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Response to Written Comments -24- 24 April 2007 <br /> City of Tracy WWTP <br /> San Joaquin County <br /> RESPONSE: Regional Water Board staff agree that the BPTC evaluation study <br /> cannot be performed, or may be unnecessary, until the Discharger adequately <br /> characterizes background groundwater quality. Therefore, the BPTC evaluation <br /> study is only required if the groundwater monitoring results show that the <br /> discharge of waste is threatening to cause or has caused groundwater to contain <br /> waste constituents in concentrations statistically greater than background water <br /> quality. This change has been made in the agenda version of the proposed <br /> WDRs. <br /> CITY OF TRACY — WDR COMMENT #3: Finding 41 sets forth the legal requirements <br /> of Water Code section 13267(b), but does not contain an analysis of the costs and <br /> whether those costs bear a reasonable relationship to the benefits to be received, and <br /> do not identify evidence for the need for the required reports. This analysis and <br /> evidence must be supplied prior to imposing monitoring and reporting requirements. <br /> RESPONSE: The monitoring requirements in the proposed WDRs are the <br /> minimum necessary to determine compliance with the requirements. <br /> CITY OF TRACY — WDR COMMENT #4: The Order section of the WDR on page 11 <br /> does not act to rescind the previous permit. Rescission language should be added to <br /> ensure that two different permits are not regulating the same facilities/discharges. <br /> RESPONSE: There are no previous versions of waste discharge requirements <br /> for this Facility, therefore, there is nothing to rescind. The proposed NPDES <br /> permit rescinds the old NPDES permit, which includes land discharge <br /> requirements. The proposed NPDES permit will be heard at the same hearing as <br /> the proposed waste discharge requirements to regulate the land discharge units. <br /> CITY OF TRACY — WDR COMMENT #5: Provision EA. seems to authorize the <br /> Executive Order to revise the MRP. To the extent that the MRP is part of the WDRs, <br /> this language appears to be prohibited by CWC section 13223 and should be deleted. <br /> RESPONSE: These requirements are waste discharge requirements, not an <br /> NPDES permit. Water Code section 13223 authorizes the Regional Water Board <br /> to delegate authority to the Executive Officer to issue and revise monitoring <br /> programs. To the contrary, some revisions to NPDES monitoring programs, in <br /> particular reduction in monitoring, must be made by the Regional Water Board <br /> after a public hearing. <br /> CITY OF TRACY — WDR COMMENT #6: Provision E.5. requires that the "Discharger <br /> shall comply with the 'Standard Provisions..."'. However, Tracy is already required to <br /> comply with the Standard Provisions under its NPDES permit, which is to be adopted at <br /> Regional Water Quality Control Board, Central Valley Region <br /> Board Meeting — 3/4 May 2007 <br /> Item#17 <br />