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k"KLE1 N FELDER August 13, 1992 File: 24 -220025 -LA0 Ms. Carrie Cummings Forward, Inc. P.O. Box 6336 Stockton, CA 95206 SUBJECT: DTSC Report of Violations Forward Landfill Stockton, California Dear Ms. Cummings: On July 17, 1992, the California Department of Toxic Substances Control (DTSC) issued a Report of Violations for the Forward Landfill southeast of Stockton, California. The report was based on inspection of the facility on October 21, 22, and 24, 1991. As a result of the DTSC inspection, violations of hazardous waste regulations were noted (#s I-1, I-2, and 1-3). The violations are listed in DTSC letter dated Julv 17, 1992. 1%1s. Nancy Lancaster of DTSC specifically listed the items of concern in a telephone conversation with Forward, which are summarized below: During sampling of the ®yells, purge ground water was discharged to the around surface. V This item was addressed in the approved Ground Water Sampling and Analysis Plan (SAP), prepared by Eljumaily and Butler Associates (EBA) in August 1988, which is included in the Postclosure Permit as Attachment 1. The plan says on page 2 that during sampling, discharge to the ground may occur. Kleinfelder's Postclosure Plan for WMU A, Addendum No 2, dated August S, 1991 also states that purge water will be discharged to the ground. Since the concentration of volatile organic compounds detected in ground water monitoring at Forward have consistently been low (below DTSC primary maximum contaminant levels (MCLS) for drinking water), Kleinfelder does not believe the discharge of purged water to the ground will pose a risk to the environment or public health. Since the Postclosure Permit was issued, Kleinfelder has assumed sampling responsibility at the landfill and uses their own SAP, which although different, meets or exceeds the sampling protocol described in the EBA SAP and should be considered an addendum to the Forward postclosure permit. The first addendum to the permit was postclosure costs, so the Kleinfelder sampling plan was titled Addendum 2. 2. Depth -to -water measurements were not taken upon completion of purging and sampling to evaluate drawdown. The EBA SAP indicated on page 2 that drawdown measurements will be taken after sampling. Addendum No. 2 to the Postclosure Permit does not address this because Kleinfelder does not see the value of taking drawdown measurements. If during purging, a well dewaters, then this is denoted on the well purge characterization form. FI -2-92-227 Page 1 of 2 CopyTicht 1992 Kleinfelder, Inc. KLEINFELDER W.- Fitt, ,(!o° s,;t -xn ,•ntt). C\ 1'-)32-`�l�r )66- -t-,