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REGIONAL WATER BOARD REMPNSE (SWRCB/OCC FILE A-1886) • -12- PETITION FOR REVIEW OF WAWE DISCHARGE REQUIREMENTS ORDER NO. R5-2007-0113 (NPDES NO. CA0079243) CITY OF LODI, WHITE SLOUGH WATER POLLUTION CONTROL FACILITY the waters of the state. No antidegradation analysis is required if the Regional Water Board reasonably conclude that degradation will not occur.3 The Petitioner also argues that mass limits for discharges to impaired surface waters must be based on mean loading for metals in order to comply with Order WQO 90-05. As stated in the Fact Sheet, the only 303(d)-listed pollutant with reasonable potentia 14 is mercury. The Order imposes an interim mass limit of 0.113 pounds per month, pending adopting of the Delta methylmercury TMDL. The interim mass limitation for mercury is based on current Facility performance and was established in accordance with Section 2.1.1 of the SI p5 for bioaccumulative priority pollutants. The Petitioner also argues that reverse osmosis treatment technology should be considered BPTC for wastewater discharges of impairing pollutants and that the antidegradation analysis must explicitly detail how and why run-of-the-mill tertiary systems that facilitate increased mass loadings of impairing constituents can be considered BPTC (See, Petition, p. 22). The permit is fully protective of the beneficial uses of the receiving water. In accordance with federal regulations, the permit includes effluent limitations for all constituents where there is a reasonable potential to cause or contribute to an exceedance of the applicable water quality objectives in the receiving water. As stated above, mercury is the only 303(d)-listed pollutant with reasonable potential and the permit includes mass limitations. Furthermore, the use of large-scale reverse osmosis treatment for wastewater treatment plants must be carefully considered due to adverse environmental effects of the technology. The State Water Board, in Water Quality Order 2005-005 (for the City of Manteca), states, "...the State Board takes official notice [pursuant to Title 23 of California Code of Regulations, Section 648.2]of the fact that operation of a large-scale reverse osmosis treatment plant would result in production of highly saline brine for which an acceptable method of disposal would have to be developed. Consequently, any decision that would require use of reverse osmosis to treat the City's municipal wastewater effluent on a large scale should involve thorough consideration of the expected environmental effects." We disagree that every permitting action must consider whether to designate a water as an outstanding national resource water (ONRW). (See, Petition, p. 19.) At any rate, the petitioner has not provided or pointed to any evidence supporting such a designation of Dredger Cut. Consideration of an ONRW designation for the entire Delta is beyond the scope of this permitting action. The Water Boards are currently taking actions to protect the Deltas Considering ONRW designations would be more appropriate as part of that effort. 3 Attwater memo, supra, p.3 4 DDT and organochlorine pesticides were not even detected in effluent but are being monitoring using more sensitive detection limits. Diazinon and chlorpyrifos were not detected, but any limitations for them would be based on adopted TMDLs. 5 "For bioaccumulative priority pollutants for which the receiving water has been included on the CWA Section 303(d) list, the RWQCB should consider whether the mass loading of the bioaccumulative pollutant(s) should be limited to representative, current levels pending TMDL development in order to implement the applicable water quality standard." 6 State Water Board Resolution 2007-0079; Central Valley Water Board Resolution R5-2007-0161 (6 December 2007).