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0 0 <br /> 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 identifythe 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 />