SITE INFORMATION AND CORRESPONDENCE_CASE 2

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California K ional Water Quality Contr,..,Board Central Valley Region t Karl E.Longley,SCD,P.E.,Chair Arnold Linda S.Adams 11020 Sun Center Drive 4200,Rancho Cordova,California 95670.6114 Schwaraenegger Secretaryfar Phone(916)464-3291 -FAX(916)464-4645 Governor Environmental http.11www.walerbowds.ca.gov/centralvalley Protection 4 March 2009 Ms. Jeanine Townsend, Clerk to the Board State Water Resources Control Board 1001 1 Street, 24th Floor 95814 Sacramento, CA 95812-0100 COMMENTS FOR PETITION OF WASTE DISCHARGE REQUIREMENTS ORDER NO. R5-2007-0036 FOR THE CITY OF TRACY WASTEWATER TREATMENT PLANT, SWRCB/OCC FILE NO. A-1846(a) and A-1846(b) — 17 MARCH 2009 STATE WATER RESOURCES CONTROL BOARD MEETING Thank you for the opportunity to comment on the 2 February 2009 draft State Water Board Water Quality Order (Draft Order) referenced above. The Central Valley Regional Water Quality Control Board (Regional Water Board) agrees with portions of the Draft Order, but has concerns with some issues. The Regional Water Board comments are discussed below. The City of Tracy has recently completed a major expansion of its wastewater treatment plant, including construction of tertiary filtration for pathogen removal, and nitrification/denitrification treatment units to address water quality issues in the southern Delta. Electrical Conductivity The City of Tracy's discharge has elevated levels of salinity, which led the Regional Water Board to conclude that the discharge has reasonable potential to cause or contribute to an exceedance of the Bay-Delta Plan's water quality objectives for electrical conductivity in the South Delta. Federal regulations require water quality-based effluent limitations be included in the permit based on the Bay-Delta Plan objectives. The City could not immediately comply with such limitations; therefore, a compliance schedule is necessary. In this case, a compliance schedule cannot be included in the permit, because the Bay-Delta Plan objectives are existing requirements. A compliance schedule is required in a separate enforcement order, such as a time schedule order. To comply with the requirements of CWC 133850)(3), which allows for an exemption from the issuance of mandatory minimum penalties, the time schedule could not exceed five years. The draft Order suggests adopting a TMDL or basin plan amendment if source reduction and/or treatment are not feasible. Recent experience suggests that five years is not adequate time to consider the salt reduction study and other alternatives, and complete a planning process that would resolve the City of Tracy's noncompliance. Modification of the south Delta salinity objectives has already been under active consideration for at least four years. (Order WQ 2005-0005 [City of Manteca]; Notice of Public Staff Workshop at http://www.waterrights.ca.gov/baydelta/docs/southerndeltasalinity/ notice 021809.pdf.) California Environmental Protection Agency Q j Recycled Paper