STATEMENT BY STORRS WATERMAN 

 proposed standards on Residues, Toxic or other deleterious 

 substances and aesthetic considerations, 



"We believe that the oyster larval bloassay 

 test Is not appropriate for the waters under consideration 

 because no natural oyster sets occur in these waters. 



"Several specifications, notably those relating 

 to pH, turbidity, temperature and color either infer or 

 state that no variance in the levels observed are allowed 

 when natural levels fall outside the range specified. We 

 believe that this is unnecessarily restrictive in all of 

 these instances and that some provision for variance be 

 provided outside the specified range if such natural con- 

 ditions which are by definition out of the control of any 

 discharging Industry or municipality should occur. 



"It is possible that several of the standards 

 proposed including pH, oxygen and turbidity will fall out- 

 side the limiting levels stated on occasion due to natural 

 causes. At such times the Implementation of the standards 

 proposed is not clear. A standard that is not feasible 

 to meet cannot be implemented and detracts from the overall 

 standards proposed. 



"The reference made to other unidentified 

 interstate waters on Page l8 of the brochure is not an 

 acceptable means for promulgating standards for such 



