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Kt:G1t* <br /> MAY 2 3 201 y/ ¢ Eo r.nNec3 gnpw Jp <br /> OOlI00aa1♦ � eMECPFiAav pOURKIUft <br /> Water Boards <br /> Central Valley Regional Water Quality Control Board <br /> 16 May 2017 <br /> Joseph Lipka CERTIFIED MAIL <br /> Forward Landfill 917199 9991 7036 6990 3186 <br /> 9999 South Austin Road <br /> Manteca, CA 95336 <br /> WATER CODE SECTION 13267 ORDER FOR TECHNICAL REPORTS REGARDING <br /> ACCEPTANCE OF HAZARDOUS WASTE, FORWARD LANDFILL, SAN JOAQUIN COUNTY <br /> The disposal of solid waste at the Forward Landfill in San Joaquin County is regulated by Waste <br /> Discharge Requirements (WDRs) Order R5-2014-0006 and Cleanup and Abatement Order <br /> R5-2017-0703. Republic Services Inc. (Discharger) owns and operates the facility. <br /> Summary of Events: <br /> On 14 June 2016, the Discharger notified Board staff that it had accepted and discharged <br /> approximately 6,200 tons of hazardous waste between April 2014 and December 2015. The <br /> material was discharged into Future Units 04, 06, 08, 10, 13 and 14. The waste was ash which <br /> came from Woodland Biomas Ltd. and contained hazardous levels of copper. The generator of <br /> the material, Woodland Biomass, did not receive a"variance"for the discharge of this material <br /> to a Class II Unit from the Department of Toxic Substances Control (DTSC) and therefore this <br /> discharge of hazardous waste is a violation of Discharge Prohibition A.1 of Order R5-2014- <br /> 0006, which states "The discharge of hazardous waste'is prohibited. For the purpose of this <br /> Order, the term 'hazardous waste'is as defined in California Code of Regulations, Title 23, <br /> section 2510 et seq." <br /> On 20 June 2016, staff issued a Notice of Violation (NOV)to the Discharger for the acceptance <br /> of hazardous waste. The NOV required the Discharger to notify the Department of Toxic <br /> Substance Control (DTSC) and remove all hazardous waste from the facility by 1 August 2016. <br /> Additionally, the NOV required the Discharger to submit a Hazardous Waste Removal Report by <br /> 31 August 2016. <br /> On 20 July 2016, the Discharger submitted a response to the NOV. The response stated that <br /> only 672 tons of the original 6,200 tons of waste qualified as hazardous waste. Additionally, the <br /> Discharger stated that removal of the waste was infeasible as it was intermixed with non- <br /> hazardous waste and would require the removal of 1.5 million cubic yards of <br /> overburden/municipal solid waste. Removal of the waste and overburden was estimated to take <br /> over a year and cost in excess of fifteen million dollars. In lieu of removal, the Discharger <br /> submitted a fate and transport model that assessed the potential impacts of the ash on <br /> groundwater quality and proposed to enhance leachate and groundwater monitoring at the <br /> facility. <br /> On 12 August 2016, staff met with the Discharger to discuss the NOV and status of the model, <br /> The Discharger reiterated that removal of the hazardous waste was infeasible and presented <br /> some preliminary findings regarding the fate and transport modeling. Staff explained that the <br /> KARL E Loraotev SCD, P,E . cmmA I PAMEt4 C. CREEDoN P.E., BCEE, EAECUTWE 0MCER <br /> 11020 Sur,Conlon Dywe 0200,Rancho Cordova.CA 95070 i www,waterboards.ce.gov/centraivaNey <br /> L,aCc C•.-�✓nv <br />