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TECHNICAL MEMORANDUM <br />Evaluation of Bed Ash Disposal <br />Forward Landfill <br />San Joaquin, California <br />November 1, 2016 <br />Page 2 <br />On July 20, 2016, Republic Services (Republic) submitted a response to the NOV that described <br />the impracticability of selectively excavating the WBP bed ash from the landfill and requested a <br />meeting with CVRWQCB to discuss the NOV and the feasible options available to address <br />CVRWQCB concerns. This meeting was held on August 12 at the CVRWQCB Sacramento office <br />and (among other items) addressed the results of an evaluation of potential water quality <br />impacts associated with bed ash disposal at the landfill. Following the meeting, CVRWQCB staff <br />requested that the potential water quality impact evaluation be documented in a technical <br />report. The results of these evaluations are summarized below. <br />PURPOSE AND SCOPE <br />The objectives of the evaluations described below were to evaluate the potential groundwater <br />quality impacts associated with bed ash disposal and to assess the feasibility of selectively <br />excavating bed ash with Soluble Threshold Limit Concentrations (STLC) greater than 25 mg/L. The <br />scope of work completed to meet these objectives included: <br />• Review of WBP data to assess the amount of bed ash delivered to Forward Landfill <br />between April 2014 and December 2015; <br />• Review of analytical result summaries provided by WBP to evaluate copper <br />concentrations and identify other chemicals of concern that may be present in the bed <br />ash; <br />• Review of Forward Landfill information to identify the disposal locations within the landfill <br />and assess the feasibility of finding and selectively removing the bed ash; and <br />• Completion of an evaluation to assess the potential concentration of copper in <br />groundwater at the point of compliance for the landfill if copper was to leach from the <br />bed ash at approximately the same rate indicated by STLC test data and subsequently leak <br />from the bottom of the landfill. <br />BED ASH CHARACTERISTICS <br />Analytical data provided by WBP included a data summary for quarterly analyses performed for <br />pH and the CAM 17 metals data antimony, arsenic, barium, beryllium, cadmium, chromium, <br />cobalt, copper, lead, mercury, molybdenum, nickel, selenium, silver, thallium, vanadium, and zinc <br />