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�N, <br />CaliforniaRegional ater Quality Control Board <br />Dr. Alan Lloyd <br />Secretaryfor <br />Lnvironmental <br />':Protection <br />4 November 2005 <br />Mr. Curtis Fujii <br />Allied Waste Industries <br />901 Bailey Road <br />Pittsburg CA 94565 <br />Central Valley Region <br />Robert Schneider, Chair <br />191 <br />Arnold Schwarzenegger <br />Governor <br />11020 Sun Center Drive #200 Rancho Cordova, CA 95670-6114 <br />(916) 464-3291 • Fax (916) 464-4775 <br />http://wwwswrcb.ca.gov/rwgc65 <br />NOV 82005 <br />Mr. Robert McClellon ENVIRONMENT HEALTH <br />San Joaquin Co. Environ. Healthl MfMICES <br />304 Weber Ave. 3rd Floor <br />Stockton, CA 95202 <br />There is apparently some misunderstanding of how waste should be classified and managed at Forward <br />landfill. Waste Discharge Requirements Order No. R5-2003-0049 (WDRs) permit Forward Inc. and <br />Allied Waste Industries to discharge designated waste, nonhazardous solid waste, and inert waste to <br />constructed waste management units. All three of these waste classes may be discharged to Class II <br />waste management units at the facility. while Class III units may not accept designated wastes, even as <br />daily or interim cover material. Section 13173 of the Water Code defines designated waste as either of <br />the following: "(a) Hazardous waste that has been granted a variance from hazardous waste <br />management requirements pursuant to Section 25143 of the Health and Safety Code "; "(b) <br />Nonhazardous waste that consists of, or contains, pollutants that, under- arrrbient environmental <br />conditions at a waste management unit, could be released in concentrations exceeding applicable <br />water quality objectives or that could reasonably be expected to affect beneficial uses of the waters of <br />the state as contained in the appropriate state water quality control plan." Without a variance from <br />DTSC, hazardous waste may not be discharged at the Forward facility. Therefore, any nonhazardous <br />waste that contains soluble constituents that poses a threat to water quality may only be discharged to a <br />Class II waste management unit. Contaminated soils accepted at the facility for disposal or for use as <br />cover material must also be classified and managed according to the above requirements. <br />Monitoring and Reporting Program No. R5-2003-0049 (a part of Forward's WDRs) sets specific <br />designated levels for soluble cadmium, chromium (VI), copper, lead, mercury, nickel, zinc, TPH- <br />diesel, TPH-gasoline, and BTEX. The WDRs allow waste containing these constituents to be <br />discharged to a Class III waste management unit only if the WET extract concentrations are below the <br />designated levels. Wastes containing these specified constituents at or above the designated levels <br />may be discharged to Class II units. <br />The WDRs do not establish designated levels for other constituents. However, all designated waste <br />must be discharged to a Class II unit. It is the responsibility of the discharger and the landfill to <br />characterize and classify the waste for appropriate disposal. In 1989, all Class III landfills in the <br />Central Valley Region were sent information (copy attached) on how to properly classify waste for <br />acceptance at their facilities. Page 3 of that letter presents a formula for determining designated levels. <br />To further assist in making these determinations, the attached document "Recommended Waste <br />cceptance Limits for Inorganics at Class III Landfills" (recommended limits) may be used as <br />California Environmental Protection AAenc <br />Ca Recycled Paper <br />