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0 the Lime/soil mix was comingled with approximately 235,233 cubic yards of landfilled material. Selective removal of the Lime/soil mix would not be feasible because the waste mixture would not be distinguishable from other wastes accepted at the Forward Landfill. In order to remove the 9.1 tons of Lime/soil mix,Forward would have to remove all of the MSW comingled with the Lime/soil mix;the excavated waste will then have to be containerized, manifested,and then disposed of as hazardous waste at a suitable hazardous waste landfill. Excavation of this waste mass will cause significant air emissions with the potential for landfill fires,dust,and odors. There is currently limited available lined area to temporarily stockpile the excavated 235,000 CY of refuse. In addition,because it will take several months to excavate the 235,000 CY of refuse in an attempt to access the Lime/soil,the incoming waste(approximately 100,000 cy/month)would also need to be disposed in a lined area and there is insufficient remaining constructed lined capacity at the site for both the temporary stockpile and incoming waste. This severely impacts the ability of the landfill to continue operations. If the excavated 235,000 cy of refuse was transported offsite,it would affect the surrounding communities and significantly impact local air and ground transportation. The permitted limits for number of truck loads and hours of operation would have to be waived for at least the time period while removal was occurring. Concurrence by the Local Enforcement Agency would be required in order to waive these requirements. In summary,removing the 9.1 tons of hazardous Lime/soil mixture is infeasible. Incoming refuse and up to 235,000 cubic yards of MSW including non-hazardous soils from other sources would have to excavated,removed and stockpiled—severely impacting landfill and local waste disposal operations,creating the potential for landfill fires,disturbing neighboring properties with the odors,generation of dust associated with excavating large quantities of MSW,and impacting local air regulations. These impacts would be so significant as to potentially require environmental analysis under CEQA. Furthermore,the estimated cost to excavate,re-locate,and stockpile the MSW would be,conservatively,in excess of$2.4M. Because it would be nearly impossible to distinguish the Lime/soil mixture from other non-hazardous excavated waste, Forward would have to transport and dispose of all of the excavated MSW at a disposal site permitted to accept hazardous waste. The estimated cost of transportation and disposal would be well in excess of$20 Million. With respect to the hazard level of the 12.6 pH Lime/soil mix,this material has been comingled with non- hazardous contaminated soils and other waste material.Combining these materials with the Lime/soil mix has most certainly buffered the Lime/soil to below the 12.5 pH limit threshold.This lowered pH level will further hinder any effort to distinguish or segregate the Lime/soil mix from other MSW. In addition,the lined cell and leachate collection system provide a closed loop system for containment and management of any elevated pH containing materials or liquids. In lieu of removal,Forward is respectfully requesting to complete a fate and transport model to assess the potential impacts of the Lime/soil mixture disposal at Forward. Preliminary results indicate no measurable effects will occur on groundwater quality. We will transmit the results of this evaluation under separate cover. We would like to meet with you in person, at your convenience, to discuss the NOV letter and the options proposed/included in this response. If you have questions or comments regarding the above information, please contact me at(209)982-4298. Regard f l�nvironmental h Li a Manager Attachment 9999 South Austin Road Manteca, CA 95336 (209)982-4298/(209) 982-1009 fax ilipka republicservices.com