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REGIONAL BOARD RESPONSE (SWRCB/OCC FILE A-1634) - 12 - <br /> PETITION <br /> 12 - <br /> PETITION FOR REVIEW OF WASTE DISCHARGE REQUIREMENTS <br /> ORDER NOS. R5-2004-0028 AND R5-2004-0029 <br /> CITY OF MANTECA WATER QUALITY CONTROL FACILITY <br /> justification was provided to support this position. As more thoroughly stated in the response to <br /> comments, the Regional Board does not disagree with the concept of Manteca's request,but <br /> lacks adequate information to support the alternative discharge strategy. <br /> A reopener is not necessary to initiate a change in operation. The Regional Board can consider <br /> new information if an adequate technical justification is submitted. There is adequate time in the <br /> existing time schedule (Provision 4 and Effluent Limitations B.3 and B.8) to provide information <br /> needed to support an alternative discharge scenario. <br /> TENTH BASIS: FAILURE TO ALLOW DISCHARGE OF PERMITTED FLOW <br /> Manteca requests that the State Board modify, or order the Regional Board to modify, <br /> Order No. R5-2004-0028 to amend effluent Limitations B.6, B.7 and B.8 to state that the <br /> average dry weather discharge to the San Joaquin River shall not exceed the stated now <br /> limits (6.95, 8.11 and 9.87 mgd, respectively). <br /> The previous NPDES permit for the City of Manteca's discharge allowed the City to discharge <br /> up to 8.11 mgd, including all industrial flows, after fully utilizing its land disposal capacity. The <br /> Basis of Design Report, which was included as part of the permit application, proposes an <br /> expansion of the Manteca WQCF to a design capacity of 9.87 mgd. In addition, the City <br /> proposes to segregate industrial flows, up to 0.55 mgd, and to directly apply these flows to land, <br /> thereby utilizing land disposal capacity previously maintained for treated municipal effluent, <br /> providing, in effect, an overall plant expansion to 10.42 mgd. This change in treatment plant <br /> design capacity is reflected as the design flow(Findings 2, 3, and 4) in the Permit. Effluent <br /> limitations B.1, B.2, and B.3 are based on treatment plant design capacities of 6.95 mgd, 8.11 <br /> mgd, and 9.87 mgd, respectively. Effluent Limitations B.6 and B.7, were based on the <br /> consideration that industrial flows are not segregated and are part of the design flow. Effluent <br /> Limitations in B.8 were based on the assumption that industrial flows were segregated, utilizing <br /> much of the land disposal capacity previously utilized for treated municipal effluent. <br /> The permit currently authorizes the City to discharge to surface water and to land, but the total <br /> discharge may not exceed the permitted flow rate of 8.11 mgd. At such time as the City <br /> completes plant upgrades to comply with tertiary treatment requirements, denitrification, and <br /> fully complies with other final effluent limitations described in the permit, the City may <br /> discharge up to the new expanded design capacity of 9.87 mgd, and to segregate an additional <br /> 0.55 mgd of industrial waste and discharge that amount to land. The City argues that it should be <br /> able to discharge 8.11 mgd to surface water and 0.55 mgd to land. The Regional Board does not <br /> agree with the City's assertion. It was not the intent of the Regional Board to allow expansion <br /> beyond what was previously authorized in Order No. 5-01-007 until the City fully complied with <br /> Effluent Limitations B.3, and conducted other work as specified in Provision H.4. The request by <br />