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Response to Written Comments -23- 24 April 2007 <br /> City of Tracy WWTP <br /> San Joaquin County <br /> RESPONSE: The proposed Order has been corrected. <br /> CITY OF TRACY - NPDES COMMENT #46: The City strongly urges the Regional <br /> Board not to adopt this Time Schedule Order and to instead include any necessary <br /> interim requirements suggested therein in the permit instead. Furthermore, the City <br /> contends that no TSO is needed for nitrate as there is no reasonable potential for nitrate <br /> and no limit is required and that neither a TSO nor interim limits for nitrite are needed as <br /> the City believes that it will be able to comply with the nitrite limit upon the effective date <br /> of the Permit. Finally, no TSO is needed for dissolved oxygen as an effluent limitation <br /> has not been adequately justified (see above) and the TSO contains no interim limit for <br /> DO. <br /> Request: Move all applicable and necessary requirements of the TSO, if any, into the <br /> Permit and delete the need to adopt a TSO. Make conforming changes as <br /> needed to the Permit and Fact Sheet. <br /> RESPONSE: The effluent limitations for dissolved oxygen and nitrate are <br /> appropriate, see response to CITY OF TRACY — NPDES COMMENT #16 and <br /> CITY OF TRACY — NPDES COMMENT #18, respectively. The compliance <br /> schedules for meeting these limitations must be in a TSO, because they are <br /> existing numeric standards. <br /> CITY OF TRACY - WDR COMMENT #1: The City reiterates its concern with the use of <br /> water quality objectives that are prospectively incorporated by reference from other <br /> agencies since those agencies do not follow the Water Code, CEQA, or the Clean <br /> Water Act when adopting those criteria. <br /> RESPONSE: MCLS and the narrative objective are adopted water quality <br /> objectives in the Basin Plan, and the Basin Plan includes a policy for <br /> implementation of the objectives, which is also adopted. Therefore, compliance <br /> with Water Code section 13241, CEQA, and the Clean Water Act is not required <br /> prior to implementation of those objectives in the Permit. <br /> CITY OF TRACY —WDR COMMENT #2: Finding 31 references Resolution 68-16, the <br /> state's antidegradation policy, as requiring these facilities to meet Best Practicable <br /> Treatment and Control ("BPTC"). However, it is not clear that this Resolution applies <br /> due to its application to "high quality waters." If the groundwaters are degraded as the <br /> Regional Water Board appears to state, then this Resolution would have no <br /> applicability. Until the background levels are determined, an antidegradation analysis <br /> as discussed in Findings 29-31 cannot be completed and BPTC may not be required. <br /> Regional Water Quality Control Board, Central Valley Region <br /> Board Meeting —314 May 2007 <br /> Item#17 <br />