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9 0 Page 2 of 4 <br /> and safety or the environment.This determination shall be subject to board approval.For the <br /> purposes of this subsection,the enumeration, and the workload analysis, a closed site means a <br /> site that has ceased accepting waste and, should be closed, is undergoing closure, or has met <br /> applicable closure requirements; <br /> From: De Bie, Mark[mailto:Mark.DeBie@CalRecycle.ca.gov] <br /> Sent: Monday,April 11, 20114:03 PM <br /> To: Robert McClellon [EH] <br /> Cc: Benjamin Escotto [EH];Taylor, Kevin <br /> Subject: RE: 39-AA-0048 Martin Dairy insp red staff report.docx <br /> As it a disposal site that has been exempted from the requirements of a permit,the regulations require <br /> monthly inspections. But as you point out it is only operated seasonally so we can approve an alternative <br /> inspection schedule. I'm just trying to figure out what it is that will work. My concern is that while operations <br /> are conducted that the LEA would be conducting and documenting inspections. If there are design or <br /> operational aspects of the disposal activity that warrant even less oversight,we can look at how they might <br /> substitute for direct LEA involvement. <br /> From: Robert McClellon [EH] [mailto:RMcClellon@sjcehd.com] <br /> Sent: Monday,April 11, 20113:53 PM <br /> To: De Bie, Mark <br /> Cc: Benjamin Escotto [EH];Taylor, Kevin <br /> Subject: RE: 39-AA-0048 Martin Dairy insp red staff report.dooc <br /> Mark,we regulate these sites under local ordinance.That is why we visit the sites once a month while in <br /> operation (always have). If the operator does not plan to operate the site,we make a site visit and confirm that <br /> the site is not being used.We could do as you suggest and conduct the monthly inspections, on state forms, <br /> during operations. I wasn't sure that was going to work on your end though. Robert <br /> From: De Bie, Mark[mailto:Mark.DeBie@Ca[Recycle.ca.gov] <br /> Sent: Monday,April 11, 20113:43 PM <br /> To: Robert McClellon [EH] <br /> Cc: Benjamin Escotto [EH];Taylor, Kevin <br /> Subject: RE: 39-AA-0048 Martin Dairy insp red staff report.docx <br /> Robert—so you don't want to go to once a year,but monthly while they are operating? Would the <br /> following be an appropriate way to describe the new inspection frequency? <br /> The LEA will conduct monthly inspections of the facility only during the time that wastes are received <br /> and disposed. The inspections will begin each year during the month of first receipt of waste and will <br /> conclude after the last receipt of waste has been disposed. It is expected that site handling and disposal <br /> activities will be start and conclude during a three month period each year. <br /> From: Robert McClellon [EH] [mailto:RMcClellon@sjcehd.com] <br /> Sent: Monday,April 11, 20113:38 PM <br /> To: De Bie, Mark <br /> Cc: Benjamin Escotto [EH];Taylor, Kevin <br /> Subject: FW: 39-AA-0048 Martin Dairy insp red staff report.docx <br /> The site is only operated for 3 months a year.We can inspect it in the off season, but no operation will be <br /> there.We inpect it monthly during the active season, but that is not quaterly. I do not want to waste time <br /> and effort looking at an empty field.This was an issue during our evaluation.Just trying to clean things up. <br /> The reason why we do not want to inspect quarterly is there is no reason to inspect quaterly.Thanks <br /> Robert. <br /> From: Benjamin Escotto [EH] <br /> 4/12/2011 <br />