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DSK
 
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Default Environmentalists vs. boatyards, round three

wrote:
We urge the Pollution Control Hearings board to uphold the NPDES permit
issued by the DOE. An 80% reduction of copper runoff from boatyards
from a typical 2000 ppb level to 384 would be a significant step in the
right direction, and we have no way of knowing whether storm water
runoff from any source could be as pure and pristine as the 3-4 ppb
demanded by the environmentalists. When the permits next come up for
renewal, additional information about comparable copper runoff may be
available and it could indeed then be timely to seek a reduction from
the new 384 ppb standard. We additionally urge the boatyard industry to
research, develop, and apply bottom coatings that are as
environmentally benign as possible while still adequately effective.


The way to approach this would be either area samples,
showing (or failing to show) a gradient in copper ppb, or
perhaps it would be more efficient to take point samples of
other runoff discharges.

It's true that boatyards are an environmmentally "dirty"
business and should be required to take steps for pollution
abatement. But it is neither right nor effective to put
boatyards out of business, or simply run up the costs, when
everybody else is getting a free ride. Of course, this also
suggests a way for boatyards to cheat... pipe their drainage
to somebody else's runoff.

Maybe a countersuit requiring the Riverkeepers to show
copper levels all over the affected area waters?

Regards
Doug King