SITE INFORMATION AND CORRESPONDENCE 1980-1999

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The September 9th letter also includes a memorandum (attached) from the California Department of Health Services (CDOHS) which recommends that the same, more stringent disinfection requirements ( (i .e. 2.2 MPN/100 mL (monthly median) and 23 MPN/100 mL (daily maximum)) be adopted for the White Slough discharge during the recreation season to reduce the possibility of infection from direct water contact recreation in Dredger Cut. In the letter, it is stated that advanced waste treatment would be required to meet the 2.2 MPN/100 mL requirement recommended by the CDOHS. And, although the letter states that the CVRWQCB staff would not include the CDOHS recommendation in the proposed WDR, such a requirement could be added by the Board during public hearings on the City's WDR. Summary of City of Lodi 's Position After considerable review, the City of Lodi ' s response to the proposed waste discharge requirements in the September 9th letter is summarized as follows: ° The 10/10 mg/L BOD and SS requirements are acceptable to the City. ° The City is concerned about the proposed TDS requirement, but that concern will be addressed in a separate letter. ° The proposed disinfection requirement of 2.2 MPN/100 mL (monthly median) and 23 MPN/100 mL (daily maximum) will require a substantial design change in the current project and will result in a significant delay and financial hardship for the City. ° The imposition of such a stringent disinfection requirement at this late date is untimely. ° An MPN requirement of 2.2 (monthly median)/23 (daily maximum) is NOT included in the Basin Plan. ° The proposed disinfection requirement will not appreciably improve the water quality of the receiving waters due to high background coliform levels. ° The proposed, more stringent disinfection requirement is not needed for summertime discharges to Dredger Cut. Proposed BOD and SS Requirements The City of Lodi has no problem with the proposed BOD and SS requirements. Based on discussions with the CVRWQCB staff, the City and Black & Veatch have known about these increased requirements since the planning for this project began in December 1986. As a result, the design of the White Slough expansion project has been carried out to satisfy these requirements. Financial Hardship of Proposed MPN Standard The proposed MPN requirement of 2.2 (monthly median)/23 (daily maximum) total coliforms/100 mL will be a major financial hardship for the City. This proposed requirement has not previously been discussed with the City or Black & Veatch and, as a result, the planning, design and financing of the project does not include the facilities necessary to achieve this more stringent disinfection requirement. 2