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MEMORANDUM CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD • CENTRAL VALLEY REGION 3443 Router Road, Suite A Phone: (916)255-3000 Sacramento, CA 95827-3098 CALNET: 8-494-3000 To: Jennifer Soloway From: William H. Crooks Senior Staff Counsel Executive Officer State Water Resources Control Board DATE: 22 May 1996 SIGNATURE: wt Subject: SWRCB FILE NO. A-937, CITY OF STOCKTON REGIONAL WATER QUALITY CONTROL PLANT, SAN JOAQUIN COUNTY We have reviewed the 9 May 1996 draft SWRCB Order regarding Stockton, and the letter from DeCuir & Somach, dated 7 May 1996, regarding suggested changes to State Board's proposed order in the matter of the petition of the City of Stockton. Stockton's first request was to preserve flexibility to relax or revise effluent limitations in response to changed conditions which could improve DO in the receiving water. State Board's proposed order included language that directed us to provide flexibility for future changes in effluent limits under the ,,effluent limits" section in the NPDES permit. We believe that this new language would be more appropriately placed under "provisions". We understand that State Board's proposed order will be modified accordingly, and therefore our concern has been addressed. The second request was to include language that the chlorine effluent limitations in the NPDES permit and the State Board's dismissal of the claims related to those limitations are not precedent for subsequent decisions of the CVRWQCB in its discretion to allow or disallow mixing zones for other pollutants, or for any review of those decisions. We agree with State Board staff that language to this effect is not needed in the State Board order. Our Basin Plan clearly allows for consideration of mixing zones within which water quality objectives do not apply, provided it can be shown to the satisfaction of the Board that the mixing zone will not adversely impact beneficial uses. There is nothing in either the State Board's proposed order of the NP Disc e uur ch pfectudes us from allowing app opriate mixing zones for specific pollutants. The third request was to add the following language on reclamation, "This Order does not make or imply any findings with respect to the feasibility of water reclamation or the schedule on which it could be implemented." We understand that State Board's proposed order will be modified to include a footnote to address Stockton's concern, and find this acceptable. Finally, the letter points out that Stockton considers two additional activities to be part of the current condition of the San Joaquin River which should be considered when evaluating the changes in the river flows and DO. These are the Corp of Engineers' bubbler and the agricultural barriers installed in the irrigation season. We believe it is uncertain that they will be reliably operated, and we know that they will not be under the control of Stockton or the Regional Board. Therefore, we do not agree that these activities should be considered part of the current condition. Stockton has the right to include these activities as a part of its model runs, but the Regional Board should have the discretion to determine the