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RESPONSE TO WRITTEN COMMENTS -25- City Of Stockton-Regional Wastewater Control Facility NPDES No. CA0079138 26 April 2002 Board Meeting RWQCB Response: This issue is adequately explained in the Fact Sheet in Section 9.1. Evaluation of available dilution for pathogen/disinfection considerations is adequately explained in the Fact Sheet in Section 8.7. Stockton Comment No. Art. II.b: The City has conducted a number of studies regarding the need for more restrictive coliform limitations, some of which are still ongoing. Each of these studies, including the more recent detailed evaluations,have confirmed that there is no public health threat from the existing discharge and that there is no reason to require continuous operation of the filtration facilities. Accordingly, there is no basis for imposing the more restrictive coliform requirements or for claiming that a 2 NTU daily maximum is necessary to achieve adequate pathogen control. RWQCB Response: This issue is adequately explained in the Fact Sheet in Section 9.2. In addition, the health risk assessment did not address the health risk due to consumption of shellfish. A representative from the Department of Fish and Game has verified that significant shellfish harvesting occurs year-round in the vicinity of the outfall. Stockton Comment No. Att. II.c: DHS' recommendations are based on Title 22 requirements, �ehich are not applicable to a surface water discharge. Furthermore, the Regional Board has failed to find that the applicable contact recreation standard for bacteria contained in the Basin Plan is not protective. The Regional Board has not presented evidence that the existing discharge (23 MPN/100 ml assessed on a thirty-day basis with no single sample to exceed 500 MPN/100 ml) presents any .threat to public health. The proposed coliform limits are unnecessarily stringent to ensure beneficial use protection and are not consistent with applicable state and federal laws and guidance. RWQCB Response: The fecal coliform objective by itself is not sufficiently protective for discharges of human wastewater since it is a receiving water standard for surface water and only addresses coliform, not other pathogens. It alone is not sufficient to protect all beneficial uses. Domestic sewage contains bacteria, viruses, and parasites that are a threat to public health if sewage is not adequately treated. (See Irrigation with Reclaimed Municipal Wastewater, California State Water Resources Control Board, Report No. 84-1 WR, Chapter 10, Exhibit CVR 041.) Diseases that can be caused by the microorganisms in wastewater include typhoid fever, amebic dysentery, salmonellosis, gastroenteritis, cholera, polio, pleurodynia, myocarditis, meningitis and encephalitis. (Stoddard v. Western Carolina Regional Sewer Authority (4th Cir., 1986) 784 F.2d 1200, 1203, fn. 4; People of the State oflllinois v. City of Milwaukee (7th Cir., 1979) 599 F.2d 151, 167 fn. 32.) Secondary treatment standards are not adequate for the removal and/or destruction of pathogens. The Regional Board reasonably relied on the expertise of the Department of Health Services (DHS), which is the California public agency with the statutory responsibility to protect public health. DHS recommended a tertiary level of treatment with a 2.2 MPN/100 ml limit. Stockton Comment Att. IIA: The City objects to the imposition of more restrictive coliform limitations r.:mber of =..latory, and technic: rounds. The record is devoid of evidence that a public i e: . h threat exis :, - rac City maintains compliance with the 23 MPN/100 ml permit