THE VIRGINIAN-PILOT
Copyright (c) 1995, Landmark Communications, Inc.
DATE: Monday, July 3, 1995 TAG: 9506300005
SECTION: FRONT PAGE: A12 EDITION: FINAL
TYPE: Letter
LENGTH: Medium: 66 lines
Some questions have been raised about how the Virginia Department of Environmental Quality (DEQ) controls the discharge of tributyltin (TBT), a pesticide used in a variety of applications, especially to paint boat hulls, into the waterways of the commonwealth.
The program instituted in the commonwealth to reduce TBT levels in waterways has been very successful. We have reduced the levels in four ways:
1. The General Assembly, followed by the U.S. Congress, banned TBT use on vessels smaller than 25 meters.
2. DEQ, through its permitting process, has required comprehensive ``Best Management Practices'' for shipyards which handle TBT.
3. The shipyards and ship owners themselves have voluntarily reduced the use of TBT.
4. The U.S. Environmental Protection Agency has required the reformulation of TBT to alter its release rate from ship hulls. Of these, the ban on use of TBT on smaller vessels has contributed the most reduction of TBT in Virginia waterways.
Contrary to what might have been reported, the commonwealth has neither taken nor proposed any action which would reduce the effectiveness of any of these efforts.
What we have done in the latest round of permit renewals for shipyards is to require even more extensive and rigorous use of best-management practices.
Additionally, we have required shipyards to notify DEQ prior to handling TBT, so that DEQ and the shipyards can jointly agree on appropriate safeguards.
Finally, we have proposed additional shipyard monitoring to ensure that TBT levels continue to drop.
That's an important fact: TBT levels are steadily dropping. According to the Virginia Institute of Marine Science, concentrations of TBT in oysters sampled in 1994 ranged from 17 to 3,200 parts per billion. In 1987, those concentrations range from 180 to 5,600 parts per billion. These data tend to support the contention that our approach works.
What has caused some confusion in the media is the DEQ decision for the time being to rely on prior notification, best-management practices and monitoring until an appropriate standard is developed from which we can write meaningful numerical limits. Developing such a standard is no easy task. The U.S. Environmental Protection Agency with its vast resources, has been working, without success on setting such a standard nationally since 1988. When DEQ is able to develop an appropriate TBT standard for short-term discharges, then numerical limits will be incorporated into all shipyard permits.
Perhaps the most disturbing characteristic of this public discussion has been the lack of genuine communication. DEQ has now explained to several media outlets our approach to the permits. In return, we have heard only vague criticisms. The only specific critique offered was that our approach would ``increase TBT levels'' in the waterways of Virginia.
The fact that TBT levels have been dropping while we have been on this course clearly demonstrates that any increase is unlikely. If there are more specific criticisms, if there are better approaches based on sound science, we are eager to discuss them.
FRANK DANIEL
Department of Environmental Quality
Commonwealth of Virginia
Richmond, June 20, 1995 by CNB