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I <br />81 <br />Your letter references this second portion of the RDSI to justify <br />an increase in daily volume beyond the permitted 700 cubic yards <br />of waste per day. This sentence cannot be used to substantiate <br />the receipt of an indeterminate daily volume of waste at an <br />unspecified point in the future. The RDSI discussion of the <br />possibility of future increases in daily waste volumes is made in <br />reference to site life. <br />The RDSI references a 1972 EMCON report under the heading of <br />"Site Development Plan". Your letter assumes the entire <br />focument is made part of the permit by this reference. It is <br />staff's opinion that only the site development plan and <br />supporting technical data included in the EMCON report were <br />referenced for use by the RDSI. The RDSI states: <br />The plan and supporting technical data was published in <br />their final report entitled "Geotechnical Investigation and <br />Waste Management Studies, Proposed 157 Acre Class II -I <br />Disposal Site, Stockton, California, for Forward, Inc." In <br />this study, the area method of sanitary landfilling is <br />recommended because it mazed site capacity while <br />minimizing the potential for differential settlement. With <br />minor deviations required by Group 1, special waste <br />disposal, Forward, Inc. intends to develop the site as <br />originally planned." <br />As further evidence that the 1972 EMCON report should not be <br />considered in its entirety, note that the report includes several <br />facility design and operations stipulations that were not <br />permitted or developed. Examples of these include the <br />installation of scales (p. 21), the receipt of cannery waste (p. <br />23), a leachate and gas monitoring and removal system (p. 28), <br />and used pesticide container processing facilities (p. 23). <br />Lastly, your letter cites the October 10, 1986 draft Report of <br />the Solid Waste Advisory Committee on Significant Change as a <br />basis for considering tonnage increases beyond the "tonnage <br />mentioned in the permit". The final version of the Report does <br />not include this language. A copy of the final version of the <br />Report dated May 1987, is enclosed. <br />