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�./ April 2007 Response to Written Comments -3- 24 A P City'of Tracy WWTP San Joaquin County CITY OF TRACY - NPDES COMMENT #5: Finding Q. Monitoring Requirements. The second sentence in this finding is incomplete and should be amended. Request: Amend the second sentence as follows: "Sections 13225(c), 1321l and 13383 of the CWC authorize the Regional Water Boards to require technical and monitoring reports after the requisite burden analysis is performed." RESPONSE: It is not necessary to make the change. CITY OF TRACY - NPDES COMMENT #6: Provision III.A. Discharge Prohibitions. This provision should be clarified that it only covers treated wastewater. This prohibition should no longer cover untreated wastewater upstream of the headworks as that is now covered by the Sanitary Sewer Overflow waste discharge requirements and should not be duplicatively addressed here. Request: Insert the word "treated"so Provision IIIA. only applies to the "Discharge of treated wastewater." RESPONSE: The tentative Order prohibits discharges from the sewer collection system upstream of the headworks of the wastewater treatment plant. Therefore, a change to Provision IIIA. is unnecessary. Regardless of the coverage obtained under the Statewide General Waste Discharge Requirements for Sanitary Sewer Systems (Order 2006 0003), the Discharger's collection system is part of the treatment system that is subject to the tentative Order. As such, pursuant to federal regulations and as covered by the tentative Order, the Discharger must properly operate and maintain its collection system [40 CFR section 122.41(e)], report any non-compliance [40 CFR section 122.41(1)(6) and (7)], and mitigate any discharge from the collection system in violation of this Order [40 CFR. section 122.41(d)]. CITY OF TRACY - NPDES COMMENT #7: Provision III.B. This provision should only cover the by-pass and overflow of partially treated wastewater, not untreated as that is now covered by the Sanitary Sewer Overflow waste discharge requirements. It should also make clear that taking portions of process units out of service and partial bypassing of treatment processes performed in accordance with provisions of an Operational Plan submitted by the Discharger and approved by the Executive Officer shall not be considered "bypasses" or violations of this Order. Request: Replace the word "untreated" with 'partially treated."Add the following language at the end of this section: "Taking portions of process units out of service and partial bypassing of treatment processes performed in accordance with provisions of an Operational Plan submitted by the Regional Water Quality Control Board, Central Valley Region Board Meeting —314 May 2007 Item#17