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' r <br /> STATE OF CAUFpRNIA GEORGE DEUKMEJIAN.Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROADe <br /> SACRAMENTO,CA 95827-3098 • ^"'' <br /> 19 February 1987 <br /> Mr. John Stovall <br /> Attorney at Law <br /> Neumiller & Beardslee jai ami ��LT <br /> 509 West Weber AvenueL . ' ' <br /> Stockton, CA 95203 <br /> FORWARD, INC. - SAN JOAQUIN COUNTY (CASE NO. 2209) <br /> The purpose of this letter is to clarify more fully: 1) the classification of the <br /> Forward facility under provisions in the California Administrative Code, Title 23, <br /> Chapter 3, Subchapter 15 (Subchapter 1 ), and 2) my 22 January 1987 letter to <br /> Greg Basso. In 1973, the Regional Board classified Forward as a Class II-1 <br /> Disposal Facility (Order No. 73-183) . A revision of Subchapter 15 was enacted in <br /> 1984. This revision contained a new classification and permitting scheme. <br /> Instead of adopting waste discharge requirements (WDRs) for a whole facility, the <br /> Regional Boards must now write WDRs for individual waste management units (WMUs) <br /> within a waste management facility ( F) . A WMU can be a landfill, a surface <br /> impoundment, a waste pile, or a land treatment area. <br /> In the case of Forward, the whole site is still technically a Class II-1 Solid <br /> Waste Disposal Site, not a permitted Class III site as stated in your letter of <br /> 2 February 1987. To change this classification, Class II-1 WMF operators have two <br /> choices under Subchapter 15. They may either upgrade some or all existing Wigs to <br /> Class II, or request that WMUs not accepting designated wastes be classified as <br /> Class III. In either case, the site operator must file a Report of Waste Dis- <br /> charge requesting the classification. Since the newly constructed landfill was <br /> built after the revision of Subchapter 15, it is considered to be a new WMU and <br /> must comply with the current version of Subchapter 15. My 22 January 1987 letter <br /> would have been clearer if I had said that I inspected a new WMU that will be <br /> operated as a landfill accepting nonhazardous solid waste. <br /> If you have any questions, please contact me at (916) 261-5737. <br /> TIMOTHY CRANDALL <br /> Project Engineer <br /> TAC:c ab <br /> cc: Mr. Ray Leclerc, Department of Health Services, Sacramento <br /> California Waste Management Board, Enforcement Division, Sacramento <br /> Ms. Carolyn Richardson, California Farm Bureau Federation, Sacramento <br /> Ms. Lisa Brown, Office of the District Attorney, Stockton <br /> Mr. Jack McCollough, Beta Associates, San Jose <br /> Mr. Greg Basso, Forward Inc. , Stockton <br /> San Joaquin County Local Health District, Stockton <br />