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,*.W 1 .� City of Stockton and County of San Joaquin Page 12 NPDES Permit CAS0083470 Response to Comments described in the Tentative Order to reduce pollutant discharges to the MEP and assure continued compliance with water quality standards. When considering this issue, it is important to keep in mind that the City is currently in a growth phase. The City's own growth projections predict that Stockton will grow by 46,000 residents between 2000 and 2010. With these new residents will come a commensurate increase in the City's urban area, and the number of vehicles (and RGOs) in the City. These substantial new pollutant sources will increase the likelihood that pollutants like heavy metals and hydrocarbons will cause water quality impairment in the future. Inclusion of RGOs in the Permittees' Commercial/Industrial Program is one of many BMPs in the Tentative Order intended to mitigate the impacts of new pollutant sources. 11. Comment: Discharge Prohibition B.4 requires regulation of fire fighting activities. 40 C.F.R. section 122.26(b)(2) defines an illicit discharge as "any discharge to a municipal separate storm sewer that is not composed entirely of storm water except discharges pursuant to an NPDES permit . . . and discharges resulting from fire fighting activities." In addition, section 122.26(d),which governs application requirements for medium MS4s, requires the City to prepare a program to detect and remove illicit discharges. (40 C.F.R. § 122.26(d)(2)(iv)(B).) The regulations provide that "program descriptions shall address discharges or flows from fire fighting only where such discharges or flows are identified as significant sources of pollutants to waters of the United States." (40 C.F.R. § 122.26(d)(2)(iv)(B)(1).) Pursuant to these regulations, all flows from fire fighting activities are exempt from the permit requirements except where those flows are identified as significant sources of pollutants. Fire fighting training falls into the category of fire fighting activities, and is also exempt. Prohibition B.4 should therefore be deleted Response: The Regional Board disagrees that fire fighting training falls into the category of fire fighting activities. The proposed Order does not prohibit emergency fire fighting flows; it requires the permittees to coordinate with other agencies to develop a response plan to minimize the impacts of non-emergency fire fighting flows. Staff modified the permit to simply address non-emergency fire fighting flows. Both emergency and non-emergency fire fighting flows in an urban environment may contain extremely toxic materials such as high COD, metals, PAHs and other combinations of the combustion process. The City already has an emergency response plan required by CCR Title 19, EPCRA(Emergency Planning and Community Right to Know) and the California Health and Safety Code (HSC). The purpose of Hazardous Material Release Response Plans and Inventory set forth in HSC section 25500 et seq. is "to protect the public health and safety and the environment, through establishment of business and area plans relating to the handling and release or threatened release of hazardous materials."HSC § 25500 and those plans are to be"developed in consultation with the other agencies within the jurisdiction that are responsible for fire protection, emergency response, and environmental health. The City has a response plan and this Order encourages the City to continue that process and to consider a BMP to reduce the threat from fire fighting flows. Minor changes were made to the tentative Order to clarify the City's responsibility.