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Forward Inc. - 3 - 24 March 2022 <br />water storage. The constant rate pump test should continue until equilibrium is <br />approached to ensure that the data set acquired is adequate to accurately <br />characterize aquifer conditions in both the shallow and the intermediate aquifer <br />zones. Additionally, water elevations in monitoring wells within distal portions of <br />the plume should be monitored and evaluated. The pump test should be <br />followed by a similar duration of active well recovery monitoring. Please <br />understand that the performance of the pumping system is outlined in item 3.C <br />of the CAO (above). <br />• The Extraction Well Installation Summary Report and Site Investigation Report <br />shall include all the data collected from the sieve analysis, boring logs, a <br />discussion of how the appropriate filter pack and well screen slot size had been <br />selected, how the casing material used for the well itself was selected, and the <br />justification for the methodology used for calculating the aquifer parameters. <br />• As part of the site investigation, soil vapor probes are proposed to be installed <br />locations CDCR-SB-01 through 5 at depths of 5, 15 and 45 feet below ground <br />surface. The 2019 workplan proposed up to five vapor probes to be installed at <br />each location (area of interest). To determine the appropriate depth intervals <br />for the vapor probes, Forward should consider incorporating the membrane <br />interface probe (MIP) technologies previously used during the investigation at <br />7833 Newcastle and advance the probe to groundwater to assess the potential <br />for VOCs volatilizing from groundwater. Justification for the vapor probe depths <br />shall be included in the Extraction Well Installation Summary Report and Site <br />Investigation Report. <br />While the Regional Board cannot direct the Discharger on how to comply with the <br />requirements of the CAO, the bulleted list above clearly identifies staff’s concerns. <br />Following the completion of the field work, Forward Inc is required by the CAO to <br />submit the following information: “…the Discharger shall submit an Interim <br />Groundwater Plume Remediation System Installation Report that certifies the <br />installation and continuous operation of the additional groundwater extraction wells. <br />Once installed, the extraction wells shall be monitored weekly for flow...”. Please <br />beware, the CAO also states: “If the Discharger fails to comply with the provisions of <br />this Order, the Central Valley Water Board may refer this matter to the Attorney <br />General for judicial enforcement or the Assistant Executive Officer may issue a <br />complaint for administrative civil liability. Failure to comply with this Order may result in <br />the assessment of administrative civil liability up to $10,000 per violation per day, <br />pursuant to the Water Code sections 13268, 13350, and/or 13385.”