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NEW COMMENTS <br /> 11. The JTD,Appendix C-1, page 1 of 5,uses a 4 to 1 ratio to figure site soil needs for daily and <br /> intermediate cover.Using the 4 to 1 ratio the soils need total 1440 cubic yards/day. On page 4 of <br /> 5 of Appendix C-1 using a volumetric calculation the site needs total 1222 cubic yards per day. <br /> The volumetric calculation is figuring 12-inch layer of cover material. Title 27 CCR Section <br /> 20690 requires that a minimum of 6 inches of soil be used as daily cover. The EHD feels that the <br /> more conservative number is more indicative of site use considering the calculation is for daily <br /> and intermediate cover. Please provide calculations that are consistent and accurate. <br /> 12. The JTD, page 4-8, Section 4.3.1,states that"Forward reviewed 2005 weight and volume records, <br /> which provided the maximum daily need for each material."In 2005 Forward Landfill was cited <br /> 9 times for T 27 CCR, Section 21600,for issues related to the over use of ADC and beneficial use <br /> materials. The year 2005 is not an acceptable base year for calculations to determine site needs. <br /> 13. The JTD index is incorrect. The pages do not correspond to the index. Please revise and correct <br /> the index to reflect the proposed changes. <br /> 14. The EHD is still reviewing Forward Inc.'s letter of May 2, 2006 regarding site life. A separate <br /> letter addressing site life concerns will be sent after a thorough <br /> If you have any questions regarding this matter, you can contact me at(209) 468-0332 <br /> �� ...Gk�_.. <br /> Robert McClellon, Supervising REHS <br /> Environmental Health Department <br /> Cc: Howard Levenson, California Integrated Waste Management Board <br /> Keith Kennedy, California Integrated Waste Management Board <br /> David Irey, San Joaquin County, Deputy District Attorney <br /> Lochlin Caffey, Allied Waste Systems <br /> John R. Boucher, Bryan A. Stirrat& Association <br /> Page 3 of 3 <br /> I <br />