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Forward Inc. - 3 - 24 March 2022 water storage. The constant rate pump test should continue until equilibrium is approached to ensure that the data set acquired is adequate to accurately characterize aquifer conditions in both the shallow and the intermediate aquifer zones. Additionally, water elevations in monitoring wells within distal portions of the plume should be monitored and evaluated. The pump test should be followed by a similar duration of active well recovery monitoring. Please understand that the performance of the pumping system is outlined in item 3.0 of the CAO (above). • The Extraction Well Installation Summary Report and Site Investigation Report shall include all the data collected from the sieve analysis, boring logs, a discussion of how the appropriate filter pack and well screen slot size had been selected, how the casing material used for the well itself was selected, and the justification for the methodology used for calculating the aquifer parameters. • As part of the site investigation, soil vapor probes are proposed to be installed locations CDCR-SB-01 through 5 at depths of 5, 15 and 45 feet below ground surface. The 2019 workplan proposed up to five vapor probes to be installed at each location (area of interest). To determine the appropriate depth intervals for the vapor probes, Forward should consider incorporating the membrane interface probe (MIP) technologies previously used during the investigation at 7833 Newcastle and advance the probe to groundwater to assess the potential for VOCs volatilizing from groundwater. Justification for the vapor probe depths shall be included in the Extraction Well Installation Summary Report and Site Investigation Report. While the Regional Board cannot direct the Discharger on how to comply with the requirements of the CAO, the bulleted list above clearly identifies staff's concerns. Following the completion of the field work, Forward Inc is required by the CAO to submit the following information: "...the Discharger shall submit an Interim Groundwater Plume Remediation System Installation Report that certifies the installation and continuous operation of the additional groundwater extraction wells. Once installed, the extraction wells shall be monitored weekly for flow...". Please beware, the CAO also states: "If the Discharger fails to comply with the provisions of this Order, the Central Valley Water Board may refer this matter to the Attorney General for judicial enforcement or the Assistant Executive Officer may issue a complaint for administrative civil liability. Failure to comply with this Order may result in the assessment of administrative civil liability up to $10,000 per violation per day, pursuant to the Water Code sections 13268, 13350, and/or 13385."