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Middle St. Johns - Florida Department of Environmental Protection

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Water Quality Assessment Report: <strong>Middle</strong> <strong>St</strong>. <strong>Johns</strong> 461<br />

2956B that dissolved oxygen is naturally low, and bioassessment data indicate that<br />

aquatic life use support is being maintained, therefore these have not been listed. As<br />

<strong>of</strong> the November 5, 2003 update <strong>of</strong> the IWR database, DO was not impaired in water<br />

segment 2986B and it is not listed.<br />

3. Those impaired water segments on the 1998 303(d) list that do not meet the<br />

sufficiency requirements for the planning list must be placed in category 3c and on<br />

the planning list to remain consistent with [section] 62-303.300(2) <strong>of</strong> the IWR]. The<br />

assessment status <strong>of</strong> two water segments needs to be changed from insufficient data<br />

to planning list. (WBID: 2994A, 2962).<br />

RESPONSE: All 1998 303(d) listed parameters for which there were no data or<br />

insufficient data for assessment under the IWR were retained on the planning list, in<br />

the 3c EPA Integrated Report Category, but their proposed status is shown as “no<br />

data” or “insufficient data” (ND/3c or ID/3c). This was done to distinguish them<br />

from 3c listings for which there were sufficient data for assessment (PL/3c). All non-<br />

1998 303(d) listed parameters for which there were no data or insufficient data were<br />

shown as such, and placed into categories 3a or 3b respectively (ND/3a or ID/3b).<br />

4. According to EPA guidance, when sufficient evidence <strong>of</strong> impairment is presented in a<br />

small data set, the water should be identified as a water quality limited segment. In<br />

several water segments insufficient data are found in the verified period, but<br />

sufficient exceedances occur to place a parameter on the verified list. Although the<br />

data may be insufficient according to the IWR (< 20 samples), the number <strong>of</strong><br />

exceedances is higher than that allowed by the IWR. EPA views this as sufficient<br />

evidence <strong>of</strong> impairment and believes it should be placed on the verified list. (WBID:<br />

2893A, 2973, 2893B, 2929B1, 2956).<br />

RESPONSE: Table 2 in section 62-303.420 <strong>of</strong> the IWR provides thresholds <strong>of</strong><br />

verified impairment, based upon a minimum number <strong>of</strong> exceedances at given ranges<br />

<strong>of</strong> total observations. A minimum <strong>of</strong> 20 observations is required, for verification to<br />

be considered under the IWR. This minimum number is intended to ensure that<br />

conclusions about impairment are not drawn based upon small, unrepresentative data<br />

sets.<br />

5. Silver is not listed as a new parameter <strong>of</strong> concern from the IWR on the master list.<br />

Please enter silver into that column. (WBID: 2925).<br />

RESPONSE: Silver in water segment 2925 met the data sufficiency requirements<br />

for assessment under the IWR, as <strong>of</strong> the November 5, 2003 update <strong>of</strong> the IWR<br />

database, and is considered potentially impaired. It has been added to the planning<br />

list.

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