HYDRO29533 - Laserfiche WebLink

Home Browse Search

0 a MR: ROBERT J. SHUKLE CDPS N0. CO-0027154 OCTOBER 3, 1985 PAGE 4 for the reasons set forth in a separate letter you o-+ill receive from David Arkell. Because the spring is not a new source, a compliance schedule is appropriate. Even if the Pond is a new source, the proposed parameter of manganes should be deleted from the renewed Permit for this Discharge Point. Thi parameter is being proposed apparently because manganese has appeared i samples taken of the water at the spring. However, as demonstrated in Tabl III, samples of water at the Discharge Point indicate that manganese is not concern at the point of discharge into waters of the State. Because th discharge point and not the spring is the appropriate measuring point, it i not appropriate to include manganese as a parameter, and it should be remove from the renewal Permit. The reduction in probably a result of water passes through a greater tendency tc manganese between the spring and the oxidation to less solvable compounds the discharge point. These less lu ~ecipitate out eithe in the ditc n Lne discharge point is before the spring ble compounds have Between e spring Further, manganese is not generally considered toxic to aquatic life, but is objectionable in public water supplies only because of cosmetic effects and taste (EPA Water Quality Criteria, 1976). As stated in your letter of August 29, there are no water users immediately downstream from this Discharge Point 005. Water quality data taken at the discharge point of Pond F (site 87) is set forth in Tables I and II. Additional data is forthcoming and will be submitted to you by October 18, 1985. Silver Limitations CYCC believes that the proposed silver limitations imposed at outfalls #005 and #001 are not appropriate due to analytic uncertainty surrounding sil- ver values at low levels. CYCC believes that a daily maximum silver limita- tion of 0.0005 mg/1 and a 30 day average limitation of 0.0003 mg/1 are appropriate due to reasons stated below. CYCC's testing laboratory, 8ookcliffs Laboratories, has obtained quality control data for laboratory-pure water which indicate that silver values near the detection limit have a 95% confidence interval of being within a range of +0.0002 mg/1. The range for real world samples would be greater. 8ookcliffs Laboratories recommends that to ascertain if a water sample exceeds an esta- bli.,::~d limit for some parameter, the analytical method for that parameter should have a detection limit at least five times lower than the established limit. Attached is 8ookcliffs' letter to CYCC documenting the analytical uncertainty. ~~~s is i~„/°-~ i n,~, ~,°' i >v~ u~1 ~ll ~ ~~ ~ ~~ pb~ ~P~wr ~ ~~~ P~ ~5 ~~ ~~~~. r Using the best available technology (8nT), it is not statistically pos- sible to consistently meet the proposed silver limitations. For example,