Facility’s technical report, which is a violation of Compost General Order Prohibition 1 and Specification 4.

MSB committed to installing a scraper onto the underside of the conveyor (return side) to prevent digestate from dropping and accumulating outside of the permitted composting operation area. As of September 13, 2023, a scraper has not been installed and the Dtable area does not have a berm surrounding the working surface as was indicated within the CMU technical report (dated April 6, 2021). In accordance with the County’s previous determination and as supported by the additional explanation of the ongoing violation addressed above, liquidated damages of $500 per day until remedied amount to $70,000 as of September 13, 2023 and will continue to be assessed until resolved.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey, CEO & Managing Member
MSB Investors, LLC
September 13, 2023

Alleged Violation #5: The Facility conveyance system pipes continue to be damaged and leak wastewater to areas outside of the Facility, which violates Compost General Order Design, Construction, and Operation Requirements – All Tiers number 11.

On July 18, 2023, County staff noted runoff from the CMU deck had entered into the drainage system piping and was leaking onto the landfill’s intermediate cover, even after MSB had previously attempted to block off the inlets. MSB’s schedule for replacement of the entire drainage system piping was originally estimated for completion by the end of May but was revised to October 1, 2023, however until replaced this continues to be a violation of the general compost order. In accordance with the County’s previous determination and as supported by the additional explanation of the ongoing violation addressed above, liquidated damages of $500 per day until remedied amount to $70,000 as of September 13, 2023 and will continue to be assessed until resolved.

Alleged Violation #6: The Dischargers have not implemented sufficient corrective actions to address previous noncompliance, which violates General Order Additional Requirement

2. As shown in MSB’s photo documentation submitted to the CCRWQCB on July 15, 2023 (Attachment A) and observed during the County’s inspection on July 18, 2023, MSB has remedied several corrective actions that were noted in the CCRWQCB’s June 13, 2023 inspection. MSB confirmed in an operations meeting on August 9, 2023 that repairs to the fence on the CMU deck were underway. The County also acknowledges that John Kular and Rincon on behalf of MSB submitted a revised WWMP to the CCRWQCB on June 13, 2023 and a follow up WWMP on August 17, 2023, however not all corrective actions have been completed and there are additional actions required by MSB to comply with the General Order as addressed in the CCRWQCB’s Notice of Violation and inspection (Attachments B and C). Please continue to keep the County updated on the status of these outstanding items and provide an expected date for completion. In accordance with the County’s previous determination and as supported by the additional explanation of the ongoing violation addressed above, liquidated damages of $500 per day until remedied amount to $70,000 as of September 13, 2023 and will continue to be assessed until resolved.

Alleged Violation #7: The Dischargers have not adequately reported events of noncompliance or notified Central Coast Water Board of all Compost General Order violations, such as notification and reporting of the continued wastewater discharges from the Facility, which violates Compost General Order Monitoring and Reporting section B.3. and Compost General Order Notification Requirement 4.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey, CEO & Managing Member
MSB Investors, LLC
September 13, 2023

As previously mentioned, the laboratory analytical results for the runoff sample collected on June 14, 2023 by MSB were submitted to the CCRWQCB on August 15, 2023, 18 days after the deadline as required by WDR monitoring and reporting requirements B.3.h within 45 days of the discharge (due July 28, 2023). In addition, incident reports for discharge events that occurred earlier in 2023 are still outstanding. The County acknowledges that the laboratory analytical reports for discharge events that occurred on March 10, 14, 22, and 30 were uploaded to GeoTracker, however, details required by WDR monitoring and reporting requirements B.3 were not included and must be remedied by MSB. In accordance with the County’s previous determination and as supported by the additional explanation of the ongoing violation addressed above, liquidated damages of $500 per day until remedied amount to $70,000 as of September 13, 2023 and will continue to be assessed until resolved.

Alleged Violation #8: The Use of unapproved feedstocks due to the inclusion of significant physical contaminants, including plastics and glass, which is prohibited by Compost General Order Prohibition 3 and 4 and Specification 7.

The County acknowledges that MSB and Rincon have objected to the CCRWQCB’s alleged violation #8 and have committed to submitting a response to address the regulatory overlap between the State Water Resources Control Board Order WQ 2020- 0012-DWQ and CalRecycle’s mandates for organic diversion. As noted in the email response dated August 29, 2023, the CCRWQCB “will not approve mixed material as a Compost General Order allowable feedstock or as an additive. The Tajiguas CMU remains in violation of Compost General Order Prohibition 3 and 4 and Specification 7, and the facility must not accept material that does not meet feedstock requirements while the facility is permitted under the Compost General Order.” Please provide the County with an expected date for Rincon’s response to the CCRWQCB. To date the County has assessed MSB with $70,000 of liquidated damages associated with this violation and will continue assessing liquidated damages until this matter is remedied or the violation is withdrawn by the CCRWQCB. MSB is required to keep the County apprised of the status of this violation.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey, CEO & Managing Member
MSB Investors, LLC
September 13, 2023

The County is pleased to acknowledge that MSB has made good faith efforts to remediate one alleged violation following the County’s June 21, 2023 letter:

Alleged Violation #4: Facility berms continue to be damaged, which violates Compost General Order Design, Construction, and Operation Requirements – All Tiers number 10 and Maintenance Requirement 1.

As shown in MSB’s photo documentation submitted to the CCRWQCB on July 15, 2023 (Attachment A) and observed during the County’s inspection on July 18, 2023, berms and asphalt repairs on the CMU deck were completed on June 30, 2023 and July 14, 2023.

MSB also confirmed in a follow up meeting on August 9, 2023 that a slurry coat was applied to the asphalt repairs made around the CMU Baker tanks to improve the integrity of the newly installed berm. Liquidated damages of $500 per day were assessed until the corrective action was remedied on July 14, 2023 and amount to $39,500. Accordingly, these damages are due and payable to the County within 10 days of the date of this letter.

Please be aware that the County has taken into consideration MSB’s arguments for allowing noncompliance of the WDR due to Uncontrollable Circumstances that were beyond the reasonable control of the Contractor (as defined in the Agreement, Section 1.138) and have found them to be without merit. MSB’s Technical Report and WWMP outlines the operational procedures MSB should have followed under different rainfall scenarios and windrow moisture conditions at the CMU (Technical Report, Table 2 – Rainfall Event Action Plan). The WDR requires the CMU be designed, constructed, and maintained to convey all precipitation and runoff from a 25-year, 24- hour peak storm event at a minimum. The Technical Report calculated a 25-year, 24-hour rainfall depth of 6.71 inches. During the first and second quarters of 2023, the Gaviota Coast rain gauge (2581), located in an adjacent canyon, recorded a maximum 24-hour precipitation of 4.17 inches on January 8, 2023 (Attachment D); this rain event and subsequent rain events should have either been captured by the CMU Runoff Collection Tank, or contingency actions deployed according to the Technical Report. MSB also failed to notify the County and CCRWQCB within 48 hours of knowledge of WDR violations or within 24 hours of becoming aware of non-compliance that endangers the environment. Additionally, please note that John Kular's advice on the applicable WDR in your July 6, 2023 response is incorrect. The Notice of Applicability dated June 11, 2021 (Attachment E) from the CCRWQCB states that the CMU is permitted under Order no. WQO2020-0012.

On April 25, 2023, MSB was given notice of the County’s intent to assess liquidated damages and along with a description and written explanation of non-compliance based on the CCRWQCB NOV dated March 17, 2023. The County has evaluated evidence presented by MSB both in writing, over the phone, and through testimony of MSB’s employees regarding progress made and delays in addressing the required corrective actions. Based on the status of the unresolved corrective actions detailed above, the County will to continue assessing liquidated damages according to the prior Notice of Intention and this decision is final.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 John Dewey, CEO & Managing Member
MSB Investors, LLC
September 13, 2023

Regarding the resolved violation, we require your payment for related liquidated damages, as outlined in our Agreement, within 10 days from the date of this letter. If these liquidated damages of $39,500 are not paid within the 10-day period, MSB will be in default of the Agreement. As to the ongoing violations addressed in this letter, as of September 13, 2023 MSB currently owes the County $420,000. This is excluding violation number 8, as we will wait to issue an invoice for this violation until there is resolution by CCRWQCB as discussed above. While the contract requires payment of liquidated damages within 10 days after being assessed, as these damages are ongoing and based on the significant sum, MSB has 30 days from the date of this letter to pay these damages.

Swift action is urged to rectify these corrective actions and avoid further consequences. This letter does not waive any remedies available to the County as the result of MSB’s failure to timely cure the breach of the contract by July 6, 2023. Based on the collaboration and communication of the parties, the County provided MSB with an additional 30 days from July 6th to August 6 th to cure,
and based on this letter, is providing MSB an additional 56 days to cure until October 1, 2023.

However, this additional time does not stay or waive the ongoing assessment of liquidated damages, as address above, or the County right to pursue other remedies. Collaboration is crucial to addressing violations and ensuring project compliance. Your timely attention is anticipated, as well as your diligence to pursue the cure to completion, and we aim to resolve these matters promptly for the successful progression of the project.

Sincerely,
Jeanette Gonzales-Knight, PE
Interim Deputy Director
cc: Scott McGolpin, Santa Barbara County Public Works Department Marty Wilder, Santa Barbara County Public Works Department Carlyle Johnston, Santa Barbara County Public Works Department Attachment A: Response to Central Coast Regional Water Quality Control Board and Photo Documentation dated July 15, 2023
Attachment B: Central Coast Regional Water Quality Control Comments to Water and Wastewater Management Plan, Email dated June 29, 2023
Attachment C: Central Coast Regional Water Quality Control Comments to Water and Wastewater Management Plan, Email dated August 28, 2023 Attachment D: 2023 Rainfall at the Gaviota Coast
Attachment E: Central Coast Regional Water Quality Control Board Notice of Applicability dated June 11, 2021
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment A
Response to Central Coast Regional Water Quality Control Board and Photo Documentation dated July 15, 2023

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 1 Jeanette Gonzales-Knight
From: Caitlyn Teague <[email protected]>
Sent: Saturday, July 15, 2023 2:14 PM
To: Olson, Tammie@Waterboards; [email protected]; Scott McGolpin Cc: [email protected]; [email protected]; Martin Wilder; Travis Spier; Jeanette GonzalesKnight; Christina Wilder; Kevin Brown; Campos Bernal, Norma; Tkac, Jacqueline N.@Waterboards; Schroeter, Angela@Waterboards; Lodge, Ryan@Waterboards; Haserot, Jordan@Waterboards; Tryon, Thea@Waterboards; Anderson, Tamara@Waterboards; Stanley, Todd@Waterboards; Woodard, Jesse@Waterboards; Torin Snyder; Kiernan Brtalik
Subject: RE: NOTICE OF VIOLATION: TAJIGUAS COMPOST MANAGEMENT UNIT, SANTA BARBARA COUNTY Attachments: Response to June NOV_July 15 2023.pdf; Photo documentation of corrective actions July 15 2023.pdf Caution: This email originated from a source outside of the County of Santa Barbara. Do not click links or open attachments unless you verify the sender and know the content is safe.

Dear Central Coast Regional Water Quality Control Board, On behalf of Mustang Renewable Power Ventures, LLC. (Discharger), Rincon Consultants, Inc. (Rincon) has prepared the aƩached Response to June 20, 2023, NOV, and Photo documentaƟon of correcƟve acƟon items at the Tajiguas CMU (Facility). The aƩached files can also be accessed at the link below. hƩps://rinconconsultants.files.com/f/b6c9f8840b557642
The Response to June NOV table has been formaƩed to address each alleged violaƟon (Items 1‐12) idenƟfied in the June 20, 2023, NOV. Each item includes a descripƟon of the alleged violaƟon, the status of correcƟve acƟon, documents to recƟfy/develop, and a proposed schedule.

The photo documentaƟon of correcƟve acƟons compares (before) photographs from the June 13, 2023 inspecƟon report and (aŌer) photographs from July 14, 2023 that document repairs made at the Facility.

We would like to request a follow up meeƟng with the Water Board to review progress at the Facility and demonstrate our commitment to compliance with the Compost General Order and all water quality standards. Please let us know when a follow up meeƟng can be scheduled and do not hesitate to reach out with any quesƟons or requests.

Thank you,
Caitlyn
Caitlyn Teague, QSD/P, QISP, Sr. Environmental Scientist (She/Her/Hers)
805‐644‐4455 Main | 805‐509‐8399 Mobile | 805‐586‐3208 Direct [email protected]
Trusted | Fair | Transparent | Accountable | Disciplined | Entrepreneurial Ranked 2021 “Best Environmental Services Firm to Work For” by Zweig Group Time Off Alert: 07/21 – 07/24
From: Olson, Tammie@Waterboards <[email protected]> Sent: Tuesday, June 20, 2023 3:31 PM
To: [email protected]; [email protected]
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 2 Cc: [email protected]; [email protected]; Caitlyn Teague <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Tkac, Jacqueline N.@Waterboards <[email protected]>; Schroeter, Angela@Waterboards <[email protected]>; Lodge, Ryan@Waterboards <[email protected]>; Haserot, Jordan@Waterboards <[email protected]>; Tryon, Thea@Waterboards <[email protected]>; Anderson, Tamara@Waterboards <[email protected]>; Stanley, Todd@Waterboards <[email protected]>; Woodard, Jesse@Waterboards <[email protected]> Subject: [EXT] NOTICE OF VIOLATION: TAJIGUAS COMPOST MANAGEMENT UNIT, SANTA BARBARA COUNTY CAUTION: This email originated from outside of Rincon Consultants. Be cautious before clicking on any links, or opening any attachments, until you are confident that the content is safe .

NOTICE OF VIOLATION: TAJIGUAS COMPOST MANAGEMENT UNIT, SANTA BARBARA COUNTY The Central Coast Regional Water Quality Control Board is increasing its efforts to transmit correspondence and other information electronically, reducing the amount of paper used, and increasing the speed of which information is distributed. Therefore, you are receiving the attached correspondence for the subject site from the Central Coast Water Board in a Portable Data Format (PDF) and will not receive a hard copy unless requested. If you need help opening this document please refer to the link below:
http://www.adobe.com/products/acrobat/readstep2.html
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 CCRWQCB Notice of Violation to Santa Barbara County ReSource Center CMU Mustang Response - Summary Status
Item Document Alleged Violation Status of Corrective Action Documents to Rectify/Develop Proposed Schedule 1 Central Coast
Regional Water
Quality Control
Board
(CCRWQCB)
Notice of
Violation (NOV)
June 20, 2023
On June 13, 2023, the Central Coast Water Board performed an inspection of the Facility. The June 13, 2023, Inspection Report noted that the violations outlined in the March 13, 2023, NOV had not been corrected. The continued Compost General Order violations include the following:

1. Water and wastewater have not been managed in
accordance with the operational procedures within the
approved Water and Wastewater Mangement Plan (WWMP),
which is required by Compost General Order Specification 6.

In Progress. The Discharger is working on operational efficiencies to handle and manage water in accordance with the approved WWMP. Compost Management Unit (CMU) staff will be trained to improve operational procedures and housekeeping in and around the Tajiguas ReSource Center (Facility).

The revised Water and Wastewater Management Plan (WWMP) will include all relevant information related to how water and wastewater will be managed at the Facility. The basic operating philosophy has not changed. Piles will be covered when a stormwater diversion is necessary due to lack of leachate storage capacity and/or saturation of compost windrows. The Discharger will space the piles closer together so that tarpaulins fully overlap over the narrow aisles between the windrows. That will leave a very limited but wide aisle around all the windrows to be mechanically swept by a street sweeper. The outer aisle will be swept regularly irrespective of impending rainfall to prevent compost from being ground into the asphalt surface making it difficult to effectively clean.

During the winter of 2022/23, the runoff capacity storage was exceeded several times due to successive heavy rainfalls and the inability of the ADF percolate system to accept wastewater due to equipment malfunctions. Despite the improved procedures described in Section 5, it is conceivable that the runoff capacity storage could be exceeded in the future and that some other cause may prevent the diversion of site runoff which has not contacted compost. In such cases, the contingency plan would be to rent additional baker tanks to be temporarily installed on the CMU deck. High capacity rented trash pumps would transfer collected wastewater from the CMU baker tanks to the rented tanks.We will augment the WWMP text to clarify this.

Corrective actions will be included in
monthly monitoring and maintenance
reports (monthly reports).

UV tarps have been ordered and will
be on-site by July 14, 2023. Rental kick
broom will be delivered to the CMU by
Friday, July 7, 2023.
2 CCRWQCB NOV
June 20, 2023

2. The unauthorized discharge of wastewater to surface water (Pila Creek), which violates Compost General Order Prohibition

6. During the June 13, 2023, inspection wastewater was seen leaving the Facility and entering two landfill stormwater drains that connect to landfill sediment basins. According to County staff, the basins discharged to Pila Creek on April 4.

In Progress. During the June 13, 2023, inspection, Central Coast Water Board staff informed the Dischargers that a wastewater sample must be taken of the wastewater discharging from the Facility, that they must estimate the volume of discharge, and must immediately stop wastewater from discharging. On June 15, 2023, Rincon Consultants, Inc., on behalf of the Dischargers, verified via email that the Dischargers collected a wastewater sample from the leaking Facility runoff collection pipes on June 14, 2023. Laboratory results for the June 14, 2023 are still pending as of July 5, 2023, but the discharge was stopped on June 15, 2023. Once the laboratory results are received, a complete incident report will be submitted. The Discharger has also removed impacted soil. The impacted soil removal is complete and undergoing third party verification with Santa Barbara County personnel.

Incident Report for June 13, 2023 discharge. Pending laboratory results. Incident report will be completed by Friday, July 28, 2023 (assuming lab
results will be received before then.)
3 CCRWQCB NOV
June 20, 2023

3. The discharge of feedstock and compost outside of
designated areas, including below the conveyor connecting the ADF to the CMU, and the D-table area which still does not have a berm surrounding the working surface as was indicated within the Facility’s technical report, which is a violation of Compost General Order Prohibition 1 and Specification 4.

In Progress. By the end of July 2023, a welder is scheduled to weld a scraper onto the underside of the conveyor (return side) at the drop point in the CMU deck bunker to reduce digestate spillage on the return (underside) conveyor. Any spillage of digestate under the decompactor conveyor to the CMU will be cleaned up at least weekly. The existing BMP of spillage control in the middle of the converyor (waddle berm and tarp) will be continued. The following repairs were completed by June 30,2023: 1) Asphalt repairs to the two large areas in front of the CMU bunkers, 2) all CMU berm repairs, and 3) the addition of the asphalt curb/berm around the CMU Baker Tanks.

WWMP and monthly reports Welding will be completed prior to August 1, 2023.
4 CCRWQCB NOV
June 20, 2023

4. Facility berms continue to be damaged, which violates Compost General Order Design, Construction, and Operation Requirements – All Tiers number 10 and Maintenance
Requirement 1.

Completed. Facility berms have been improved. Asphalt repairs were completed at the ReSource Center on June 30, 2023. Additional asphalt repairs were completed on July 14, 2023.

WWMP and monthly reports. Documentation of apshalt repairs will be included in the June monthly
report, which will be submitted by July
15, 2023.
5 CCRWQCB NOV
June 20, 2023

5. The Facility conveyance system pipes continue to be
damaged and leak wastewater to areas outside of the Facility, which violates Compost General Order Design, Construction, and Operation Requirements – All Tiers number 11.

In Progress. The first phase of the leak repair process was completed on Friday, June 23, 2023, when Pacific Petroleum was on site to complete the removal of all sediment in and cleaning of the two permanent baker tanks.

We have also blocked off the two existing inlets so no new compost leachate or other liquid on the CMU deck will flow into the piping connecting to the two baker tanks. Any new leachate that may accumulate near the drainage inlets or low points on the CMU deck during the summer months will be collected with our vacuum truck and fed into the ADF percolate system. Additional sandbags have been deployed coupled with asphalt berm repairs will assist in the prevention of flow outside the CMU deck. The aforementioned asphalt berm surrounding the baker tanks is in place to prevent discharge to the environment. Currently, Mustang and Pacific Petroleum are investigating the integrity of the piping and tank systems. Mechanical work is ongoing to ensure system integrity.

Drainage inlets will remain blocked off until the completion of the removal and replacement of the corrugated plastic pipe with fused HDPE pipe including the addition of two additional inlets required on the western end of the CMU (required due to nearly two feet of settlement that has occurred since the CMU was constructed in early 2021). The closed and open status of these inlets will be part of our monthly inspections and monitoring report.

We received two bids (Raminha and Kirkland Construction) as of June 25, 2023. We have selected Kirkland and have asked them to update their bid with some additional design clarifications recently provided by our engineer, John Kular. As discussed on our teams meeting with Jordan of Santa Barbara County on April 19th, the completion of entire drainage system piping will be completed prior to October 1, 2023. Kirkland has estimated an 8-10 week scheduled for pipe procurement, mobilization and installation and has reconfirmed that they can complete the project no later than October 1, 2023.

WWMP and monthly reports. Completion of entire drainage system piping will be completed prior to
October 1, 2023.
6 CCRWQCB NOV
June 20, 2023

6. The Dischargers have not implemented sufficient corrective actions to address previous noncompliancecomplete violates General Order Additional Requirement 2.

Completed. A summary of corrective actions that address previous non-compliance in the June 2023 monthly report.

June 2023 monthly report. July 15, 2023 submittal of June monthly report.
7 CCRWQCB NOV
June 20, 2023

7. The Dischargers have not adequately reported events of noncompliance or notified Central Coast Water Board of all Compost General Order violations, such as notification and reporting of the continued wastewater discharges from the Facility, which violates Compost General Order Monitoring and Reporting section B.3. and Compost General Order Notification Requirement 4.

In Progress. In addition to monthly reports, In the future, any noncompliance will be reported, and the Water Board notified, as needed. Implementing training procedures.

Monthly reports. July 15, 2023 submittal of June
monthly report.

Compiled by Caitlyn Teague, Rincon Consultants 1 of 2 7/14/2023 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 CCRWQCB Notice of Violation to Santa Barbara County ReSource Center CMU Mustang Response - Summary Status
Item Document Alleged Violation Status of Corrective Action Documents to Rectify/Develop Proposed Schedule 8 CCRWQCB NOV
June 20, 2023

8. Use of unapproved feedstocks due to the inclusion of significant physical contaminants, including plastics and glass, which is prohibited by Compost General Order Prohibition 3 and 4 and Specification 7.

Objection. The inert, inorganic materials are screened out of the digestate and the compost in several steps using screens with decreasing aperture sizes. Finally, the glass and stones are removed by the desimetric table (D-table).

The solid inerts provide a benefit to the composting process by enhancing air flow through the compost windrows.

These substances are present during the composting process, but they are not feedstock by definition as they do not form part of the finished compost. The inerts are removed from the finished compost in accordance with the US Compost Council standards. The presence of all of these materials as well as the composting and screening process were all thoroughly described in Section 7.d of the approved CMU Technical report.

In summary, there is a regulatory language overlap between SWRCB with its compost management aims and the mandates of Cal Recycle for organic diversion. The premise and design details of ReSource Center’s digestate & finished compost management and ADF was noticed properly by Santa Barbara County Planning to RWCQB during environmental review and no comments were submitted by SWRCB or RWQCB on the digestate management and feedstock control.

WWMP and monthly reports. Compost reports will be included with the revised May 2023 monthly report
and future monthly reports.
9 CCRWQCB NOV
June 20, 2023
As indicated in the March 17, 2023, NOV, the drainage
conveyance pipes were leaking wastewater outside of the Facility. The March 20, 2023, response to the March 17, 2023, Notice of Violation submitted on behalf of the Dischargers, indicated that the drainage conveyance pipes would be fixed after the rainy season. Per the Compost General Order, the “wet season” is defined as October 1 to April 30. As was noted in the June 13, 2023, inspection report, the pipes have not been repaired and the pipes continue to discharge wastewater from the Facility, even after the end of the wet season.

In Progress. Please see Status of Corrective Action on Item 5. WWMP and monthly reports. Completion of entire drainage system piping will be completed prior to
October 1, 2023.
10 CCRWQCB NOV
June 20, 2023
MRP B.3. and B.4. require that the Dischargers notify the Central Coast Water Board within 48 hours of knowledge of Compost General Order violations or within 24 hours of becoming aware of noncompliance that endangers human health or the
environment. As required by MRP B.4. the Dischargers must submit a report within 10 working days of an incident such as a wastewater discharge. No such report has been submitted for the discharge noted during the June 13, 2023, inspection.

In Progress. Laboratory results for the June 14, 2023 are still pending as of July 14, 2023, but the discharge was stopped on June 15, 2023. Once the laboratory results are received, a complete incident report will be submitted.

The Discharger has also removed impacted soil. The impacted soil removal is complete and undergoing third party verification with the Santa Barbara County personnel.

Incident Report for June 13, 2023 discharge. Pending lab results. Incident report will be completed by Friday, July 28, 2023 (assuming lab
results will be received before then.)
11 CCRWQCB NOV
June 20, 2023
During the June 13, 2023, inspection, Central Coast Water Board staff informed the Dischargers that a wastewater sample must be taken of the wastewater discharging from the Facility, that they must estimate the volume of discharge, and must
immediately stop wastewater from discharging. On June 15, 2023, Rincon Consultants, Inc., on behalf of the Dischargers, verified via email that the Dischargers collected a wastewater sample from the leaking Facility runoff collection pipes on June 14, 2023. The Facility continues to be in violation of MRP B.4. until a complete incident report is submitted and the discharge ceases. The Dischargers must also correct impacts from the discharge, such as the removal of impacted soil and wastewater that flowed offsite.

In Progress. Please see Status of Corrective Action on Item 2.

The Discharger has also removed impacted soil along the discharge flow path to the stormwater inlets and put into a Pacific Petroleum roll-off bin. It is around 10 yards of material. We do not know where it will be disposed of yet, as we will need to get landfill specific lab analysis completed. We plan to back fill with road base.

Incident Report for June 13, 2023 discharge. Pending laboratory results. Incident report will be completed by Friday, July 28, 2023 (assuming lab
results will be received before then.)
12 CCRWQCB NOV
June 20, 2023
Compost General Order Monitoring Requirements 1 and 2
require that Dischargers comply with the requirements within the site specific MRP. MRP B.1. requires the submittal of monthly monitoring and maintenance reports by the 15th of each month. On June 14, 2023, Rincon Consultants, Inc.
submitted the May 2023 Monthly Monitoring and Maintenance Report for the Tajiguas Compost Management Unit. The report was found to be insufficient at meeting the MRP requirements* Completed. The May 2023 Monthly Monitoring and Maintenance Report will be revised and resubmitted in compliance with the MRP requirements. Monthly reports, thereafter will also be in compliance.

May 2023 Monthly Monitoring and Maintenance Report. May and June 2023 monthly reports will be submitted to GeoTracker prior
to July 15, 2023.
*MRP Requirements (Row 13, Item 12)

1. The report was not properly signed and did not include the proper statement of certification in accordance with Compost General Order Report Requirement 5.

2. The report did not provide a transmittal letter explaining the essential points including identifying violations as well as actions taken or planned to correct violations, as required by MRP B.1.a.

3. The report did not include a map showing location of observation stations or monitoring points as required by MRP B.1.b.

5. The report did not include all information in MRP section A.1.b. as required to be reported per MRP B.1.d. including not reporting the available capacity within storage systems and capacity contained, estimated in gallons.

6. The report did not discuss the status of Compost General Order compliance and the status of correcting violations, as required by B.1.j.

7. The report did not include information for the percent of physical contaminants (e.g., glass, metal, plastic) by dry weight of received feedstock at the compost facility within the reporting month or what the primary physical contaminates were, as required by MRP B.1.k.

4. The report did not include all information in MRP section A.1.a. as required to be reported per MRP B.1.c. including a map showing where ponding on the working surface was observed, estimated size of affected area and flow rate of wastewater leaving the facility, a map of where wastewater had affected areas outside of the facility, and photographs of observed and corrected deficiencies.

Compiled by Caitlyn Teague, Rincon Consultants 2 of 2 7/14/2023 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
1 Photograph 1A. June 13, 2023. Conveyor system that moves compost feedstock (digestate) from the ADF to the CMU continues to have feedstock material beneath the conveyor from fallen material.

Photograph 1B. July 14, 2023. Scraper pending installation on conveyor belt.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
2 Photograph 2A. June 13, 2023. Compost on D-table working surface.

No berm around this area of the CMU, as was included in the approved technical report for the site.

Photograph 2B. July 14, 2023. Asphalt berm has been installed to the west side of the baker tanks.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
3 Photograph 3A. June 13, 2023. Orange gloves littered the entrance area of the facility.

Photograph 3B. July 14, 2023. Orange gloves have been removed.

Staff will continue to be trained to improve housekeeping procedures.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
4 Photograph 4A. June 13, 2023. Ponded wastewater near the north area of the working surface and at the stormwater/wastewater outlet to the stormwater/ wastewater conveyance pipes.

Photograph 4B. July 14, 2023. Ponded water was not observed. The storm drain inlet has been blocked off to prevent leachate from entering the broken conveyance system (pending repair).

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
5 Photograph 5A. June 13, 2023. Compost windrows and wastewater. Photograph 5B. July 14, 2023. Compost windrows, facing south.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
6 Photograph 6A. June 13, 2023. Ponded wastewater at the northern portion of the working surface.

Photograph 6B. July 14, 2023. View of working surface, facing west.

The berm has been repaired with asphalt.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
7 Photograph 7A. June 13, 2023. Compost windrows with wastewater next to the windrows.

Photograph 7B. July 14, 2023. Compost windrows. Minimal leachate observed.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
8 Photograph 8A. June 13, 2023. Ponded wastewater at the northern portion of the working surface.

Photograph 8B. July 14, 2023. Ponded water was observed at the northern portion of the working surface. Storm drain inlets have been blocked to prevent discharge to the conveyance system.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
9 Photograph 9A. June 13, 2023. Ponded wastewater at the northern portion of the working surface with a scraper pushing
compost/material into the ponded area after scraper dragged its blade around the perimeter of the working surface.

Photograph 9B. July 14, 2023. Ponded water was not observed at the northern portion of the working surface. Storm drain inlets have been blocked to prevent discharge to the conveyance system.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
10 Photograph 10A. June 13, 2023. Water truck spraying compost windrows.

Photograph 10B. July 14, 2023. CMU deck has been allowed to dry.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
11 Photograph 11A. June 13, 2023. Damaged area of the working surface with ponded water and scraped asphalt surface.

Photograph 11B. July 14, 2023. Damaged areas of the working surface have been repaired with asphalt.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
12 Photograph 12A. June 13, 2023. Ponded wastewater at the northern portion of the facility.

Photograph 12B. July 14, 2023. Ponded water was not observed at the northern portion of the facility. Storm drain inlets have been blocked to prevent discharge to the conveyance system.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
13 Photograph 13A. June 13, 2023. Wastewater near stored screens with littered compost, trash, and other material.

Photograph 13B. July 14, 2023. No water observed.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
14 Photograph 14A. June 13, 2023. Piled tarps, not properly stored. Photograph 14B. July 14, 2023. Tarp storage area. Tarps will be replaced with Gore material later this year.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
15 Photograph 15A. June 13, 2023. Tanks of percolate from the ADF stored at the CMU.

Photograph 15B. July 14, 2023. Tanks of percolate from the ADF stored at the CMU.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
16 Photograph 16A. June 13, 2023. Water truck spraying compost piles. Photograph 16B. July 14, 2023. Compost piles facing north.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
17 Photograph 17A. June 13, 2023. Damaged working surface, berms, and litter fence.

Photograph 17B. July 14, 2023. Berm has been repaired with asphalt.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
18 Photograph 18A. June 13, 2023. Damaged litter fence. Photograph 18B. July 14, 2023. The fence is scheduled to be repaired.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
19 Photograph 19A. June 13, 2023. Damaged facility berm. Photograph 19B. July 14, 2023. The facility berm has been repaired with asphalt.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
20 Photograph 20A. June 13, 2023. Damaged facility berm. Photograph 20B. July 14, 2023. The facility berm has been repaired with asphalt.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
21 Photograph 21A. June 13, 2023. Significant physical contaminants within windrows.

Photograph 21B. July 14, 2023. Compost windrows, facing south.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
22 Photograph 22A. June 13, 2023. Damaged working surface where feedstock/digestate enters the facility from the ADF.

Photograph 22B. July 14, 2023. The working surface where feedstock/ digestate enters the facility from ADF has been repaired with asphalt.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
23 Photograph 23A. June 13, 2023. Wastewater flowing off D-table working surface.

Photograph 23B. July 14, 2023. An asphalt berm has been installed to prevent discharge.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
24 Photograph 24A. June 13, 2023. Wastewater flowing off D-table working surface.

Photograph 24B. July 14, 2023. An asphalt berm has been installed to prevent discharge.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
25 Photograph 25A. June 13, 2023. Wastewater outside of the working surface within recently placed gravel.

Photograph 25B. July 14, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
26 Photograph 26A. June 13, 2023. Wastewater flowing outside of the compost facility towards a lower landfill bench.

Photograph 26B. July 14, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
27 Photograph 27A. June 13, 2023. Wastewater flowing from damaged pipe onto landfill surface.

Photograph 27B. July 14, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
28 Photograph 28A. June 13, 2023. Collected wastewater beneath damaged pipe. Wastewater overflowing from bins.

Photograph 28B. July 14, 2023. There is no longer collected wastewater below the conveyance system.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
29 Photograph 29A. June 13, 2023. Wastewater actively flowing from damaged pipes.

Photograph 29B. July 14, 2023. There is no longer wastewater below the conveyance system.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
30 Photograph 30A. June 13, 2023. Wastewater actively flowing from damaged pipes.

Photograph 30B. July 14, 2023. There is no longer wastewater below the conveyance system.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
31 Photograph 31A. June 13, 2023. Wastewater flowing from the Dtable area towards a lower landfill bench.Photograph 31B. July 14, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
32 Photograph 32A. June 13, 2023. Pipe on bench where wastewater flows to the landfill north sediment basin.

Photograph 32B. July 14, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
33 Photograph 33A. June 13, 2023. Wastewater flowing from the compost facility onto a landfill bench where it enters a stormwater pipe connected to the north sediment basin.

Photograph 33B. July 14, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
34 Photograph 34A. June 13, 2023. Wastewater flowing from the compost facility onto a landfill bench where it enters a second stormwater pipe connected to the south sediment basin.

Photograph 34B. July 11, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
35 Photograph 35A. June 13, 2023. Wastewater flowing along landfill bench over an unlined area of the landfill.

Photograph 35B. July 11, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
36 Photograph 36A. June 13, 2023. Wastewater flowing along landfill bench over an unlined area of the landfill.

Photograph 36B. July 11, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 MSB Investors LLC
Tajiguas ReSource Center
Photo Documentation of Corrective Actions – July 14, 2023 Rincon Consultants, Inc.
37 Photograph 37A. June 13, 2023. Wastewater flowing onto a landfill bench, over an unlined area of the landfill, where some wastewater enters a stormwater pipe while the remaining wastewater flows along bench into a second stormwater pipe. The first pipe (photo 32 and 33) connects to the north sediment basin and the second pipe (photo 34 and 37) connects to the south sediment basin.

Photograph 37B. July 11, 2023. Stained soil has been removed and stored in a roll off bin.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment B
Central Coast Regional Water Quality Control Comments to Water and Wastewater Management Plan, Email dated June 29, 2023
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 1 Jeanette Gonzales-Knight
From: Haserot, Jordan@Waterboards <[email protected]> Sent: Thursday, June 29, 2023 1:20 PM
To: John Kular
Cc: John Dewey; Caitlyn Teague; Dylan Ellis; Wilder, Christina; Brown, Kevin; Gonzales-Knight, Jeanette; Wilder, Marty
Subject: RE: CMU Water & Wastewater Plan
Attachments: Resource Center Water and WW Mgt Plan.pdf
Caution: This email originated from a source outside of the County of Santa Barbara. Do not click links or open attachments unless you verify the sender and know the content is safe.

Hi John,
I have reviewed the updated Water and Wastewater Management Plan for the Tajiguas Compost Management Unit and have the following questions:

1. The plan doesn’t clearly delineate between wastewater and stormwater, for example stormwater versus wastewater tanks. Wastewater/leachate is any liquid that contacts waste (feedstock, compost, additives, etc.). Section 2 indicates that the CMU storage tank can feed the stormwater storage tank. Is the stormwater tank used for storage of completely clean stormwater or wastewater?

2. Where is the stormwater tank located versus the CMU storage tank? Is there a map showing the locations of the different tanks?

3. Are the three tanks listed in section 2 proposed for compost wastewater reuse on the piles?

4. The plan states, “In general, the water board considers any industrial waters to be ineligible for disposal to the pond because the pond drains into the Pila Creek. Despite this restriction, the operator is proposing to mitigate the water quality of the collected stormwater such that it closely resembles stormwater runoff collected by the pond from the landfill surface.” Compost wastewater is not considered industrial stormwater. Neither the IGP nor the Compost General Order permit the discharge of treated wastewater. If stormwater requires treatment, it is not stormwater, it is compost wastewater. Table 2 option 1 describes treating stormwater and then discharging the treated water through the stormwater overflow pipe to the landfill pond. Has the operator obtained an NPDES permit or separate WDR to discharge treated wastewater, as proposed in this plan?

5. Table 2 describes actions related to the ADF tank pad. Where is the ADF tank pad located and is it part of the compost facility that is covered under the Compost General Order?

6. The figure on PDF page 2 includes a dark blue line for water supply from well or runoff collection tank and appears to wrap around most of the facility. Does this represent a pipe? What does it feed?

7. Please provide details about wastewater reuse or other water use at the facility, such as information about any material used for odor control.

8. What are the contingency plans for wastewater management when the tanks fill up? Is there a contract in place to haul to a wastewater treatment plant or a contract in place to bring in additional tanks when needed?

9. Will there be a berm around the D-table area, as originally designed? DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 2 10. The currently approved Water and Wastewater Management Plan within the technical report references table 2 which includes scenarios for covering piles during rain events. Will the piles no longer be covered? How will the working surface be cleaned prior to stormwater diversion? This revised Water and Wastewater Management Plan is a standalone document and must include all relevant information related to how water and wastewater will be managed at the facility.

11. What does the onsite SCADA system monitor and control?

12. Are there sensors to estimate the volume of diverted water as stormwater?

13. Do the wastewater tanks still have an overflow structure or pipe? Does the overflow have a shut off valve or how will operators prevent the tank from overflowing?

14. Where will stormwater samples be taken?

15. Table 1 includes a remedy for issues related to the CMU deck and partial tarping of the compost and states, “Supervisor to make decision to contain wastewater or divert storm water much earlier (3 days) in advance of rain events.” Please provide more details within the plan for how operators will prepare for a stormwater diversion event. Does this mean all compost and feedstock will be completely covered at least three days before diversion events? What about site sweeping and other procedures previously listed in the plan?

16. Table 1 also includes plans to empty baker tanks completely between stormwater events.

Where will this water be emptied to?

17. What will trigger contingency measures to be implemented? Please specify within the report.

The Compost General Order requires that detention ponds be maintained to capture runoff from a 25-year, 24-hour event. In other words, operators are required to always have the capacity to capture runoff from a 25-year, 24-hour event, even after a storm event. Since the use of tanks is proposed as an alternative to detention pond use, the operator must explain how the alternative provides equivalent water quality protection to the permit standard.

18. What will the new ceiling mounted ultrasonic sensors measure?

19. Table 1 includes information about baker tanks and the addition of new sensors. What do these sensors measure?

20. The submittal has a “draft” watermark. Please ensure all submittal are final versions of reports/plans.

21. Table 4 includes estimates for the total area of the facility. Why has the total area of the facility changed? Does the working surface still include the D-table area? Please let me know if you have any questions or want to discuss.

Thanks,
Jordan Haserot
Water Resource Control Engineer
Land Disposal Unit
Central Coast Regional Water Quality Control Board
(805) 542-4781
From: John Kular <[email protected]>
Sent: Tuesday, June 13, 2023 3:26 PM
To: Haserot, Jordan@Waterboards <[email protected]> DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 3 Cc: John Dewey <[email protected]>; Caitlyn Teague <[email protected]>; Dylan Ellis <[email protected]>
Subject: CMU Water & Wastewater Plan
EXTERNAL:

Regards,
John Kular, P.E.

John Kular Consulting
3790 Kingsbarns Drive
Roseville, CA 95747
[email protected]
661‐302‐1292
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Resource Center
Water and Wastewater Management Plan

1. Wastewater Conveyance System
The wastewater conveyance system is shown on the 2023 Compost Site Plan. The composfing area is also known as the Compost Management Unit or CMU. It consists of a sloped asphalt deck, perimeter asphaltcovered berms, four steel-grated drainage inlets, and a fused HDPE storm drain piping system which conveys the CMU runoff to two Baker Tanks. The drainage inlets are protected by concentric rings of straw/coco-fiber waftles. The Baker Tanks are equipped with internal baffle walls to trap coarse sediments.

The Baker Tanks also have level sensors which can acfivate two 100-Hp pumps which pump the accumulated wastewater to the 380,000-gallon CMU Storage Tank. Each Baker Tank has 21,000 gallons capacity.

2. Wastewater Re-Use
The CMU Storage Tank has a 2-inch diameter discharge that feeds a5 Hp pump. The pump discharges through two bag filters into a 2-inch diameter HDPE pipe which can feed any of the following:

1. 10,000-gallon storm water storage tank

2. 10,000-gallon recycled water tank (also fed by the ADF wastewater treatment system)

3. Two Percolate Tanks with combined 600,00-gallon capacity The filtered wastewater can be re-used from the stormwater tank to condifion the compost or it can be re-used to supplement the percolate tanks. The ADF percolate system consumes approximately 10,000 gallons per day under dry condifions. The water and wastewater balance with supporfing calculafions is described in greater detail in Secfion 5.

4. Compost and Percolate Water Needs
The priority is to feed the percolate tanks with captured CMU runoff. On average this captured volume will be 1.92 million gallons per year. At fimes, to provide capacity in the CMU storage tank, the runoff will be re-used to maintain compost moisture. The average amount of captured runoff diverted to this purpose is only 37,500 gallons per year. Supplementary well water required for compost condifioning is 71,000 gallons per year.

3. Problems Experienced in 2022/23 and Recommended Remedies The Resource Center experienced numerous problems with the stormwater collecfion system during the winter of 2022/23 culminafing in receiving a Nofice of Violafion from the Regional Water Board for failing to control and retain runoff in the manner prescribed in the CMU Technical Report and Waste Discharge Permit. The sources of these problems were primarily operafional notwithstanding the extremely wet winter that was experienced. The total wet season rainfall was 36.4 inches of precipitafion, far in excess of the average seasonal rainfall depth of 21.0 inches.

In order to prevent a repeated occurrence of these problems it is necessary to idenfify the sources of the problems and remedies to prevent recurrence. These are summarized in Table 1.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 D-Table
ADF
AD Compost
Curing Area
5 1
5 5
5 B
A
2 "
Sto
c
kp
i
l
e
~
2 ,
0 0
0 CY
D
S
Ex. Well 5
A
2 "
Sto
c
kp
i
l
e
~
2 ,
0 0
0 CY
D
S
U
n
s
c
re
e
n
e
d
Co
m
p
o
st
~
3 ,
7 0
0 CY
D
S
Finished Compost
~1,000 CYDS
Section
No Scale
Berm Detail
No Scale
4'
2'

LANDFILL

CLOSURE CAP
TRRP
Drainage Pipe 10' min.
1 6
5 4
5 6 4
2 3
1 B
A B
CMU Runoff to CMU Runoff Collection TankCMU Runoff Collection Pipe Overflow Collection to North Sedimentation Basin
Water Supply from Well or Runoff Collection Tank
12345
BT
Compost windrows
Litter fence
3" AC wearing course
MPV 600 paving mat over 3" AC base course
12" min. compacted earth fill
Baker Tank

KEYNOTES
LEGEND
2023 COMPOSTING AREA SITE PLAN
Tajiguas ReSource Center
Permitted Waste Disposal Boundary
Solid Waste Facility Permit Boundary
0 SCALE (FEET)
80' 160'
Prepared by:

John Kular Consulting
890 Lindamere Ct, Simi Valley, CA 93065
661-302-1292 kularconsult.com
Dust Control Spray Pattern
AREAS
Compost Windrows.....1.78 acCompost Stockpiles.... 0.62 ac Pavement.................... 5.02 ac
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Table 1 - Problems Experienced in 2022/23 and Recommended Remedies Locafion Problem Cause Remedies
CMU Deck Damaged asphalt surface
and berms.

Loader operator error. Operator training
CMU Deck Ponding on deck. CMU differenfial
seftlement.

Install extension of storm
drain system with 2
addifional inlet locafions.

CMU Deck Wind dislodged tarps from
compost windrows and
stockpiles.

Inadequate anchorage
of tarps.

Use sand-filled PVC pipes
to weigh down edges of
tarps rather than sandbags
so that wind cannot lift
tarps between sandbags.

CMU Deck Parfial tarping of compost
resulted in increased runoff
while prevenfing diversion
of stormwater because the
clean and dirty runoff
mixed.

Operator error.

Supervisors knew
proper procedure but
CMU laborers didn’t
understand importance
of complete tarping of
compost.

Operator training.

Supervisor to make
decision to contain
wastewater or divert storm
water much earlier (3 days)
in advance of rain events.

CMU SD
Inlets
Clogged Inlets Inadequate compost
tarp coverage.

Wider Tarps ordered,
operator training to
prepare for storms earlier,
clean CMU deck befter and
install more waftles and
gravel bags.

CMU storm
drains
Pipes separated at joints,
resulfing in leakage.

CMU seftlement. High
winds, inadequate
anchorage.

Install confinuous-fused,
jointless storm drain
system with closer anchor
spacing. Empty Baker
Tanks completely between
stormwater events to
reduce water pressure on
storm drains. Inspect
anchors and storm drains
regularly and adjust storm
drain slope, augment
anchors as the top deck
seftles.

Baker Tank Pump #2 could not start in
automafic mode, due to
sensor malfuncfion.

Level Sensor #2
malfuncfion.

Replace sensors with type
of sensor that is less
suscepfible to damage.

New sensors are ceiling
mounted, ultrasonic not
cable-mounted, pressure
style.

Baker Tank Pump #1 stopped working
during a rain event.

Debris trapped in winter
2021/22 was not
Baker tanks to be
completely empfied during
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 removed from Baker
tanks in the dry months
of 2022 and became
lodged in the pump inlet
pipe.
the dry season and all
debris removed.

Baker Tank Pumps stopped working for
short durafions during
runoff events.

Debris lodged against
level sensors.

Baker tanks to be
completely empfied during
the dry season and all
debris removed. New
sensors are ceiling
mounted, ultrasonic not
cable-mounted, pressure
style.

Baker Tank Could not accurately
esfimate Baker Tank
overflow rates.

Level sensors are too
close to pump inlets and
provide inaccurate
readings when pumps
cycle on/off.

New sensors have been
installed further from the
pump inlets and will be in
operafion for September
2023.

CMU SW
Tank
Could not send SW to
percolate system as
intended for long periods of
fime.

Percolate system
clogging, temperature
limitafions.

More frequent acidcleaning of percolate
distribufion system. Befter
management of percolate
tank levels. Installed debris
traps in percolate recycle
system.

4. Wastewater Mifigafion Opfions
The opfions below are intended to deal with a surplus of selected stormwater from the compost deck. The percolate system has been unable to consume sufficient water in the winter months to offset the collected stormwater from the compost deck. This is because the digestate is much wefter from the collected trash during rain events. The water board considers collected stormwater that has been in contact with compost to be classified as wastewater. Wastewater is not eligible to be disposed of to the landfill stormwater pond.

In general, the water board considers any industrial waters to be ineligible for disposal to the pond because the pond drains into the Pila Creek. Despite this restricfion, the operator is proposing to mifigate the water quality of the collected stormwater such that it closely resembles stormwater runoff collected by the pond from the landfill surface.

Table 2 - Summary of Stormwater/Wastewater Use Methods
Opfion 1 Opfion 2 Opfion 3
Locafion ADF Tank Pad ADF Tank Pad ADF Tank Pad
Components Exisfing Bag filters,
relocated MRF UV
Treatment System
Exisfing Bag Filters Exisfing Bag Filters
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 How it works Stored water in CMU SW
Storage Tank is pumped
through the bag filter
system and through the
UV treatment system and
is discharged through the
CMU SW Tank overflow
pipe to the CMU storm
drain system to the landfill
pond.

Stored water in CMU SW
Storage Tank is pumped
through the bag filter system
to the ADF Percolate tanks for
re-use.

Stored water in CMU
SW Storage Tank is
pumped through the
bag filter system to the
ADF SW storage tank
for re-use to condifion
compost using tanker
truck.

When it would
be used
At operator discrefion but
generally when the CMU
SW storage tank is >50%
full and the rainy season is
< 50% complete.

Whenever there is available
water in the CMU CW Storage
Tank and available space in
the percolate tanks.

During warm weather
months when compost
moisture is
subopfimum.

Limitafions on
use
Landfill pond level status.

Treated water
classificafion.

UV treatment is limited to
30 gpm. Max. Daily flow
rate = 43,200 GPD
Percolate tanks temperature
limits rate of cool water
transfer from CMU tank.

Maximum flow rate is 12 gpm
or 17,280 GPD due to pipe
sizes at the percolate tanks.

When compost
moisture is too high.

Availability of transfer
truck. Ability of transfer
truck to apply water at
proper rate and
locafion.

Strategy
Used?
Proposed 2022/2023 2022
Problems
experienced
None, not implemented
yet.

Percolate system
malfuncfions limited SW use.

Cold winter of 2022/23
limited transfer rate to
percolate system.

Excess runoff on CMU
deck. Truck
unavailable
Changes
proposed
New system. Provide operafional
guidelines and training to
staff to implement this opfion
in a more controlled manner
to avoid lowering percolate
system temperatures.

Increase frequency of
percolate system
maintenance (acidic flushing
of percolate distribufion
system) to keep system online without interrupfion.

Implement dual water
source spray system.

Using well water or
storm water (when
available).

Benefits of
proposed
change
Ability to treat and drain a
relafively large quanfity of
stormwater from the CMU
storage tank to make
space for forecasted
runoff events.

Can apply water to any
locafion on the
compost deck in a
controlled spray. No
dependence on
availability of tanker
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 truck or staff. Befter
opportunity to use SW
during periodic dry
periods during the
rainy season.

5. New Strategy - Supporfing Calculafions
The CMU Technical Report included three sets of water balance calculafions. They are briefly described in Table 3. Calculafions #2 and #3 anficipated that the only re-use of collected storm water would be applied to the compost for moisture condifioning as the percolate supplementafion was expected to be minimal.

The CMU deck compost coverage was also theorefical. Actual operafions have resulted in lower compost deck coverage and consequently higher runoff for the same rainfall. Therefore, new calculafions were performed to adjust for these factors. The calculafions are shown in Tables 4, 5 and 6.

Table 3- CMU Water Balance Calculafions
# Descripfion Purpose
1 Single 24-hour, 25-year storm
HydroCAD Simulafion
To size storm water runoff collecfion system per SWQCB
regulafions.
2 Annual water balance based on
average rainfall and evaporafion
on a month-by-month basis
To size storm water runoff collecfion system (alternafive method).
3 40-year simulafion of site
precipitafion
To determine how often a stormwater diversion would
occur based on daily rainfall depths from 1974-2017.

Table 4 – Summary of HydroCAD Simulafions for 25 Year, 24-hour Rainfall (6.71 inches depth) Variable Units 2021 HydroCAD -
Design
2023 HydroCAD -AsBuilt
Bare Asphalt Acres 3.30 2.62
Compost Acres 1.80 2.40
Total Area Acres 5.13 5.02
Runoff Depth Inches 2.21 3.18
Runoff Volume Acre-feet 0.944 1.329*
Peak Flow CFS 6.69 10.64
*New peak runoff volume exceeds available runoff storage by 11,000 gallons. One addifional Baker tank is recommended to meet Compost Regulafions storage requirements.

Table 5 - See following page.

Table 6 – See following pages for table. Summary Graph is below. Over the 42-year period the CMU is expected to divert run-off approximately four fimes based on the historical data.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 TABLE 5 CMU MONTHLY WATER BUDGET

TAJIGUAS RESOURCE RECOVERY PROJECT
Input Calculated
5/31/2023
Water Sources ANNUAL Units JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Totals/Aves Source of data
and/or
calculation:

Rainfall depth 21.0 inches 4.59 4.97 3.90 1.20 0.35 0.10 0.01 0.01 0.26 0.78 1.62 3.17 20.96 SBCFC Station
262 Gaviota
Coast

1.75 feet 0.38 0.41 0.33 0.10 0.03 0.01 0.00 0.00 0.02 0.07 0.14 0.26 1.75 Monthly fraction % 22% 24% 19% 6% 2% 0% 0% 0% 1% 4% 8% 15% 100% Effective rainfall 0.37 0.40 0.32 0.09 0.02 0.00 0.00 0.00 0.01 0.06 0.13 0.25 Evapotranspiration 48.5 inches 2.4 2.8 4 5 5.3 4.8 5.5 5.5 4.6 3.7 2.8 2.1 48.5 CIMIS feet 0.20 0.23 0.33 0.42 0.44 0.40 0.46 0.46 0.38 0.31 0.23 0.18 4.04 Station 94 Monthly fraction % 5% 6% 8% 10% 11% 10% 11% 11% 9% 8% 6% 4% 100% Santa Ynez Runoff Calculation
Area (SF) C-value CF CF CF CF CF CF CF CF CF CF CF CF CF CMU
Finished
Compost
stockpile 27007 0.10 1006 1092 851 243 52 0 0 0 32 149 338 686 4447 Compost
windrows 77537 0.10 2888 3134 2442 698 149 0 0 0 90 426 969 1971 12768 Asphalt
aisles 114127 0.90 38261 41514 32355 9244 1969 0 0 0 1198 5649 12839 26107 169136 Runoff, Sum 42155 45739 35648 10185 2169 0 0 0 1320 6224 14146 28764 186351 Compost rainwater absorption
Area (SF) K-value CF CF CF CF CF CF CF CF CF CF CF CF CF CMU
Finished
Compost
stockpile 27007 0.90 9054 9824 7656 2188 466 0 0 0 284 1337 3038 6178 40024 Compost
windrows 77537 0.90 25994 28204 21982 6280 1338 0 0 0 814 3838 8723 17737 114910 Absorption, Sum 35048 38028 29638 8468 1803 0 0 0 1098 5175 11761 23914 154934 Water Loss
K-value CF CF CF CF CF CF CF CF CF CF CF CF CF
Evapotranspiration
Compost
surface SF 136661 0.70 19133 22321 31888 39859 42251 38265 43845 43845 36671 29496 22321 16741 Manipulation Volume 1350 1350 1350 1350 1350 1350 1350 1350 1350 1350 1350 1350 Heat
Compost
weight lbs 85600 0.20 275 275 275 275 275 275 275 275 275 275 275 275 avg. daily Sum 20757 23946 33512 41484 43876 39890 45470 45470 38296 31121 23946 18366 406135 1128 Net water use -14291 -17082 1874 33016 42072 39890 45470 45470 37198 25946 12185 -5549 246201 684 Moisture content of
compost at end of
month start at 48% 51% 52% 48% 40% 38% 39% 37% 37% 39% 42% 45% 49% avail tank storage
start of
month Max= 56504 56504 35739 14390 2133 13338 32559 53949 75340 96730 116800 131966 139211 Added runoff to tank during month 42155 45739 35648 10185 2169 0 0 0 1320 6224 14146 28764 186351 Water applied to compost from CMU storage 0 3000 2000 0 0 0 0 0 0 0 0 0 5000 ADF percolate
water consumption 160000 gal. 21390 CF 21390 21390 21390 21390 21390 21390 21390 21390 21390 21390 21390 21390 256684 Tank storage end of month 20765 42114 54371 43166 23945 2555 -18836 -40226 -60296 -75462 -82707 -75333 Storage % full 37% 75% 96% 76% 42% 5%
Notes: 85600
1 Surface area for evapotranspiration is for inclined surface area because that is the surface exposed to wind and sun. 0.1 2 All other surface areas are plan area surfaces. To use inclined surface for incident rainfall would esssentially create extra rainfall depth. 8.345 3 C-value for compost runoff is same as C-value used in 40-year simulation for consistency. 71433 4 K-value for water use constants to distinguish from runoff constant C-value. 5 Runoff constants may seem low but these are not single storm event runoff constants. 6 ADF percolate consumption added in 2023.
7 Negative tank storage means supplementary well water is needed for percolate and/or compost conditioning. target range is 40-60%,
supplementary water required
to maintain 40% min.
compost weight in lbs
cumulative deficiency in m.c.
lb/gal
gallons supplementary water
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 TRRP CMU 2023 Revised Areas Type I 24-hr 25 YEAR Rainfall=6.71" Prepared by John Kular Consulting Printed 5/31/2023
HydroCAD® 10.20-2g s/n 07434 © 2022 HydroCAD Software Solutions LLC Page 2 Summary for Subcatchment 4S: CMU pad CN 36 98
Runoff = 10.64 cfs @ 10.04 hrs, Volume= 1.329 af, Depth= 3.18" Routed to nonexistent node 6P
Runoff by SCS TR-20 method, UH=SCS, Weighted-CN, Time Span= 0.00-30.00 hrs, dt= 0.05 hrs Type I 24-hr 25 YEAR Rainfall=6.71"
Area (ac) CN Description
* 2.620 98 AC aisles
* 2.400 36 compost piles

5.020 68 Weighted Average

2.400 47.81% Pervious Area

2.620 52.19% Impervious Area
Tc Length Slope Velocity Capacity Description
(min) (feet) (ft/ft) (ft/sec) (cfs)

12.0 Direct Entry,
Subcatchment 4S: CMU pad CN 36 98
Runoff
Hydrograph
Time (hours)
3029282726252423222120191817161514131211109876543210
Flow (cfs)
11 10
9 8
7 6
5 4
3 2
1 0
Type I 24-hr
25 YEAR Rainfall=6.71"
Runoff Area=5.020 ac
Runoff Volume=1.329 af
Runoff Depth=3.18"
Tc=12.0 min
CN=68

10.64 cfs
HYDROCAD CALCULATION FOR 25-YR, 24- HR STORM
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 0 100000
200000
300000
400000
500000
600000
700000
800000
1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 Maximum Runoff Historical Simulation
Year Maximum Runoff Volume Max. Tank Volume
TABLE 6 SUMMARY GRAPH
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment C
Central Coast Regional Water Quality Control Comments to Water and Wastewater Management Plan, Email dated August 28, 2023

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 1 Jeanette Gonzales-Knight
From: Haserot, Jordan@Waterboards <[email protected]> Sent: Monday, August 28, 2023 1:09 PM
To: Caitlyn Teague
Cc: John Dewey; John Kular; Dylan Ellis; Matthew Dunn; Gerardo Pinelas; Thomas Sanford; Kiernan Brtalik; Christina Wilder; Jeanette Gonzales-Knight; Kevin Brown Subject: RE: Tajiguas CMU Water and Wastewater Management Plan - August 16, 2023 Attachments: RE: CMU Water & Wastewater Plan
Caution: This email originated from a source outside of the County of Santa Barbara. Do not click links or open attachments unless you verify the sender and know the content is safe.

Hi Caitlyn,
Thank you for the submittal.

I reviewed the revised Water and Wastewater Management Plan. However, the Plan still appears to be deficient. The August 16, 2023, Tajiguas Water and Wastewater Management Plan does not answer a number of questions that were asked via email on June 29, 2023, for the previous submitted version of the Plan including questions 6, 7, 9, 10, 13, 15, 17, 18, and 19 (email attached).

Below are some outstanding questions in addition to the questions provided in the previous email.

Related to previous question 7 and the odor control section. Please list the compounds used for odor control within the Plan. Is wastewater reused and sprayed using the misters? Has the LEA approved this use? I have concerns with misting wastewater on the perimeter of the facility. Due to workers health and safety concerns that would allow workers to inhale misted wastewater, we cannot approve this use of wastewater.

Related to previous question 15. Will the site prevent additional material from entering the compost facility when diversion procedures begin, as a way to ensure that all compost, feedstock, and materials are fully covered three days prior to diversion and to help ensure that the swept working surface remains clean? Please expand on this section and be specific what procedures will be put in place three days prior to diversion.

Related to previous question 17. As discussed during our meeting on July 26, 2023, the plan must specify what will trigger operators to implement contingency measures such as bringing in additional tanks for wastewater storage. As previously discussed, the proposed Water and Wastewater Management Plan must indicate how the operator will provide equivalent water quality protection to the permit standard of detention ponds being maintained to capture runoff from a 25-year, 24-hour storm.

The Plan states, “[n]ew peak runoff volume exceeds available runoff storage by 11,000 gallons. One additional Baker tank is recommended to meet Compost Regulations storage requirements.” When will the new Baker tank be brought to the site and where will the permanent tank be located? The wastewater reuse section states that, “[t]he CMU storage tank feeds the 10,000-gallon recycled water tank.” Where is the recycled water tank located on Exhibit 2? Does this mean that recycled water and compost wastewater would be mixed in this tank? Is this tank exclusively used for reused DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 2 wastewater used on the compost? My understanding is that the recycled water is sprayed via a sprinkler system near the MRF and is permitted under a separate WDR. Recycled water used for this use must not be comingled with wastewater.

I recall there being issues with overflow and wastewater discharge outside of normal work hours this past rainy season, which resulted in potential unknown discharges and difficulty fully estimating overflow discharges. The Plan states, “[t]he runoff and wastewater items monitored by SCADA do not generate alarms.” If there are no alarms for the SCADA system, and if the CMU runoff tank exceeds capacity and wastewater flows out of the overflow pipe, how will operators be notified of an issue and how will the volume of discharge be estimated?
The extent of the D-table isn’t clearly delineated on maps, and the new berm doesn’t appear to be shown. Please ensure that maps clearly delineate all CMU areas and berms. Compost has been documented on the D-table area during previous inspections and there is a concern about wastewater generation from compost contacting stormwater and running offsite. Since the D-table isn’t fully enclosed, the report must indicate how wastewater on the D-table will be managed and/or prevented.

Please let me know if you have any questions or would like to discuss.

Jordan Haserot
Water Resource Control Engineer
Land Disposal Unit
Central Coast Regional Water Quality Control Board
(805) 542-4781
From: Caitlyn Teague <[email protected]>
Sent: Thursday, August 17, 2023 7:16 AM
To: Haserot, Jordan@Waterboards <[email protected]> Cc: John Dewey <[email protected]>; John Kular <[email protected]>; Dylan Ellis <[email protected]>; Matthew Dunn <[email protected]>; Gerardo Pinelas <[email protected]>; Thomas Sanford <[email protected]>; Kiernan Brtalik <[email protected]>; Wilder, Christina <[email protected]>; Gonzales‐Knight, Jeanette <[email protected]>; Brown, Kevin <[email protected]> Subject: Tajiguas CMU Water and Wastewater Management Plan ‐ August 16, 2023 EXTERNAL:

Good morning Jordan,
On behalf of Mustang Renewable Power Ventures, LLC. (Discharger), the revised Tajiguas CMU Water and Wastewater Management Plan is attached for your review and approval. Please let us know if you have any questions or requests.

Thank you,
Caitlyn
Caitlyn Teague, QSD/P, QISP, Sr. Environmental Scientist (She/Her/Hers)
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 3 805‐644‐4455 Main | 805‐509‐8399 Mobile | 805‐586‐3208 Direct [email protected]
Trusted | Fair | Transparent | Accountable | Disciplined | Entrepreneurial Ranked 2021 “Best Environmental Services Firm to Work For” by Zweig Group Time Off Alert: 08/17 – 08/19
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Tajiguas Resource Center
Water and Wastewater Management Plan

1. Terminology Used in This Document
The California State Water Resources Control Board (Water Board) and CalRecycle define leachate as any liquid formed by the drainage of liquids from waste or by the percolafion or flow of liquid through waste (27 CCR § 20164). The Wastewater Division of the Water Board and County Environmental Health Department (EHD) both use the term wastewater to refer to sanitary sewage. For consistency with Appendix B of the MRP, this document will use the term wastewater for storm water runoff that has come into contact with compost. The term leachate will not be used. Piping that conveys storm water runoff and or wastewater will be called storm drains.

2. Wastewater Conveyance System
The wastewater conveyance system is shown on the 2023 Composfing Area Site Plan. The composfing area is also known as the Compost Management Unit or CMU. It consists of a sloped asphalt deck, perimeter asphalt-covered berms, four steel-grated drainage inlets, and a fused HDPE storm drain piping system which conveys the CMU runoff to two Baker Tanks. The drainage inlets are always protected by concentric rings of straw/coco-fiber waftles. Waftles are replaced as required. The Baker Tanks are equipped with internal baffle walls to trap coarse sediments. The Baker Tanks also have level sensors which can automafically acfivate two 100-Hp pumps which pump the accumulated wastewater to the 380,000-gallon CMU Runoff Collecfion Tank. Each Baker Tank has 21,000 gallons capacity.

3. Stormwater Diversion
In the event that insufficient wastewater storage is available to store runoff from a forecasted rain event, the operator will prepare the site for a stormwater diversion to the landfill’s northern sedimentafion basin. Preparafions will include:
 100% tarp coverage of all compost windrows and material stockpiles,  mechanical and hand sweeping of asphalt areas,
 weighing down of tarpaulins to prevent displacement by wind,  hand-operated closure of valves to divert collected runoff to bypass the Baker tanks,  sampling of the runoff during the bypass event to verify stormwater quality.  as all diversions are by definifion insfigated by the operator, sampling will be manual rather than automafic.
 A flow meter will be installed on the diversion pipe.

4. Wastewater Re-Use
The CMU Runoff Collecfion Tank has a 2-inch diameter steel discharge pipe that feeds a 5 Hp pump. The pump discharges through two bag filters into a 2-inch diameter HDPE pipe which can feed any of the following:

1. 10,000-gallon wastewater storage tank.

2. 10,000-gallon recycled water tank (also fed by the ADF wastewater treatment system)

3. Two Percolate Tanks with combined 600,00-gallon capacity 1 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 D-Table
ADF
AD Compost
Curing Area
5 1
5 5
5 B
A
2 "
Sto
c
kp
i
l
e
~
2 ,
0 0
0 CY
D
S
Ex. Well 5
A
2 "
Sto
c
kp
i
l
e
~
2 ,
0 0
0 CY
D
S
U
n
s
c
re
e
n
e
d
Co
m
p
o
st
~
3 ,
7 0
0 CY
D
S
Finished Compost
~1,000 CYDS
Section
No Scale
Berm Detail
No Scale
4'
2'

LANDFILL

CLOSURE CAP
TRRP
Drainage Pipe 10' min.
1 6
5 4
5 6 4
2 3
1 B
A B
CMU Runoff to CMU Runoff Collection TankCMU Runoff Collection Pipe Overflow Collection to North Sedimentation Basin
Water Supply from Well or Runoff Collection Tank
12345
BT
Compost windrows
Litter fence
3" AC wearing course
MPV 600 paving mat over 3" AC base course
12" min. compacted earth fill
Baker Tank

KEYNOTES
LEGEND
2023 COMPOSTING AREA SITE PLAN
Tajiguas ReSource Center
Permitted Waste Disposal Boundary
Solid Waste Facility Permit Boundary
0 SCALE (FEET)
80' 160'
Prepared by:

John Kular Consulting
890 Lindamere Ct, Simi Valley, CA 93065
661-302-1292 kularconsult.com
Dust Control Spray Pattern
AREAS
Compost Windrows.....1.78 acCompost Stockpiles.... 0.62 ac Pavement.................... 5.02 ac
2 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 The tank locafions are shown on the exhibit below, enfitled 2023 CMU Composfing Area Site Plan. The filtered wastewater can be re-used from the wastewater tank to condifion the compost or it can be reused to supplement the percolate tanks. The ADF percolate system consumes approximately 10,000 gallons per day under dry condifions. The water and wastewater balance with supporfing calculafions is described in greater detail in Secfion 9.

5. Odor Control
Currently the ADF and CMU facilifies use misters to spray deodorant at the ADF door, the ADF to CMU conveyor and around the east and south CMU fence lines. The deodorant is primarily intended to address ADF digestate odors and compost odor during windrow turning operafions. Re-use of filtered CMU wastewater is not odorous relafive to these afore-menfioned sources.

6. SCADA System
The Resource Center SCADA system monitors several hundred items but relevant to the WWMP it monitors all tank levels and Baker tank pump run status. This informafion together with NOAA weather forecasts enables the CMU and ADF operators to make fimely decisions with respect to CMU effluent reuse and storm event preparafions. The runoff and wastewater items monitored by SCADA do not generate alarms. On-site operator intervenfion is required to override automafic pump funcfions. The pumps turn on and off automafically in response to water levels in the tanks.

7. Compost and Percolate Water Needs
The priority is to feed the percolate tanks with captured CMU runoff (wastewater). On average this captured volume will be 1.92 million gallons per year. At fimes, to provide capacity in the CMU Runoff Collecfion Tank, the filtered wastewater will be re-used to maintain compost moisture. The average amount of captured wastewater diverted to this purpose is only 37,500 gallons per year. Supplementary well water required for compost condifioning is 71,000 gallons per year.

8. Problems Experienced in 2022/23 and Recommended Remedies The Resource Center experienced numerous problems with the stormwater collecfion system during the winter of 2022/23 culminafing in receiving a Nofice of Violafion from the Regional Water Board for failing to control and retain runoff in the manner prescribed in the CMU Technical Report and Waste Discharge Permit. The sources of these problems were primarily operafional notwithstanding the extremely wet winter that was experienced. The total wet season rainfall was 36.4 inches of precipitafion, far in excess of the average seasonal rainfall depth of 21.0 inches.

In order to prevent a repeated occurrence of these problems it is necessary to idenfify the sources of the problems and remedies to prevent recurrence. These are summarized in Table 1. 3 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Table 1 - Problems Experienced in 2022/23 and Recommended Remedies Locafion Problem Cause Remedies
CMU Deck Damaged asphalt
surface and berms.

Loader operator error. Operator training
CMU Deck Ponding on deck. CMU differenfial
seftlement.

Install extension of storm drain
system with 2 addifional inlet
locafions.

CMU Deck Wind dislodged
tarps from compost
windrows and
stockpiles.

Inadequate anchorage of
tarps.

Use sand-filled PVC pipes to
weigh down edges of tarps rather
than sandbags so that wind
cannot lift tarps between
sandbags.

CMU Deck Parfial tarping of
compost resulted in
increased runoff
while prevenfing
diversion of
stormwater because
the clean and dirty
runoff mixed.

Operator error.

Supervisors knew the
proper procedure but
CMU laborers didn’t
understand importance of
complete tarping of
compost.

Operator training. Supervisor to
make decision to contain
wastewater or divert storm water
to the sediment basin much
earlier (3 days) in advance of rain
events. This will provide enough
fime for complete coverage of
compost and feedstocks plus a
thorough cleaning of asphalt
areas.

CMU SD
Inlets
Clogged Inlets Inadequate compost tarp
coverage.

Wider Tarps ordered, operator
training to prepare for storms
earlier, clean CMU deck befter
and install more waftles and
gravel bags.

CMU storm
drains
Pipes separated at
joints, resulfing in
leakage.

CMU seftlement. High
winds, inadequate
anchorage.

Install confinuous-fused, jointless
storm drain system with closer
anchor spacing. Temporarily
empty Baker Tanks completely
between stormwater events to
reduce water pressure on storm
drains unfil jointed pipe is
replaced with fused pipe. Inspect
anchors and storm drains
regularly and adjust storm drain
slope, augment anchors as the
top deck seftles. Install asphalt
curb around north and west side
of Baker tanks to trap leaked
fluids.

Baker Tank Pump #2 could not
start in automafic
mode, due to sensor
malfuncfion.

Level Sensor #2
malfuncfion.

Replace sensors with type of
sensor that is less suscepfible to
damage. New sensors are ceiling
mounted, ultrasonic not cablemounted, pressure style which 4 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 were subject to fouling with
captured debris.

Baker Tank Pump #1 stopped
working during a
rain event.

Debris trapped in winter
2021/22 was not removed
from Baker tanks in the
dry months of 2022 and
became lodged in the
pump inlet pipe.

Baker tanks to be completely
empfied during the dry season
and all debris removed.

Baker Tank Pumps stopped
working for short
durafions during
runoff events.

Debris lodged against level
sensors.

Baker tanks to be completely
empfied during the dry season
and all debris removed. New
sensors are ceiling mounted,
ultrasonic not cable-mounted,
pressure style.

Baker Tank Pipe connecfions
leaked
CMU surface seftlement
caused pipe joints to
separate.

Replace nested, jointed pipe with
fused pipe joints.

Baker Tank Could not accurately
esfimate Baker Tank
overflow rates.

Level sensors are too close
to pump inlets and
provide inaccurate
readings when pumps
cycle on/off.

New sensors have been installed
further from the pump inlets and
will be in operafion for
September 2023.

CMU Storage
Tank
Could not send SW
to percolate system
as intended for long
periods of fime.

Percolate system clogging,
temperature limitafions.

More frequent acid-cleaning of
percolate distribufion system.

Befter management of percolate
tank levels. Installed debris traps
in percolate recycle system.

9. Wastewater Mifigafion Opfions
The opfions below are intended to deal with a surplus of wastewater from the compost deck. The percolate system has been unable to consume sufficient water in the winter months to offset the collected wastewater from the compost deck. This is because the digestate is much wefter from the collected trash during rain events. The Water Board considers collected stormwater that has been in contact with compost to be classified as wastewater as discussed in Secfion 1. Wastewater is not eligible to be discharged to the Tajiguas Landfill Sediment Basins.
5 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Table 2 - Summary of Wastewater Use Opfions
Opfion 1- exisfing Opfion 2 - exisfing
Locafion ADF Tank Pad ADF Tank Pad
Components Exisfing Bag Filters Exisfing Bag Filters
How it works Stored water in CMU Runoff Collecfion
Tank is pumped through the bag filter
system to the ADF Percolate tanks for reuse.

Stored water in CMU Runoff Collecfion
Tank is pumped through the bag filter
system to the ADF Wastewater storage
tank for re-use to condifion compost
using vacuum truck.

When it would
be used
Whenever there is available water in the
CMU Runoff Collecfion Tank and available
space in the percolate tanks.

During warm weather months when
compost moisture is subopfimum.

Limitafions on
use
Percolate tanks temperature limits rate of
cool water transfer from CMU tank.

Maximum flow rate is 12 gpm or 17,280
GPD due to pipe sizes at the percolate
tanks.

When compost moisture is too high.

Availability of vacuum truck. Ability of
vacuum truck to apply water at proper
rate and locafion.

Strategy
Used?
2022/2023 2022
Problems
experienced
Percolate system malfuncfions limited
wastewater re-use.

Cold winter of 2022/23 limited transfer
rate to percolate system.

Excess runoff on CMU deck. Truck
unavailable.

Changes
proposed
Provide operafional guidelines and
training to staff to implement this opfion
in a more controlled manner to avoid
lowering percolate system temperatures.

Increase frequency of percolate system
maintenance (acidic flushing of percolate
distribufion system) to keep system online without interrupfion.

Implement dual water source spray
system as shown on the 2023 Composfing
Area Site Plan. Using well water or
captured runoff (when available).

Benefits of
opfion
Can apply water to any locafion on the
compost deck in a controlled spray. No
dependence on availability of tanker
truck or staff. Befter opportunity to use
wastewater during periodic dry periods
during the rainy season.

10. Confingency Plans
During the winter of 2022/23, the runoff capacity storage was exceeded several fimes due to successive heavy rainfalls and the inability of the ADF percolate system to accept wastewater due to equipment malfuncfions. Despite the improved procedures described in Secfion 5, it is conceivable that the runoff capacity storage could be exceeded in the future and that some other cause may prevent the diversion of site runoff which has not contacted compost. In such cases, the confingency plan would be to rent addifional baker tanks to be temporarily installed on the landfill operafions deck. The operator has a master agreement in place with Pacific Petroleum to rent the tanks and transfer pumps. High-capacity 6 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 T1
T2 ADF
W5
P
CMU
Existing Baker Tanks
D-Table
(Compost Screening)
Percolate Tanks
Landfill
Operations
Deck
Landfill
Maintenance
Building
New Baker
Tanks (x 10)
CW-1
New Baker
Tanks (x 10)
Water
Treatment
Facility
Well Water
Storage Tank
CMU RunoffCollection Tank
Exhibit 2 - Contingency Plan
25-yr/24-hr Runoff to CMU Runoff Collection Tank
Runoff Collection
Overflow Collection to North Sedimentation Basin
Water Supply from Well or Runoff Collection Tank
Prepared by:

John Kular Consulting
3790 Kingsbarns Dr, Roseville, CA 95747
661-302-1292 kularconsult.com
Tajiguas ReSource Center

NO SCALE
Legend:

Existing Well 5
P Pump
W5
Recycled Water Storage Tank
T1 Wastewater Storage TankT2
Surface Water Quality
Monitoring Location
CW-1
7 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 rented trash pumps would transfer collected wastewater from the CMU baker tanks to the rented tanks.

Space has been idenfified on the Resource Center footprint to temporarily store 20 Baker Tanks which would double available storage capacity or the equivalent volume to runoff from two fimes the 25-year, 24-hour storm. See Exhibit 2 – Confingency Plan.

11. New Strategy - Supporfing Calculafions
The CMU Technical Report included three sets of water balance calculafions. They are briefly described in Table 3. Calculafions #2 and #3 anficipated that the only re-use of collected wastewater would be applied to the compost for moisture condifioning as the percolate supplementafion was expected to be minimal.

The CMU deck compost coverage was also theorefical. Actual operafions have resulted in lower compost deck coverage and consequently higher runoff for the same rainfall. Therefore, new calculafions were performed to adjust for these factors. The calculafions are shown in Tables 4, 5 and 6.

Table 3- CMU Water Balance Calculafions
# Descripfion Purpose
1 Single 24-hour, 25-year storm
HydroCAD Simulafion
To size storm water runoff collecfion system per SWQCB
regulafions.
2 Annual water balance based on
average rainfall and evaporafion
on a month-by-month basis
To size storm water runoff collecfion system (alternafive method).
3 40-year simulafion of site
precipitafion
To determine how often a stormwater diversion would
occur based on daily rainfall depths from 1974-2017.

Table 4 – Summary of HydroCAD Simulafions for 25 Year, 24-hour Rainfall (6.71 inches depth) Variable Units 2021 HydroCAD -
Design
2023 HydroCAD -AsBuilt
Bare Asphalt Acres 1.80 2.62
Compost Acres 3.30 2.40
Total Area Acres 5.13 5.02
Runoff Depth Inches 2.21 3.18
Runoff Volume Acre-feet 0.944 1.329*
Peak Flow CFS 6.69 10.64
*New peak runoff volume exceeds available runoff storage by 11,000 gallons. One addifional Baker tank is recommended to meet Compost Regulafions storage requirements.

Table 5 - See following page.

Table 6 – See following pages for table. Summary Graph is below. Over the 42-year period the CMU is expected to divert run-off approximately four fimes based on the historical data. 8 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 0 100000
200000
300000
400000
500000
600000
700000
800000
1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 Maximum Runoff Historical Simulation
Year Maximum Runoff Volume Max. Tank Volume
9 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 TRRP CMU AUG 2020 new tank location Type I 24-hr 25 YEAR Rainfall=6.71" Prepared by John Kular Consulting Printed 4/5/2021
HydroCAD® 10.10-4a s/n 07434 © 2020 HydroCAD Software Solutions LLC Page 6 Summary for Subcatchment 4S: CMU pad
Runoff = 6.69 cfs @ 10.05 hrs, Volume= 0.947 af, Depth= 2.21" Runoff by SCS TR-20 method, UH=SCS, Weighted-CN, Time Span= 0.00-30.00 hrs, dt= 0.05 hrs Type I 24-hr 25 YEAR Rainfall=6.71"
Area (ac) CN Description
* 1.800 98 AC aisles
* 3.330 36 compost piles

5.130 58 Weighted Average

3.330 64.91% Pervious Area

1.800 35.09% Impervious Area
Tc Length Slope Velocity Capacity Description
(min) (feet) (ft/ft) (ft/sec) (cfs)

12.0 Direct Entry,
Subcatchment 4S: CMU pad
Runoff
Hydrograph
Time (hours)
3029282726252423222120191817161514131211109876543210
Flow (cfs)
7 6
5 4
3 2
1 0
Type I 24-hr
25 YEAR Rainfall=6.71"
Runoff Area=5.130 ac
Runoff Volume=0.947 af
Runoff Depth=2.21"
Tc=12.0 min
CN=58

6.69 cfs
10 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 TRRP CMU 2023 Revised Areas Type I 24-hr 25 YEAR Rainfall=6.71" Prepared by John Kular Consulting Printed 5/31/2023
HydroCAD® 10.20-2g s/n 07434 © 2022 HydroCAD Software Solutions LLC Page 2 Summary for Subcatchment 4S: CMU pad CN 36 98
Runoff = 10.64 cfs @ 10.04 hrs, Volume= 1.329 af, Depth= 3.18" Routed to nonexistent node 6P
Runoff by SCS TR-20 method, UH=SCS, Weighted-CN, Time Span= 0.00-30.00 hrs, dt= 0.05 hrs Type I 24-hr 25 YEAR Rainfall=6.71"
Area (ac) CN Description
* 2.620 98 AC aisles
* 2.400 36 compost piles

5.020 68 Weighted Average

2.400 47.81% Pervious Area

2.620 52.19% Impervious Area
Tc Length Slope Velocity Capacity Description
(min) (feet) (ft/ft) (ft/sec) (cfs)

12.0 Direct Entry,
Subcatchment 4S: CMU pad CN 36 98
Runoff
Hydrograph
Time (hours)
3029282726252423222120191817161514131211109876543210
Flow (cfs)
11 10
9 8
7 6
5 4
3 2
1 0
Type I 24-hr
25 YEAR Rainfall=6.71"
Runoff Area=5.020 ac
Runoff Volume=1.329 af
Runoff Depth=3.18"
Tc=12.0 min
CN=68

10.64 cfs
11 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 TABLE 5 CMU MONTHLY WATER BUDGET

TAJIGUAS RESOURCE RECOVERY PROJECT
Input Calculated
5/31/2023
Water Sources ANNUAL Units JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Totals/Aves Source of data
and/or
calculation:

Rainfall depth 21.0 inches 4.59 4.97 3.90 1.20 0.35 0.10 0.01 0.01 0.26 0.78 1.62 3.17 20.96 SBCFC Station
262 Gaviota
Coast

1.75 feet 0.38 0.41 0.33 0.10 0.03 0.01 0.00 0.00 0.02 0.07 0.14 0.26 1.75 Monthly fraction % 22% 24% 19% 6% 2% 0% 0% 0% 1% 4% 8% 15% 100% Effective rainfall 0.37 0.40 0.32 0.09 0.02 0.00 0.00 0.00 0.01 0.06 0.13 0.25 Evapotranspiration 48.5 inches 2.4 2.8 4 5 5.3 4.8 5.5 5.5 4.6 3.7 2.8 2.1 48.5 CIMIS feet 0.20 0.23 0.33 0.42 0.44 0.40 0.46 0.46 0.38 0.31 0.23 0.18 4.04 Station 94 Monthly fraction % 5% 6% 8% 10% 11% 10% 11% 11% 9% 8% 6% 4% 100% Santa Ynez Runoff Calculation
Area (SF) C-value CF CF CF CF CF CF CF CF CF CF CF CF CF CMU
Finished
Compost
stockpile 27007 0.10 1006 1092 851 243 52 0 0 0 32 149 338 686 4447 Compost
windrows 77537 0.10 2888 3134 2442 698 149 0 0 0 90 426 969 1971 12768 Asphalt
aisles 114127 0.90 38261 41514 32355 9244 1969 0 0 0 1198 5649 12839 26107 169136 Runoff, Sum 42155 45739 35648 10185 2169 0 0 0 1320 6224 14146 28764 186351 Compost rainwater absorption
Area (SF) K-value CF CF CF CF CF CF CF CF CF CF CF CF CF CMU
Finished
Compost
stockpile 27007 0.90 9054 9824 7656 2188 466 0 0 0 284 1337 3038 6178 40024 Compost
windrows 77537 0.90 25994 28204 21982 6280 1338 0 0 0 814 3838 8723 17737 114910 Absorption, Sum 35048 38028 29638 8468 1803 0 0 0 1098 5175 11761 23914 154934 Water Loss
K-value CF CF CF CF CF CF CF CF CF CF CF CF CF
Evapotranspiration
Compost
surface SF 136661 0.70 19133 22321 31888 39859 42251 38265 43845 43845 36671 29496 22321 16741 Manipulation Volume 1350 1350 1350 1350 1350 1350 1350 1350 1350 1350 1350 1350 Heat
Compost
weight lbs 85600 0.20 275 275 275 275 275 275 275 275 275 275 275 275 avg. daily Sum 20757 23946 33512 41484 43876 39890 45470 45470 38296 31121 23946 18366 406135 1128 Net water use -14291 -17082 1874 33016 42072 39890 45470 45470 37198 25946 12185 -5549 246201 684 Moisture content of
compost at end of
month start at 48% 51% 52% 48% 40% 38% 39% 37% 37% 39% 42% 45% 49% avail tank storage
start of
month Max= 56504 56504 35739 14390 2133 13338 32559 53949 75340 96730 116800 131966 139211 Added runoff to tank during month 42155 45739 35648 10185 2169 0 0 0 1320 6224 14146 28764 186351 Water applied to compost from CMU storage 0 3000 2000 0 0 0 0 0 0 0 0 0 5000 ADF percolate
water consumption 160000 gal. 21390 CF 21390 21390 21390 21390 21390 21390 21390 21390 21390 21390 21390 21390 256684 Tank storage end of month 20765 42114 54371 43166 23945 2555 -18836 -40226 -60296 -75462 -82707 -75333 Storage % full 37% 75% 96% 76% 42% 5%
Notes:
1 Surface area for evapotranspiration is for inclined surface area because that is the surface exposed to wind and sun. 2 All other surface areas are plan area surfaces. To use inclined surface for incident rainfall would esssentially create extra rainfall depth. 3 C-value for compost runoff is same as C-value used in 40-year simulation for consistency. 4 K-value for water use constants to distinguish from runoff constant C-value. 5 Runoff constants may seem low but these are not single storm event runoff constants. 6 ADF percolate consumption added in 2023.
7 Negative tank storage means supplementary well water is needed for percolate and/or compost conditioning. target range is 40-60%,
supplementary water required
to maintain 40% min.
12 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 County of Santa Barbara Area (SF) C-value
Daily Rainfall Record - through 09-15-2017 CMU
Finished
Compost
stockpile 27007 0.10 0.62
Compost
windrows 77537 0.10 1.78
#262 - Gaviota Coast
Asphalt
aisles 114127 0.90
Lat 34-29-20, Long 120-07-52, Elev 425 ft Average Daily Water Consumption (CF) 0 Daily Rainfall (in inches) recorded as of 8am for the previous 24 hours (PST) Intervention occurs when stored volume exceeds 436,000 gallons.

Codes: PR = Preliminary data, E = Estimated from nearby gauge Effective rainfall (causing runoff) is 24 hour rainfall minus 0.1 inches station id water year year month day daily rain code
days
since rain
effective
rain (in)
effective
rain (ft)
Volume
(CF)
Water
Consumption
(CF)
Cumulative
Volume
(CF)
Cumulative
Volume
(Gallons) Intervention
Water
Year Max Vol.

Water
Year
Max. Daily
Rainfall
Depth
25-Year
Max.

Rainfall
depth
262 1974 1973 10 8 0.08 0.00 1974 153076 1974 2.27 6.71 262 1974 1973 10 23 0.45 15 0.35 0.029 3301 0 3301 24690 1975 354826 1975 5.13 6.71 262 1974 1973 11 12 0.20 20 0.10 0.008 943 0 943 7054 1976 129092 1976 1.93 6.71 262 1974 1973 11 16 0.29 4 0.19 0.016 1792 0 1792 13403 1977 164363 1977 2.43 6.71 262 1974 1973 11 25 0.99 9 0.89 0.074 8393 0 8393 62782 1978 228556 1978 3.34 6.71 262 1974 1973 11 27 0.82 2 0.72 0.060 6790 0 6790 50790 1979 150254 1979 2.23 6.71 262 1974 1973 11 28 0.01 1 0.00 0.000 0 0 0 0 1981 136146 1981 2.03 6.71 262 1974 1973 12 1 1.41 1 1.31 0.109 12354 0 12354 92410 1983 319555 1983 4.63 6.71 262 1974 1973 12 13 0.05 12 0.00 0.000 0 0 0 0 1984 122038 1984 1.83 6.71 262 1974 1973 12 21 0.43 8 0.33 0.028 3112 0 3112 23279 1985 189052 1985 2.78 6.71 262 1974 1973 12 27 0.32 6 0.22 0.018 2075 0 2075 15519 1986 165068 1986 2.44 6.71 262 1974 1973 12 31 0.16 4 0.06 0.005 566 0 566 4233 1987 232788 1987 3.40 6.71 262 1974 1974 1 1 0.17 1 0.07 0.006 660 0 660 4938 1988 108635 1988 1.64 6.71 262 1974 1974 1 3 0.42 2 0.32 0.027 3018 0 3018 22573 1989 28217 1989 0.00 6.71 262 1974 1974 1 4 1.28 1 1.18 0.098 11128 0 11128 83239 1990 73364 1990 1.26 6.71 262 1974 1974 1 5 0.21 1 0.11 0.009 1037 0 1037 7760 1991 281462 1991 4.09 6.71 262 1974 1974 1 6 1.69 1 1.59 0.133 14995 0 14995 112162 1992 239843 1992 3.50 6.71 262 1974 1974 1 7 2.27 1 2.17 0.181 20465 0 20465 153076 1993 253951 1993 3.70 6.71 262 1974 1974 1 11 0.15 4 0.05 0.004 472 0 472 3527 1994 129797 1994 1.94 6.71 262 1974 1974 1 12 0.15 1 0.05 0.004 472 0 472 3527 1995 329431 1995 4.77 6.71 262 1974 1974 1 16 0.37 4 0.27 0.023 2546 0 2546 19046 1996 192579 1996 2.83 6.71 262 1974 1974 1 17 0.40 1 0.30 0.025 2829 0 2829 21163 1997 279346 1997 4.06 6.71 262 1974 1974 3 1 0.26 15 0.16 0.013 1509 0 1509 11287 1998 412670 1998 5.95 6.71 262 1974 1974 3 2 1.33 1 1.23 0.103 11600 0 11600 86767 1999 131913 1999 1.97 6.71 262 1974 1974 3 3 0.64 1 0.54 0.045 5093 0 5093 38093 2000 313912 2000 4.55 6.71 262 1974 1974 3 4 0.16 1 0.06 0.005 566 0 566 4233 2001 552343 2001 5.09 6.71 262 1974 1974 3 7 1.01 3 0.91 0.076 8582 0 8582 64193 2002 160130 2002 2.37 6.71 262 1974 1974 3 26 0.15 19 0.05 0.004 472 0 472 3527 2003 373872 2003 5.40 6.71 262 1974 1974 3 27 1.07 1 0.97 0.081 9148 0 9148 68426 2004 341423 2004 4.94 6.71 262 1974 1974 3 28 0.13 1 0.03 0.003 283 0 283 2116 2005 375283 2005 5.42 6.71 262 1974 1974 3 29 0.19 1 0.09 0.008 849 0 849 6349 2006 207393 2006 3.04 6.71 262 1974 1974 3 31 0.40 2 0.30 0.025 2829 0 2829 21163 2007 108635 2007 1.64 6.71 262 1974 1974 4 1 0.15 1 0.05 0.004 472 0 472 3527 2008 187352 2008 2.76 6.71 262 1974 1974 4 2 0.07 1 0.00 0.000 0 0 0 0 2009 145316 2009 2.16 6.71 262 1975 1974 10 28 0.72 56 0.62 0.052 5847 0 5847 43736 2010 301214 2010 4.37 6.71 13 TABLE 6 - 42-YEAR PRECIPITATION SIMULATION
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1975 1974 10 29 0.31 1 0.21 0.018 1980 0 1980 14814 2011 236315 2011 3.45 6.71 262 1975 1974 11 21 0.23 23 0.13 0.011 1226 0 1226 9170 2012 122743 2012 1.84 6.71 262 1975 1974 12 3 5.13 13 5.03 0.419 47437 0 47437 354826 2013 100875 2013 1.53 6.71 262 1975 1974 12 4 0.27 1 0.17 0.014 1603 0 1603 11992 2014 114278 2014 1.72 6.71 262 1975 1974 12 27 2.01 23 1.91 0.159 18013 0 18013 134735 2015 171417 2015 1.14 6.71 262 1975 1974 12 28 1.07 1 0.97 0.081 9148 0 9148 68426 2016 139673 2016 2.08 6.71 262 1975 1975 1 31 0.03 34 0.00 0.000 0 0 0 0 2017 189758 2017 2.79 6.71 262 1975 1975 2 1 0.49 1 0.39 0.033 3678 0 3678 27511
262 1975 1975 2 2 2.76 1 2.66 0.222 25086 0 25086 187642 262 1975 1975 2 3 0.04 1 0.00 0.000 0 0 0 0
262 1975 1975 2 4 0.37 1 0.27 0.023 2546 0 2546 19046
262 1975 1975 2 8 0.34 4 0.24 0.020 2263 0 2263 16930
262 1975 1975 2 9 0.85 1 0.75 0.063 7073 0 7073 52906
262 1975 1975 2 10 0.13 1 0.03 0.003 283 0 283 2116
262 1975 1975 3 5 1.04 26 0.94 0.078 8865 0 8865 66309
262 1975 1975 3 6 0.40 1 0.30 0.025 2829 0 2829 21163
262 1975 1975 3 7 1.08 1 0.98 0.082 9242 0 9242 69131
262 1975 1975 3 8 0.09 1 0.00 0.000 0 0 0 0
262 1975 1975 3 10 0.75 2 0.65 0.054 6130 0 6130 45852
262 1975 1975 3 13 0.37 3 0.27 0.023 2546 0 2546 19046
262 1975 1975 3 16 0.08 3 0.00 0.000 0 0 0 0
262 1975 1975 3 21 0.17 5 0.07 0.006 660 0 660 4938
262 1975 1975 3 22 0.93 1 0.83 0.069 7828 0 7828 58550
262 1975 1975 4 5 0.32 14 0.22 0.018 2075 0 2075 15519
262 1975 1975 4 6 0.53 1 0.43 0.036 4055 0 4055 30333
262 1975 1975 4 25 0.09 19 0.00 0.000 0 0 0 0
262 1976 1975 10 10 0.44 15 0.34 0.028 3206 0 3206 23984 262 1976 1975 10 11 0.04 1 0.00 0.000 0 0 0 0
262 1976 1975 10 30 0.13 19 0.03 0.003 283 0 283 2116
262 1976 1975 11 28 0.36 29 0.26 0.022 2452 0 2452 18341 262 1976 1975 12 12 0.06 15 0.00 0.000 0 0 0 0
262 1976 1976 2 4 0.04 23 0.00 0.000 0 0 0 0
262 1976 1976 2 5 0.56 1 0.46 0.038 4338 0 4338 32449
262 1976 1976 2 6 0.42 1 0.32 0.027 3018 0 3018 22573
262 1976 1976 2 7 0.88 1 0.78 0.065 7356 0 7356 55023
262 1976 1976 2 8 0.97 1 0.87 0.073 8205 0 8205 61371
262 1976 1976 2 9 1.61 1 1.51 0.126 14240 0 14240 106518 262 1976 1976 2 10 1.93 1 1.83 0.153 17258 0 17258 129092 262 1976 1976 2 13 0.03 3 0.00 0.000 0 0 0 0
262 1976 1976 2 23 0.06 10 0.00 0.000 0 0 0 0
262 1976 1976 2 24 0.21 1 0.11 0.009 1037 0 1037 7760
262 1976 1976 2 29 0.21 5 0.11 0.009 1037 0 1037 7760
262 1976 1976 3 1 1.06 3 0.96 0.080 9054 0 9054 67720
262 1976 1976 3 2 0.56 1 0.46 0.038 4338 0 4338 32449
262 1976 1976 3 3 0.08 1 0.00 0.000 0 0 0 0
262 1976 1976 3 4 0.01 1 0.00 0.000 0 0 0 0
262 1976 1976 4 12 0.21 39 0.11 0.009 1037 0 1037 7760
262 1976 1976 4 14 0.16 2 0.06 0.005 566 0 566 4233
262 1976 1976 4 15 0.58 1 0.48 0.040 4527 0 4527 33860
14 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1977 1976 9 9 0.35 24 0.25 0.021 2358 0 2358 17635
262 1977 1976 9 10 1.21 1 1.11 0.093 10468 0 10468 78302 262 1977 1976 9 11 0.65 1 0.55 0.046 5187 0 5187 38798
262 1977 1976 9 28 1.23 17 1.13 0.094 10657 0 10657 79712 262 1977 1976 9 29 0.33 1 0.23 0.019 2169 0 2169 16225
262 1977 1976 12 30 0.33 32 0.23 0.019 2169 0 2169 16225 262 1977 1976 12 31 0.75 1 0.65 0.054 6130 0 6130 45852 262 1977 1977 1 2 1.57 2 1.47 0.123 13863 0 13863 103697 262 1977 1977 1 3 0.02 1 0.00 0.000 0 0 0 0
262 1977 1977 1 5 0.99 2 0.89 0.074 8393 0 8393 62782
262 1977 1977 1 6 2.43 1 2.33 0.194 21974 0 21974 164363 262 1977 1977 1 7 0.08 1 0.00 0.000 0 0 0 0
262 1977 1977 3 15 0.11 39 0.01 0.001 94 0 94 705
262 1977 1977 3 16 1.10 1 1.00 0.083 9431 0 9431 70542
262 1977 1977 3 24 0.07 8 0.00 0.000 0 0 0 0
262 1977 1977 3 25 0.12 1 0.02 0.002 189 0 189 1411
262 1977 1977 5 7 0.15 13 0.05 0.004 472 0 472 3527
262 1977 1977 5 8 1.66 1 1.56 0.130 14712 0 14712 110045 262 1977 1977 5 10 0.31 2 0.21 0.018 1980 0 1980 14814
262 1978 1977 11 5 0.17 26 0.07 0.006 660 0 660 4938
262 1978 1977 12 21 0.05 47 0.00 0.000 0 0 0 0
262 1978 1977 12 23 0.28 2 0.18 0.015 1698 0 1698 12698 262 1978 1977 12 24 0.04 1 0.00 0.000 0 0 0 0
262 1978 1977 12 25 0.06 1 0.00 0.000 0 0 0 0
262 1978 1977 12 26 0.34 1 0.24 0.020 2263 0 2263 16930 262 1978 1977 12 27 1.93 1 1.83 0.153 17258 0 17258 129092 262 1978 1977 12 28 1.45 1 1.35 0.113 12731 0 12731 95232 262 1978 1978 1 3 0.47 6 0.37 0.031 3489 0 3489 26101
262 1978 1978 1 4 0.33 1 0.23 0.019 2169 0 2169 16225
262 1978 1978 1 5 0.30 1 0.20 0.017 1886 0 1886 14108
262 1978 1978 1 6 0.41 1 0.31 0.026 2924 0 2924 21868
262 1978 1978 1 9 2.19 3 2.09 0.174 19710 0 19710 147433 262 1978 1978 1 10 0.29 1 0.19 0.016 1792 0 1792 13403
262 1978 1978 1 14 1.75 4 1.65 0.138 15561 0 15561 116394 262 1978 1978 1 15 0.05 1 0.00 0.000 0 0 0 0
262 1978 1978 1 16 1.41 1 1.31 0.109 12354 0 12354 92410 262 1978 1978 1 18 0.07 2 0.00 0.000 0 0 0 0
262 1978 1978 1 19 0.17 1 0.07 0.006 660 0 660 4938
262 1978 1978 2 5 0.82 17 0.72 0.060 6790 0 6790 50790
262 1978 1978 2 6 0.07 1 0.00 0.000 0 0 0 0
262 1978 1978 2 7 1.91 1 1.81 0.151 17070 0 17070 127681 262 1978 1978 2 8 2.49 1 2.39 0.199 22539 0 22539 168595 262 1978 1978 2 9 3.34 1 3.24 0.270 30556 0 30556 228556 262 1978 1978 2 10 0.41 1 0.31 0.026 2924 0 2924 21868
262 1978 1978 2 11 0.13 1 0.03 0.003 283 0 283 2116
262 1978 1978 2 12 1.50 1 1.40 0.117 13203 0 13203 98759 262 1978 1978 2 13 0.05 1 0.00 0.000 0 0 0 0
262 1978 1978 3 1 0.12 19 0.02 0.002 189 0 189 1411
262 1978 1978 3 2 1.22 1 1.12 0.093 10562 0 10562 79007 15 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1978 1978 3 3 1.09 1 0.99 0.083 9336 0 9336 69837
262 1978 1978 3 4 2.51 1 2.41 0.201 22728 0 22728 170006 262 1978 1978 3 5 0.11 1 0.01 0.001 94 0 94 705
262 1978 1978 3 9 0.63 4 0.53 0.044 4998 0 4998 37387
262 1978 1978 3 21 0.30 12 0.20 0.017 1886 0 1886 14108 262 1978 1978 3 22 1.52 1 1.42 0.118 13392 0 13392 100170 262 1978 1978 3 28 1.27 6 1.17 0.098 11034 0 11034 82534 262 1978 1978 3 29 0.32 1 0.22 0.018 2075 0 2075 15519
262 1978 1978 3 30 1.02 1 0.92 0.077 8676 0 8676 64899
262 1978 1978 3 31 0.39 1 0.29 0.024 2735 0 2735 20457
262 1978 1978 4 4 0.43 4 0.33 0.028 3112 0 3112 23279
262 1978 1978 4 6 0.27 2 0.17 0.014 1603 0 1603 11992
262 1978 1978 4 14 1.54 8 1.44 0.120 13580 0 13580 101580 262 1978 1978 4 25 0.37 11 0.27 0.023 2546 0 2546 19046 262 1978 1978 4 26 0.04 1 0.00 0.000 0 0 0 0
262 1979 1978 9 4 0.41 8 0.31 0.026 2924 0 2924 21868
262 1979 1978 9 5 0.65 1 0.55 0.046 5187 0 5187 38798
262 1979 1978 11 11 0.19 37 0.09 0.008 849 0 849 6349
262 1979 1978 11 14 0.69 3 0.59 0.049 5564 0 5564 41620 262 1979 1978 11 22 1.36 8 1.26 0.105 11883 0 11883 88883 262 1979 1978 11 23 0.70 1 0.60 0.050 5658 0 5658 42325 262 1979 1978 12 17 0.57 25 0.47 0.039 4432 0 4432 33155 262 1979 1978 12 18 0.44 1 0.34 0.028 3206 0 3206 23984 262 1979 1978 12 19 0.18 1 0.08 0.007 754 0 754 5643
262 1979 1979 1 6 2.23 18 2.13 0.178 20087 0 20087 150254 262 1979 1979 1 7 0.05 1 0.00 0.000 0 0 0 0
262 1979 1979 1 8 0.05 1 0.00 0.000 0 0 0 0
262 1979 1979 1 9 0.22 1 0.12 0.010 1132 0 1132 8465
262 1979 1979 1 17 0.42 8 0.32 0.027 3018 0 3018 22573
262 1979 1979 1 18 1.46 1 1.36 0.113 12826 0 12826 95937 262 1979 1979 1 19 0.49 1 0.39 0.033 3678 0 3678 27511
262 1979 1979 1 21 0.49 2 0.39 0.033 3678 0 3678 27511
262 1979 1979 1 29 0.07 8 0.00 0.000 0 0 0 0
262 1979 1979 1 30 0.62 1 0.52 0.043 4904 0 4904 36682
262 1979 1979 1 31 0.94 1 0.84 0.070 7922 0 7922 59255
262 1979 1979 2 1 0.05 1 0.00 0.000 0 0 0 0
262 1979 1979 2 2 0.52 1 0.42 0.035 3961 0 3961 29628
262 1979 1979 2 13 1.17 11 1.07 0.089 10091 0 10091 75480 262 1979 1979 2 14 0.01 1 0.00 0.000 0 0 0 0
262 1979 1979 2 16 0.32 2 0.22 0.018 2075 0 2075 15519
262 1979 1979 2 20 1.82 4 1.72 0.143 16221 0 16221 121332 262 1979 1979 2 21 0.30 1 0.20 0.017 1886 0 1886 14108
262 1979 1979 2 22 0.86 1 0.76 0.063 7167 0 7167 53612
262 1979 1979 3 1 0.68 10 0.58 0.048 5470 0 5470 40914
262 1979 1979 3 16 1.15 15 1.05 0.088 9902 0 9902 74069 262 1979 1979 3 17 0.01 1 0.00 0.000 0 0 0 0
262 1979 1979 3 27 1.65 10 1.55 0.129 14618 0 14618 109340 262 1979 1979 3 28 0.13 1 0.03 0.003 283 0 283 2116
262 1979 1979 3 30 0.44 2 0.34 0.028 3206 0 3206 23984
16 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1981 1980 12 4 2.03 E226 5 1.93 0.161 18201 0 18201 136146 262 1981 1980 12 5 0.08 E226 1 0.00 0.000 0 0 0 0
262 1981 1981 1 23 1.23 E226 49 1.13 0.094 10657 0 10657 79712 262 1981 1981 1 28 1.45 E226 5 1.35 0.113 12731 0 12731 95232 262 1981 1981 1 29 0.50 E226 1 0.40 0.033 3772 0 3772 28217 262 1981 1981 2 8 1.26 10 1.16 0.097 10940 0 10940 81829 262 1981 1981 2 9 0.54 1 0.44 0.037 4150 0 4150 31038
262 1981 1981 2 26 1.30 17 1.20 0.100 11317 0 11317 84650 262 1981 1981 2 27 0.04 1 0.00 0.000 0 0 0 0
262 1981 1981 3 1 1.57 5 1.47 0.123 13863 0 13863 103697 262 1981 1981 3 2 0.42 1 0.32 0.027 3018 0 3018 22573
262 1981 1981 3 3 0.05 1 0.00 0.000 0 0 0 0
262 1981 1981 3 4 1.74 1 1.64 0.137 15466 0 15466 115689 262 1981 1981 3 5 1.16 1 1.06 0.088 9997 0 9997 74774
262 1981 1981 3 19 0.75 E 14 0.65 0.054 6130 0 6130 45852 262 1981 1981 3 20 0.32 E 1 0.22 0.018 2075 0 2075 15519 262 1981 1981 3 21 0.27 E 1 0.17 0.014 1603 0 1603 11992 262 1981 1981 3 22 0.45 E 1 0.35 0.029 3301 0 3301 24690 262 1981 1981 4 19 0.55 E226 28 0.45 0.038 4244 0 4244 31744 262 1983 1982 11 9 0.03 20 0.00 0.000 0 0 0 0
262 1983 1982 11 10 0.28 1 0.18 0.015 1698 0 1698 12698 262 1983 1982 11 18 0.48 8 0.38 0.032 3584 0 3584 26806 262 1983 1982 11 19 0.35 1 0.25 0.021 2358 0 2358 17635 262 1983 1982 11 23 0.22 4 0.12 0.010 1132 0 1132 8465
262 1983 1982 11 28 0.20 5 0.10 0.008 943 0 943 7054
262 1983 1982 11 29 1.71 1 1.61 0.134 15183 0 15183 113573 262 1983 1982 11 30 1.07 1 0.97 0.081 9148 0 9148 68426 262 1983 1982 12 1 0.30 2 0.20 0.017 1886 0 1886 14108
262 1983 1983 1 18 1.27 48 1.17 0.098 11034 0 11034 82534 262 1983 1983 1 19 0.01 1 0.00 0.000 0 0 0 0
262 1983 1983 1 21 0.39 2 0.29 0.024 2735 0 2735 20457
262 1983 1983 1 22 4.63 1 4.53 0.378 42721 0 42721 319555 262 1983 1983 1 23 0.33 1 0.23 0.019 2169 0 2169 16225
262 1983 1983 1 24 0.77 1 0.67 0.056 6319 0 6319 47263
262 1983 1983 1 26 0.79 2 0.69 0.058 6507 0 6507 48674
262 1983 1983 1 27 1.12 1 1.02 0.085 9619 0 9619 71953
262 1983 1983 1 28 1.24 1 1.14 0.095 10751 0 10751 80418 262 1983 1983 2 2 0.11 5 0.01 0.001 94 0 94 705
262 1983 1983 2 5 0.36 3 0.26 0.022 2452 0 2452 18341
262 1983 1983 2 6 0.37 1 0.27 0.023 2546 0 2546 19046
262 1983 1983 2 7 0.56 1 0.46 0.038 4338 0 4338 32449
262 1983 1983 2 8 0.14 1 0.04 0.003 377 0 377 2822
262 1983 1983 2 12 1.25 4 1.15 0.096 10845 0 10845 81123 262 1983 1983 2 13 0.03 1 0.00 0.000 0 0 0 0
262 1983 1983 2 23 0.39 10 0.29 0.024 2735 0 2735 20457 262 1983 1983 2 24 0.26 1 0.16 0.013 1509 0 1509 11287
262 1983 1983 2 25 1.79 1 1.69 0.141 15938 0 15938 119216 262 1983 1983 2 26 1.34 1 1.24 0.103 11694 0 11694 87472 262 1983 1983 2 27 2.74 1 2.64 0.220 24897 0 24897 186231 17 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1983 1983 2 28 0.33 1 0.23 0.019 2169 0 2169 16225
262 1983 1983 3 1 0.40 4 0.30 0.025 2829 0 2829 21163
262 1983 1983 3 2 1.12 1 1.02 0.085 9619 0 9619 71953
262 1983 1983 3 3 2.66 1 2.56 0.213 24143 0 24143 180587 262 1983 1983 3 4 0.06 1 0.00 0.000 0 0 0 0
262 1983 1983 3 13 0.23 9 0.13 0.011 1226 0 1226 9170
262 1983 1983 3 16 0.51 3 0.41 0.034 3867 0 3867 28922
262 1983 1983 3 17 0.04 1 0.00 0.000 0 0 0 0
262 1983 1983 3 18 0.28 1 0.18 0.015 1698 0 1698 12698
262 1983 1983 3 20 0.71 2 0.61 0.051 5753 0 5753 43031
262 1983 1983 3 21 0.06 1 0.00 0.000 0 0 0 0
262 1983 1983 3 22 0.41 1 0.31 0.026 2924 0 2924 21868
262 1983 1983 3 23 0.67 1 0.57 0.048 5376 0 5376 40209
262 1983 1983 3 24 0.42 1 0.32 0.027 3018 0 3018 22573
262 1983 1983 3 25 0.01 1 0.00 0.000 0 0 0 0
262 1983 1983 3 27 0.22 2 0.12 0.010 1132 0 1132 8465
262 1983 1983 4 17 0.81 21 0.71 0.059 6696 0 6696 50085 262 1983 1983 4 18 0.64 1 0.54 0.045 5093 0 5093 38093
262 1983 1983 4 19 1.01 1 0.91 0.076 8582 0 8582 64193
262 1983 1983 4 20 0.76 1 0.66 0.055 6224 0 6224 46558
262 1983 1983 4 21 0.05 1 0.00 0.000 0 0 0 0
262 1983 1983 4 22 0.08 1 0.00 0.000 0 0 0 0
262 1983 1983 4 23 0.01 1 0.00 0.000 0 0 0 0
262 1983 1983 4 28 0.43 5 0.33 0.028 3112 0 3112 23279
262 1983 1983 4 29 0.04 1 0.00 0.000 0 0 0 0
262 1984 1983 9 29 0.30 E 30 0.20 0.017 1886 0 1886 14108 262 1984 1983 9 30 1.83 E 1 1.73 0.144 16315 0 16315 122038 262 1984 1983 10 1 0.68 2 0.58 0.048 5470 0 5470 40914
262 1984 1983 11 10 0.01 40 0.00 0.000 0 0 0 0
262 1984 1983 11 11 1.69 1 1.59 0.133 14995 0 14995 112162 262 1984 1983 11 12 0.12 1 0.02 0.002 189 0 189 1411
262 1984 1983 11 20 0.14 8 0.04 0.003 377 0 377 2822
262 1984 1983 11 21 0.22 1 0.12 0.010 1132 0 1132 8465
262 1984 1983 11 22 0.01 1 0.00 0.000 0 0 0 0
262 1984 1983 11 24 1.27 2 1.17 0.098 11034 0 11034 82534 262 1984 1983 12 9 1.00 16 0.90 0.075 8488 0 8488 63488 262 1984 1983 12 10 0.22 1 0.12 0.010 1132 0 1132 8465
262 1984 1983 12 24 1.35 14 1.25 0.104 11788 0 11788 88177 262 1984 1983 12 25 1.25 1 1.15 0.096 10845 0 10845 81123 262 1985 1984 11 12 0.34 18 0.24 0.020 2263 0 2263 16930 262 1985 1984 11 13 0.06 1 0.00 0.000 0 0 0 0
262 1985 1984 11 23 0.01 10 0.00 0.000 0 0 0 0
262 1985 1984 11 24 0.93 1 0.83 0.069 7828 0 7828 58550 262 1985 1984 11 27 0.17 3 0.07 0.006 660 0 660 4938
262 1985 1984 11 28 0.17 1 0.07 0.006 660 0 660 4938
262 1985 1984 12 2 0.14 5 0.04 0.003 377 0 377 2822
262 1985 1984 12 3 0.05 1 0.00 0.000 0 0 0 0
262 1985 1984 12 7 1.35 4 1.25 0.104 11788 0 11788 88177 262 1985 1984 12 8 0.05 1 0.00 0.000 0 0 0 0
18 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1985 1984 12 10 0.79 2 0.69 0.058 6507 0 6507 48674 262 1985 1984 12 15 0.77 5 0.67 0.056 6319 0 6319 47263 262 1985 1984 12 19 1.38 4 1.28 0.107 12071 0 12071 90294 262 1985 1985 1 9 0.54 21 0.44 0.037 4150 0 4150 31038
262 1985 1985 1 10 0.22 1 0.12 0.010 1132 0 1132 8465
262 1985 1985 2 8 2.78 29 2.68 0.223 25274 0 25274 189052 262 1985 1985 2 9 0.03 1 0.00 0.000 0 0 0 0
262 1985 1985 3 6 0.01 28 0.00 0.000 0 0 0 0
262 1985 1985 3 7 0.47 1 0.37 0.031 3489 0 3489 26101
262 1986 1985 11 24 2.20 48 2.10 0.175 19805 0 19805 148138 262 1986 1985 11 25 1.17 1 1.07 0.089 10091 0 10091 75480 262 1986 1985 11 29 0.91 E 4 0.81 0.068 7639 0 7639 57139 262 1986 1985 11 30 0.80 1 0.70 0.058 6602 0 6602 49379 262 1986 1985 12 1 0.03 2 0.00 0.000 0 0 0 0
262 1986 1985 12 2 1.76 E 1 1.66 0.138 15655 0 15655 117100 262 1986 1986 1 3 0.07 32 0.00 0.000 0 0 0 0
262 1986 1986 1 4 0.75 1 0.65 0.054 6130 0 6130 45852
262 1986 1986 1 5 0.28 1 0.18 0.015 1698 0 1698 12698
262 1986 1986 1 29 0.69 24 0.59 0.049 5564 0 5564 41620 262 1986 1986 1 30 0.25 1 0.15 0.013 1415 0 1415 10581
262 1986 1986 1 31 0.62 1 0.52 0.043 4904 0 4904 36682
262 1986 1986 2 11 0.11 11 0.01 0.001 94 0 94 705
262 1986 1986 2 12 2.44 1 2.34 0.195 22068 0 22068 165068 262 1986 1986 2 13 2.15 1 2.05 0.171 19333 0 19333 144611 262 1986 1986 2 14 1.76 1 1.66 0.138 15655 0 15655 117100 262 1986 1986 2 15 0.05 1 0.00 0.000 0 0 0 0
262 1986 1986 2 16 0.12 1 0.02 0.002 189 0 189 1411
262 1986 1986 2 17 0.33 1 0.23 0.019 2169 0 2169 16225
262 1986 1986 2 18 0.40 1 0.30 0.025 2829 0 2829 21163
262 1986 1986 2 19 0.58 1 0.48 0.040 4527 0 4527 33860
262 1986 1986 3 7 0.07 19 0.00 0.000 0 0 0 0
262 1986 1986 3 8 2.15 1 2.05 0.171 19333 0 19333 144611 262 1986 1986 3 9 0.62 1 0.52 0.043 4904 0 4904 36682
262 1986 1986 3 10 1.68 1 1.58 0.132 14901 0 14901 111456 262 1986 1986 3 11 0.05 1 0.00 0.000 0 0 0 0
262 1986 1986 3 12 0.20 1 0.10 0.008 943 0 943 7054
262 1986 1986 3 14 0.52 2 0.42 0.035 3961 0 3961 29628
262 1987 1986 9 21 0.12 38 0.02 0.002 189 0 189 1411
262 1987 1986 9 22 0.13 1 0.03 0.003 283 0 283 2116
262 1987 1986 9 23 0.07 1 0.00 0.000 0 0 0 0
262 1987 1986 9 24 1.38 1 1.28 0.107 12071 0 12071 90294 262 1987 1986 12 5 0.18 E 12 0.08 0.007 754 0 754 5643
262 1987 1986 12 6 0.25 E 1 0.15 0.013 1415 0 1415 10581 262 1987 1987 1 3 0.46 28 0.36 0.030 3395 0 3395 25395
262 1987 1987 1 4 0.79 1 0.69 0.058 6507 0 6507 48674
262 1987 1987 1 5 0.12 1 0.02 0.002 189 0 189 1411
262 1987 1987 1 6 0.98 1 0.88 0.073 8299 0 8299 62077
262 1987 1987 1 7 0.03 1 0.00 0.000 0 0 0 0
262 1987 1987 2 8 0.05 32 0.00 0.000 0 0 0 0
19 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1987 1987 2 9 0.42 1 0.32 0.027 3018 0 3018 22573
262 1987 1987 2 10 2.02 1 1.92 0.160 18107 0 18107 135441 262 1987 1987 2 13 1.83 3 1.73 0.144 16315 0 16315 122038 262 1987 1987 2 15 0.14 2 0.04 0.003 377 0 377 2822
262 1987 1987 2 22 0.45 7 0.35 0.029 3301 0 3301 24690
262 1987 1987 2 23 0.16 1 0.06 0.005 566 0 566 4233
262 1987 1987 2 24 0.14 1 0.04 0.003 377 0 377 2822
262 1987 1987 2 25 0.24 1 0.14 0.012 1320 0 1320 9876
262 1987 1987 3 4 0.26 10 0.16 0.013 1509 0 1509 11287
262 1987 1987 3 5 3.40 1 3.30 0.275 31121 0 31121 232788 262 1987 1987 3 6 2.19 1 2.09 0.174 19710 0 19710 147433 262 1987 1987 3 13 0.14 7 0.04 0.003 377 0 377 2822
262 1987 1987 3 21 0.73 8 0.63 0.053 5941 0 5941 44441
262 1988 1987 9 7 0.01 17 0.00 0.000 0 0 0 0
262 1988 1987 9 20 0.01 13 0.00 0.000 0 0 0 0
262 1988 1987 9 27 0.01 7 0.00 0.000 0 0 0 0
262 1988 1987 9 28 0.01 1 0.00 0.000 0 0 0 0
262 1988 1987 10 22 1.47 25 1.37 0.114 12920 0 12920 96642 262 1988 1987 10 23 0.17 1 0.07 0.006 660 0 660 4938
262 1988 1987 10 24 0.06 1 0.00 0.000 0 0 0 0
262 1988 1987 10 29 0.73 5 0.63 0.053 5941 0 5941 44441 262 1988 1987 10 31 0.24 2 0.14 0.012 1320 0 1320 9876
262 1988 1987 11 4 0.03 4 0.00 0.000 0 0 0 0
262 1988 1987 11 5 0.12 1 0.02 0.002 189 0 189 1411
262 1988 1987 11 17 0.14 12 0.04 0.003 377 0 377 2822
262 1988 1987 12 4 0.71 18 0.61 0.051 5753 0 5753 43031 262 1988 1987 12 6 0.44 2 0.34 0.028 3206 0 3206 23984
262 1988 1987 12 16 1.40 10 1.30 0.108 12260 0 12260 91705 262 1988 1987 12 27 0.36 11 0.26 0.022 2452 0 2452 18341 262 1988 1987 12 28 0.82 1 0.72 0.060 6790 0 6790 50790 262 1988 1988 1 4 0.86 7 0.76 0.063 7167 0 7167 53612
262 1988 1988 1 5 0.67 1 0.57 0.048 5376 0 5376 40209
262 1988 1988 1 16 0.02 11 0.00 0.000 0 0 0 0
262 1988 1988 1 17 1.37 1 1.27 0.106 11977 0 11977 89588 262 1988 1988 2 26 0.59 40 0.49 0.041 4621 0 4621 34566 262 1988 1988 2 27 0.03 1 0.00 0.000 0 0 0 0
262 1988 1988 2 28 1.58 1 1.48 0.123 13957 0 13957 104402 262 1988 1988 4 14 0.34 17 0.24 0.020 2263 0 2263 16930 262 1988 1988 4 19 1.64 5 1.54 0.128 14523 0 14523 108635 262 1988 1988 4 20 0.46 1 0.36 0.030 3395 0 3395 25395
262 1988 1988 4 23 0.44 3 0.34 0.028 3206 0 3206 23984
262 1990 1989 9 29 0.12 E226 36 0.02 0.002 189 0 189 1411 262 1990 1989 10 22 0.50 E226 24 0.40 0.033 3772 0 3772 28217 262 1990 1989 10 24 0.25 E226 2 0.15 0.013 1415 0 1415 10581 262 1990 1989 11 26 0.25 E226 33 0.15 0.013 1415 0 1415 10581 262 1990 1990 1 1 0.05 6 0.00 0.000 0 0 0 0
262 1990 1990 1 2 0.20 1 0.10 0.008 943 0 943 7054
262 1990 1990 1 12 1.13 10 1.03 0.086 9714 0 9714 72658 262 1990 1990 1 13 0.44 1 0.34 0.028 3206 0 3206 23984
20 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1990 1990 1 14 0.77 1 0.67 0.056 6319 0 6319 47263
262 1990 1990 1 15 0.10 1 0.00 0.000 0 0 0 0
262 1990 1990 1 16 0.23 1 0.13 0.011 1226 0 1226 9170
262 1990 1990 1 17 0.10 1 0.00 0.000 0 0 0 0
262 1990 1990 2 3 0.02 17 0.00 0.000 0 0 0 0
262 1990 1990 2 4 0.49 1 0.39 0.033 3678 0 3678 27511
262 1990 1990 2 16 1.14 12 1.04 0.087 9808 0 9808 73364 262 1990 1990 2 17 0.26 1 0.16 0.013 1509 0 1509 11287
262 1990 1990 2 18 0.02 1 0.00 0.000 0 0 0 0
262 1990 1990 3 13 0.05 E226 26 0.00 0.000 0 0 0 0
262 1990 1990 4 17 0.35 E226 35 0.25 0.021 2358 0 2358 17635 262 1990 1990 5 27 0.75 40 0.65 0.054 6130 0 6130 45852 262 1991 1990 12 19 0.24 23 0.14 0.012 1320 0 1320 9876 262 1991 1990 12 20 0.29 1 0.19 0.016 1792 0 1792 13403 262 1991 1991 1 3 0.18 14 0.08 0.007 754 0 754 5643
262 1991 1991 1 4 0.80 1 0.70 0.058 6602 0 6602 49379
262 1991 1991 1 5 0.08 1 0.00 0.000 0 0 0 0
262 1991 1991 1 10 0.51 5 0.41 0.034 3867 0 3867 28922
262 1991 1991 2 26 0.44 47 0.34 0.028 3206 0 3206 23984 262 1991 1991 2 27 2.82 1 2.72 0.227 25652 0 25652 191874 262 1991 1991 2 28 1.70 1 1.60 0.133 15089 0 15089 112867 262 1991 1991 3 1 0.16 4 0.06 0.005 566 0 566 4233
262 1991 1991 3 4 0.71 3 0.61 0.051 5753 0 5753 43031
262 1991 1991 3 14 0.17 10 0.07 0.006 660 0 660 4938
262 1991 1991 3 17 1.97 3 1.87 0.156 17635 0 17635 131913 262 1991 1991 3 18 4.09 1 3.99 0.333 37629 0 37629 281462 262 1991 1991 3 19 0.09 1 0.00 0.000 0 0 0 0
262 1991 1991 3 20 0.97 1 0.87 0.073 8205 0 8205 61371
262 1991 1991 3 24 0.77 4 0.67 0.056 6319 0 6319 47263
262 1991 1991 3 25 0.37 1 0.27 0.023 2546 0 2546 19046
262 1991 1991 3 26 0.80 1 0.70 0.058 6602 0 6602 49379
262 1991 1991 3 27 0.03 1 0.00 0.000 0 0 0 0
262 1992 1991 10 26 0.30 30 0.20 0.017 1886 0 1886 14108 262 1992 1991 12 27 1.46 32 1.36 0.113 12826 0 12826 95937 262 1992 1991 12 28 0.56 1 0.46 0.038 4338 0 4338 32449 262 1992 1991 12 29 1.35 1 1.25 0.104 11788 0 11788 88177 262 1992 1991 12 30 0.09 1 0.00 0.000 0 0 0 0
262 1992 1992 1 3 0.33 4 0.23 0.019 2169 0 2169 16225
262 1992 1992 1 5 1.97 2 1.87 0.156 17635 0 17635 131913 262 1992 1992 1 7 0.23 2 0.13 0.011 1226 0 1226 9170
262 1992 1992 2 6 0.62 30 0.52 0.043 4904 0 4904 36682
262 1992 1992 2 9 0.77 3 0.67 0.056 6319 0 6319 47263
262 1992 1992 2 10 1.19 1 1.09 0.091 10280 0 10280 76891 262 1992 1992 2 11 0.10 1 0.00 0.000 0 0 0 0
262 1992 1992 2 12 3.50 1 3.40 0.283 32065 0 32065 239843 262 1992 1992 2 13 0.28 1 0.18 0.015 1698 0 1698 12698
262 1992 1992 2 14 0.03 1 0.00 0.000 0 0 0 0
262 1992 1992 2 15 1.53 1 1.43 0.119 13486 0 13486 100875 262 1992 1992 3 2 0.51 18 0.41 0.034 3867 0 3867 28922
21 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1992 1992 3 5 1.20 3 1.10 0.092 10374 0 10374 77596 262 1992 1992 3 6 0.57 1 0.47 0.039 4432 0 4432 33155
262 1992 1992 3 7 0.15 1 0.05 0.004 472 0 472 3527
262 1992 1992 3 19 0.02 12 0.00 0.000 0 0 0 0
262 1992 1992 3 20 0.76 1 0.66 0.055 6224 0 6224 46558
262 1992 1992 3 21 0.11 1 0.01 0.001 94 0 94 705
262 1992 1992 3 22 1.29 1 1.19 0.099 11223 0 11223 83945 262 1992 1992 3 23 0.38 1 0.28 0.023 2641 0 2641 19752
262 1993 1992 10 29 0.13 37 0.03 0.003 283 0 283 2116
262 1993 1992 10 30 0.67 1 0.57 0.048 5376 0 5376 40209 262 1993 1992 12 3 0.13 4 0.03 0.003 283 0 283 2116
262 1993 1992 12 6 1.44 3 1.34 0.112 12637 0 12637 94526 262 1993 1992 12 7 1.07 1 0.97 0.081 9148 0 9148 68426
262 1993 1992 12 10 0.02 3 0.00 0.000 0 0 0 0
262 1993 1992 12 11 0.41 1 0.31 0.026 2924 0 2924 21868 262 1993 1992 12 17 0.23 6 0.13 0.011 1226 0 1226 9170
262 1993 1992 12 18 0.03 1 0.00 0.000 0 0 0 0
262 1993 1992 12 19 0.10 1 0.00 0.000 0 0 0 0
262 1993 1992 12 28 0.85 9 0.75 0.063 7073 0 7073 52906 262 1993 1992 12 29 0.34 1 0.24 0.020 2263 0 2263 16930 262 1993 1992 12 30 0.01 1 0.00 0.000 0 0 0 0
262 1993 1993 1 1 0.36 2 0.26 0.022 2452 0 2452 18341
262 1993 1993 1 6 3.15 5 3.05 0.254 28764 0 28764 215153 262 1993 1993 1 7 0.79 1 0.69 0.058 6507 0 6507 48674
262 1993 1993 1 10 0.37 3 0.27 0.023 2546 0 2546 19046
262 1993 1993 1 12 0.87 2 0.77 0.064 7262 0 7262 54317
262 1993 1993 1 13 1.18 1 1.08 0.090 10185 0 10185 76185 262 1993 1993 1 14 0.11 1 0.01 0.001 94 0 94 705
262 1993 1993 1 15 1.37 1 1.27 0.106 11977 0 11977 89588 262 1993 1993 1 16 1.60 1 1.50 0.125 14146 0 14146 105813 262 1993 1993 1 17 0.89 1 0.79 0.066 7450 0 7450 55728
262 1993 1993 1 18 1.23 1 1.13 0.094 10657 0 10657 79712 262 1993 1993 2 8 2.35 21 2.25 0.188 21219 0 21219 158719 262 1993 1993 2 9 0.43 1 0.33 0.028 3112 0 3112 23279
262 1993 1993 2 19 1.47 10 1.37 0.114 12920 0 12920 96642 262 1993 1993 2 20 0.11 1 0.01 0.001 94 0 94 705
262 1993 1993 2 21 0.02 1 0.00 0.000 0 0 0 0
262 1993 1993 2 22 1.10 1 1.00 0.083 9431 0 9431 70542
262 1993 1993 2 23 1.74 1 1.64 0.137 15466 0 15466 115689 262 1993 1993 2 25 0.74 2 0.64 0.053 6036 0 6036 45147
262 1993 1993 2 26 0.83 1 0.73 0.061 6884 0 6884 51496
262 1993 1993 3 24 0.27 29 0.17 0.014 1603 0 1603 11992 262 1993 1993 3 25 3.70 1 3.60 0.300 33951 0 33951 253951 262 1993 1993 3 26 0.20 1 0.10 0.008 943 0 943 7054
262 1993 1993 3 27 1.19 1 1.09 0.091 10280 0 10280 76891 262 1994 1993 11 10 0.25 14 0.15 0.013 1415 0 1415 10581 262 1994 1993 11 11 0.08 1 0.00 0.000 0 0 0 0
262 1994 1993 11 29 0.72 18 0.62 0.052 5847 0 5847 43736 262 1994 1993 12 11 1.41 13 1.31 0.109 12354 0 12354 92410 22 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1994 1993 12 13 0.64 2 0.54 0.045 5093 0 5093 38093 262 1994 1993 12 14 0.04 1 0.00 0.000 0 0 0 0
262 1994 1994 1 23 0.47 40 0.37 0.031 3489 0 3489 26101 262 1994 1994 1 24 1.17 1 1.07 0.089 10091 0 10091 75480 262 1994 1994 1 25 0.05 1 0.00 0.000 0 0 0 0
262 1994 1994 2 3 0.61 9 0.51 0.043 4810 0 4810 35976
262 1994 1994 2 4 0.15 1 0.05 0.004 472 0 472 3527
262 1994 1994 2 6 0.41 2 0.31 0.026 2924 0 2924 21868
262 1994 1994 2 7 1.94 1 1.84 0.153 17353 0 17353 129797 262 1994 1994 2 8 0.03 1 0.00 0.000 0 0 0 0
262 1994 1994 2 16 0.04 8 0.00 0.000 0 0 0 0
262 1994 1994 2 17 1.87 1 1.77 0.148 16692 0 16692 124859 262 1994 1994 2 18 0.11 1 0.01 0.001 94 0 94 705
262 1994 1994 2 19 1.41 1 1.31 0.109 12354 0 12354 92410 262 1994 1994 2 20 0.29 1 0.19 0.016 1792 0 1792 13403
262 1994 1994 3 6 0.19 E 17 0.09 0.008 849 0 849 6349
262 1994 1994 3 7 0.52 E 1 0.42 0.035 3961 0 3961 29628 262 1994 1994 3 19 0.42 12 0.32 0.027 3018 0 3018 22573 262 1994 1994 3 24 1.14 5 1.04 0.087 9808 0 9808 73364
262 1994 1994 4 25 0.50 E 32 0.40 0.033 3772 0 3772 28217 262 1994 1994 5 7 0.10 E 12 0.00 0.000 0 0 0 0
262 1994 1994 5 17 0.14 10 0.04 0.003 377 0 377 2822
262 1994 1994 5 18 0.11 1 0.01 0.001 94 0 94 705
262 1995 1994 9 23 0.05 36 0.00 0.000 0 0 0 0
262 1995 1994 10 3 0.07 11 0.00 0.000 0 0 0 0
262 1995 1994 10 4 0.40 1 0.30 0.025 2829 0 2829 21163
262 1995 1994 11 7 0.31 34 0.21 0.018 1980 0 1980 14814 262 1995 1994 11 8 0.01 1 0.00 0.000 0 0 0 0
262 1995 1994 11 15 0.35 7 0.25 0.021 2358 0 2358 17635 262 1995 1994 11 16 0.60 1 0.50 0.042 4715 0 4715 35271 262 1995 1994 12 20 0.32 35 0.22 0.018 2075 0 2075 15519 262 1995 1994 12 24 0.50 4 0.40 0.033 3772 0 3772 28217 262 1995 1995 1 2 0.05 9 0.00 0.000 0 0 0 0
262 1995 1995 1 3 1.16 1 1.06 0.088 9997 0 9997 74774
262 1995 1995 1 4 4.24 1 4.14 0.345 39043 0 39043 292044 262 1995 1995 1 5 0.01 1 0.00 0.000 0 0 0 0
262 1995 1995 1 7 1.64 2 1.54 0.128 14523 0 14523 108635 262 1995 1995 1 8 0.82 1 0.72 0.060 6790 0 6790 50790
262 1995 1995 1 9 1.61 1 1.51 0.126 14240 0 14240 106518 262 1995 1995 1 10 4.77 1 4.67 0.389 44042 0 44042 329431 262 1995 1995 1 11 0.12 1 0.02 0.002 189 0 189 1411
262 1995 1995 1 12 0.52 1 0.42 0.035 3961 0 3961 29628
262 1995 1995 1 14 0.88 2 0.78 0.065 7356 0 7356 55023
262 1995 1995 1 15 0.13 1 0.03 0.003 283 0 283 2116
262 1995 1995 1 16 0.18 1 0.08 0.007 754 0 754 5643
262 1995 1995 1 20 0.58 4 0.48 0.040 4527 0 4527 33860
262 1995 1995 1 21 0.05 1 0.00 0.000 0 0 0 0
262 1995 1995 1 22 0.53 1 0.43 0.036 4055 0 4055 30333
262 1995 1995 1 23 2.02 1 1.92 0.160 18107 0 18107 135441 23 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1995 1995 1 24 2.31 1 2.21 0.184 20842 0 20842 155898 262 1995 1995 1 25 1.41 1 1.31 0.109 12354 0 12354 92410 262 1995 1995 2 8 0.70 14 0.60 0.050 5658 0 5658 42325
262 1995 1995 2 9 0.11 1 0.01 0.001 94 0 94 705
262 1995 1995 2 13 0.89 4 0.79 0.066 7450 0 7450 55728
262 1995 1995 2 14 0.50 1 0.40 0.033 3772 0 3772 28217
262 1995 1995 3 1 0.07 18 0.00 0.000 0 0 0 0
262 1995 1995 3 2 0.61 1 0.51 0.043 4810 0 4810 35976
262 1995 1995 3 3 0.12 1 0.02 0.002 189 0 189 1411
262 1995 1995 3 4 0.60 1 0.50 0.042 4715 0 4715 35271
262 1995 1995 3 5 2.10 1 2.00 0.167 18861 0 18861 141084 262 1995 1995 3 9 0.11 4 0.01 0.001 94 0 94 705
262 1995 1995 3 10 4.39 1 4.29 0.358 40458 0 40458 302625 262 1995 1995 3 11 1.43 1 1.33 0.111 12543 0 12543 93821 262 1995 1995 3 20 0.63 9 0.53 0.044 4998 0 4998 37387
262 1995 1995 3 21 0.11 1 0.01 0.001 94 0 94 705
262 1995 1995 3 22 1.56 1 1.46 0.122 13769 0 13769 102991 262 1995 1995 3 23 0.35 1 0.25 0.021 2358 0 2358 17635
262 1995 1995 4 16 0.32 24 0.22 0.018 2075 0 2075 15519 262 1995 1995 4 17 0.01 1 0.00 0.000 0 0 0 0
262 1995 1995 4 18 0.06 1 0.00 0.000 0 0 0 0
262 1995 1995 5 15 0.09 27 0.00 0.000 0 0 0 0
262 1995 1995 5 16 0.97 1 0.87 0.073 8205 0 8205 61371
262 1995 1995 6 2 0.03 17 0.00 0.000 0 0 0 0
262 1995 1995 6 15 0.50 13 0.40 0.033 3772 0 3772 28217 262 1995 1995 6 16 0.54 1 0.44 0.037 4150 0 4150 31038
262 1996 1995 11 1 0.22 E329 16 0.12 0.010 1132 0 1132 8465 262 1996 1995 12 12 1.22 42 1.12 0.093 10562 0 10562 79007 262 1996 1995 12 13 0.41 1 0.31 0.026 2924 0 2924 21868 262 1996 1995 12 23 0.39 10 0.29 0.024 2735 0 2735 20457 262 1996 1995 12 24 0.29 1 0.19 0.016 1792 0 1792 13403 262 1996 1996 1 16 0.33 23 0.23 0.019 2169 0 2169 16225 262 1996 1996 1 19 0.13 3 0.03 0.003 283 0 283 2116
262 1996 1996 1 20 0.16 1 0.06 0.005 566 0 566 4233
262 1996 1996 1 21 0.16 1 0.06 0.005 566 0 566 4233
262 1996 1996 1 22 0.18 1 0.08 0.007 754 0 754 5643
262 1996 1996 1 24 0.02 2 0.00 0.000 0 0 0 0
262 1996 1996 1 25 0.29 1 0.19 0.016 1792 0 1792 13403
262 1996 1996 1 27 0.21 2 0.11 0.009 1037 0 1037 7760
262 1996 1996 1 30 0.24 3 0.14 0.012 1320 0 1320 9876
262 1996 1996 1 31 1.40 1 1.30 0.108 12260 0 12260 91705 262 1996 1996 2 2 0.04 2 0.00 0.000 0 0 0 0
262 1996 1996 2 3 1.02 1 0.92 0.077 8676 0 8676 64899
262 1996 1996 2 5 0.50 2 0.40 0.033 3772 0 3772 28217
262 1996 1996 2 15 0.10 10 0.00 0.000 0 0 0 0
262 1996 1996 2 19 2.83 4 2.73 0.228 25746 0 25746 192579 262 1996 1996 2 20 1.67 1 1.57 0.131 14806 0 14806 110751 262 1996 1996 2 21 0.30 1 0.20 0.017 1886 0 1886 14108
262 1996 1996 2 25 0.40 4 0.30 0.025 2829 0 2829 21163
24 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1996 1996 2 26 0.26 1 0.16 0.013 1509 0 1509 11287
262 1996 1996 2 27 0.44 1 0.34 0.028 3206 0 3206 23984
262 1996 1996 3 3 0.01 7 0.00 0.000 0 0 0 0
262 1996 1996 3 4 0.81 1 0.71 0.059 6696 0 6696 50085
262 1996 1996 3 12 1.15 8 1.05 0.088 9902 0 9902 74069
262 1996 1996 4 1 0.50 20 0.40 0.033 3772 0 3772 28217
262 1996 1996 4 16 0.06 15 0.00 0.000 0 0 0 0
262 1996 1996 4 17 0.19 1 0.09 0.008 849 0 849 6349
262 1996 1996 4 18 0.16 1 0.06 0.005 566 0 566 4233
262 1996 1996 5 16 1.09 28 0.99 0.083 9336 0 9336 69837 262 1997 1996 10 30 2.95 45 2.85 0.238 26878 0 26878 201045 262 1997 1996 11 21 0.98 22 0.88 0.073 8299 0 8299 62077 262 1997 1996 11 23 2.63 2 2.53 0.211 23860 0 23860 178471 262 1997 1996 12 9 0.09 17 0.00 0.000 0 0 0 0
262 1997 1996 12 10 1.48 1 1.38 0.115 13014 0 13014 97348 262 1997 1996 12 11 4.06 1 3.96 0.330 37346 0 37346 279346 262 1997 1996 12 12 0.21 1 0.11 0.009 1037 0 1037 7760
262 1997 1996 12 22 0.53 10 0.43 0.036 4055 0 4055 30333 262 1997 1996 12 27 0.38 5 0.28 0.023 2641 0 2641 19752 262 1997 1996 12 28 0.27 1 0.17 0.014 1603 0 1603 11992 262 1997 1996 12 30 0.03 2 0.00 0.000 0 0 0 0
262 1997 1996 12 31 0.26 1 0.16 0.013 1509 0 1509 11287 262 1997 1997 1 1 0.11 1 0.01 0.001 94 0 94 705
262 1997 1997 1 2 0.99 1 0.89 0.074 8393 0 8393 62782
262 1997 1997 1 3 0.95 1 0.85 0.071 8016 0 8016 59961
262 1997 1997 1 13 0.38 10 0.28 0.023 2641 0 2641 19752 262 1997 1997 1 15 0.76 2 0.66 0.055 6224 0 6224 46558
262 1997 1997 1 20 0.17 5 0.07 0.006 660 0 660 4938
262 1997 1997 1 21 0.09 1 0.00 0.000 0 0 0 0
262 1997 1997 1 22 0.32 1 0.22 0.018 2075 0 2075 15519
262 1997 1997 1 23 1.68 1 1.58 0.132 14901 0 14901 111456 262 1997 1997 1 25 0.18 2 0.08 0.007 754 0 754 5643
262 1997 1997 1 26 1.39 1 1.29 0.108 12166 0 12166 90999 262 1997 1997 1 27 0.19 1 0.09 0.008 849 0 849 6349
262 1998 1997 11 11 0.65 15 0.55 0.046 5187 0 5187 38798 262 1998 1997 11 13 0.12 2 0.02 0.002 189 0 189 1411
262 1998 1997 11 14 0.20 1 0.10 0.008 943 0 943 7054
262 1998 1997 11 16 0.50 2 0.40 0.033 3772 0 3772 28217 262 1998 1997 11 20 0.10 4 0.00 0.000 0 0 0 0
262 1998 1997 11 26 0.55 6 0.45 0.038 4244 0 4244 31744 262 1998 1997 11 27 0.25 1 0.15 0.013 1415 0 1415 10581 262 1998 1997 11 30 0.45 3 0.35 0.029 3301 0 3301 24690 262 1998 1997 12 1 0.05 2 0.00 0.000 0 0 0 0
262 1998 1997 12 5 1.85 4 1.75 0.146 16504 0 16504 123448 262 1998 1997 12 6 4.10 1 4.00 0.333 37723 0 37723 282168 262 1998 1997 12 8 0.52 2 0.42 0.035 3961 0 3961 29628
262 1998 1997 12 15 0.03 7 0.00 0.000 0 0 0 0
262 1998 1997 12 18 0.18 3 0.08 0.007 754 0 754 5643
262 1998 1997 12 19 1.22 1 1.12 0.093 10562 0 10562 79007 25 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1998 1998 1 4 0.20 16 0.10 0.008 943 0 943 7054
262 1998 1998 1 5 0.15 1 0.05 0.004 472 0 472 3527
262 1998 1998 1 6 0.60 1 0.50 0.042 4715 0 4715 35271
262 1998 1998 1 10 2.50 4 2.40 0.200 22634 0 22634 169301 262 1998 1998 1 13 0.12 3 0.02 0.002 189 0 189 1411
262 1998 1998 1 15 0.24 2 0.14 0.012 1320 0 1320 9876
262 1998 1998 1 19 0.32 4 0.22 0.018 2075 0 2075 15519
262 1998 1998 1 29 0.82 10 0.72 0.060 6790 0 6790 50790 262 1998 1998 1 30 0.11 1 0.01 0.001 94 0 94 705
262 1998 1998 1 31 0.09 1 0.00 0.000 0 0 0 0
262 1998 1998 2 2 5.95 2 5.85 0.488 55170 0 55170 412670 262 1998 1998 2 3 1.88 1 1.78 0.148 16787 0 16787 125565 262 1998 1998 2 4 0.27 1 0.17 0.014 1603 0 1603 11992
262 1998 1998 2 6 1.56 2 1.46 0.122 13769 0 13769 102991 262 1998 1998 2 7 0.33 1 0.23 0.019 2169 0 2169 16225
262 1998 1998 2 8 1.86 1 1.76 0.147 16598 0 16598 124154 262 1998 1998 2 9 0.40 1 0.30 0.025 2829 0 2829 21163
262 1998 1998 2 14 1.25 5 1.15 0.096 10845 0 10845 81123 262 1998 1998 2 15 1.52 1 1.42 0.118 13392 0 13392 100170 262 1998 1998 2 17 0.98 2 0.88 0.073 8299 0 8299 62077
262 1998 1998 2 20 1.08 3 0.98 0.082 9242 0 9242 69131
262 1998 1998 2 22 1.63 2 1.53 0.128 14429 0 14429 107929 262 1998 1998 2 23 1.15 1 1.05 0.088 9902 0 9902 74069
262 1998 1998 2 24 0.32 1 0.22 0.018 2075 0 2075 15519
262 1998 1998 3 6 0.35 13 0.25 0.021 2358 0 2358 17635
262 1998 1998 3 25 2.00 19 1.90 0.158 17918 0 17918 134030 262 1998 1998 3 26 0.32 1 0.22 0.018 2075 0 2075 15519
262 1998 1998 3 28 0.23 2 0.13 0.011 1226 0 1226 9170
262 1998 1998 3 29 0.12 1 0.02 0.002 189 0 189 1411
262 1998 1998 4 1 0.58 3 0.48 0.040 4527 0 4527 33860
262 1998 1998 4 2 0.12 1 0.02 0.002 189 0 189 1411
262 1998 1998 4 4 0.33 2 0.23 0.019 2169 0 2169 16225
262 1998 1998 4 11 0.07 7 0.00 0.000 0 0 0 0
262 1998 1998 4 12 1.64 1 1.54 0.128 14523 0 14523 108635 262 1998 1998 4 14 0.05 2 0.00 0.000 0 0 0 0
262 1998 1998 5 2 0.15 18 0.05 0.004 472 0 472 3527
262 1998 1998 5 3 0.97 1 0.87 0.073 8205 0 8205 61371
262 1998 1998 5 4 0.07 1 0.00 0.000 0 0 0 0
262 1998 1998 5 5 0.42 1 0.32 0.027 3018 0 3018 22573
262 1998 1998 5 6 0.10 1 0.00 0.000 0 0 0 0
262 1999 1998 9 5 0.75 30 0.65 0.054 6130 0 6130 45852
262 1999 1998 11 8 0.45 34 0.35 0.029 3301 0 3301 24690 262 1999 1998 11 28 1.25 20 1.15 0.096 10845 0 10845 81123 262 1999 1998 12 1 0.75 4 0.65 0.054 6130 0 6130 45852
262 1999 1998 12 6 0.20 5 0.10 0.008 943 0 943 7054
262 1999 1999 1 20 0.65 45 0.55 0.046 5187 0 5187 38798 262 1999 1999 1 21 0.07 1 0.00 0.000 0 0 0 0
262 1999 1999 1 26 0.22 5 0.12 0.010 1132 0 1132 8465
262 1999 1999 1 27 0.15 1 0.05 0.004 472 0 472 3527
26 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 1999 1999 1 31 0.67 4 0.57 0.048 5376 0 5376 40209
262 1999 1999 2 9 0.42 9 0.32 0.027 3018 0 3018 22573
262 1999 1999 2 10 0.30 1 0.20 0.017 1886 0 1886 14108
262 1999 1999 3 9 0.10 30 0.00 0.000 0 0 0 0
262 1999 1999 3 11 0.35 2 0.25 0.021 2358 0 2358 17635
262 1999 1999 3 15 1.97 4 1.87 0.156 17635 0 17635 131913 262 1999 1999 3 16 0.55 1 0.45 0.038 4244 0 4244 31744
262 1999 1999 3 17 0.02 1 0.00 0.000 0 0 0 0
262 1999 1999 3 19 0.09 2 0.00 0.000 0 0 0 0
262 1999 1999 3 20 1.01 1 0.91 0.076 8582 0 8582 64193
262 1999 1999 3 21 0.34 1 0.24 0.020 2263 0 2263 16930
262 1999 1999 3 23 0.13 2 0.03 0.003 283 0 283 2116
262 1999 1999 3 24 0.03 1 0.00 0.000 0 0 0 0
262 1999 1999 3 25 1.70 1 1.60 0.133 15089 0 15089 112867 262 1999 1999 3 26 0.64 1 0.54 0.045 5093 0 5093 38093
262 1999 1999 3 27 0.01 1 0.00 0.000 0 0 0 0
262 1999 1999 4 6 0.54 10 0.44 0.037 4150 0 4150 31038
262 1999 1999 4 7 0.39 1 0.29 0.024 2735 0 2735 20457
262 1999 1999 4 8 0.03 1 0.00 0.000 0 0 0 0
262 1999 1999 4 9 0.18 1 0.08 0.007 754 0 754 5643
262 1999 1999 4 11 0.48 2 0.38 0.032 3584 0 3584 26806
262 1999 1999 4 12 1.24 1 1.14 0.095 10751 0 10751 80418 262 2000 1999 11 8 1.30 26 1.20 0.100 11317 0 11317 84650 262 2000 1999 11 17 0.02 9 0.00 0.000 0 0 0 0
262 2000 1999 11 20 0.30 3 0.20 0.017 1886 0 1886 14108 262 2000 2000 1 17 0.02 28 0.00 0.000 0 0 0 0
262 2000 2000 1 18 0.01 1 0.00 0.000 0 0 0 0
262 2000 2000 1 24 0.01 6 0.00 0.000 0 0 0 0
262 2000 2000 1 25 1.00 1 0.90 0.075 8488 0 8488 63488
262 2000 2000 1 26 0.02 1 0.00 0.000 0 0 0 0
262 2000 2000 1 30 0.00 4 0.00 0.000 0 0 0 0
262 2000 2000 1 31 0.40 1 0.30 0.025 2829 0 2829 21163
262 2000 2000 2 4 0.40 4 0.30 0.025 2829 0 2829 21163
262 2000 2000 2 10 0.80 6 0.70 0.058 6602 0 6602 49379
262 2000 2000 2 11 0.30 1 0.20 0.017 1886 0 1886 14108
262 2000 2000 2 12 1.10 1 1.00 0.083 9431 0 9431 70542
262 2000 2000 2 13 0.67 1 0.57 0.048 5376 0 5376 40209
262 2000 2000 2 14 1.53 1 1.43 0.119 13486 0 13486 100875 262 2000 2000 2 15 1.00 1 0.90 0.075 8488 0 8488 63488
262 2000 2000 2 16 0.04 1 0.00 0.000 0 0 0 0
262 2000 2000 2 17 0.04 1 0.00 0.000 0 0 0 0
262 2000 2000 2 20 0.26 3 0.16 0.013 1509 0 1509 11287
262 2000 2000 2 21 1.45 1 1.35 0.113 12731 0 12731 95232 262 2000 2000 2 22 0.79 1 0.69 0.058 6507 0 6507 48674
262 2000 2000 2 23 1.64 1 1.54 0.128 14523 0 14523 108635 262 2000 2000 2 24 0.08 1 0.00 0.000 0 0 0 0
262 2000 2000 2 27 0.64 3 0.54 0.045 5093 0 5093 38093
262 2000 2000 2 28 0.46 1 0.36 0.030 3395 0 3395 25395
262 2000 2000 2 29 0.01 1 0.00 0.000 0 0 0 0
27 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2000 2000 3 1 0.01 3 0.00 0.000 0 0 0 0
262 2000 2000 3 3 0.17 2 0.07 0.006 660 0 660 4938
262 2000 2000 3 4 0.32 1 0.22 0.018 2075 0 2075 15519
262 2000 2000 3 5 0.85 1 0.75 0.063 7073 0 7073 52906
262 2000 2000 3 6 0.66 1 0.56 0.047 5281 0 5281 39503
262 2000 2000 3 8 0.83 2 0.73 0.061 6884 0 6884 51496
262 2000 2000 3 9 0.04 1 0.00 0.000 0 0 0 0
262 2000 2000 4 15 0.16 37 0.06 0.005 566 0 566 4233
262 2000 2000 4 16 0.01 1 0.00 0.000 0 0 0 0
262 2000 2000 4 17 4.55 1 4.45 0.371 41967 0 41967 313912 262 2000 2000 4 18 1.51 1 1.41 0.118 13297 0 13297 99464 262 2000 2000 4 19 0.03 1 0.00 0.000 0 0 0 0
262 2000 2000 4 20 0.01 1 0.00 0.000 0 0 0 0
262 2000 2000 5 23 0.01 33 0.00 0.000 0 0 0 0
262 2000 2000 6 17 0.07 25 0.00 0.000 0 0 0 0
262 2000 2000 6 18 0.18 1 0.08 0.007 754 0 754 5643
262 2000 2000 6 24 0.05 6 0.00 0.000 0 0 0 0
262 2001 2000 9 16 0.01 23 0.00 0.000 0 0 0 0
262 2001 2000 10 12 0.11 27 0.01 0.001 94 0 94 705
262 2001 2000 10 13 0.01 1 0.00 0.000 0 0 0 0
262 2001 2000 10 26 0.11 13 0.01 0.001 94 0 94 705
262 2001 2000 10 27 1.27 1 1.17 0.098 11034 0 11034 82534 262 2001 2000 10 28 0.03 1 0.00 0.000 0 0 0 0
262 2001 2000 10 29 1.33 1 1.23 0.103 11600 0 11600 86767 262 2001 2000 10 30 0.17 1 0.07 0.006 660 0 660 4938
262 2001 2000 12 7 0.10 8 0.00 0.000 0 0 0 0
262 2001 2001 1 8 0.73 32 0.63 0.053 5941 0 5941 44441
262 2001 2001 1 9 0.13 1 0.03 0.003 283 0 283 2116
262 2001 2001 1 11 5.09 2 4.99 0.416 47059 0 47059 352004 262 2001 2001 1 12 1.92 1 1.82 0.152 17164 0 17164 128386 262 2001 2001 1 13 0.15 1 0.05 0.004 472 0 472 3527
262 2001 2001 1 24 1.01 11 0.91 0.076 8582 0 8582 64193 262 2001 2001 1 25 0.03 1 0.00 0.000 0 0 0 0
262 2001 2001 1 26 0.91 1 0.81 0.068 7639 0 7639 57139
262 2001 2001 1 27 0.17 1 0.07 0.006 660 0 660 4938
262 2001 2001 2 10 0.72 14 0.62 0.052 5847 0 5847 43736 262 2001 2001 2 11 0.15 1 0.05 0.004 472 0 472 3527
262 2001 2001 2 12 1.24 1 1.14 0.095 10751 0 10751 80418 262 2001 2001 2 13 1.54 1 1.44 0.120 13580 0 13580 101580 262 2001 2001 2 14 0.59 1 0.49 0.041 4621 0 4621 34566
262 2001 2001 2 15 0.01 1 0.00 0.000 0 0 0 0
262 2001 2001 2 18 0.12 3 0.02 0.002 189 0 189 1411
262 2001 2001 2 19 0.23 1 0.13 0.011 1226 0 1226 9170
262 2001 2001 2 20 1.28 1 1.18 0.098 11128 0 11128 83239 262 2001 2001 2 21 0.08 1 0.00 0.000 0 0 0 0
262 2001 2001 2 23 0.24 2 0.14 0.012 1320 0 1320 9876
262 2001 2001 2 24 0.23 1 0.13 0.011 1226 0 1226 9170
262 2001 2001 2 25 1.03 1 0.93 0.078 8771 0 8771 65604
262 2001 2001 2 26 0.42 1 0.32 0.027 3018 0 3018 22573
28 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2001 2001 2 27 0.03 1 0.00 0.000 0 0 0 0
262 2001 2001 2 28 0.31 1 0.21 0.018 1980 0 1980 14814
262 2001 2001 3 4 0.61 7 0.51 0.043 4810 0 4810 35976
262 2001 2001 3 5 7.93 1 7.83 0.653 73843 0 73843 552343 yes 262 2001 2001 3 6 3.94 1 3.84 0.320 36214 0 36214 270881 262 2001 2001 3 7 0.55 1 0.45 0.038 4244 0 4244 31744
262 2001 2001 3 10 0.04 3 0.00 0.000 0 0 0 0
262 2001 2001 4 1 0.01 22 0.00 0.000 0 0 0 0
262 2001 2001 4 7 1.47 6 1.37 0.114 12920 0 12920 96642 262 2001 2001 4 8 0.04 1 0.00 0.000 0 0 0 0
262 2001 2001 4 10 0.14 2 0.04 0.003 377 0 377 2822
262 2001 2001 4 21 0.98 11 0.88 0.073 8299 0 8299 62077 262 2002 2001 9 8 0.01 17 0.00 0.000 0 0 0 0
262 2002 2001 10 30 0.11 53 0.01 0.001 94 0 94 705
262 2002 2001 10 31 0.62 1 0.52 0.043 4904 0 4904 36682 262 2002 2001 11 11 1.65 11 1.55 0.129 14618 0 14618 109340 262 2002 2001 11 12 0.06 1 0.00 0.000 0 0 0 0
262 2002 2001 11 13 1.26 1 1.16 0.097 10940 0 10940 81829 262 2002 2001 11 24 0.22 11 0.12 0.010 1132 0 1132 8465 262 2002 2001 11 25 2.37 1 2.27 0.189 21408 0 21408 160130 262 2002 2001 11 29 1.25 4 1.15 0.096 10845 0 10845 81123 262 2002 2001 11 30 0.02 1 0.00 0.000 0 0 0 0
262 2002 2001 12 3 1.28 4 1.18 0.098 11128 0 11128 83239 262 2002 2001 12 10 0.23 7 0.13 0.011 1226 0 1226 9170
262 2002 2001 12 14 0.04 4 0.00 0.000 0 0 0 0
262 2002 2001 12 15 0.10 1 0.00 0.000 0 0 0 0
262 2002 2001 12 20 0.01 5 0.00 0.000 0 0 0 0
262 2002 2001 12 21 0.38 1 0.28 0.023 2641 0 2641 19752 262 2002 2001 12 29 0.37 8 0.27 0.023 2546 0 2546 19046 262 2002 2001 12 30 0.45 1 0.35 0.029 3301 0 3301 24690 262 2002 2001 12 31 0.28 1 0.18 0.015 1698 0 1698 12698 262 2002 2002 1 3 0.38 3 0.28 0.023 2641 0 2641 19752
262 2002 2002 1 12 0.01 9 0.00 0.000 0 0 0 0
262 2002 2002 1 27 0.08 15 0.00 0.000 0 0 0 0
262 2002 2002 1 28 0.80 1 0.70 0.058 6602 0 6602 49379
262 2002 2002 1 29 0.05 1 0.00 0.000 0 0 0 0
262 2002 2002 2 17 0.95 19 0.85 0.071 8016 0 8016 59961 262 2002 2002 2 18 0.01 1 0.00 0.000 0 0 0 0
262 2002 2002 3 7 0.30 20 0.20 0.017 1886 0 1886 14108
262 2002 2002 3 17 0.01 10 0.00 0.000 0 0 0 0
262 2002 2002 3 18 0.26 1 0.16 0.013 1509 0 1509 11287
262 2002 2002 3 23 0.09 5 0.00 0.000 0 0 0 0
262 2002 2002 3 24 0.07 1 0.00 0.000 0 0 0 0
262 2002 2002 4 3 0.01 10 0.00 0.000 0 0 0 0
262 2002 2002 5 20 0.14 47 0.04 0.003 377 0 377 2822
262 2002 2002 7 13 0.02 24 0.00 0.000 0 0 0 0
262 2002 2002 8 12 0.01 30 0.00 0.000 0 0 0 0
262 2003 2002 9 29 0.24 48 0.14 0.012 1320 0 1320 9876
262 2003 2002 11 7 0.18 9 0.08 0.007 754 0 754 5643
29 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2003 2002 11 8 5.40 1 5.30 0.442 49983 0 49983 373872 262 2003 2002 11 9 2.01 1 1.91 0.159 18013 0 18013 134735 262 2003 2002 11 10 0.09 1 0.00 0.000 0 0 0 0
262 2003 2002 11 22 0.01 12 0.00 0.000 0 0 0 0
262 2003 2002 11 30 0.08 8 0.00 0.000 0 0 0 0
262 2003 2002 12 7 0.03 8 0.00 0.000 0 0 0 0
262 2003 2002 12 15 1.01 8 0.91 0.076 8582 0 8582 64193 262 2003 2002 12 17 2.36 2 2.26 0.188 21313 0 21313 159425 262 2003 2002 12 18 0.09 1 0.00 0.000 0 0 0 0
262 2003 2002 12 19 0.01 1 0.00 0.000 0 0 0 0
262 2003 2002 12 20 3.03 1 2.93 0.244 27632 0 27632 206688 262 2003 2002 12 21 0.12 1 0.02 0.002 189 0 189 1411
262 2003 2002 12 22 1.25 1 1.15 0.096 10845 0 10845 81123 262 2003 2002 12 29 0.25 7 0.15 0.013 1415 0 1415 10581 262 2003 2002 12 31 0.06 2 0.00 0.000 0 0 0 0
262 2003 2003 1 1 0.06 1 0.00 0.000 0 0 0 0
262 2003 2003 2 11 0.49 41 0.39 0.033 3678 0 3678 27511 262 2003 2003 2 12 0.79 1 0.69 0.058 6507 0 6507 48674
262 2003 2003 2 13 1.90 1 1.80 0.150 16975 0 16975 126975 262 2003 2003 2 14 0.48 1 0.38 0.032 3584 0 3584 26806
262 2003 2003 2 16 0.02 2 0.00 0.000 0 0 0 0
262 2003 2003 2 17 0.02 1 0.00 0.000 0 0 0 0
262 2003 2003 2 25 0.81 8 0.71 0.059 6696 0 6696 50085
262 2003 2003 2 27 0.16 2 0.06 0.005 566 0 566 4233
262 2003 2003 2 28 0.01 1 0.00 0.000 0 0 0 0
262 2003 2003 3 5 0.02 8 0.00 0.000 0 0 0 0
262 2003 2003 3 15 4.62 10 4.52 0.377 42627 0 42627 318850 262 2003 2003 3 16 0.91 1 0.81 0.068 7639 0 7639 57139
262 2003 2003 4 3 0.08 18 0.00 0.000 0 0 0 0
262 2003 2003 4 5 0.01 2 0.00 0.000 0 0 0 0
262 2003 2003 4 13 0.93 8 0.83 0.069 7828 0 7828 58550
262 2003 2003 4 14 1.37 1 1.27 0.106 11977 0 11977 89588 262 2003 2003 4 15 0.01 1 0.00 0.000 0 0 0 0
262 2003 2003 4 28 0.18 13 0.08 0.007 754 0 754 5643
262 2003 2003 4 29 0.04 1 0.00 0.000 0 0 0 0
262 2003 2003 5 3 2.36 4 2.26 0.188 21313 0 21313 159425 262 2003 2003 5 4 0.10 1 0.00 0.000 0 0 0 0
262 2003 2003 5 7 0.04 3 0.00 0.000 0 0 0 0
262 2003 2003 5 8 0.01 1 0.00 0.000 0 0 0 0
262 2003 2003 5 24 0.01 16 0.00 0.000 0 0 0 0
262 2003 2003 6 3 0.02 10 0.00 0.000 0 0 0 0
262 2003 2003 6 4 0.04 1 0.00 0.000 0 0 0 0
262 2003 2003 6 6 0.01 2 0.00 0.000 0 0 0 0
262 2003 2003 6 10 0.08 4 0.00 0.000 0 0 0 0
262 2004 2003 11 1 0.90 E312 22 0.80 0.067 7545 0 7545 56434 262 2004 2003 11 4 0.10 E312 3 0.00 0.000 0 0 0 0
262 2004 2003 11 9 1.85 E312 5 1.75 0.146 16504 0 16504 123448 262 2004 2003 11 12 0.05 E312 3 0.00 0.000 0 0 0 0
262 2004 2003 11 13 0.10 E312 1 0.00 0.000 0 0 0 0
30 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2004 2003 11 16 0.03 E312 3 0.00 0.000 0 0 0 0
262 2004 2003 12 7 0.01 E312 22 0.00 0.000 0 0 0 0
262 2004 2003 12 8 0.03 E312 1 0.00 0.000 0 0 0 0
262 2004 2003 12 10 0.01 E312 2 0.00 0.000 0 0 0 0
262 2004 2003 12 11 0.06 E312 1 0.00 0.000 0 0 0 0
262 2004 2003 12 12 0.06 E312 1 0.00 0.000 0 0 0 0
262 2004 2003 12 15 0.18 E312 3 0.08 0.007 754 0 754 5643 262 2004 2003 12 21 0.10 E312 6 0.00 0.000 0 0 0 0
262 2004 2003 12 23 0.23 2 0.13 0.011 1226 0 1226 9170
262 2004 2003 12 24 0.39 1 0.29 0.024 2735 0 2735 20457 262 2004 2003 12 25 0.95 1 0.85 0.071 8016 0 8016 59961 262 2004 2003 12 26 1.15 1 1.05 0.088 9902 0 9902 74069 262 2004 2003 12 30 0.09 4 0.00 0.000 0 0 0 0
262 2004 2004 1 2 0.69 3 0.59 0.049 5564 0 5564 41620
262 2004 2004 1 3 0.14 1 0.04 0.003 377 0 377 2822
262 2004 2004 1 25 0.01 22 0.00 0.000 0 0 0 0
262 2004 2004 1 28 0.06 3 0.00 0.000 0 0 0 0
262 2004 2004 2 3 1.26 6 1.16 0.097 10940 0 10940 81829 262 2004 2004 2 4 0.02 1 0.00 0.000 0 0 0 0
262 2004 2004 2 18 0.36 14 0.26 0.022 2452 0 2452 18341 262 2004 2004 2 19 0.48 1 0.38 0.032 3584 0 3584 26806
262 2004 2004 2 21 0.09 2 0.00 0.000 0 0 0 0
262 2004 2004 2 22 0.23 1 0.13 0.011 1226 0 1226 9170
262 2004 2004 2 23 1.10 1 1.00 0.083 9431 0 9431 70542
262 2004 2004 2 26 4.94 3 4.84 0.403 45645 0 45645 341423 262 2004 2004 2 27 0.02 1 0.00 0.000 0 0 0 0
262 2004 2004 3 2 0.64 6 0.54 0.045 5093 0 5093 38093
262 2004 2004 3 16 0.01 14 0.00 0.000 0 0 0 0
262 2004 2004 5 6 0.01 21 0.00 0.000 0 0 0 0
262 2004 2004 6 19 0.01 44 0.00 0.000 0 0 0 0
262 2005 2004 10 17 0.96 29 0.86 0.072 8110 0 8110 60666 262 2005 2004 10 18 0.34 1 0.24 0.020 2263 0 2263 16930 262 2005 2004 10 19 0.07 1 0.00 0.000 0 0 0 0
262 2005 2004 10 20 2.22 1 2.12 0.177 19993 0 19993 149549 262 2005 2004 10 22 0.01 2 0.00 0.000 0 0 0 0
262 2005 2004 10 27 2.23 5 2.13 0.178 20087 0 20087 150254 262 2005 2004 11 5 0.62 9 0.52 0.043 4904 0 4904 36682
262 2005 2004 11 8 0.21 3 0.11 0.009 1037 0 1037 7760
262 2005 2004 11 18 0.01 10 0.00 0.000 0 0 0 0
262 2005 2004 11 28 0.01 10 0.00 0.000 0 0 0 0
262 2005 2004 12 5 0.06 8 0.00 0.000 0 0 0 0
262 2005 2004 12 6 0.32 1 0.22 0.018 2075 0 2075 15519
262 2005 2004 12 7 0.12 1 0.02 0.002 189 0 189 1411
262 2005 2004 12 8 0.70 1 0.60 0.050 5658 0 5658 42325
262 2005 2004 12 27 1.36 19 1.26 0.105 11883 0 11883 88883 262 2005 2004 12 28 4.83 1 4.73 0.394 44607 0 44607 333663 262 2005 2004 12 29 0.82 1 0.72 0.060 6790 0 6790 50790 262 2005 2004 12 30 0.33 1 0.23 0.019 2169 0 2169 16225 262 2005 2004 12 31 2.04 1 1.94 0.162 18296 0 18296 136851 31 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2005 2005 1 1 0.04 1 0.00 0.000 0 0 0 0
262 2005 2005 1 2 0.22 1 0.12 0.010 1132 0 1132 8465
262 2005 2005 1 3 2.24 1 2.14 0.178 20182 0 20182 150960 262 2005 2005 1 4 0.91 1 0.81 0.068 7639 0 7639 57139
262 2005 2005 1 7 1.79 3 1.69 0.141 15938 0 15938 119216 262 2005 2005 1 8 2.15 1 2.05 0.171 19333 0 19333 144611 262 2005 2005 1 9 5.42 1 5.32 0.443 50172 0 50172 375283 262 2005 2005 1 10 3.93 1 3.83 0.319 36120 0 36120 270176 262 2005 2005 1 11 0.85 1 0.75 0.063 7073 0 7073 52906
262 2005 2005 1 12 0.08 1 0.00 0.000 0 0 0 0
262 2005 2005 1 21 0.01 9 0.00 0.000 0 0 0 0
262 2005 2005 1 27 0.28 6 0.18 0.015 1698 0 1698 12698
262 2005 2005 1 28 0.39 1 0.29 0.024 2735 0 2735 20457
262 2005 2005 1 29 0.12 1 0.02 0.002 189 0 189 1411
262 2005 2005 2 11 0.35 13 0.25 0.021 2358 0 2358 17635 262 2005 2005 2 12 0.06 1 0.00 0.000 0 0 0 0
262 2005 2005 2 16 0.46 4 0.36 0.030 3395 0 3395 25395
262 2005 2005 2 17 0.01 1 0.00 0.000 0 0 0 0
262 2005 2005 2 18 1.13 1 1.03 0.086 9714 0 9714 72658
262 2005 2005 2 19 2.43 1 2.33 0.194 21974 0 21974 164363 262 2005 2005 2 20 0.70 1 0.60 0.050 5658 0 5658 42325
262 2005 2005 2 21 1.54 1 1.44 0.120 13580 0 13580 101580 262 2005 2005 2 22 1.02 1 0.92 0.077 8676 0 8676 64899
262 2005 2005 2 23 2.71 1 2.61 0.218 24614 0 24614 184114 262 2005 2005 2 28 0.66 5 0.56 0.047 5281 0 5281 39503
262 2005 2005 3 3 0.24 6 0.14 0.012 1320 0 1320 9876
262 2005 2005 3 4 0.98 1 0.88 0.073 8299 0 8299 62077
262 2005 2005 3 5 0.25 1 0.15 0.013 1415 0 1415 10581
262 2005 2005 3 10 0.01 5 0.00 0.000 0 0 0 0
262 2005 2005 3 18 0.01 8 0.00 0.000 0 0 0 0
262 2005 2005 3 19 0.57 1 0.47 0.039 4432 0 4432 33155
262 2005 2005 3 20 0.09 1 0.00 0.000 0 0 0 0
262 2005 2005 3 22 0.31 2 0.21 0.018 1980 0 1980 14814
262 2005 2005 3 23 4.92 1 4.82 0.402 45456 0 45456 340012 262 2005 2005 3 28 0.11 5 0.01 0.001 94 0 94 705
262 2005 2005 4 4 0.03 7 0.00 0.000 0 0 0 0
262 2005 2005 4 9 0.06 5 0.00 0.000 0 0 0 0
262 2005 2005 4 28 1.15 19 1.05 0.088 9902 0 9902 74069 262 2005 2005 4 29 0.03 1 0.00 0.000 0 0 0 0
262 2005 2005 5 6 1.03 7 0.93 0.078 8771 0 8771 65604
262 2005 2005 5 9 0.38 3 0.28 0.023 2641 0 2641 19752
262 2006 2005 9 26 0.04 48 0.00 0.000 0 0 0 0
262 2006 2005 10 18 0.87 23 0.77 0.064 7225 0 7225 54045 262 2006 2005 10 22 0.04 4 0.00 0.000 0 0 0 0
262 2006 2005 10 23 0.04 1 0.00 0.000 0 0 0 0
262 2006 2005 10 24 0.04 1 0.00 0.000 0 0 0 0
262 2006 2005 11 9 1.89 16 1.79 0.149 16879 0 16879 126253 262 2006 2005 11 10 0.04 1 0.00 0.000 0 0 0 0
262 2006 2005 12 2 0.35 23 0.25 0.021 2399 0 2399 17941 32 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2006 2005 12 3 0.16 1 0.06 0.005 542 0 542 4055
262 2006 2005 12 19 0.04 16 0.00 0.000 0 0 0 0
262 2006 2005 12 26 0.12 7 0.02 0.002 171 0 171 1278
262 2006 2005 12 27 0.04 1 0.00 0.000 0 0 0 0
262 2006 2005 12 31 0.16 4 0.06 0.005 542 0 542 4055
262 2006 2006 1 1 1.57 1 1.47 0.123 13908 0 13908 104035 262 2006 2006 1 2 2.56 1 2.46 0.205 23191 0 23191 173466 262 2006 2006 1 3 0.35 1 0.25 0.021 2399 0 2399 17941
262 2006 2006 1 14 0.29 11 0.19 0.016 1792 0 1792 13403 262 2006 2006 1 15 0.07 1 0.00 0.000 0 0 0 0
262 2006 2006 1 18 0.01 3 0.00 0.000 0 0 0 0
262 2006 2006 1 19 0.01 1 0.00 0.000 0 0 0 0
262 2006 2006 2 18 0.58 30 0.48 0.040 4527 0 4527 33860 262 2006 2006 2 19 0.34 1 0.24 0.020 2263 0 2263 16930
262 2006 2006 2 20 0.04 1 0.00 0.000 0 0 0 0
262 2006 2006 2 27 0.04 7 0.00 0.000 0 0 0 0
262 2006 2006 2 28 3.04 1 2.94 0.245 27726 0 27726 207393 262 2006 2006 3 3 0.75 6 0.65 0.054 6130 0 6130 45852
262 2006 2006 3 4 0.02 1 0.00 0.000 0 0 0 0
262 2006 2006 3 6 0.27 2 0.17 0.014 1603 0 1603 11992
262 2006 2006 3 7 0.28 1 0.18 0.015 1698 0 1698 12698
262 2006 2006 3 10 0.26 3 0.16 0.013 1509 0 1509 11287
262 2006 2006 3 11 0.32 1 0.22 0.018 2075 0 2075 15519
262 2006 2006 3 12 0.13 1 0.03 0.003 283 0 283 2116
262 2006 2006 3 13 0.05 1 0.00 0.000 0 0 0 0
262 2006 2006 3 15 0.01 2 0.00 0.000 0 0 0 0
262 2006 2006 3 17 0.03 2 0.00 0.000 0 0 0 0
262 2006 2006 3 18 0.24 1 0.14 0.012 1320 0 1320 9876
262 2006 2006 3 21 0.32 3 0.22 0.018 2075 0 2075 15519
262 2006 2006 3 26 0.19 5 0.09 0.008 849 0 849 6349
262 2006 2006 3 28 0.86 2 0.76 0.063 7167 0 7167 53612
262 2006 2006 3 29 1.38 1 1.28 0.107 12071 0 12071 90294 262 2006 2006 3 31 0.02 2 0.00 0.000 0 0 0 0
262 2006 2006 4 1 0.34 1 0.24 0.020 2263 0 2263 16930
262 2006 2006 4 3 0.31 2 0.21 0.018 1980 0 1980 14814
262 2006 2006 4 4 2.82 1 2.72 0.227 25652 0 25652 191874 262 2006 2006 4 5 0.29 1 0.19 0.016 1792 0 1792 13403
262 2006 2006 4 6 0.05 1 0.00 0.000 0 0 0 0
262 2006 2006 4 8 0.02 2 0.00 0.000 0 0 0 0
262 2006 2006 4 11 0.12 3 0.02 0.002 189 0 189 1411
262 2006 2006 4 14 0.12 3 0.02 0.002 189 0 189 1411
262 2006 2006 4 15 0.30 1 0.20 0.017 1886 0 1886 14108
262 2006 2006 4 17 0.01 2 0.00 0.000 0 0 0 0
262 2006 2006 4 26 0.09 9 0.00 0.000 0 0 0 0
262 2006 2006 5 3 0.01 7 0.00 0.000 0 0 0 0
262 2006 2006 5 4 0.01 1 0.00 0.000 0 0 0 0
262 2006 2006 5 13 0.01 9 0.00 0.000 0 0 0 0
262 2006 2006 5 22 1.64 9 1.54 0.128 14523 0 14523 108635 262 2006 2006 6 1 0.12 10 0.02 0.002 189 0 189 1411
33 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2006 2006 8 4 0.03 34 0.00 0.000 0 0 0 0
262 2006 2006 8 5 0.12 1 0.02 0.002 189 0 189 1411
262 2007 2006 9 8 0.01 34 0.00 0.000 0 0 0 0
262 2007 2006 10 2 0.04 25 0.00 0.000 0 0 0 0
262 2007 2006 11 27 0.32 56 0.22 0.018 2075 0 2075 15519 262 2007 2006 12 9 0.21 13 0.11 0.009 1037 0 1037 7760
262 2007 2006 12 10 0.72 1 0.62 0.052 5847 0 5847 43736 262 2007 2006 12 11 0.12 1 0.02 0.002 189 0 189 1411
262 2007 2006 12 12 0.01 1 0.00 0.000 0 0 0 0
262 2007 2006 12 17 0.06 5 0.00 0.000 0 0 0 0
262 2007 2006 12 22 0.03 5 0.00 0.000 0 0 0 0
262 2007 2006 12 27 0.44 5 0.34 0.028 3206 0 3206 23984 262 2007 2006 12 28 0.07 1 0.00 0.000 0 0 0 0
262 2007 2007 1 18 0.01 21 0.00 0.000 0 0 0 0
262 2007 2007 1 27 0.48 9 0.38 0.032 3584 0 3584 26806
262 2007 2007 1 28 0.87 1 0.77 0.064 7262 0 7262 54317
262 2007 2007 1 29 1.48 1 1.38 0.115 13014 0 13014 97348 262 2007 2007 1 31 0.20 2 0.10 0.008 943 0 943 7054
262 2007 2007 2 6 0.01 6 0.00 0.000 0 0 0 0
262 2007 2007 2 11 1.64 5 1.54 0.128 14523 0 14523 108635 262 2007 2007 2 12 0.04 1 0.00 0.000 0 0 0 0
262 2007 2007 2 13 0.03 1 0.00 0.000 0 0 0 0
262 2007 2007 2 15 0.02 2 0.00 0.000 0 0 0 0
262 2007 2007 2 17 0.04 2 0.00 0.000 0 0 0 0
262 2007 2007 2 19 0.47 2 0.37 0.031 3489 0 3489 26101
262 2007 2007 2 20 0.02 1 0.00 0.000 0 0 0 0
262 2007 2007 2 21 0.02 1 0.00 0.000 0 0 0 0
262 2007 2007 2 22 0.06 1 0.00 0.000 0 0 0 0
262 2007 2007 2 23 1.11 1 1.01 0.084 9525 0 9525 71247
262 2007 2007 2 25 0.03 2 0.00 0.000 0 0 0 0
262 2007 2007 2 27 0.10 2 0.00 0.000 0 0 0 0
262 2007 2007 2 28 0.19 1 0.09 0.008 849 0 849 6349
262 2007 2007 3 17 0.01 20 0.00 0.000 0 0 0 0
262 2007 2007 3 27 0.06 10 0.00 0.000 0 0 0 0
262 2007 2007 4 20 0.76 24 0.66 0.055 6224 0 6224 46558 262 2007 2007 4 21 0.22 1 0.12 0.010 1132 0 1132 8465
262 2007 2007 4 23 0.33 2 0.23 0.019 2169 0 2169 16225
262 2007 2007 7 11 0.01 18 0.00 0.000 0 0 0 0
262 2008 2007 9 4 0.04 24 0.00 0.000 0 0 0 0
262 2008 2007 9 22 0.08 18 0.00 0.000 0 0 0 0
262 2008 2007 9 23 0.16 1 0.06 0.005 542 0 542 4055
262 2008 2007 10 13 0.39 21 0.29 0.024 2770 0 2770 20718 262 2008 2007 10 28 0.04 15 0.00 0.000 0 0 0 0
262 2008 2007 11 4 0.04 7 0.00 0.000 0 0 0 0
262 2008 2007 12 7 0.35 34 0.25 0.021 2399 0 2399 17941 262 2008 2007 12 8 0.04 1 0.00 0.000 0 0 0 0
262 2008 2007 12 18 0.55 10 0.45 0.038 4255 0 4255 31827 262 2008 2007 12 19 1.42 1 1.32 0.110 12423 0 12423 92926 262 2008 2007 12 20 0.04 1 0.00 0.000 0 0 0 0
34 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2008 2007 12 21 0.04 1 0.00 0.000 0 0 0 0
262 2008 2008 1 5 2.76 15 2.66 0.221 25047 0 25047 187352 262 2008 2008 1 6 0.39 1 0.29 0.024 2770 0 2770 20718
262 2008 2008 1 7 0.55 1 0.45 0.038 4255 0 4255 31827
262 2008 2008 1 22 0.08 15 0.00 0.000 0 0 0 0
262 2008 2008 1 23 2.40 1 2.30 0.192 21706 0 21706 162357 262 2008 2008 1 24 2.01 1 1.91 0.159 17993 0 17993 134585 262 2008 2008 1 25 0.58 E 1 0.48 0.040 4527 0 4527 33860 262 2008 2008 1 27 2.63 E 2 2.53 0.211 23860 0 23860 178471 262 2008 2008 1 28 1.05 E 1 0.95 0.079 8959 0 8959 67015 262 2008 2008 2 3 1.43 E 6 1.33 0.111 12543 0 12543 93821 262 2008 2008 2 4 0.12 1 0.02 0.002 171 0 171 1278
262 2008 2008 2 20 0.20 16 0.10 0.008 913 0 913 6832
262 2008 2008 2 22 0.28 2 0.18 0.015 1656 0 1656 12386
262 2008 2008 2 23 0.12 1 0.02 0.002 171 0 171 1278
262 2008 2008 2 24 1.26 1 1.16 0.097 10938 0 10938 81817 262 2008 2008 2 25 0.04 1 0.00 0.000 0 0 0 0
262 2008 2008 4 3 0.08 9 0.00 0.000 0 0 0 0
262 2009 2008 10 5 0.08 32 0.00 0.000 0 0 0 0
262 2009 2008 10 31 0.04 26 0.00 0.000 0 0 0 0
262 2009 2008 11 2 0.35 2 0.25 0.021 2399 0 2399 17941
262 2009 2008 11 4 0.63 2 0.53 0.044 4998 0 4998 37382
262 2009 2008 11 26 1.61 22 1.51 0.126 14280 0 14280 106812 262 2009 2008 11 27 0.47 1 0.37 0.031 3512 0 3512 26273 262 2009 2008 11 29 0.04 2 0.00 0.000 0 0 0 0
262 2009 2008 12 15 2.16 E 17 2.06 0.172 19427 0 19427 145316 262 2009 2008 12 16 0.12 1 0.02 0.002 171 0 171 1278
262 2009 2008 12 17 0.20 1 0.10 0.008 913 0 913 6832
262 2009 2008 12 22 0.31 5 0.21 0.018 2027 0 2027 15164 262 2009 2008 12 25 0.04 3 0.00 0.000 0 0 0 0
262 2009 2008 12 26 0.16 1 0.06 0.005 542 0 542 4055
262 2009 2009 1 22 0.12 27 0.02 0.002 171 0 171 1278
262 2009 2009 1 23 0.16 1 0.06 0.005 542 0 542 4055
262 2009 2009 1 24 1.10 E 1 1.00 0.083 9431 0 9431 70542 262 2009 2009 2 5 0.35 12 0.25 0.021 2399 0 2399 17941
262 2009 2009 2 6 0.63 1 0.53 0.044 4998 0 4998 37382
262 2009 2009 2 7 1.48 E 1 1.38 0.115 13014 0 13014 97348 262 2009 2009 2 9 0.24 2 0.14 0.011 1285 0 1285 9609
262 2009 2009 2 10 0.04 1 0.00 0.000 0 0 0 0
262 2009 2009 2 12 0.08 2 0.00 0.000 0 0 0 0
262 2009 2009 2 14 0.43 2 0.33 0.028 3141 0 3141 23495
262 2009 2009 2 16 1.10 2 1.00 0.084 9453 0 9453 70708
262 2009 2009 2 17 0.79 E 1 0.69 0.058 6507 0 6507 48674 262 2009 2009 2 22 0.08 5 0.00 0.000 0 0 0 0
262 2009 2009 2 23 0.04 1 0.00 0.000 0 0 0 0
262 2009 2009 3 4 0.55 12 0.45 0.038 4255 0 4255 31827
262 2009 2009 3 5 0.04 1 0.00 0.000 0 0 0 0
262 2009 2009 3 21 0.04 16 0.00 0.000 0 0 0 0
262 2009 2009 3 22 0.33 E 1 0.23 0.019 2169 0 2169 16225 35 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2009 2009 4 8 0.54 E 17 0.44 0.037 4150 0 4150 31038 262 2009 2009 6 5 0.59 27 0.49 0.041 4626 0 4626 34604
262 2009 2009 6 6 0.04 1 0.00 0.000 0 0 0 0
262 2010 2009 10 13 0.35 E389 38 0.25 0.021 2358 0 2358 17635 262 2010 2009 10 14 4.37 E389 1 4.27 0.356 40269 0 40269 301214 262 2010 2009 10 15 0.12 E389 1 0.02 0.002 189 0 189 1411 262 2010 2009 12 7 0.63 23 0.53 0.044 4998 0 4998 37382 262 2010 2009 12 8 0.67 1 0.57 0.047 5369 0 5369 40159
262 2010 2009 12 11 0.59 3 0.49 0.041 4626 0 4626 34604 262 2010 2009 12 12 0.43 1 0.33 0.028 3141 0 3141 23495 262 2010 2009 12 13 0.71 1 0.61 0.051 5740 0 5740 42936 262 2010 2009 12 31 0.08 18 0.00 0.000 0 0 0 0
262 2010 2010 1 13 0.39 13 0.29 0.024 2770 0 2770 20718 262 2010 2010 1 14 0.04 1 0.00 0.000 0 0 0 0
262 2010 2010 1 18 0.98 4 0.88 0.074 8339 0 8339 62377
262 2010 2010 1 19 1.14 1 1.04 0.087 9824 0 9824 73486
262 2010 2010 1 20 0.59 1 0.49 0.041 4626 0 4626 34604
262 2010 2010 1 21 1.85 1 1.75 0.146 16507 0 16507 123476 262 2010 2010 1 22 1.14 1 1.04 0.087 9824 0 9824 73486
262 2010 2010 1 23 0.47 1 0.37 0.031 3512 0 3512 26273
262 2010 2010 1 26 0.04 3 0.00 0.000 0 0 0 0
262 2010 2010 1 27 0.51 1 0.41 0.034 3884 0 3884 29050
262 2010 2010 2 5 1.14 9 1.04 0.087 9824 0 9824 73486
262 2010 2010 2 6 1.14 1 1.04 0.087 9824 0 9824 73486
262 2010 2010 2 7 0.24 1 0.14 0.011 1285 0 1285 9609
262 2010 2010 2 9 0.04 2 0.00 0.000 0 0 0 0
262 2010 2010 2 10 0.39 1 0.29 0.024 2770 0 2770 20718
262 2010 2010 2 20 0.12 10 0.02 0.002 171 0 171 1278
262 2010 2010 2 21 0.04 1 0.00 0.000 0 0 0 0
262 2010 2010 2 24 0.04 3 0.00 0.000 0 0 0 0
262 2010 2010 2 25 0.51 1 0.41 0.034 3884 0 3884 29050
262 2010 2010 2 27 1.22 2 1.12 0.093 10567 0 10567 79040 262 2010 2010 3 3 0.04 7 0.00 0.000 0 0 0 0
262 2010 2010 3 4 0.31 1 0.21 0.018 2027 0 2027 15164
262 2010 2010 3 7 0.16 3 0.06 0.005 542 0 542 4055
262 2010 2010 4 5 0.63 29 0.53 0.044 4998 0 4998 37382
262 2010 2010 4 6 0.04 1 0.00 0.000 0 0 0 0
262 2010 2010 4 12 1.18 6 1.08 0.090 10196 0 10196 76263 262 2010 2010 4 13 0.04 1 0.00 0.000 0 0 0 0
262 2010 2010 4 20 0.04 7 0.00 0.000 0 0 0 0
262 2010 2010 4 21 0.47 1 0.37 0.031 3512 0 3512 26273
262 2010 2010 4 22 0.20 1 0.10 0.008 913 0 913 6832
262 2010 2010 4 28 0.04 6 0.00 0.000 0 0 0 0
262 2010 2010 5 18 0.12 20 0.02 0.002 171 0 171 1278
262 2011 2010 10 6 1.18 19 1.08 0.090 10196 0 10196 76263 262 2011 2010 10 7 0.04 1 0.00 0.000 0 0 0 0
262 2011 2010 10 16 0.04 9 0.00 0.000 0 0 0 0
262 2011 2010 10 17 0.08 1 0.00 0.000 0 0 0 0
262 2011 2010 10 19 0.04 2 0.00 0.000 0 0 0 0
36 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2011 2010 10 20 0.12 1 0.02 0.002 171 0 171 1278
262 2011 2010 10 30 1.42 10 1.32 0.110 12423 0 12423 92926 262 2011 2010 11 8 0.20 9 0.10 0.008 913 0 913 6832
262 2011 2010 11 20 0.67 12 0.57 0.047 5369 0 5369 40159 262 2011 2010 11 21 0.28 1 0.18 0.015 1656 0 1656 12386 262 2011 2010 11 22 0.04 1 0.00 0.000 0 0 0 0
262 2011 2010 11 24 0.08 2 0.00 0.000 0 0 0 0
262 2011 2010 12 4 0.12 11 0.02 0.002 171 0 171 1278
262 2011 2010 12 6 0.71 2 0.61 0.051 5740 0 5740 42936
262 2011 2010 12 17 0.28 11 0.18 0.015 1656 0 1656 12386 262 2011 2010 12 18 1.06 1 0.96 0.080 9082 0 9082 67931 262 2011 2010 12 19 3.07 1 2.97 0.248 28017 0 28017 209570 262 2011 2010 12 20 2.72 1 2.62 0.218 24676 0 24676 184575 262 2011 2010 12 21 0.79 1 0.69 0.057 6483 0 6483 48491 262 2011 2010 12 22 0.75 1 0.65 0.054 6111 0 6111 45713 262 2011 2010 12 23 0.04 1 0.00 0.000 0 0 0 0
262 2011 2010 12 24 0.04 1 0.00 0.000 0 0 0 0
262 2011 2010 12 26 0.94 2 0.84 0.070 7968 0 7968 59599 262 2011 2010 12 29 0.83 3 0.73 0.061 6854 0 6854 51268 262 2011 2010 12 30 0.04 1 0.00 0.000 0 0 0 0
262 2011 2011 1 2 0.47 3 0.37 0.031 3512 0 3512 26273
262 2011 2011 1 3 0.59 1 0.49 0.041 4626 0 4626 34604
262 2011 2011 1 4 0.08 1 0.00 0.000 0 0 0 0
262 2011 2011 2 14 0.04 41 0.00 0.000 0 0 0 0
262 2011 2011 2 15 0.08 1 0.00 0.000 0 0 0 0
262 2011 2011 2 16 0.71 1 0.61 0.051 5753 0 5753 43031
262 2011 2011 2 17 0.04 1 0.00 0.000 0 0 0 0
262 2011 2011 2 18 2.32 1 2.22 0.185 20936 0 20936 156603 262 2011 2011 2 19 0.43 1 0.33 0.028 3112 0 3112 23279
262 2011 2011 2 25 0.75 6 0.65 0.054 6111 0 6111 45711
262 2011 2011 2 27 0.04 2 0.00 0.000 0 0 0 0
262 2011 2011 3 2 0.08 6 0.00 0.000 0 0 0 0
262 2011 2011 3 3 0.32 1 0.22 0.018 2075 0 2075 15519
262 2011 2011 3 19 0.17 16 0.07 0.006 660 0 660 4938
262 2011 2011 3 20 3.45 1 3.35 0.279 31593 0 31593 236315 262 2011 2011 3 21 0.93 1 0.83 0.069 7828 0 7828 58550
262 2011 2011 3 22 0.02 1 0.00 0.000 0 0 0 0
262 2011 2011 3 23 0.12 1 0.02 0.002 189 0 189 1411
262 2011 2011 3 24 0.56 1 0.46 0.038 4338 0 4338 32449
262 2011 2011 3 25 0.75 1 0.65 0.054 6130 0 6130 45852
262 2011 2011 3 27 0.09 2 0.00 0.000 0 0 0 0
262 2011 2011 4 3 0.04 7 0.00 0.000 0 0 0 0
262 2011 2011 4 4 0.01 1 0.00 0.000 0 0 0 0
262 2011 2011 4 8 0.03 4 0.00 0.000 0 0 0 0
262 2011 2011 5 15 0.05 37 0.00 0.000 0 0 0 0
262 2011 2011 5 16 0.01 1 0.00 0.000 0 0 0 0
262 2011 2011 5 17 0.44 1 0.34 0.028 3206 0 3206 23984
262 2011 2011 5 18 0.20 1 0.10 0.008 943 0 943 7054
262 2011 2011 5 19 0.02 1 0.00 0.000 0 0 0 0
37 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2011 2011 6 5 0.64 17 0.54 0.045 5093 0 5093 38093
262 2011 2011 6 6 0.56 1 0.46 0.038 4338 0 4338 32449
262 2011 2011 6 22 0.01 16 0.00 0.000 0 0 0 0
262 2012 2011 9 23 0.01 32 0.00 0.000 0 0 0 0
262 2012 2011 9 29 0.01 6 0.00 0.000 0 0 0 0
262 2012 2011 10 5 0.59 7 0.49 0.041 4621 0 4621 34566
262 2012 2011 10 6 0.33 1 0.23 0.019 2169 0 2169 16225
262 2012 2011 11 5 0.02 30 0.00 0.000 0 0 0 0
262 2012 2011 11 6 0.27 1 0.17 0.014 1603 0 1603 11992
262 2012 2011 11 12 1.01 6 0.91 0.076 8582 0 8582 64193 262 2012 2011 11 20 0.69 8 0.59 0.049 5564 0 5564 41620 262 2012 2011 11 21 0.75 1 0.65 0.054 6130 0 6130 45852 262 2012 2011 12 12 0.39 22 0.29 0.024 2735 0 2735 20457 262 2012 2011 12 13 0.27 1 0.17 0.014 1603 0 1603 11992 262 2012 2012 1 21 1.83 39 1.73 0.144 16315 0 16315 122038 262 2012 2012 1 23 0.63 2 0.53 0.044 4998 0 4998 37387
262 2012 2012 1 24 0.86 1 0.76 0.063 7167 0 7167 53612
262 2012 2012 2 7 0.06 14 0.00 0.000 0 0 0 0
262 2012 2012 2 8 0.11 1 0.01 0.001 94 0 94 705
262 2012 2012 2 9 0.01 1 0.00 0.000 0 0 0 0
262 2012 2012 2 14 0.14 5 0.04 0.003 377 0 377 2822
262 2012 2012 2 16 0.01 2 0.00 0.000 0 0 0 0
262 2012 2012 3 17 1.33 32 1.23 0.103 11600 0 11600 86767 262 2012 2012 3 18 0.48 1 0.38 0.032 3584 0 3584 26806
262 2012 2012 3 19 0.24 1 0.14 0.012 1320 0 1320 9876
262 2012 2012 3 25 0.73 6 0.63 0.053 5941 0 5941 44441
262 2012 2012 3 26 0.44 1 0.34 0.028 3206 0 3206 23984
262 2012 2012 4 1 0.46 6 0.36 0.030 3395 0 3395 25395
262 2012 2012 4 11 1.84 10 1.74 0.145 16409 0 16409 122743 262 2012 2012 4 12 0.04 1 0.00 0.000 0 0 0 0
262 2012 2012 4 13 0.53 1 0.43 0.036 4055 0 4055 30333
262 2012 2012 4 14 0.42 1 0.32 0.027 3018 0 3018 22573
262 2012 2012 4 23 0.09 9 0.00 0.000 0 0 0 0
262 2012 2012 4 24 0.01 1 0.00 0.000 0 0 0 0
262 2012 2012 4 25 0.04 1 0.00 0.000 0 0 0 0
262 2012 2012 4 26 0.67 1 0.57 0.048 5376 0 5376 40209
262 2012 2012 4 27 0.06 1 0.00 0.000 0 0 0 0
262 2012 2012 6 5 0.01 8 0.00 0.000 0 0 0 0
262 2012 2012 6 18 0.01 13 0.00 0.000 0 0 0 0
262 2012 2012 7 5 0.01 18 0.00 0.000 0 0 0 0
262 2012 2012 7 7 0.01 2 0.00 0.000 0 0 0 0
262 2012 2012 7 8 0.01 1 0.00 0.000 0 0 0 0
262 2013 2012 9 7 0.14 30 0.04 0.003 377 0 377 2822
262 2013 2012 9 13 0.01 6 0.00 0.000 0 0 0 0
262 2013 2012 10 3 0.01 21 0.00 0.000 0 0 0 0
262 2013 2012 10 23 0.08 20 0.00 0.000 0 0 0 0
262 2013 2012 11 10 0.05 18 0.00 0.000 0 0 0 0
262 2013 2012 11 16 0.06 6 0.00 0.000 0 0 0 0
262 2013 2012 11 17 0.94 1 0.84 0.070 7922 0 7922 59255 38 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2013 2012 11 18 0.30 1 0.20 0.017 1886 0 1886 14108 262 2013 2012 11 19 0.01 1 0.00 0.000 0 0 0 0
262 2013 2012 11 20 0.01 1 0.00 0.000 0 0 0 0
262 2013 2012 11 29 0.42 9 0.32 0.027 3018 0 3018 22573 262 2013 2012 11 30 0.39 1 0.29 0.024 2735 0 2735 20457 262 2013 2012 12 1 0.89 2 0.79 0.066 7450 0 7450 55728
262 2013 2012 12 2 0.34 1 0.24 0.020 2263 0 2263 16930
262 2013 2012 12 3 1.53 1 1.43 0.119 13486 0 13486 100875 262 2013 2012 12 13 0.16 10 0.06 0.005 566 0 566 4233
262 2013 2012 12 15 0.05 2 0.00 0.000 0 0 0 0
262 2013 2012 12 16 0.11 1 0.01 0.001 94 0 94 705
262 2013 2012 12 17 0.06 1 0.00 0.000 0 0 0 0
262 2013 2012 12 18 0.32 1 0.22 0.018 2075 0 2075 15519 262 2013 2012 12 23 0.48 5 0.38 0.032 3584 0 3584 26806 262 2013 2012 12 24 1.28 1 1.18 0.098 11128 0 11128 83239 262 2013 2012 12 26 0.27 2 0.17 0.014 1603 0 1603 11992 262 2013 2012 12 29 0.95 3 0.85 0.071 8016 0 8016 59961 262 2013 2012 12 30 0.65 1 0.55 0.046 5187 0 5187 38798 262 2013 2013 1 6 0.20 7 0.10 0.008 943 0 943 7054
262 2013 2013 1 7 0.16 1 0.06 0.005 566 0 566 4233
262 2013 2013 1 16 0.02 9 0.00 0.000 0 0 0 0
262 2013 2013 1 24 0.69 8 0.59 0.049 5564 0 5564 41620
262 2013 2013 1 25 0.87 1 0.77 0.064 7262 0 7262 54317
262 2013 2013 1 26 0.16 1 0.06 0.005 566 0 566 4233
262 2013 2013 1 27 0.01 1 0.00 0.000 0 0 0 0
262 2013 2013 2 8 0.08 12 0.00 0.000 0 0 0 0
262 2013 2013 2 9 0.09 1 0.00 0.000 0 0 0 0
262 2013 2013 2 20 0.33 11 0.23 0.019 2169 0 2169 16225 262 2013 2013 3 7 0.05 18 0.00 0.000 0 0 0 0
262 2013 2013 3 8 1.04 1 0.94 0.078 8865 0 8865 66309
262 2013 2013 3 16 0.02 8 0.00 0.000 0 0 0 0
262 2013 2013 3 30 0.01 14 0.00 0.000 0 0 0 0
262 2013 2013 3 31 0.42 1 0.32 0.027 3018 0 3018 22573
262 2013 2013 4 1 0.01 1 0.00 0.000 0 0 0 0
262 2013 2013 4 2 0.03 1 0.00 0.000 0 0 0 0
262 2013 2013 4 4 0.01 2 0.00 0.000 0 0 0 0
262 2013 2013 4 5 0.01 1 0.00 0.000 0 0 0 0
262 2013 2013 4 23 0.01 18 0.00 0.000 0 0 0 0
262 2013 2013 4 25 0.04 2 0.00 0.000 0 0 0 0
262 2013 2013 4 29 0.01 4 0.00 0.000 0 0 0 0
262 2013 2013 4 30 0.03 1 0.00 0.000 0 0 0 0
262 2013 2013 5 5 0.02 5 0.00 0.000 0 0 0 0
262 2013 2013 5 6 0.06 1 0.00 0.000 0 0 0 0
262 2013 2013 6 3 0.07 28 0.00 0.000 0 0 0 0
262 2013 2013 6 9 0.05 6 0.00 0.000 0 0 0 0
262 2013 2013 6 12 0.01 3 0.00 0.000 0 0 0 0
262 2013 2013 6 26 0.01 14 0.00 0.000 0 0 0 0
262 2013 2013 7 4 0.01 9 0.00 0.000 0 0 0 0
262 2013 2013 7 22 0.01 18 0.00 0.000 0 0 0 0
39 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2013 2013 7 23 0.01 1 0.00 0.000 0 0 0 0
262 2013 2013 7 29 0.03 6 0.00 0.000 0 0 0 0
262 2013 2013 8 5 0.01 7 0.00 0.000 0 0 0 0
262 2013 2013 8 15 0.01 10 0.00 0.000 0 0 0 0
262 2013 2013 8 16 0.03 1 0.00 0.000 0 0 0 0
262 2013 2013 8 19 0.01 3 0.00 0.000 0 0 0 0
262 2013 2013 8 20 0.01 1 0.00 0.000 0 0 0 0
262 2014 2013 9 10 0.01 21 0.00 0.000 0 0 0 0
262 2014 2013 9 20 0.01 10 0.00 0.000 0 0 0 0
262 2014 2013 9 21 0.01 1 0.00 0.000 0 0 0 0
262 2014 2013 10 27 0.01 37 0.00 0.000 0 0 0 0
262 2014 2013 10 29 0.26 2 0.16 0.013 1509 0 1509 11287 262 2014 2013 11 21 0.22 23 0.12 0.010 1132 0 1132 8465 262 2014 2013 11 29 0.32 8 0.22 0.018 2075 0 2075 15519 262 2014 2013 11 30 0.06 1 0.00 0.000 0 0 0 0
262 2014 2013 12 7 0.18 8 0.08 0.007 754 0 754 5643
262 2014 2013 12 8 0.07 1 0.00 0.000 0 0 0 0
262 2014 2013 12 20 0.01 12 0.00 0.000 0 0 0 0
262 2014 2014 2 3 0.42 14 0.32 0.027 3018 0 3018 22573
262 2014 2014 2 7 0.65 4 0.55 0.046 5187 0 5187 38798
262 2014 2014 2 27 1.62 20 1.52 0.127 14335 0 14335 107224 262 2014 2014 2 28 1.72 1 1.62 0.135 15278 0 15278 114278 262 2014 2014 3 1 0.73 4 0.63 0.052 5941 0 5941 44441
262 2014 2014 3 2 1.04 1 0.94 0.078 8865 0 8865 66309
262 2014 2014 3 3 0.02 1 0.00 0.000 0 0 0 0
262 2014 2014 3 7 0.01 4 0.00 0.000 0 0 0 0
262 2014 2014 3 27 0.23 20 0.13 0.011 1226 0 1226 9170
262 2014 2014 3 28 0.01 1 0.00 0.000 0 0 0 0
262 2014 2014 3 30 0.03 2 0.00 0.000 0 0 0 0
262 2014 2014 4 1 0.22 2 0.12 0.010 1132 0 1132 8465
262 2014 2014 4 2 0.27 1 0.17 0.014 1603 0 1603 11992
262 2014 2014 4 3 0.01 1 0.00 0.000 0 0 0 0
262 2014 2014 4 10 0.01 7 0.00 0.000 0 0 0 0
262 2014 2014 4 26 0.03 16 0.00 0.000 0 0 0 0
262 2014 2014 5 27 0.01 31 0.00 0.000 0 0 0 0
262 2014 2014 6 9 0.02 13 0.00 0.000 0 0 0 0
262 2014 2014 6 10 0.02 1 0.00 0.000 0 0 0 0
262 2014 2014 6 11 0.01 1 0.00 0.000 0 0 0 0
262 2014 2014 7 5 0.01 25 0.00 0.000 0 0 0 0
262 2014 2014 7 16 0.04 11 0.00 0.000 0 0 0 0
262 2014 2014 7 20 0.01 4 0.00 0.000 0 0 0 0
262 2014 2014 7 27 0.01 7 0.00 0.000 0 0 0 0
262 2014 2014 8 15 0.01 19 0.00 0.000 0 0 0 0
262 2014 2014 8 24 0.01 9 0.00 0.000 0 0 0 0
262 2015 2014 10 10 0.02 17 0.00 0.000 0 0 0 0
262 2015 2014 11 1 0.62 22 0.52 0.043 4904 0 4904 36682 262 2015 2014 11 2 0.01 1 0.00 0.000 0 0 0 0
262 2015 2014 12 2 0.72 31 0.62 0.052 5847 0 5847 43736 262 2015 2014 12 3 2.53 1 2.43 0.202 22917 0 22917 171417 40 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2015 2014 12 5 0.04 2 0.00 0.000 0 0 0 0
262 2015 2014 12 6 0.01 1 0.00 0.000 0 0 0 0
262 2015 2014 12 12 1.48 6 1.38 0.115 13014 0 13014 97348 262 2015 2014 12 13 0.03 1 0.00 0.000 0 0 0 0
262 2015 2014 12 16 0.74 3 0.64 0.053 6036 0 6036 45147 262 2015 2014 12 17 0.52 1 0.42 0.035 3961 0 3961 29628 262 2015 2014 12 19 0.01 2 0.00 0.000 0 0 0 0
262 2015 2015 1 11 0.82 23 0.72 0.060 6790 0 6790 50790 262 2015 2015 1 20 0.01 9 0.00 0.000 0 0 0 0
262 2015 2015 1 27 0.12 7 0.02 0.002 189 0 189 1411
262 2015 2015 2 4 0.05 8 0.00 0.000 0 0 0 0
262 2015 2015 2 5 0.01 1 0.00 0.000 0 0 0 0
262 2015 2015 2 7 0.27 2 0.17 0.014 1603 0 1603 11992
262 2015 2015 2 8 1.14 1 1.04 0.087 9808 0 9808 73364
262 2015 2015 2 9 0.16 1 0.06 0.005 566 0 566 4233
262 2015 2015 2 18 0.01 9 0.00 0.000 0 0 0 0
262 2015 2015 2 23 0.37 5 0.27 0.022 2546 0 2546 19046
262 2015 2015 3 1 0.12 9 0.02 0.002 189 0 189 1411
262 2015 2015 3 3 0.16 2 0.06 0.005 566 0 566 4233
262 2015 2015 3 4 0.01 1 0.00 0.000 0 0 0 0
262 2015 2015 3 10 0.02 6 0.00 0.000 0 0 0 0
262 2015 2015 3 30 0.01 20 0.00 0.000 0 0 0 0
262 2015 2015 4 7 0.02 8 0.00 0.000 0 0 0 0
262 2015 2015 4 8 0.31 1 0.21 0.017 1980 0 1980 14814
262 2015 2015 4 26 0.02 18 0.00 0.000 0 0 0 0
262 2015 2015 5 1 0.01 5 0.00 0.000 0 0 0 0
262 2015 2015 5 15 0.10 14 0.00 0.000 0 0 0 0
262 2015 2015 6 1 0.01 17 0.00 0.000 0 0 0 0
262 2015 2015 6 9 0.03 8 0.00 0.000 0 0 0 0
262 2015 2015 6 10 0.19 1 0.09 0.007 849 0 849 6349
262 2015 2015 6 11 0.02 1 0.00 0.000 0 0 0 0
262 2015 2015 6 13 0.02 2 0.00 0.000 0 0 0 0
262 2016 2015 9 14 0.01 32 0.00 0.000 0 0 0 0
262 2016 2015 9 15 0.10 1 0.00 0.000 0 0 0 0
262 2016 2015 10 5 0.18 21 0.08 0.007 754 0 754 5643
262 2016 2015 11 3 0.08 29 0.00 0.000 0 0 0 0
262 2016 2015 11 10 0.03 7 0.00 0.000 0 0 0 0
262 2016 2015 11 16 0.14 6 0.04 0.003 377 0 377 2822
262 2016 2015 12 11 0.06 26 0.00 0.000 0 0 0 0
262 2016 2015 12 12 0.07 1 0.00 0.000 0 0 0 0
262 2016 2015 12 14 0.22 2 0.12 0.010 1132 0 1132 8465
262 2016 2015 12 20 0.27 6 0.17 0.014 1603 0 1603 11992 262 2016 2015 12 22 0.03 2 0.00 0.000 0 0 0 0
262 2016 2015 12 23 0.04 1 0.00 0.000 0 0 0 0
262 2016 2015 12 25 0.04 2 0.00 0.000 0 0 0 0
262 2016 2016 1 5 1.26 11 1.16 0.097 10940 0 10940 81829 262 2016 2016 1 6 0.71 1 0.61 0.051 5753 0 5753 43031
262 2016 2016 1 7 0.89 1 0.79 0.066 7450 0 7450 55728
262 2016 2016 1 8 0.03 1 0.00 0.000 0 0 0 0
41 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2016 2016 1 10 0.06 2 0.00 0.000 0 0 0 0
262 2016 2016 1 11 0.11 1 0.01 0.001 94 0 94 705
262 2016 2016 1 18 0.02 7 0.00 0.000 0 0 0 0
262 2016 2016 1 19 0.14 1 0.04 0.003 377 0 377 2822
262 2016 2016 1 20 0.91 1 0.81 0.067 7639 0 7639 57139
262 2016 2016 1 23 0.09 3 0.00 0.000 0 0 0 0
262 2016 2016 1 31 0.40 8 0.30 0.025 2829 0 2829 21163
262 2016 2016 2 1 0.66 1 0.56 0.047 5281 0 5281 39503
262 2016 2016 2 18 0.30 17 0.20 0.017 1886 0 1886 14108 262 2016 2016 3 5 0.02 18 0.00 0.000 0 0 0 0
262 2016 2016 3 6 2.08 1 1.98 0.165 18673 0 18673 139673 262 2016 2016 3 7 0.53 1 0.43 0.036 4055 0 4055 30333
262 2016 2016 3 8 0.40 1 0.30 0.025 2829 0 2829 21163
262 2016 2016 3 12 0.62 4 0.52 0.043 4904 0 4904 36682
262 2016 2016 3 14 0.03 2 0.00 0.000 0 0 0 0
262 2016 2016 3 20 0.02 6 0.00 0.000 0 0 0 0
262 2016 2016 4 8 0.14 19 0.04 0.003 377 0 377 2822
262 2016 2016 4 9 0.51 1 0.41 0.034 3867 0 3867 28922
262 2016 2016 4 10 0.58 1 0.48 0.040 4527 0 4527 33860
262 2016 2016 5 4 0.05 24 0.00 0.000 0 0 0 0
262 2016 2016 5 18 0.01 14 0.00 0.000 0 0 0 0
262 2016 2016 5 19 0.01 1 0.00 0.000 0 0 0 0
262 2016 2016 5 29 0.03 10 0.00 0.000 0 0 0 0
262 2016 2016 5 30 0.01 1 0.00 0.000 0 0 0 0
262 2016 2016 5 31 0.01 1 0.00 0.000 0 0 0 0
262 2016 2016 6 3 0.01 3 0.00 0.000 0 0 0 0
262 2016 2016 6 4 0.01 1 0.00 0.000 0 0 0 0
262 2016 2016 6 5 0.06 1 0.00 0.000 0 0 0 0
262 2016 2016 6 25 0.01 20 0.00 0.000 0 0 0 0
262 2016 2016 7 15 0.02 21 0.00 0.000 0 0 0 0
262 2016 2016 7 25 0.03 10 0.00 0.000 0 0 0 0
262 2016 2016 7 31 0.01 6 0.00 0.000 0 0 0 0
262 2016 2016 8 1 0.01 1 0.00 0.000 0 0 0 0
262 2016 2016 8 15 0.02 14 0.00 0.000 0 0 0 0
262 2016 2016 8 18 0.03 3 0.00 0.000 0 0 0 0
262 2017 2016 9 19 0.01 32 0.00 0.000 0 0 0 0
262 2017 2016 9 20 0.01 1 0.00 0.000 0 0 0 0
262 2017 2016 10 14 0.01 25 0.00 0.000 0 0 0 0
262 2017 2016 10 15 0.01 1 0.00 0.000 0 0 0 0
262 2017 2016 10 16 0.03 1 0.00 0.000 0 0 0 0
262 2017 2016 10 17 0.54 1 0.44 0.037 4150 0 4150 31038 262 2017 2016 10 26 0.01 9 0.00 0.000 0 0 0 0
262 2017 2016 10 27 0.01 1 0.00 0.000 0 0 0 0
262 2017 2016 10 28 0.24 1 0.14 0.012 1320 0 1320 9876
262 2017 2016 10 29 0.03 1 0.00 0.000 0 0 0 0
262 2017 2016 10 31 0.28 2 0.18 0.015 1698 0 1698 12698 262 2017 2016 11 1 0.01 1 0.00 0.000 0 0 0 0
262 2017 2016 11 21 0.92 20 0.82 0.068 7733 0 7733 57844 262 2017 2016 11 27 0.34 6 0.24 0.020 2263 0 2263 16930 42 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2017 2016 11 28 0.01 1 0.00 0.000 0 0 0 0
262 2017 2016 12 9 0.11 12 0.01 0.001 94 0 94 705
262 2017 2016 12 13 0.01 4 0.00 0.000 0 0 0 0
262 2017 2016 12 16 1.89 3 1.79 0.149 16881 0 16881 126270 262 2017 2016 12 24 1.52 8 1.42 0.118 13392 0 13392 100170 262 2017 2016 12 30 0.02 6 0.00 0.000 0 0 0 0
262 2017 2016 12 31 0.25 1 0.15 0.012 1415 0 1415 10581 262 2017 2017 1 1 0.01 1 0.00 0.000 0 0 0 0
262 2017 2017 1 5 0.66 4 0.56 0.047 5281 0 5281 39503
262 2017 2017 1 7 0.21 2 0.11 0.009 1037 0 1037 7760
262 2017 2017 1 8 0.31 1 0.21 0.017 1980 0 1980 14814
262 2017 2017 1 9 1.96 1 1.86 0.155 17541 0 17541 131208 262 2017 2017 1 11 0.77 2 0.67 0.056 6319 0 6319 47263
262 2017 2017 1 12 0.15 1 0.05 0.004 472 0 472 3527
262 2017 2017 1 13 0.03 1 0.00 0.000 0 0 0 0
262 2017 2017 1 19 1.73 6 1.63 0.136 15372 0 15372 114983 262 2017 2017 1 20 0.74 1 0.64 0.053 6036 0 6036 45147
262 2017 2017 1 21 1.70 1 1.60 0.133 15089 0 15089 112867 262 2017 2017 1 22 0.42 1 0.32 0.027 3018 0 3018 22573
262 2017 2017 1 23 1.13 1 1.03 0.086 9714 0 9714 72658
262 2017 2017 1 24 0.14 1 0.04 0.003 377 0 377 2822
262 2017 2017 2 2 0.03 9 0.00 0.000 0 0 0 0
262 2017 2017 2 3 0.59 1 0.49 0.041 4621 0 4621 34566
262 2017 2017 2 4 0.40 1 0.30 0.025 2829 0 2829 21163
262 2017 2017 2 5 0.01 1 0.00 0.000 0 0 0 0
262 2017 2017 2 6 2.14 1 2.04 0.170 19239 0 19239 143906 262 2017 2017 2 7 0.47 1 0.37 0.031 3489 0 3489 26101
262 2017 2017 2 8 0.88 1 0.78 0.065 7356 0 7356 55023
262 2017 2017 2 9 0.04 1 0.00 0.000 0 0 0 0
262 2017 2017 2 10 0.01 1 0.00 0.000 0 0 0 0
262 2017 2017 2 11 0.59 1 0.49 0.041 4621 0 4621 34566
262 2017 2017 2 17 1.00 6 0.90 0.075 8488 0 8488 63488
262 2017 2017 2 18 2.79 1 2.69 0.224 25369 0 25369 189758 262 2017 2017 2 19 0.16 1 0.06 0.005 566 0 566 4233
262 2017 2017 2 20 0.96 1 0.86 0.072 8110 0 8110 60666
262 2017 2017 2 21 0.46 1 0.36 0.030 3395 0 3395 25395
262 2017 2017 2 22 0.11 1 0.01 0.001 94 0 94 705
262 2017 2017 2 26 0.09 4 0.00 0.000 0 0 0 0
262 2017 2017 2 27 0.01 1 0.00 0.000 0 0 0 0
262 2017 2017 2 28 0.02 1 0.00 0.000 0 0 0 0
262 2017 2017 3 6 0.36 9 0.26 0.022 2452 0 2452 18341
262 2017 2017 3 14 0.01 8 0.00 0.000 0 0 0 0
262 2017 2017 3 15 0.01 1 0.00 0.000 0 0 0 0
262 2017 2017 3 16 0.01 1 0.00 0.000 0 0 0 0
262 2017 2017 3 18 0.02 2 0.00 0.000 0 0 0 0
262 2017 2017 3 19 0.01 1 0.00 0.000 0 0 0 0
262 2017 2017 3 20 0.01 1 0.00 0.000 0 0 0 0
262 2017 2017 3 21 0.39 1 0.29 0.024 2735 0 2735 20457
262 2017 2017 3 22 0.61 1 0.51 0.042 4810 0 4810 35976
43 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 262 2017 2017 3 23 0.14 1 0.04 0.003 377 0 377 2822
262 2017 2017 4 8 0.49 16 0.39 0.032 3678 0 3678 27511
262 2017 2017 4 14 0.05 6 0.00 0.000 0 0 0 0
262 2017 2017 4 17 0.09 3 0.00 0.000 0 0 0 0
262 2017 2017 4 18 0.15 1 0.05 0.004 472 0 472 3527
262 2017 2017 4 19 0.28 1 0.18 0.015 1698 0 1698 12698
262 2017 2017 5 4 0.03 15 0.00 0.000 0 0 0 0
262 2017 2017 5 5 0.04 1 0.00 0.000 0 0 0 0
262 2017 2017 5 7 0.11 2 0.01 0.001 94 0 94 705
262 2017 2017 5 8 0.11 1 0.01 0.001 94 0 94 705
262 2017 2017 5 24 0.01 16 0.00 0.000 0 0 0 0
262 2017 2017 6 20 0.01 27 0.00 0.000 0 0 0 0
262 2017 2017 6 23 0.04 3 0.00 0.000 0 0 0 0
262 2017 2017 7 12 0.03 20 0.00 0.000 0 0 0 0
262 2017 2017 7 18 0.01 6 0.00 0.000 0 0 0 0
262 2017 2017 7 24 0.01 6 0.00 0.000 0 0 0 0
262 2017 2017 7 25 0.01 1 0.00 0.000 0 0 0 0
262 2017 2017 8 26 0.01 32 0.00 0.000 0 0 0 0
262 2017 2017 8 27 0.05 1 0.00 0.000 0 0 0 0
262 2017 2017 8 28 0.01 1 0.00 0.000 0 0 0 0
262 2018 2017 9 4 0.01 7 0.00 0.000 0 0 0 0
262 2018 2017 9 11 0.27 7 0.17 0.014 1603 0 1603 11992
44 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment D
2023 Rainfall at the Gaviota Coast

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Attachment E
Central Coast Regional Water Quality Control Board Notice of Applicability dated June 11, 2021
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Central Coast Regional Water Quality Control Board
June 11, 2021
Sent via Electronic Mail
Certified mail No. 7020 1810 0002 0768 8024
John Dewey
Chief Executive Officer
Mustang Renewable Power Ventures, LLC
17 Corporate Plaza Drive, Suite 200
Newport Beach, CA 92660
[email protected]
Dear Mr. Dewey,
LAND DISPOSAL PROGRAM: TAJIGUAS COMPOST MANAGEMENT UNIT, 14470 CALLE REAL, GOLETA, SANTA BARBARA COUNTY – NOTICE OF
APPLICABILITY, WATER QUALITY ORDER 2020-0012 AND APPROVAL OF THE WATER AND WASTEWATER MANAGEMENT PLAN, WDID NO. 3 420621873 Central Coast Regional Water Quality Control Board (Central Coast Water Board) staff received a notice of intent (NOI) and filing fee on June 18, 2020 for the proposed Tajiguas Compost Management Unit (Facility) composting operation. On May 19, 2021, staff received a Technical Report for the proposed Facility via GeoTracker with a sitespecific Water and Wastewater Management Plan. The Facility will be located at 14470 Calle Real in Goleta as a postclosure land use on the top deck of the Tajiguas Solid Waste Site (Landfill). The County of Santa Barbara, Department of Public Works is the landowner of the Facility. The Facility operator will be Mustang Renewable Power Ventures, LLC (Discharger). The documents were submitted to obtain coverage under Water Quality Order 2020-0012-DWQ, General Waste Discharge Requirements for Commercial Composting Operations (General Order). For more information please visit the weblink to the General Order
(https://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/2020/ wqo2020_0012_dwq.pdf).

Notice of Applicability
Central Coast Water Board staff developed this notice of applicability (NOA) in response to the NOI and Technical Report. Based on staff’s review of these documents, the Facility meets the conditions of the General Order, and is hereby covered under General Order 2020-0012-DWQ as a Tier II composting operation. The Discharger DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Mr. John Dewey - 2 - June 11, 2021
must comply with all Tier II requirements of the General Order and as outlined in this NOA.

The filing fee for the Tajiguas Compost Management Unit is based on Threat to Water Quality and Complexity rating of 3C. The submitted $2,625 filing fee covers the first year permitted by this NOA. The Discharger shall submit the required annual fee (as specified in the annual billing statement issued by the State Water Resources Control Board) until the NOA is officially terminated.

The Discharger is responsible for implementing all operations in a manner that complies with the General Order. Any noncompliance with the General Order constitutes a violation of the Water Code, and is grounds for enforcement action, and/or termination of enrollment under the General Order. Compliance with the General Order requires the Discharger to implement and comply with all aspects of the NOI and Technical Report.

Conditions of the Composting General Order NOA include, but are not limited to:
1) The Discharger be in full compliance with the General Order prior to beginning composting operations and waste placement.
2) A Final Post-Construction Report must be submitted 60 days after the completion of all construction activities associated with all applicable containment and monitoring structures, as required for compliance with this General Order and the MRP. The Final Post-Construction Report must contain as-built plans and specifications to document that containment and monitoring structures were properly constructed and tested.
3) By April 1st of each year, the Discharger must submit an Annual Monitoring and Maintenance Report as required by the Monitoring and Reporting Program (MRP). 4) A revised NOI is required at least 90 days prior to adding a new feedstock, additive, or amendment, changing material or construction specifications, changing a monitoring program, or changing an operation or activity not described in the approved NOI and technical report.
5) The Discharger must comply with any required stormwater permits and regulations.

Please see the State Water Resources Control Board Storm Water Program page for information about stormwater permits.
(https://www.waterboards.ca.gov/water_issues/programs/stormwater/) Attachment B of the General Order includes specific monitoring and reporting requirements that you must comply with, including routine monitoring and reporting. As indicated in the General Order, the State Water Board and Regional Water Boards are transitioning to the paperless office system. Dischargers must submit reports (both technical and monitoring reports) to the State Water Board’s GeoTracker database over the Internet in portable document format (PDF) as specified in California Code of Regulations, Title 23, Section 3892(d) and Section 3893. In addition, analytical data must be uploaded to the GeoTracker database in Electronic Deliverable Format (EDF) DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Mr. John Dewey - 3 - June 11, 2021
under a site-specific global identification number. Please use your site specific Geotracker project identification number (T10000017039) to upload reports and data.

The Tajiguas Compost Management Unit GeoTracker page can be found at:
https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T10000017039.

Water and Wastewater Management Plan
The Technical Report includes a Water and Wastewater Management Plan with information about how water will be managed onsite to prevent the discharge of wastewater from the Facility. Leachate and wastewater are defined in the General Order as “any liquid formed by the drainage of liquids from, or percolation/flow of liquids through any feedstock, additive, amendment, or compost (active, curing, or final product) pile.”
The Discharger will to collect site runoff (leachate/wastewater) from low intensity rainfall events within collection tanks to then reuse the wastewater on the compost piles to maintain moisture conditions. For high intensity and long duration storms, the Discharger plans to prevent the production of wastewater by covering compost with waterproof tarpaulins, sweeping the isles between the windrows, deploying coconut fiber waddles between the compost rows, and discharging clean stormwater to the Landfill’s North Sedimentation Basin, which ultimately discharges to Pila Creek.

The Discharger included a water balance analysis to demonstrate that if the Facility is managed and operated according to the Water and Wastewater Management Plan, wastewater will not be discharged from the Facility. Per the MRP, the Discharger will submit an Annual Monitoring and Maintenance Report with inspection and monitoring information which includes reporting quarterly information about capacities within the storage systems, inspection information about the wastewater management system, and information detailing discharges from the Facility. Central Coast Water Board staff have reviewed and hereby approves the Water and Wastewater Management Plan.

Information to Petition This Action
Any person affected by this action of the Water Board may petition the State Water Board to review the action in accordance with California Water Code, Section 13320 and California Code of Regulations, Title 23, Section 2050. The petition must be received by the State Water Board, Office of Chief Counsel, P.O. Box 100 Sacramento, 95812 within 30 days of the date of this order. Copies of the law and regulations applicable to filing petitions will be provided upon request.

DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Mr. John Dewey - 4 - June 11, 2021
If you have any questions, please contact Jordan Haserot by phone at (805) 542-4781 or email at [email protected], or Ryan Lodge at (805) 549-3506.

Sincerely,
for Mathew T. Keeling
Executive Officer
Cc:

Leslie Wells (Santa Barbara County Public Works), [email protected] Todd Curtis (Santa Barbara County Public Works), [email protected] Jamie Reyes (Santa Barbara County Public Works), [email protected] Jeanette Gonzales-Knight (Santa Barbara County Public Works), [email protected] John Kular (John Kular Consulting), [email protected] Norma Campos Bernal (Santa Barbara County Public Health, LEA), [email protected]
Ember Christensen (State Water Board), [email protected] Ryan Lodge (Central Coast Water Board), [email protected] Jordan Haserot (Central Coast Water Board), [email protected] R:\RB3\Shared\LDU\Program\Compost\Compost Facilities\Tajiguas\NOA letter Tajiguas Compost.docx
GeoTracker ID: T10000017039
DocuSign Envelope ID: 0208E3D8-3EF0-4614-B564-F04008AC266F DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 1 Jeanette Gonzales-Knight
From: Carlyle Johnston
Sent: Wednesday, October 11, 2023 10:44 PM
To: [email protected]; 'Dylan Ellis'; Gerardo Pinelas Cc: Marty Wilder; Jeanette Gonzales-Knight; Travis Spier Subject: County Right to Perform: CMU Runoff Pipe Replacement Dear John Dewey,
This email is serving as official notice of County Right to Perform under Section 14.8 of the Agreement between the County and MSB (included below for convenience).

Today you were notified by the County’s Operations Manager Travis Spier that no work has taken place on the CMU Runoff Pipe Replacement project since the County inspection that took place on October 3, 2023 (an eight day period).

Per Section 14.8, the County has the right to take over a project inhibiting performance if activity is has been suspended for seven (7) days or more. Additionally, this project’s completion is 11 days past the deadline specified by the RWQCB in their Notice of Violation (NOV). The County is taking over this project and will complete the required work with a private contractor to ensure its completion in a timely manner and in full compliance with the RWQCB.

We expect this work to begin Tuesday, October 17, 2023. Full cooperation with your staff is necessary during this project’s completion.

Further details on this project will be shared with you in the coming days.

Please contact me if you have any questions.

Carlyle
805 882 3617
DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9

ATTACHMENT B
Health and Safety Incident Reports
DocuSign Envelope ID: 98909AAC-4B22-4F17-9C5A-C54D3B956ED9 Employee Incident Report
Reported By: Gerardo Pinales Jr
Title/Role: Environmental Compliance and Safety Manager Incident Number: 082823001
Date of Finalized Report: August 30th, 2023
Date of Incident: August 28th, 2023
Time of Incident: 06:24
Employee Name(s): Heriberto Moreno
Employee Role: Loader Operator
Location: 14470 Calle Real Goleta, CA 93117 Anaerobic Digestion Facility (ADF), Digester Hallway
Police Report Reference Number: N/A
Name/Role/Contact of Parties Involved:

1. Apolinar Flores (Mustang RPV LLC.)

2. Abelardo Melgoza (Mustang RPV LLC.)
Name/Role/Contact of Witnesses Involved: None. Camera footage of the incident.

Incident Description:

On 8/28/23 at the Tajiguas Landfill Anaerobic Digester Facility, at approximately 06:24 Heriberto Moreno of Mustang RPV LLC. staff was executing his standard practice of moving digestate out from fermentor chambers. Specifically, as a loader operator at fermenter #14. After unlocking and opening the primary fermenter door with the assistance of Mr. Apolinar Flores, the residual percolate was released from the chamber that was caused by a clogged fermentor drain. This caused the hallway to flood due to the abnormal residual amount. Mr. Moreno then instructed Mr. Flores to retreat from the work area over the concern of Mr. Flores' off-gassing exposure. Mr. Flores did not have a respirator on hand at the time of the hallway flooding. Once Mr. Flores removed himself from the work area of the fermentor door, Mr. Moreno then proceeded to remove the secondary 'gate' by himself. Once the gate was lifted, he moved north bound up the hallway. In this motion, the door was being lifted with the loader bucket and the fermenter gate door struck the fully recessed aerial lift that was placed in the hallway.

The lift was up alongside and between fermenter doors 8 and 9 at the time of the Employee Incident Report #082823001