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t <br />STATE OF CALIFORNIA GEORGE DEUKMEJIAN, Governor <br />CALIFORNIA REGIONAL WATER QUALITY CONTROLBOARD- <br />CENTRAL VALLEY REGION <br />3443 ROUTIER ROAD <br />SACRAMENTO, CA 95827 3098 '"' <br />11 July 1989 <br />Mr. Greg Basso Mr. Tom Woodward <br />Forward Inc. EBA Wastechnologies <br />P. 0. Box 6336 P. 0. Box 4600 <br />Stockton, CA 95206 Santa Rosa, CA 95402 <br />FORWARD LANDFILL, SAN JOAQUIN COUNTY (CASE NO. 2209) <br />We have reviewed EBA's design report and construction quality <br />assurance (CQA) plan for landfill waste management unit <br />(WMU) D89. The proposed landfill unit is regulated as an <br />expansion of waste management area D as described in the <br />facility's waste discharge requirements (WDRs). The proposed <br />unit is an 8.7 acre Class III landfill with a bottom liner <br />consisting of 4 feet of compacted clay with a dendritic <br />leachate collection and removal system (LCRS). The <br />construction of WMU D89 is planned in three phases beginning <br />with a 3.9 acre phase north of existing WMU D88. Phases II <br />and III will extend the unit to within 75 feet of the <br />facility's northern property line. <br />We note that the design report and plans are not signed or <br />certified as required by the facility's WDRs. <br />We also note the use of the term "designated waste" in <br />describing the types of waste which may eventually be <br />discharged to the northern portions of WMU D89. Designated <br />waste is not permitted in a Class III landfill. Your <br />prcposed landfill design is based on isolating certain wastes <br />which are not capable of generating acidic leachate, such as <br />coal ash, from acidic leachate generated by refuse in the <br />southern portion of the landfill. Under these circumstances, <br />ash which is not a designated waste when tested by the Waste <br />Extraction Test (WET) using deionized water would be suitable <br />for discharge to the northern portion of WMU D89. Waste <br />which was not a designated waste when analyzed by the <br />standard WET method using citrate buffer could be codisposed <br />with nonhazardous solid waste in the southern portion of the <br />unit. In both cases, the soluble constituents in the waste <br />must be below designated levels for this facility. <br />