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California Regional Water Quality Control Board <br /> vCentral Valley Region - <br /> Robert Schneider,Chair \9 \'/ <br /> Winston H.Hickox — fl - Gray Davis <br /> Secretaryjor Sacramento Main Office Governor <br /> Environmental Internet Address: http://w .sw cb.ca.gov/- gcb5 FEB 2 8 2003 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> TO: MICHAEL LEVY FROM: THOMAS R. PINKOS <br /> Senior Staff Counsel Executive Officer <br /> DATE: 27 February 2003 SIGNATURE: /i w►t�ct� <br /> SUBJECT: COMMENTS ONSTATE WATER RESOURCES CONTROL BOARD DRAFT ORDER <br /> IN THE MATTER OF THE PETITION OF THE CITY OF STOCKTON FOR <br /> REVIEW OF WASTE DISCHARGE REQUIREMENTS, ORDER NO. R5-2002-0083 <br /> (NPDES NO. CA0079138)AND CEASEAND DESIST ORDER NO. R5-2002-0084, <br /> CITY OFSTOCKTON, REGIONAL WASTEWATER CONTROL FACILITY <br /> SAN JOA QUIN COUNTY(SWRCB/OCC FILE A-1483) <br /> The Central Valley Regional Water Quality Control Board(Regional Board) appreciates this opportunity <br /> to comment on the draft State Water Resources Control Board (State Board) Order(Draft Order)in the <br /> matter of the Petition of City of Stockton for Review of Waste Discharge Requirements Order No. <br /> R5-2002-0083 (NPDES No. CA 0079138) and Cease and Desist Order R5-2002-0084 for the Regional <br /> Wastewater Control Facility(RWCF). Overall, the Regional Board strongly supports the Draft Order's <br /> conclusions regarding the Stockton permit. This memorandum re-emphasizes the Regional Board's <br /> position on three key permitting issues; dilution, ammonia, and tertiary treatment. The Draft Order <br /> upholds the Regional Board's decisions regarding these significant issues. <br /> DILUTION <br /> The over riding technical issue in the Stockton NPDES permit is whether dilution should be granted. <br /> The City developed seriously flawed water quality models that concluded there is assimilative capacity <br /> available for all pollutants. In contrast, the Regional Board found by analyzing net river flows, there <br /> was likely very little dilution during above average wet years. The Regional Board found it was <br /> reasonable to assume that the San Joaquin River(SJR) flows would be less during critically dry years, <br /> resulting in little or no dilution. Therefore, the Regional Board concluded that dilution should not be <br /> granted for most constituents. Given the severely impaired condition of the SJR,the presence of <br /> threatened and endangered species in the vicinity of the discharge, and the cumulative impacts of <br /> multiple pollutants present in the receiving water, the Regional Board found this conclusion to be <br /> reasonable and necessary to protect the beneficial uses of the receiving waters. The Draft Order finds <br /> that the Regional Board's determination to not grant dilution for most constituents was appropriate and <br /> proper. <br /> Dilution is a key issue. Without dilution credits, Stockton must meet stringent effluent limitations to <br /> protect the beneficial uses of the SJR. Despite more than a decade of study, there is no agreement <br /> between Stockton and the Regional Board on how to determine the dilution available for Stockton's <br /> California Environmental Protection Agency <br /> C4 Recycled Paper <br />