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LEWIS ENGINEERING <br /> _E., , 1TEX:51a6D1.7223FAX510.601.7206 <br /> July 26, 2013 <br /> Mr. Howard Hold <br /> Central Valley Regional Water Quality Control Board <br /> 11020 Sun Center Drive, Suite 200 <br /> Rancho Cordova, CA 95670-6114 <br /> SUBJECT: RESPONSE TO 22 JULY 2013 NOTICE OF VIOLATION AND <br /> INSPECTION REPORT, FORWARD LANDFILL, SAN JOAQUIN COUNTY, <br /> CA <br /> Dear Mr. Hold: <br /> Lewis Engineering is submitting this response to the 22 July 2013 Notice of Violation <br /> (NOV) on behalf of Forward, Inc. (Forward). This letter contains the most recent <br /> information on the cannery waste operations at Forward in 2013 based on discussions <br /> with Forward personnel following their detailed review of their records. <br /> 1.0 CANNERY RINSE WATER <br /> Forward's Waste Discharge Requirements R5-2003-0049 (site WDRs) allow the <br /> discharge of liquids and semi-solid waste to Class II impoundments. The WDRs include a <br /> list of specific items that can be discharged to the impoundments, such as leachate and <br /> landfill gas condensate, and also allow "other wastes that are compatible with the liner <br /> system and meet the approval of the Board." The site WDRs do not specifically require <br /> written approval from the Board and it was Forward's understanding, based on <br /> conversations and documents submitted to the RWQCB from 2011 to 2013, that the use <br /> of the Class II impoundments for cannery rinse water was acceptable. <br /> In addition, based on the 2011 request of Mr. Robert McClellon of San Joaquin County <br /> Environmental Health, who serves as CalRecycle's Local Enforcement Agency (LEA), <br /> Forward performed an analytical test of the cannery rinse water. Value Engineering <br /> evaluated the results of the cannery rinse water analytical tests and found that they were <br /> compatible with the Class II impoundment liner. The Value Engineering report, which <br /> includes the analytical test results, is included in Attachment A. <br /> Nonetheless, due to the RWQCB's 22 July 2013 letter, Forward has ceased discharging <br /> cannery rinse water to the Class II leachate impoundments and is currently storing <br /> cannery rinse water in holding tanks in the composting area for use in the composting <br /> operations. The rinse water is applied at a rate to minimize leachate generation. The <br /> -1- <br />