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PUBLIC HEALTH SERVICES <br /> OPOU'N•C <br /> SAN JOAQUIN COUNTY Q <br /> JOGI KHANNA M.D.,M.P.H. y: ` <br /> Health Officer <br /> pR a\P <br /> P.O. Box 2009 • (1601 East Hazelton Avenue) • Stockton,California 95201 CQC%F <br /> (209) 468-3400 <br /> April 6 , 1990 cop4cl.-) <br /> TO: Richard Larrouy, Associate Planner <br /> San Joaquin County Planning Division <br /> FROM : Fred Kaufman, Program Manager <br /> Environmental Health Division <br /> RE ! Tentative Waste Discharge Report <br /> Quality Assured Packing <br /> We have the following comments and concerns regarding the <br /> expansion of the facilities and its potential impact as a result <br /> of the modification of the Waste Discharge Report . <br /> 1 . We have received a significant number of citizen complaints <br /> each year as a result of discharges to surface disposal . <br /> The majority of the complaints were confirmed . The over 200 <br /> per cent increase in waste water flow has the potential to <br /> increase this number and over a broader area. <br /> 2 . The proposed year-round operation of the plant also will <br /> Impact waste water disposal . Evaporation rates and <br /> percolation rates vary seasonally . This also has the <br /> potential to increase complaints . The indicated use of well <br /> water in the summer season to dilute waste water will reduce <br /> BOD and Nitrogen loading; however, this will not be the case <br /> in the winter months . <br /> 3 . The uptake of Nitrogen varies according to the crop planted <br /> and the season of the year. It. appears that the consultants <br /> have written off water quality in the upper 90 feet and have <br /> also made the statement that NO3 levels from 69 to 71 ppm <br /> are only moderate . State and E .P.A . Drinking Water MCL' s <br /> for NO3 are 45 ppm in public water systems . Test results <br /> above 45 ppm exceed these standards . <br /> 4 . The consultant proposes that water quality in the Laguna <br /> formations are good . He does not state at what depths the <br /> Laguna formations are found . A check of well logs in this <br /> area indicate that most all wells , including QAP wells #1 <br /> and #2 , are grout sealed to 50 feet and then gravel packed <br /> to the well 's maximum depth . This furnishes a ready conduit, <br /> to introduce contaminates from the 50 to 90 foot range into <br /> the deeper aquifers . <br /> Environmental Health would recommend that an environmental review <br /> be done concerning water and waste water qual,,W issues . <br /> A Division of San Joaquin County Health Care Services N_J <br />