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John Funderburg, Principal Planner ' October 30, 201 g Pulte S landfill-related contamination, all domestic and t:hnn irrigation wells within a rcasonable distance mutt be tested_ I Nor does the SDEI R provide any information about the effects of the Ocvntanhinated p.►roundw•ater plume on nearby agricultural lands. The area surrounding the cont. landfill is primarily a ►ricultw•al. There are numerous agricultural supply wells and (cont.) p Y 6 ' distribution tanks in the area. SDEIR at TV,G-4. The SDEiR fails to identify nearby wells dial provide water for these agricultural operations, let alone disclose whether any of ' these wells are contaminated.The SDEIR's failure to evaluate threats to agricultunal operations from contnininated groundwater is a glaring omission. The Cental Valley Water Board explants that the landfill's current water ' extraction system is not(1)controlling the ongoing release of VOCs from migrating beyond the paint of compliance; (2)preventing the VOC plume fivin migrating further downg,radient, (3)overcoming the artificial draw created by the nearby pumping wells; or restoring the beneficial uses of the a uifcr in all zones affected b the release. Exhibit (4) res g q Y OB f Clean Up and Abatement Order R5-2017-07031.Until Forward can demonstrate that it call inrplcnhertt a system to ensure that no VOCs will be present in the groundwater beyond the landfill boundw-ies the SDEIR lacks the evidentiary,basis to conclude that impacts relating to groundwater quality will be less than significant. Clearly, the County should deny any permit far additional waste disposal until Forward can demonstrate that ' the groundwater contamination has been fully abated. 2. Surface Water The SDEIR's conclusion that impacts to surface water quality would be less than significant also does not withstand scrutiny. The SDEIR acknowledges that the Project would result in significmit impacts to surface water quality if erosion from soil stockpiles ' and landfill surfaces is not properly controlled,or if inadvertent spills of mfuse or other substances occur. SDEIR at iV.0-17; IV.G-1 S. it goes on to state that this contamirinteti water could migrate to Littlejohn Creek and flow downstream to the San Joaquin River. Id. Yet, in lieu of analyzing the specific consequences to these waterways, the document ' 4O explains that water managenhent promlures are proposed art part of the Project. Specifically, die 5UylR Ino;ti tthe prepmation of hydraulic and dr ina p study that ' would culminate iib an undefined"project design feature"to control drainage run-on and runoff SDEIR at MG-17.The SDEIR makes two fundamental mistakes. First, it relies on a measure that would allegedly reduce the Project's:, impacts on ' surface water quality yet it provides no analysis or evidentiary support for why this nreasus•e wchuld be effective, A conclusion regarding the significance of an environnhcnttal S N-II I I I A l_Y ' 1h(tl.ih�Itl.hiC;l:Riir