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Regional Water Quality Control Board <br />December 23, 2013 <br />Page 7 <br />the Landfill has completed this further investigation to the satisfaction of the Water <br />Board—and if the Water Board nonetheless decides to permit disposal of cannery rinse <br />water in the compost facility—the Water Board should regulate the composting operation <br />under the stringent monitoring, siting, construction, and design standards applicable to a <br />Class II waste pile under Title 27. <br />In any event, the Water Board should revise the WDRs to include more <br />stringent requirements related to the disposal of cannery rinse water in the compost <br />facility. The proposed monitoring program only requires a quarterly monitoring of the <br />retention basin liquid and of the leachate from active compost areas. Without <br />significantly more detail, it could be impossible to trace odor, vector, and water -source <br />contamination problems back to specific practices and discharges at the compost facility. <br />The Water Board should establish enforceable odor standards, and should require the <br />Landfill to install electronic or other proven odor -monitoring devices. The Water Board <br />should require the Landfill to create a set of standard procedures—such as ceasing <br />composting operations or covering compost piles—that it must utilize to remedy odor or <br />vector problems if unacceptable odor or vector levels are reached. The Water Board <br />should also require the Landfill to install additional vector control devices in the compost <br />facility area. <br />IV. Request to Revise WDRs and Incorporate Additional Mitigation Measures. <br />Clean San Joaquin urges the Water Board to prohibit disposal of cannery <br />rinse water into the compost facility and to incorporate the mitigation measures discussed <br />above into the WDRs for Forward Landfill in order to avoid further degradation and <br />contamination of water sources, the spread of disease -carrying vectors, and the <br />proliferation of noxious odors. Without these precautions and enforceable measures, <br />Forward Landfill's cannery waste operations will continue to threaten San Joaquin <br />Valley's water resources. <br />552884.10 <br />Very Truly Yours, <br />SHUTE, MIHALY & WEINBERGER LLP <br />Peter R. Miljanich <br />SHUTE, MIHALY <br />-WEINBERGERu_P <br />