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Mr. Rick Reed *"' - 3 - Ift.00 8 September 1999 We have considered the existing location of the dry wastewater treatment pond to that proposed in the California Environmental Quality Act (CEQA) documents and in the Use Permit. If the pond is relocated south of the existing stormwater detention pond, then the area that the pond currently occupies would necessarily be converted to cropland (i.e. disposal field). According to our calculations, as much on-site acreage (9 acres) as possible will be needed for the agronomic disposal of the manured wastewater in order to prevent groundwater degradation. In addition, odor nuisances and uncontrolled runoff of the wastewater are more likely to occur if the area currently occupied by the wastewater treatment pond is used for cropland. Therefore, we will recommend to our Board to adopt the Tentative WDRs with the revision that the pond remains at its current location. 5. This area is windy year round and using sprinklers to spray wastewater will only end up on the neighbors land. A berm or ditch should be built around this slaughter house property to keep its wastes confined to their property. If sprinklers are to be used, then a high solid fence should be built to help keep the spray confined to their property. The ditch or berm would help keep run-off from spilling over. We concur with your concern regarding the need to keep the waste from the slaughterhouse operations within the property boundaries. The WDRs already require this as stated in Prohibition A.7 and Specification B.12. We have revised the language in Prohibition A.7 to try to address your concerns over the potential for wastewater overapplication by different methods. However,we cannot specify how Stagno applies his wastewater to the cropland, and thus cannot require that ditches,berms, or walls be constructed. We note however, that the prevailing winds are westerly,which would cause odors to be blown away from the adjacent residences. 6. This land and surrounding land is agriculture consisting of tomatoes, pumpkins, onions, etc. It is not pasture land or confined animal pens as stated in your report. Finding No. 19 described theeg_neral land use. However, in order to address your comment,we have clarified this land use finding to specify that found in the immediate area of the site. 7. The manure storage area should be enclosed and transported off site.sooner than stated in your report. The manure storage area at the Stagno facility has been constructed, is covered, and should be adequately protected during rainfall events. This storage area exceeds the quality of other manure storage areas typical of confined animal facilities. We are unable to address your comment regarding the schedule for transport of the manure. However,the WDRs do specify the average 30-day discharge of manure,which is based on the estimated manure production rate and days of operation. Specification C.2 in no way identifies the rate at which the manure is to be transported from the storage area. 8. We would also ask that an independent party be hired to monitor and test their monitoring wells, soil samples, and water run-off. The Discharger may either conduct his own monitoring or hire an outside firm. We cannot specify who shall conduct the monitoring. However, if a Discharger performs his own monitoring,we are c:kkwii les\agricultum\agietters\agltr006