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Regional Water Quality Control Board December 23, 2013 Page 6 I1' Proper Sampling To be effective, the WDRs must ensure that the Landfill follows proper sampling and monitoring techniques for its cannery waste operations. The Pilot Project Plan, attached to the FEIR, details extensive sampling and monitoring procedures, and careful handling techniques, that should be used to evaluate whether land application of cannery waste is further jeopardizing nearby water sources. Pilot Project Plan at 5-13. But the extensive sampling procedures outlined in the Pilot Project Plan are not mentioned in the WDRs. In light of the inadequacies of Forward's past practices, and the fact that cannery waste could further degrade regional water quality, the WDRs should incorporate these sampling and monitoring procedures. Without the comprehensive sampling and monitoring program discussed in the Pilot Project Plan, the Water Board cannot ensure that the sampling and monitoring procedures in place will reveal accurate data regarding the cannery waste's effects on water quality. At the very least, the Water Board should require the Landfill to sample soil in the application area prior to and after application. Without quantification of pre - and post -application conditions, Forward and the Water Board cannot assess the procedure's effects on the environment in general and on water quality in particular. These procedures are necessary to prevent the type of water pollution that the Landfill's operations have caused in the past. The Pilot Project Plan also included a worker safety plan. Pilot Project Plan at 6. Any testing, sampling, or monitoring that occurs at the land application site should explicitly incorporate this plan in order to ensure worker safety. III. The Water Board Should Prohibit Disposal of Cannery Rinse Water in Compost Facility. The WDRs state that "excess cannery rinse water may be treated in the compost facility." WDRs at 10. The existing compost facility creates serious odor and vector -related nuisances, and the addition of cannery rinse water to the compost facility can only exacerbate these nuisance conditions and threaten water quality. The Water Board should refuse to permit the discharge of cannery rinse water to the compost facility. At the very least, the Water Board should postpone any approval of cannery rinsate disposal to the compost facility until the Landfill has undertaken a detailed investigation of the cannery rinsate's contribution to the odor, vector, and water degradation problems that are already presented by the existing compost facility. After Sf-9UTEl, MIHALY ' WEINBERGERLLP