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FORWARDINCORPORATED July 26, 2005 2005 JUL 28 Pn" 3: 21 S;,;: �%;; C"1 i;, TY HEALTH CEP :RTHENT Mr. Robert McClellan San Joaquin County Environmental Health Dept. 304 East Weber Ave, Third Floor Stockton, CA 95202 RE: June 2005 Inspection Report for Forward Landfill Dear Robert: P.O. Box 6336 1145 W. Charter Way • Stockton, CA 95206 (209) 466-4482 • (800) 204-4242 • FAX (209) 466-.1067 We are in receipt of your June 4, 2005 Disposal Site Inspection Report for the Forward Landfill. Upon review, we believe the Report contains several findings that are based on inaccurate information and therefore require rescission or correction. Additionally, this transmittal will serve to bring you up to date on compliance efforts related to the submittal of an amended RDSI, methane gas control compliance activities and closure of the north side of the former Austin Road facility (to address leachate issues). Our comments are as follows. Exceedance of Permitted Tonnage Limitations The Disposal Site Inspection Report (Dated: June 4, 2005) identifies two violations for exceeding either our permitted daily or weekly average maximums for receipt of waste at the facility. In fact the facility did not exceed these permit limits and we have attached a summary of the daily tonnage received for June 2005 which show a detailed breakdown of the type and quantity of material received. While the total amount of all materials (including soil used for cover and other uses) is consistent with the details of your inspection, the amount of waste and other non -soil material used for beneficial reuse and ADC did not exceed either the permitted daily or weekly average maximums for receipt of waste at the facility. During our recent meeting with you and at our joint meeting with the California Integrated Waste Management Board staff on May 4, 2005, this issue was discussed in detail. It appeared that is was clear to everyone present at those meetings that soil used for cover or other on-site uses does not and never has counted towards the daily and weekly maximums outlined in the Facilities Permit. The conclusion that soil is not disposal or diversion and is not traditionally or normally counted within facility tonnage caps is supported by subsequent discussions with CIWMB staff and by materials published by the Board. While you may have some concern over how the material is used on-site and for what purpose, these materials historically have not counted towards the caps. We have begun keeping detailed records of how soil that is brought into the site mar