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Draft Supplemental Environmental Impact Report Page IV.G-13 Forward Inc. Landfill 2018 Expansion Project 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,which have been addressed by Forward. The RWQCB requested that on or before May 31,2018,Forward submit a report certifying that the discharge of treated groundwater is in compliance with Order R5-2003-0080. In response,Forward installed a new groundwater treatment system of granular activated carbon (GAC)in May 2018, and the effluent system is now in compliance with the order. Based on totalizing flow meter readings, an estimated 14.9 million gallons of extracted groundwater was treated during the second quarter 2018,yielding approximately 0.28 pounds of VOCs removed during this period. Forward Unit The groundwater quality at the Forward Unit, as indicated by monitoring wells has generally been good. Occurrences of low level volatile organic compounds are detected above drinking water standards in the areas of the unlined Forward unit of the Forward Landfill and downgradient of it. More recently, VOCs and some inorganic compounds have been detected at the Forward units that are likely associated with landfill gas. The RWQCB issued a letter, dated May 9,2018, requesting an evaluation of the exceedances. In addition, the RWQCB requested implementation of interim corrective measures to begin to address the detected VOCs in groundwater. Forward submitted the "Evaluation Monitoring and Interim Corrective Action Workplan" on June 29,2018, for RWQCB approval. In a letter dated May 10, 2018, the RWQCB also requested a workplan to install additional wells on the southeast side of the Forward Unit to monitor groundwater that is flowing in that direction as a result of adjacent agricultural pumping. Forward submitted the "Forward Landfill Well Installation Workplan"on June 28, 2018 and it is also being reviewed by the RWQCB. These workplans will be implemented following RWQCB approval. 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. Historically, similar exceedances of inorganic CLs have been measured and verified in samples collected from detection monitoring program wells. Forward is proposing to perform an evaluation of these exceedances,pending approval of its June 28, 2018 workplan by the RWQCB. Current Groundwater Quality To date evaluation monitoring indicates that chlorinated hydrocarbon impacts extend as much as 8,000 feet downgradient of the Austin Road Unit. The zone of groundwater affected by VOCs is shown in Figure IV.G-2 (the principal VOCs of concern include PCE and TCE). As shown in this figure,the limits of affected groundwater appear to be well-constrained both laterally and