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Response to Written Comments -22- 24 April 2007 <br /> City of Tracy WWTP <br /> San Joaquin County <br /> Board is not required to include a compliance schedule in the permit. Regional <br /> Water Board staff is not proposing to make a change. The TSO and permit are <br /> consistent with past Regional Water Board practices. <br /> CITY OF TRACY - NPDES COMMENT #43: Page F-46, Paragraph V.C.3.x.vi. <br /> Salinity Sources. The City suggests the following changes to the paragraph related to <br /> the discharges from Leprino: <br /> OPGR beF 22nnn the The TDS of Leprino's pre-treated industrial wastewater <br /> discharged to the iRdl-StFa; ponds is primarily in the range of 1500 mg/L to 2300 <br /> mg/L. has an aveFage TDS of about 1000 mg/L, but tr pies to an aVeFage TDS of <br /> ever 3000;ng/L by the time the-wastewater is returned to the main ''aG '„ityThis <br /> results in a GigRifiGant salt load to the main treatment faGility, and ultiFnately W <br /> Old-RivPr Leprino's pre-treated industrial wastewater is then commingled with <br /> Discharger's water in the 52 acres of ponds and discharged to the main <br /> treatment facility." <br /> Request: Make the suggested changes to the paragraph above. <br /> RESPONSE: Some of the suggested language changes have been made to the <br /> tentative Order. <br /> CITY OF TRACY - NPDES COMMENT #44: Page F-62. Paragraph V.C.5.a. Acute <br /> Aquatic Toxicity. The City questions whether a reasonable potential analysis has <br /> been performed prior to inclusion of toxicity requirements in the draft permit. <br /> Request: Perform a reasonable potential analysis for acute toxicity prior to imposing <br /> limits for acute toxicity. <br /> RESPONSE: The Basin Plan states that "...effluent limits based upon acute <br /> biotoxicity tests of effluents will be prescribed where appropriate...". It is <br /> appropriate to include acute toxicity effluent limitations in the proposed Order, <br /> because the discharge contains toxic pollutants that if not properly controlled will <br /> cause or have the reasonable potential to cause or contribute to an exeedance of <br /> the Basin Plan's narrative toxicity objective. <br /> CITY OF TRACY - NPDES COMMENT #45: Pages F-65 and F-66, Paragraph V.D.1. <br /> Interim Limits. The Fact Sheet states that there are interim limits for Electrical <br /> Conductivity, when that interim limit was removed from the Permit. <br /> Request: Remove the Interim Limit language for EC from the Fact Sheet. <br /> Regional Water Quality Control Board, Central Valley Region <br /> Board Meeting —3/4 May 2007 <br /> Item#17 <br />