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CDCR and DGS - 3 - 16 September 2025 monitoring well AMW-52S in May 2025, located near the southern boundary of the CDCR Facilities and upgradient of AMW-22S, contained low levels of carbon tetrachloride at a maximum concentration of 2.2 ppb and chloroform at a maximum concentration of 0.53 ppb. Similarly, the shallow wells located on or near the border between the Landfill and the CDCR Facilities (e.g., AMW-13, -21 S, -31 S, -37S, -40S, - 41 S, -42S, -43S, -44, -45, and -46) generally have shown no detectable amounts of carbon tetrachloride or chloroform in samples taken between 2013 and 2025. In summary, there is a significant amount of carbon tetrachloride and chloroform in the shallow groundwater near the center of the CDCR Facilities, but the shallow groundwater migrating towards the CDCR Facilities from the Landfill contains little to no carbon tetrachloride and chloroform. The logical conclusions to explain this data are (1) the Landfill is not contributing a significant amount of carbon tetrachloride or chloroform to the shallow groundwater migrating under the CDCR Facilities and (2) there is at least one separate source of carbon tetrachloride and chloroform on the CDCR Facilities contributing to groundwater contamination. The Landfill installed several groundwater monitoring and extraction wells at the CDCR Facilities and adjacent properties. However, the extraction wells located at the CDCR Facilities remain non -operational due to Forward Inc.'s inability to gain reasonable access to the CDCR Facilities to install the necessary pumps, electrical connections, and associated piping. As a result, active remediation of the shallow and intermediate aquifer zones beneath the CDCR Facilities is not currently occurring, and the migration of the groundwater plume(s) beyond the CDCR Facilities remains uncontrolled. Legal Requirements for Water Code Section 13267 Order Technical Reports: Water Code section 13267, subdivision (a), provides "[a] regional board, in establishing or reviewing any ... waste discharge requirements..., may investigate the quality of any waters of the state within its region." Water Code section 13267, subdivision (b), further provides: In conducting an investigation specified in subdivision (a), the regional board may require that any person who has discharged, discharges, or is suspected of having discharged or discharging waste ... that could affect the quality of waters within its region shall furnish, under penalty of perjury, technical or monitoring program reports which the regional board requires. The burden, including costs, of these reports shall bear a reasonable relationship to the need for the report and the benefits to be obtained from the reports. In requiring those reports, the regional board shall provide the person with a written explanation with regard to the need for the reports and shall identify the evidence that supports requiring that person to provide the reports. Data collected by Forward Inc. at the CDCR Facilities provides evidence to suspect a source of carbon tetrachloride and chloroform being released from the CDCR Facilities into the shallow aquifer zone which has the potential to comingle with the groundwater plume from the Landfill. The groundwater plume(s) has impacted the beneficial uses of