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California,,"--gional Water Quality <br /> Ventral Valley Region <br /> Karl E.Longley,SeD,P.E.,Chair o <br /> Linda S.Adams Arnold <br /> Secretaryfor Sacramento Main Office Schwarzenegger <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 <br /> Protection <br /> Phone(916)464-3291 °FAX(916)464-4645 Governor <br /> http://www.waterboards.ca.gov/centralvalley <br /> 15 November 2007 <br /> Don Oliver <br /> Valley Organics, Inc. <br /> 12900 N. Lower Sacramento Road <br /> Lodi, California 95242 <br /> RESPONSE TO FOLLOW I- LETTER FOR VALLEY ORGANICS, INC., LATHROP, SAN <br /> JOAQUIN COUNTY <br /> The Regional Water Quality Control Board (Regional Water Board) 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 water pond in the event concentrations exceed existing <br /> underlying groundwater quality. <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 pont of view, reclassifies the "green waste" only <br /> operation and waste discharge requirements likely will be required. <br /> 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 BPs to <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 /> 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 /> Qa Recycled Paper <br />