SITE INFORMATION AND CORRESPONDENCE 1980-1999

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enforcement actions may be pursued. In addition, the permit may be reopened and modified. Language in Requirement G.l and in the Groundwater section of the Fact Sheet describing the compliance point for groundwater monitoring is somewhat vague. We propose the following language to satisfy what we believe to be the intent of the compliance point: Points of compliance will be established not more than 250 feet from the outside edge of fields irrigated with reclaimed water or fields where biosolids have been applied, and shall not extend beyond the exterior boundary of property owned or controlled by the Discharger. We ask that the following language be substituted for Requirement GA.: "The discharge shall not cause total coliform organisms to exceed a most probable number of 2.2/100ml over any seven-day period." Comment 3. Tertiary Filtration and Disinfection Requirements The Tentative Discharge Requirements specify tertiary filtration and disinfection even though the City is in compliance with a much stricter discharge requirement (23 MPN Total Coliform) than the numerical disinfection objectives in the current Basin Plan (200 MPN'Fecal Coliform). It is our understanding that Regional Board staff are preparing a position paper on disinfection issues to be addressed in the Basin Plan Update. It is also our understanding that the intent of the staff involved in the Basin Plan Update is to resolve as many of these issues as possible in the Basin Plan Update. There is no legal basis for the Regional Board to prescribe stricter disinfection requirements until the numerical standards in the Basin Plan are updated (see enclosed detailed comments from Hall & Associates, Exhibit 2). So that compliance with potentially stricter disinfection standards can be implemented in a timely mariner if such standards are adopted into the Basin Plan, we propose that the discharge requirements include the following: Preparation of a report which evaluates alternatives and provides recommendations for meeting criteria in Title 22 reclamation standards and DHS Guidelines for Wastewater Disinfection, to be completed by December 1, 2000. We propose-that the timetable specified under H.2., PROVISIONS, be in months relative to the adoption of stricter numerical disinfection standards in the Basin Plan rather than be absolute dates. The risks to public health are already minimal at the current levels of disinfection. In addition, City staff have not observed any instances of full body water contact recreation in Dredger Cut during the last 5 years. The City has not been discharging during the months of June through August when contact recreation or agricultural reuse on vegetable crops would be most likely. Therefore, there is no significant risk to public health by waiting for legally adopted updated numerical Basin Plan objectives prior to committing over 10 million dollars in City funds for tertiary filtration and disinfection. tentcommentsw95 Exhibit 1 Page 3 12/17/99