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California gional Water Quality Cont of Board <br />Central galley Region <br />Karl E. Longley, SCD, P.E., Chair , y <br />Linda S. Adams <br />Secretatyfor Sacramento Dain office Arnold <br />Environmental 11020 Sun Center Drive #200, Rancho Cordova, California 95670-6114 Schwarzenegger <br />Protection Phone (916) 464-3291 • FAX (916) 464-4645 Governor <br />http://Nvww.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 UP 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 BMPs 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 />co Recycled Paper <br />