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W wzo-� wow�- <br />-M 21 <br />J July 20, 2020 <br />FOR: Mr. Tom Patti, San Joaquin County Supervisor, District 3 <br />The San Joaquin County Board of Supervisors <br />44 North San Joaquin Street <br />Stockton, CA 95202 <br />The San Joaquin County Environmental Health Department (EHD) <br />1868 Hazelton Ave. <br />Stockton, CA 95205 <br />PROJECT: Onsite Wastewater Treatment System (OWTS) Designs <br />SUBJECT: Rebuttal to OWTS Design Review by Questa Engineering <br />Today, I received a Memorandum from EHD regarding an Onsite Wastewater Treatment System (OWTS) <br />review by Mr. Norman Hantzsche, PE of Questa Engineering. The review concerns an innovative OWTS <br />(septic) system design I was contracted to complete individually as the engineer -of -record for four <br />residential homeowners. This document not only provides rebuttal to Mr. Hantzsche's review of my report, <br />it also provides the San Joaquin County Board of Supervisors with information they should be made aware <br />of concerning EHD. <br />Mr. Hantzsche is a private consultant retained by EHD; he is not employed by the County. He has no <br />authority to approve or reject any OWTS design in San Joaquin County. This authority ultimately comes <br />from the Central Valley Regional Water Quality Control Board in Sacramento who can concur with, or <br />reject any design. <br />I would like to begin with background information. In addition to holding a CA Registered Civil Engineer <br />license, I have a degree in Plant Science/Agronomy from the University of California, Riverside, having <br />completed courses in soil physics, soil chemistry and soil biology. 1 am a certified agronomist, manure <br />management and nitrogen management plan specialist. No one else in the State of California holds these <br />credentials. I wrote the first Nitrate Loading Study for EHD almost 30 years ago, and have written <br />hundreds since, along with designing many wastewater treatment systems. <br />Mr. Hantzsche has addressed his comments in three separate Paragraphs of his review. My rebuttal will <br />correlate with each of these numbered Paragraphs. In Paragraph 1, Mr. Hantzsche references Section 10.9 <br />of the State OWTS Policy and that my design is not compliant with this Section. Section 10.9 is found in <br />the Tier 3 - Impaired Areas Section. There are no "Impaired Areas" in San Joaquin County, making <br />Section 10.9 inapplicable, and thus making his entire argument in Paragraph 1 moot. <br />In Paragraph 2, Mr. Hantzsche's goes into great detail to refute my design and calculations for leaching <br />area. Shockingly, he criticizes my design that has virtually no impedance to lateral effluent flow at the soil - <br />effluent interface (primarily the "floor" of the OWTS structure), while not understanding that conventional <br />"rock and pipe" has severe impedance to lateral flow due to drain rock covering more than 95% of the soil - <br />effluent interface. <br />Page 1 of 2 <br />P.O. Box 3794 ❑ Turlock, CA 95381 ❑ 209.402.1652 ❑ ddchesney(a charter.net <br />