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1 Forward landfill - 2 - 22 July 2013 San Joaquin County The discharge of cannery residuals to the green waste composting area is acceptable. However, the discharge of cannery rinse water and cannery mud is not a permitted discharge and is in violation of the WDRs and Title 27 as outlined below. Cannery Rinse Water The discharge of cannery rinsate water to the Class 11 surface impoundment without obtaining approval from the Regional Board is a violation of Discharge Specification B.3. of WDRs Order R5-2003-0049 which states: "The discharge of liquid and semi-solid waste to the Class 11 surface impoundment is limited to leachate for the landfill units and surface impoundment leachate collection and removal system (LCRSs), septage, chemical toilet waste, boiler blowdown water, grease trap pumpings, non -hazardous landfill gas condensate, and other waste that are compatible with the -liner system and meet the approval of the Board." Republic Services has not requested, nor received, approval from the Board to discharge cannery rinse water into the surface impoundment. Therefore you must cease the discharge immediately. If Republic Services desires to discharge cannery rinse water to the Class 11 surface impoundment in the future, then you must submit a formal written request to the Regional Board. The request shall include a Cannery Rinse Water Operations Plan which describes how the surface impoundment will managed to prevent odors and sludge accumulation. The Plan shall also include a water balance describing the volume of all types of liquid wastes which are discharged into the impoundments and demonstrating whether there is enough capacity, on a year-round basis, to accept the cannery rinse water. Cannery Mud The discharge of cannery mud to the area north of the lanrdfill is not permitted under the current WDRs. We recognize that Republic Services submitted Report of Waste Discharge and - requested that the WDRs be modified to allow this discharge to take place. However, because Republic Services has not yet received CEQA approval from San Joaquin County for this discharge, the Board cannot adopt WDRs that allow the discharge. Therefore,.Republic Services must immediately cease all discharge of cannery waste to the land north of the landfill until the new WDRs are adopted. Failure to do so is a violation of California Water Code section 13264(x)(1). Although the discharge and drying of cannery mud on the interim cover of waste management units FU -4 and FU -5 is not specifically described in the WDRs, this practice might be acceptable provided that the drying operations are conducted such that the intermediate cover is maintained, water percolation is minimized, and odors are not generated. Therefore, if Republic Services wishes to continue this practice, then you must immediately submit a Cannery Mud Operation Plan describing the cannery mud drying operation. The plan shall describe how the mud will be dried and managed to maintain the interim cover over the waste management units, prevent liquid runoff and odors, and minimize water percolation. Additionally, the use of cannery waste as alternative daily cover is prohibited by §20690 (b)(3)(A) of Title 27 which states, "(3) Processed Green Material. (A) For the purposes of this section, Processed green material means any plant material that is either separated at the point of generation, or separated at a centralized facility that employs methods to minimize contamination. Green material includes, but is not limited to, yard trimmings, untreated wood waste, paper products, and natural frber products. Green material does not include treated wood waste, mixed demolition or mixed construction debris, manure and plant waste from the food processing industry, alone or blended with soil. ...." Therefore, the use of cannery waste