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AOL Page 3 of 3 IF 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 are 4 am—6 pm. The increase in the self-haul hours of operation will be only until 5 pm which is earlier than the commercial closing time. Will the CIWMB support a permit modification in this case or will a permit revision be necessary instead? Sincerely, Garrett Backus, REHS San Joaquin County Environmental Health Department 304 E Weber Ave, 3rd floor Stockton, CA 95202 telephone: (209)468-2986 fax: (209) 468-8392 email: gbackus@sjcehd.com 5/2/2007