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ENVIRONMENTAL L DEPARTMENT <br /> Pqu'" SAN JOAQUIN COUNTY <br /> y Donna K. Heran, R.E.H.S. Unit Supervisors <br /> :{ Director 304 East Weber Avenue,Third Floor Carl Borgman,R.E.H.S. <br /> o Laurie A. Cotulla, R.E.H.S. Stockton,California 95202-2708 Mike Huggins, R.E.H.S.,R.D.I. <br /> c. P Program Manager Telephone: (209)468-3420 Douglas W.Wilson,R.E.H.S. <br /> Margaret Lagorio,R.E.H.S. <br /> Fax: (209)464-0138 Robert McClellon, R.E.H.S. <br /> Website:www.sjgov.org/ehd/ .teff Carruesco,R.E.H.S. <br /> June 22,2006 <br /> cc <br /> Kevin Basso General Mana r <br /> Manager <br /> Post Office Box 6336 <br /> Stockton, CA 95206 <br /> RE: Joint Technical Document(JTD)Amendment No. 2. <br /> The Environmental Health Department(EHD)has received and reviewed the proposed JTD amendment. <br /> The proposed amendment does not meet Title 27 California Code of Regulation 21665 and therefore has <br /> been rejected.The EHD has the following comments regard the proposed amendment: <br /> 1. The JTD, Page 4-9, Section 4.3.2, states "Therefore, on days when less waste is received the site <br /> can accept more loads of the beneficial reuse materials." Would the number of additional loads <br /> of beneficial reuse material be based on site needs? If the material accepted is for future use, <br /> how would it be handled, stored and tracked?Please explain. <br /> The response provided in the amendment did not fully address the question. Please elaborate on <br /> where the soil will be stockpiled and where the records are maintained. <br /> 2. The JTD, Page 4-9 Section 4.3.1, indicates that the soil needs for daily, intermediate, and <br /> operations layers were added together to derive the maximum contaminated soil limit. <br /> The actual site needs should reflect an average and not a peak amount. Revise to include <br /> a reasonable average tonnage limit. <br /> Title 27 CCR, Section 20686 restricts beneficial reuse materials to"quantities of solid wastes no <br /> more than necessary to meet the minimum requirements". The volumes listed in the chart on page <br /> 4-9, Section 4.3.1, as averages more than cover the site needs to meet the minimum requirements. <br /> Please explain the rationale for maximum needs. The EHD has concerns that the maximum needs <br /> would lead to an over use of the beneficial use materials accepted at the facility. <br /> 3. The JTD, Page 6-1, Section 6.1, states "Forward is proposing to extend the hours of operation <br /> for the landfill to 4 a.m. to 9:30 p.m., with waste receipt stopping at 9:00 p.m."Revise to reflect <br /> current actual hours of operation. <br /> The response provided in the amendment did not fully address the question. Please remove the <br /> wording that indicates that Forward Inc. is proposing to extend the hours of operation. <br /> 4 The JTD, Page 6-13, Section 6.4.6.1,please explain in detail the types beneficial reuse materials, <br /> and how they meet 20686(a) and(b). <br /> The response provided in the amendment did not fully address the question. Please provide an <br /> explanation of how the facility operator plans to meet the T 27 CCR Section 20686 (a)&(b). <br /> Page 1 of 3 <br />