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Mr. Ross Atkinson February 4, 2014 Page 2 comments. Clean San Joaquin respectfully requests that the Board reconsider these revisions. First, in response to Forward Landfill's comment 17 (regarding item A.8 on page 9 of the MRP), the Board states that sampling can be reduced at the cannery waste site "if justified and approved by Water Board staff." The term "if justified" is vague and does not provide an enforceable standard. Forward Landfill has a history of regulatory noncompliance, and groundwater continues to be contaminated by volatile organic compounds flowing from the Landfill. It is therefore critical that standards be concrete, meaningful, and enforceable. The Water Board should revise the MRP to include a concrete, objective, and quantitative standard. For example, the Water Board could revise the MRP so that "Sampling can be reduced if Forward has not applied cannery waste to the sample site for five continuous years, and will not apply cannery waste to the site in the future." In any event, the Water Board should replace the "if justified" standard with an objectively quantifiable measure that demonstrates sampling is no longer necessary to protect local health or environmental and water resources. Second, in response to Forward's comment 2 (regarding item 17 on page 5 of the WDRs), the Water Board agreed that cannery rinsate mud may be applied to air- dry on a compacted clay pad with other wastes. The same drying procedures that Clean San Joaquin requested, and the Water Board adopted, for other land -application areas— twice-daily tilling, complete drying within five days, and even spreading to no more than 3" thick, among others—must also be specifically required for rinsate applied to the clay pad. This other drying site may otherwise result in problems with nuisance odors, the proliferation of disease -carrying vectors, and water degradation. Third, in response to Forward's comment 8 (regarding item 7 on page 29 of the WDRs), the Water Board stated that Forward can apply more cannery waste on the land application area than would result in 300 pounds per acre of nitrogen, if that increased load "can be justified based on crop uptake." Additional nitrogen -rich cannery waste can only be properly applied if crops actually take up more nitrogen than 300 pounds per acre. The WDRs should directly and specifically state that more cannery waste can be applied only if crops used for nitrogen uptake can actually absorb 300 pounds of nitrogen per acre as well as the amount of nitrogen above the 300 -pound -per - acre level that is applied to the land surface. The provision, as currently written, is vague and could allow for the accumulation of excess nitrogen in land application areas. This accumulation could lead to the various harmful results identified in item 83, page 20 of the WDRs, including fly breeding and nuisance odors caused by anaerobic decay and the percolation of harmful metals into groundwater. The Water Board should revise this provision to specifically: (1) state precisely how the Water Board will assess the amount SHUTE MIHALY ' WEINBERGERLLa