Middle St. Johns - Florida Department of Environmental Protection

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460 Water Quality Assessment Report: Middle St. Johns Appendix J: Summary of Public Comments and the Department’s Responses on Florida’s 2003 Verified List of Impaired Surface Waters: Middle St. Johns River Group 2 Basin EPA Comments 1. Some parameters of concern do not contain data in the verified period, but do contain data in the planning period and are being proposed for delisting. Is the state using planning period data for delisting in the absence of verified period data Why isn’t the state also using planning period data for listing in the absence of verified period data (WBID: 2893D). RESPONSE: As of the November 5, 2003 update of the IWR database, there were sufficient data in both the planning and verified periods to assess waterbody segment 2893D (Lake Monroe) for the three parameters which were 1998 303(d) listed and are being proposed for delisting. These are lead, selenium and un-ionized ammonia. To answer these questions however in a more generic manner, where sufficient data are available for assessment of a 1998 303(d) listed parameter in the planning period, and the parameter meets standards, the parameter may be proposed for delisting, even if there are no data or insufficient data for assessment of the parameter in the verified period. This is consistent with section 62-303.720(1) of the IWR. Where a parameter meets standards in the planning period, and there are sufficient data in the verified period for assessment of the parameter, and the parameter is verified impaired, it will be added to the verified list. Where sufficient data are available for assessment of a parameter in the planning period, and the parameter is shown to be potentially impaired, and there are no data or insufficient data in the verified period to assess it, it will be added to the planning list. 2. Placing dissolved oxygen and/or biology in category 5 as verified impaired without identifying the causative pollutant is consistent with EPA policy, but inconsistent with FDEP regulations. EPA does support the proposal for listing dissolved oxygen without the pollutant identified. (WBID: 2964, 2962, 2925, 2893E, 28933, 2921, 2893Z, 2893B, 3001, 3014, 2991A, 2956B, 2986B, 3004). RESPONSE: Corrections have been made to the dissolved oxygen listings for water segments 2964, 2925, 28933, 2921, 2893B and they have been retained on the planning list. Only those dissolved oxygen listings for which the causative pollutant has been identified are now listed as verified impaired, consistent with section 62- 303.710(2) of the IWR. BOD has been identified as the causative pollutant for the DO impairments in water segments 2962, 3004, and 3014, therefore these have been retained on the verified list. Elevated algal biomass has been identified as the causative pollutant for the DO impairment 2893E, therefore it has been retained on the verified list. It was determined in WBIDs 2893Z, 2956B, 3001, 2991A, and
Water Quality Assessment Report: Middle St. Johns 461 2956B that dissolved oxygen is naturally low, and bioassessment data indicate that aquatic life use support is being maintained, therefore these have not been listed. As of the November 5, 2003 update of the IWR database, DO was not impaired in water segment 2986B and it is not listed. 3. Those impaired water segments on the 1998 303(d) list that do not meet the sufficiency requirements for the planning list must be placed in category 3c and on the planning list to remain consistent with [section] 62-303.300(2) of the IWR]. The assessment status of two water segments needs to be changed from insufficient data to planning list. (WBID: 2994A, 2962). RESPONSE: All 1998 303(d) listed parameters for which there were no data or insufficient data for assessment under the IWR were retained on the planning list, in the 3c EPA Integrated Report Category, but their proposed status is shown as “no data” or “insufficient data” (ND/3c or ID/3c). This was done to distinguish them from 3c listings for which there were sufficient data for assessment (PL/3c). All non- 1998 303(d) listed parameters for which there were no data or insufficient data were shown as such, and placed into categories 3a or 3b respectively (ND/3a or ID/3b). 4. According to EPA guidance, when sufficient evidence of impairment is presented in a small data set, the water should be identified as a water quality limited segment. In several water segments insufficient data are found in the verified period, but sufficient exceedances occur to place a parameter on the verified list. Although the data may be insufficient according to the IWR (< 20 samples), the number of exceedances is higher than that allowed by the IWR. EPA views this as sufficient evidence of impairment and believes it should be placed on the verified list. (WBID: 2893A, 2973, 2893B, 2929B1, 2956). RESPONSE: Table 2 in section 62-303.420 of the IWR provides thresholds of verified impairment, based upon a minimum number of exceedances at given ranges of total observations. A minimum of 20 observations is required, for verification to be considered under the IWR. This minimum number is intended to ensure that conclusions about impairment are not drawn based upon small, unrepresentative data sets. 5. Silver is not listed as a new parameter of concern from the IWR on the master list. Please enter silver into that column. (WBID: 2925). RESPONSE: Silver in water segment 2925 met the data sufficiency requirements for assessment under the IWR, as of the November 5, 2003 update of the IWR database, and is considered potentially impaired. It has been added to the planning list.
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Middle St. Johns - Florida Department of Environmental Protection

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