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0 0 <br /> Geo-Lo is <br /> ASS0CIATES� <br /> June 27, 2017 <br /> Mr. Brendan Kenny <br /> Engineering Geologist <br /> Central Valley Regional Water Quality Control Board <br /> 11020 Sun Center Drive, Suite 200 <br /> Rancho Cordova, CA 95670 <br /> CVRWQCB WATER CODE SECTION 13267 ORDER FOR TECHNICAL REPORTS REGARDING <br /> ACCEPTANCE OF HAZARDOUS WASTE, FORWARD LANDFILL, SAN JOAQUIN COUNTY, <br /> CALIFORNIA <br /> Forward Landfill <br /> San Joaquin County,California <br /> Dear Mr. Kenny: <br /> The following letter was prepared by Geo-Logic Associates (GLA) on behalf of Forward, Inc. <br /> (Forward) to request clarification for items included in the May 16, 2017, Central Valley <br /> Regional Water Quality Control Board (CVRWQCB) Water Code Section 13267 Order for <br /> Technical Reports Regarding Acceptance of Hazardous Waste at Forward Landfill. This waste <br /> included bed ash that was received from Woodland Biomass Power (WBP) and disposed within <br /> Subtitle D-lined waste disposal units at the Forward Landfill between the first quarter of 2014 <br /> and December 2015. The bed ash was generated by WBP's wood-fired electric generating <br /> facility located in Woodland, California. The CVRWQCB Order is attached. <br /> BACKGROUND <br /> On or about June 2, 2016, WBP notified Forward Landfill it had delivered bed ash to the landfill <br /> for the purposes of disposal or beneficial reuse and provided data that indicated approximately <br /> 2,431 tons of bed ash was delivered to the landfill between the first quarter of 2014 and <br /> December 2015. The WBP letter further stated that "WBP discovered that for certain time <br /> periods between April 2014 and December 2015, Bed Ash generated by the Facility and <br /> provided to Forward Landfill had levels of copper above the regulatory limits for Non- <br /> Hazardous characterization." <br /> On June 20, 2016, the CVRWQCB submitted a Notice of Violation (NOV) for the "illegal <br /> acceptance of hazardous waste,"that required Forward Landfill to: <br /> • Immediately notify the DTSC that hazardous waste was placed in the landfill,- <br /> By <br /> andfill;By August 1, 2016 remove all hazardous waste associated with WBP from the landfill; <br /> • By August 31, 2016 submit documentation that all WBP-generated hazardous waste had <br /> been removed,transported, and disposed in an "appropriately permitted" landfill; <br /> 11415 W.Bernardo Court,Suite 200,San Diego,California• T 858.451.1136 • F 858.451.1087 • www.geo-logic.com <br />