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t i windrows are located on asphalt and/or clay surfaces to minimize leachate percolation. The windrows are turned following the rinse water application which maximizes composting efficiency while minimizing potential odor generation and vector attraction. The facility is graded to contain run off and storm water and drains to the storm water pond on the west side of the facility. The compost operations are regulated by CalRecycle through the LEA. Forward met with Mr. McClellon, on 23 July 2013 and discussed the use of cannery rinse water for compost operations. This use of cannery rinse water was considered acceptable by Mr. McClellon. In addition, Mr. McClellon sent an email to the RWQCB on 25 July 2013 (see Attachment B) stating the use of cannery rinse water for compost operations was acceptable and suggested that: 1. The location of the windrows be up wind as far as possible (not near the road). 2. The windrow receive additional turning to reduce the incidence of anaerobic activity and to aid in the drying on the cannery liquid. Forward will comply with Mr. McClellon's suggestions. In addition, Forward is preparing a Cannery Rinse Water Operations Plan to request approval from the RWQCB for storage and evaporation of cannery rinse water in the onsite Class II impoundments. Once approved by the RWQCB, the Class II impoundments will be used as a contingency plan if Forward reaches agronomic rates in the compost operation or land application (once land application is approved). This plan will be submitted shortly. 2.0 CANNERY MUD Forward did not discharge cannery mud to the borrow area north of the landfill, but used this clay lined area as a temporary transfer pad. The use of this area for temporary holding and transfer has previously been discussed with RWQCB staff and documented in various reports submitted by Forward to the RWQCB. Nonetheless, Forward ceased using the transfer pad area on 27 June 2013 and removed all materials from this area and placed them on the drying pads on the top deck of WMU FU-04 and FU-05. The mud was dried and then transported to the active face. As a clarification, Forward's tentative WDRs will allow for the land application of cannery wastes, which includes applying cannery muds, rinse water, and residuals directly to the ground and spreading and disking these materials into the native soils. A crop is subsequently planted to uptake nitrates. This process is much more intensive than the temporary transferring of cannery muds on a lined pad. Until the tentative WDRs are approved for the land application of cannery waste, Forward is planning to place and dry cannery waste muds above the top deck interim cover of Class II WMUs. This operation is consistent with the intent of WDR Order R5-