SITE INFORMATION AND CORRESPONDENCE_CASE 2

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Response to Written Comments -18- 24 April 2007 City of Tracy WWTP San Joaquin County CITY OF TRACY - NPDES COMMENT #31: Provision VI.C.6.b. Collection System. The City very much appreciates the modification of the previously imposed requirements applicable to the collection system now that the collection system will be regulated separately under the statewide permit. However, the proposed provision uses language that might be interpreted to make compliance with that separate permit a condition of this NPDES permit. To remedy this problem, the language of this provision must be amended to state: "The Discharger shall be subject to the requirements of Order 2006-0003 and any future revisions thereto, which are not incorporated herein. Request: Clarify that the statewide collection system general permit is not incorporated by reference into this NPDES permit for the treatment plant. RESPONSE: The City's request is reasonable and the suggested language has been added to the agenda version of the tentative Order. CITY OF TRACY - NPDES COMMENT #32: Provision VII.G. Total Residual Chlorine Effluent Limitations (Section IV.A.1.e.) The City appreciates the changes made to this Compliance Determination section and inclusion of language related to continuously monitored chlorine residual or dechlorination agents. Nevertheless, the City contends that some of the new language is unnecessary and prejudges that something is a violation without a hearing, the ability to present defenses, or to explain the results. Request: Remove the first sentence from the last paragraph, which reads. 'Any excursion above the 1-hour average or 4-day average total residual chlorine effluent limitations is a violation." RESPONSE: The City's request is reasonable and the suggested modification has been made in the agenda version of the tentative Order. CITY OF TRACY - NPDES COMMENT #33: Provision VII.H. TDS Annual Mass Loading. The City questions the need for language that appears to create a rolling- annual average instead of a calendar year annual limit. The City requests that section H.2 be replaced with the following: "2. Twelve monthly mass loadings shall be calculated for each calendar month. The Discharger shall submit a cumulative total of the mass loadings for the previous calendar year in its annual report and the monthly mass loadings shall be reported twelve Aalpnda monthsy with each self-monitoring report." RESPONSE: The City's request is reasonable and the suggested modification has made in the agenda version of the tentative Order. Regional Water Quality Control Board, Central Valley Region Board Meeting — 3/4 May 2007 Item#17