SITE INFORMATION AND CORRESPONDENCE_2005-CURRENT

Home Browse Search

Findin s: In establishing the effluent limitations in NPDES permits that are needed to comply with applicable water quality control plans, the Regional Board is not required to consider costs of compliance. Similarly, the fact that compliance with an effluent limitation would have a small effect on the concentration of the constituent in the receiving water is no basis for rejecting a properly established effluent limitation. For the reasons discussed in Section II.A.2. above,however,this order revises the effluent limitations for EC established in the City's permit and, in so doing, eliminates what are by far the largest potential costs of compliance with the Regional Board order. The costs of construction, operation, and maintenance of a reverse osmosis facility need not be incurred in order to comply with the City's permit as revised by this order. Although the cost of compliance is not a valid basis for objection to the permit effluent limitations for iron, it is in the public interest to clarify that the City's costs are expected to be substantially less than the estimate cited in the City's petition." The City's estimate is based on the assumption that the City would have to utilize chemical treatment for removal of iron from its effluent. However, the City presented testimony that the iron in its source water at the time of the hearing was below detectable limits, and that the source of iron in the City's effluent is unknown." The Regional Board's pretreatment compliance inspection report states that the City has not issued or reissued permits to new or existing significant industrial users (SIUs); the City has not applied appropriate pretreatment standards to all SIUs; the City is not conducting any compliance inspections at its SIUs; and the City has not conducted any compliance sampling since the 2001 pretreatment compliance audit. The record also shows that permit applications for some companies discharging to the City's WQCF were accompanied by attachments to a pretreatment inspection report indicating that the industrial wastewater from their facilities contained iron and several other regulated constituents." Other industries that discharge to the WQCF include metal finishers, food processors, and vehicle wash facilities. 16 The City estimated that the annual cost of complying with the permit effluent limitations on iron would be $857,000. 37 At the time of the hearing, the City relied exclusively on ground water. 's The pretreatment inspection reports were filed by Advanced Interconnect Technologies and San Joaquin Cogen Ltd. 20.