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Forward Landfill 3 6 October 2023 GeoTracker No: L10008827999 II. Legal Requirements Monitoring Specification G.6 of the WDRs states, "The Discharger shall comply with all Standard Monitoring Specifications and Response to a Release Specifications listed in Sections I and J of the SPRRs dated January 2012 which are attached hereto and made part of this Order by reference." Standard Monitoring Specification I. 45. states: "Whenever a constituent is detected at a detection monitoring point at a concentration that exceeds the concentration limit from the water quality protection standard, the Discharger shall conduct verification sampling to confirm if the exceedance is due to a release or if it is a false-positive (unless previous monitoring has already confirmed a release for that constituent at that monitoring point). An exceedance of the concentration limit from the water quality protection standard is considered measurably significant evidence of a release that must be either confirmed or denied." As presented in the table above, at the latest, this standard was met upon the receipt of the retest results. Yet the Central Valley Water Board received no notification." Standard Monitoring Specification I. 46.b.2. states, "2) Confirmation of a Release. As soon as the retest data are available, the Discharger shall conclude that measurably significant evidence of a release is confirmed if(not including the original sample) two or more analytes equal or exceed their respective MDLs or if one or more analyte equals or exceeds its PQL. The Discharger shall then: a) Immediately verbally notify the Central Valley Water Board whether or not the retest confirmed measurably significant evidence of a release for the analyte at the monitoring point, and follow up with written notification submitted by certified mail within seven days of the verbal notification; and b) Carry out the requirements of Section J, RESPONSE TO A RELEASE if a release has been confirmed. III. Evidence of Violation 1) Violation 1. Failure to Comply with Monitoring Specification G.6. Beginning on 29 June 2023, the Discharger began sampling groundwater monitoring well AMW-56 and continued sampling the monitoring well bi-weekly until 11 September 2023. All six of the sampling events indicated multiple volatile organic compounds were consistently present in groundwater collected from the monitoring device. However, the Discharger did not notify the Regional Board of the Release until 29 September 2023, nearly 90 days after the first sampling event. IV. Corrective Action to Reestablish Compliance 1) Update Forward's Monitoring and Reporting procedures to ensure timely reporting in accordance with the WDRs.