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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 21600(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 />