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Response to Written Comments Page 2 of 11 09 October 2023 <br /> Forward Landfill, Inc. <br /> 1.) The Regional Water Quality Control Board Response to 1 st set of written comments <br /> for the Forward Landfill dated 10/11 August 2023 "Response To Questions" (to be <br /> shortened to RTC from here forward). The RTC I received and the RTC that is posted to <br /> your website are different, why is that? The one I received had 41 comments, the one <br /> on your website now has 52. Why did you not update me with the 2nd version? This <br /> makes me think you have something to hide. <br /> RESPONSE: <br /> A pdf version of the Response to 1 st Set of Written Comments for the then circulated <br /> Tentative Waste Discharge Requirements Order No. R5-2021-XXXX were emailed to <br /> interested parties. Due to web content accessibility guidelines, the document format <br /> was changed and updated to be posted on the website. This in turn fixed issues with <br /> numbering and references that were seen in the pdf version. Both documents have the <br /> same responses and total number of response to comments. <br /> COMMENT NO. 2: <br /> 2.) From the 2nd paragraph of the RTC, I would like to know how the recent high <br /> rainfall and high meltwater flows have impacted the facility with regards to surface <br /> impoundment and potential release, as these responses were prior to the high rainfall <br /> and high runoff event of this season? Secondly, how has this impacted the plume and <br /> are any mitigation efforts being proposed, as these high rainfall events are probably <br /> more likely than not. <br /> RESPONSE: <br /> The average rainfall depth that was seen in the area during the November 2022 to April <br /> 2023 (wet season) was 3.8 inches, with the highest precipitation depth at 8.5 inches for <br /> December 2022 (Station ID SOC, www.ncei.noaa.gov). Compared to the average of the <br /> highest 5 years precipitation data from 1919 to 2020 (data from PRISM Climate Group, <br /> Oregon State University, https://prism.oregonstate.edu), there was in increase in the <br /> amount of rainfall depth that was received in December 2022 and March 2023. <br /> December 2022 received 8.5 inches compared to an average of 2.45 inches and March <br /> 2023 saw 5.23 inches compared to an average of 4.42 inches. <br /> Forward Inc. brought in ten temporary liquid storage tanks to supplement the leachate <br /> storage capacity of the surface impoundments during the 2022-2023 winter season. <br /> An analysis was conducted to assess the effects of recent rainfall activity and how <br /> groundwater elevations changed from the Fourth Quarter 2022 Water Quality <br /> Monitoring Report (WQMR) to the First Quarter 2023 WQMR. Groundwater elevations <br /> were sampled between 10/28/2022 to 11/9/2022 and 1/24/2023 to 2/10/2023 in the <br /> Fourth Quarter 2022 WQMR and First Quarter 2023 WQMR, respectively. All the <br /> groundwater wells with sufficient comparable data (4 out of 87 wells did not have <br /> elevations for Fourth Quarter 2022) saw an increase in water levels from one reporting <br /> season to the next and ranged from 0.75 feet to 45.4 feet. Out of 87 groundwater wells <br />