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Forward Landfill 6 15 August 2023 GeoTracker No : L10008827999 Attachment A : Comments from Review of Remedial Investigation Update and Revised Feasibility Study Addendum The 30 June 2023 Remedial Investigation Update and Revised Feasibility Study Addendum is materially deficient . Central Valley Water Board staff cannot accept a document that does not comply with the requirements specified in the CAO and other applicable regulations and resolutions . Cover Letter The CAO requires that "[e]ach report submitted to the Central Valley Water Board shall be included in the Discharger's Operating Record. Furthermore, any person signing a document submitted under this Order shall make the following certification : 'I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments and that, based on my knowledge and on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the information is true, accurate, and complete . I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. "' No certification statement was provided ; therefore , the report is uncertified , in violation on the CAO , and the report must be rejected . The Report The report states "Several corrective action strategies, including gas collection and groundwater recovery and treatment, have been implemented at the Landfill to address the detection of VOCs in groundwater. In addition to these efforts, the California Regional Water Quality Control Board (RWQCB) for the Central Valley Region requested additional tasks be performed to continue to address VOCs in groundwater downgradient of the Landfill. These additional tasks are outlined in Cleanup and Abatement Order (CAO) R5-2017- 0703 for the Forward Landfill (RWQCB 2017) . " Finding 9 of the CAO states in part , "the Discharger has been unsuccessful in containing and cleaning up the VOC plume . Therefore, this 2017 Order requires additional investigation to fully delineate the vertical and lateral extent of the plume and the installation of enhanced corrective action measures such that no VOCs will be present in the groundwater beyond the landfill boundaries. " The report states "Installation of the leachate and landfill gas collection systems, as well as the Point of Compliance (POC) groundwater capture system and artificial recharge basin (which created a clean waterfront migrating downgradient of the POC) , have proved successful at preventing further migration of detectable concentrations of VOCs, primarily tetrachloroethene (PCE) , in the shallow and intermediate groundwater zones beyond the POC. The remedial actions have also restored the beneficial uses of groundwater in most zones affected by the release from the Landfill by the required date of July 1 , 2023". Central Valley Water Board staff dispute this assessment . The Landfill falls under Federal as well as State landfill regulations , which clearly define the expectations for Corrective Action Programs at these sites . The California Code of Regulations , Title 27 , Section 20430 outlines the expectation of a Corrective Action Program , in part , as follows :