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I John Funderburk;, Principal Planner ' October 30,2018 Page 3 1 Lns Angales UrliTed School L)istriel ii. t'irt-of 1.•nc 41�gelev(1, IMified")(1997)58 Cal. App.4th 1019. 1025-26. ' The SDLIR concedes that flit Projcct could exacerbate the VOC-contaminated groundwat.cr phone;because the additional landfill Acreage would allow for more leachate ' generation. SDEIR at 1V.G-21. This leachate could further contaminate the underlying grocurdwatcr due to"a ccmibination of potential spills, leaks, (and) failurres of one sort or another, despile the cQntrals in place."Id. (emphasis added), Despite this vague ' acknowledgement,the document fails to conduct the necessary analysis to determine the likelihood of spills, leaks and failures impacting groundwater as a result of the Project. Nor does the SDEIR disclose the actual and specific; consequences to groundwater quality should a spill or leak occur, i.e.,how a spill would affect the turrebon and habitat of nearby waterbodies such as Littlejohns Creek. OVOCs,once in the envirunmcnt,do not readily break down artd can remain for ' (cont.) long periods of limfi e.Exhibit A (Baseline Report). The landll's history of VOC cuntandrialion is a case in point. VOCs were detected in area groundwater wells years agu. SDEIR at 111-18. After years of effort to contain the contamination, the plume continues to spread. Yet, rather than clearly disclose that Forward remains unwilling or unable to protect nearby properties from exposure to contaminated groundwater, the SDEIR attempts to mask it. Indeed,die SDEIR would have us believe that the ' groundwater contamination problem has mostly been solved (see SDEIR at 111-32, referring to VOC removal in the past tense; SDEIR at IV.E-4,referring to a 2008 abatement order calling for Forward to implement source control to prevent VOCs front migrating past the landfill; and SDEIR at IV.G-6, stating that "there have been no reported detectable VOCs in the surface water samples collected in the recent samples"). The California Regional Water Quality Control Board, however, tells a very different ' story. According t.o a 2017 Abatement Order, Forward "consistently violate fs] the t%OC afJly�nl limit."See California Regional Water Quality Control Board central Valley Itegion (C'entini Valley Water Board) Clean Up and Abatement Order R5-2017-0703 For For%%rd lac, and Repuhlic Services, Inc.,(emphasis added) attached as Exhibit B. ' In the few instances in which the SDEIR does acknowledge contaminated gmundwater, it downplays any potential impacts. For example,regarding the geographic extent of the landfill's contaminated groundwater,the SDEIR states that the limits of ,A ffected groundwater appear to be Well conswwined both laterally and veixically. SDEIR at IV.G-13;IV.G-1 d. Here, too,the Central Valley Water Board dii-ectly contradicts the SDEIR: "The plume-continues to migrate past die Point of-Compliance,defined below. ' and is potentially impacting other domestic wells, which were previously thought to be outside of the plume." Exhibit B at 2 (Clean Up and Abatement Order R5-2017-0703). In ' SHUTI:, KIIIIALY WL INK)-_ I