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0 0 <br /> Receiving Nater Limits <br /> The City has two primary objections to the Receiving Nater Limitations as set <br /> forth in Paragraph F, pp. 15 —17: (1)-the pH, temperature, and turbidity limitations are <br /> not appropriate or necessary to protect beneficial uses; and (2) the Regional Board failed <br /> to accurately represent the full Basin Plan requirements with regard to several parameters. <br /> Specific comments to various receiving water limitations are provided below. <br /> 1. Temperature <br /> EPA's current criteria (1956) deleted the Delta restriction for temperature. The <br /> Regional Board should strike the Basin Plan's temperature requirement in its entirety or <br /> clarify that it only applies to peak increases in the summer months and is not otherwise <br /> applicable during periods when water temperatures are well within the range for <br /> maintaining a healthy fishery. Until formal amendment of the Basin Plan takes place to <br /> reflect the change in criteria, if the Regional Board decides to retain Delta temperature <br /> provision in the Permit, a seasonal average (three-month block) should be used to apply <br /> the objectives. <br /> 2. Appropriate Averaging Periods for Temperature pH and Turbidity <br /> The current Basin Plan was specifically amended to allow averaging for <br /> compliance with the turbidity, temperature, and pH objectives, recognizing that <br /> "instantaneous"compliance with the Delta provisions is unnecessary.-(See, e.g.; Basin <br /> Plan at III-5.00 providing for the availability of averaging periods for pH.) Extended <br /> seasonal averages will be fully protective of instream uses. Therefore, the City requests <br /> the Regional Board to include extended averaging periods (at least three months) in <br /> permit for pH, temperature, and turbidity to reflect the Basin Plan if limitations for such <br /> parameters are found to be necessary to protect uses. <br /> 3. pH Limitations <br /> The proposed Permit contains two sets of pH limitations (Section B.6. and Section <br /> F.7.). The more stringent limitations contained at paragraph D.S. are not necessary to <br /> ensure a healthy fishery. In particular, the provision regarding the need to restrict any pH <br /> NPDESPermitComments Exhibit 2 Page 22 12/17/99 <br />