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7 7�,(LAAW�tOFFFI/C�ES OF Dy AT <br /> THOMAS A BR E <br /> THOMAS M. BRUEN A PROFESSIONAL CORPORATION TELEPHONE: (925) 295-3131 <br /> ERIK A. REINERTSON 1990 NORTH CALIFORNIA BOULEVARD FACSIMILE: (925) 2953 132 <br /> SUITE 940 TBRUEN(7a SBCGLOBAL.NET <br /> WALNUT CREEK,CALIFORNIA 94596 <br /> July 18, 2006 <br /> VIA FEDEX <br /> David J. Irey, Esq. <br /> Supervising Deputy District Attorney <br /> Environmental Prosecutions Unit <br /> Cort Tower Building <br /> 343 E. Main Street <br /> Stockton, CA 95202 <br /> Re: Forward Landfill, San Joaquin County <br /> Dear David: <br /> I want to thank you for meeting with Jeff Setness,Mike Hakeem and me at your offices <br /> on June 14th to discuss the status of your investigation regarding the Forward Landfill. As I <br /> mentioned at the meeting, I represent Forward, Inc. ("Forward"). <br /> During our meeting we discussed the areas that were the primary focus of your <br /> investigation. We offered to write you a letter explaining Forward's position on each of these <br /> issues. You also asked us to indicate what changes, if any, the Forward Landfill had made in its <br /> operations concerning these issues. <br /> We concluded from our meeting that there were three issues that were of concern to you: <br /> (1) the use of greenwaste containing food waste as alternative daily cover(ADC); (2)whether the <br /> Forward Landfill had exceeded its daily tonnage limitations and was therefore using up its <br /> landfill capacity faster than allowed under its Solid Waste Facility Permit(SWFP); and(3) <br /> whether the Forward Landfill was receiving hazardous waste in violation of its permit—i.e., auto <br /> shredder waste. The purpose of this letter is to respond to these areas of concern and,where <br /> appropriate, to provide supporting documentation that may assist you in your investigation. We <br /> sincerely hope that as a result of our discussions and this exchange of information, you will <br /> conclude that your office should close this investigation. <br /> L' , The Use of Greenwaste with Food Waste as Alternative Daily Cover. <br /> In March of 2004, Robert McClellan of the San Joaquin County Environmental Health <br /> Department(which is the Local Enforcement Agency(LEA) in the County for the California <br /> Integrated Waste Management Board(CIWMB))wrote Forward, Inc. a letter expressing the <br />