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1 <br /> <br /> <br /> <br /> <br />(209-235-9622 (o) <br />ocordero@republicservices.com <br />9999 S. Austin Road <br />Manteca, CA 95336 <br />P: (209) 982-4298 <br />F: (209) 982-1009 <br /> <br /> <br />Mr. Brendan Kenny <br />Engineering Geologist <br />Central Valley Regional Water Quality Control Board <br />11020 Sun Center Drive, Suite 200 <br />Rancho Cordova, CA 95670 <br /> <br />August 1, 2025 <br /> <br />RE: 2025 Annual Corrective Action Evaluation Report <br />Forward Landfill, 9999 South Austin Road, San Joaquin County, California <br /> <br />Dear Brendan: <br />In accordance with Section B.5 of the Monitoring and Reporting Program specified in the Forward Landfill <br />Waste Discharge Requirements set forth in the Central Valley Regional Water Quality Control Board <br />(RWQCB) Order No. R5-2024-0002 (2024 Order), Forward, Inc. submits this 2025 Annual Corrective Action <br />Evaluation Report for the Forward Landfill. <br />Corrective action measures implemented at the Site to date include leachate collection systems and landfill <br />cells, landfill gas management, point of compliance (POC) groundwater capture and treatment, residential <br />groundwater treatment systems, and an artificial groundwater recharge basin. The enclosed report <br />evaluates the effectiveness of these corrective action measures through comparing groundwater morning <br />results and total volatile organic compound (TVOC) concentrations temporally and spatially from third <br />quarter 2024 to second quarter 2025 (the reporting period). A summary of the results presented in the <br />enclosed report is as follows: <br /> The Site is in compliance with the three exceedance criteria set forth by the Evaluations Procedures <br />for Proposed Corrective Action at Austin Road Landfill, Addendum to May 2001 Engineering Feasibility <br />Study (Revised August 2001),1 indicating the current corrective action measures at the Site are <br />effective; therefore, these measures will continue to be operated as currently designed. A summary of <br />monitoring results for the reporting period is as follows: <br />o There were no exceedances of the TVOC mass threshold limit (TL; 789.5 kilograms) during the <br />reporting period. <br />o TVOC mass increased from third quarter 2024 to second quarter 2025 (three consecutive quarters) <br />due to the addition of wells to the monitoring program in fourth quarter 2024 (seven wells) and <br />second quarter 2025 (eight wells). Of the additional 15 wells, 12 were placed in the center of the <br />plume mass located on the California Department of Corrections and Rehabilitation (CDCR) <br />property, and these wells have TVOC concentrations that directly contributed to the increase in <br />TVOC mass during the reporting period. The 2026 Annual Corrective Action Evaluation Report will <br />include the same monitoring well network evaluated in second quarter 2025, an update to the <br />corrective action wells under evaluation, and a recalculation of TLs (see discussion below). <br />Therefore, the 2026 Annual Corrective Action Evaluation Report will provide a more accurate <br />evaluation of the TVOC concentration trends compared to the current monitoring well network. <br />o Concentrations of TVOCs did not exceed the TLs in any individual wells during the reporting period. <br /> Given the general lack of detectable methane above 1 percent in the Title 27 perimeter landfill gas <br />probes during the reporting period, the landfill gas collection and control system continues to operate <br />effectively. <br /> <br /> <br />1 Herst & Associates. 2002.Evaluation Procedures for Proposed Corrective Action at Austin Road Landfill, Addendum <br />to May 2001 Engineering Feasibility Study (Revised August 2001). February.