SITE INFORMATION AND CORRESPONDENCE_CASE 2

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Response to Written Comments -19- 24 April 2007 City of Tracy WWTP San Joaquin County CITY OF TRACY - NPDES COMMENT #34: Pages D-6 and D-9 to D-10, Paragraphs V.B.2.a. and b., and VII.A. These paragraphs relate to Non-Municipal Facilities, do not apply and should be removed from this municipal permit. Request: Remove Paragraphs V.B.2.a. and b., and VII.A., and renumber Paragraph V.B.2.c. as V.B.2.a., and Paragraph VII.B as VII.A. RESPONSE: The provisions related to non-municipal facilities do not apply to the City's permit. However, to ensure consistency in NPDES permits the provisions will not be removed. CITY OF TRACY - NPDES COMMENT #35: Page E-2, Paragraph Il, Table of Monitoring Locations. The monitoring stations related to Outfall 002 (M-001 and R- 004) should be clarified to explain that these sites related to Outfall 002 need not be monitored unless and until Outfall 002 is operational. This change would be consistent with footnote 1 on page E-10. The City also suggests that R-001 be changed to "Old River, approximately 1 mile upstream of Outfall 001, downstream of the split of Old and Middle Rivers, see Figure E-1." Request: Add an asterisk at the bottom of page E-2 that states: " The Discharger need not collect samples from Outfall 002 or Monitoring Location R-004 until Outfall 002 is operational and in use."Amend the R-001 site as requested. RESPONSE: The City's request is reasonable and the suggested modifications have been made to the agenda version of the proposed Order. CITY OF TRACY - NPDES COMMENT #36: Pages E-4 and E-7 Methylmercury samples now required. The City contends that since the Delta mercury TMDL has not yet been approved, the imposition of methyl mercury monitoring is premature and should be removed. Request: Remove the methylmercury monitoring as there are no adopted criteria for methylmercury against which to compare monitoring data, and this monitoring has not been justified under Water Code §13267(b) and§13225(c). Instead, modify Provision V1.C.1. to authorize a reopener to amend the monitoring requirements after adoption of a mercury TMDL. RESPONSE: Section 13383 of the Water Code allows the Regional Water Board to require monitoring. The requirement to monitor for Methylmercury is appropriate, because the Delta waterways are listed in accordance with CWA Regional Water Quality Control Board, Central Valley Region Board Meeting — 3/4 May 2007 Item#17