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f Messrs. Shareghi and Teed-Bose - 3 - 21 July 2008 <br /> k <br /> soil sampling program be implemented? If so, how will those decisions be made and <br /> what approval from the Regional Water Board will be sought? <br /> 12. The plan to compare the nitrogen concentrations in sludge to background soil <br /> concentrations (Section 4.3.2) is questionable. Typical domestic wastewater sludge is <br /> likely to have total nitrogen concentrations in the range of 2 to 5 percent (20,000 to <br /> 50,000 mg/kg) of total solids; native materials are unlikely to have comparable <br /> concentrations. <br /> 13. The size of the samples that will be collected may not be large enough to allow follow- <br /> up analysis if needed. For example, if total concentrations indicate soluble <br /> concentrations might impact groundwater quality, a waste extraction test may be <br /> justified. If inadequate sample remains, a second field sample collection event may be <br /> required. We recommend the sample size be evaluated with that possibility in mind. If <br /> needed, collect a larger sample. <br /> If you have any questions on this information, please contact me at (916) 464-4616. <br /> TIMOTH/RO�"BRIEN <br /> Waste Discharge to Land Unit <br /> cc: Mike Huggins, San Joaquin County Environmental Health Department, Stockton <br /> Micheline Doyle Kipf, P.G., Condor Earth Technologies, Inc., Stockton <br /> W 9$uRtObrimTSen losquinNountsin HouseMueShi I 1 July 08.doc <br />