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Robert McClellon October 8, 2014 Page 2 Forward would take when a load has a strong odor. We can find no indication that the July TPR or the July RCSI address this issue. Moreover, language relating to Forward's Odor Impact Monitoring Plan has been stricken from the July TPR. The Landfill Expansion Project Final EIR includes a mitigation measure that requires Forward to modify its Odor Control Management Plan to include daily management odor inspections when cannery wastes are being processed. Final EIR at II -15, 2-16. We request that the TPR and RCSI be revised to include a provision requiring daily odor inspections of Forward's composting facility. Finally, the 2014 RCSI states (at 3-14) that "odors are controlled by processing the wastes and removing them as soon as possible after they have been brought into the RRF." Yet, the RCSI also states (at 2-6) that residual wastes will be hauled to the landfill at the end of each day or within 48 hours. Allowing waste to sit unprocessed for 48 hours has the potential to result in significant odor impacts. We request that the TPR and RCSI be revised to require that residual wastes be hauled to the landfill at the end of each day or within 24 hours. II. Debris and Litter from Forward's Facility Has the Potential to Adversely Impact Neighboring Properties. Forward's operations have the potential to result in litter impacts to neighbors. See Landfill Expansion Project Draft EIR at II -44. The June 18, 2014 letter from EHD to Forward states that Forward should provide the Litter Plan or delete reference to the Plan. Forward's July TPR and July RCSI remove the references to the Litter Management Plan but do not include provisions sufficient to ensure proper litter management. Instead, the 2014 RCSI (at 3-16 ) simply states that litter is collected on a daily basis and placed in the landfill. The Landfill Expansion Final EIR (at II -47, 48) includes numerous measures to protect neighboring properties. In order to ensure that litter from Forward's operations do not adversely impact neighboring properties, these measures, set forth below, should be included in the TPR and RCSI: Daily inspection will be conducted to control litter on- and off-site, including the North and South Branches of the South Fork of Little Johns Creek, approach roads, entrance facilities, the transfer station/resource recovery facility, portable litter control fences, landfill perimeter fence, leachate impoundments, and storm water facilities including ditches, berms, and detention/sedimentation basins. All trucks will be tarped upon entering and exiting the facility. This policy will be strictly enforced. In accordance with San Joaquin County Ordinance No. 28870, SHUTE, MIHALY C`-°WEINBERGERu.p