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September 22, 2005 Mr. Robert McClellon, Supervising REHS San Joaquin County Environmental Health Department 304 East Weber Avenue, Third Floor Stockton, California 95202 RE: Forward Landfill, Soil Definition Dear Mr. McClellon: This documents the criteria used to define soil delivered to Forward Landfill as either "Class II Soil," or "Soil Material." Class II Soil requires disposal in the refuse fill. Soil Material is suitable for other uses such as daily and intermediate cover, road and cell construction, drainage and grading improvements, gas system construction or tipping pad construction. These are the most common uses. However, others may arise at various times. In addition, this letter also presents a brief description of the process to evaluate soil and determine the appropriate category. Soil Evaluation Process Soils proposed for delivery to Forward Landfill are subject to a thorough and rigorous review and evaluation process. The objective of this process is to determine (1) the suitability of the soil for delivery to Forward Landfill (i.e., is the soil a hazardous waste that the landfill should not accept?) and (2), the proper reporting category for the soil (i.e., Class II Soil or Soil Material). Typically, the generator is responsible for sampling and analyzing the soil and submitting the description of the soil (the profile) to Forward Landfill personnel for review and evaluation. Once material is deemed acceptable at the facility, the generator is given manifests for each load of material that contain tracking codes so our system can track how much material came from a given project and ensure that only approved materials are delivered to the facility. Soil Definitions As we discussed, Forward Landfill personnel use three criteria to define soils accepted at landfill. These are: • Class II Levels for Metals • Bay Area Air Quality Control Board (BAAQMD) Regulation 8, Rule 40 • Physical Characteristics