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i • • By September 15, 2016, 2016 submit a report that contains: (i) the waste profile and acceptance plan that was in place between April 2014 and December 2015; (ii) the waste acceptance training that was in place between April 2014 and December 2015; (iii) a copy of the Special Waste Service Agreement dated August 29, 2013 between WBP and Republic; and (iv) a copy of all analytical data and shipping manifests from WBP for the period of August 2013 through June 2016. On July 20, 2016, FORWARD submitted a response to the NOV that described the impracticability of selectively excavating the WBP bed ash from the landfill and requested a meeting with CVRWQCB to discuss the NOV and the feasible options available to address CVRWQCB concerns. This meeting was held on August 12, 2016 at the CVRWQCB Sacramento office and (among other items) addressed the results of an evaluation of potential water quality impacts associated with bed ash disposal at the landfill. Following the meeting, CVRWQCB staff requested that the potential water quality impact evaluation be documented in a technical report. The results of these evaluations were documented in a November 1, 2016 Technical Memorandum that concluded: • Selective excavation of the WBP bed ash is not feasible and removal of the bed ash would require that virtually all the 1.68 million tons of co-disposed municipal solid waste (MSW) in the bed ash disposal area would be necessary to remove the bed ash.' An excavation and offsite disposal of this amount of material would cost tens of millions of dollars (or more) and would result in significant adverse environmental impacts due to truck traffic, temporary suspension of landfill gas extraction in the excavation area, and increased probability of subsurface fires;z and • The potential leaching of copper from the bed ash and subsequent leakage (should it occur) would have no measurable effect on groundwater quality below or adjacent to the site. The November 1, 2016 Technical Memorandum is attached to this letter for reference. 'Depending on depths of burial,the total amount of excavation could exceed 1.7 million tons due to excavation slope requirements. Z Offsite disposal of 1.68 million tons of waste could require about 67,000 truckloads and more than 21 million roundtrip vehicle miles assuming a hauling capacity of 25 tons per truck and disposal at the Kettleman Hills Landfill (the closest Class I landfill to Forward Landfill) Forward Landfill Response to CVRWQCB 2 Date:June 24,2017