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r <br /> Memo to Antonia Vorster -3- 15 January 1987 <br /> All constituents analyzed show decreased concentrations between initial and <br /> sustained flows except the lead concentrations at the Whiskey Slough platform. <br /> In addition, all lead values from the runoff samples exceed the-fresh water <br /> aquatic life, 4-day average protection criteria. The increase of the concentra- <br /> tion at the Whiskey Slough platform indicates the 4-day average may be exceeded. <br /> The increase may be due to paint on the platform and sloppy "housekeeping". <br /> In general , concentrations were higher in the initial samples than they were in <br /> the sustained samples. This is most likely explained by the presence of the <br /> corrosion inhibitor in the system's pipelines and the rinsing of contaminants <br /> collected on the platforms themselves. <br /> Due to the infrequent use of the firewater protection system, the limited flow <br /> (two 24-hour days at 4,000 gpm) , and the similarity between background and <br /> sustained flow water quality, I feel there will be no significant impact on <br /> water quality and we can waive waste discharge requirements for the subject <br /> operation at this time. <br /> However, we should request the following from PGandE: <br /> 1. Determine why the levels of lead increased at the Whiskey Slough platform <br /> and how, if possible, they can be decreased. <br /> 2. A maintenance plan to keep the platforms as free of debris as possible. <br /> 3. A justification of the concentration of corrosion inhibitor being used to <br /> protect the system. <br /> 4. Monitoring of initial and sustained runoff of each platform for heavy <br /> metals (ICAP). <br /> DL8:jj <br />