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i <br /> ENVIRONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY <br /> r' y Donna K. Heran, R.E.H.S. Unit Supervisors <br /> Director® 304 East Weber Avenue,Third Floor Carl Borgman,R.E.H.S. <br /> Laurie A. Cotuft, R.E.H.S. Stockton,California 95202-2708 Mike Huggins, R.E.H.S., R.D.I. <br /> �,: •P Program Manager Telephone: (209)468-3420 Douglas W.Wilson,R.E.H.S. <br /> Margaret Lagorio,R.E.H.S. <br /> Fax: (209)464-0138 Robert McClellon, R.E.H.S. <br /> Website:www.sjgov.org/ehd/ Jeff Carruesco, R.E.H.S. <br /> March 17, 2006 <br /> Kevin Basso, General Manager <br /> Post Office Box 6336 <br /> Stockton, CA 95206 <br /> RE: Joint Technical Document(JTD) Amendment No. 1. <br /> The Environmental Health Department(EHD)has received and reviewed the proposed JTD <br /> amendment. The proposed amendment does not meet Title 27 California Code of Regulation <br /> 21665 and is therefore has been rejected. The EHD has the following comments regard the <br /> proposed amendment: <br /> 1. The Solid Waste Facility Permit Application(SWFPA) indicates on Page 1, Part 2. C., <br /> that the facility is a Class II disposal site. The facility has areas that are approved to <br /> accept only Class III waste. See page 4-3 of JTD second to last paragraph. Revise the <br /> application to reflect actual conditions at the site. <br /> 2. On Page 2, B. La., of the SWFPA, (Peak Daily Tonnage or Cubic Yards), it appears that <br /> the facility is proposing to take Alternative Daily Cover(ADC)material above the 8,668 <br /> tonnage limit. The ADC tonnages need to be included in the peak daily tonnage for the <br /> facility. Revise the application to clarify that ADC tonnages are a subset of the daily peak <br /> tonnage received by the facility. <br /> 3. The SWFPA indicates, on Page 3. Part 6.,that JTD Amendment No. 1 was submitted on <br /> July 1, 2005. The cover letter submitted with the application indicates January 27, 2006. <br /> Revise the application to reflect the actual date of submittal. <br /> 4. The JTD, Page 4-1, Section 4.1, indicates that the facility may construct a hazardous <br /> materials storage locker. The facility is equipped with a hazardous material storage <br /> locker. Revise to reflect actual conditions at the site. <br /> 5. The JTD, Page 4-4, Section 4.1.2, states that the compost operation is operated by Sierra <br /> Organics. Sierra Organics no longer operates any portion of the site. Revise to reflect <br /> actual conditions at the site. <br /> 6. The JTD, Page 4-5, Section 4.1.3, indicates that Ogden Power Pacific, Inc., operates the <br /> methane gas recovery system. A different company now operates the methane recovery <br /> system. Revise to reflect actual conditions at the site. <br /> 7. The JTD, Page 4-8, Section 4.3.1, lists the ADC by types and proposes a limit for each <br /> type. The table seems to imply that the facility could accept all ADC types in the <br /> Page 1 of 4 <br />