Introduction
Water is a precious commodity on the South Rim of the Grand Canyon. Kaibab limestone which forms the Rim is highly permeable and runoff from rain and snow permeates the ground which slopes away from the Rim resulting in scarce surface water and springs below the Rim. In 1926, the National Park Service constructed a recycling plant for reclaiming waste water for irrigation and other utility purposes. Indian Garden is the former site of Havasupai farms where water from Garden Creek with year round water flow made it the first inner canyon source of water on the South Rim. With the completion of the pump station, water no longer has to be hauled by rail into the Grand Canyon. Construction to replace two water pumps at the Grand Canyon National Park Indian Garden north pump house began in September of 2020.
January 8, 2021
Swathi Kasanneni
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ADEQ – Water Quality Division
1110 W. Washington St.
Phoenix, AZ 85007
Dear Ms. Kasanneni
Environmental Review, Inc. has reviewed the Draft Permit, Fact Sheet and Preliminary Decision to Issue an AZPDES Permit Renewal #AZ0023621, Indian Garden Potable Water Pump Station, Coconino County dated January 25, 2021. Public Notice 20-37 and has the following comments:
Draft Permit:
1) Table of Contents and Draft Permit: these contain a Part III and a Part V. The draft permit references a Part IV seven times but there is no part IV.
2) Part 1.A.1 – This read: “The Permittee shall limit and monitoring discharges from Outfall 001...”. Consider revising it to read “The Permittee shall adhere to discharge limitations and monitoring requirements…”
3) Table 1 – Fix the typo: Total Dissolved Splids to Solids.
4) Table 1, footnote 3 – enter a space between discharge and characterization.
5) Part 1.B Table 2 – for consistency, enter a space between numbers and units of measure i.e., 3 µg/L, 819 µg/L and 3 µg/L.
6) Part 1.B Table 2 footnote #2 – enter a space between discharge and assessment.
7) Part 1.B Table 2 footnote #4 – enter a space between discharge and characterization.
8) Part 1.C Table 3 footnote #3 – consider adding “the permittee” between requires and to.
9) Part 1.D.1 Should this be tables 1-4 and not just tables 1-3?
10) Part 1.E.4 This section reads “greater than 90%”. Should that be “less than 90%”? (please verify)
11) Part 2.A.3.b.iv cites 9 Arizona Administrative Code (A.A.C) 14, article 6. If this is meant to be A.A.C Title 18, Chapter 9, Article 6 (AAC Title 18 –Environmental Quality/Chapter 9 - Department of Environmental Quality -Water Pollution Control/Article 6, then it is inaccurate because Article 6 has been repealed. Verify the rule reference.
12) Part 2.A.4 has a rule reference to (Arizona Revised Statute) A.R.S Title 9, Chapter 14/Cities and Towns and there is no Chapter 14. I believe the correct citation should be A.A.C Title 9 Chapter 14 –Department of Health Services – Laboratories.
13) Part 2.A.5.a – Once a rule title is written out the first time, (Arizona Administrative Code, Title 9, Chapter 14, Section 609) consider using this format of rule citation throughout the document A.A.C. R9-14-609.
14) Part II.B.5 Table 5 and Table 6 Acronyms and Definitions – Consider spelling out and defining NODI.
15) Part II.B.7.b – The link: http://www.azdhs.gov is directed to the Arizona Department of Health Services Covid page and not the Microsoft Word – Data Qualifiers Rev 4.0 09052012 web (azdhs.gov) document, please verify the correct link.
16) Appendix C.14.c.ii and 15.c.iii: there is a reference in these sections for (f)(2) of section 13, to maintain consistency consider changing it to (f)(ii).
Fact Sheet:
1) Section I - Facility Name: Is it Indian Garden or Indian Gardens?
2) Section III - Applicable Treatment Processes: Has the permittee looked into alternate forms of dichlorination? Ascorbic Acid is a proven method of dichlorination and is considerably less expensive than Sodium Sulfite, the current method for dichlorination.
3) Section VI – The date of the most recent inspection is stated as April 18, 2016 but it notes files were reviewed through November of 2020. If there was an inspection in November of 2020, wouldn’t that be the most recent?
4) There are two Section VIIIs – the first on page 5 - DETERMINATION OF EFFLUENT LIMITATIONS and ASSESSMENT LEVELS and the second on page 12 - NARRATIVE WATER QUALITY STANDARDS.
5) Page 6, paragraph 2, sentence 1 states – “It is assumed that RP exists for exceedance of water quality criteria for the pollutants, if chlorine or bromine is used in the treatment process, total residual chlorine (TRC).” Is part of this sentence missing?
6) Page 8, paragraph 3 and 4: Please define EC monitoring.
Please direct your response to: This email address is being protected from spambots. You need JavaScript enabled to view it.
Sincerely,
Laura Macklin, Associate in Arizona
Senior Reviewer
Environmental Review, Inc., a 501(c)(3) Nonprofit Public Benefit Corporation
1792 Rogers Avenue, San Jose, CA 95112, http://www.envreview.org/
References and Document Links: