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RECEIVED <br /> ENVIRONMENTAL REPUBLIC <br /> H E;-,LT., ,::� IJTMENT f�ISERVICES <br /> Mr.Howard Hold <br /> Acting Supervisor <br /> Compliance and Enforcement Section <br /> Central Valley Regional Water Quality Control Board <br /> 11020 Sun Center Drive,Suite 200 <br /> Rancho Cordova,CA 95670 <br /> April 03,2018 <br /> RE: Notice of Violation for the Illegal Acceptance of Hazardous Waste—Union Pacific Railroad Lime/Soil Mix, <br /> Forward Landfill,San Joaquin County <br /> Dear Mr.Hold: <br /> This letter is being submitted by Forward, Inc. ("Forward"), the owner and operator of the Forward Landfill. <br /> Forward is a subsidiary of Republic Services, Inc.This letter is in response to the Notice of Violation letter issued by <br /> the Central Valley Regional Water Quality Board (CVRWQCB)on 02 March 2018, requesting a summary of actions <br /> that Forward has completed to determine infeasibility of removing the Lime soil mix accepted from a Union Pacific <br /> Railroad facility. <br /> Volume of Hazardous Waste: <br /> In November 2017,Forward approved and then accepted and disposed of approximately 9.1 tons of Lime <br /> comingled with up to 3%debris and soil from the Union Pacific Railroad as a result of a spill on to the ground from <br /> a railcar. As listed on the Special Waste Profile submitted by Union Pacific the pH was initially reported to be 12.8, <br /> however based on the laboratory analyses,the pH of the Lime was 12.6(the upper limit for pH for disposal is <br /> 12.5). The Lime exceeds the Hazardous Waste Criteria(40 CFR261.22/CA Title 22,22-66261.22)for Corrosivity <br /> and is therefore classified as hazardous waste. <br /> The issue was brought to our attention on 26 January 2018,as part of the monthly LEA inspection of Forward by <br /> Robert McClellon,Program Coordinator REHS-San Joaquin County Environmental Health Department(SJCEHD). <br /> An NOV was included in the January inspection report(received 1 February 2018)—the NOV requested a response, <br /> due to be submitted to the LEA no later than 1 March 2018,describing the actions taken to correct the issue <br /> Location of Lime/Soil: <br /> Based on the delivery date of 14 November 2017,the Lime/soil mix was placed in the newly constructed Subtitle <br /> D-lined cell WMU-FU 17(see attached figure showing the approximate disposal location of the Lime). <br /> Removal/Disposal of Lime/Soil: <br /> The 9.1 tons of Lime/soil mix was comingled with approximately 127,130 tons of municipal solid waste(MSW) <br /> along with approved special wastes,including approximately 444 tons of non-hazardous contaminated soil from <br /> other sources and approximately 35,181 tons of cover soil. The average operational density of the landfilled <br /> material following receipt of the Lime/soil mix was approximately 0.70 tons per cubic yard(tons/cy);therefore, <br /> 9999 South Austin Road <br /> Manteca, CA 95336 <br /> (209) 982-4298/(209) 982-1009 fax <br /> ilipka republicservices.com <br />