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d _ <br /> California Farm Bureau Federation <br /> 1601 Expc)sition Boulevard r jalramcnto►, Cg 85815 • Telephone(916)924.4000 <br /> HAND DELIVERED <br /> January 6, 1988 <br /> Mr. Timothy Crandall <br /> Project Engineer <br /> California Regional Water Quality <br /> Control Board <br /> Central Valley Region <br /> 3443 ibutier Road <br /> Sacr mento, California 95827-3098 <br /> Re Tentative Vaste Discharge <br /> Requirements for Forward, <br /> Incorporated, Waste Management <br /> Facility Class II Landfills, Class <br /> III Landfills, Class II Surface <br /> Impoundment, Land Treatment Unit, <br /> San Joaquin County <br /> Dear -Mr. Crandall: <br /> This letter is in response to the California legional Water Quality Control <br /> Board request of December 11, 1987, for written comments or recommendations <br /> regarding the Tlentative Waste Discharge Requirements for the Forward Incor- <br /> porated Waste Management Facility. California Farm Bureau Federation and San <br /> Joaquin Farm Bureau Federation' (collectively "Farm Bureau") hereby express <br /> their objection to the proposed disposal of wastes containing greater than one <br /> percent friable asbestos in Forward, Incorported Waste Management Units "D" and <br /> "H." <br /> It is my understanding that neither above TV= will have an impermeable lower <br /> liner. I further understand that it is the position of your office that <br /> although friable asbestos is a known carcinogen, listed as a toxin under 22 <br /> C.A.C. 66680, and under 22 C.A.C. 66699(b) as an "inorganic persistent and <br /> bioaccumulative toxic substance," the absence of evidence conclusively <br /> establishing that asbestos fibers are carcinogenic or toxic when ingested <br /> orally justifies its disposal in landfills without impermeable lower liners. <br /> C <br /> I note that the ground water level at the subject diposal site is shallow, -� <br /> reported by your office to stand at approximately 50 feet below the land sur- <br /> face. Such a shallow ground water reservoir is vulnerable to contamination, <br /> and .it appears to us that concern for the public health and long-term economic_`- <br />