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STATE OF CALIFORNIA GEORGE DEUKMEJIAN,Governor CALIFORNIA REGIONAL WATER QMLITY CONTROL BOARD— ........ CENTRAL VALLEY REGION 3443 ROUTIER ROAD SACRAMENTO,CA 95827-3098 25 August 1988 2 Mr. Greg Basso AUG 6 1988 Forward Inc. VWROmENTI�L 14EALTH P. O. Box 6336 FERMIT/sERACES Stockton, CA 95206 RECLASSIFICATION OF WASTE MANAGEMENT UNIT (WMU) A AT FORWARD LANDFILL, SAN JOAQUIN COUNTY (CASE NO. 2209) The Regional Water Quality Control Board (Regional Board) is required by Title 23, California Code of Regulations, Chapter 3, Subchapter 15 (Subchapter 15) to reclassify existing waste management units. Subchapter 15 requires the, waste management units be classified according to their ability to hold waste. Section 2530 of Subchapter 15 requires that waste management units comply with the applicable siting criteria given in the Subchapter. Waste management units for hazardous waste (Class I units) are required by Section 2531(b)(1) to be underlain by natural geologic materials which have a permeability of not more than 1 X 10-7 cm/sec, and which are of sufficient thickness to prevent vertical movement of fluid, including waste and leachate, from waste management units to waters of the state as long as wastes in such units pose a threat to water quality. Hydrogeologic data provided for the Forward site indicate that WMU A, which contains hazardous waste, is not located in a geologic setting which meets the siting criteria for a Class I waste management unit. Therefore, you must either remove the wastes, obtain a variance for the waste from the Department of Health Services, or retrofit WMU A with an engineered alternative approved by the Regional Board. As specified in Section 2510 (b), alternatives shall only be approved where the discharger demonstrates that: (1) The construction or prescriptive standard is not feasible as provided in Section 2510 (c), and (2) there is a specific engineered alternative that (A) is consistent with the performance goal addressed by the particular construction or prescriptive standard, and (B) affords equivalent protection against water quality impairment. Section 2510 (c) states that to establish that compliance with prescriptive standards in Subchapter 15 is not feasible, the discharger shall demonstrate that compliance with a prescriptive standard: (1) is unreasonably and unnecessarily burdensome and will cost substantially more than alternatives which meet the criteria in Section 2510 (b); or (2) is impractical and will not promote attainment of applicable performance standards. Subchapter 15 requires the Regional Board to consider all relevant technical and economic factors, including, but not limited to, present and projected costs of compliance, potential costs for remedial action in the event that waste or leachate is released to the environment, and the extent of ground water resources which could be affected.