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Mr. Greg Basso -2- 29 November 1988 1. WMU F must be constructed in compliance with Waste Discharge Requirements Order No. 88-023, including the monitoring and reporting provisions of the Order. 2. The CQA testing must be conducted as specified in the EBA plan and the results submitted in the final construction report. 3. Waste discharge to the surface impoundment is limited to leachate from WMUs D and E and surface runoff from portions of WMU A. Discharge of off-site liquid waste or leachate from sumps under WMU A to the surface impound- ment is prohibited . The final construction report, including CQA data and complete details of liner penetration testing, must be submitted and approved by Board staff prior to discharge of any waste to the surface impoundment. In our letter of 21 November 1988 regarding the WMU D landfill expansion, it was our understanding that you intend to discharge ash and asbestos south of the interior dike in the expansion area. Asbestos may also be discharged north of the dike in compliance with your WDRs. The important point of our 21 November 1988 letter was that the method by which you classify ash for disposal in WMU D depends on whether the ash will contact acidic landfill leachate. If ash is comingled or covered with waste capable of generating acidic leachate (e.g. municipal solid waste) then a standard Waste Extraction Test (WET) [Title 22, California Code of Regula- tions, Section 66700] must be used to determine soluble constituent concentrations in the ash. Ash monofilled or codisposed with waste that is not capable of producing acidic leachate (e.g. asbestos) may be tested using the WET method substituting deionized water for the extraction solution. If you have any questions on this subject, please call Steve Rosenbaum at (916) 361--5732. Ji t WILLIAM J. MARSHALL, Chief Waste Discharge to Land Unit SER: