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%W01 v <br /> Response to Written Comments -25- 24 April 2007 <br /> City of Tracy WWTP <br /> San Joaquin County <br /> the same hearing. For this reason, "Discharger' should be changed to "Leprino." <br /> Further, many of the standard provisions are of federal origin and do not apply to <br /> WDRs. Portions applicable to the WDRs should be cut out of the Standard Provisions <br /> and applied herein. Finally, there are duplications with the Standard Provisions that <br /> should be removed if the Standard Provisions are maintained as applicable directly. For <br /> example, Provision E.6 references "proper operation and maintenance," which is a <br /> requirement of the Standard Provisions. Additionally, Provision E.10. specifically <br /> references reporting requirements "[a]s described in the Standard Provisions." There is <br /> no need for such duplication and maintaining this duplication places the City in jeopardy <br /> of violating two permit provisions for a single action. For these reasons, the Regional <br /> Water Board should make the requested changes to remove the language applying the <br /> Standard Provisions to the City. <br /> RESPONSE: A late revision has been proposed for the tentative WDRs to clarify <br /> that to the extent that there are duplicate provisions they only apply once. <br /> CALIFORNIA SPORTFISHING PROTECTION ALLIANCE (CSPA) COMMENTS <br /> CSPA —NPDES COMMENT #1: The Order does not contain a protective or legal <br /> effluent limit for EC. <br /> RESPONSE: The Staff Report provides a detailed analysis of the compliance <br /> and permitting issues with respect to salinity. The Regional Water Board has <br /> several options to consider. <br /> CSPA —NPDES COMMENT #2: The proposed Permit contains a compliance schedule <br /> for aluminum based on "a new interpretation of the Basin Plan" as detailed in the Fact <br /> Sheet, page F-32 and Finding No. k. The Regional Board fails to provide any <br /> explanation or definition of the "new interpretation" of the Basin Plan. <br /> RESPONSE: There are a number of Basin Plan narrative standards that are the <br /> basis for numeric effluent limits. The two most common narrative standards <br /> impacting NPDES Permits are the "No Toxics in Toxic Concentrations" standard, <br /> and the 'Taste and Odor' standard. Time schedules can be included in permits <br /> for effluent limitations based upon "new interpretations' of narrative water quality <br /> objectives. An August 2005 Second District California Appeals Court Ruling <br /> [CBE v. SWRCB regarding the Avon Refinery (aka, Tosco Refinery)] greatly <br /> expanded the scope of "new interpretation". Any effluent limit based upon a <br /> narrative water quality objective is a "new interpretation" that will allow a time <br /> Regional Water Quality Control Board, Central Valley Region <br /> Board Meeting — 3/4 May 2007 <br /> Item#17 <br />