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0 0 <br /> TECHNICAL MEMORANDUM <br /> TO: Joseph Lipka/Republic Services <br /> FROM: Richard Mitchell/RMC Geoscience <br /> SUBJECT: Evaluation of Bed Ash Disposal at Forward Landfill,San Joaquin County, California <br /> DATE: November 1, 2016 <br /> INTRODUCTION <br /> This Technical Memorandum summarizes the results of an investigation of bed ash received from <br /> Woodland Biomass Power(WBP) and disposed at the Forward Landfill between the first quarter <br /> of 2014 and December 2015. The bed ash was generated by WBP's wood-fired electric <br /> generating facility located in Woodland, California. On or about June 2, 2016, WBP notified <br /> Forward Landfill it had delivered bed ash to the landfill for the purposes of disposal or beneficial <br /> reuse and provided data that indicated approximately 2,431 tons of bed ash was delivered to <br /> Forward Landfill between the first quarter of 2014 and December 2015. The WBP letter further <br /> stated that "WBP discovered that for certain time periods between April 2014 and December <br /> 2015, Bed Ash generated by the Facility and provided to Forward Landfill had levels of copper <br /> above the regulatory limits for Non-Hazardous characterization." <br /> On June 20,2016,the CVRWQCB submitted a Notice of Violation(NOV)for the"illegal acceptance <br /> of hazardous waste,"that required Forward Landfill to: <br /> • Immediately notify the DTSC that hazardous waste was placed in the landfill; <br /> • By August 1, 2016 remove all hazardous waste associated with WBP from the landfill; <br /> • By August 31, 2016 submit documentation that all WBP-generated hazardous waste had <br /> been removed,transported, and disposed in an "appropriately permitted" landfill; <br /> • By September 15, 2016, 2016 submit a report that contains: (i) the waste profile and <br /> acceptance plan that was in place between April 2014 and December 2015; (ii)the waste <br /> acceptance training that was in place between April 2014 and December 2015;(iii)a copy <br /> of the Special Waste Service Agreement dated August 29, 2013 between WBP and <br /> Republic; and (iv) a copy of all analytical data and shipping manifests from WBP for the <br /> period of August 2013 through June 2016. <br />