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• <br />Therefore, we respectfully request that the CIWMB inspection report of April 20, 2005 <br />be revise to remove the violation that food waste was not removed from the green waste <br />destined for ADC. Thank you for your consideration to this matter. <br />Proposed Action Plan: <br />We acknowledge that the sorting process used at Forward needs to be more closely <br />monitored and improved to insure that contamination is minimized. Therefore, we will <br />review the program outlined in earlier letters to the LEA and revise that program to <br />insure that our "pickers" are thoroughly briefed on the removal of restricted materials and <br />whenever possible, food materials. We will include training materials to assist them and <br />include training materials in Spanish and English. Further, we will work with the LEA <br />on a program to improve the performance of this material as an ADC and, if necessary, <br />include a more complete description of this program in any JTD revision. <br />3. Joint Technical Document Amendment <br />As required by Title 27, California code of Regulations, Section 2I600(b)(6)(B) Forward <br />will submit an application to amend our JTD to estimate the range in tons of alternative <br />daily cover and other materials used for beneficial reuse, based on waste types, applicable <br />cover to waste volume ratios, applicable density conversion factors and applicable <br />engineering specifications. <br />In response to your concerns regarding the facility exceeding the daily and weekly <br />tonnage limits on MSW, ADC and beneficial reuse, we will propose a revised JTD that <br />will include proposed tonnage limits for various types of materials that are beneficially <br />reused or utilized as cover or ADC. The tonnage limits specified in the JTD will be in <br />addition to the daily and weekly tonnage caps that are listed in the current SWFP. <br />However, we are not proposing to include soils and clean inerts that are not considered <br />designated wastes or MSW in the weekly tonnage caps specified in the permit nor will <br />we be proposing to specify limits for those materials in the JTD. However, the JTD <br />amendments will include descriptions of the facilities proposed use of soils and inerts as <br />specified in Title 27, California code of Regulations, Section 21600(b)(6)(B). We believe <br />that this approach will allow the facility to immediately comply with a reasonable <br />interpretation of the weekly and daily tonnage limits until additional limits on ADC and <br />beneficial reuse can be established in a revised JTD. <br />The current JTD will also be reviewed in order to identify particular areas requiring <br />additional clarification such as the 6:1 cover ratio for ADC usage at the site that was <br />referenced in recent correspondence from your department. The application to revise the <br />JTD will be submitted by July 31, 2005. <br />.'7 <br />