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TECHNICAL MEMORANDUM Evaluation of Bed Ash Disposal Forward Landfill San Joaquin, California November 1, 2016 Page 3 between the beginning of 2010 and the end of 2015.1 WBP did not provide copies of the laboratory analytical reports and it is not known whether other constituents were analyzed. The WBP data summary is included in Appendix A. Table 1 provides a statistical summary of the analytical results and shows that no tested constituent exceeded its respective Total Threshold Limit Concentration (TTLC). Therefore, the bed ash is not hazardous with respect to TTLC criteria and the tested constituents. However, STLC Waste Extraction Test (WET) results showed that some of the samples met or exceeded the non-RCRA soluble hazardous waste criterion of 25 mg/L for copper. As shown by the WBP data included in Appendix A and summarized in Table 1, no other tested constituent exceeded its STLC regulatory threshold. BED ASH DELIVERY AND DISPOSAL Table 2 summarizes the amount of bed ash delivered and disposed at the landfill between the first quarter of 2014 and the fourth quarter of 2015 and includes WBP quarterly bed ash TTLC and STLC data for the same period of time. The bed ash delivered to the site by WBP was not segregated and was co -disposed with other wastes, including about 201,000 tons of ash from the Butte Fire. As indicated in Table 2, the amount of landfilled WBP bed ash was about 2,431 tons, or about one tenth of one percent of the total 1,683,604 tons of waste landfilled during the same period. All the bed ash was placed in Forward Units (FU) FU -04, FU -06, FU -08, FU -10, FU -13, and F-14 in the four areas shown in Figure 1 and no bed ash was placed in the pre -Subtitle D portion of the landfill. These units were all constructed with Subtitle -D liners that include leachate collection and recovery systems (LCRS) that convey the leachate to perimeter sumps. As shown in Table 2, bed ash accepted during the first three quarters of 2014 was disposed in Area 1 and Area 2. The amount placed in each area is not known; as a result, the evaluations summarized below assumed 50 percent of the bed ash received during this period was placed in Area 1 and 50 percent was placed in Area 2. FEASIBILITY OF EXCAVATION If it is assumed the ash was uniformly distributed, it would occur in layers less than 0.1 -foot -thick at different elevations (or depths of burial) across the total of the four disposal areas shown in 1 CAM refers to the California Administrative Manual, also known as the California Code of Regulations (CCR). CCR Title 22 §66261.24 specifies the 17 metals that can qualify waste as hazardous.