The Virginian-Pilot
                             THE VIRGINIAN-PILOT 
              Copyright (c) 1996, Landmark Communications, Inc.

DATE: Monday, April 8, 1996                  TAG: 9604050019
SECTION: FRONT                    PAGE: A8   EDITION: FINAL 
TYPE: Letter 
                                             LENGTH: Short :   49 lines

REPORT FACTS ABOUT STATE OVERSIGHT OF TBT

``Group says shipyard getting pollution break'' (MetroNews, March 22) misrepresents several key facts about how tributyltin (TBT) is treated by the Department of Environmental Quality (DEQ).

The inaccurate claim by the Chesapeake Bay Foundation (CBF) that Virginia ``quietly'' drafted a water-pollution permit for Newport News Shipbuilding does not match the record. Let's review the facts:

DEQ has been processing the Newport News Shipyard permit since 1991, and the draft permit has been previously noticed in newspapers of record. In August 1995, DEQ coordinated a site visit to two local shipyards to educate the environmental groups and EPA about the complexity of this issue. TBT was the major topic at a joint environmental board meeting in October 1995. DEQ has written letters, provided fact sheets and draft permits, and hosted meetings and conference calls to address concerns of the environmental groups, namely CBF and the James River Association. Representatives of these groups have had ample and repeated access to DEQ files related to the permit.

The article incorrectly states that the draft permit relaxes safeguards for toxic discharges and does not require any testing for toxic materials other than TBT. In fact, the proposed permit continues the toxics requirements from the previously issued permit and requires testing for numerous metals. Specifically, the draft permit requires toxics monitoring at the dry docks.

DEQ's Hampton Roads regional director was misquoted as saying toxic monitoring was stopped as a compromise. In fact, he explained that an earlier version of the permit required biological testing at the start of the permit on some discharges, based on one data point for some chemicals. Data generated from the first two years of the permit will be used to determine whether biological testing is necessary. The permit includes a reopener clause to allow that permit to be modified with specific biological toxics requirements. Chemical testing will be required for the life of the permit.

Perhaps most important, as requested by the environmental groups, DEQ has proposed the most stringent permit limit for shipyard discharges of TBT.

TBT is an important issue to the health of marine organisms, as well as the economic vitality of the shipyards. It deserves your most careful reporting.

ROBERT G. BURNLEY, director

Program support and evaluation

Department of Environmental Quality

Richmond, March 28, 1996 by CNB