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waters. Draft Guidance for Fresh Watei•Beaches (updated April 23, 1999) ("Beach <br /> Guidance"). The purpose of that document is to assist "local health agencies with regard <br /> to the healthfulness of recreational waters and beaches" (Beach Guidance, p. 2). This <br /> guidance is directly applicable to White Slough and Bishop Cut in the context of this <br /> permitting action since the Regional Board has determined that these fresh waters have a <br /> beneficial use of body contact recreation. <br /> DHS recommends informing the public of"contamination of recreational water <br /> and the risk of possible illness," and advising against "swimming and/or water contact" <br /> where monitoring data indicate a microbiological indicator standard is exceeded (Beach <br /> Guidance, p.l). Specifically, DHS recommends posting when a single sample for the <br /> following levels of indicator organisms is exceeded: total coliform 10,000 MPN/100 ml; <br /> fecal coliform, 400 MPN/100m1; enterococcus 61 MPN/100 ml; E. coli 235 NDN/100 <br /> ml. Furthermore, DHS recommends warning the public of potential health hazards when <br /> the 30-day log mean of at least five (5) samples exceeds: total coliform.1000 MPN/100 <br /> ml; fecal coliform, 200 MPN/100ml; enterococcus 33 MPN/100 ml; E. coli 126 <br /> MPN/100 ml. All of these objectives are magnitudes less stringent than the 2.2 MPN <br /> total coliform that DHS has recommended that the Regional Board impose on the City <br /> and demonstrate that a 2.2 MPN total coliform limitation is not required to protect public <br /> health. <br /> b. Federal and Other State Criteria Documents- - <br /> The Basin Plan also states that the Regional Board will rely on published federal <br /> criteria documents to determine the level of water quality necessary to protect beneficial <br /> uses where numeric objectives have not been set. (Basin Plan at III-1.00.) Based upon <br /> health impacts studies and criteria documents, EPA recommends that states use fecal <br /> coliform, E. coli, or enterococcus bacteria as the appropriate indicators for bathing areas. <br /> DHS admits that the standards, which the Regional Board seeks to impose upon the City, <br /> are more restrictive than those imposed anywhere else in the country. (Hultquist <br /> Testimony at 95.) <br /> NPDESPcrrtnitCommcnts Exhibit 2 Page 14 12/17/99 <br />