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Regional Water Quality Control Board Response to Written Comments <br /> Regarding Stockton Regional Wastewater Control Facility Proposed <br /> Cease and Desist Order and Tentative Waste Discharge Requirements <br /> The following are responses to written comments received from interested parties in response to the <br /> proposed Cease and Desist Order and Tentative Waste Discharge Requirements (NPDES No. <br /> C-k0079138) for the Stockton Regional Wastewater Control Facility(RWCF), Stockton Califom;a <br /> ,sued on 15 February 2002. Written comments from interested parties were required to be received <br /> by the Regional Board by 22 March 2002 in order to receive full consideration. Comments were <br /> received by the deadline from: <br /> 1. City of Stockton, Department of Municipal Utilities <br /> 2. DeltaKeeper <br /> 3. US EPA Region IX <br /> 4. National Marine Fisheries Service <br /> Written comments from the above interested parties are summarized below, followed by the response <br /> of the Regional Water Quality Control Board (Board). <br /> CITY OF STOCKTON COMMENTS <br /> Comments on Proposed Cease and Desist Order <br /> Stockton Comment No. 1: The effluent limitations for ammonia are not justified. <br /> RWQCB Response: This issue will be dealt within our response to Section III, Ammonia, on page <br /> 19 of the City of Stockton's (City or Discharger) letter. <br /> Stockton Comment No. 2: The schedule that is stated in the proposed enforcement order is <br /> infeasible. <br /> RWQCB Response: Water Code Section 133850)(3) provides that subdivisions (h) and (i) do not <br /> apply to a violation of an effluent limitation where the waste discharge is in compliance with a cease <br /> and desist order, if several conditions are met. One of the conditions is that the time schedule may not <br /> exceed 5 years in length. The Cease and Desist Order was drafted to comply with this section of the <br /> Water Code, thereby preventing the imposition of mandatory civil penalties. Therefore, the schedule <br /> should remain as written. <br /> Stockton Comment No. 3: The Board should allow a schedule of compliance in the permit. <br /> RWQCB Response: The Clean Water Act requires publicly owned treatment works to comply with <br /> the secondary treatment and applicable water quality standards existing prior to 1 July 1977. The <br /> promulgated ammonia criteria and the narrative toxicity objective were in place prior to 1 July 1977. <br /> "S EPA 1999 Update of Ambient Water Quality Criteria for Ammonia did not signific. <br /> the numeric value for acute and chronic c ria for ammonia toxic ht genera., t <br />