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Attachment 1 <br /> ❑ � /� IGmleya to <br /> � [ and Associates, Inc. <br /> Memorandum <br /> 4431 Embarcadem Ddw <br /> Wed Palm Beech, Fbdda <br /> 3%87 <br /> To: Erik Olson, Terry Southard, Himanshu Mehta, Gerry LeBeau <br /> From: John Potts <br /> Re: Analysis of FDEP November 3, 2006 RAI on South WTP Concentrate <br /> Discharge Permit Renewal, Proposal for Engineering Fee Increase <br /> 044572009 <br /> Date: December 18, 2006 <br /> The November 3, 2006 Additional Information Request (RAI) in regards to <br /> the application for renewal of the South RO Water Plant (South ROWTP) by- <br /> product discharge permit requested the following analytical investigations. <br /> • FDEP remains of the opinion that the intermittent toxicity is a result of <br /> Major Seawater Ion Imbalance (MSHT). <br /> • FDEP has requested water chemistry testing of those ions associated with <br /> MSIIT on by-product treated by the current chlorine/aeration as well as the <br /> aerated only processes. This testing is to include ammonia and fluoride <br /> which are not part of the MSI1T ions. It is our opinion that this testing is <br /> intended to identify subtle yet sufficiently significant differences in the <br /> treatment processes that could have an effect on the toxicity as it relates to <br /> MSIlT. <br /> • The data collected is to be compared in a fashion similar to that used in <br /> comparing water quality data from the raw water supply wells serving this <br /> plant. <br /> • The levels of ions present are to be compared with information developed <br /> by the Gas Research Institute using the two toxicity models developed <br /> during the Gas Research Institute studies. <br /> • Should data indicate that MSUT is likely the cause of intermittent toxicity <br /> in the by-product then the MSUT testing must be conducted again. <br /> The RAI was professional in nature and contained no deadline based <br /> statements. This can be interpreted to imply that FDEP is in agreement with <br /> ■ <br /> TEL 561 845 8865 <br /> FAX 581 on 8175 <br />