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Regional Water Quality Control Board December 23, 2013 Page 4 Processing Residuals"), and Lewis Engineering/GLA, Pilot Project Plan, Forward Landfill, Food Processing Residuals (2012), describe certain measures that are necessary to prevent adverse effects from the Landfill's cannery waste operations. The WDRs rely on the FEIR and its attachments, WDRs at 24, but do not include the full set of mitigation measures recommended in these documents. The WDRs should incorporate these requirements in order to protect local residents and water sources. A. Solar Drying The WDRs should require the Landfill to perform thorough solar drying of cannery waste, which is essential to prevent the breeding of vectors, to reduce noxious odors, and to prevent the percolation of harmful chemicals into water sources. Attachments to the FEIR outline detailed procedures that Forward should follow to fully dry cannery waste and thereby avoid the potentially injurious consequences of its disposal. In particular, the FEIR states that: (1) drying should be completed within five days; (2) the ground surface should be prepared prior to the application of waste; (3) waste should be spread 1"-3" deep in order to ensure complete drying; and (4) waste must be stirred at 12 -hour intervals with a spring tooth cultivation device in order to facilitate drying. See Food Processing Residuals at 3-1, Letter from Kevin Basso, General Manager of Forward Landfill, to Robert McClellan, San Joaquin County Public Health Services (Mar. 27, 2007) (appended to Food Processing Residuals). By contrast, the WDRs only generally require drying and the even spreading of cannery waste. Drying according to the FEIR specifications is necessary for several reasons. First, thorough drying prevents anaerobic decomposition, which is a primary source of the noxious odors that pervade the Landfill and surrounding area. Food Processing Residuals at 3-1. Second, complete drying within five days interrupts biting flies' lifecycles, and as mentioned above, biting flies are not only painful nuisances, but also potential disease vectors. Id. Drying also prevents the organic materials in cannery waste from being accessible as nutrition for other vectors, such as rats. Drying is therefore essential to confine pathogens contained in cannery waste. Third, without drying, various substances—Nitrogen, metals, and VOCs—can percolate into groundwater. WDRs at 19-21. Given that local groundwater is already polluted by landfill leachates, the Water Board should require Forward Landfill to rigorously manage its cannery waste facility to prevent additional contamination. Otherwise, the likely result will be the further degradation of local water sources. SHUTE, MIHALY WE[NBERGERu.P