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Extraction wells in the deeper aquifers on the prison property are likely to draw the VOC contamination in the shallow, low permeable zone into the more permeable deeper zones and cause what appears to be the relatively contained VOC contamination in the shallow zone at the property to migrate into deeper soils and to further spread both on the prison property and potentially off site. These discoveries on the CDCR site, made once Forward and its consultants were finally allowed access to the prison facilities, show that the interim remedy in the CAO should be reconsidered. In addition, it should be noted that Forward has been directed by RWQCB staff not to undertake any additional site investigation activities on the prison property, which Forward and its consultants have previously recommended to the RWQCB on more than one occasion. Forward's consultants have identified multiple alternative options for remediation of the source area. We respectfully request that the RWQCB seriously consider the proposed remedial alternatives presented in the FS Addendum and encourage a coordinated effort with other responsible parties for the separate source area(s) on the CDCR property. Forward also respectfully requests the RWQCB comment on the multiple lines of evidence that suggest a separate VOC source area with total VOC concentrations >25 pg/L is also present beneath the residential property located at 7833 Newcastle Road and how this information affects the CAO requirements. 2) The alleged failure to submit a compliant Feasibility Study on the date specified in the CAO: 1 December 2019. To summarize the NOV, it is alleged that Forward failed to submit a Revised Engineering Feasibility Study in compliance with item 5.c of the CAO by December 1, 2019, because the June 30, 2023, submittal of the FS addendum was not certified by Forward and was therefore considered materially deficient. This certification error has since been corrected. The FS Addendum was resubmitted on August 25, 2023, with a certification statement included in the cover letter. Furthermore, in November 2019, Forward previously submitted the Groundwater Plume Investigation Report(GPIR) and Revised Engineering Feasibility Study(Revised FS) in accordance with Task 5.c of the CAO. To date, the RWQCB has not acknowledged or reviewed the November 2019 Revised FS. The Revised FS recommended submitting an addendum following further investigation of VOC concentrations downgradient of the Landfill,which were completed and are discussed in the June 2023 FS addendum. Forward has also submitted several technical reports documenting extensive assessment activities conducted to delineate an offsite source of TCE impacts in the vicinity of 7833 Newcastle Road including: - 7833 Newcastle Road Site Investigation Report, April 17, 2020 - Newcastle Road Site Investigation Report— Phase 2, November 6, 2020 - Newcastle Road Supplemental Site Investigation Report, November 20, 2020 To date, the RWQCB has not acknowledged its review of the reports and has provided no written comments regarding the data and findings from the report. The investigations of off-site properties described in this letter indicate that groundwater downgradient of the landfill is impacted by offsite source(s). This information was not available at the time the CAO was issued in 2017 and the offsite impacts must be considered for establishing background levels, cleanup targets and coordination with other responsible parties for remediation strategy. 3