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., California kegional Water Quality Control Board - Central Valley Region j Steven T.Butler,Chair Winston 11.Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://w .sw b.ca.gov/-�gcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 8 September 1999 Mr. Rick Reed 840 Frewert Road Lathrop, California 95330 RESPONSE TO COMMENTS ON TENTATIVE WASTE DISCHARGE REQUIREMENTS, STAGNO'S MEAT COMPANY, SAN JOA QUIN COUNTY Thank you for your 11 August 1999 letter commenting on the Tentative Waste Discharge Requirements (WDRs) for Stagno's Meat Company. We have reviewed your comments and have provided responses. Your comments are provided below in bold face type followed by our response. I urge you to re-consider issuing a discharge permit to Stagno's Meat Company here in Lathrop, California. As a state agency, we do not have the authority to prevent the operation of a business,particularly when the business has submitted a Report of Waste Discharge (RWD). We are aware that many businesses operate illegally without permits, thereby challenging us to discover and enforce against the operation. In the case of Stagno's Meat Company, a RWD was submitted on 2 April 1998. We consider any operation that has applied for a permit, to have acknowledged our authority, thus providing us the mechanism to assure that water quality is protected. The San Joaquin River is one of the most polluted rivers in this state. We must put our foot down and say no more pollution. Clearly this proposed slaughterhouse will be dumping many kinds of chemicals into their waste ponds which will eventually end up on the soil, and then to the ground water. There is no limit on the amount of chemicals that they will use. Monitoring wells will only detect the rise in chemical levels after the damage has been done. The primary wastes that will be discharged from the slaughterhouse operations will consist of manured wastewater and rinsewaters from the slaughterhouse. The wastewaters will be discharged to only one pond,which is to be lined. The wastewater in the pond will periodically be applied to the cropland as it contains nutrients, which are beneficial to the soil and crops. The Discharger(Stagno) has proposed lining the pond,which will mitigate the downward percolation of wastewater. Further, Specification B. 8 of the Tentative WDRs require that the pond either be lined or underlain by soil which contains at least 10 percent clay, or artificial materials of equivalent impermeability, as mandated in Section 22562(d),Article 1, Subchapter 2, Title 27, of the California Code of Regulations. The permit also requires that the wastewater be applied to the cropland at agronomic rates to prevent leaching of wastes to the groundwater(Specification B. 11). Monitoring of the soil and groundwater are also required to c:\ckwfileslagricultum\agletters\agltr006 California Environmental Protection Agency 0 Recycled Paper