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In the meantime, Forward has made arrangements to connect off-site properties, including the prison <br /> facilities and several residences, to the City of Stockton public water supply system. In some cases <br /> where such connections were impractical for a few residential properties, Forward provided these <br /> residential properties with individual water treatment systems at no cost to the homeowners. <br /> Therefore, as detailed above, we believe the current CAO provisions for an extraction and treatment <br /> system at the CDCR property will not achieve the CAO's goals and may well only serve to spread the <br /> localized contamination at the CDCR property. <br /> Full compliance with the CAO requirements as drafted in 2017 would ignore critical information from further <br /> site investigations subsequently conducted at properties north of the landfill. As we understand the <br /> RWQCB's position stipulated in the CAO,this would include the installation of extraction wells located near <br /> the center of plume mass on the CDCR property,and the neighboring 7833 Newcastle Road,which multiple <br /> lines of evidence suggest both properties represent separate source area(s) with independent VOC <br /> release(s). Forward respectfully requests the RWQCB review the FS addendum in its entirety and provide <br /> comments on the separate source area(s)with independent VOC release(s)and the formation of potentially <br /> commingled plume(s) on the CDCR property, and that the RWQCB consider the groundwater extraction <br /> well testing results on the CDCR property, and further consider the proposed remedial alternatives <br /> presented for this separate source area(s) with total VOC concentrations >25 fag/L. <br /> The discoveries of two separate contamination sources in the shallow zone of the aquifer downgradient of <br /> the landfill and of the geologic conditions on the prison property warrant a thorough review and <br /> reconsideration of the 2017 CAO, which is now six years old. The CAO does not reflect current knowledge <br /> of groundwater contamination north of the landfill and provides for remedial action that we believe will be <br /> ineffective. <br /> Forward Inc. prides itself on being a good neighbor and landfill operator. We continue to welcome any <br /> opportunity to sit down with RWQCB to resolve these issues cooperatively. If you have questions or <br /> comments regarding the above information, please contact me at (650) 713-3632. <br /> Kindest regards, <br /> 6� <br /> Ben Wade <br /> West Environmental Manager <br /> Enclosures <br /> 1. Partial Log of Forward Email Communications with CDCR and DGS <br /> 2. Figure Showing POC GWTS Capture Zone and Offsite Sources <br /> 3. Table Summarizing Major Project Progress Milestones <br /> 5 <br />