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FORWARD Man S.Austin Road Manteca,CA 95336 Landfill P:(209)982-4298 F:(209)982-10091009 Mr.Brendan Kenny Engineering Geologist Central Valley Regional Water Quality Control Board 11020 Sun Center Drive,Suite 200 Rancho Cordova,CA 95670 August 25,2023 RE: Remedial Investigation Update and Revised Feasibility Study Addendum Dear Mr.Kenny: On June 30, 2023, Forward, Inc. (Forward) submitted a document titled, Remedial Investigation Update and Revised Feasibility Addendum(FS Addendum),to update the conceptual site model (CSM)for the Forward Landfill ("Landfill")and assess remedial actions being implemented to address the volatile organic compounds(VOCs)in groundwater downgradient of the Landfill. On August 15,2023, Forward received a Notice of Violation(NOV)of Cleanup and Abatement Order(CAO) R5-2017-0703 from the Central Valley Regional Water Quality Control Board(RWQCB),which called out that our June 30 submission omitted the required certification statement. In the closing of this letter, you will find the required certification statement and enclosed is the resubmitted FS Addendum. This letter also addresses additional allegations set forth in the NOV. From our perspective,the NOV does not acknowledge information relevant to the allegations which has been presented in the FS addendum including: • Forward has already demonstrated to the RWQCB that the improvements to the groundwater extraction and treatment system at the Forward landfill have provided complete capture of VOCs at the Landfill's POC, meeting one of the Remedial Action Objectives(RAOs)stipulated in the CAO. • Multiple lines of evidence suggest separate source areas with independent VOC releases present downgradient of the Landfill at 7833 Newcastle Road and on the CDCR prison property. • Access restrictions related to the CDCR prison property security previously communicated to the RWQCB completely prevented Forward from accessing the CDCR property until mid-2021, at which time Forward was only allowed to conduct a limited utility survey on a portion of the CDCR property. • After obtaining access for a further site investigation in mid-2022 and 2023, Forward installed and tested multiple groundwater extraction wells on the CDCR property.The results of this testing demonstrated the prescribed method of remediation by way of extraction wells located in the center of plume mass is not feasible and could potentially result in further plume migration. • Forward has evaluated multiple alternatives to compensate for the infeasibility of the prescribed extraction method in the CAO.These alternatives represent the state of the practice for mitigation of volatile organic compounds present in groundwater. It is recommended that the RWQCB consider the alternative recommended in the FS Addendum in lieu of the extraction well system,which Forward's site investigation has demonstrated is not feasible. Forward respectfully requests the RWQCB review the enclosed FS Addendum in its entirety and provide comments on the separate source area(s)with independent VOC release(s)on the CDCR property,the groundwater extraction well testing results on the CDCR property, and the proposed remedial alternatives presented for this separate source area(s) with total VOC concentrations >25 µg/L. Additionally, please confirm that the installation of groundwater extraction wells and a treatment system on the residential property located at 7833 Newcastle Road is not required for compliance with the CAO. Forward is submitting this letter for the purpose of resubmitting the FS Addendum and to request that the RWQCB review the FS Addendum forthwith,and will soon be providing a further detailed response to each of the allegations in the NOV.