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JUL-25-2001 04:48P FROM:CWR INDUSTRIES 2093692703 TO:4688392 P:1/2 <br /> It AV <br /> RtCEI'VED <br /> JUL 2 6 2001 <br /> Memormd= I.- A <br /> E Ing D�-]Psnl- <br /> To: Steven Shih,San Joaquin County Public Health Services <br /> CC: Aaron Leach,Jose Baffaza,TU Scotts Company <br /> From: Jack Mori,California Waste Rcwvcjy Systems <br /> OnW. 07/25/2001 <br /> Re: Amendment to Report of Compost Site Information <br /> Steven; <br /> I have reviewed the Public Resources Code and Title 14 of the CPATvffl <br /> regulations per our conversations earlier today. Having done this,I strongly believe <br /> t4ojs reasonable interpretation of the current regulations to allow the County to <br /> ake request made in the Scotts Company letter dated July 19, 2001. <br /> Jj*0C.and as I mentioned,the other approach to consider is compliance with the <br /> condition Which requires, "Y be processed at <br /> 72 h f <br /> ours o arrival on site'through interpretation of the PRC definition <br /> 0, 0000rig". Public Resources Code Section 40172 est "Processing means <br /> ofi-1. <br /> - ---------- <br /> ! <br /> separation, recovery, conversion, or recycling of solid w aste' Once <br /> tl* ' is received at the Scotts facility it will be inspected for evidence of <br /> 0 contamination, and consolidated into a stockpile configuration in preparation <br /> f"nding and screening. These initial steps fit into the definitions of separation <br /> and reduction. <br /> After reviewing the various sections of Title 14,1 continue to believe that the <br /> regulations allow for precisely the type of amendment we are proposing. Article 3, <br /> Section 17863 of Title 14(Report of Composting Site Information)says that an initial <br /> Report of Composting Site Information(RCSI)must be filed with the LEA at the <br /> time the original solid waste permit is issued. This section states that an RCS1 shall <br /> include the following;(f) . . . description of maximum and average storage time. <br /> Therefore,I believe that it can be safely concluded that those it included as the <br /> LEA <br /> Co do fisted on the final page oft a original pernift are actually the initial <br /> RCSI conditions. The same section of Article 3 of Title 14 also states that any <br /> intended change to the feedstock must be reported to the LEA so as to maintain the <br /> permit status. The regulation then states that such a change may become the is for <br /> a revision to the permit. Lastly,note that item#9 of the LEA Can&tzons gives the <br /> LEA the authority to modify this permit. <br /> . ..... ........ <br />