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RESPONSE TO WRITTEN COMMENTS -35- <br /> City Of Stockton- Regional Wastewater Control Facility <br /> NPDES No. CA0079138 <br /> 26 April 2002 Board Meeting <br /> been detected in the effluent or receiving water, and therefore effluent limitations were not included in <br /> the permit. <br /> DeltaKeeper Comment No. 10: A Reasonable Potential Analysis Must be Conducted for <br /> Temperature. <br /> RWQCB Response: Please seethe response to Stockton's comment N.N. (Thermal Discharge <br /> Requirements). <br /> DeltaKeeper Comment No. 11: The Schedules Of Compliance In The Permit Are Inconsistent <br /> With The Clean Water Act. <br /> RWQCB Response: The permit includes compliance schedules only where allowed by the State <br /> Implementation Plan, EPA regulations, and the Basin Plan. The permit and Fact Sheet explain the <br /> bases for including compliance schedules in the permit. The Basin Plan allows compliance schedules <br /> for those where the Regional Board is applying an objective that was adopted after 1995 or where it <br /> determines that it is applying a new interpretation of an existing standard. This approach has been <br /> accepted by the State Water Resources Control Board in the TOSCO Order. See Order WQ 2001-06 <br /> at page 54. <br /> DeltaKeeper Comment No. 12: The Permit fails to comply with CEQA and defers mitigation <br /> measures. <br /> RWQCB Response: The permit complies with CEQA by imposing requirements that adequately <br /> protect the beneficial uses of the waters of the state. <br /> DeltaKeeper Comment No. 7: Finding No. 52 is incorrect. The previous permit never provided <br /> for a mixing zone for pH. The pH range limit in the previous permit of 6.0 to 8.5 was a violation of <br /> the Basin Plan objective of 6.5 to 8.0 and, consequently, was illegal. Finding No. 52 should be <br /> corrected. <br /> RWQCB Response: Comment noted. Finding 52 has been corrected. <br /> USEPA REGION IX COMMENTS <br /> USEPA Comment No. 1: Your staff has prepared an outstanding permit which is both legally <br /> sound and scientifically defensible. It should result insignificant improvement of water quality in the <br /> San Joaquin River and Delta and we therefore support this permit's adoption. <br /> Because the Stockton Deep Water Ship Channel and the De'ta haired and because � u' ngered <br /> species use the San Joaquin River, it is especi.ilh :r.. erative f, i)ermit to contain wa, i quality <br /> based effluent limits (WQBELs). We are pleased to see that effluent limits have been established for <br />