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0 0 MAY 16, 2017 CVRWQCB ORDER On May 16, 2017, the CVRWQCB issued a Water Code Section 13267 Order for Technical Reports Regarding Acceptance of Hazardous Waste at the landfill that requires: "Leachate, LCRS Sump, Pan Lysimeter Monitoring. Effective 1 July 2017, Republic Services Inc. shall implement semi-annual monitoring for pH and dissolved inorganics/metals (as identified in Table VIII of MRP 115-2014-0006) from all leachate sumps and pan lysimeters associated with Future Units 4,6,8, 10, 13 and 14. These leachate sumps are identified as WMU FU- 04, 06, 08, 13, and 14. The pan lysimeters are identified as FU04, FU05, FU06 and FU10. The results of the monitoring shall be included with the Quarterly Monitoring Report corresponding to the quarter in which the monitoring occurred. Groundwater Sampling. Effective 1 July 2017 and continuing quarterly, Republic Services shall analyze groundwater samples collected from existing upgradient groundwater monitoring well AMW-2 and existing downgradient monitoring wells AMW-1, AMW-4 and AMW-7 for the dissolved inorganics/metals listed in Table VIII of Monitoring and Reporting Program 115-2014-0006.The results of the monitoring shall be included with the Quarterly Monitoring Report corresponding to the quarter in which the monitoring occurred. Effective Immediately, Republic Services shall report the tonnage and sampling results for all ash received at the landfill on a quarterly basis. The tonnage of ash and sampling results shall be tabulated and include the regulatory threshold limits for all waste constituents such that determination of the waste as non-hazardous waste is readily identifiable. The tabulated results shall be submitted with the Quarterly Monitoring Reports." The CVRWQCB Order also implies that a variance from the Department of Toxic Substances Control (DTSC) is required for the landfill to comply with Waste Discharge Requirements (WDRs) Order 115-2014-0006. REQUEST FOR CLARIFICATION As indicated above, the CVRWQCB Order requires leachate and groundwater analyses for the dissolved inorganic and metal monitoring parameters identified in Table VIII of MRP R5-2014- 0006. Table 1 summarizes these parameters with respect to regulatory total threshold limit concentrations (TTLC) and soluble threshold limit concentrations (STLC),the results of WBP bed ash analytical results, and the geometric mean of the analytical results as a percentage of the TTLC and STLC values. As shown in this table: There are no TTLCs or STLCs for aluminium, cyanide, iron, and tin. There are also no bed ash data for these constituents. Therefore, there is no rational method available to assess potential WBP bed ash-related impacts associated with these constituents; and Forward Landfill Response to CVRWQCB 3 Date:lune 24,2017