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Mr. Jon G. Crawford NVI - 3 - `WI 13 September 1999 City of Lathrop separation requirement without a waiver by your Board to this requirement. Even if you utilize the information cited in Finding 15,the applicant cannot meet the 5-foot separation requirement. Should the Regional Board waive this requirement for this the permit,the City of Lathrop would expect similar action on our existing and future waste discharge requirements. We consider on-site data to be more valid than off-site data when evaluating the hydrogeology of a specific location. The Report of Waste Discharge provided the results of three deep borings, which were drilled at the Stagno site in January 1998 when groundwater levels would be expected to be at the. highest levels. Depth to groundwater was encountered in these borings at 10.7, 10.4 and 7.8 feet below ground surface. The boring with the shallowest groundwater was installed east of the stormwater detention pond. The wastewater treatment pond is in an area of higher ground elevation than the area surrounding the stonnwater detention pond. The base of the pond is approximately 4 feet below grade. Therefore, a 5 foot separation between the base of the pond and groundwater has been maintained with the pond in its current location. 5. Requirement B-16 does not define "excessively objectionable odors...". This definition should be spelled out and easily defined, so that the Regional Board staff will be able to explain to every resident of Lathrop why the odors emanating from this facility are not objectionable. The language in this Specification has been modified as follows: "Objectionable odors originating from this facility shall not be perceivable beyond the limits of the property owned by the Discharger." The requirement against odor emissions is standard language in all WDRs. However, it should be noted that the area is zoned for agriculture, and therefore, odors are to be expected. A well managed facility should keep odors to minimum. According to the National Weather Service, the average wind direction is westerly with an average wind speed of 7.4 miles per hour. The Stagno site is approximately 2 miles northwest of the City of Lathrop. Prevailing winds would not blow odors southeastward toward the City. The City of Lathrop requests that the Regional Water Quality Control Board deny the application for waste discharge requirement for Richard Stagno, Stagno's Meat Company due to inadequate treatment capability and facilities, and the potential damage to surrounding residents and property as a result of the inadequate treatment of the proposed waste stream, Should the Board consider issuing requirements for Stagno's Meat Company, the City of Lathrop would request that additional requirements be placed on the discharger as described above. The Discharger submitted a RWD,which was found complete, and WDRs were prepared. WDRs provide the mechanism to assure that water quality is protected. We therefore see no need to prevent issuance of the WDRs. We believe that with lining of the wastewater treatment pond and with effluent, soil, and groundwater monitoring, sufficient mechanisms are in place to protect water quality. c:kkwfrIes\agriculture\aglett s\ag1tr011