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The EHD recommends you to modify the daily tonnage report so that it clearly states <br />how each category of material was handled, i.e., if the material was disposed, used as <br />ADC, stockpiled or put to beneficial reuse. <br />The EHD recommends you to use waste definitions from the existing regulations <br />when defining waste types received at the facility to the extent possible. For <br />example, there are definitions in the regulation for construction and demolition <br />debris, Construction, Demolition and Inert (CDI) material, Construction and <br />Demolition Waste and Inert Debris. <br />2. Processed Green Material Used as Alternative Dail- Cover <br />You cited Section 20690(a)(3)(A) of Title 27 of California Code of Regulations <br />(27CCR) in your letter. That section does not exist. <br />27CCR 20690(b)(3)(A) states "...processed green material means any plant material <br />that is either separated at the point of generation, or separated at a centralized facility <br />that employs methods to minimize contamination. Green material includes, but not <br />limited to, yard trimmings, untreated wood wastes, paper products, and natural <br />fiber products....". Please note that the definition in that section refers to "..plant <br />material.." and that all inclusions mentioned are of plant origin, not animal products, <br />found in food waste, or other municipal solid waste, all of which is referred to as <br />0 contamination. <br />Title 14 of CCR (14CCR) 17225.30 defines garbage as follows: "garbage includes <br />all kitchen and table food waste, and animal or vegetable waste that attends or <br />results from the storage, preparation, cooking and handling of food stuffs". <br />14CCR17225.59 defines rubbish as "rubbish includes non-putrescible solid wastes <br />such as ashes, paper, cardboard, tin cans, yard clippings, wood, glass, bedding, <br />crockery, plastics, rubber by-products or litter." 14CCR17225.57 defines residential <br />refuse as "residential refuse includes all types of domestic garbage and rubbish <br />which originate in the residential dwellings." The City of Stockton curbside green <br />waste program encourages resident to deposit food waste (garbage by definition) with <br />the green waste; thus the green waste collected via this program is not separated at <br />the point of generation. Pursuant to the above definitions, that program collected <br />residential refuse, not green waste. <br />27CCR 20690(a)(1) states "alternative materials of alternative thickness for daily <br />cover (other than at least six inches of earthen material) for municipal solid waste <br />landfill units may be approved by the EA with concurrence by the CIWMB, if the <br />owner or operator demonstrates that the alternative material and thickness control <br />vectors, fires, odors, blowing litter, and scavenging without presenting a threat to <br />human health and the environment." 27CCR 20690(a)(2) states "Alternative daily <br />cover alone, or in combination with compacted earthen material, shall be placed over <br />the entire working face at the end of each operating day or at more frequent intervals <br />to control vectors, fires, odors, blowing litter, and scavenging without presenting a <br />