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LEWIS ENGNEZONG 98 AVE,F43NAOMr,CA 94611 TkIZ 5 1 0.6D 1.7223.FAX510.601.7206 September 7, 2005 Mr. Chandler Martin San Joaquin County Community Development Dept. 1810 East Hazelton Ave. Stockton, CA 95205-6232 Subject: Refuse Tonnage Considerations,Forward Landfill Use Permit(UP-00-7) Dear Chandler: As we discussed during our August 26,2005 meeting, an issue has been raised by the San Joaquin Environmental Health Department(the local enforcement agency or LEA for the Forward Landfill) regarding Use Permit tonnage limits for the Consolidated Forward Landfill Project. The basic question is whether the Use Permit tonnage limits are a refuse tonnage or a total tonnage. The refuse tonnage refers to the tonnage of refuse that is accepted and disposed at the landfill, whereas the total tonnage refers to the amount of refuse, alternative daily cover (ADC), soil and other beneficial reuse material accepted at the landfill. While the tonnage limits specified in the Use Permit do not state whether they apply to refuse or all material accepted at the facility, the "Approved Use" of the Forward Landfill project is defined in the Project Description contained in Chapter III of the Final Environmental Impact Report; Consolidated Forward Landfill Project (Grasetti Environmental Consulting, December 2002) (EIR). Numerous analyses, such as traffic, air quality and health risk assessments,were performed in support of the EIR and are documented within it. In addition, the Project Description, 2001 Permit Revisions Forward Landfill(Lewis Engineering, 200 1) and the Final Draft Joint Technical Document (Lewis Engineering, BAS, and GeoLogic Associates, August 2001) were prepared on behalf of the project proponent, Forward, Inc., to define the project. These documents are referenced throughout the EIR and are included in the reference list(ref: EIR pg. 223). Because the Joint Technical Document provides the basis for the landfill's Waste Discharge Requirements' and the Solid Waste Facility Permit', the Final Draft Joint Technical Document was also submitted to and reviewed by the responsible regulatory agencies during the time the EIR was being prepare&. The tonnage limit contained within the Project Description of the EIR(ref:EIR pg. 57)is based on combining the regulatory permits for the former Austin Road and Forward Landfills into one consolidated landfill. The former Forward and Austin Road Landfills were permitted to accept Landfill permit regulated by the Regional Water Quality Control Board(RWQCB) 2 Landfill permit regulated by the California Integrated Waste Management Board through Local Enforcement Agencies. For the Forward Landfill the Local Enforcement Agency is the San Joaquin Environmental Health Department 3 Review comments on the Final Draft JTD were provided by the LEA and RWQCB in 2001. None of the review comments addressed the tonnage limits.