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• 0 Ash including ash from the Butte fire and ash from other sources;the excavated waste will then have to be containerized, manifested and then disposed of as hazardous waste at a suitable hazardous waste landfill. Excavation of this waste mass will cause significant air emissions with the potential for fires. There would be limited and,perhaps insufficient, lined area to temporarily stockpile the excavated 1.5 million cy of refuse. Attempting to relocate waste of this magnitude will severely impact the ability of the landfill to continue operations. The facility currently consumes approximately 1.1 million cy of airspace in a year,as such it would take over a year to excavate,stockpile waste;identify the ash,safely dispose the ash and then relocate the waste that has been stockpiled. Permitted limits for number of truck loads and hours of operation would have to be waived for at least the one-year time period while removal was occurring. Concurrence by the Local Enforcement Agency would be required in order to waive these requirements. Please note,in reviewing summary tables of Bed Ash Weekly Composite Sample Results(April 2015 through April 2016)and Quarterly Composite Sample Results(1Qtr 2014 through iQtr 2016)provided by WBP to Forward revealed that no test data result exceeded the Total Threshold Limit Concentration(TTLC)for any constituent therefore the dry ash was not hazardous with respect to the TTLC criteria. Soluble Threshold Limit Concentration (STLC)Waste Extraction Test(WET)results(provided by WBR)revealed 8 of the 14 quarterly composite samples had extract(fluid)copper concentration equal to or greater than the STLC non-RCRA hazardous waste criterion of 25 mg/L for copper. The samples were submitted to two independent analytical laboratories which then reported significantly different results for what were presumed to be split quarterly samples. When these differences are taken in account,two of the seven quarterly composite samples exceeded the STLC procedure in both of the reported laboratory results. Please note,the STLC procedure uses citric acid with a pH of 5 as the leaching solution. This is conservative and is not likely for a landfill environment where citric acid is not present and the only fluids likely to contact the ash are precipitation and leachate. In summary, removing the 672 tons of hazardous Bed Ash is infeasible. Up to 1.5 million cubic yards of municipal solid waste including ash from other sources and including ash from the Butte Fire would have to excavated/ removed/stockpiled severely impacting landfill and local waste disposal operations and impacting local air regulations. The estimated cost to excavate and re-locate/stockpile the wastes on site(at Forward)would be over $15M. Please note,the Bed Ash is not readily distinguished in the field which would result in any commingled waste to be also disposed of as hazardous waste. The excavation and removal process will require over one year to complete and would result in a significant impact to local air and ground transportation. Additionally there is no space currently available to properly handle and stockpile the excavated wastes on site. In lieu of removal, Forward is in the process of completing fate and transport modeling to assess the potential impacts of bed ash disposal and preliminary results indicate no measurable effects on groundwater quality. We will transmit the results of this evaluation along with proposed enhancements to the facility leachate and groundwater monitoring program under separate cover. We would like to meet with you in person, at your convenience, to discuss the NOV letter, and the options proposed/included in this response. If you have questions or comments regarding the above information, please contact me at(209)982-4298. Regard 1 ph Lipka Environmental Manager Attachments 9999 South Austin Road Manteca, CA 95336 (209) 982-4298/(209) 982-1009 fax ilipkaArepublicservices.com