228£. 



STATEMENT BY STORRS WATERMAN 



no mortalities attributable to the substance tested after 

 two weeks' exposure. This method we believe is more under- 

 standable and useful than the LC[-„ methods proposed. 



9. The standard proposed for color poses 

 some of the same questions Indicated earlier for turbidity 

 in terms of experience and data. We request that in this 

 case no number values be promulgated at this time and a 

 simple "adverse effect on use" specification be written. 



"lO. We do not understand why bioassays would 

 be required for shellfish growing area under aesthetic 

 conditions. It is requested that the last sentence on Page 

 17 be struck. 



"The establishment of standards for aesthetic 

 conditions that specify no evidence of matter other than 

 from natural causes or origin appears to be far beyond that 

 necessary to protect the use. For example, with today's 

 sensitive instrumentation, miniscule quantities of other 

 than natural material could be detected and yet no aesthetic 

 problem exist. 



"Now a few general comments are made about 

 the tentative standards proposed. As pointed out earlier 

 in our suggested criteria, we believe that any bioassay 

 performed should be related to existing water use and per- 

 formed on resident species. This applies directly to the 



