SITE INFORMATION AND CORRESPONDENCE_2005-CURRENT

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� s establish that the State Board intended for permit effluent limitations to play a limited role with respect to achieving compliance with the EC water quality objectives in the southern Delta. The year-round 1000 µmhos/cm EC effluent limitation in the City's permit that became effective immediately upon adoption of Order No. R5-2004-0028 is a reasonable condition that will reduce the salinity of the City's effluent and help achieve compliance with the receiving water quality objectives in the Basin Plan. The City's shift toward use of lower salinity surface water for a large portion of its water supply, as well as other source control measures, should allow the City to comply with the 1000 µmhos/cm requirement." Adoption of a cease and desist order to ensure that the City pursues the steps necessary to bring it into compliance with a 1000 µmhos/cm EC effluent limitation is also a reasonable enforcement action. The record indicates, however, that compliance with the permit effluent limitation of 700 µmhos/cm EC scheduled to become effective on April 1, 2005, could not be assured without construction and use of reverse osmosis facilities.21 Construction and operation of reverse osmosis facilities to treat discharges from the City's WQCF,prior to implementation of other measures to reduce the salt load in the southern Delta,would not be a reasonable approach.24 Without prejudging the question of possible revisions to the southern Delta EC water quality objectives, or the question of the possible conditions that may eventually be imposed on the City's permit or other permits in order to comply with water quality objectives for EC in the San Joaquin River and southern Delta, the State Board concludes that establishing zz Establishing an effluent limitation of 1000µmhos/cm is consistent with the present conditions in the Department of Water Resources'and Bureau of Reclamation's water right permits that require operation of State Water Project and Central Valley Project facilities as necessary to comply with the 1000µmhos/cm EC requirement in the southern Delta. (Revised Water Right Decision 1641,p. 88.) as The Regional Board recognized that the City could not comply with the 700µmhos/cm standard scheduled to become effective on April 1, 2005. Therefore,the cease and desist order adopted by the Regional Board placed the City on a time schedule calling for implementation of the 700 µmhos/cm standard by 2009. 24 Our conclusion regarding the reasonableness of pursuing reverse osmosis at the present time is influenced by the fact that the State Board recently adopted a staff report recommending that the periodic review of the 1995 Delta Plan should consider receiving information relevant to possible revision of the southern Delta water quality objectives for EC. (State Board Resolution No. 2004-0062.) The staff report states: ". . .staff also recommends that the implementation recommendation for these[southern Delta EC] objectives be reviewed to ensure that they are timely described, effective, feasible, and consistent with existing requirements for salinity management in the southern Delta. To the extent possible,staff recommends that review of this issue be coordinated with the CVRWQCB's ongoing TMDL and Basin Plan Amendment(BPA) efforts for salt and boron on the San Joaquin River." (State Board Resolution No. 2004-0062,attachgd staff report,p. 32.) 14.