COMPLIANCE INFO_1990-1998 - Laserfiche WebLink

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�► • CITY OF TRACY 6 30 August 1990 , SLUDGE MANAGEMENT PLAN JULY 1990 established. While nitrogen, phosphorus and potassium content of the sludge will be important to K & L Farms, metals analysis will be required to insure that the maximum cumulative metal loadings are not exceeded. The recommended constituents for sludge monitoring are listed in Table 12 of the Report. The objective of the ground water monitoring will be to provide ongoing evaluation of the impacts that sludge application may have on shallow ground water in the vicinity of the site. The monitoring well network will consist of five new monitoring wells around the K & L site plus K & L's Agricultural Well 1, a 40-foot-deep well on the eastern corner of the site. It should be noted that the initial monitoring network will be only for the 300 acres surrounding the airport which the City will be using for the demonstration. The monitoring network will be set up to measure the constituents, listed in Table 12 of the Report, in the ground water and to determine the ground water flow direction and hydraulic gradient. The objective of the soils monitoring program will to evaluate the effectiveness of sludge treatment and to determine if the sludge application is impacting the soil . Soil samples from soil profiles collected from 0 to 8 inches and 8 to 48 inches will be analyzed for constituents listed in Table 12 of the Report. The Report recommends collecting annual soil samples from at least five different site locations. The sample for each depth at each location should be a composite of three auger borings taken from a 50-foot-diameter sampling area. Below is a list of our short- and long-term concern which must be addressed by the City. Some of the short-term concerns will also have to be addressed in any long-term proposal . SHORT TERM CONCERNS COMMENT 1: In the Ground Water Characteristic section, the Report states that ground water was not encountered above ten feet at the site. However, ground water may rise beneath the site during irrigation season which would allow for leaching of inorganics into the ground water, we are requesting that your include monitoring of your drains beneath the site. It is important that the ground water being monitored originate from beneath the areas in which the sludge has been applied. Therefore, the monitoring program should include the collection of water samples from the drains which has not commingled with water from areas surrounding the sludge application site. Also, water samples should be collected from upgradient of the site and from where the drain discharge leaves the site. COMMENT 2: In the attached 13 August 1990 memorandum (see Attachment 2) from Rudy Schnagl, Agricultural Regulatory Unit, made several comments regarding the crop and sludge application management at the site. Comments #2 and #3 in his memo have been addressed in the Report, Comment #1 (impacts on future sludge applications due to the slow release of nitrogen) and Comment #4 (including leaf analyses in the monitoring program for the site) of his memo still need to be addressed. We are requesting that