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Furthermore, the "detection level" criteria in the Basin Plan are in conflict with <br /> the federal water quality criteria for pesticides which are specified as protective of aquatic <br /> life uses. These safe levels are much higher than the minimum level of detection for <br /> organochlorine pesticides that the Regional Board seeks to impose (i.e., greater than 0.02 <br /> ug/1 is acceptable). (See, Fact Sheet at p.10.) In other words, the Regional Board staff is <br /> seeking to impose limitations more stringent than the best available scientific information <br /> without demonstrating a water quality-based need. Accordingly, the detection level <br /> provision should be deleted from the Permit because it bears no relationship to actual use <br /> protection needs. In the alternative, the City requests that the Regional Board revise the <br /> effluent limitations for pesticides to be consistent with the federal water quality criteria <br /> guidance for pesticides and only establish limitations for those parameters that may <br /> exceed the federal criteria, considering appropriate averaging periods. <br /> Disinfection Requirements <br /> I. Introduction <br /> The Regional Board has required the City to adequately disinfect, oxidize, <br /> coagulate, clarify, filter, and meet 2.2 MPN/100 ml total coliform as a 7-day median on a <br /> year-round basis, finding that such limitations are necessary to protect the beneficial uses <br /> of agricultural supply and water contact recreation. (Finding 36.) Based on the <br /> information provided, it appears that the Regional Board did not evaluate the level of risk <br /> associated with the threat of any specific pathogen in the City's discharge to public health <br /> or the beneficial uses of Dredger Cut, White Slough or Bishop Cut (jointly the"receiving <br /> waters")_ Finally, the Regional Board concluded that Lodi must also monitor compliance <br /> pursuant to a turbidity limitation of 2 NTU as a daily maximum limitation. (Permit B.1.) <br /> In reaching these conclusions, the Regional Board relied upon the recommended <br /> treatment standards from the Department of Health Services ("DHS"). (Finding 36.) <br /> These recommendations were based on Title 22 requirements, which are not applicable to <br /> surface water discharge, and on DHS' lyasteivater Disii fection for Public Health <br /> Protection and Uniform Guidelines for 6Yasteivater Disinfection ("Uniform Guidelines") <br /> which were presented to, but not adopted by, the State Water Resources Control Board <br /> WDESPermitComments Exhibit 2 Page 9 12/17/99 <br />