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w r Regional Water Quality Control Board December 23, 2013 Page 5 B. Setbacks from Water Sources. The Water Board should require the Landfill to continue to use existing setbacks from water sources, if only to prevent any worsening of current levels of water quality degradation. Reports attached to the FEIR maintain that Forward Landfill has established 50-foot setbacks between the facility boundary and all naturally occurring water bodies. Food Processing Residuals at 4-1. Further, the reports specify that no water supply wells are to be located within 1,000 feet of the land application area. Id. These measures are essential to minimize available pathways for contamination to ground and surface water sources. Considering the Landfill's record of regulatory noncompliance, these setbacks are necessary simply to maintain current conditions, which, as discussed above, have already resulted in extensive contamination. The Water Board should not permit the Landfill to create further hazards to local water sources by permitting the Landfill to cease using these basic preventative measures. C. Daily Records of Waste Disposal, Location, and Unusual Occurrences, and Removal of Extraneous Material from Applied Cannery Waste. The Water Board should require the Landfill to keep daily records of all waste disposed of at the facility, disposal areas, and unusual occurrences, and should require the Landfill to remove extraneous material from applied cannery waste. Item K(7) of the Standard Provisions and Reporting Requirements attached to the WDRs requires Forward Landfill to "maintain legible records of the volume and type of each waste discharged at each waste management unit or portion of a unit, and the manner and location of discharge." This measure does not go far enough. In addition to the general provision contained in item K(7), the Water Board should require the Landfill to implement the daily recording measures discussed in the FEIR. This would include the daily recordation of(1) loads received, (2) locations of disposal, and (3) unusual occurrences, as well as the removal of extraneous material from the waste at the time of disposal. Letter from Kevin Basso, General Manager of Forward Landfill, to Robert McClellan, San Joaquin County Public Health Services (Mar. 27, 2007) (appended to Food Processing Residuals). It is imperative that these records be kept daily. The Water Board, the Landfill, and other interested parties, such as surrounding neighbors, will need this specific information in order to adequately monitor the Landfill's cannery waste operations. Without this level of detail, it could be impossible to trace odor, vector, and water-source contamination problems back to specific practices and discharges. Crucially, daily records would allow the Water Board and the Landfill to identify, track, prevent, and contain further water contamination. SH UTE_ MIHALY - u/EINBERGERu-P