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Comment 11: The JTD, Page 4-9, Section 4.3.1, indicates that the soil needs for daily, <br /> intermediate, and operations layers were added together to derive the <br /> maximum contaminated soil limit. The actual site needs should reflect an <br /> average and not a peak amount. Revise to include a reasonable average <br /> tonnage limit. <br /> Response: Based on current records (2005), Section 4.3.1 was revised to provide actual <br /> site needs for the acceptance of beneficial reuse materials for both daily <br /> average and maximum limits. <br /> Comment 12: The JTD, Page 4-9, Section 4.3.2, states, "Therefore, on days when less waste <br /> is received the site can accept more loads of the beneficial reuse materials." <br /> Would the number of additional loads of beneficial reuse material be based <br /> on site needs? If the material accepted were for future use, how would it be <br /> handled, stored and tracked? Please explain. <br /> Response: Section 4.3.2 has been revised. <br /> Comment 13: On Page 4-10, Section 4.5, of the JTD, "weekly averages" is worded such <br /> that it appears that the facility is accepting "35,987 tons, six days a week." <br /> Revise to reflect actual conditions at the site. <br /> Response: Section 4.5 has been revised. <br /> Comment 14: The JTD, Page 4-11, Section 4.5, states "discussions with the LEA resulted in <br /> the conclusions that ash and cement kiln dust are believed to have similar <br /> properties to PGM and that C&D material is believed to have similar <br /> properties to treated auto shredder residue." See comment 10 listed above. <br /> There was no conversation regarding similar properties. It was based on the <br /> fact that the facility uses very little or no ash and cement kiln dust as ADC. <br /> Revise to remove any reference to the discussion with the LEA. <br /> Response: Section 4.5 has been revised to delete the reference to discussions with the <br /> LEA. <br /> Comment 15: The JTD, Page 4-12, Section 4.7.1, indicates that the site life estimate is <br /> reduced. This issue was raised on the previous JTD amendment review <br /> (August 2005). The Environmental Health Department (EHD) asked for an <br /> explanation in writing of the change in site life and has not received it. <br /> Please provide a written explanation. <br /> Response: A letter was sent to the Environmental Health Department (Mr. Robert <br /> McClellon) on May 2, 2006 to address the reduced site life estimates. This <br /> letter discussed the factors affecting site life estimates, provided a summary <br /> of the landfill's airspace and site life estimates, and, finally, provided <br /> 3 <br /> J:\Allied\Forward\JTD Amendment\March 2006 JTD-LEA Resp\JTD\Response to LEA comments.doc;5/16/2006 <br />