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A <br />,_', <br />EOMUNO G. 6rm RoJR. <br />�SS <br />1�N : <br />GOVERNOR <br />C 4 L f O w w A <br />MATTHEW Roo.,ouE2 <br />Water Boards <br />SECRETARY O <br />FNVIRONM�NTAJ PFnTFP.TiCN <br />•.. '• •: • i •� <br />6 January 2014 <br />Peter Miljanich . JAN 1 201 <br />Shute, Mihaly &Weinberger LLP <br />396 Hayes St. EW-RONi�hlrA(. L , ; '� <br />San Francisco, CA 94102 PERMIT/ ERVICES <br />RESPONSE TO COMMENTS REGARDING WASTE DISCHARGE REQUIREMENTS FOR <br />FORWARD LANDFILL, SAN JOAQUIN COUNTY <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 I www.waterboards.ca.gov/centralvalley <br />%� pCCYCL[o PAPER <br />