CORRESPONDENCE_2025 - Laserfiche WebLink

Home Browse Search

CDCR and DGS -4- 16 September 2025 the aquifer. Additional investigation is required to determine if these plumes have combined into one comingled plume or are moving independent of one another and, depending on the outcome of that investigation, to determine appropriate next steps consistent with the obligations of the Central Valley Water Board. Discharger is suspected of having caused or permitted waste to be discharged or deposited where it has discharged to waters of the state and has created, and continues to threaten to create, a condition of pollution or nuisance. Pursuant to Water Code section 13267, the Central Valley Water Board issues this Order requiring the investigation and submission of a vadose zone and groundwater plume investigation workplan to evaluate the nature and extent of releases emanating from the CDCR Facilities. This 13267 Order also requires the submittal of a Groundwater Plume Investigation Report and an Engineering Feasibility Study to evaluate remedial options for the vadose zone and impacted aquifer zones. The estimated cost for the preparation of the reports and site activities is $238,0005, based on similar reports submitted to the Central Valley Water Board for similar work. The reports are a necessary step towards remediation (if necessary), as the reports will provide the technical data necessary to determine if the CDCR Facilities are a separate source of groundwater contamination, and if so, (1) will identify the VOCs in that separate source, (2) will delineate the lateral and vertical extent of the plume from the CDCR Facilities, and (3) whether the plume from the CDCR Facilities has commingled with the Landfill plume. This data is necessary to be able to determine the type, size, and location of the remedial equipment. Without this data, remedial planning cannot occur. Remediation is necessary to prevent further impacts to the underlying aquifer and its users — including potential impacts to irrigation use by agricultural operations near the CDCR Facilities— and a community that has historically been disproportionately burdened by environmental pollution. Based on weighing the above costs and benefits, the burden, including costs, of the required work and reports bears a reasonable relationship to the need for the reports and the benefits to be obtained thereby. The Central Valley Water Board understands there is pending litigation between Forward Inc. and the Discharger regarding legal liability for the plume(s) described herein. This Order does not apportion or assign any liability; instead, this Order requires certain technical investigation and reporting, consistent with the mission of the Central Valley Water Board and the Water Code, to determine appropriate next steps. Nothing in this Order should be construed as barring the Discharger from obtaining legal relief (e.g., contribution) related to the plume(s). 5 Costs are estimated as follows: $7,000 for work plan preparation (40 hours x $175/hour); $4,000 for facility records review (40 hours x $100/hour); $3,000 for utility survey (24 hours x $125/hour); $8,000 for geophysical survey (16 hours x $500/hour); $32,000 for investigation borings (10 borings of 80' each x $40/foot); $40,000 for soil gas probes and vapor survey (10 probes of 50' each x $80/foot); $90,000 to install groundwater monitoring wells (6 wells, each 100' deep x $150/foot); $1,596 for groundwater sample VOC analyses (6 samples x $266/sample); $28,000 for groundwater plume investigation report and EFS (160 hours x $175/hour); $2,400 to review and stamp report (8 hours x $300/hour); $21,599 for 10% contingency.