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HERST & ASSOCIATES, INC. Mr. Brendan Kenny California Regional Water Quality Control Board Central Valley Region 11020 Sun Center Drive, Suite 200 Rancho Cordova, California 95670-6114 July 30, 2015 Dear Mr. Kenny: 2015 Annual Corrective Action Evaluation Report Austin Road Unit, Forward Landfill San Joaquin County, California Global Presence Personal Attention On behalf of Forward, Inc. and in accordance with Section B.5 of the February 14, 2014 Monitoring and Reporting Program (M&RP) R5-2014-0006, Herst & Associates, Inc. is submitting this Annual Corrective Action Evaluation Report for the Austin Road Unit (ARU) of the Forward Landfill, On February 26, 2002, Forward, Inc. submitted the Evaluation Procedures,for Proposed Corrective Action at Austin Road Landfill, Addendum to May 2001 EFS (Retrised August 2001) (hereafter, Evaluation Procedures Report). This report described procedures for evaluating the effectiveness of groundwater corrective action measures at the ARU. The California Regional Water Quality Control Board (RWQCB) later incorporated these procedures into Section B.5 of the M&RP. Corrective action measures implemented to date at the ARU include landfill gas management, groundwater pumping, and an artificial groundwater recharge area. Landfill gas collection began in 1985. Groundwater pumping at extraction wells EW -1 and EW -2 has reportedly been underway since 1994. Groundwater pumping at extraction well EW -4 has reportedly been underway since May 2009. Groundwater pumping at extraction well EW -3R has reportedly been underway since October 2009. The artificial recharge area was constructed in October 2002 and has reportedly been in use since May 2003. The Evaluation Procedures Report specifies three criteria that shall be used for evaluating groundwater corrective action measures at the ARU. Any of the following shall constitute an exceedance: • An exceedance of the total volatile organic compound (TVOC) mass Tluushold Limit (TL); • An increase in TVOC mass for four consecutive monitoring events; or An exceedance of any of the individual well TVOC concentration TLs. The Evaluation Procedures Report specifies a TL for TVOC mass that is derived from historical groundwater monitoring data. The TVOC mass TL therefore represents a historical upper bound of TVOC mass in impacted groundwater. An exceedance of the TVOC mass TL—or four consecutive increases in TVOC mass—would be suggestive of potential increasing VOC concentrations on a plume -wide basis. Similarly, the Evaluation Procedure Report also specifies TLs for TVOC 4631 North St. Peters Parkway Telephone (636) 939-9111 St. Charles, Missouri 63304 Fax (636) 939-9757