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Central Valley Regional Water Quality Control Board <br />24 March 2022 <br />Joshua Mills Via e-mail <br />Area Environmental Manager <br />Forward Landfill <br />9999 South Austin Road <br />Manteca, CA 95336 <br />REVIEW OF REVISED CDCR SITE INVESTIGATION AND REMEDIAL DESIGN <br />WORKPLAN ADDENDUM, FORWARD INC. AND REPUBLIC SERVICES, <br />FORWARD LANDFILL, SAN JOAQUIN COUNTY <br />Forward Inc., a subsidiary of Republic Services (Discharger) owns and operates the <br />Forward Landfill in San Joaquin County. Waste disposal operations, landfill closure, <br />implementation of corrective actions and groundwater remediation at the Forward <br />Landfill is regulated by Waste Discharge Requirements (WDRs) Order R5-2003-0080, <br />R5-2014-0006 and Cleanup and Abatement Order (CAO) R5-2017-0703. <br />Requirement 3.C of the CAO requires the Discharger to submit an Interim Groundwater <br />Plume Remediation System Workplan, which proposes the installation of additional <br />groundwater extraction wells to remediate areas north of the landfill where the <br />Discharger identified total VOC concentrations in groundwater exceeding 25 µg/l. The <br />extraction wells shall be located near the center of plume mass and must be able to <br />contain and treat the VOCs, create an inward gradient of the groundwater table, <br />measured from existing monitoring wells within the plume, in all zones affected by the <br />release. <br />Areas north of the landfill were VOCs exceeded 25 µg/l included both Forward Landfill’s <br />property and the California Department of Corrections and Rehabilitation (CDCR) <br />Regional Board staff previously reviewed and approved an Interim Groundwater <br />Remediation Workplan on 3 August 2017 however do to access issues with CDCR the <br />plan was not fully implemented. <br />On 11 October 2019 the Discharger submitted a CDCR Investigation Workplan, which <br />was approved by Board staff, with the understanding that the investigation was outside <br />the scope of the CAO and the Discharger should install the previously approved <br />groundwater extraction well prior to conducting the investigation (Regional Board letter <br />dated 21 October 2019). <br />Regional Board staff has reviewed the Revised CDCR Site Investigation and Remedial <br />Design Workplan Addendum submitted on 7 March 2022. The Workplan proposes a <br />multi-phase approach to 1). Install one groundwater extraction well into the shallow <br />aquifer zone and two piezometers near existing groundwater monitoring wells AMW-22