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"J76 R AFT <br /> • On April 7, 2005, the EHD received a letter from Forward Inc. The letter subject was the <br /> procedures for processing of green waste, City of Stockton, green waste collection <br /> program. The letter goes as far as to use the definitions found in Title 14 CCR, Section <br /> 17852 (a)(21) and 17868.5, and Title 27 CCR 20690 (b)(3) (see exhibit kk). <br /> On April 8, 2005,the EHD received a letter from Forward Inc. The letter contested <br /> several issue on the inspection report of February 24, 2005 and asked the EHD to revised <br /> one of the violations to an area of concern. The request came from the site operator, <br /> James Moore. Mr. Moore stated that Section 20790, 27CCR was very specific and that it <br /> only related to public contact for the Leachate. Mr. Moore stated that the facility was <br /> closed to the public and therefore did not apply. Mr. Moore requested that the inspection <br /> report be revised to an area of concern for 20790, 27CCR. The EHD responded to the <br /> letter on, April 27, 2005. Robert McClellon reviewed the section and agreed that there <br /> was no public contact. The inspection was revised to a violation for Site Maintenance, <br /> Section 20750, 27 CCR(see exhibit 11). <br /> On April 20 2005, Michael Kith and Robert McClellon employees of the EHD conducted <br /> a monthly routine inspection. The inspection was a joint inspection with Keith Kennedy <br /> and Jeff Watson of the CIWMB staff and the following was noted. The concentrations of <br /> methane gas in the monitoring probe GP 9 ranged from 0.0%to 57.5%. This was <br /> documented under the violation of Explosive Gases Control, Section 20919.5 of 27CCR. <br /> • The facility was cited for a violation of Terms and Conditions of the Permit Section, <br /> 44004, PRC. The facility was accepting waste above what the facility permit allows. The <br /> facility was also violated for Significant Change Section 44014 (b), PRC. The facility <br /> exceeded the permitted tonnage limit on more than one occasion each month. The facility <br /> was cited for a violation for Report of Disposal Site Information(RDSI) Section 21600, <br /> 27 CCR. The facility had not updated the RDSI as requested in the last joint CIWMB <br /> inspection. The facility was also cited for Contaminated Green Waste Section 20690 <br /> (b)(3), 27 CCR. The site personnel responsible for removing the food waste from the <br /> green waste was seen removing the food waste from a plastic bag and reintroducing the <br /> food waste back into the green waste and throwing the bag away. The leachate seep was <br /> ongoing and was noted as an area of concern, section 20750, 27CCR, pictures were taken <br /> (see exhibit mm). <br /> On May 4, 2005, a meeting was held between the EHD, the CIWMB and the <br /> representatives from Forward Inc. and Allied Waste Industries Inc. The meeting was <br /> held, at the CIWMB offices, to discuss the site's status and the recent joint inspection. <br /> Subjects discussed at the meeting were tonnages that the facility receives above the <br /> tonnage limit, over use of ADC, revised reporting format, Joint Technical Document <br /> (JTD) amendments, and the MSW Green Waste ADC. The facility personnel indicated <br /> that they thought it could be resolved with a better reporting format. They stated that <br /> they had always been allowed to receive waste over their tonnage limit. The EHD stated <br /> that the permit allows for total tonnage and nothing else. They stated that the number in <br /> the permit was for disposal tonnage and not for ADC and Beneficial reuse. They wanted <br /> • to argue on the definition of green waste as it pertains to ADC and not green waste. <br />