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Page 2 of 3 is To: Evan Edgar Cc: Robert McClellon [EH] Subject: FW: Tracy Material Recovery&Transfer Facility Hi Evan, I am forwarding an email exchange with CIWMB regarding the public hours increase. CIWMB is recommending that the change be processed as a permit revision. Our position is that the change should be a permit modification for reasons stated below. T27CCR21620 (new regs effective 4-13-07) require the LEA to process a RFI amendment first. To get the ball rolling, send us a RFI amendment which requests this change. We will make a determination within 30 days whether a permit modification or revision is necessary. Garrett From: Hohlwein, Reinhard [mailto:RHohlwein@ciwmb.ca.gov] Sent: Wednesday, April 11, 2007 3:23 PM To: Garrett T. Backus [EH] Cc: Robert McClellon [EH]; Madison-Johnson, Mary Subject: RE: Tracy Material Recovery &Transfer Facility Hi again Garrett-after speaking with Mark DeBie, Mark has the following interpretation: On the list of things that require a permit revision in the new regs, one of them is an increase in hours. Mark feels that by moving the public hours to a new time (4-5 p.m.) that is, for him, technically an expansion of hours. Since that is on the list, that makes it a revision. Please forward this info on to Evan as well. And let me know how else I can help thanks - Reinhard From: Garrett T. Backus [EH] [mailto:gbackus@sjcehd.com] Sent: Monday, April 09, 2007 1:26 PM To: Hohlwein, Reinhard Cc: Robert McClellon [EH] Subject: Tracy Material Recovery &Transfer Facility Hi Reinhard, We have a transfer station in our county, Tracy Transfer(39-AA-0024), who currently has the permitted hours of operation of 4 am—6 pm (Commercial, Daily) and 6 am—4 pm (Public, Daily). The transfer station wants to change their public hours to 8 am—5 pm (Mon-Sat). The only increase in hours will be 4-5 pm. The traffic study in the 1993 Report of Facility Information (RFI),Appendix D, supports self—haul traffic from 8 am—5 pm, 7 days a week. The facility consultant, Evan Edgar, has asked me what type of permit and/or RFI change is required for this change. I looked over the new Permit Implementation Regulations effective April 13, 07 and I think that this change will require a RFI amendment and a permit modification. Both the RFI and permit will need the self-haul hours updated. I have looked at Title 27 CCR 21620 part 4 which lists four facility changes which require a permit revision. One change listed is"Increase in the permitted hours of operation." I think that this change does not constitute an increase in hours of operation since the permitted commercial hours of operation 4/27/2007