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t . 1 <br />G 1, OF Tnq,, _ <br />o3 CITY OF TRACY <br />m Utilities Division <br />rag a; 3900 Holly Drive t j P1 1: 2 1 Telephone: (209) 836-1650 <br />RPOV0, Tracy, CA 95376 Fax: (209) 836-0932 <br />September 12, 1994 <br />State of California <br />Regional Water Quality Control Board <br />Central Valley Region <br />3443 Routier Road, Suite A <br />Sacramento, Ca. 95827-3098 <br />Attention: Mr. Mike Mossbacher <br />Subject: Fall 1994 Sludge Pre -Application Report <br />The Waste Discharge Requirements issued to the City of Tracy require that a pre - <br />application report be submitted to your office before any sludge can be land applied each <br />year. The enclosed report contains all information specified in the Waste Discharge <br />Requirements. <br />As you can see, we will be applying sludge only on fields that are growing alfalfa this year. <br />In past years, we have been applying sludge to a mature almond field. The EPA 503 <br />regulations, however, specify that: "Food crops with harvested parts that touch the <br />sewage sludge/soil mixture and are totally above the land surface shall not be harvested for <br />fourteen months after application of sewage sludge Our farmer's almonds are shaken <br />onto the gound and harvested about eleven months after application. Previous analyses on <br />the sludge for pathogens have given results that met the EPA Class A requirements. One <br />sample from last spring, however, had 2 viable helminth ova measured per 4 grams of <br />solids (the requirement is less than one). We are concerned about the almond application. <br />We have collected nine samples recently for the pathogen analysis set, one from each bed <br />and one from the onsite stockpile left over from last year. We plan to apply any remaining <br />sludge that we have to almonds if these results meet the Class A requirements. Let us <br />know if you can help clarify this issue. <br />Our farmer hopes to apply sludge during the last week of September or first week in <br />October. Therefore, your approval would be appreciated as soon as possible. Please <br />contact us if you have any questions or comments about the planned application. <br />Sincerely, <br />(_�) —zc�. Ns;R-- <br />Darrell D. Scott <br />Water Quality Laboratory Supervisor <br />cc: Ed Padilla, San Joaquin County Dept. of Public Health Services <br />Ed Kaiser, K&L Farms <br />