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E Mr. Ross Atkinson February 4, 2014 Page 4 sample site (e.g., sample location and description, sketch of the sample area, date and time of sample collection, field instrument readings and observations, etc.); photographs at sample locations and surrounding locations; clear labeling of samples to facilitate tracking, including an identification number on each sample, and the location and date of sampling; and preparation of a sampling report. Pilot Project Plan at pages 5 to 13. The Water Board did not incorporate these procedures into the revised WDRs and MRP. Clean San Joaquin greatly appreciates the Water Board's decision to adopt of pre- and post -application sampling requirements in the revised WDRs. But pre- and post - application sampling is not enough to ensure the protection of water and environmental quality if careful sampling methods are not used. The Water Board should require Forward, in its sampling program, to comply with all of the procedures included in the Pilot Project Plan to ensure the continued health and safety of the Landfill's neighbors. The Water Board should require these sampling and monitoring techniques for all of the Landfill's cannery waste application sites. At the very least, the Water Board should require these procedures for all new operations at the Landfill involving cannery waste. These new operations include application of cannery rinsate to the compost facility, application of rinsate mud to the clay pad referenced in item 17, page 5 of the WDRs, and application of more than 300 pounds per acre of cannery waste to certain crop areas. Without careful sampling and monitoring, the Water Board will be unable to evaluate the contribution from these new operations to odor, vector, and water quality problems already present at the Landfill. In fact, Clean San Joaquin's December 23, 2013 comment letter requested that the Water Board "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." In response to this comment, the Water Board stated in its January 6, 2014 response letter: "Cannery rinsate may be discharged to the compost facility when the Discharger demonstrates to the satisfaction of Water Board staff that cannery rinsate does not cause nuisance odors or attract vectors." The Water Board should specifically require Forward to comply with the Pilot Project Plan sampling procedures as part of its demonstration that the rinsate does not contribute to odor, vector, and water -degradation problems at the compost site. III. Additional Mitigation Measures the Water Board Should Incorporate into the Final WDRs for Forward Landfill. In its December 23, 2013 letter, Clean San Joaquin requested that the Water Board: (1) regulate composting operations under Title 27; (2) require more frequent (than SHUTE MIHALY WEINBERGERLLP