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Attachment 3. This translator estimate is based on the partition coefficients that EPA <br /> developed from STORET data from a number of sites. The coefficients for Dredger Cut <br /> may be slightly different, but it is obvious from the effluent data collected over the past <br /> two years that there would be no reasonable potential to exceed the dissolved water <br /> quality objective. <br /> Finally, chronic whole effluent toxicity tests using daphnids (the most sensitive to <br /> metals) have consistently shown that there is no toxicity being caused by any metal <br /> present in the discharge. As such, reliance on the narrative standard of no toxics in toxic <br /> amounts, as explained above, is no justification for the imposition of the stringent metals <br /> limit. <br /> As the available data do not demonstrate that dissolved lead levels are above <br /> EPA's water quality criteria and a calculation based on EPA derived partition coefficients <br /> show that the correct limitations will be much higher than those derived using a default <br /> translator, it is apparent that lead limitations are not appropriate at this-time. Effluent <br /> limitations for lead should be monitor only until sufficient site-specific information has <br /> been obtained to determine whether there is a reasonable potential for the water quality <br /> objective to be exceeded. A schedule of compliance to complete the data gathering <br /> would be appropriate. <br /> Pesticides <br /> The City objects to the effluent limitations for organochlorine pesticides set forth <br /> in Section B.1 of the Permit. The City believes that the water quality standards for <br /> pesticides contained in the Basin Plan are, on their face, illegal because the criteria are not <br /> a clearly-defined standard. Rather, the Basin Plan criteria for organochlorine pesticides <br /> are set at the detection level, which may be a continuous downward spiral as detection <br /> technology improves. Setting an objective at the level of detection is arbitrary and <br /> capricious because of the failure to demonstrate a relationship between the effluent <br /> limitations and the aquatic life use impacts as required by the Porter-Cologne Act. Water <br /> Code § 13241. <br /> NPD[SPermitComments Exhibit 2 Pale 8 12/17/99 <br />