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Date: Aug. 28, 2007  

Subject: Lodi's response to State Water Board investigation

Contact: Communications Specialist Jeff Hood, (209) 333-6801; Public Works Director Richard Prima, (209) 333-6759.

Agency's conclusions about Lodi treatment plant seriously flawed

LODI – A state agency’s recent investigation of groundwater at Lodi’s sewage treatment plant ignored key data in two city reports, resulting in many inaccurate conclusions about the facility’s impacts on the environment.

The issues raised by the State Water Resources Control Board’s Aug. 1 report have been addressed already through the city’s cooperation with the Central Valley Regional Water Quality Control Board, which will consider renewing Lodi’s discharge permit at its September meeting in Fresno.

(Read Public Works Director Richard Prima's Aug. 27 letter to the regional board here; view what the experts say about the state board report here)

Lodi has, in fact, been a leader in San Joaquin County for its discharge practices. In January 2005, Lodi became the county’s first city to treat wastewater to a standard making it suitable for irrigating food crops. At the same time, Lodi began using ultra-violet light to destroy pathogens, instead of potentially hazardous chlorine. The use of UV light greatly reduces the creation of toxic disinfection byproducts.

“We’re proud to be at the forefront of good wastewater practices,” Lodi City Manager Blair King said. “As more stringent discharge regulations have come along, our ratepayers have cooperated with the state by funding millions of dollars in plant upgrades, rather than delaying the inevitable.”

The leader of a local environmental organization even complimented the city for its treatment plant, telling The (Stockton) Record in 2005 that Lodi was “setting the standard for compliance and a demonstrated concern for the White Slough area in the Delta. They demonstrated a willingness … to do what they could to protect water quality.”

Many of the errors in the state board’s Aug. 1 report could have been avoided had its author simply checked his assumptions with city staff, regional board staff or the engineering experts who have guided the city through $45 million in plant upgrades since 1999.

Among the state board investigation’s shortcomings:

  • Background levels of nitrate and other elements in groundwater are unknown, despite the 19 test wells drilled by the city, because of other potential sources, such as nearby dairies and an intrusion of brackish water from the Delta.
  • The investigation by the state noted that Lodi overloaded adjacent farmland with nitrogen in 2001, but the report failed to state that Lodi changed its discharging practices after discovering the impact. In fact, following the city’s 2006 report, Lodi retained a soils scientist to ensure nitrogen loading was reduced to a sustainable rate.
  • The state report also noted Lodi discharged effluent onto fallow fields in 2001, but failed to point out it was done to test the soil’s absorption rate and that subsequent monitoring did not identify any impacts from the test.
  • The report failed to recognize salinity and nitrogen sources coming from outside the wastewater plant boundaries.
  • The report failed to recognize that part of the White Slough plant upgrades includes $20.6 million that will result in lower nitrogen levels in treated domestic wastewater.

In contrast to the State Board evaluation, the Regional Board staff did rely on all of the available information, such as all the information in the city’s 2004 and 2006 investigations, to develop the tentative permit that is currently under consideration.

For more information about the White Slough Water Pollution Control Facility, visit http://www.lodi.gov/public_works/wastewater_treatment_plant.html


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