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Statement of Facts <br />Forward, Inc. <br />Page 2 <br />During the spring of 1984, the ponds were cleaned, and the <br />dried sludge and contaminated soil were excavated to a depth <br />of one foot beneath the ponds and placed into Trench 4 of <br />WMU-A. Removal reportedly was completed during October, 1984. <br />A temporary earthen cover was placed over WMU-A. <br />The facility submitted the Closure Plan for WMU-A in <br />September, 1987. After review of this plan by RWQCB and DHS, <br />a Notice of Deficiency was sent to Forward, Inc. to request <br />additional information for the closure. The additional <br />information was submitted in April, 1988. After review of the <br />Closure Plan and addendum to the Closure Plan with response <br />from RWQCB, a Closure Plan package was compiled. The Closure <br />Plan was approved on July 29, 1988, by DHS and EPA after a 30 <br />day public notice period. Modifications to the closure plan, <br />including additional groundwater monitoring wells and a <br />modification of the clay cover, were submitted and approved on <br />April 1989 after a 30 day public notice period. The current <br />proposal is for a Post Closure Monitoring permit which is <br />required by State and Federal regulations when hazardous waste <br />is left in place and capped. The Part A application, Post <br />Closure Plan, Notice of Deficiency and Post Closure Plan <br />Addendum are included in the public notice package. The Post <br />Closure Permit will make the Plan an enforceable document and <br />specify additional requirements. <br />Post Closure Plan/Permit Description <br />The Closure Plan as approved in April 1989, after a 30 day <br />public notice, consisted of an engineered clay cover system <br />for the hazardous waste landfill unit and a groundwater <br />monitoring system. State and Federal regulations require that <br />the cover system and groundwater monitoring system be <br />maintained and monitored for a minimum of 30 years. The plan <br />consists of the following: <br />1) Periodic sampling and analysis of groundwater wells; <br />2) Inspection of cover integrity including rodent <br />intrusion, subsidence, and erosion; <br />3) Repair of any breaches of cover integrity; and <br />4) Reports to DHS, at least annually, of groundwater <br />sampling results and inspection and repair procedures. <br />