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Forward Landfill - 2 - 21 November 2024 <br />Staff Comments: <br />As a point of clarification and as outlined in Cleanup and Abatement Orders R5- <br />2008-0714, R5-2017-0703, and the recent WDRs R5-2024-0002 the release of <br />volatile organic compounds from the Austin Road Unit of the Forward Landfill <br />has and continues to impact groundwater quality downgradient of the Forward <br />Landfill and beneath the CDCR facility. <br />Additionally, Central Valley Water Board staff previously authorized the <br />installation of groundwater extraction wells, groundwater monitoring wells, <br />hydraulic testing, and the use modular granular activated charcoal treatment <br />systems in letters dated 3 August 2017, 27 December 2018, 24 March 2022, <br />and 27 March 2023 (attached). Please review the letters prior to installing the <br />proposed groundwater extraction well EW-5 to ensure that the construction <br />requirements by San Joaquin County and data collection requirements from <br />Title 27 and the Regional Board are met (e.g. continuous coring from ground <br />surface, logging of borings in accordance with §20415 E.2.a of Title 27, well <br />development, and sampling requirements). <br />What the report does not include is documentation from CDCR regarding the <br />proposed installation of the GWETS onsite. The Central Valley Water Board <br />needs to understand if CDCR can accept installation of a treatment system in a <br />secure facility. Central Valley Water Board staff previously voiced concerns <br />about system shutdowns and the need for immediate access to remedy any <br />unscheduled shutdown. Item 5(a) of the CAO states in part: “Effective <br />immediately, the Discharger shall operate the existing groundwater extraction <br />system, or any upgraded or replaced corrective action system, continuously. <br />until the groundwater plume is remediated to comply with concentration limits <br />within the WDRs.” The Order goes onto define continuously in footnote #7 as: <br />“24 hours a day, 365 days a year operation except for periodic and required <br />maintenance or unpreventable equipment failure.” <br />These potential access issues were mentioned in the 2023 Revised Engineering <br />Feasibility Study and need to be clarified. Has CDCR reviewed and approved <br />installation of the proposed treatment system, conveyance lines and the <br />necessary utility connections? Central Valley Regional Board staff will be <br />scheduling a conference call to discuss this issue with CDCR and Forward <br />Landfill as soon as possible. <br />As stated in staff’s 12 September 2024 letter “Compliance with the CAO is <br />compared to the dates and requirements of that Order.Until the interim <br />corrective action system is operating and the inward gradient of the <br />groundwater table, measured from existing monitoring wells within the plume, in <br />all zones affected by the release, Forward Landfill will remain out of compliance <br />with the 2017 CAO. This continued noncompliance exposes Forward to an <br />administrative civil liability (monetary penalties issued by the Board itself) as