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KLUIUNAL WA I LK IJUAKU NIz6PUNSL (J5WHGB/UGC I-lle A-1d4b(a) and A-7 d4b(b)) _11_ <br /> PETITIONS FOR REVIEW OF W 'E DISCHARGE REQUIREMENTS <br /> ORDER NO. R5-2007-0036 (NPDt-6 NO. CA0079154) AND <br /> TIME SCHEDULE ORDER NO. R5-2007-0037 <br /> CITY OF TRACY, WASTEWATER TREATMENT PLANT <br /> interim effluent limitation is based on current treatment plant performance and will ensure that <br /> the mass loading of salinity does not increase as the effluent flow rate increases. The Order <br /> also includes final WQBELs based on the Basin Plan numeric site-specific objectives, as <br /> modified as a late revision at the 4 May 2007, Regional Water Board hearing, which state that <br /> ,the electrical conductivity in the discharge shall not exceed a month ly.average of <br /> 700 pmhos/cm (April 1 to August 31) and a monthly average of 1000 pmhos/cm (September 1 <br /> to March 31). The effluent limitations for electrical conductivity become effective immediately <br /> if (1) the Discharger fails to submit a Salinity Plan to reduce its salinity impacts to the Southern <br /> Delta, including a schedule, to comply with conditions (1) — (3) below, to the Regional Water <br /> Board within six months of the effective date of the Order, or (2) the Discharger fails to timely <br /> implement the Salinity Plan upon the Regional Water Board's approval. The proposed Salinity <br /> Plan will be circulated for no less than 30 days of public comment prior to the Regional Water <br /> Board's consideration and approval. <br /> (1) The Discharger implements all reasonable steps as agreed to by the Executive Officer to <br /> obtain alternative, lower salinity water supply sources; <br /> (2) The Discharger develops and implements a salinity source control program that will <br /> identify and implement measures to reduce salinity in discharges from residential, <br /> commercial, industrial and infiltration sources in an effort to meet an interim salinity goal of <br /> a maximum 500 pmhos/cm electrical conductivity increase over the weighted average <br /> conductivity of the City of Tracy's water supply; and <br /> (3) The Discharger participates financially in the development of the Central Valley Salinity <br /> Management Plan at a level commensurate with its contributions of salinity to the <br /> Southern Delta. <br /> Upon determination by the Regional Water Board that the Discharger has materially failed to <br /> comply with the approved Salinity Plan due to circumstances within its control, the final <br /> WQBELs for electrical conductivity shall become effective immediately. Furthermore, the <br /> Order requires that the Discharger implement best practicable treatment or control (BPTC) of <br /> its discharge and requires the development and implementation of pollution prevention plan for <br /> salinity in accordance with CWC section 13263.3(d)(1)(D). <br /> CSPA — CONTENTION B: The antidegradation analysis is woefully inadequate and <br /> inconsistent with the state's antidegradation policy <br /> See responses to ELF — CONTENTION A and ELF — CONTENTION B, above. <br /> CSPA — CONTENTION C: The flow limitations in the Order fail to comport with federal <br /> Regulations. The discharge flow limitations in the Order are presented as average monthly <br /> for ADWF and as maximum daily for peak-wet weather flow (PWWF). Unfortunately, the <br /> technical basis for the flow limitations is not discussed in the Order. The federal definition of <br /> daily maximum is an average for the day. Therefore the PWWF limitation is actually a daily <br /> average. The monthly average ADWF and one day's average wet weather flow (PWWF) are <br />