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Based on discussions with staff, historical failures of toxicity testing for mysidopsis <br /> bahia (mysid shrimp) have occurred and were reported to FDEP . Follow up meetings <br /> with FDEP and IRC staff regarding the failures , have been conducted of which FDEP <br /> has suggested considering an ion imbalance review to determine the nature and type of <br /> failures . Based on our experience, we recommend proceeding with a toxicity <br /> investigation evaluation (TIE) since ion imbalance is most likely the culprit of the <br /> existing toxicity failures and not a result of toxic substances in the concentrate . <br /> Through the testing evaluation, we can additionally identify if toxic substances, such as <br /> residual chlorine, may be the cause of the toxicity failures . <br /> The FDEP Guidance Manual provides a rigid procedure to be followed in conducting <br /> bio- assay testing to determine if ion imbalance toxicity is present . This testing will be <br /> conducted by Aqua Survey Laboratories located in Flemington, NJ as they have shown <br /> an ability in the past to accurately conduct this testing . Water quality testing is also <br /> required in order to identify the amount of seawater ions present in the sample of <br /> concentrate . This testing must be accurate and results provided within 24 hours . <br /> The effort for this task includes bio-assay testing, preparation of report, water quality <br /> parameter testing, sample collection, shipping, lab coordination, and final report review. <br /> Task 5 — Respond to RFI ' s <br /> Due to the unpredictable nature of these permit renewals for concentrate disposal to <br /> surface waters, considerable time and effort can be expended for responses to requests <br /> for additional information. A variance for acute toxicity will be requested under the <br /> application renewal . Without the TIE, it cannot be determined at this point if a mixing <br /> zone for chronic toxicity will be required; however, the necessary work to address <br /> chronic toxicity is included in this scope. Initial calculations to support a mixing zone <br /> for toxicity will be provided under this scope . Effort beyond addressing chronic <br /> toxicity to FDEP can be provided as additional scope . <br /> We anticipate up to two requests for additional information which does not include <br /> additional modeling, water quality analysis , re-do ' s of the bio-assay testing, and any <br /> complex modeling FDEP may require above and beyond what is typically required for <br /> these permit, which is beyond the work described herein . Should the permitting process <br /> drag out beyond a reasonable time frame and involve extensive coordination and <br /> additional responses beyond what is listed herein with EPA, this is considered a <br /> additional scope and can be negotiated under a separate work order. <br /> SCHEDULE <br /> We anticipate submittal of draft application to IRC staff by end of April 2005 to mid <br /> May 2005 . The permit application will be submitted to FDEP by June 17 , 2005 . We <br /> will respond to BFI ' s in accordance with FDEP protocol . <br /> INFORMATION PROVIDED BY OWNER <br /> • Copies of all plant permits <br /> H :\044572009\South RO Plant Concentrate Disposal-revl . doc 3 <br />