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STATE OF CALIFORNIA- Environmental Prote Agency PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION OF <br /> 3443 Routier Road, Suite A --- <br /> S-^•amento, CA 95827-3098 <br /> JE: (916) 255-3000 <br /> r.. : (916)255-3015 -- �a,,,�,�.'a <br /> yIJ 101 <br /> 1 <br /> 4 <br /> J 7 November 1994 <br /> Kerry Sullivan �dl, 81994 <br /> San Joaquin County �UMN4dlyl l Y ULV C.Lvr r+Lid l JC~?' <br /> Community Development Department PLANNING DIVOR! <br /> 1810 East Hazelton Avenue <br /> Stockton, CA 95205 <br /> GENERAL PLAN AMENDMENT REGARDING SEWAGE AND SLUDGE DISPOSAL <br /> San Joaquin County is considering adoption of a General Plan amendment which would prohibit the <br /> treatment, storage or disposal of sewage or sewage sludge within the Delta Primary Zone if the <br /> wastes did not originate from within the Zone. We believe that this prohibition is not needed and <br /> may eliminate less expensive or environmentally preferable options for wastewater and sludge <br /> treatment and disposal. <br /> There certainly can be environmental, public health, and nuisance problems associated with the <br /> treatment and disposal of wastewater and sludge. These potential problems exist whether or not the <br /> wastes originate outside of the Primary Zone. However, the adoption of Waste Discharge <br /> Requirements by the Regional Board, and the CEQA review required for most projects, are <br /> specifically designed to identify, evaluate and mitigate these concerns. We see no inherent problems <br /> with the disposal of these wastes in the Delta Primary Zone which would justify the prohibition. In <br /> some circumstances, projects bringing wastes into the Zone may have less of an environmental risk <br /> or be more cost effective than treatment or disposal of those wastes outside of the Zone. With the <br /> prohibition, municipalities may have to pay more for wastewater and sludge disposal, either directly <br /> by having to move their wastes to a more distant location for disposal, or indirectly by having to <br /> provide a higher degree of treatment needed for some alternative method of disposal. <br /> We recommend against adoption of the amendment. <br /> If you have any questions, please contact Mr. Kenneth Landau at (916) 255-3026. <br /> 0". <br /> WILLIAM H. CROOKS <br /> Executive Officer <br /> cc: Regional Board Members <br /> Mr. Walter Pettit, Executive Director, State Water Resources Control Board, Sacramento <br /> Ms. Betsy Jennings, Office of the Chief Counsel, State Water Resources Control Board, <br /> Sacramento <br /> Ms. Marjit Aramburu, Delta Protection Commission, Walnut Grove <br />