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California Regional Water Quality Control Board <br /> Dr. Alan Lloyd Central Valle Re <br /> Secretary for y 81011 (0 <br /> vtronn:ental Robert Schneider,Chair Arnold Sc vernor negger <br /> Governor <br /> rotection <br /> 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> (916)464-3291 •Fax(916)464-4775 <br /> http://www,swreb.ca.gov/rwgcb5 n5 <br /> �U1 <br /> 4 November 2005 NOV _ <br /> 8 2005 <br /> Mr. Curtis Fujii Mr. Robert McClellon ENVIRONMENT <br /> Allied Waste Industries PER T HEALTH <br /> San Joaquin Co. Environ. Health T�I�T�s &ICES <br /> 901 Bailey Road 304 Weber Ave. 3`d Floor <br /> Pittsburg CA 94565 Stockton, CA 95202 <br /> CLASSIFICATION OF WASTE, FORWARD LANDFILL, SAN JOAQUIN COUNTY <br /> There is apparently some misunderstanding of how waste should be classified and managed at Forward <br /> landfill. Waste Discharge Requirements Order No. R5-2003-0049 (WDRs)permit Forward Inc. and <br /> Allied Waste Industries to discharge designated waste, nonhazardous solid waste, and inert waste to <br /> constructed waste management units. All three of these waste classes may be discharged to Class II <br /> waste management units at the facility. while Class III units may not accept designated wastes, even as <br /> -daily or interim cover material. Section 13173 of the Water Code defines designated waste as either of <br /> the following "(a) Hazardous waste that has been granted a variance from hazardous waste <br /> management requirements pursuant to Section 25143 of the Health and Safety Code"; "(b) <br /> Nonhazardous waste that consists of, or contains,pollutants that, under an Dierzt envir�-)nm <br /> en I <br /> conditions at a waste management unit, could be releaseta <br /> d in concentrations exceeding applicable <br /> water quality objectives or that could reasonably be expected to affect beneficial uses of the waters of <br /> the state as contained in the appropriate state water quality control plan." Without a variance from <br /> DTSC, hazardous waste may not be discharged at the Forward facility. Therefore, any nonhazardous <br /> waste that contains soluble constituents that poses a threat to water quality may only be discharged to a <br /> Class II waste management unit. Contaminated soils accepted at the facility for disposal or for use as <br /> cover material must also be classified and managed according to the above requirements. <br /> Monitoring and Reporting Program No. R5-2003-0049 (a part of Forward's WDRs) sets specific <br /> designated levels for soluble cadmium, chromium(VI), copper, lead, mercury, nickel, zinc, TPH- <br /> diesel, TPH-gasoline, and BTEX. The WDRs allow waste containing these constituents to be <br /> discharged to a Class III waste management unit only if the WET extract concentrations are below the <br /> designated levels. Wastes containing these specified constituents at or above the designated levels <br /> may be discharged to Class II units. <br /> The WDRs do not establish designated levels for other constituents. However, all designated waste <br /> must be discharged to a Class II unit. It is the responsibility of the discharger and the landfill to <br /> characterize and classify the waste for appropriate disposal. In 1989, all Class III landfills in the <br /> Central Valley Region were sent information(copy attached) on how to properly classify waste for <br /> acceptance at their facilities. Page 3 of that letter presents a formula for determining designated levels. <br /> aTo further assist in making these determinations, the attached document "Recommended Waste <br /> cceptance Limits for Inorganics at Class III Landfills" (recommended limits) may be used as <br /> California Environmental Protection Agenc <br /> �d Recycled Paper <br />