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Mr. Curtis Fujii -2- <br />Mr. <br />2 - <br />Mr. Robert McClellon <br />27 October 2005 <br />guidance in determining whether a waste is designated for the constituents presented. Due to the depth <br />to groundwater and the types of vadose zone soils beneath the Forward facility, the "High" attenuation <br />levels on this chart would be appropriate. Designated levels for other constituents not called out in <br />WDRs or noted in the recommended limits table may be calculated using the formula on page 3 of the <br />attached letter and the water quality limits published on the Region 5 website at <br />http://www.waterboards.ca. gov/centralvalley/available_documents/index.html4WaterQualityGoals. <br />This guidance should be viewed as a starting point. Characteristics of each site will determine which <br />wastes can safely be discharged to a Class III unit and which wastes must be discharged only in a Class <br />II unit. <br />Regional Board staff understands that not establishing designated levels for most constituents in <br />facility WDRs has resulted in a level of misunderstanding. To resolve this we propose to revise the <br />facility MRP to incorporate the recommended limits. The MRP can be revised without a public <br />hearing so this could happen fairly quickly. Until the revision can be completed, all parties should <br />treat the recommended limits as designated levels. Forward should propose to the Regional Water <br />Board any changes to the recommended limits with justification by 1 December 2005. <br />If you have any questions, please call me at (916) 464-4614 <br />ROSS D. ATKINSON <br />Associate Engineering Geologist <br />cc: Mr. Geno Yekta, CIMWB, Sacramento. <br />Mr. Lochlin Caffey, Forward Inc. Stockton <br />RDA;C:\MyDocuments\Forward\desigW steCl ass.doc <br />