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level of treatment." (Finding 36.) The Regional Board has failed to provide further <br /> justification for the imposition of this burdensome turbidity requirement. Apparently, the <br /> Regional Board has imposed this new effluent limitation on turbidity to provide an <br /> additional layer of protection for disinfection requirements that are designed to protect <br /> against short-term excursions. Putting aside these generalizations, there is no support for <br /> the turbidity limit in the record or that for the City, there is any significant correlation <br /> between turbidity and vines levels or other appropriate indicators. <br /> Moreover, DHS' Uniform Guidelines specifically state that coliform readings are <br /> dispositive of whether or not adequate disinfection has occurred. (See, Uniform <br /> Guidelines at Category II.c.) As there is no evidence that virus levels are excessive, there <br /> is also no evidence demonstrating that the turbidity limit is necessary to protect contact <br /> recreational uses. This provision should be deleted from the Permit. <br /> 12. Recommendations for Disinfection Requirements <br /> The Regional Board has failed to demonstrate that the imposition of 2.2 MPN/100 <br /> total coliform effluent limitation is necessary to protect public health or beneficial uses in <br /> Dredger Cut, White Slough, or Bishop Cut. There is no evidence in the record that the <br /> City's current discharge, which consistently and reliably performs superior to the 23 <br /> MPN/100 ml effluent limitation in its existing waste discharge requirements, poses a <br /> threat to public health. Furthermore, the Regional Board's determination that a seasonal <br /> adjustment for less restrictive standards in the winter months is not justified is simply <br /> without merit. Reasonable people do not swim or engage in other body contact recreation <br /> activities that have a reasonable likelihood of significant ingestion of receiving waters in <br /> the colder months from November through April. For the foregoing reasons, the City <br /> requests that the Regional Board revert back to the disinfection requirements of 23 <br /> MPN/100 ml 30-day median, 500 daily maximum effluent limits as required by WDR <br /> Order 93-030. <br /> NPDESPermitComments Exhibit 2 Page 21 12/17/99 <br />