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�-� _ 13 September 1999 Mr. Jon G. Crawford - 2 - City of Lathrop Your concern regarding the location of the Stagno facility to future residential development is a land use issue. The adoption of WDRs for this facility is not the appropriate forum to discuss these concerns. We find,however, that this proposed slaughterhouse is consistent with the agricultural land use in this area of San Joaquin County. In any other event, the Board would require such a facility to discharge to a municipal system and provide a high level of pre-treatment prior to discharge. I would suggest that the - proposed septic tank and grease trap will not meet this higher level of treatment. Therefore I would request that the Board establish discharge requirements 30 mg/L BOD and 30 mg/L Suspended Solids, as you should any other discharger in this area. Monitoring should also be on a daily basis to ensure compliance. Contrary to your assumption, the Regional Board does not have the authority to require a permitted Discharger to hook-up to city sewer service. Should the Discharger elect to use this service, then pretreatment requirements would be established by the service provider in a user permit. The suggested effluent limits are applicable to a domestic wastewater treatment plant and are established as a performance standard,easily achieved with proper design and operation. We have compared the WDRs for the Stagno facility to other permitted slaughterhouses, and have also found that these limits are generally not established. In addition, we found that the monitoring frequencies varied, often with more frequent monitoring for the sites with much larger flows than that established for the Stagno facility. A semi-annual frequency for monitoring the effluent is appropriate where the flows will not exceed 30,000 gallons daily. 2. Grease traps only work if properly maintained. The discharge requirement should establish a cleaning schedule of a minimum of every 2 days. A cleaning schedule was not established in the Tentative WDRs. However, the WDRs prohibit the overflow of untreated or partially treated wastes, as well as, offal, fats, oils and greases (FOG) from being discharged to the holding pond or cropland. It is incumbent upon the Discharger to maintain the grease trap, to fully comply with the WDRs,which would require routine cleaning of the grease trap. 3. Screenings, FOG, offal and manure should be required to be hauled offsite every two days. Off-site removal of the screenings, FOG, and offal is required. Solids are prohibited from being discharged to land in the WDRs. The rates at which these wastes are removed are dependent on the rate at which they accumulate. Because the WDRs establish maximum limits for the disposal of wastes to land, establishing a schedule for removal of wastes off site is inappropriate,particularly if the Discharger operates at a volume less than allowed in the permit. Further, the WDRs specify that the treatment or discharge shall not create a nuisance condition, which may be invoked should the Discharger fail to manage the wastes in an appropriate manner. It is our understanding that the rate of waste removal is under the jurisdiction of other agencies, such as the County Health Department or the U.S. Department of Agriculture. 4. Borings from surrounding properties seem to indicate that the groundwater in the area is only 3-8 feet below existing grade. The proposed ponds would not be capable of meeting the 5-foot c:kkwfiles\agriculturc\aglettem\agltr011