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4STATE OF CALFORNIA—CALIFORNIA EWRONAAEs OPROTECTON AGENCY VM WILSON. r <br /> -DEPARTMENT OF TOXIC SUBSTANCES CONTROL <br /> REGION I <br /> CROYDON WAY, SURE 3 <br /> NTO, CA 95827-2106 <br /> �! P'01_ <br /> Mr. Michael Feeley, Chief <br /> Permits & Solid Waste Branch <br /> U.S. Environmental Protection Agency <br /> Region IX EH-3] <br /> 95 Hawthorne Street <br /> San Francisco, California 93305 <br /> QUEST FOR REVIEW OF PROPOSED SIMPLIFIED POST-CLOSURE PERMIT <br /> MODIFICATION FOR THE FORWARD DFILL, EPA I.D. I CAD990794133 <br /> Dear Mr. Feeley: <br /> Enclosed for your review and approval is a copy of a Draft <br /> Post-Closure Permit Modification that the Department of Toxic <br /> Substances Control ( SC) has developed for the Forward Landfill, <br /> located near Stockton, California. <br /> This Draft Permit Modification utilizes a simplified <br /> approach to drafting permit documents without compromising the <br /> legal basis and enforceability of the document. It incorporates <br /> by reference all applicable regulatory requirements. In <br /> contrast, historical permit documents have employed numerous <br /> lengthy conditions which paraphrased and cited the regulations. <br /> DTSC believes that the simplified format approach, as <br /> proposed in the enclosed document,, is preferable to the <br /> historical model. The advantages to be gained by adopting this <br /> new format as a model for future permits include: <br /> * A simpler (and shorter' permit document. This will <br /> make the permit much more "user friendly" -for both the <br /> permittee and the regulating agency. <br /> A By referencing and incorporating all applicable <br /> regulations, and not relying on individual permit <br /> iters to completely and accurately write all the <br /> otherwise necessary conditions into the permit, the <br /> potential for permit enforceability problems will be <br /> AHq�rl�n¢ ,Z <br />