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San Joaquin County Environmental Heath Department State Focused Inspection Reoit= Forward Landfill SWIS #39 -AA -0015 (d) The owner or operator shall maintain a record of beneficial reuse in accordance with Title 14, California Code of Regulations, section 18800 et seq. The records shall be available for inspection by authorized representatives of the enforcement agency, the local health agency, and the CIWMB during normal business hours and retained in the operating record near the site or in an alternative location approved by the enforcement agency." During the review of the tonnage reports for Forward Landfill it was noted that 9,726.03 tons of waste was identified as beneficial reuse over four days from March 7, 2005 through March 10, 2005 and an additional 10,649.26 tons of waste was identified as beneficial reuse over four days from February 22, 2005 through February 25, 2005. Forward Representatives should provide the local enforcement agency and CIWMB staff information that clarifies how this beneficial reuse material was used to avoid a finding of overuse of solid waste as beneficially reused. As stated in Section 20686(b) above, "should the CIWMB determine that an owner or operator violated this standard, the owner or operator shall revise the applicable reports to reflect the overuse as disposal, and pay the required Board of Equalization disposal tipping fees for the amount of overuse." This regulation (Section 20686 — Beneficial Reuse) also requires alternative daily cover reuse to comply with the requirements of Section 20690. Section 20690(a)(7) states that "waste derived materials used as alternative daily cover shall be restricted to quantities no more than necessary to meet the performance requirements of this section. Should the CIWMB determine after consulting with the enforcement agency that an owner or operator violated this standard, the owner or operator shall revise the applicable reports to reflect the overuse as disposal, and pay the required Board of Equalization disposal tipping fees for the amount of overuse." During the review of the tonnage reports for Forward Landfill it was noted that on 28 separate occasions the facility had a refuse to cover ratio of approximately 3:1 or less over a 66 day period. This is in conflict with Forward Landfill's Report of Disposal Site Information which states that the refuse to cover ratio is 6:1. Per the regulations, Forward Representatives need to provide the local enforcement agency and CIWMB staff information that clarifies the use of cover material at Forward Landfill. 0 2. Section 20690(a)(5) — Alternative Daily Cover — General Requirements. This section states, in part, that the "owner or operator shall maintain'a record of waste derived alternative daily cover in accordance with Title 14, California Code of Regulations, Section 18800 et. seq. The records shall be available for inspection by authorized representatives of the enforcement agency, the local health agency, and the CIWMB during normal business hours and retained in the operating record near the site or in an alternative location approved by the enforcement agency. Per a review of several months worth of Daily Cover Certification records used by Forward Landfill it was noted that each record indicated that green waste alternative daily cover or a combination of green waste alternative daily cover and tarpaulins were used on a regular basis. However, on the day of the inspection the working face was covered with treated auto shredder waste and Forward Landfill representatives indicated that treated auto shredder waste had been used frequently over the past several months. When asked why the Daily Cover Certification records did not indicate any use of treated auto shredder waste local enforcement agency staff and CIWMB staff were told that site personnel probably just fill out the form the same way every day. If the records provided do indeed misrepresent what was actually occurring at the site during the period reviewed, this area of concern could be noted as a violation. The only tonnage records immediately available for review at the focused inspection were from February 1, 2005 through April 18, 2005. Forward Representatives stated that they would send the remaining inspections reports covering a one year period (April 20, 2004 through January 31, 2005) via the Federal Express delivery service. At the time this inspection report was mailed, May 4, 2005, CIWMB staff had not received the requested tonnage records. v Page 6 of 6 Inspector