Ion Exchange schematic - www.bing.com/images
INTRODUCTION:
Perfluorinated compounds have been around since the 1940s but have only been detected in Tucson drinking water since 2009 when the Sentry program was started. The Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic acid (PFOA) detections were well below the Health Advisory (HA) limitations set at 70 Parts per Million (ppm). Per- and polyfuoroalkyl substances are hydrophilic synthetic organo-fluorine chemical compounds that have multiple fluorine atoms attached to an alkyl chain. According to The Organization for Economic Co-operation and Development (OECD), there are at least 4730 different PFAS compounds with at least three perfluorinated carbons.
This permit is addressing these compounds and performing a study on ways to remove them from drinking water.
COMMENT LETTER
June 8, 2021
Arizona Department of Environmental Quality
Central Tucson PFAS Project Demonstration Facility
400 E. Congress St., Suite 433
Tucson, Arizona 85701
Mr. McAllister
Water Quality Division
1110 W. Washington Street
Phoenix, AZ 85007
This email address is being protected from spambots. You need JavaScript enabled to view it.
Dear Mr. McAllister, et. al.:
Environmental Review, Inc. has reviewed the Authorization to Discharge under the Arizona Pollutant Discharge Elimination System (AZPDES), Permit #AZ0026212, in compliance with the provisions of Arizona Revised Statutes (A.R.S.) Title 49, Chapter 2, Article 3.1; the Federal Water Pollution Control Act, (33 U.S.C. §1251 et. seq., as amended), and Arizona Administrative Code (A.A.C.) Title 18, Chapter 9, Articles 9 and 10, and amendments and has the following technical comments:
Draft Permit:
1. Table of Contents - Part IV is missing here and in the permit itself.
2. Page 3, Table 1 – Under discharge limitations for Discharge Flow millions of gallons per day (MGD), provide a citation for “REPORT (2)”
3. Page 3, Table 2 –Under Assessment Levels for Hardness provide a citation for “REPORT (mg/L)”.
4. Page 4, Section D, Effluent Characterization Testing –The draft permit states here that the permittee must monitor to characterize the facilities effluent, whether discharging or not. However, since there is only one outfall, this appears to be erroneous.
5. Page 6, first sentence, footnote 3 –this section says to follow the TIE/TRE processes in Part IV.E of the permit, however, there is no Part IV (see comment 1 above).
6. Page 9, Tables 5 &6 –Uses the NODI Codes designation for water quality results to report on the DMR. Please provide the definitions and/or link to the ADEQ page of codes. (https://azdeq.gov/nodi).
7. Appendix A, Part B, Hypothesis Testing – Define LOEC similar to NOEC and provide some context so it is meaningful to readers of our website.
8. Appendix A, Part B – has LOD replaced MDL? Define and provide some context so it is meaningful to readers of our website.
Fact Sheet:
1. The address, 4301 E 32nd St is a Tucson Water Well Site. The permit describes the discharge point, as Outfall 001. However, here in the Fact Sheet it is clear that the discharge will be treated on site and then discharged to the stormwater system. For clarity, add this description to the permit.
2. How will the discharge from the well site be protected from public access prior to entering the sewer system?
3. What is the disposal method for the spent synthetic IX resin? Please provide context, so it is meaningful to readers on our website.
4. Page 4, Part VII, first paragraph: Define the acronym BPJ and provide context so it is meaningful to readers on our website. The list of acronyms in the draft permit is incomplete and should also contain those from the fact sheet.
Please direct your response and comments 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:
AZPDES draft permit.pdf (azdeq.gov)
ADEQ Fact Sheet (public) (azdeq.gov)