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• • <br /> RECEIVED <br /> JUN 14 2018 <br /> ENVIRONMENTAL MR <br /> HEALTH DEPAFTJ�IIENT � W REPUBLIC <br /> bA6 SERVICES <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 /> July 20,2016 <br /> RE: Notice of Violation for the Illegal Acceptance of Hazardous Waste, Forward Landfill,San Joaquin County <br /> Dear Mr. Kenny: <br /> This letter is being submitted by Forward, Inc. ("Forward"), the owner and operator of the Forward Landfill. <br /> Forward, Inc. is a subsidiary of Republic Services, Inc. This letter is in response to the Notice of Violation letter <br /> issued by the Central Valley Regional Water Quality Board(CVRWQCB)on 20 June 2016 and the e-mail sent 19 July <br /> 2016 requesting a summary of actions that Forward has completed to determine infeasibility of removing the Bed <br /> Ash accepted from Woodland Biomass Power, Ltd(WBP)facility. <br /> Volume of Hazardous Waste: <br /> Forward received a letter dated June 9"',2016 from Woodland Biomass Power, Ltd. (WBP),informing Forward that <br /> "WBP discovered that for certain time periods between April 2014 and December 2015, Bed Ash generated by the <br /> Facility and provided to Republic had levels of Copper above the regulatory limits for Non-Hazardous <br /> characterization." Forward received a total of 6,205.43 tons of ash,which included Fly Ash(which was not <br /> hazardous)and the Bed Ash,from WBP during this period.On July 15,2016,WBP confirmed that only 672 tons of <br /> ash sent to Forward Landfill for disposal exceeded the thresholds for copper. <br /> Location of Bed Ash: <br /> Based on the delivery dates,and disposal locations used in 2014 and 2015,the Bed Ash was placed in Subtitle D- <br /> lined areas, Forward Unit(FU)—04,-06,-08,-10,-13, -14 during this period(see attached figures provided by GLA <br /> showing the disposal locations of the Bed Ash). Based on these disposal locations,the volume of refuse to be <br /> removed to access the Bed Ash was then calculated. The refuse volume was calculated by evaluating isopachs <br /> generated from quarterly surveys of the area in question from the 2nd Quarter 2014 to the 4`h Quarter 2015 and <br /> developing a boundary around the area;the boundary area was limited by the specific areas of the site where the <br /> ash would have been placed.The bounded area was compared with the April 2016 topographic map;a 2:1 slope <br /> was assumed to be required to excavate down to the bounded area. The estimated volume of refuse to be <br /> removed was 1.55 million cubic yards(mcy). Please note the estimate did not account for settlement,and fluffing <br /> of waste,which would increase the amount of overburden to be removed. <br /> Removal/Disposal of Bed Ash: <br /> The Bed Ash was comingled with municipal solid waste(MSW);Bed Ash accepted after October 2015 was <br /> comingled with debris,including 201,000 tons of ash resulting from the Butte Fire Selective removal of the Bed <br /> Ash would not be feasible because the ash is not distinguishable from other ash accepted at the Forward Landfill. <br /> In order to remove these 672 tons of ash, Forward would have to remove all of the MSW comingled with the Bed <br /> 9999 South Austin Road <br /> Manteca, CA 95336 <br /> (209) 982-4298/ (209) 982-1009 fax <br /> ilipka republicservices.com <br />