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3 {T[ Q P.O.Box 6336 <br /> FORWARD i <br /> .L 1145 W.Charter Way•Stockton,CA 95206 <br /> \ '} INCORPORATED (209)466.4482•(800)204-4242•FAX(209)466•.1067 <br /> 2005 JUL c8 PIS 3: 21 <br /> SR 1.1 r^. •: V 1 1 <br /> �,1� :. Ut�iiTY <br /> July 26, 2005 c v R 0':<H� !T A L <br /> HEALTH DEP.TRTHENT <br /> Mr. Robert McClellan <br /> San Joaquin County Environmental Health Dept. <br /> 304 East Weber Ave, Third Floor <br /> Stockton, CA 95202 <br /> RE: June 2005 Inspection Report for Forward Landfill <br /> Dear Robert: <br /> We are in receipt of your June 4, 2005 Disposal Site Inspection Report for the Forward <br /> Landfill. Upon review, we believe the Report contains several findings that are based on <br /> inaccurate information and therefore require rescission or correction. Additionally, this <br /> transmittal will serve to bring you up to date on compliance efforts related to the <br /> submittal of an amended RDSI, methane gas control compliance activities and closure of <br /> the north side of the former Austin Road facility (to address leachate issues). Our <br /> comments are as follows. <br /> Exceedance of Permitted Tonnage Limitations <br /> The Disposal Site Inspection Report (Dated: June 4, 2005) identifies two violations for <br /> exceeding either our permitted daily or weekly average maximums for receipt of waste at <br /> the facility. In fact the facility did not exceed these permit limits and we have attached a <br /> summary of the daily tonnage received for June 2005 which show a detailed breakdown <br /> of the type and quantity of material received. While the total amount of all materials <br /> (including soil used for cover and other uses) is consistent with the details of your <br /> inspection, the amount of waste and other non-soil material used for beneficial reuse and <br /> ADC did not exceed either the permitted daily or weekly average maximums for receipt <br /> of waste at the facility. <br /> During our recent meeting with you and at our joint meeting with the California <br /> Integrated Waste Management Board staff on May 4, 2005, this issue was discussed in <br /> detail. It appeared that is was clear to everyone present at those meetings that soil used <br /> for cover or other on-site uses does not and never has counted towards the daily and <br /> weekly maximums outlined in the Facilities Permit. The conclusion that soil is not <br /> disposal or diversion and is not traditionally or normally counted within facility tonnage <br /> caps is supported by subsequent discussions with CIWMB staff and by materials <br /> published by the Board. While you may have some concern over how the material is <br /> used on-site and for what purpose, these materials historically have not counted towards <br /> the caps. We have begun keeping detailed records of how soil that is brought into the site <br /> ®v <br />