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The presence of those industries and the absence of a well-implemented <br /> pretreatment program establish that there is a significant potential for reducing the amount of <br /> iron and other regulated constituents entering the City's WQCF through an effective pretreatment <br /> program. If an effective pretreatment program were instituted, the concentrations of pollutants <br /> reaching the WQCF would be reduced and the City's cost of complying with the permit effluent <br /> limitations for iron and other constituents would be substantially reduced.99 The record does not <br /> establish that it would be financially infeasible for the City to meet the requirements in its permit, <br /> as amended by this order. <br /> III. OTHER MATTERS <br /> In implementing the Basin Plan's narrative toxicity objective for aluminum, the <br /> Regional Board utilized a numeric objective based on the USEPA's Ambient Water Quality <br /> Criteria for the Protection of Freshwater Aquatic Life, as authorized by 40 Code of Federal <br /> Regulations part 122.44(d)(1)(vi)(B). The City contests the effluent limitation for aluminum on a <br /> variety of grounds not addressed in this order. However, the Regional Board's response to the <br /> City's petition acknowledges that aluminum can exist in a non-toxic form as aluminum silicate. <br /> The federal ambient water quality criteria for aluminum state that acid-soluble aluminum is <br /> probably the best measurement for establishment of aluminum effluent limitations.40 The <br /> Regional Board suggests it would be appropriate to modify the effluent limitation for aluminum <br /> to allow using acid soluble methods of measurement for showing compliance with the effluent <br /> limitations, which prevent aquatic toxicity. (Regional Board Response to Petition,p. 8.) <br /> Modification of the City's permit in the manner suggested by the Regional Board would provide <br /> appropriate relief to the City without adversely affecting water quality. <br /> The City's petition also questions effluent limitations B.7. and B.B., which <br /> restrict average dry weather discharge flow from its WQCF to specified amounts "less the <br /> 39 Legal requirements under the Clean Water Act and federal regulations governing industrial pretreatment programs <br /> for publicly owned treatment facilities are addressed on pages 26,27, 50 and 51 of Order No R5-2004-0028. <br /> 40 U.S. EPA's Ambient Water Quality Criteria for the Protection of Freshwater Aquatic Life. <br /> 21. <br />