Comments on the Tentative Waste Discharge Requirements for Grizzly Lake Community Services District, Delleker Wastewater Treatment Plant

Dear Ms. Matthews:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for the Delleker Wastewater Treatment Plant (WWTP) of the Grizzly Lake Community Services District
(District). CVCWA is a non-profit organization representing more than 50 publicly owned treatment works throughout the Central Valley Region in regulatory matters affecting surface water discharge, land application, and water reuse. We approach these matters with a perspective to balance environmental and economic interests consistent with state and federal law. Upon reviewing the Tentative Order, CVCWA has concerns with respect to several issues. First, CVCWA is concerned with the proposed application (or lack thereof) of appropriate dilution credits. Second, CVCWA is concerned with the reasonable potential analysis statements concerning ammonia. Third, CVCWA is concerned with groundwater limitations for electrical conductivity (EC) and total dissolved solids (TDS). CVCWA’s comments and recommendations with respect to these issues are provided herein.