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Geo -Logic <br />ASSOCIATES <br />February 28, 2025 <br />Mr. Howard Hold, PG <br />Mr. Brendan Kenny, PG <br />Central Valley Regional Water Quality Control Board <br />11020 Sun Center Drive, Suite 200 <br />Rancho Cordova, CA 95670 <br />RESPONSE TO DECEMBER 17, 2024 NOTICE OF VIOLATION <br />Forward Landfill, GeoTracker No: L10008827999 <br />San,baauin Countv, California <br />Dear Mr. Hold and Mr. Kenny: <br />Geo -Logic Associates (GLA) prepared this letter report on behalf of Forward Landfill, Inc. <br />(Forward) to document the removal and disposal of a non -conforming load that was <br />delivered to the landfill on November 6, 2024 in error under a non -hazardous manifest. This <br />material was associated with a site cleanup, performed by Clean Harbors, to address a <br />transformer leak of about one gallon onto a concrete slab at a PG&E facility in Stonyford, <br />California. On receipt at the landfill, the approximately 2.17 -ton load of mixed soil and <br />concrete was placed in an existing stockpile on the top lift of a disposal area overlying the <br />Austin Road Unit of the landfill. <br />After the material had been received and placed in the existing stockpile, the generator <br />(Clean Harbors) notified Forward that a sample of the waste material had an Aroclor 1242 <br />concentration of 399.0 mg/kg on Friday, December 6, 2024. On Monday, December 9, 2024, <br />Forward Landfill notified the Central Valley Regional Water Quality Control Board <br />(CVRWQCB) of this result, and on December 17, 2024, the CVRWQCB issued a Notice of <br />Violation (NOV) that included a requirement to submit a report documenting that all <br />hazardous waste has been removed from the site and disposed of properly. The NOVfurther <br />required that the report include copies of characterization records, excavation records, <br />hauling manifests, and disposal manifests. <br />This letter acknowledges the violation as presented in Section III of the NOV and describes <br />corrective actions as required in Section IV of the NOV. As required in Section IV of the NOV, <br />this document presents soil handling and excavation records (Attachment 1), <br />characterization records (Attachments 2 & 3), and hauling manifests (Attachment 4). <br />