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Response to Written Comments -4- 24 April 2007 City of Tracy WWTP San Joaquin County Discharger and approved by the Executive Officer shall not be considered "bypasses"or violations of this Order." RESPONSE: A change to Provision III.B. is unnecessary. See response to CITY OF TRACY — NPDES COMMENT #6. CITY OF TRACY - NPDES COMMENT #8: Section IV.A.1.a.- i. Final Effluent Limits. The use of the language "effective immediately" is confusing since some of the final limits are not effective immediately because interim limits apply. Request: Amend the language in Provision W.A.1. to read: "Effective immediately, the discharge of treated wastewater shall maintain compliance with the following final effluent limitations, or interim effluent limitations as applicable, at Discharge Point 001..." This will help avoid confusion over applicable limits and be consistent with footnote 5 on pg. 10. RESPONSE: Footnotes are included in the tentative Order to clarify there are interim effluent limitations for copper, BODS, TSS, turbidity, and total coliform organisms. Therefore, the proposed change is unnecessary. CITY OF TRACY - NPDES COMMENT #9: Section IV.A.1.a. Oil and Grease/Settleable Solids Limits. The Oil and Grease and Settleable Solids limits were imposed with no valid justification or statistical reasonable potential analysis for either constituent. There is no demonstrated reasonable potential to exceed the narrative objectives for these constituents because there is no evidence that these constituents are causing nuisance, visible film or coating (for oil and grease), or adversely affecting beneficial uses. Request: Remove the Oil and Grease and Settleable Solids limits. RESPONSE: Regional Water Board staff agrees that the record does not include sufficient information to impose effluent limits for these constituents. Therefore, a late revision is proposed to remove these effluent limitations. The proposed Order contains receiving water limits and monitoring. If further information demonstrates the need for effluent limits, the Order may be reopened to add effluent limits for these constituents. CITY OF TRACY - NPDES COMMENT #10: Section IV.A.1.a., Table 4, and Pages E- 4 and E-6. PH Limits. The City contends that continuous monitoring of pH is necessary and requests that monitoring be changed to a daily grab sample as is currently done. However, if the need for continuous monitoring is adequately justified, then the City requests the following language be added to a footnote to the limits for pH: Regional Water Quality Control Board, Central Valley Region Board Meeting — 3/4 May 2007 Item#17