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i..i <br /> RESPONSE TO WRITTEN COMMENTS -29- <br /> City Of Stockton -Regional Wastewater Control Facility <br /> NPDES No. CA0079138 <br /> 26 April 2002 Board Meeting <br /> RWQCB Response: The 7-day median is based on Title 22 regulations, which have been <br /> recommended by DHS. Please see section 9.1 of the Fact Sheet. <br /> Stockton CommentNo. Att. II.k.: Seasonal use is appropriate,people do not swim in the <br /> receiving waters during wet weather events or periods of cold temperatures. <br /> RWQCB Response: People are not precluded from swimming during the colder months. <br /> Additionally, DHS recently sent a letter to the Board dated 12 April 2002 reiterating their <br /> recommendation for year-round Title 22 reclamation requirements. The letter also emphasizes their <br /> concern regarding the prevalence of year-round subsistence sports fishing and shellfish harvesting <br /> within the proximity of the discharge. <br /> Stockton Comment No. Att. II.1: Uniform Guidelines provide no basis for turbidity limitation. <br /> RWQCB Response: The turbidity limitation is based on Title 22 regulations, which have been <br /> recommended by DHS. Please see section 9.1 of the Fact Sheet. <br /> Stockton Comment No. Att. Il.m: The City requests that the Regional Board maintain current <br /> disinfection requirements of 23 MPN/100 ml thirty-day median and 230 MPN/100 ml daily maximum. <br /> RWQCB Response: The comment is noted. <br /> DELTAKEEPER COMMENTS <br /> DeltaKeeaer Comment No. 1: The Discharger's Late Submissions Are Seriously Flawed. <br /> RWQCB Response: Comment noted. Detailed comments by staff regarding the submissions are <br /> contained in Attachments A, B, and C. <br /> DeltaKeeaer Comment No. 2: The Proposed Permit Fails To Consider Cumulative Effects. <br /> RWQCB Response: The permit recognizes that the river is impaired for a number of constituents, <br /> and takes steps to address the issues. It does not provide any dilution credits except for human <br /> carcinogens, and in that instance requires a study to address the cumulative impacts. It requires <br /> significant capital investment in new treatment processes, requires source control for several <br /> pollutants, and a mercury offset program. It also requires the initiation of a toxicity reduction <br /> evaluation to address chronic whole effluent toxicity issues. <br /> Keeper Comment N,): 3: The Permit Is Not Protective Of Enda ed Specie.. <br />