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i� Draft Supplemental Environmental Impact Report Page VIII-59 Forward Inc.Landfill 2018 Expansion Project J. Responses to Shute Mihaly and Weinberger(Clean San Joaquin) Letter J-1. The states that SDEIR acknowledges that the Project would have the potential to impact groundwater quality,but it fails to support the determination that that these impacts will not be significant. The measures included as part of the project described in the SDEIR Impacts IV.G4 and G-6 have been vetted by, and are under continued review of,the Central Valley Regional Water Quality Control Board (CVRWQCB). The CVRWQCB is the agency responsible for the assessment of groundwater impacts from the landfill, and it controls those potential impacts through compliance with its Waste Discharge Requirements(WDR) orders.As a condition of project approval,Forward would be required to obtain additional WDRs for the proposed new lined cells before they can be operated. The potential groundwater impacts from the proposed expansion would be mitigated to a less-than-significant level by combination of the implementation of mitigation measures described following the stipulation of the WDRs, along with the CVRWQCB-approved design of landfill liners and leachate collection systems at both the in southern and northeastern proposed expansion areas, as described in the SEIR. J-1a. This comment discusses the legacy groundwater issues associated with the unlined portion of the Former Austin Road Landfill (Austin Unit). The Austin Road Landfill was purchased by Forward from the City of Stockton(City)in 2000. At that time an area of groundwater contaminated with volatile organic compounds(VOCs)had been identified as originating from the unlined Austin Road Landfill. Pursuant to its agreement with the City, Forward took over the responsibility from the City for monitoring and remediating this pre-existing plume under supervision of the CVRWQCB,the lead agency responsible for oversight of groundwater monitoring and remediation activities associated with the Forward Landfill. In contrast to the unlined Austin Road Landfill and older Forward Landfill units, the proposed Project includes the addition of lined landfill areas or "cells." The lined landfill cells would be designed and constructed in accordance with current federal and state Subtitle D standards.The effectiveness of Subtitle D landfill liners in preventing leakage is well documented and,therefore,the lined cells would not contribute to the existing legacy groundwater issues associated with the old unlined landfill cells. See further discussion in the Response to Item J-1B. The CVRWQCB issued Cleanup and Abatement Order R5-2017-07-03 in 2017(CAO)to address groundwater impacts from the VOCs associated with the Former Austin Road Sanitary Landfill (Austin Road Unit).The Austin Road Unit was unlined and did not operate leachate collection and removal systems.The Austin Road Unit is now overlain f by waste management units (WMUs)that are lined and contain those systems. Dissolved-phase VOCs impacts from the Austin Road Unit have been documented in groundwater downgradient of the site to the northeast. Extensive site investigation and assessment activities have been conducted to delineate the extent of VOC impacts with