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FORWARD Man S.Austin Road <br /> ]J Manteca,CA 95336 <br /> 4298 <br /> Land i ll (209)982-1009 <br /> F:(209)982-1009 <br /> Stephani Gisi <br /> Senior Engineering Geologist <br /> Title 27 Permitting and Mining Unit <br /> Central Valley Regional Water Quality Control Board <br /> 11020 Sun Center Drive, Suite 200 <br /> Rancho Cordova, California 95670 <br /> Date: July 7, 2023 <br /> Subject: Review of Tentative Waste Discharge Requirements Order R5-2023-####and Tentative Monitoring & <br /> Reporting Program R5-2023-XXXX <br /> Dear Ms. Gisi, <br /> Forward, Inc. (Forward) has reviewed the Tentative Waste Discharge Requirements Order R5-2023-#### (WDR) <br /> and Tentative Monitoring & Reporting Program R5-2023-XXXX (MRP) provided by the Central Valley Regional <br /> Water Quality Control Board (CVRWQCB) on June 7, 2023, for Forward Landfill located at 9999 S. Austin Road, <br /> Manteca, California. As part of the review, Forward prepared a list of comments presented in Table 1. Select <br /> comments in Table 1 are clarified in Table 2 and Figures 1 and 2. Table 2 includes a comparison of the current <br /> monitoring well network and their proposed Program and water bearing zones, with proposed additions and <br /> corrections highlighted in yellow. Additionally, Item 6 in Table 1 is discussed in more detail below. <br /> Residential Domestic Wells <br /> The Findings section of the Tentative WDR, Table 3, page 17 proposes to include the 57 residential domestic <br /> wells currently sampled under directive of the Cleanup and Abatement Order(CAO) R5-2017-0703' into the <br /> Corrective Action Program of the Tentative WDR; however, the data collected from the majority of these <br /> residential domestic wells since 2017 indicate they have not been affected by a release from Forward Landfill <br /> and, therefore, should not be incorporated into the monitoring and reporting program proposed in the Tentative <br /> WDR. <br /> There are 47 residential domestic wells that Forward has previously requested be removed from the Domestic <br /> Well Sampling and Analysis Program 1,2 in three reduction request submittals provided to the CVRWQCB in June <br /> 20203, February 20214, and May 20215; therefore, at a minimum these wells should not be included in the <br /> Tentative WDR. The residential domestic wells previously proposed to be removed from the CAO R5-2017-0703 <br /> sampling program include the wells located along CA-99, Arch Road, Sunny Road, Santa Ana Way, Kaiser Road, <br /> Mariposa Road and Jack Tone Road. Since sampling was implemented in 2017, 12 semi-annual monitoring <br /> 1 Central Valley Regional Water Quality Control Board.2017. Cleanup and Abatement Order R5-2017- <br /> 0703 For Forward Inc. and Republic Services Inc., Forward Landfill, San Joaquin County. July 3. <br /> 2 Geo-Logic Associates.2017. Forward Landfill—Domestic Well Sampling and Analysis Plan. May 25. <br /> 3 Arcadis. 2020. Domestic Well Sampling and Analysis Program Reduction Request, Forward Landfill. June 30. <br /> 4 Arcadis. 2021 a. Domestic Well Sampling and Analysis Program Reduction Request, Forward Landfill. February 22. <br /> 5 Arcadis. 2021 b. Domestic Well Sampling and Analysis Program Reduction Request, Forward Landfill. May 18. <br /> 1/2 <br />