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°Aa c SAW.10A0UIN --COU NTY c�tiFoaN`r' Greatness grows here. July 20, 2020 Chesney Consulting P.O. Box 3794 Turlock, California 95381 Environmental Health Department RE: Plan Check: Engineered Filter Beds -Design Not Approved 7095 East Sedan Avenue APN: 22610018, SR0082092 228 W. Klo Road APN: 191-240-18, SR0082168 27420 S. Walnut Ct. APN: 248-240-21, SR0082187 16479 S. Tide Road APN: 203-100-17, SR0082207 Wayne Fox, REHS, Interim Director PROGRAM COORDINATORS Robert McClellon, REHS Jeff Carruesco, REHS, RDI Willy Ng, REHS Muniappa Naidu, REHS Michael Kith, REHS Melissa Nissim, REHS The San Joaquin County Environmental Health Department (EHD) has completed the review of the plan check for the engineered filter bed designs for the four locations identified above. Note that the design for all four locations are basically the same. The Water Quality Control Board was consulted on this design but did not have enough internal knowledge to comment. They recommended EHD seek private consultation. EHD consulted with private practice engineers -Ron Crites, Brown and Caldwell and Norman Hantzche, Questa Engineering. Based on recommendation from consulting engineers and EHD staff, it has been determined that the design does not adequately address nitrate reduction and effluent disposal. EHD has determined the following: 1. The proposed design using the Infiltrator EZFIow system and vegetation to reduce the Nitrate loading for the parcel is an experimental concept not proven or tested through NSF or another third party - therefore it is not an approved technology. The systems are to serve permanent homes and determining if the design will work is not practical after the home is completed and in use. 2. The disposal design is inadequate and does not have the minimum disposal area required. The proposed design to use the EZFIow units in a grid pattern is not a true filter bed. When the soil is added back between the EZFIow units, the absorption area or the area where the leaching material contacts the soil is limited to the area of the EZFIow unit. The disposal area is to be sized to at least the minimum disposal area as designated in table 9.7.1 of the San Joaquin County onsite Wastewater Treatment System Standards. 3. The design is inadequate to address Nitrate reduction of the effluent and to keep Nitrate from migrating to the ground water. The effluent coming out of the septic tank is in the form of organic nitrogen and has not yet broken down to form the nitrate or ammonia used by plants because of a lack of oxygen in the tank. It will take time for the organic nitrogen to break down and most effluent will peculate into the soil below a depth that plants can uptake the nitrates before it breaks down. An effective treatment to break down organic nitrogen to nitrate and ammonia is to add oxygen to the septic tank in the form 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjgov.org/ehd