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Mr. Jon Crawford ? • 16 December 1999 the proposed NPDES permit, the City will have the associated responsibility, alone with other — dischargers, for bringing the San Joaquin River into compliance with water quality objectives. We reviewed the information the City submitted in their RWD. As discussed in our 17 November 1999 meeting, the City's application is deficient in many.areas. Following are issues requiring resolution: 1. Lathrop needs to better evaluate the constituents expected to be present in its treated wastewater effluent. The analyses required for the existing land application under the existing WDR are insufficient for evaluation of its appropriateness for surface water discharge. Data should be provided for all conventional pollutants, as well as priority pollutants, diazinon, and chlorpyriphos. Staff will need this information to assess the contribution of the proposed discharge to the impaired water body. The proposed discharge will be fundamentally different from the current.discharge at the Industrial WWTP, so analyses of that discharge may be of little use in evaluating the proposed NPDES discharge. 2. Form 200, Section V of the submitted application indicates that the proposed expansion of the wastewater treatment plant is exempt from the California Environmental Quality Act (CEQA) process. Additionally, it states that a Notice of Determination (NOD)has been filed. Please note that the NOD submitted with the application packet was filed in October 1991 and was specific for the design and construction of the existing 0.6 million gallon per day(mid)wastewater treatment plant. Your permit application specifies an increase of the average daily flow to 1.2 mgd. Also, as discussed at the meeting, the envisioned future treatment system will include multiple satellite treatment plants throughout the community that are linked and discharge through a master plant Because the future plans are significantly different from historical proposals, the CEQA process must be completed. 3. At our meeting,the City proposed the concept of a master plan for sewage management and treatment. You discussed the possibility that reclamation throughout the community m4y be__. possible, or that land at the nearby Libbey Owens Ford glass manufacturing plant may become available for land application purposes. Prior to proceeding with drafting either new waste discharge requirements or an NPDES permit .the Board will require a formalized sewage management plan. Please submit a copy of your draft Master Plan as soon as it is available. 4. The following comments pertain to EPA Form A, Section I: Item 7 is incomplete, as it did not estimate the total volume discharged in mgd. A clearer understanding of proposed surface water discharges needs to be presented. Item 8 states that there will be no intermittent, seasonal discharges,whereas this was the basic plan presented at the meeting. Please clarify your plans. Item 10 states the population served is 300,whereas you propose to discharge 1.2 mgd. Please correct the form to address plans for growth and development. Item 11 states there are no industrial flows to the facility,whereas the current treatment plant is accepting industrial wastewater flows from Nestles Company. All industrial flows must be addressed in the permit application. .