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n <br />Ed Padilla <br />Page 3 of 4 <br />Additional Comments <br />- The existing permit does not discuss the items listed below, <br />however, the draft permit does. <br />■ The receipt of dewatered cannery waste, industrial <br />waste, dead animals, sewage sludge, and nonhazardous <br />ash. <br />These items can be considered a significant change <br />depending on the amount of waste received. For <br />example, if receipt of dead animals refers to those <br />found on the side of the road this would not constitute <br />a significant change. However, truck loads of dead <br />animals would be a significant change. <br />■ Change in the hours of operation from 7:30 a.m. - <br />4:30 p.m. to 7:00 am. - 7:00 p.m. <br />Please submit the following documents: the Water SWAT <br />report and an application for a permit. When submitting the <br />application please include the date it was received and <br />accepted by your office. The application should be <br />consistent with the draft permit. <br />The Engineering Review Report dated December 1988 frequently <br />references other documents. The Board's policy is that it <br />be a "stand-alone" document. I recommend that all pertinent <br />information be extracted from the referenced documents and <br />included as an appendix to the document. <br />Board staff has concerns regarding the facility's role in <br />meeting AB 939 waste diversion requirements. I am unable to <br />recommend concurrence in the issuance of a SWFP if it is <br />determined that the issuance of the proposed permit would <br />prevent or substantially impair achievement of the <br />requirements prescribed in PRC 41780. This section requires <br />each city or county to implement a schedule which will <br />divert 25 percent of all solid waste from landfill or <br />transformation facilities by January 1, 1995, and 50 percent <br />by January 1, 2000, through source reduction, recycling, and <br />composting. Please provide information substantiating this <br />facility's role in developing the city/county's waste <br />diversion requirements. If you have any questions regarding <br />this issue, please contact Cathy Donahue of the Board's <br />Local Assistance Branch at (916) 327-5704. <br />