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ENVIRONMENTAL ALTH DEPARTMENT SAN JOAQUIN COUNTY -�f•,. G Unit Supervisors Donna K.Heran,R.E.H.S.N Carl Bor an,R.E.H.S. -X Director 304 East Weber Avenue, Third Floor Mike Huggins,R.E.H.S.,R.D.I. Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. • .. �P• Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. F... Laurie A.Cotulla,R.E.H.S. Fax: (209) 464-0138 Robert McClellon,R.E.H.S. Program Manager Mark Barcellos,R.E.H.S. December 30,2002 Mr.Mark DeBie,Branch Manager CIWMB P.O.Box 4025 Sacramento,CA 995812-4025 RE: CIWMB ADC SURVEY VISIT AT FORWARD,INC.LANDFILL(39-AA-0015) M0'r Dear MreBie: In response to your letter dated December 2, 2002 concerning the Alternative Daily Cover(ADC) survey conducted at Forward, Inc. Landfill, the Environmental Health Department (EHD) has worked with the facility operator to address the survey findings. Each finding is listed below, followed by the EHD response. The facility operator's response letter dated December 20, 2002 is also attached for your review. 1. The lack of sufficient records of ADC usage per Title 27 CCR Section 20690 (a) (5). The site operators were directed to provide a response per your request. The records will be maintained at the site as specified under Title 27 CCR Section 20690(a).The records will include the requirements of Title 14 CCR Section 18802. The records will track the type and amount of ADC used at the site. The site operators indicated that 98% of the ADC used at the site is processed green waste. The tracking of the ADC usage will be part of the planning process for cover needs at the site. The site operators were directed to provide calculations that indicate the rate at which the processed green waste will be used for ADC (see attached letter). 2. The large size of the active face on the day of the survey. The site operators are aware of the need to minimize the size of the working face. The site is small (157 acres) and very active. The site operators have concerns over safe unloading as referenced in Title 27 CCR Section 20630. Additionally,the site operators have been directed by the EHD to minimize and track the size of the working face through utilization of the inspection form developed by Forward, Inc.personnel(see attached letter). 3. Long term availability of sufficient of soil for use as cover. The facility operators have provided calculations for the projected amount of soil cover necessary for site operations. The calculations come from their RDSI from 1993. The calculations indicate that Forward, Inc. Landfill, as currently approved, will not need any off-site soil for daily operations or final closure activities. However, the site is currently in the process of combining with the Austin Road Landfill. If efforts to consolidate the two landfills are successful, the calculations will change. The site will be short on soil and may require importation of soil for 1 closure activities. The new calculations can be found in the proposed JTD for the combined facility.