ML030920169

NPDES Permit No. SC0030856 Modification

ML030920169
Person / Time
Site:	Summer
Issue date:	04/02/2003
From:	Browne M South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SC0030856
Download: ML030920169 (13)

Text

Melvin N. Browne Manger, Nuclear Licensing 803.345-4141 A SCANA COMPANY U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 NPDES PERMIT NO. SC0030856 MODIFICATION South Carolina Electric & Gas Company (SCE&G) hereby submits a copy of a modification to the Virgil C. Summer Nuclear Station National Pollutant Discharge Elimination System (NPDES) permit. The revision was approved by the South Carolina Department of Health and Environmental Control on March 12, 2003, with an effective date of April 1, 2003.

Should you have any questions regarding this submittal, please contact Ms. Susan B.

Reese at (803) 345-4591.

Very truly yours, Melv N. rowne SBR/MNB/sr Attachment c:

N. 0. Lorick N. S. Cams T. G. Eppink (w/o Attachment)

R. J. White L. A. Reyes K. R. Cotton NRC Resident Inspector K. M. Sutton NSRC RTS (0-L-99-0079)

File (814.07-1)

DMS (RC-03-0071)

Coo \\

SCE&G I Virgil (. Summer Nuclear Station. P. O. Box 88. Jenkinsville, South (arolina 29065.T (803) 345 5209. www.scona com

MODIFICATION:

April 1, 2003 Part III. Limitations and Monitoring Requirements A. Effluent Limitations and Monitoring Requirements

1.

During the period beginning on the effective date of this permit and lasting through the expiration date, the pernittee is authorized to discharge from outfall serial number 001: once through noncontact cooling water to the Monticello Reservoir Such discharge shall be limited and monitored by the permittee as specified below:

EFFLUENT DISCHARGE LIMITATIONS MONITORING CHARACTERISTICS REQUIREMENTS Mass Concentration Monthly Daily Daily Monthly Daily Sampling Average Maximum Minimum Average Maximum Frequency Sample Type Flow MR', MGD MR', MGD Continuous Estimate2 Intake Temperature 3 MRI MR Continuous Continuous 4mR Plume Temperature-32.20C(900F)

MR Continuous Continuous Discharge Temperature

-MR 450C(1 13'F)

Continuous Continuous Copper6 1/Month Grab Iron7 MI MRI 1/Month Grab Manganese7 MI MI 1/Month Grab pH 6.0 s.u.

8.5 s.u.

1/Month Grab

'MR: Monitor and Report 2See Part II.J.

3Intake temperature shall be measured on the inlet side of the main condenser 4Plume temperature shall be taken at the intake structure of Fairfield Pumped Storage Facility when the Fairfield Pumped Storage Facility is generating 5Discharge temperature shall be monitored at the outlet corresponding to an individual unit prior to mixing with the receiving stream 6See Part V.A.4 7See Part V.A.5 Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s) unless otherwise specified:

after treatment but prior to mixing with the receiving stream.

CD W p

P0

_F -bl o

LA 00 CN There shall be no addition of chlorine to the main condenser cooling water

Part III. Limitations and Monitoring Requirements A. Effluent Limitations and Monitoring Requirements

2.

During the period beginning on the effective date of this permit and lasting through the expiration date, the permittee is authorized to discharge from outfall serial number 003: low level radiological wastes to the Broad River Such discharge shall be limited and monitored by the permittee as specified below:

EFFLUENT CHARACTERISTICS DISCHARGE LIMITATIONS MONITORING REQUIREMENTS Mass Concentration Monthly Daily Daily Monthly Daily Sampling Sample Type Average Maximum Minimum Average Maximum Frequency SampleType Flow MR', MGD, MR', MGD

'/Occurence 3

Estimate 2 Total Suspended Solids 30 mg/i 100 mg/l I/Occurence3 Grab Oil & Grease 15 mg/I 20 mg/i l/Occurence3 Grab

,H

_6.0 s.u.

9.0 s.u.

1/Month Grab

'MR: Monitor and Report 2See Part 11J. 1 3Samples shall be taken at least once per occurrence of discharge but need not be more than once per month Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): the nearest accessible point after the discharge from the Liquid Waste Processing System or the Waste Monitor Tanks, but prior to mixing with the receiving stream.

~0 cc-on th C,

To

(

A To 00 Uhf f

MODIFICATION:

April 1, 2003 Part III. Limitations and Monitoring Requirements A. Effluent Limitations and Monitoring Requirements It.

During the period beginning on the effective date of this permit and lasting through the expiration date, the permittee is authorized to discharge from outfall serial number 014: combination of internal Outfalls 005, 06A, 06B and 008 to the Monticello Reservoir Such discharge shall be limited and monitored by the permittee as specified below:

EFFLUENT I

DISCHARGE LIMITATIONS MONITORING Mass Concentration Monthly Daily Daily Monthly Daily Sampling Average Maximum Minimum Average Maximum Frequency Sample Type Flow MR', MGD MR', MGD Continuous Continuous2 Total Residual Chlorine3 0.011 mg/l 0.019 mg/l 1/Month Grab Ammonia 2.1 mg/I 4.2 mg/i 1/Month Grab Copper 0.028 mg/l 0.039 mg/l 1/Month Grab pH (April - October) 6.0 s.u.

9.0 s.u.

I/Month Grab pH (November - March) 6.0 s.u.

8.5 s.u.

1/Month Grab

'MR: Monitor and Report 2See Part 1.J. 1 3See Part V.A.4 Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s) unless otherwise specified:

after discharge but prior to mixing with the receiving stream.

IV It I o

° n

L

Part III Page 29 of 45 Permit No. SCO030856 B. Effluent Toxicity Limitations and Monitoring Requirements

1. During the period beginning on the effective date and lasting through the expiration date, the permnittee is authorized to discharge from outfall 001: once through noncontact cooling water to the Monticello Reservoir Such discharge shall be limited and monitored by the permittee as specified below:

EFFLUENT DISCHARGE MONITORING REQUIREMENTS CHARACTERISTICS LIMITATIONS Quarterly - -

Measurement Sample Type

- Average'

-Maximum!

Frequency WET Chronic Testing

@ CTC= 100%

'25 2, 40a%2 I/Quartee?.

Grab Whole Effluent Toxicity Chronic Testing MR %2 MR %2,

l/Quartd?

Grab

-Reproduction @ CTC=

100%__

Whole Effluent Toxicity Chronic Testing - Mortality MR %2 MR %2 l/Quarte?

Grab

@CTC= 100%

'Quarterly average is defined as the mean of percent effects for all valid tests performed during the monitoring period following the procedures given in Part V.B. 1.d. Maximum is defined as the highest percent effect of all valid tests performed during the monitoring period following the procedures in Part V.B.l.d.

2 See Part V.B. I for additional toxicity reporting requirements. MR = Monitor and Report.

3 Valid tests must be separated by at least 13 days (from the time the first sample is taken to start one test until the time the first sample is taken to start a different test). There is no restriction on when a new test may begin following a failed or invalid test.

a.

Samples used to demonstrate compliance with the discharge limitations and monitoring requirements specified above shall be taken at or near the final point-of-discharge but, prior to mixing with the receiving waters or other waste streams.

b. If only one valid test is conducted during a quarter, results from that test must be used to assess compliance with the quarterly average limit as well as the maximum limit. If more than one valid test is completed during the quarter, the mean percent inhibition of all valid tests must be used to demonstrate compliance with the quarterly average limit.

c.

Valid test results from split samples shall be reported on the DMR. For reporting an average on the DMR, individual valid results for each test from a split sample are averaged first to determine a sample value. That value is averaged with other sample results obtained in the reporting period and the average of all sample results reported. For reporting the maximum on the DMR, individual valid results for each test from a split sample are averaged first to determine a sample value. That value is compared to other sample results obtained in the reporting period and the maximum of all sample results reported. For the purposes of reporting, split samples are reported as a single sample regardless of the number of times it is split. All laboratories used shall be identified on the DMR attachment.

MODIFICATION:

April 1, 2003 PartV Page 36 of 45 Permit No. SC0030856 Part V. Other Requirements A. Effluent Requirements

1. There shall be no discharge of floating solids or visible foam in other than trace amounts, nor shall the effluent cause a visible sheen on the receiving waters.

2. Unless authorized elsewhere in this Permit, the permittee must meet the following requirements concerning maintenance chemicals for the following waste streams:

once-through noncontact cooling water, recirculated cooling water, boiler blowdown water, and air washer water. Maintenance chemicals shall be defined as any man-induced additives to the above-referenced waste streams.

a. Detectable amounts of any of the one hundred and twenty-six priority pollutants is prohibited in the discharge, if the pollutants are present due to the use of maintenance chemicals.

b. Slimicides, algicides and biocides are to be used in accordance with registration requirements of the Federal Insecticides, Fungicide and Rodenticide Act.

c. The use of maintenance chemicals containing bis(tributyltin) oxide is prohibited.

d. Any maintenance chemicals added to the above-referenced waste streams must degrade rapidly, either due to hydrolytic decomposition or biodegradation.

e. Discharges of maintenance chemicals added to waste streams must be limited to concentrations which protect indigenous aquatic populations in the receiving stream.

f.

The permittee must keep sufficient documentation on-site that would show that the above requirements are being met. The information shall be made available for on-site review by Department personnel during normal working hours.

g. The occurrence of instream problems may necessitate the submittal of chemical additive data and permit modification to include additional monitoring and limitations.

3. The company shall notify SCDHEC in writing no later than sixty (60) days prior to instituting use of any additional maintenance chemicals in the cooling water system. Such notification shall include:

1. Name and general composition of the maintenance chemical

2. Quantities to be used

3. Frequency of use

4. Proposed discharge concentration

5. EPA Registration number, if applicable

6. Aquatic toxicity information

4. The Water Quality-Based Effluent Limitations (WQBEL) for the parameters listed are not quantifiable using EPA-approved analytical methods. Therefore, the practical quantitation limit (PQL) using the analytical method stated below shall be considered as being in compliance with the limit provided appropriate

MODIFICATION:

April 1, 2003 Part V Page 37 of 45 Permit No. SC0030856 biological monitoring requirements are incorporated into the permit.

Parameter Analytical Method POL Total Residual Chlorine SM4500CIB, C, D, F or G 50 jIg/l

5. This permit may be reopened to eliminate monitoring requirements if reasonable potential is determiined not to exist or to include limitations if the discharge causes, has the reasonable potential to cause or contributes to an instream water quality violation for copper, iron and manganese based on two years of data collected at the sampling frequency stated in Part III.

B. Whole Effluent Toxicity and Other Biological Monitoring Requirements

1. For the'limits identiJIed in Part LI.B.l:

a. A three brood chro6iic toxicity test shall be conducted at the frequency stated in Part l.B, "Effluent Toxicity, Limitations and Monitoring tRequifereennits," using the CTC of 100% and the following test concentrations: 0% (control), 50%, 60%, 71% and 84% effluent. The permittee may add additional test concentrations without prior authorization from the Department provided that the test begins with at least 10 replicates in each concentration and all data is used to determine permit compliance.

b. The test shall be conducted using EPA Method 1002.0 in accordance with "Short-Term Methods for Estimating Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms,"

(EPA/600/4-91/002; 3rd ed., 1994) using Ceriodaphnia dubia as the test species.

Rationale Page 25 of 60 Permit No. SC0030856 support its request that alternative thermal effluent limitations be allowed under Section 316(a) of the Act. In April 30, 1976, a determination was made that the permittee had submitted adequate information to demonstrate that the alternative limitations for the thermal component of the discharge would assure the protection and propagation of a balanced, indigenous population of shellfish, fish and wildlife in and on the Monticello Reservoir. The alternate maximum discharge temperature for Outfall 001 is 450C(l 13'F). A maximum thermal plume temperature of 32.20C(900F) and temperature rise of 1.660C(3.00F) is also imposed. On December 4, 2000, the permittee requested that the requirement to monitor the plume temperature rise be eliminated. There"have been no observed adverse impacts to the aquatic environment attributed to the plume temperature rise. DMR data from 1993 until present shows that there have been no violations of the 3 F plume temperature rise. The Department agreed that there was no useful data being generated by the continuous monitoring at Monticello Reservoir and the request to remove plume temperature rise monitoring requirements from the permit was granted August 2001.

A continuation of the 3 16(a) variance was allowed by the reissuance of the NPDES permit on July 1, 1984, January 3, 1989, and June 19, 1997. A request to continue the variance was included as part of the application for reissuance of the NPDES Permit which was received on April 17, 2002. In order to support the request, the permittee has indicated there has been no change in facility operation and to change -in the biological conimunity. A tertative determination has been made that continuation of the 316(a) variance-is appropriate-in the reissuance of this per'mit.

5. Other Information: In addition to the discharge temperature, the permittee monitors and reports the plume temperature at the inlet structure as well as the intake temperature on the inlet side of the main condenser.

6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: yes

7. Effluent limitations guidelines (ELGs) and professional judgment-based limits: N/A

8. PQL:

9.

Conclusion:

Based on the approved 316(a) study, the limit is Discharge Temperature:

Monthly average: MR Daily maximum: 450C (I 130F)

Sampling Frequency: Continuous Sample type: Continuous Intake Temperature:

Monthly average: MR Daily maximum: MR Sampling Frequency: Continuous Sample type: Continuous Plume Temperature:

Monthly average: 32.20C (90'F)

Daily maximum: MR Sampling Frequency: Continuous Sample type: Continuous Copper

1. Previous permit limits: N/A

2. NPDES Application (2C & 2E): 1.84 jig/I

3. DMR Data: N/A

MODIFICATION:

April 1, 2003 Rationale Page 26 of 60 Permit No. SC0030856

4. Water Quality Criterion: see spreadsheet

5. Other Information:

6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: Yes, based on Aquatic Life from R.61-68

7. Effluent limitations guidelines (ELGs) and professional judgment-based limits: N/A

8. PQL: 0.010mg/I 9.

Conclusion:

In a letter dated September 24, 2002, the permittee stated that there was no source for copper in this outfall and that the level of copper in the discharge is equal to the amount of copper in the intake. As explained in Section II.G.2.b.i.2, if the background concentration is equal to or greater than the applicable stream standard for the parameter of concern, then the derived concentration limit (C.,,) for that parameter and for the protection of that stream standard, is established equal to the stream standard.

The Department does not have any intake data to compare to the discharge data. However, due to the fact that there is insufficient data to do a reasonable potential calculation, the limit for copper shall be monitor and report. A reopener clause will be added to Part V.A in order to evaluate the monitoring data for reasonable potential.

Reasonable potential may be evaluated after each sample using the guidelines established in the permit rationale. (In accordance with Part II.J.4.b.(1), zero may be used in the calculation when the PQL stated above is achieved.) At any time reasonable potential is determined not to exist, the permittee may submit a written request that copper monitoring be discontinued. In addition, the permittee may conduct a dilution study, mixing zone study, recalculation procedure, water-effect ratio procedure, resident species procedure or other EPA-approved procedure in order to either eliminate the monitoring requirement for copper or obtain a site specific limit.

Daily maximum: Monitor and Report Monthly Average: Monitor and Report Sampling Frequency: 1/Month Sample type: Grab Mercury

1. Previous permit limits: N/A

2. NPDES Application (2C & 2E): <0.200 pg/I

3. DMR Data: N/A

4. Water Quality Criterion: see spreadsheet

5. Other Information: The data submitted on the Form 2C was above the PQL. The permittee resampled and the result for the effluent was 2.41 ng/l.

6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: No

7. Effluent limitations guidelines (ELGs) and professional judgment-based limits: N/A

8. PQL: 0.0005 jig/I; EPA Method 1669/1631E 9.

Conclusion:

The reasonable potential calculation using the new sample for mercury of 2.41 ng/l is as follows The

MODIFICATION:

April 1, 2003 Rationale Page 27 of 60 Permit No. SC0030856 number of samples (n) is equal to 1, and the highest value from this data set is 2.41 ng/l. The Coefficient of Variation for a data set where n<10 is estimated to equal 0.6.

The Reasonable Potential Multiplying Factor (RPMF) from Table 3-2 is 6.2. The reasonable potential multiplying factor is used with the highest data point to give the 95% Confidence Level and 95% Probability Basis for the highest reasonable potential for the parameter. Multiply the RPMF by the highest value in the data set to obtain the maximum receiving water concentration as follows: RWC = 6.2 x 0.00000241 = 0.0000149 mg/I The governing criterion for mercury is the Human Health limit of 0.000051 mg/I. Since the RWC is less than the Human Health limit, there is no reasonable potential for excursion above ambient criteria. Therefore, there shall be no limit for mercury based on reasonable potential.

Aluminum

1. Previous permit limnits: N/A

2. NPDES Application(2C&2E): 416plg/l

3. DMR Data: N/A

4. Water Quality Criterion: see spreadsheet

5.

Other Information:

6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: Yes, based on Aquatic Life from 53 FR 33178, 8/30/88

7. Effluent limitations guidelines (ELGs) and professional judgment-based limits: N/A

8. PQL: 0.05 mg/I 9.

Conclusion:

Due to the fact that there is no state standard, there shall be no limit for aluminum.

Iron

1. Previous permit limits: N/A

2. NPDES Application (2C & 2E): 443 jg/I

3. DMR Data: N/A

4. Water Quality Criterion: see spreadsheet

5.

Other Information:

6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: Yes, based on Human Health Water/Organism Consumption from R.61-68

Rationale Page 28 of 60 Permit No. SC0030856

7. Effluent limitations guidelines (ELGs) and professional judgment-based limits: N/A

8. PQL: 0.02 mg/i 9.

Conclusion:

In a letter dated September 24, 2002, the permittee stated that the level of iron in the discharge is equal to the amount of iron in the intake. As explained in Section lJ.G.2.b.i.2, if the background concentration is equal to or greater than the applicable stream standard for the parameter of concern, then the derived concentration limit (C.O) for that parameter and for the protection of that stream standard, is established equal to the stream standard.

The Department does not have any intake data to compare to the discharge data. However, due to the fact that there is insufficient data to do a reasonable potential calculation, the limit for iron shall be monitor and report. A reopener clause will be added to Part VA in order to evaluate the monitoring data for reasonable potential.

Reasonable potential may be evaluated after each sample using the guidelines established in the permit rationale. (In accordance with Part ML.J.4.b.(l), zero may be used in the calculation when the PQL stated above is achieved.) At any time reasonable potential is determined not to exist, the permittee may submit a written request that iron monitoring be discontinued. In addition, the permittee may conduct a dilution study, mixing zone study, recalculation procedure, water-effect ratio procedure, resident species procedure or other EPA-approved procedure in order to either eliminate the monitoring requirement for iron or obtain a site-specific limit.

Daily maximum: Monitor & Report Monthly Average: Monitor & Report Sampling Frequency: I/Month Sample type: Grab Manganese

1. Previous permit limits: N/A

2. NPDES Application (2C & 2E): 51.5 pg/I

3. DMR Data: N/A

4. Water Quality Criterion: see spreadsheet

5. Other Information:

6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: Yes, based on Human Health Water/Organism Consumption from R61-68

7. Effluent limitations guidelines (ELGs) and professional judgment-based limits: N/A

8. PQL: 0.01 mg/I 9.

Conclusion:

In a letter dated September 24, 2002, the permittee stated that the level of manganese in the discharge is equal to the amount of manganese in the intake. As explained in Section II.G.2.b.i.2, if the background concentration is equal to or greater than the applicable stream standard for the parameter of concern, then the derived concentration limit (C,4iO) for that parameter and for the protection of that stream standard, is established equal to the stream standard.

The Department does not have any intake data to compare to the discharge data. However, due to the fact that there is insufficient data to do a reasonable potential calculation, the limit for manganese shall be monitor and report. A reopener clause will be added to Part V.A in order to evaluate the monitoring data for reasonable potential.

Reasonable potential may be evaluated after each sample using the guidelines established in the permit rationale. (In accordance with Part II.J.4.b.(1), zero may be used in the calculation when the PQL stated above is achieved.) At any time reasonable potential is determined not to exist, the permittee may submit a written request that manganese

Rationale Page 51 of 60 Permit No. SC0030856 pH

1. Previous Permit Limits (effective 10/1/1997):

October - April: 6.0 - 8.5 standard units May-September: 6.0 - 9.0 s.u.

Sampling Frequency: 1/Month Sample type: Grab

2. NPDES Application (2C & 2E): (No. of pH analyses: 12)

Minimum: 6.9 standard units.

Maximum: 9.0 standard units.

3. DMR Data: The highest pH was reported on 10/01 as 9.0 s.u. and the lowest pH was reported on 11/97 as 6.3 s.u.

4. Water Quality Data: Effluent Limits for,pH are established in accordance with Reg. 61-68.G. 10. For Class Fresh Water this value is 6.0 - 8.5 standard units.

r

5. Effluent limitation guidelines: N/A

6.

Other information: On December 6, 1999, VC Summer requested an alternate limit for pH of 6.0 - 9.5 s.u. during the months of May - September. The request was a result of permit violations for pH, which the permittee attributed to an algae growth problem due to high temperatures and dry weather during the summer. The Watershed Water Oualitv Management Strategy for the Broad Basin (Technical Report No. 001-98) issued by SCDHEC shows an increasing trend for pH in Lake Monticello and classified uses are being maintained. The Department therefore concludes that there is not an anthropogenic cause for the algal growth. VC Summer requested that the pH variance months be changed to April - October. The algae blooms have been starting earlier and lasting longer due to the extreme drought and heat.

7. PQL: Not applicable 8.

Conclusion:

November - March: 6.0 - 8.5 standard units April - October: 6.0 - 9.0 s.u.

Sampling Frequency: I/Month Sample type: Grab Copper

1. Previous permit limits:

Daily maximum: 0.028 mg/I Monthly Average: 0.039nmg/i Sampling Frequency: 1/Month Sample type: Grab

2. NPDES Application (2C & 2E): 3.38 Ag1l

3. DMR Data: 0.035 mg/I (10/97)

4. Water Quality Criterion: see spreadsheet

5.

Other Information:

MODIFICATION:

April 1, 2003 Rationale Page 52 of 60 Permit No. SC0030856

7. Effluent limitations guidelines (ELGs) and professional judgment-based limits: N/A

8. PQL: 0.010mg/l 9.

Conclusion:

Based on reasonable potential, limit shall be imposed for copper. A schedule of compliance shall be included to allow time to comply with the limit.

Daily maximum: 0.007 mg/i Monthly Average: 0.009 mg/I Sampling Frequency-1/Month Sample type: Grab Mercury

1. Previous permit limits: N/A

2. NPDES Application (2C & 2E): <0.200 jig/l

3.

DMR Data: N/A

4. Water Quality Criterion: see spreadsheet

5. Other Information: The data submitted on the Form 2C was above the PQL. The pernittee resampled and the result for the effluent was 1.62 ngfl and 1.56 ng/l.

6. Does the discharge cause, have the Reasonable Potential to Cause or Contribute: No

7. Effluent limitations guidelines (ELGs) and professional judgment-based limits: N/A

8. PQL: 0.0005 jig/I; EPA Method 1669/1631E 9.

Conclusion:

The reasonable potential calculation using the new samples for mercury of 1.62 ng/l and 1.56 ng/1 is as follows. The number of samples (n) is equal to 2, and the highest value from this data set is 1.62 ng/l. The Coefficient of Variation for a data set where n<l0 is estimated to equal 0.6.

The Reasonable Potential Multiplying Factor (RPMF) from Table 3-2 is 3.8. The reasonable potential multiplying factor is used with the highest data point to give the 95% Confidence Level and 95% Probability Basis for the highest reasonable potential for the parameter. Multiply the RPMF by the highest value in the data set to obtain the maximum receiving water concentration as follows: RWC = 3.8 x 0.00000 162 = 0.00000616 mg/l The governing criterion for mercury is the Human Health limit of 0.000051 mg/I. Since the RWC is less than the Human Health limit, there is no reasonable potential for excursion above ambient criteria. Therefore, there shall be no limit for mercury based on reasonable potential.

Aluminum