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Response to Written Comments -16- 24 April 2007 <br /> City of Tracy WWTP <br /> San Joaquin County <br /> contrary to the ruling in SWRCB's precedential order in the Tosco Avon Refinery case, <br /> Order No. 2001-06. <br /> Request To remedy this problem, the words "and implement"should be removed, or <br /> the following sentence be added to the end of Provisions VI.C.3.a. and b.: <br /> ".... The Pollution Prevention Plan required herein is not incorporated by <br /> reference into this permit." <br /> RESPONSE: The suggested language has been included in the agenda version <br /> of the proposed Order. <br /> CITY OF TRACY - NPDES COMMENT #27: Provision VI.C.4b. Compliance <br /> Schedules. Phase 1 Improvements. The Regional Board should modify the language <br /> to state that "The permitted average daily discharge dry weather flow may increase to <br /> 10.8 mgd" upon compliance with the stipulated conditions. Further, the Regional Board <br /> should clarify that the average dry weather flow is defined as the flow for three <br /> consecutive dry weather months in a calendar year. <br /> Request. Make suggested changes to permit language. <br /> RESPONSE: The tentative Order includes flow limits expressed as "average <br /> daily discharge flow." Provision VI.C.4.b. provides the conditions upon which the <br /> permitted average daily discharge flow may be increased from 9 million gallons <br /> per day (mgd) to 10.8 mgd. There is no need to modify the term used for the <br /> permitted flow. <br /> The purpose of the effluent limitation for average daily discharge flow is to ensure <br /> that the Facility is operating within its design capabilities. Compliance with the <br /> average daily discharge flow is defined in Section VII.J. to be based on dry <br /> weather flows. A late revision is proposed to clarify the compliance <br /> determination language by stating that that compliance with the average daily <br /> discharge flow will be based on the average daily flow for three consecutive dry <br /> weather months in a calendar year, which is consistent with the design of the <br /> Facility. <br /> CITY OF TRACY - NPDES COMMENT #28: Provisions VI.C.4.b.i. and VI.C.4.c.i. <br /> Final Effluent Limits. The language of these sections needs to include "The discharge <br /> shall demonstrate compliance with Final or interim Effluent Limitations in Provision <br /> IV.A.1., Interim Effluent Limitations IV.A.5.d. and f., and Receiving Water Limitations <br /> V.A." <br /> Regional Water Quality Control Board, Central Valley Region <br /> Board Meeting— 3/4 May 2007 <br /> Item#17 <br />