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? ; L <br /> A PROJECT OF SAN FRANCISCO BAYKEEPER <br /> 17 December 1999 <br /> o c„ <br /> r•7 <br /> Ms. Patricia H. Leary <br /> Mr. Robert Fagerness <br /> Regional Water Quality Control Board 0 <br /> 77 <br /> Central Valley Region o <br /> 3443 Routier Road, Suite A <br /> Sacramento, California 95827-3003 Via Fax: Hardcopy to Follow <br /> Re: Tentative Waste Discharge Requirements,NPDES No. CA0079243 for White Slough Water <br /> Pollution Control Plant,Lodi, San Joaquin County. <br /> Dear Ms. Leary and Mr. Fagerness: <br /> On behalf of DeltaKeeper and San Francisco BayKeeper(hereinafter DeltaKeeper), thank you for <br /> this opportunity to comment on the proposed permit(Tentative Permit) for the White Slough Water <br /> Pollution Control Facility,Lodi (Discharger). We appreciate staff's generous time and cheerful <br /> assistance in helping us understand the underlying issues relating to the proposed permit. <br /> The Tentative Permit is a significant milestone in the continued improvement of permits issued by <br /> the Central Valley Regional Water Quality Control Board(Regional Board). It was a pleasure to <br /> discover the effluent data assembled in readily understood tables, defensible reasonable potential <br /> analyses clearly explained and the concise but detailed Information Sheet. <br /> Our remaining concerns are that the: <br /> 1. absence of mass limits in the permit is inconsistent with federal regulations. Required <br /> mass limits include mercury,pesticides,electrical conductivity,toxicity(both acute and <br /> chronic), zinc,lead, cyanide,Bis (2-ethylhexyl)phtahalate,chlorine and possibly <br /> trihalomethanes, <br /> 2. proposed permit fails to comply with federal and state antidegradation policy, <br /> 3. turbidity receiving water limit and the total suspended solids effluent limit backslides <br /> from the previous permit, <br /> 4. proposed coliform limit(30-day average) is inadequate to protect human health, <br /> 5. monitoring plan is insufficient to characterize the wastestream and insure compliance with <br /> DeltaKeeper,Tentative NPDES Permit,Lodi, 17 December 1999,Page 1. <br /> 3536 RainierAvenue Telephone:209 464 5090 <br /> Stockton Printed on recycled paper Facsimile:209 464 5174 <br /> CA 95204 Hotline: 1 800 KEEPBAY <br />