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Ms. Nancy Takashiro - 2 - 8 September 1999 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. Stagno also proposed slaughtering a few animals a day now he has changed it to five-hundered per day. It seems like everything he proposed at the beginning, now he has changed them. We have no information regarding Mr. Stagno's original proposal. The estimated number of animals to be slaughtered daily was included in the Report of Waste Discharge submitted to our office on 2 April 1998. Our WDRs do not place limitations on the number of animals to be slaughter, rather the amount of wastes to be produced and discharged by the site operations. Therefore, the number of animals slaughtered could be greater than 500 on any given day,provided the Discharger can adequately manage all of the waste streams produced during processing and does not exceed the limitations established in the WDRs. Every neighbor for miles does not want Stagno's slaughter house located here. Property devaluation, flies, smell,water contamination, noise and the list goes on. It is not in our agency's jurisdiction to address potential property devaluation or noise from the proposed slaughterhouse. However, we can address your other listed concerns. As for the flies,we find that the Discharger sprays, at a minimum on a monthly basis,the manure storage area and the livestock currently held at the facility. When operations begin, this practice will continue. We have included this information as a new Finding in the WDRs. As for odors, there will be some associated with the holding of livestock and with management of the wastewater. There should be no odors from the slaughtering process as this is conducted indoors. A well managed facility can keep odors to a minimum. In addition, the prevailing winds in this area are from the west with an average annual wind speed of 7.4 miles per hour(new finding in the WDRs), which should keep odors to a minimum and away from the residences to the west of the site. As for water contamination, this cannot be addressed at this time as the facility has yet to be installed. The Discharger has proposed to line the wastewater pond,which will mitigate the potential for the downward migration of waste compounds. Groundwater monitoring will be required and will be used to assure that waste disposal practices do not pollute groundwater quality(refer to Groundwater Limitations and Provision F.5 in the Tentative WDRs). Stormwater from the roofs of the holding pens, manure storage area, and slaughterhouse will be captured and routed to the on-site stormwater detention pond (Finding No. 13). This is an acceptable method of stormwater management. The Tentative WDRs also contain several specifications regarding the requirements for stormwater runoff and the associated effects (Specifications B. 1 through 3, and 15). We have also discovered that they have, and will have no requirements of parking their diesel trucks and tractors on open dirt. All of their heavy machinery and vehicles should be required to park on pavement and not open land. This will only damage the groundwater from leaking gases and oils from the trucks. We ask that they build an area reserved for their heavy machinery, and that they monitor this area for contamination also. c:kkwtiles\agriculture\agletters\agltr008