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Mr. Ross Atkinson February 4, 2014 Page 3 of nitrogen per acre that crops can, and actually will, take up; (2) require Forward to demonstrate how much additional nitrogen can be taken up by any particular crop areas; and (3) mandate that Forward regularly test to ensure that excess nitrogen is not accumulating in crop areas where more than 300 pounds of nitrogen is applied per acre. Finally, in Comment 31, Forward requested that dissolved oxygen be removed from the list of sampled substances in Table V of the MRP. The Water Board responded by removing dissolved oxygen from this list. Neither Forward nor the Water Board explained why it is appropriate to no longer test for dissolved oxygen. In the interest of transparency, the Water Board should provide an explanation as to why sampling for dissolved oxygen is no longer useful or necessary. If there is no adequate explanation for this change, the Water Board should reinstate the requirement to test for dissolved oxygen. II. The Water Board Should Enhance the Sampling and Monitoring Requirements in the WDRs and MRP. As mentioned in Clean San Joaquin's December 23, 2013 comment letter, the Final EIR for the Forward Landfill Expansion Project included a report by Lewis Engineering entitled Pilot Project Plan, Forward Landfill, Food Processing Residuals ("Pilot Project Plan"). The Pilot Project Plan detailed extensive sampling and monitoring techniques used at the site of Forward's cannery waste pilot project. See Pilot Project Plan at pages 5 to 13. Clean San Joaquin requested that the Water Board require Forward to implement this sampling and monitoring program with respect to all of its cannery waste application sites. Without such a program in place, the Water Board could not effectively ascertain the cannery waste's effects on odors, vectors, and water sources. The Pilot Project Plan included a number of important requirements, including: a worker health and safety plan; random selection of sample sites with one sample per acre of land -application surface, and additional sampling where a different soil condition is observed; more in-depth sampling at randomly selected sites; analysis of samples for total organic carbon, electrical conductivity, sodium, chloride, sulfate, TPH- GRO/DRO (C6 -C28), and pH, as well as metals identified in rinsate samples, including aluminum, arsenic, barium, cadmium, mercury, selenium, and vanadium, in addition to the substances identified in the WDRs; the requirement that labs analyzing the samples be state -certified, be certified in the analytical methods used, and follow and perform industry standard quality assurance and control methods; chain -of -custody documentation of samples; best practices (e.g., placing samples into a cooler immediately upon collection to ensure that samples accurately reflect soil conditions); decontamination procedures for reusable sampling equipment; taking a variety of field notes at each SHUTE MIHALY WEINBERGERLLP