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Ms. Claudia Gemberling July 21, 2006 Page 3 of 6 the preparation of EIR's for landfills: hllp://www.ciwmb.ca.gov/LEACentral/CEQA/diMosal.htm, and for transfer/processing stations: http://www.ciwmb.ca.gov/LEACentral/CEQA/Transfer.htm. Days and Hours of Operation The NOP states on page 1-2 that noise from heavy equipment would be restricted to the hours of 6:00 a.m. to 10:00 p.m. if nearby residences are impacted by noise, otherwise there would be no restrictions imposed on the use of heavy equipment. Page 2-63 proposes to extend the use of large equipment on the landfill and in the transfer station, and any activity involving movement of earth, refuse, or refuse -derived materials, to 5:30 a.m. to 7:00 p.m. The project also proposes to allow the use of the landfill facility by County or other authorized personnel for other uses at any time. Such uses are described as administrative tasks, equipment maintenance, operation of environmental control facilities, and use of construction equipment as needed to maintain compliance with other permit requirements. In the DEIR be very specific regarding the days and hours of operation. Clearly identify the days and hours the facility is open to the public, the days and hours of waste receipt, the days and hours of waste processing, and the days and hours of other site activities. Peak Tonnage The NOP indicates the proposed maximum disposal tonnage to be 1,200 tpd, but not the peak daily tonnage received. The issuance of a Solid Waste Facilities Permit (SWFP) will require that peak daily tonnage received be proposed and analyzed in the DEIR. All material, except equipment and supplies, which pass over the scale, must be analyzed for in the environmental document. Traffic and Related Transportation System Impacts_.,__ The issuance of a SWFP will require that peak daily vehicle counts be proposed and analyzed in the DEIR. This includes refuse trucks, self -haul vehicles and employee vehicles. Page 1-2 of the NOP proposes to "increase the maximum incoming vehicle trip limit from 600 to 850 vehicles per day." Typically, one vehicle trip equals two vehicles (1 -inbound & 1 -outbound); please specify in the DEIR the peak daily vehicle count anticipated to access the site. On site traffic circulation and the cumulative effect of traffic for the proposed project should also be discussed in detail in the DEIR. Transfer Station Include a full discussion of the operations at the transfer station in the DEIR. For example, is the load checking procedure different in the transfer station since they take self haul? Is different equipment used? Will there be an increase in tons received at the transfer station? Where are metals, CRTs, etc. taken when accumulated. Materials Recovery & Recycling Describe the materials recovery operations in the DEIR. Discuss in detail the types of materials, the volume, the on-site storage location and storage time limits of the materials separated for recycling and waste diversion. Alternative Daily Cover If the use of additional Alternative Daily Covers (ADC) is proposed, discuss the specific types of ADC proposed for use at this landfill and any positive or negative impacts from the use of the types of ADC proposed for use in the DEIR. Acceptable Waste Indicate in the DEIR the types of waste to be accepted as well as those types of waste to be excluded. Discuss load checking/screening procedures. Describe procedures for handling hazardous waste and/or Household Hazardous Waste (HHW) that may come in self -haul and commercial loads that are not U:\Allstaff\CEQA\2006 DOCS\COUNTIES\San Joaquin-39\Comment Letters\2006062113 North County Recycling & SLF NOP.doc