COMPLIANCE INFO - Laserfiche WebLink

Home Browse Search

RECEIVED ENVIRONMENTAL REPUBLIC H E;-,LT., ,::� IJTMENT f�ISERVICES Mr.Howard Hold Acting Supervisor Compliance and Enforcement Section Central Valley Regional Water Quality Control Board 11020 Sun Center Drive,Suite 200 Rancho Cordova,CA 95670 April 03,2018 RE: Notice of Violation for the Illegal Acceptance of Hazardous Waste—Union Pacific Railroad Lime/Soil Mix, Forward Landfill,San Joaquin County Dear Mr.Hold: This letter is being submitted by Forward, Inc. ("Forward"), the owner and operator of the Forward Landfill. Forward is a subsidiary of Republic Services, Inc.This letter is in response to the Notice of Violation letter issued by the Central Valley Regional Water Quality Board (CVRWQCB)on 02 March 2018, requesting a summary of actions that Forward has completed to determine infeasibility of removing the Lime soil mix accepted from a Union Pacific Railroad facility. Volume of Hazardous Waste: In November 2017,Forward approved and then accepted and disposed of approximately 9.1 tons of Lime comingled with up to 3%debris and soil from the Union Pacific Railroad as a result of a spill on to the ground from a railcar. As listed on the Special Waste Profile submitted by Union Pacific the pH was initially reported to be 12.8, however based on the laboratory analyses,the pH of the Lime was 12.6(the upper limit for pH for disposal is 12.5). The Lime exceeds the Hazardous Waste Criteria(40 CFR261.22/CA Title 22,22-66261.22)for Corrosivity and is therefore classified as hazardous waste. The issue was brought to our attention on 26 January 2018,as part of the monthly LEA inspection of Forward by Robert McClellon,Program Coordinator REHS-San Joaquin County Environmental Health Department(SJCEHD). An NOV was included in the January inspection report(received 1 February 2018)—the NOV requested a response, due to be submitted to the LEA no later than 1 March 2018,describing the actions taken to correct the issue Location of Lime/Soil: Based on the delivery date of 14 November 2017,the Lime/soil mix was placed in the newly constructed Subtitle D-lined cell WMU-FU 17(see attached figure showing the approximate disposal location of the Lime). Removal/Disposal of Lime/Soil: The 9.1 tons of Lime/soil mix was comingled with approximately 127,130 tons of municipal solid waste(MSW) along with approved special wastes,including approximately 444 tons of non-hazardous contaminated soil from other sources and approximately 35,181 tons of cover soil. The average operational density of the landfilled material following receipt of the Lime/soil mix was approximately 0.70 tons per cubic yard(tons/cy);therefore, 9999 South Austin Road Manteca, CA 95336 (209) 982-4298/(209) 982-1009 fax ilipka republicservices.com