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ENVIRONMENTAL HEALTHIDEPARTMENT oAqu�nr, c SAN JOAQUIN COUNTY Q :a Donna K.Heran,R.E.H.S. Unit Supervisors " `' �` a Director 304 East Weber Avenue, Third Floor Carl Borginan,R.E.H.S. '` `• Al Olsen,R.E.H.S. Mike Huggins,R.E.H.S.,R.D.I. Stockton, California 95202-2708 C'q< F.Rw Program Manager Douglas W.Wilson,R.E.H.S. ° aurieA�.Cotulla,R.E.H.S. Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. Progrd Manager Fax: (209) 464-0138 Robert McClellon,R.E.H.S. Mark Barcellos,R.E.H.S. M June 16, 2005 David Welch, M. Sc., Sr. Geologist Neil O. Anderson &Associates, Inc. FILE COPY - 902 Industrial Way Lodi, CA 95240 RE: Liquid Waste Plan Check for 18325 South Airport Way, Manteca Land Use Application #PA-0400384, Service Request#SR0042582 San Joaquin County, Environmental Health Department (EHD) has received and reviewed the proposed engineered Orenco Advan Tex Wastewater Treatment system for the above referenced .Land Use Application. EHD has the following comments and concerns related to the proposed wastewater treatment system for this application: The EHD reviewed the studies provided from the University of California, Davis (UCD), NSF International, Ann Arbor, Michigan,and Novatec Consultants of Vancouver, British Columbia. As referred to in the Neil O. Anderson &Associates, Inc. (NOA) study and aforementioned I studies,reduction of Carbonaceous Biochemical Oxygen Demand(CBOD), Total Suspended Solids (TSS), and turbidity can be accomplished with the proposed treatment system. The NOA study states that the Advan Tex Treatment System can reduce total nitrogen levels 50 to 75%; however, information in the UC Davis study states a 30%reduction with little support data. The EHD is concerned that the studies submitted do not address denitrification. In fact, little or no measurements were reported for nitrate removal on the Advan Tex Treatment System. The EHD is requesting that you provide information preferably from a third party that has evaluated the Advan Tex wastewater system that demonstrates the system can produce effluent that meets the 10 mg/L as Nitrate-Nitrogen(N03-N). The EHD believes that this requirement is necessary in meeting the requirements of the Porter-Cologne Act. It has been two years since prior approval of a similar system at another site was granted. No results were submitted as requested by the EHD. The EHD would like you to consider the complexity of this wastewater treatment system. The EHD's approval of any of these systems will require a certified operator to maintain and operate the system, in addition to routine monitoring and reporting of effluent that would be reported by a State Certified lab to the EHD. If monitoring shows impact to above specified limits, then the owner and NOA would be responsible for reducing impact of the monitoring. If said system cannot meet the Porter-Cologne Act standards and permit requirements of the EHD, the system must be brought into compliance or the facility must connect to public sewer.