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6 <br />from the green waste after it is brought to the site. It is not the feedstock. Sorry for the confusion. The site operator <br />stated that his goal is to get the green waste in to a windrow within 24 hours, but that does not always happen. It is <br />important to properly screen and process the green material prior to placing it into the windrow. It impacts the final <br />product. The residuals are being removed within 24 hours. Please let me know if you have any questions regarding this. <br />Robert <br />Robert McClellon, Program Coordinator REHS <br />San Joaquin County Environmental Health Department <br />Ph (209) 468-0332 <br />Fax(209) 468-8392 <br />From: Laurel L. Impett fmailto:ImpetL@smwlaw.com] <br />Sent: Friday, December 12, 2014 10:05 AM <br />To: Robert McClellon [EH] <br />Cc: dn.rathje@yahoo.com; cleansanjoa uin@gmail.com; dheran@sjehd.com <br />Subject: RE: Forward Inc. Permit <br />Mr. McClellon, <br />We have reviewed the Final Draft Solid Waste Facility Permit ("SWFP") 39 -AA -0020. <br />Section 17 (n) states that wastes to be composted must go directly into the composting operation and may be <br />stockpiled on site for no more than seventy-two (72) hours. <br />This provision — allowing wastes to be stockpiled on site for up to 72 hours -- is unacceptable and is not <br />consistent with your October 10, 2014 letter to me which states that "waste or residuals [are] to be removed <br />within 24 hours." <br />Neither the RCSI or the TPR appear to allow waste to sit on site for 72 hours. In fact, in response to Clean San <br />Joaquin's concerns, you agreed to revise both documents to state that wastes be removed within 24 hours to <br />eliminate odors and vectors and to ensure overall good housekeeping. See e.g., TPR at 2-1, 2-4, 3-4, 3-6, 3-13 <br />and RCSI at 2-6; 3-12, 3-13. <br />We can only assume that this provision in the Final Draft SWFP is an error. We would appreciate clarification <br />of this critical issue as soon as possible. <br />Thank you, <br />Laurel <br />Laurel L. Impett, AICP, Urban Planner <br />Shute, Mihaly & Weinberger LLP <br />396 Hayes Street <br />San Francisco, CA 94102-4421 <br />v: 415/552-7272 <br />f: 415/552-5816 <br />www.smwlaw.com <br />Please consider the environment before printing this e-mail or attachments. <br />GREEN <br />PW MINES$ <br />