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� tti 0 Y ;4 j U N 14 2018 TECHNICAL MEMORANDUM ENV1RQN10FNTAI EA TH _ERT�14E.NT TO: Joseph Lipka/Republic Services FROM: Richard Mitchell/RMC Geoscience SUBJECT: Evaluation of Bed Ash Disposal at Forward Landfill, San Joaquin County, California DATE: November 1, 2016 INTRODUCTION This Technical Memorandum summarizes the results of an investigation of bed ash received from Woodland Biomass Power (WBP) and disposed at the Forward Landfill between the first quarter of 2014 and December 2015. The bed ash was generated by WBP's wood -fired electric generating facility located in Woodland, California. On or about June 2, 2016, WBP notified Forward Landfill it had delivered bed ash to the landfill for the purposes of disposal or beneficial reuse and provided data that indicated approximately 2,431 tons of bed ash was delivered to Forward Landfill between the first quarter of 2014 and December 2015. The WBP letter further stated that "WBP discovered that for certain time periods between April 2014 and December 2015, Bed Ash generated by the Facility and provided to Forward Landfill had levels of copper above the regulatory limits for Non -Hazardous characterization." On June 20, 2016, the CVRWQCB submitted a Notice of Violation (NOV) forthe "illegal acceptance of hazardous waste," that required Forward Landfill to: • Immediately notify the DTSC that hazardous waste was placed in the landfill; • By August 1, 2016 remove all hazardous waste associated with WBP from the landfill; • By August 31, 2016 submit documentation that all WBP-generated hazardous waste had been removed, transported, and disposed in an "appropriately permitted" landfill; • By September 15, 2016, 2016 submit a report that contains: (i) the waste profile and acceptance plan that was in place between April 2014 and December 2015; (ii) the waste acceptance training that was in place between April 2014 and December 2015; (iii) a copy of the Special Waste Service Agreement dated August 29, 2013 between WBP and Republic; and (iv) a copy of all analytical data and shipping manifests from WBP for the period of August 2013 through June 2016.