SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

� J RESPONSE TO WRITTEN COMMENTS _32_ City Of Stockton - Regional Wastewater Control Facility NPDES No. CA0079138 26 April 2002 Board Meeting limits for CBOD and ammonia, organic nitrogen was overlooked in the last permit. The proposed Permit continues this backsliding by again failing to include a limit for organic nitrogen. Water quality based limits controlling constituents causing and/or contributing to oxygen depletion in the lower San Joaquin River must be included in the Tentative Permit. The Permit must establish a water quality based limit for CBOD plus ammonia plus organic nitrogen. The mass loading of oxygen demand constituents must be held to current levels. Finding No. 39 states that the wastewater treatment plant is an important source of oxygen demand in late September and early October. The Finding must be changed to reflect the fact that the plant is also the dominant source of oxygen demand constituents during November and early December. Finding No. 38 states that staff has committed to develop a TMDL control plan by June 2003. The DO TMDL Technical Committee has made admirable progress to that end. The Implementation Plan for the TMDL is not scheduled to be presented to the Regional Board until June 2004. Considering existing adverse effects on water quality and the presence of species protected under state and federal endangered species acts, the Discharger must not be allowed to make conditions worse pending completion of the TMDL. Receiving Water Limitation No. 14 states that the discharge shall not cause violation of any applicable water quality standard for receiving waters other than those for DO.... Please provide the statutory authority for waiving the water quality objective for dissolved oxygen in an impaired waterway that is critical habitat for endangered species. RWQCB Response: Please see RWQCB response to DeltaKeeper Comment No. S regarding the effluent limitations for oxygen demanding substances. Finding 39 states the findings of the Dissolved Oxygen TMDL Steering Committee regarding September and October, 1999. Regarding the comment that the Discharger cannot be allowed to make conditions worse pending completion of the TMDL, the proposed permit contains several requirements that will reduce the oxygen demanding substances discharged to the SJR. The proposed permit contains new effluent limitations for ammonia and DO, contains requirements to construct tertiary facilities, and requires the continuous operation of the existing tertiary facilities. Therefore, the new requirements should significantly reduce the oxygen demanding substances discharged to the SJR pending completion of the DO TMDL. Receiving Water Limitation No. 14 states that the discharge shall not cause violation of any applicable water quality standard for receiving waters other than those for DO. The purpose of this statement is that even after all the requirements listed above to reduce the oxygen demanding substances, the receiving water still may not meet water quality objectives for DO. The RWCF, however, is not solely responsible for the DO problem downstream of its discharge.