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6 January 2014RE IVED <br />Peter Miljanich , <br />JAN 0 1201 <br />Shute, Mihaly & Weinberger LLP ENVIRONMENTALH L <br />396 Hayes St. PERMIT/SERVICES <br />San Francisco, CA 94102 <br />Central Valley Water Board staff has reviewed your comments of 23 December 2013 <br />concerning the Tentative Waste Discharge Requirements for Forward Landfill. Staff has the <br />following responses to your comments. We have paraphrased Clean San Joaquin's comments <br />preceding each of our responses. A copy of the comment letter is enclosed. <br />Comment A: Solar Drying <br />Drying is necessary to prevent anaerobic decomposition of the waste which is a primary source <br />of odors; complete drying within five days interrupts insect lifecycles; and drying limits waste <br />accessibility to vectors. <br />Response: The following has been added to the Discharge Specifications Section of the <br />proposed Order: <br />1. The Discharger shall implement the following BMPs for cannery waste: <br />a. The ground surface shall be prepared prior to the application of waste. <br />b. Waste shall be spread thinly, no more than 3 inches deep, to ensure complete drying <br />within five days. <br />c. Waste shall be turned twice daily with a cultivating device to facilitate drying. <br />Comment B: Setbacks from Water Sources <br />Setbacks should be established to protect water bodies and water wells. <br />Response: The following has been added to the Facility Specifications Section of the proposed <br />Order: <br />1. The Discharger shall maintain a 50 -foot setback between land application areas and all <br />natural occurring water bodies. <br />2. Land application areas shall be at least 1,000 feet from a domestic water supply well. <br />Comment C: Daily Records of Waste Disposal, Location, and Unusual Occurrences, and <br />Removal of Extraneous Material from Applied Cannery Waste <br />KARL E. LONGLEY ScD, P.E., CHAIR I PAMELA C. CREEDON. EXECUTIVE OFFICER <br />11020 Sun Center Drive #200, Rancho Cordova, CA 95670 1 wv—,waterboards.ca-govlcentratvauey <br />a?-CYCLCO --, <br />Eum, nc G. BRowr, JP. <br />GOVc FIi Ofi <br />p 4 L 1 V p W N 1 A <br />MATTHEW RooRIOUEZ <br />aterBoards <br />SECRETARY FOP <br />FNVIRnNM'r\Tpl PAOIF-I- <br />6 January 2014RE IVED <br />Peter Miljanich , <br />JAN 0 1201 <br />Shute, Mihaly & Weinberger LLP ENVIRONMENTALH L <br />396 Hayes St. PERMIT/SERVICES <br />San Francisco, CA 94102 <br />Central Valley Water Board staff has reviewed your comments of 23 December 2013 <br />concerning the Tentative Waste Discharge Requirements for Forward Landfill. Staff has the <br />following responses to your comments. We have paraphrased Clean San Joaquin's comments <br />preceding each of our responses. A copy of the comment letter is enclosed. <br />Comment A: Solar Drying <br />Drying is necessary to prevent anaerobic decomposition of the waste which is a primary source <br />of odors; complete drying within five days interrupts insect lifecycles; and drying limits waste <br />accessibility to vectors. <br />Response: The following has been added to the Discharge Specifications Section of the <br />proposed Order: <br />1. The Discharger shall implement the following BMPs for cannery waste: <br />a. The ground surface shall be prepared prior to the application of waste. <br />b. Waste shall be spread thinly, no more than 3 inches deep, to ensure complete drying <br />within five days. <br />c. Waste shall be turned twice daily with a cultivating device to facilitate drying. <br />Comment B: Setbacks from Water Sources <br />Setbacks should be established to protect water bodies and water wells. <br />Response: The following has been added to the Facility Specifications Section of the proposed <br />Order: <br />1. The Discharger shall maintain a 50 -foot setback between land application areas and all <br />natural occurring water bodies. <br />2. Land application areas shall be at least 1,000 feet from a domestic water supply well. <br />Comment C: Daily Records of Waste Disposal, Location, and Unusual Occurrences, and <br />Removal of Extraneous Material from Applied Cannery Waste <br />KARL E. LONGLEY ScD, P.E., CHAIR I PAMELA C. CREEDON. EXECUTIVE OFFICER <br />11020 Sun Center Drive #200, Rancho Cordova, CA 95670 1 wv—,waterboards.ca-govlcentratvauey <br />a?-CYCLCO --, <br />