SITE INFORMATION AND CORRESPONDENCE_CASE 2

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Response to Written Comments -14- 24 April 2007 City of Tracy WWTP San Joaquin County RESPONSE: Regional Water Staff believe references to a separate Order that regulates the groundwater discharges are appropriate. Furthermore, the request to remove the sections relating to groundwater and renumber the table of contents cannot be granted. The sections must remain to maintain consistency in the section numbering. It has been stated that these sections are not applicable. CITY OF TRACY - NPDES COMMENT #22: Provision V.A.6.b. and V.A.13.f. MCLs. The tentative permit applies MCLs for radioactivity and pesticides directly to surface waters even though MCLs only apply to treated, served tap water. Request: For the reasons provided herein and previously in comments related to the use of MCLs, Provisions V.A.6.b. and V.A.13.f. should be deleted. RESPONSE: The receiving water has the designated beneficial use of municipal and domestic supply. The Basin Plan includes water quality objectives for radioactivity and pesticides requiring waters designated for use as domestic or municipal supply shall not contain concentrations of pesticides or radionuclides in excess of the Maximum Contaminant Levels. The receiving water limitations implement the Basin Plan. CITY OF TRACY - NPDES COMMENT #23: Provisions VI.A.2.c. (second paragraph) and VI.B.1. Unlawful Permit Modification. The City objects to provisions that purport to require compliance with new regulatory effluent standards and prohibitions and new monitoring requirements even without an amendment of the permit. Request: Remove the second paragraph of Provision VI.A.2.c. and the portion of V1.B.1, which states ", and future revisions thereto." RESPONSE: The permit does not delegate authority to the Executive Officer, nor require compliance with prospective objectives. The permit includes a reopener. The permit does state that if a new federal law or regulation requires immediate compliance, dischargers would have to comply with that new law or regulation. CITY OF TRACY - NPDES COMMENT #24: Provision VI.C.1.g. Water Effects Ratios (WER) and Metal Translators. The language should be modified to state that if the Discharger spends the time, cost, and effort to perform a scientifically valid study to determine site-specific WERs and/or site-specific dissolved-to-total metal translators for copper, iron, and/or aluminum, and if those study results are approved by the Regional Water Quality Control Board, Central Valley Region Board Meeting —3/4 May 2007 Item#17