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REGIONAL BOARD RESPONSE (SWRCB/OCC FILE A-1483) -23- PETITION FOR REVIEW OF WASTE DISCHARGE REQUIREMENTS ORDER NOS. R5-2002-0083 AND R5-2002-0084 CITY OF STOCKTON REGIONAL WASTEWATER CONTROL FACILITY it is implementing the Porter-Cologne Act, the Basin Plan, and Resolution 68-16. Water Code section 13000 requires the state to "exercise its full power and jurisdiction to protect the quality of the waters in the state from degradation . . ." Resolution 68-16 requires the Regional Board to maintain the highest water quality unless certain findings and requirements are made. In this case, there is insufficient information to make a finding that further degradation should be allowed without determining the existing water quality. Groundwater Limitation F.2 maintains the existing water quality and allows the Discharger to provide additional information that might justify the allowance of additional degradation of the groundwater. NINTH BASIS: IMPRACTICAL SCHEDULE OF COMPLIANCE Stockton request that the State Board direct the RWQCB to modify the compliance schedule for the tertiary treatment requirement and other new effluent limits,which have a final compliance date of 1 May 2006. This issue was not raised during the public comment period for the NPDES Permit and should be rejected by the State Board. In response, however, the Regional Board adopted a four year time schedule for compliance with Title 22 tertiary filtration requirements because the Regional Board concluded that it was feasible to construct the system within that timeframe, and Stockton submitted no information to the contrary. Tertiary filtration is largely a stand-alone unit process requiring relatively little integration with other process units, so design and construction times are relatively short. The compliance schedule must be as short as feasible: (1)to correct existing public health concerns as rapidly as possible, and (2) because the Basin Plan at IV-17.00 requires that time schedules "shall contain a final compliance date, based on the shortest practicable time (determined by the Regional Board)required to achieve compliance." If an extension of the compliance schedule is granted, extending the schedule beyond 1 April 2007 will cause problems in complying with effluent limits for constituents covered by the SIP. The SIP allows a maximum compliance schedule of 5 years, or 1 April 2007 for the Stockton Pen-nit. To the extent that tertiary treatment removes SIP constituents, delaying completion of Title 22 tertiary filtration past 1 April 2007 complicates Stockton's ability to comply with the new effluent limits. TENTH BASIS: UNREASONABLE MONITORING AND STUDY REOUIREMENTS Stockton requests that the State Board direct the RWQCB to delete inappropriate monitoring and study requirements. "114. The Permit includes a requirement to prepare a Human Carcinogen Study. (Provision 5.b.) This requirement is unreasonable, is not justified as necessary to protect beneficial uses or the environment and requires Stockton to conduct basic research unrelated to its discharge. Further, it is not reasonably related to the need for the information to be obtained." Water Code section 13383 authorizes the Regional Board to require dischargers subject to NPDES permits to, among other requirements, sample effluent, retain records, and provide other information as