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4 <br /> G,,•i OF TRq CY <br /> _ CITY OF TRACY <br /> _o <br /> i $I <br /> Utilities Division <br /> 3900 Holly Drive Telephone: (209)836-1650 <br /> 9 A+COApOtyp'tY'' Tracy, CA 95376 Fax: (209)836-0932 <br /> Analytical Results <br /> The attached tables shows analytical results obtained on samples collected in 1995. <br /> Results met or exceeded the compliance limits for a sludge applied as Class B. <br /> Vector Attraction Reduction <br /> Digested sludge is allowed to dry in our air drying beds for at least three months at <br /> temperatures over 0 degrees centigrade on a daily basis. The average sludge applied in fall <br /> of 1995 was over 75 percent solids. <br /> Our land applied sludge meets vector attraction reduction requirements because it is air <br /> dried, digested sludge that is applied at over 75 % solids. <br /> Operation <br /> Our permit requires that we track metals loadings, both annual and cumulative, to our <br /> fields. We can demonstrate from this data that we are meeting the Class B application <br /> requirements. Ongoing monitoring may show that we will consistently meet Class A <br /> requirements. <br /> I am enclosing annual and cumulative metals loadings for your review. <br /> In calendar year 1995, we applied sludge to fields that were used to grow baby lima beans, <br /> safflower and alfalfa. Since our program began in 1990, we have also applied to fields <br /> growing almonds and sugar beets. The almonds and beans are above ground food crops <br /> that are harvested prior to 14 months after application. We have confirmed, with you, <br /> however that almonds and beans, crops with hulls, were not intended to fall within this <br /> restriction. We will continue to consider it acceptable to apply to these crops, at <br /> agronomic rates, in the future. <br /> Certification Statement <br /> " I certify, under penalty of law, that Class B pathogen requirements in paragraph <br /> 503.32(b) and the vector attraction reduction requirement in paragraph 503.33(b)(8) have <br /> been met. This determination has been made under my direction and supervision in <br /> accordance with the system designed to ensure that qualified personnel properly gather <br /> and evaluate the information used to determine that the pathogen and vector attraction <br /> 2 <br />