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FORWARD 9999 S.Austin Road ]J Manteca,CA 95336 Landfill P:(209)982-4298 F:(209)982-1009 Mr. Brendan Kenny Engineering Geologist Central Valley Regional Water Quality Control Board 11020 Sun Center Drive, Suite 200 Rancho Cordova, CA 95670 September 8, 2023 RE: Response to 15 August 2023 Notice of Violation of CAO R5-2017-0703 Dear Mr. Kenny: Forward, Inc. (Forward) is committed to timely remediation of groundwater impacts originating from the former Austin landfill. On June 30, 2023, 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). The NOV does not account for the following relevant information: - 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 are present downgradient of the Landfill at 7833 Newcastle Road and on the CDCR prison property. - Access restrictions related to 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. On August 25, 2023, the subject FS Addendum was resubmitted with the certification statement and a request for the RWQCB to provide comments on the proposed remedial alternatives. Forward is submitting this letter to provide a further detailed response to each of the allegations in the NOV.