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REGIONAL BOARD RESPONSE (SWRCB/OCC FILE A-1483) -4- STATE BOARD DRAFT WATER QUALITY ORDER PETITION FOR REVIEW OF WASTE DISCHARGE REQUIREMENTS ORDER NOS. R5-2002-0083 AND RS-2002-0084 CITY OF STOCKTON REGIONAL WASTEWATER CONTROL FACILITY The Regional Board found that it is appropriate to apply DHS's reclamation criteria and DHS's site- specific recommendations for the SJR to the discharge because the SJR is used for agriculture, domestic, and water contact recreation purposes. The reclamation criteria are appropriate to apply since water contact recreation would result in similar or greater exposure than the activities specifically included in those regulations and Title 22. Moreover, the more stringent disinfection criteria of Title 22 are appropriate since relatively undiluted effluent may be used for the irrigation of food crops or for golf courses and parks. Additionally,based on testimony of Lt. Dennis DeAnda from the Department of Fish and Game', Joseph Spano from DHS', and Bill Jennings of Deltakeeper', subsistence fishing and shellfish harvesting are a common occurrence near the point of discharge year-round, which supports the requirement to provide tertiary treatment year-round rather than only during the summer. The State Board has previously held that the Regional Board can properly consider the reclamation(now recycled water) criteria where wastewater is discharged under circumstances that are analogous to the direct reuse of recycled water. See State Board Order WQ 86-14. The Regional Board considered the factors specified in CWC section 13263, including considering the provisions of Water Code section 13241,in adopting the disinfection requirements under Title 22 criteria. Cost information provided by the Discharger regarding upgrades to meet Title 22 specifications are estimated to be$6.6 million in construction costs and approximately$3.4 million more per year in operation and maintenance costs for flows of 42 mgd at the plant'. For flows of 55 mgd, the maximum allowed by Order R5-2002-0083, the estimated construction costs are projected at$14.6 million and the annual operation and maintenance cost is projected at$4.44 million. The Regional Board found, on balance, these requirements are necessary to protect the beneficial uses of the SJR, including water contact recreation and irrigation uses. REMANDED EFFLUENT LIMITATIONS Dichloromethane The Draft Order finds that the Regional Board must consider section 13241 factors if it implements a numeric water quality objective to apply a more stringent effluent limit than the CTR for dichloromethane. The Regional Board agrees that where there is a CTR criterion that is developed to be protective of a certain beneficial use, it should apply the CTR and not a non-promulgated goal based on implementing a narrative water quality objective. For some constituents, however, the CTR criteria may not be protective of all beneficial uses or fully protective of certain uses. The Regional Board is required by the Water Code and the Basin Plan to protect all beneficial uses. It may be necessary to implement a numeric or narrative water quality objective, and not just the CTR, to protect uses that are not addressed by the CTR criteria. In such cases, the Regional Board should not be required to consider the section 13241 factors to protect those other uses. The Draft Order is not clear on this point. In addition, 40 CFR section 122.44(d)requires the Regional Board to implement narrative objectives as specified in ' Transcript from the 26 April 2002 Central Valley Regional Water Quality Control Board hearing,Pgs 107-110 Ibid.Pgs. 115-116 5 Ibid. Pg. 106 6 The RWCF has a secondary treatment capacity of 42 mgd.