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0 <br /> California Regional Water Quality Control Board . <br /> v Central Valley Region <br /> ^Y , <br /> Robert Schneider,Chair <br /> Alan Lloyd,Ph.D. Arnold Schwameneggc <br /> Agency Secretary Sacramento Main Officen Governor <br /> InternetInternet Address: htlp://wwwswrcb.ca.cb.ca.gov/rwgcb5 lu0u1 � <br /> 11020 Sun Center Drive,Suite 200,Rancho Cordova,CA 95670 <br /> Phone(916)464-3291 •FAX(916)464-4780 <br /> FEB 2 8 200 <br /> ENVIRONMENT HEALTH <br /> TO: DEBBIE IRVIN FROM: THOMAS RIVER IVICES <br /> Clerk to the Board Executive Officer <br /> DATE: 25 February 2005 SIGNATURE: ' ! �FQCLT> <br /> SUBJECT: COMMENTS ON THE DRAFT STATE WATER RESOURCES CONTROL <br /> BOARD ORDER IN THE MATTER OF THE PETITION OF THE CITY OF <br /> MANTECA FOR REVIEW OF WASTE DISCHARGE REQUIREMENTS ORDER <br /> NO. R5-2004-0028 (NPDES NO. CA0081558) AND CEASE AND DESIST ORDER <br /> NO. R5-2004-0029, (SWRCB/OCC FILE A-1634) <br /> The Central Valley Regional Water Quality Control Board (Regional Board) appreciates this opportunity <br /> to comment on the draft State Water Resources Control Board (State Water Board) Order(Draft Order) <br /> in the matter of the Petition of the City of Manteca for Review of Waste Discharge Requirements Order <br /> No. R5-2004-0028 (NPDES No. CA 008155.8) and Cease and Desist Order R5-2004-0029. Overall, the <br /> Regional Board supports the Draft Order's conclusions and appreciates the level of effort in providing <br /> clear direction in reviewing the Orders. <br /> 1. Effluent Limitations Established Based on Water Quality Objectives for Electrical <br /> Conductivity (EC). The Draft Order indicates that the 700µ6/cm effluent limit in the Manteca <br /> permit is not appropriate and revises the Order to include a year round limit of 1,000µS/cm. The <br /> Draft Order appears to be in conflict with the water quality objectives for the southern Delta where <br /> Manteca discharges. The EC water quality objectives for the southern Delta are 700µS/cm during <br /> the irrigation season (April—August) and 1000µS/cm the remainder of the year, based on Revised <br /> Water Right Decision 1641 (D-1641). However, the southern Delta irrigation season water quality <br /> objective includes a caveat that allows the 700µS/cm to be replaced with 1,000µS/cm "... if <br /> permanent barriers are constructed or equivalent measures are implemented in the southern Delta <br /> and an operations plan that reasonably protects southern Delta agriculture is prepared by the DWR <br /> and the USBR and approved by the Executive Director of the SWRCB". (D-1641, p. 182) <br /> There is a difference between the Lower San Joaquin River and the southern Delta. The waste load <br /> allocations established for point sources in the Lower San Joaquin River TMDL are concentration <br /> based and set equal to the existing water quality objectives at Vernalis. In other words, the TMDL <br /> will require point source dischargers to comply with the 7001AS/cm objective during the irrigation <br /> season (April-August). It should be noted that the TMDL provides NPDES permitted dischargers <br /> lb to 20 years to comply with waste load allocations. <br /> California Environmental Protection Agency <br /> �a Recycled Paper' <br />