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Interoffice Communication
To J. E. Leeman - Houston
From M. G. Hayes - Westlake
Date April 12, 1984
Subject
TWC Meeting
On April 5 a Technical Water Committee meeting was held. Joining the member company representatives were J. Dale Givens and a number of other DEQ representatives and Myron Knudson from EPA. Also joining the group was Jim Dukes, the contractor with the update of the waste load allocation.
Mr. Knudson basically stated that if industry in Calcasieu Parish forced the DEQ to submit something to EPA that was unacceptable, EPA's response would be harsh, unreasonable permits based on EPA discretion, with heavy emphasis on toxics control. This was primarily aimed at the industry proposal to drop the water quality standard for dissolved oxygen. He also stated that all permits in Region VI must be issued by September,
1985.
Mr. Dukes indicated his contract expired in December, 1984. He briefly discussed, with other DEQ representatives, some fundamental studies to be performed in the Calcasieu River. However, due to the relatively short time frame for completion of his contract, little additional or modified data may be included in the process. The model he will use will be the Receiv II Model by Aware, modified according to the DEQ in put and EPA standard assumptions, for certain parameters.
For purposes of commenting on the DEQ and EPA approach on the Calcasieu River, I need certain information.
1. I questioned Mr. Knudson on the legislative history behind water quality standards, specifically whether fresh water stan dards were universally applied to brackish and salt water situa tions. To follow this question, I would like information on the intent of the requirement, whether this application was originally intended to cover salt water situations and whether this judgement was EPA's interpretation.
2. With respect to #1, is EPA universally applying these criteria to estuaries? Are Mobile Bay, the Delaware River estuary, Chesapeake Bay, etc., covered by these standards? A region by region evaluation may be in order.
3. With respect to #1, I was told after the meeting by the other EPA representative present that a Water Quality Criteria for
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J. E. Leeman Page 2 April 12, 1984
estuaries was in development, but the current status was unknown. What is the status and can we acquire a copy of the existing working draft, whatever the status, and an idea of the proposal date? This is the most important piece of the picture still outstanding. 4. What are the criteria by which water quality standards may be modified? I would expect quite a bit of this information to be readily available in existing documents or through du Pont. Unfortunately, the lead time for commenting on the proposed Louisiana Water Control Regulations is short; the information requested is needed by May 1. If any piece cannot be returned, please let me know as soon as possible. Thanks.
M. G. Hayes mbr cc: RTF JCL MMG RB
CRH EB
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