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DRAFT [TENTATIVE] WASTE DISCHARGE REQUIREMENTS ORDER R5-2023-00XX 21 <br />FORWARD, INC. <br />FORWARD LANDFILL <br />SAN JOAQUIN COUNTY <br />60.On 20 June 2016, a Notice of Violation for Acceptance of Hazardous Waste was <br />issued. Forward Landfill accepted and buried hazardous waste on several dates <br />between April 2014 and December 2015. <br />61.On 16 May 2017, Water Code section 13267 Order for Enhanced Monitoring was <br />issued for failure to remove hazardous waste. <br />62.On 2 March 2018, a Notice of Violation for Acceptance of Hazardous Waste was <br />issued for the illegal acceptance of hazardous waste. The hazardous waste was <br />identified by the LEA as approximately 9 tons of lime mixed with debris and soil <br />associated with a Union Pacific Railroad cleanup action. <br />63.On 9 May 2018, a Notification of Release was issued to the Discharger for the <br />Forward Landfill WMU. <br />64.On 8 September 2018, the Discharger submitted an alternative source <br />demonstration report to DTSC and addressed the statistically significant <br />exceedance of organic and inorganic constituents of concern in groundwater <br />wells downgradient from WMU A. The Discharger concluded that the <br />concentration limit exceedance was caused by another Forward Landfill unit <br />upgradient of WMU A. <br />65.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 />66.On 3 August 2021, a Notice of Violation was issued regarding observed <br />settlement above the former Austin Road Unit. Based on the Settlement Analysis <br />on the Austin Road Unit – Leachate/Gas System Impacted report submitted by <br />the Discharger on 3 September 2021, these WDRs require the functionality of the <br />LCRS above the 4-foot clay cap to be evaluated. See Section I,Table 17, Item 7. <br />67.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 Evaluation <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,