Laserfiche WebLink
\_ l <br /> Response to Written Comments -26- 24 April 2007 <br /> City of Tracy WWTP <br /> San Joaquin County <br /> schedule to be placed in an NPDES Permit when that effluent limit is first applied <br /> to that discharger. <br /> CSPA —NPDES COMMENT #3: The proposed Permit, Fact Sheet, pages F-30 and 31, <br /> removed two paragraphs discussing reasonable potential utilizing effluent variability and <br /> replaced them with a paragraph stating that all "reasonable potential" analyses with <br /> conducted in accordance with SIP Section 1.3 contrary to Federal Regulations 40 CFR <br /> § 122.44(d)(1)(ii). <br /> RESPONSE: Until adoption of the SIP by the State Water Board, USEPA's <br /> Technical Support Document for Water Quality-based Toxics Control (TSD) was <br /> the normal protocol followed for permit development for all constituents. The SIP <br /> is required only for California Toxics Rule (CTR) and National Toxics Rule (NTR) <br /> constituents and prescribes a different protocol when conducting a Reasonable <br /> Potential Analysis (RPA), but is identical when developing water quality-based <br /> effluent limitations (WQBELs). For some time after SIP adoption, SIP protocols <br /> were used for CTR/NTR constituents, and TSD protocols were used for non- <br /> CTR/NTR constituents. While neither protocol is necessarily better or worse in <br /> every case, using both protocols in the same permit has led to confusion by <br /> dischargers and the public, and greater complexity in writing permits. Currently <br /> there is no State or Regional Water Board Policy that establishes a <br /> recommended or required approach to conduct an RPA or establish WQBELs for <br /> non-CTR/NTR constituents. However, the State Water Board has held that the <br /> Regional Water Board may use the SIP as guidance for water quality-based <br /> toxics control. The SIP states in the introduction "The goal of this Policy is to <br /> establish a standardized approach for permitting discharges of toxic pollutants to <br /> non-ocean surface waters in a manner that promotes statewide consistency." <br /> Therefore, for consistency in the development of NPDES permits, we have <br /> begun to use the RPA procedures from the SIP to evaluate reasonable potential <br /> for both CTR/NTR and non-CTR/NTR constituents. <br /> CSPA —NPDES COMMENT #4: Table F-4, Statistics for Effluent Constituents with <br /> detectable Results, has been removed from the Fact Sheet contrary to the public's right <br /> to know. <br /> RESPONSE: Table F-4 has been added to the proposed Order. <br /> Regional Water Quality Control Board, Central Valley Region <br /> Board Meeting— 3/4 May 2007 <br /> Item#17 <br />