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EDmuNc G. BROWN JR. <br /> GOVERIOR <br /> M....E,,Romouiiz <br /> NRV FOR <br /> FNV1RnNMFNTA1 PR0TFr.Ti0R <br /> Water Boards <br /> Central Valley Regional Water Quality Control Board <br /> 6 January 2014 IVED <br /> RE 41 1 <br /> 0 1 <br /> Peter MiIjanich JAN 2014 <br /> Shute, Mihaly &Weinberger LLP <br /> 396 Hayes St. ENVIRONMENTALI-IM- <br /> ,..,T <br /> FERMITISERVICES H <br /> San Francisco, CA 94102 <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 13: 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. Lot,IGLEY ScD, P.E., CHAIR 1 PAMELA C. CREECON. EXECUTIVE OFFICER <br /> 11020 Sur Center Drive#200,Rancho Cordova,CA 95670 5 --waterboards.ca.gov/centralvalley <br /> RECYC—-- <br />