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• . Draft Supplemental Environmental Impact Report Page IV.G-14 • Forward Inc. Landfill 2018 Expansion Project The Forward Landfill exaction and treatment system use the extracted water for landfill operations. However, they recently had a violation cited by the RWQCB (May, 2018). The treatment and discharge of treated groundwater at the Forward Landfill in San Joaquin County • is regulated by Waste Discharger Requirements (WDRs) Order R5-2003-0080. The RWQCB . noted that the VOC concentrations reported in Q4-2018 and Q1-2018 are a violation of Discharge Specification B.4. of Order R5-2003-0080, which states "Treated effluent discharged to the infiltration gallery shall have non-detect levels of VOCs using EPA Method 8260." Various water quality violations have been cited by the Water Board since 2015. The RWQCB requested that on or before May 31,2018, Republic Services submit a report certifying that the discharge of treated groundwater is in compliance with Order R5-2003-0080. • Based on analytical laboratory testing results from October 27, 2017, the influent to the • groundwater treatment system contained 6.98 µg/L of VOCs. Based on totalizing flow meter • readings, an estimated 21.2 million gallons of extracted groundwater was treated during the first quarter 2018, yielding approximately 0.63 pounds of VOCs removed during this period. Treated effluent discharged into the infiltration pond contained trace concentrations of up to four VOCs in the monthly effluent samples. In addition, cis-1,2-dichloroethene, PCE, and TCE • were consistently measured above the practical quantitation limit during the fourth-quarter . monitoring event. Total VOC concentrations in the effluent ranged from 3.29 to 3.46 µg/L during the monitoring period. • Forward Unit The groundwater quality at the Forward Unit, as indicated by monitoring wells, is generally good. Occurrences of low level volatile organic compounds are detected above drinking water • standards in the areas of the unlined Austin unit of the Forward Landfill and downgradient to • it. VOCs are not typically detected at the monitoring wells near the lined portions of the Forward Landfill. Therefore, the Forward Landfill liner and leachate collection system appears to have adequate integrity (i.e., are not leaking). Environmental monitoring for the first quarter of yielded results similar to previous quarters. Currently, water quality impacts at the Forward Unit are limited to a few wells north of the closed Class I WMU A unit that show low level concentrations of VOCs,mainly at trace levels and well below safe drinking water standards. The WMU A unit does not contain a "Subtitle D" • liner and LCRS. Some exceedances of inorganic constituent CLs were detected at the Forward Unit in the first quarter of 2009. Historically, similar exceedances of inorganic CLs have been measured and • verified in samples collected from detection monitoring program wells, followed by no release . demonstrations, which have concluded that the inorganic CL exceedances are likely the result of naturally occurring conditions and therefore not indicative of a release from the landfill. In an attempt to reduce the number of false positive results, Forward is proposing to update the CLs • for the Forward Unit.