SITE INFORMATION AND CORRESPONDENCE_CASE 2

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RCVIUIYAL VVM I CR DUMRV MCOr UIVJC �OVVMUM/Uld, rile A-709ola/ ano A-7040fo)) _ty_ PETITIONS FOR REVIEW OF W -E DISCHARGE REQUIREMENTS ORDER NO. R5-2007-0036 (NPL�NO. CA0079154) AND J TIME SCHEDULE ORDER NO. R5-2007-0037 CITY OF TRACY, WASTEWATER TREATMENT PLANT and operation of a reverse osmosis treatment plant. The State Water Board, in Water Quality Order 2005-005 (for the City of Manteca), states, "...the State Board takes official notice (pursuant to Title 23 of California Code of Regulations, Section 648.21 of the fact that operation of a large-scale reverse osmosis treatment plant would result in production of highly saline brine for which an acceptable method of disposal would have to be developed. . Consequently, any decision that would require use of reverse osmosis to treat the City's municipal wastewater effluent on a large scale should involve thorough consideration of the expected environmental effects." The State Water Board states in that Order, "Although the ultimate solutions to southern Delta salinity problems have not yet been determined, previous actions establish that the State Board intended for permit limitations to play a limited role with respect to achieving compliance with the EC water quality objectives in the southern Delta." The State Water Board goes on to say, "Construction and operation of reverse osmosis facilities to treat discharges...prior to implementation of other measures to reduce the salt load in the southern Delta, would not be a reasonable approach." The Regional Water Board, with cooperation of the State Water Board, has begun the process to develop a new policy for the regulation of salinity in the Central Valley. In a statement issued at the 16 March 2006, Regional Water Board meeting, board member Dr. Karl Longley recommended that the Regional Water Board continue to exercise its authority to regulate discharges of salt to minimize salinity increases within the Central Valley. Dr. Longley stated, "The process of developing new salinity control policies does not, therefore, mean that we should stop regulating salt discharges until a Salinity Policy is developed. In the meantime, the Board should consider all possible interim approaches to continue controlling and regulating salts in a reasonable manner, and encourage all stakeholder groups that may be affected by the Regional Board's policy to actively participate in policy development." Consistent with the policies expressed in the Manteca order, the State Water Board recently resolved: The Water Boards will take actions to address salinity issues in the Bay-Delta and upstream areas including: (1) develop and implement CV-SALTS, a comprehensive long-term salinity management program for the Central Valley; (2) act on DWR's request to change Order WR 2006-0006; (3) enforce the southern Delta salinity objectives and take other corrective actions; and (4) pursue a contract to review the southern Delta salinity objectives in the Bay-Delta Plan. In the strategic workplan, the Water Boards staff will propose for the State Water Board's consideration the scope of a basin planning and water right process to review and, as appropriate, amend the southern Delta salinity objectives or their implementation, while ensuring that agricultural uses are protected, and allocate responsibility for meeting the objectives. These actions are in addition to the TMDL actions discussed below. (State Water Board Resolution 2007-0079.) As discussed in more detail below, water quality modeling demonstrated that under reasonable worst-case conditions, the City of Tracy discharge has limited impacts on the salinity problem in the South Delta. Therefore, requiring the Discharger to meet WQBELs for EC based on the South Deltasalinity objectives, which