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UP-88-16 page 2 Pit overtopping is a second potential source of ground water contamination from silage effluent. The pre-application does not identify pit capacities . Therefore, it is not possible to determine whether pits are adequate to accomodate the proposed waste volumes and seasonal storm water runoff. The site is sub- ject to flooding to an elevation of +25 feet (M. S .L. ) in a 100-Year Flood incident. No flood control or storm drainage measures are included in the pre-application proposal. It is apparent that an engineered silage system design must be prepared in order to address potential ground water contamination by silage effluent. Cattle manure storage and disposal poses another potential source of ground water contamination. The pre-application contains no information in regard to this issue. It is assumed, therefore, that cattle manure will be retained on site and distributed as a soil amendment for crop production. According to a recent staff conversation with the Regional Water Quality Control Board, it appears that a land use intensity of five steer per acre would generate the upper limit of organic constituency that could be consumed by a typical one-acre crop. The keeping of 200 steer on the 18 . 75-acre project site would generate an animal-to acre-ratio of 10 . 6 to 1 . Therefore, it seems that the quantity of manure generated by the feed lot use may exceed the absorption capacity of on-site crops . The unabsorbed constituents may percolate below crop root zones and down into the ground water aquifer. The project proponents submitted a letter (December 11 , 1987) as evidence that the feed lot and silage uses have attained a legal non-conforming status . The letter, and an attached letter from the previous property owner, state that, since 1962 , from 50 to 1000 head of livestock have been fed on site continuously. The attachment letter states that, since 1969 , the cattle have been fed cannery waste as well as other supplemental feed. Planning Division records dating back to 1961 do not disclose that any permits have been issued for these operations. Therefore, the Planning Division has determined that the feed lot and silage uses for the project site do not have a legal non-conforming status. Soil Amendment Use: The pre-application states that coffee grounds from a Ripon plant will be trucked in, spread out over a drying site, and then mixed with on-site soil stock piles on a 1 : 1 ratio for production of a landscaping soil. Supplemental information is necessary to complete the explanation of soil amendment operational character- istics and site utilization. Site Plan: The site plan submitted actually is the grading plan approved for a prevous excavation permit (EP-84-5) .