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San Joaquin County Environmental Heath Department State Focused Inspection Report Forward Landfill SWIS#39-AA-0015 ratio of 6:1 on page 4-10 of Forward Landfill's Report of Disposal Site Information,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"would not be equal to the 6:1 ratio included in the Report of Disposal Site Information. The August 11,2004 18-month inspection report indicated that more information was required in order to determine if the quantity of waste material designated as"Cover Material"is different than what is stated in the Report of Disposal Site Information and potentially more than necessary to meet the performance requirements for the particular daily cover. To date Forward Landfill has yet to provide documentation regarding the amount of tonnage used for alternative daily cover at the active face. There have also been several subsequent requests by the local enforcement agency for this documentation. CIWMB staff's August 11,2004 18-month inspection report also indicated that the new alternative daily cover regulations took effect on July 23,2004,and that these regulations changed the reporting requirements for each solid waste facility's 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. To date Forward Landfill has yet to submit a Solid Waste Facilities Permit application for a Report of Disposal Site Information amendment estimating 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. This focused inspection was also conducted as a follow-up to an April 29,2004 meeting with Forward Landfill representatives,the local enforcement agency and CIWMB staff regarding the use of solid waste(processed green material that contained food waste)as an alternative daily cover. VIOLATIONS: A. The inspection identified two violations of Division 30,Public Resources Code,Part 4,Chapter 3. 1. Section 44004-Significant Change. No operator of a solid waste facility shall make any significant change in the design or operation of the solid waste facility not authorized by the existing permit,unless the change is approved by the enforcement agency,and conforms with this division,and all regulations adopted pursuant to this division and the terms and conditions of the solid waste facilities permit are revised to reflect the change. During the review of the tonnage reports provided by the operator for Forward Landfill,it was noted that on 16 separate occasions the facility exceeded its maximum permitted daily tonnage of 8,668 tons over a 66 day period(see Table 1). This is a change that is inconsistent with the current limits and therefore not authorized by the existing permit and would require a revision to the permit prior to making the change;therefore,it is a violation of Forward Landfill's June 17,2003 Solid Waste Facilities Permit. Page 2 of 6 Inspector