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threat to human health and the environment ...". During routine inspection,the EHD staff has observed meat, bones, pasta and sauce, etc. in the green waste pile after being processed at Forward Resource and Recovery facility. Those food wastes, by its nature and composition, attracts vectors and creates odor;therefore it conflicts with the performance requirement of 27CCR 20690(a)(1) and (a)(2). 27CCR 20690(a)(11) states "The owner or operator shall implement a program described in the Report of Disposal Site Information as required by section 21600(b)(6)to minimize contamination of alternative daily cover with wastes not included within the individual alternative daily cover material types specified in subdivision (b) of this section and wastes that would conflict with the performance requirements of(a)(2)". During routine inspection,the EHD staff has noted on several occasions that food waste (meats, bones, pasta and other food waste) remained in the green waste pile destined for ADC usage. During one inspection, the EHD staff and the California Integrated Waste Management Board (CIWMB) staff observed your employee removed only the plastic bag, emptying bones, hot dogs and buns into the green waste pile. To date, the program, employed by your facility to separate food waste and green material from the mixture of food waste, green material and municipal solid waste, has not been successful. The EA condition 17(t) of Solid Waste Facility Permit (SWFP) states that"the processed green material shall not contain greater than five (5) percent contamination ® (plastic or paper bags, mix solid waste, or construction and demolition)". This condition is intended for the contamination listed in the parenthesis and is not intended to conflict with the State Minimum Standards (SMS). It is intended for incidental, not intentional, placement of those contaminants. The EA condition 17(a) states that"the operator shall comply with all State Minimum Standards for solid waste handling and deposal as specified in Title 27, California Code of Regulation (CCR)". In the event that any EA conditions conflict with the SMS as specified in 27CCR, the EA condition 17(a)and the SMS in 27CCR shall prevail. As described above, the City of Stockton curbside green waste program, which collects food waste with the green waste, does not meet the requirement listed in EA conditions, SMS and/or 27CCR 20690. The inclusion of food waste in the green waste destined for use as ADC conflicts with the performance requirement of 27CCR 20690(a)(2). Based on the EHD observation and definitions listed in 27CCR,the EHD has determined that your facility has been using the residential refuse, not clean green waste, as ADC. 3. Joint Technical Document Amendment Please be informed that any proposed changes in tonnage, conditions of the SWFP and/or any deemed significant change in the operation of this facility may require a revision of the SWFP as described in 27CCR 21620(c) and section 44004 of the Public Resources Code.