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San Joaquin County Environmer, Bath Division �lT��i►% i�i�il 11.E State 18 -Month Inspection Report Forward Landfill SWIS #39 -AA -0015 CIWMB staff reviewed Forward Landfill's Daily Incoming Waste spreadsheets from January through June of 2004 subsequent to the inspection. CIWMB staff found it difficult to determine the amount of waste material being counted towards Forward Landfill's permitted daily tonnage limit of 8,668 tons per day and the total amount of waste material being used as daily cover at the facility. CIWMB staff, in consultation with the local enforcement agency, have determined that the weight and volume records kept by Forward Landfill are not in a format where the local enforcement agency or CIWMB staff can verify that the facility is within its permitted tonnage limits. Title 27,Califomia Code of Regulations, Section 20510(a) — CIWMB Disposal Site Records states, in part, that each site operator shall maintain records of weights or volumes accepted in a form and manner approved by the EA. Board staff recommend that the local enforcement agency require the operator to submit records of weights or volumes in an alternative format so the local enforcement agency and CIWMB staff can easily determine the amount of waste material being counted towards Forward Landfill's permitted daily tonnage limit and the amount of waste material being used as daily cover at the facility. Also, during the inspection, Board staff observed the use of tarpaulins on half of the previous days working face as alternative daily cover. (The other half of the working face was covered with treated auto shredder waste.) According to the Daily Incoming Waste spreadsheet, Forward Landfill received 93,348.64 tons of "trash" and 34,860.08 tons of "Cover Material" during the month of June 2004. Using the refuse to cover ratio of 6:1 on page 4-10 of Forward Landfill's Joint Technical Document, the amount of cover that should have been used was 15,558.11 tons. It should also be pointed out that the "Stockpile" column for the month of June 2004 read 73.4 tons. If Forward Landfill is using tarpaulins and covering only half of the active face with treated auto shredder waste the amount of waste material designated as "Cover Material" seems excessive for one month. Board staff in consultation with the local enforcement agency agrees that more information from the operator is required in order to determine if the quantity of waste material designated as "Cover Material" is not more than necessary to meet the performance requirements for the particular daily cover. As a reminder, the new alternative daily cover regulations took effect on July 23, 2004. These regulations changed the reporting requirements for each solid waste facility Report of Disposal Site Information. The new regulations require, per Title 27, California Code of Regulations, Section 21600(b)(6)(B), each operator to estimate the range in tons of alternative daily cover materials that are anticipated to be used, based on waste types, applicable cover to waste volume ratios, applicable density conversion factors and engineering specifications. CIWMB staff reviewed Forward Landfill's Report of Disposal Site Information (Joint Technical Document) and found this information has yet to be included. Board staff recommend that the local enforcement agency instruct the operator to submit an application for a Report of Disposal Site Information amendment with the newly required alternative daily cover information provided. Page 3 of 3 Inspector