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2
<br /> Two additional NOVs were issued during the December 31, 2024, inspection for litter observed on neighboring
<br />properties and for no cover placed on the southern slope. Corrective actions were completed in first quarter
<br />2025. The violation for litter was deemed corrected during the February 21, 2025, inspection, and the violation
<br />for lack of cover was deemed corrected during the March 20, 2025, inspection.
<br />In addition to the NOVs issued by the RWQCB and SJCEHD, any non-statistical exceedances as well as exceedances
<br />of the concentration limits are considered violations of the Order. Forward submitted an Exceedance of
<br />Concentration Limits letter on January 30, 2025, to document and address any exceedances at the Forward Landfill.
<br />In fourth quarter 2024, a total of 50 wells reported one or more VOCs exceeding their respective practical
<br />quantitation limits, with well AMW-22S exhibiting the highest VOC concentrations detected. Non-statistical
<br />exceedances were identified at wells AMW-6, AMW-12, MW-2A, MW-10, and MW-19R because of one or more VOC
<br />detections. There were no exceedances above the concentration limits for inorganic parameters. Exceedances of
<br />concentration limits are addressed by the ongoing Corrective Action Program that includes a landfill gas extraction
<br />system, a groundwater extraction and treatment system, and ongoing monitoring. Under the existing Corrective
<br />Action Program, the groundwater treatment system pumped approximately 50 million gallons of groundwater
<br />during fourth quarter 2024, removing approximately 0.84 pounds of VOCs.
<br />Deviations from the MRP and Proposed Corrective Actions
<br />Below is a summary of deviations from the MRP in fourth quarter 2024 and proposed corrective actions:
<br /> Piezometers CDCR-PZ-1 through CDCR-PZ-3 are listed in Table 1 of the MRP and shown on Figure 1 of the
<br />enclosed report as PZ-1 through PZ-3; however, these locations on the offsite California Department of
<br />Corrections and Rehabilitation (CDCR) property were not sampled in fourth quarter 2024. The corrective
<br />action will be to add these piezometers to the quarterly monitoring program beginning in second quarter
<br />2025. The correct nomenclature for these locations is PZ-1 through PZ-3 and should be included as such in
<br />the next revision to the MRP.
<br /> Domestic well DW-9690 is included in Table 1 of the MRP and presented on Figure 1 of the enclosed report;
<br />however, this well was reportedly abandoned in fourth quarter 2022 when the corresponding domestic
<br />residence was destroyed. Because the well was thought to be abandoned, data were last collected on
<br />August 5, 2022. Domestic well DW-9690 was located during a site inspection on April 4, 2025. The corrective
<br />action will be to determine the integrity of the well in second quarter 2025 and determine whether the well
<br />can be reincorporated into the quarterly monitoring program.
<br /> Suction lysimeters LY-E1A, LY-E1B, LY-E2A, LY-E2B, and D93B are included in Table 6 of the MRP and shown
<br />on Figure 2 of the enclosed report; however, these suction lysimeters could not be located during the fourth
<br />quarter 2024 sampling event. Samples were last collected from LY-E1A, LY-E1B, LY-E2A, LY-E2B, and D93B
<br />on January 8, 2000, November 21, 2002, October 15, 2001, November 11, 2003, and July 26, 1995,
<br />respectively. In a letter report from Geo-Logic Associates (GLA) to the RWQCB dated May 29, 2014,1 these
<br />suction lysimeters are listed as buried or damaged beyond repair, could not be located after several
<br />attempts to locate them, and are assumed destroyed. GLA proposed to replace these suction lysimeters;
<br />however, in a letter dated July 21, 2014,2 GLA indicated it would be hazardous to the environment to
<br />excavate liner and refuse in an old ash deposit area where LY-E1A/B, LY-E2A/B are located and to exempt
<br />replacement. In addition, GLA indicated that replacing D93B is unnecessary because suction lysimeter D93A
<br />monitors the same location and the second lysimeter is a backup. A response from the RWQCB could not
<br />be found on GeoTracker; therefore, the proposed corrective action is for suction lysimeters LY-E1A, LY-E1B,
<br />
<br />1 GLA. 2014. Unsaturated Zone Monitoring System Review, Forward Landfill, San Joaquin County, California.
<br />May 29.
<br />2 GLA. 2014. Response to Comments, Unsaturated Zone Monitoring System Review, Forward Landfill, San Joaquin
<br />County, California. July 21.
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