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DRAFT [TENTATIVE] WASTE DISCHARGE REQUIREMENTS ORDER R5-2023-OOXX 22 <br /> FORWARD, INC. <br /> FORWARD LANDFILL <br /> SAN JOAQUIN COUNTY <br /> concentration limit exceedance was caused by another Forward Landfill unit <br /> upgradient of WMU A. <br /> 67. On 4 June 2020, a Notice of Violation for Acceptance of Hazardous Waste was <br /> issued for the illegal acceptance of hazardous waste. The Discharger accepted <br /> hazardous waste from the Alco Iron and Metal Company, which contained <br /> hazardous levels of lead, Cadmium, Zinc, Chromium, Copper, and Nickel. <br /> 68. On 3 August 2021, a Notice of Violation was issued regarding the observed <br /> settlement above the Old Austin Unit. Based on the Settlement Analysis on the <br /> Austin Unit — Leachate/Gas System Impacted report submitted by the Discharger <br /> on 3 September 2021 , these WDRs require the functionality of the leachate <br /> collection and removal system (LCRS) above the 4-foot clay cap to be evaluated. <br /> See Section I, Table 11 Item 7. <br /> 69. On 29 March 2022, a Notice of Release was issued to the Discharger for the <br /> unauthorized release of waste from WMU F West. Liquid was discovered in the <br /> sump on 23 February 2022, which prompted the Discharger to begin transferring <br /> leachate from WMU F West to WMU F North. On 9 March 2022, liquid was <br /> discovered in suction lysimeter LY-Pond-S, which was located beneath the <br /> secondary geomembrane liner. On 22 March 2022, a leak location survey was <br /> conducted on the primary geomembrane liner. On 5 May 2022, the Discharger <br /> confirmed that two holes, six inches in diameter, were identified on the primary <br /> and secondary geomembrane liner. The Discharger established an Evaluating <br /> Monitoring Program (EMP) to assess the nature and extent of the release from <br /> the unit, as well as, design a corrective action program. Soil and groundwater <br /> data, including the installation of additional groundwater monitoring wells, <br /> indicate that there was not a significant release to the environment. During the <br /> EMP process, all liner materials, with the exception of the secondary liner on the <br /> west side of the surface impoundment, was removed. The Discharger has <br /> pursued the option to reconstruct WMU F West. <br /> 70. The groundwater extraction system consists of five groundwater extraction wells <br /> at the downgradient boundary of the former Austin Road Unit and one <br /> groundwater extraction well on the California Department of Corrections and <br /> Rehabilitation (CDCR) property, located approximately 1 ,900 feet north of the <br /> landfill. These wells are identified as EW-1, EW-2, EW-3R, EW-4, and EW-5 on <br /> the Austin Road Unit and CDCR-EW-1 on the CDCR property. VOCs were <br /> removed with an air stripper until May 2018. <br /> 71. The extracted groundwater is currently treated by two 10,000-pound granular <br /> active carbon (GAC) vessels that were installed in January 2020. The treated <br /> water is discharged to a recharge basin to recharge the shallow aquifer. <br />