CORRESPONDENCE_2018-2023 - Laserfiche WebLink

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1) The alleged failure to implement interim corrective actions by the date specified in the CAO: 1 November 2017. To summarize the NOV, it is alleged that Forward did not complete the work necessary to comply with item 3.c of the CAO by November 1, 2017, because the Landfill did not install groundwater extraction wells and a treatment system to capture and remediate a plume mass with total VOC concentrations >25 pg/L beneath the California Department of Corrections and Rehabilitation (CDCR) property north of the Landfill. As the RWQCB is aware from our ongoing communications with RWQCB staff since 2017, despite its best efforts, Forward and its consultants were unable to obtain permission from CDCR and the California Department of General Services (DGS) to access the Youth Authority prison facilities north of the Forward Landfill until mid-2021. Forward was unable to obtain a signed Right of Entry Agreement approved by CDCR, DGS, the California Department of Finance (DOF) and other state agencies until mid-March 2021, when the right-of-entry agreement between Forward and the State, acting by and through the Director of DGS and with the consent of CDCR, was given to Forward on March 19, 2021 (see enclosed communications log). After Forward's consultants obtained security clearances from CDCR, they were allowed to conduct a limited utility and sewer location survey on only a portion of the State Facilities. Forward then worked diligently with CDCR to evaluate options that were logistically feasible for boring locations and potential remediation equipment placement and utility connections. Forward subsequently obtained direction from the Regional Board on March 24, 2022, and permission from CDCR, starting in May 2022, to begin the installation of subsurface probes, monitoring wells, piezometers, and a single test extraction well at a central "administration portion" of the State Facilities to which Forward was allowed access. For security reasons, Forward's consultants were not allowed access to the areas of the State Facilities that housed facility residents and other high security areas including the prison hospital. Soil, soil vapor and groundwater samples, and other data, were obtained from the site investigation in the summer of 2022 and later in 2023. These site investigation activities continued to be limited to the central portion of the prison facilities. The RWQCB should therefore note that access restrictions to the CDCR property from 2017 through 2021 have limited the implementation of any remedial action for this VOC plume mass. In 2022 and 2023, at the direction of the RWQCB to remain in compliance with item 3.c of the CAO, Forward installed and tested multiple groundwater extraction wells in the central portion of the CDCR property. The testing results from these groundwater extraction wells demonstrate that groundwater extraction wells aimed at addressing the VOC contamination found on the CDCR property are not a practical or effective remedy. This is due in part to the discovery of a separate source of VOC contamination on the CDCR property with the greatest concentrations in the low permeability shallow zone aquifer(Figure 1), which appears to be the result of past activities by CDCR and other agencies of the State at the prison facilities. This separate source of contamination is the reason VOCs were found at the prison property in excess of the 25 micrograms per liter(pg/1) interim remedy"trigger" requirement in the 2017 CAO. In addition to the discovery of the separate source of VOC contamination on the prison property, Forward's site investigation has revealed that geologic conditions at the prison property make an extraction and treatment remedy infeasible. Again, this is because the highest VOC concentrations on the CDCR property(from the separate source of contamination) are located in the shallow zone, which is characterized by very low permeability materials. Forward's extraction well program at CDCR has found that extraction wells in the shallow zone's low permeability materials are essentially ineffective. 2