July 20, 2001
Mr. Jim Rudeen
Kansas Department of
Health & Environment, Bureau of Water
Forbes Field, Building 283
Topeka, KS 66620
Reference: Proposed Revisions to the Kansas Surface Water Quality Standards: Vol. 20, No. 20, Kansas Register page 761, May 17, 2001
Dear
Mr. Rudeen:
The Salt Institute is
the association of the major salt producers in the U.S. and around the world. Four Salt Institute member companies, Cargill Salt
Division, IMC Salt, Inc., Lyons Salt Company and Morton Salt Division, produce rock salt
or granulated-evaporated salt in Kansas.
The Salt Institute
concurs with the Kansas Department of Health & Environment’s decision to propose suspending its 352-mg/L aquatic life chronic
chloride criterion. We urge KDHE to seek and evaluate additional aquatic toxicity data, review
the Environmental Protection Agency’s calculation procedures for developing water
quality standards, and use the triennial review process in calendar year 2002 to propose
and finalize a strategy for setting a suitable chronic criterion for chloride. During the interim, maintaining the 860-mg/L
aquatic life acute chloride criterion in concert with the KDHE’s April 16, 2001
antidegradation policy should adequately protect the State’s surface waters.
We
appreciate the opportunity to support KDHE’s proposed revisions as they affect
chlorides and trust our comments will be helpful.
Very
truly yours,
Bruce M. Bertram
Technical Director