Laserfiche WebLink
a <br />exposure to uranium will be achieved only if the 40 pijC per liter <br />water quality standard is met. Thus it is essential tY~at Cotter's <br />discharges consistently comply with the 30-day average limitation <br />of 40 pi/C per liter. <br />But the monitoring requirements for uranium and otl-.er toxic metals <br />(Draft Permit, p.4) require Cotter to obtain only one "dip and take" <br />grab sample per month. The sample is to be taken out of the effluent <br />from outfall OOI which is the discharge from the fifth sedimentation <br />pond. Such a monitoring program is not adequate to ensure compliance <br />with the effluent limitations or water quality standares. <br />One grab sample per month is not a representative sample of the <br />discharge occurring during the 30-day period. One gran sample cannot <br />reasonably be assumed to represent, at most, any more than the quality <br />of the discharge on the day the grab sample is taken. As a result, <br />the required monitoring will give no indication to the Division or <br />the public whether the daily maximum standards are being consistently <br />met or whether the 30-day standards are being met at al.l. <br />This dearth of permittee data is compounded by the fact that the <br />Division typcially inspects "major" sources only once F~very 3 months. <br />*The Division routinely does not: sample a major discharge more than <br />three times per year, and does not have enough staff to consistently <br />sample for compliance with 30-day limitations. The Division, as a <br />matter of normal practice, does not obtain data which i.s any more <br />representative of the effluent than is required by the permit, and <br />the Division is in no better position to determine compliance with <br />either the 30-day average limitation or consistent com~~liance with <br />the daily maximum limitation. Thus, unless the Division devotes <br />special resources to frequent sampling of a source during a given <br />month, there is no information gathered by anyone to determine <br />whether the discharge complies with applicable limitations and water <br />quality standards. As far as EDF has been able to detE~rmine, the <br />Division has never obtained sufficient samples to determine whether <br />30-day average limitations are being consistently met key any <br />*Fred Matter, Chief of the enforcement section, informed EDF that <br />the Division inspects "major" dischargers on a quarter_Ly basis and <br />inspects all other dischargers only in response to complaints or <br />based on a pattern of violations contained iii monitoring reports <br />filed by the permittee. Whether Schwartzwalder will bc~ treated as <br />a "major" discharger is not clear since the distinctio~i established <br />by the Division is not a formal, enforceable policy of the Division <br />or the Commission. For the purpose of this Comment, EDF assumes <br />that Schwartzwalder will be treated as a major discharger, but will <br />request assurance at the public hearing that Schwartzw~sler will be <br />treated as a "major" discharger. According to Mr. Matter, the <br />Enforcement section has 4 field inspectors to inspect :L54 "major" <br />dischargers. Using the Division's written procedure of 3 grab samples <br />during 3 consecutive weeks to determine compliance with 30-day limi- <br />tations, and assuming that each major discharger has a~ least one <br />30-day limitation, then 462 site inspections are required per quarter, <br />but only 262 person-days are available if vacations an<9 sick days are <br />not counted. <br />-2- <br />