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Regional Water Quality Control Board <br />December 23, 2013 <br />Page 2 <br />1,900 feet from its northern boundary. Contaminants, odors, and vectors produced by the <br />Landfill have the potential to harm countless residents, farmers, and agricultural <br />consumers. <br />Forward Landfill's processing of cannery waste has the potential to threaten <br />water quality, generate offensive odors, and provide a substrate for the breeding of <br />vectors, and also has the potential to contaminate surrounding farmers' crops, resulting in <br />unsafe food sources and non-viable farming operations. This potential harm is especially <br />significant in the San Joaquin Valley, which is an invaluable source of food for California <br />and for the nation. <br />Clean San Joaquin seeks to ensure that the Water Board imposes measures <br />that are necessary to protect the health and safety of residents and the agricultural <br />community and lifestyle that is the strength and core of the San Joaquin Valley. <br />A. Forward Landfill Continues to Threaten Regional Water Quality. <br />Forward Landfill has been the subject of several Water Board Orders <br />resulting from its contamination of regional water resources. Discharges from the <br />existing facility already exceed state and federal water quality benchmarks. Further, a <br />Corrective Action Program (CAP) is already in place as a result of former measures' <br />ineffectiveness in stemming the advance of groundwater containing harmful levels of <br />volatile organic compounds (VOCs), such as acetone. These VOCs leached from the <br />Landfill and continue to taint drinking and irrigation water. Past Orders, the CAP, and <br />the degraded state of affected water bodies demonstrate Forward Landfill's record of <br />regulatory non-compliance. Because of this non-compliance, the water available to <br />adjacent lands continues to be degraded by the spreading VOC-contaminated <br />groundwater plume. Further contamination risks the health of other water bodies, and the <br />intensification of existing pollution levels. <br />Moreover, the San Joaquin River, the ultimate receiving water body for the <br />Landfill's discharges, is already impaired. See 2010 California 303(d) List of Water <br />Quality Limited Segments. Thus, the environment surrounding and including the <br />Landfill is especially sensitive and already significantly degraded. It is therefore critical <br />that the Water Board impose all measures that would prevent the Landfill from further <br />threatening the regional water supply. <br />Land application and disposal of cannery waste poses a serious threat to <br />water quality. Excess Nitrogen, heavy metals, and VOCs can leach from the waste into <br />groundwater and other water sources, such as the North and South Forks of Littlejohns <br />SHUTE, MIHALY <br />:`-W/EINBERGER�_�_P <br />