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N <br /> Response to Written Comments -31- 24 April 2007 <br /> City of Tracy WWTP <br /> San Joaquin County <br /> quality objectives for the south Delta are applicable for all locations in the south <br /> Delta. However, compliance with the water quality objectives will be determined <br /> at the three monitoring locations. The clarification in the December 2006 revision <br /> of the Bay-Delta Plan states the following in Appendix I (page 16): <br /> "Tables 1, 2, and 3 in the Plan provide the water quality objectives applicable <br /> to waters of the San Francisco Bay system and the legal Sacramento-San <br /> Joaquin Delta. Unless otherwise indicated, water quality objectives for a <br /> general area, such as the southem Delta, are applicable for all locations in <br /> that general area. The compliance locations indicated in the tables will be <br /> used to determine compliance with the objectives." (emphasis added) <br /> SDWA — NPDES COMMENT #9: The proposed Order describes how the contributions <br /> of Leprino Foods to Tracy's system sometimes average over 3000 TDS, yet the <br /> proposed Order does nothing to address this high salinity source. <br /> RESPONSE: The proposed Order requires the City of Tracy to meet best <br /> practicable treatment or control (BPTC) and requires the development and <br /> implementation of a pollution prevention plan in accordance with CWC section <br /> 13263.3. The City must address the discharges from Leprino Foods Company in <br /> addressing these requirements. <br /> SDWA — NPDES COMMENT #10: The proposed Order only speculates that reverse <br /> osmosis could resolve the concentration problems, with no analysis of other <br /> opportunities. Is there no opportunity to dilute the effluent before or after it is <br /> discharged? Has there been any public discourse on alternative methods of reducing <br /> the concentration and/or load? <br /> RESPONSE: The proposed Order requires the City meet BPTC, which requires <br /> a thorough evaluation of all alternatives to control the salinity of its discharge. <br /> The Regional Water Board cannot prescribe the methods of control. <br /> Regional Water Quality Control Board, Central Valley Region <br /> Board Meeting — 3/4 May 2007 <br /> Item#17 <br />