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Comment 6. Dissolved versus Total Recoverable Metals <br /> The objectives in the Basin Plan, the draft California Toxics Rule, and EPA ambient water <br /> quality criteria all specify dissolved metals concentrations. 40CFR part 122.45(c), states that: <br /> "All permit effluent lintitations, standards, or prohibitions for a metal shall be expressed in terms <br /> of'total recoverable metal'as defined in 40 CFR part 136 unless: <br /> (1) An applicable effluent standard or limitation has been promulgated tinder CYhA and <br /> specifies the limitation for the metal in the dissolved or valent or total form;or..." <br /> The Regional Board has made the case on numerous recently proposed discharge permits that <br /> numerical limits for metals are being promulgated under the CWA based on water quality <br /> objectives. The objectives in the Basin Plan, Draft California Toxics Rule, or EPA Ambient <br /> Water Quality Criteria are all in dissolved metals concentrations. Therefore exception (1) clearly <br /> applies, and any applicable discharge limits in the tentative permit should be stated in dissolved <br /> metals concentrations rather than total recoverable metals. <br /> Comment 7. Itemized Comments on the Tentative Permit <br /> Following are detailed comments on specific items in the tentative permit listed by permit <br /> section and number: " <br /> FINDINGS <br /> 12. This finding refers to Table II-1 of the Basin Plan as identifying beneficial uses of <br /> Dredger Cut. Table II-1 does not speak to beneficial uses of Dredger Cut; instead-it states in <br /> footnote 8 that beneficial uses "vary throughout the Delta and will be determined on a <br /> case-by-case basis." The City believes that it is improper under this language and page 11-2.00 of <br /> the Basin Plan to make a "blanket" finding of beneficial uses of Dredger Cut. No evidentiary <br /> basis for this finding has been identified or provided to the City. <br /> 14. The study by Litton and Nikaido did not indicate that 8.5 mgd of secondary treated <br /> effluent would cause violations of the dissolved oxygen objective in Bishop Cut. <br /> 23. See Comment 5 above regarding dilution and the enclosed detailed comments from Hall <br /> & Associates regarding cyanide. <br /> 24. See Comments 5 and 6 above as well as the enclosed detailed comments from Hall & <br /> Associates regarding zinc. (Also, see Table 1.) <br /> 25. See enclosed detailed comments from Hall & Associates regarding mercury. <br /> 26. See Comments 5 and 6 above as well as the enclosed detailed comments from Hall & <br /> Associates regarding lead. (Also, see Table 1.) <br /> tentcommenuv.95 Exhibit 1 Page 5 12/17/99 <br />