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•r <br /> I <br /> ` Californiaegional Water Quality Control Board <br /> 'It. 14 V'j <br /> ti Central Valley Region <br /> Linda S.Adams <br /> Karl E. Longley,ScD,P.E.,Chair- <br /> Secretaryfor Sacramento Main Office Arnold <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Schwarzenegger- <br /> Protection Phone(916)464-3291 •FAX(916)4644645 Governor <br /> http://www.waterboards.ca,gov/certralval ley <br /> LF <br /> 15 November 2007 v E'DD <br /> 1 r <br /> i�. <br /> NOV 1 9 Q07 i <br /> j <br /> Don Oliver ENVIRC}il HENT HEALTH <br /> f <br /> Valley Organics, Inc. PERMIT/SERVICES . <br /> 12900 N. Lower Sacramento Road ' <br /> Lodi, California 95242 p <br /> -RESPONSE T-0 FOLLOW-UP=LETTER FOR--VALLEY ORGANICS, SAi1f­ --� <br /> JOAQUIN COUNTY <br /> J <br /> The Regional Water QualityControl Board (Regional Water Boar <br /> ( g d) staff has reviewed the <br />' letter response to a meeting between Valley Organics, Inc. and Regional Water Board staff on <br /> 21 September 2007, During the meeting., staff expressed concern over the type of feedstock <br /> that Valley Organics would be composting; storm water management, process water quality, <br /> underlying groundwater quality, protection[,of underlying groundwater quality, and a <br /> contingency plan to line the process waterkpond in the event concentrations exceed existing <br /> underlying groundwater quality. <br /> n <br /> Based upon the information provided in the Response Letter dated 26 October 2007, Valley <br /> Organics, Inc. is proposing to compost "green waste" only generated from landscaping <br /> operations. However, the Feedstock Quality section indicates Valley Organics anticipates <br />` utilizing "incidental" amounts of manure as;a feedstock to increase the carbon to nitrogen ratio. <br /> Manure is known to contain high nitrogen and metals that present a threat to water quality. <br /> The use of manure, from a water quality point of view, reclassifies the "green waste" only <br /> operation and waste discharge requirements likely will be required. <br /> 4,=�Valley Organics proposes-to=employ_best management practices`(BMPs) to control run=on; - -� <br /> direct storm water and process water to the unlined retention pond, install wattles or filter <br /> socks to slow storm water flow into the retention pond, and other site specific BMPs to <br /> w <br /> minimize debris entering into the retention pond. Also, Valley Organics provide storm water <br /> quality data from other similar"green waste" composting facilities for comparison to data <br /> provided by staff in a letter dated 25 April 2007. The information presented indicates that <br /> electrical conductance (EC) and total suspended solids exceeded EPA benchmarks and that <br /> elevated EC measurements were a result of total dissolved solids (TDS). <br /> Although the Response Letter did not reference the source of information or provide analytical <br /> results for direct comparison, the constituents discussed are similar to the findings staff had <br />'i presented in the 25 April 2007 letter. This indicates the leachate associated with "green ' <br /> waste"-composting develops elevated concentrations of certain constituents above water <br /> quality objectives. <br /> California Environmental Protection Agency <br /> Recycled Paper <br /> I: I <br />