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Forward Landfill 8 15 August 2023 GeoTracker No : L10008827999 suitable or potentially suitable, at a minimum for municipal and domestic water supply (MUN), agricultural supply (AGR) , industrial service supply (IND) , and industrial process supply (PRO) . " Since the Central Valley Water Board has not de-designated groundwater within the basin , all beneficial uses apply and must be protected . Furthermore , the Water Quality Protection Standard for organic compounds which are not naturally occurring and not detected in background groundwater samples shall be taken as the detection limit of the analytical method used (e . g . , USEPA methods 8260 and 8270) . Furthermore , the CAO was clear on the cleanup values . Finding 8 and 9 of the CAO outline the expectations of the CAO and state : 8. "Monitoring Specification G . 4 of the WDRs states, "The concentrations of the constituents of concern in water passing the Point of Compliance (defined pursuant to Title 27, section 20164 as a vertical surface located at the hydraulically downgradient limit of the landfill unit that extends through the upper most aquifer underlying the unit) shall not exceed the concentration limits established pursuant to MRP No . 85-2014- 0006. " The MRP establishes the following monitoring locations as the point of compliance : Cell or Module Point of Compliance Monitoring Wells Old Forward Units MW- 1 , -2, -33 - 10, - 13, - 14, - 15, - 16, - 171 - 18, - 19, -21 . Austin Road Unit AMW4 , 41 - 6, - 7. The MRP states that the concentration limit for VOCs is non -detect. Therefore, the detection of any VOCs, in any monitoring well that is at the landfill's point of compliance or beyond, is a violation of Standard Prohibition C. 6 which states: "The discharge of waste constituents to the unsaturated zone or to groundwater is prohibited. " 9. "This 2017 Order summarizes the Discharger's efforts to date to define the vertical and lateral extent of the release from the landfill, as well as the installation of corrective action systems to control and capture the migration of contaminates. Despite these efforts, 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 . With regard to treatment of the extracted groundwater, the Discharger has consistently violated the VOC effluent limit. Therefore, this Order requires the Discharger to enhance its groundwater treatment system . This Order also requires the Discharger to address violations associated with overloading of nitrogen to the cannery waste land application area . " The cleanup goal proposed by the Discharger in the recent report for volatile organic compounds in groundwater set at the MCL does not comply with the CAO or WDRs . To return to compliance with the orders issued by the Board , the Discharger shall enhance corrective action measures such that no VOCs will be present in the groundwater beyond the Landfill boundaries . As long as the individual monitoring wells have concentrations greater than the approved water quality protection standard for organic compounds which are not naturally occurring and not detected in background the Discharger will remain in violation of the Orders . 3 3 Standard Provisions and Reporting Requirements , January 2012 for Waste Discharge Requirements , for Discharges Regulated By Subtitle D and/or Title 27 Finding 23 states : "The water quality protection standard for organic compounds which are not naturally