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OF TR,, CA <br />b3 0 <br />b ^i <br />[7 N <br />b T � <br />w� <br />f�C0RPORPs <br />Utilities Division <br />3900 Holly Drive <br />Tracy, CA 95376 <br />Telephone: (209) 836-1650 <br />Fax: (209) 836-0932 <br />soil due to sludge application is to a large extent balanced by plant uptake and soil <br />sorption. <br />Verification that Maxiumum Soluble Metal Concentrations for Soil Will not be <br />Exceeded (7) <br />Limitations to soluble metal concentrations in the soil could influence potential site life. <br />This was previously determined by life loading limits for each of the metals, so that the site <br />life was calculated directly from the metals content of the sludge. The objective of these <br />standards is to keep the metals concentration in the soil from reaching levels that could <br />lead to contamination of groundwater. If greater dilution could be demonstrated, then <br />these standards should be flexible according to the RWQCB. <br />Tables 7 and 8 were developed by our consultant and roughly predict ranges of site lifes <br />based on (1) background levels of heavy metals at K&L Farms, and (2) reported ranges of <br />soil properties for each metal. Based on these rough estimates, it appears that the site life <br />will not be shortened by the soluble metals limits in our permit. <br />Monitoring data, to date, has not shown that any single application of sludge has caused <br />soluble metals levels to exceed the specified limits. <br />