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Forward Landfill 3 15 August 2023 GeoTracker No : L10008827999 (t) Terminating Measures-- Corrective action measures taken pursuant to %(c) (e . g. , pumping and treatment of ground water) may be terminated when the discharger demonstrates to the satisfaction of the RWQCB that the concentrations of all COCs are reduced to levels below their respective concentration limits throughout the entire zone affected by the release . III . Evidence/Violations Violation 1 . Failure to Implement Corrective Action : The Discharger has failed to complete the work necessary to comply with item 3) c) of the CAO . By failing to complete item 3) c) the Landfill cannot complete item 3d of the CAO . To complete this work the Landfill is required to install enough groundwater extraction wells , within the center of the plume mass , such that an inward gradient can be measured in the wells that delineate the plume . The wells must address all zones affected by the release . The Discharger has failed to install the necessary extraction wells as well as the treatment system . Until the system is installed , with the measurable inward gradient in all zones affected by the release will the Landfill be in compliance with this requirement of the CAO . Violation 2 . Failure to submit a compliant Feasibility Study by the date specified in the CAO : The 30 June 2023 Remedial Investigation Update and Revised Feasibility Study Addendum was submitted uncertified by the Discharger and is considered materially deficient . First , Central Valley Water Board staff cannot accept an uncertified document . Certification requirements are set forth on page 18 of the CAO . Second , the report fails to take into consideration the Federal and State regulations that require a corrective action program to restore the beneficial uses to the Water Quality Protection Standards (WQPS) within the WDRs . Monitored natural attenuation , especially for a plume with concentrations above the MCL , is not acceptable . The cleanup value is set in the WDRs . A Revised Engineering Feasibility report must be submitted forthwith to address all applicable regulations . Additional comments are provided in the attachment to this Notice of Violation . Violation 3 . Failure to Restore Beneficial Uses of the Aquifer: The Landfill has yet to install a compliant interim corrective action measure or propose a compliant long-term solution to restore beneficial uses of all aquifer zones affected by the release . Item 5 . C . 111 of the CAO required the Landfill to do so by 1 July 2023 . As of the date of this letter, the Discharger has failed to meet the cleanup date that was set five-years after the issuance of the CAO . Until the gas and leachate are at the WQPS , and the beneficial uses have been restored to all zones affected by the release , will the Discharger be in compliance with the applicable requirements in the CAO . The groundwater monitoring data collected and reported by the Discharger from the aquifer downgradient of the Landfill still contains various VOCs above the detection limit associated with releases from the Landfill . The Discharger is in violation of the CAO cleanup date without any significant progress being made . IV, Corrective Action to Reestablish Compliance The Central Valley Water Board expects full compliance with the CAO , especially one that was stipulated to by the Discharger. Immediate installation of the groundwater extraction wells and treatment system (to create the inward groundwater gradient required by the CAO and restore all beneficial uses of the aquifer) is required .