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This isn't true. The shigle test by Envirometrics that was hiconclusive was only one of <br />several tests. If we had time, we would have proceeded with Envirometrics on <br />additional tests. However, in order to meet the deadline set by the School opening, <br />we had to stop piloting and proceed with the baseline concept which is the <br />construction of a conventional caustic soda scrubber. The reason that the pilot test <br />project was delayed was not the labs,'but the delays that occurred during the last <br />construction project at the plant. The activities associated with testing and starting up <br />a new expansion to the plant caused the late start of the pilot project. <br />As you know, the test project is an attempt by the County, with CDM's assistance, to <br />determine whether or not an innovative method for odor control might be worthy of <br />further development and possible use at the County in lieu of die "conventional" <br />method of odor control. The odor control method we are pilot testing involves the <br />oxidation of hydrogen sulfide with chlorine in the pipeline from the RO plant to the <br />existing degasiflers. You may recall that a similar method was employed on the <br />concentrate treatment system, and as a result your two RO plants are the only major <br />RO plants in the state passing the dreaded biotoxicity screening tests. This fact was <br />acknowledged'at the recent conference held in Orlando that was sponsored by the <br />Water Management Districts and the Southeastern Desalination Association. Other <br />RO plant owners have spent hundreds of thousands of dollars dealing with their <br />concentrate treatment systems. <br />Part of the Envirometrics role in testing involved an attempt at determining the <br />chlorine demand of hydrogen sulfide by titrating groups of samples with chlorine. <br />This is a non :standard test and we had requested that Envirometrics attempt certain <br />testing on a best effort basis since it is an experimental project. <br />The test results were sent to Brad O'keefe. I was not copied. later, Brad read the <br />results to me over the phone and we agreed that the results were not useful and we <br />would have to re -test. In fact, Envirometrics letter accompanying the test results <br />indicated that they were not satisfied with the results and asked to retest. <br />Unfortunately, I never received a copy of this letter until after we appeared before <br />the Board of County Commissioners. Much to my chagrin, their accompanying letter <br />explains why the results were inaccurate. My statement "the results presented by <br />Envirometrics were inaccurate for some unknown reason and the results were of no <br />use" was simply a statement of fact from my standpoint of not having all of the <br />correspondence involved. The test results, in no way, reflects on Envirometrics <br />ability, because what they had been asked to perform was a "non-standard", <br />experimental test. In fact, we have full confidence in Envirometrics and have <br />arranged for further testing on the pilot test with Envirometrics. <br />With respect to die Harbor Branch Samples, my statements "that the lab had failed <br />to properly handle and pretreat the samples" now Fippears to be inaccurate and I <br />stand corrected. It was my impression from discussions with the plant staff that the <br />results came back with a THM formation potential of aero. This was not the result <br />one would expect if the samples had been pre -chlorinated prior to testing. During <br />our meeting with Harbor Branch Lab last week, it became evident that this is clearly <br />a case of mis-communication between the lab and the plant staff.. Confusion over <br />which THM test to conduct is easily understood considering that the EPA has many <br />different protocols and methods for this test. I have attached some of these protocols <br />to illustrate this point. What we were looking for on our test was a 7 day THM <br />formation potential (THMFP) on the raw, untreated samples, and an actual <br />(instantaneous) TNM on the treated samples. What actually came back was the actual <br />THM, not the THM potential. <br />As in the case of Envirometrics, this event does not mean that Harbor Branch was at <br />fault, but rather we simply had to retest as stated in my communication with Bill <br />McCain. We have already met with the Director of the Harbor Branch lab and <br />assured him that we have full confidence in their lab and arranged for further testing <br />on the pilot unit. <br />FEBRUARY 28, 1995 77 <br />