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'f. ,1% 1 .0 0 STATE OF CALIFORNIA PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— CENTRAL VALLEY REGION 3443 ROUTIER ROAD, SUITE Ag ° SACRAMENTO, CA 95827-3098 PHONE: (916) 361-5600 FAX: (916) 361-5686 APR 1 5 1992 'fit_Irv'V "'.i e p .d f..... ; ?.-. ra i L, 10 April 1992 Mr. Ed Padilla Environmental Health Division San Joaquin County Public Health Services P. O. Box 2009 Stockton, CA 95201 FORWARD LANDFILL, SAN JOAQUIN COUNTY (CASE NO. 2209) We have received a request from Forward Inc. to reclassify Waste Management Unit D-89 from a Class III landfill to a Class II landfill. We see several advantages to reclassifying Unit D-89. Reclassification would simplify waste acceptance pro- cedures, optimize the use of a lined landfill, and make Class II disposal capacity available in San Joaquin County. Reclassification would not change the waste stream discharged to -89, but it would simplify the current process of approving wastes for discharge. Currently, Forward requests approval from Regional Board staff to take non-hazardous wastes on a case- by-case basis. This procedure is time consuming because we are required to evaluate potential water quality impacts of waste constituents as if D-89 was a typical Class III landfill. If D-89 was reclassified, then the waste acceptance criteria would be simplified, so the conditions on waste acceptance in D-89 could be specified in waste discharge requirements (WDRs). We propose that the revised WDRs would increase the acceptable concentration levels for metals and mineral salts, but not volatile organic compounds (VOCs). Unit D-89 has a four-foot thick compacted clay liner with a permeability of 10-6 cm/s or less and a blanket leachate collection and removal system (LCRS). Although this liner exceeds the minimum construction standards contained in California Code Regulations, Title 23, Division 3, Chapter 15 for Class II landfills, we would not increase the acceptable VOC concentrations due to their potential to migrate through clay liners. Therefore, the acceptance of VOCs would be limited to current levels. The current and proposed limits for selected constituents are shown below as an example. The limits are based on soluble concentrations as determined by the waste extraction test method (WET) in Title 22. The WDRs would also limit maximum total constituent concentrations in waste in addition to soluble concentrations.