by Angel Kruzen
This is something that Ken Midkiff and I have been working on for what seems a life time. Please write in and comment on the proposed Water Quality standard rules.
Some of the problems are:
1. Mine dewatering
On Page 850 paragraph (7) (*see below) Outstanding National Resource Waters it says that Under section (2) Antidegradation section of this rule, new releases to outstanding national resources waters from any source other then publicly owned water treatment facilities and mine dewatering water are prohibited and releases from allowed facilities.
I question the comment that mine dewatering is not prohibited from discharge. Mine dewatering should be prohibited! Mine dewatering contains chemicals and substance.
• Ammonium nitrate from mine blasting.
• Sewage
• Petroleum products from underground machinery.
• Lead, Zinc, arsenic, cadmium, cobalt, etc. are in the ore and concentrate from the mill.
• It can also cause the groundwater table to be lowered. The lowering of groundwater would effect the springs that feed the outstanding resource waters.
• See 40 CFR35.1550(e)(2) which provides that no degradation is allowed in Outstanding resource waters. Mine dewatering would be degrading the resource.
• Can you tell me of a watershed where metal mining has taken place where the watershed/water quality hasn’t been degraded?!
2. Secondary contact use:
On page 848 section (C) Fecal Coli form Bacteria (*see below) you have the following Bacteria criterion. If a stream is classified for Whole body contact then the stream can only have a fecal coli form count of two hundred colonies per one hundred milliliters (200/100ml) or E. Coli count shall not exceed 126 colonies per one hundred milliliters (126/100ml) If it is classified as secondary contact it can then received a fecal coli form count up to one thousand eight hundred colonies per one hundred milliliters (1800/100ml) or a e coli count that shall not exceed 1,134 colonies per one hundred milliliter (1134/100ml). True this is done during the recreational season and by geometric means. But how does the secondary contact numbers protect the children/citizens of the state?! When I look at the numbers that would be allowed for secondary contact use and think of the children/citizens of the state using that water for wading, boating, ect. and the amount of protection that secondary contact designation gives them. It makes me sick! Children go wading in streams all the time. Why are they only given secondary contact protection. Are they secondary citizens? A parent can tell her/his child to stay out of a stream but that doesn’t really stop them. Can you tell me of a parent whose child always does what they are told, I can’t! I do a lot of Stream Team work with kids. You don’t want to take them to a deep stream. You want something that’s safe where if something happens its easer to get to them. Once again how does the secondary contact protection in the streams that stream teams work in protect the children of the state?
3. Synergy
I did not see anywhere the term synergy used. This is a very important issue that we need to face. A lot of metals/chemicals that can be safe at a certain number when combined with other substances/metals can be toxic. The EPA has knowledge of what some of these chemicals/metals are and this should be incorporated into the table on metal criteria.
Write to:
Marlene Kirchner, Clean Water Commission Secretary
P.O. Box 176
4. Jefferson City, MO 65102.
To be considered, comments must be postmarked by 5:00 p.m. July 14, 2005. A public hearing is also scheduled for 9:00 a.m., July 6, 2005, in the Best Western Moberly Inn, 1200 Highway 24 East, Moberly, Missouri, during the regularly scheduled Clean Water Commission meeting.
(*) Missouri Register proposed Rules May 2, 2005 Vol. 30, No. 9 (http://www.sos.mo.gov/adrules/moreg/current/2005/v30n9/v30n9.asp)
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