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Valley Organics, Inc. - 2 - 28 February 2008 40 40 liter (mg/L) in sample GP-2, and that nitrate exceeded the Primary MCL of 45 mg/L in GP-2 and GP-3. We also note that there is significant spatial variability in groundwater quality at the site with TDS ranging from 940 mg/L in GP-3 to 8,170 mg/L in GP-2, with groundwater quality worsening from north to south. According to the Letter Report and well search, an on-site domestic well is located on the Sanchez Property. Although it is staffs understanding the site is to be used as a place of business and not a residence, due to the high nitrate concentrations detected in the groundwater samples, staff recommends the on-site domestic well be sampled for barium and nitrate. Although underlying groundwater appears to be of poor quality in the proposed green waste composting area, we are still concerned that composting could cause groundwater to be further degraded. Therefore, we intend to issue a monitoring and reporting program for the site that requires monthly monitoring of the runoff pond and daily rainfall monitoring following a 30-day comment period. If monitoring indicates that the runoff in the pond could impact underlying groundwater, we may require a Report of Waste Discharge for issuance waste discharge requirements for the operation. The operation may also be subject to general waste discharge requirements for green waste composting facilities if and when an order is adopted by the Regional Water Board. It is our understanding that Valley Organics will prepare a Storm Water Pollution Prevention Plan that will include site-specific Best Management Practices for handling stormwater; enroll under the General Storm Water Permit for Industrial Activities; compact the on-site soils to 90 percent relative compaction to attain a permeability of 1x10-5 cm/sec; construct berms to prevent run-on; construct a retention pond to comply with San Joaquin County stormwater requirements; filter storm water run-off going into the retention pond; and conduct storm water sampling of any runoff from the pond twice per year for pH, TDS, total suspended solids, electrical conductivity, total organic carbon, oil and grease, ammonia as nitrogen, and TKN. The project may therefore proceed with the above understanding assuming Valley Organics has secured all other necessary permits and has completed CEQA. If you have any questions please call me at (916) 464-4622. WILLIAM BRATTAIN, P.E. Water Resources Control Engineer Title 27 Permitting and Mining cc: Robert McClellon, San Joaquin County Environmental Health Department, Stockton Mattew Cotton, Integrated Waste Management Consulting, Nevada City Jason Preece, ENGEO Incorporated, Ripon