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REGIONAL WATER BOARD RESPONSE (SWRCB/OCC FILE A-1886) • -11- PETITION FOR REVIEW OF WA,*DISCHARGE REQUIREMENTS ORDER NO. R5-2007-0113 (NPDES NO. CA0079243) CITY OF LODI, WHITE SLOUGH WATER POLLUTION CONTROL FACILITY the industrial dischargers to determine if the waste was considered hazardous waste. In addition, the previous Order required the Discharger to monitor the industrial influent to the Storage Ponds annually in February for heavy metals. The monitoring was required in February, because PCP is not discharging to the industrial line at that time. The report and subsequent monitoring data demonstrate that the metal concentrations are well below human health water quality objectives and are, therefore, not a water quality concern. The petitioner also contends that the domestic wastewater discharged to the Storage Ponds and agricultural fields is not adequately regulated and as such is not exempt from Title 27. The Order recognizes the Discharger's land application practices are a threat to groundwater quality. Consequently, the Order requires the Discharger to limit the hydraulic, total nitrogen, and BOD loadings to the agricultural fields to agronomic rates to assure that pollution or nuisance does not occur. The Order also requires the Discharger to comply with groundwater limits for certain pollutants of concern (see Section V.B. Groundwater Limitations) for protection of the beneficial uses of the groundwater and to ensure that degradation does not occur. Furthermore, the Order requires a groundwater characterization study and requires the Discharger to evaluate best practicable treatment or control (BPTC) of the discharge if the groundwater monitoring results show that the discharge of waste is threatening to cause or has caused groundwater to contain waste constituents in concentrations statistically greater than background water quality. The Order adequately regulates the domestic wastewater discharges to land. Therefore, the exemption of Title 27 for domestic wastewater under section 20090(a) is applicable. CONTENTION K: ANTIDEGRADATION ANALYSIS INSUFFICIENT The Order fails to contain an adequate antidegradation analysis and violates both state and federal antidegradation requirements. The State and Federal antidegradation policies require the maintenance of high quality water unless the discharge is required to meet best practicable treatment or control of the discharge and the discharge is consistent with the maximum benefit to people of the state. The Fact Sheet contains an antidegradation analysis consistent with state and federal policies. In this case, surface water discharges are required to meet Title 22 California Code of Regulations "tertiary" standards or equivalent, which is considered to be best practicable treatment or control for most constituents of concern for similar facilities. In the previous Order, the discharger was authorized by the Regional Water Board to increase the discharge to 8.5 mgd provided it could demonstrate compliance with dissolved oxygen standards. The Discharger has provided that demonstration. Since the 2007 Order does not allow an increase or expansion over the 8.5 mgd that was previously permitted, no new antidegradation analysis is required.2 Nevertheless, the Fact Sheet evaluates pollutant by pollutant the impact to waters of the state and demonstrates that such discharges will not unreasonably degrade 2 Memo to the State Water Resources Control Board from William Attwater, mem. to Regional Board Executive Officers (10/7/87), p.5; EPA Water Quality Handbook 2d, § 4.5.