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Mr. Padilla <br />Page 7 of 7 <br />Additional Comments <br />- Staff reviewed the financial assurance mechanism and <br />determined that it does not meet the requirements of 14 CCR <br />18284 and 18285. <br />- Tentative or final WDRs should be issued for the subject <br />site. <br />- All concerns identified by the Regional Water Quality <br />Control Board must be addressed. <br />- When the WDRs are issued the RDSI must be updated to reflect <br />the additional requirements. <br />- The facility must be in full compliance with state minimum <br />standards before Staff can recommend concurrence in the <br />issuance of a SWFP. <br />Board staff has some concern regarding the facility's <br />ability to meet the waste diversion requirements. CIWMB can <br />not concur on a solid waste facilities permit which would <br />prevent or substantially impair achievement prescribed in <br />PRC 41780. Please provide information substantiating this <br />facility's role in helping the city/county achieve waste <br />diversion requirements. <br />- Please be sure the operator submits an amended application <br />with the changes and which is signed by both the owner and <br />operator before submitting the permit to our office. <br />- Because of deficiencies in the RDSI, additional review will <br />be required to incorporate necessary changes. It is also <br />important that all supporting documents be consistent. For <br />example, the information contained the permit, RDSI, <br />application, and the WDR must be consistent with one <br />another. When resubmitting the RDSI follow the procedure <br />described in the PSR section. <br />Thank you for giving me the opportunity to comment. If you have <br />any questions, please contact me at (916) 255-2434. <br />Sincerely, <br />Beatrice Cuenca <br />Waste Management Specialist <br />Permits Branch <br />Permitting and Compliance Division <br />(A):\SanJoaqu\002 <br />