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CITY OF TRACY 7 30 August 1990 <br /> SLUDGE MANAGEMENT PLAN <br /> JULY 1990 <br /> leaf analyses of the crops be included in the monitoring program to <br /> ensure that the sludge (nitrogen) is being applied at an agronomic rate. <br /> COMMENT 3: In the Soil, Water, and Crop Management section, the Report states that <br /> the 300-acre almond orchard will not be used for sludge application. It <br /> was not clear in the Report if the 1700 acres was used to determine the <br /> sludge application rates or the annual and cumulative loading limits. <br /> This concern must be addressed before either the current one-time <br /> application or any long-term proposal can be approved. <br /> LONG-TERM CONCERNS <br /> COMMENT 4: The Site Operations Plan states that the irrigation runoff from the <br /> entire farm as well as the sludge application site is captured and <br /> recycled. We request that the City conduct a liquid mass balance <br /> calculation that demonstrates that the runoff catchment basin can <br /> adequately contain runoff from the entire farm and prevent a discharge to <br /> San Joaquin River. <br /> COMMENT 5: The Site Operations Plan describes three options for sludge application <br /> at the site. Options A which includes a permanent onsite storage and <br /> Option B which includes a temporary facility, both require waste <br /> discharge permits which would not be adopted until after the period for <br /> fall tillage. Therefore, we recommend that you utilize Option C for <br /> sludge application which does not need a permitted onsite facility and <br /> could be approved in time for a fall application. <br /> RAE <br />