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Regional Water Quality Control Board <br /> December 23, 2013 <br /> Page 7 <br /> the Landfill has completed this further investigation to the satisfaction of the Water <br /> Board—and if the Water Board nonetheless decides to permit disposal of cannery rinse <br /> water in the compost facility—the Water Board should regulate the composting operation <br /> under the stringent monitoring, siting, construction, and design standards applicable to a <br /> Class II waste pile under Title 27. <br /> In any event, the Water Board should revise the WDRs to include more <br /> stringent requirements related to the disposal of cannery rinse water in the compost <br /> facility. The proposed monitoring program only requires a quarterly monitoring of the <br /> retention basin liquid and of the leachate from active compost areas. Without <br /> significantly more detail, it could be impossible to trace odor, vector, and water-source <br /> contamination problems back to specific practices and discharges at the compost facility. <br /> The Water Board should establish enforceable odor standards, and should require the <br /> Landfill to install electronic or other proven odor-monitoring devices. The Water Board <br /> should require the Landfill to create a set of standard procedures—such as ceasing <br /> composting operations or covering compost piles—that it must utilize to remedy odor or <br /> vector problems if unacceptable odor or vector levels are reached. The Water Board <br /> should also require the Landfill to install additional vector control devices in the compost <br /> facility area. <br /> IV. Request to Revise WDRs and Incorporate Additional Mitigation Measures. <br /> Clean San Joaquin urges the Water Board to prohibit disposal of cannery <br /> rinse water into the compost facility and to incorporate the mitigation measures discussed <br /> above into the WDRs for Forward Landfill in order to avoid further degradation and <br /> contamination of water sources, the spread of disease-carrying vectors, and the <br /> proliferation of noxious odors. Without these precautions and enforceable measures, <br /> Forward Landfill's cannery waste operations will continue to threaten San Joaquin <br /> Valley's water resources. <br /> Very Truly Yours, <br /> SHUTE, MIHALY & WEINBERGER LLP <br /> Peter R. Miljanich <br /> 552884.10 <br /> SHUTE, MIHALY <br /> �- -WEINBERGERt_i.P <br />