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19 MW <br />�,ai <br />_kyr /!7a"e <br />an onty <br />Environmental Health Department <br />1868 East Hazelton Avenue <br />Stockton, California 95205-6232 <br />Website: www.sjgov.org/ehd <br />Phone: (209) 468-3420 <br />Fax: (209) 464-0138 <br />October 10, 2014 <br />Laurel L. Impett <br />Shute, Mihaly Weinberger LLP <br />396 Hayes Street <br />San Francisco, CA 94102 <br />Subject: Solid Waste Permit 39 -AA -0020 <br />Dear Ms. Impett, <br />FILE COny <br />DIRECTOR <br />Donna Heran, REHS <br />PROGRAM COORDINATORS <br />Robert McClellon, REHS <br />Jeff Carruesco, REHS, RDI <br />Kasey Foley, REHS <br />Linda Turkatte, REHS <br />Rodney Estrada, REHS <br />Adrienne Ellsaesser, REHS <br />The Environmental Health Department (EHD) has received your letter of October 8, 2014. In your letter, you <br />raised several concerns regarding the proposed Transfer Processing Report (TRP) and Report of Compost <br />Information (RCSI) documents. I have reviewed your letter and have met with the operator. The operator has <br />agreed to incorporate some of your concerns into the TPR, RCSI or possibly address concerns with a condition <br />in the Draft Solid Waste facility Permit (DSWFP). The responses to your concerns are listed below: <br />1. How will Forward monitor loads for odors and the action Forward would take when a load has a strong <br />odor: Please refer to Page 3-12, of the July TPR, Section 3.2.8. It states, "Incoming loads that are <br />extremely odorous are rejected." <br />2. The suggestion that the site conduct daily odor inspections will be added to the RCSI. The Odor <br />.Management Impact Plan (OMIP) will be revised to include daily odor inspections. Currently the document <br />reads weekly odor inspections. <br />There appears to be conflict regarding processing wastes and removing them as soon as possible and the 48 <br />hour removal of residuals. The TPR and RCSI will be revised to require that the waste or residuals to be <br />removed within 24 hours. <br />4. Daily litter inspections to control onsite and offsite litter impacts: The following condition will be added to <br />the DSWFP, "Litter inspections shall be conducted each day. The areas that should be inspected are the <br />North and South Branches of the South Fork of Little Johns Creek, approach roads, entrance facilities, <br />transfer station/resource recovery facility, any portable litter fence, facility perimeter fence, leachate <br />impoundment and stonn water facilities including ditches, berms and detention/sedimentation basins." <br />5. All trucks will be tarped upon entering and exiting the facility: Page 3-10, Section 3.2.3 states, "Incoming <br />loads are required to be covered." The operator has provided a letter dated November 15, 2012, that they <br />sent to all of the regular haulers regarding vehicle tarping (attached). <br />6. Management of daily working face: This is transfer station and compost site. A working face is typically <br />referred to in a landfill setting where waste is tipped or disposed of. The transfer station has a building that <br />is open on one side. Unloading of waste occurs in that building. <br />7. Windy days and tipper location: The transfer station and compost site is not equipped with a tipper. <br />