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Furthermore, most other states recognize fecal coliform as a valid indicator <br /> applicable to municipal discharges, and such a conclusion is supported by the DHS Beach <br /> Guidance as well as in the background documents to the Uniform Guidelines. In fact, <br /> many of the states rely on a standard equivalent to that adopted in the Basin Plan. As <br /> such, the proposed disinfection limitations are not consistent with the Regional Board's <br /> own guidance document, DHS recommendations, and the approach taken by other <br /> jurisdictions throughout the United States. In light of such information, it is apparent that <br /> imposition of these extremely conservative limitations has no technical basis and is not <br /> necessary to protect public health. <br /> S. Record Does Not Contain an Assessment <br /> of Anv Risk Posed by the Lodi Discharge <br /> The Regional Board has proposed to adopt waste discharge requirements for <br /> coliform in contrast to the requirements of the Basin Plan, DHS Beach-Guidance, and <br /> EPA recommended criteria. The tentative permit implements a wholly different standard: <br /> total coliform cannot exceed 2.2 MPN/100 ml on a 7-day average with 23 MPN/100 ml <br /> exceeded no more than one time in any 30-day period. (Permit, p.10.) DHS estimates <br /> that for wastewaters, a 200 fecal limit is equivalent to at least 1,000 total coliform. In <br /> addition, adjusting the standard averaging period from thirty days to seven days makes <br /> the limit about t-wo to four times more restrictive than the approach typically used by the <br /> Regional Board. Thus, the DHS-recommended effluent limitation (2.2 total coliform-7- <br /> day average) is about 1,000 to 2,000 times more restrictive than its own recommended <br /> surface water quality objective for fecal coliform. There is no analysis or documentation <br /> in the record demonstrating that an effluent limitation thousands of times more restrictive <br /> than the 200 MPN/100 ml (fecal coliform 30-day average) is necessary to avoid a <br /> significant risk to public health or the environment, and as such may be viewed as <br /> arbitrary and capricious. <br /> NPDESPermitComments Exhibit 2 Page 15 12/17/99 <br />