Comment Submitted by
Brian Bernados
2008-04-17 19:15:10
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California has traditionally had a policy that called for a water to have it own regenerated off-site GAC returned to it. Many of the concerns may be addressed by #61i78r1.
In Section 3.2.1, the regeneration facility quality control test information must be submitted, but there is nothing specified as to what the QC testing and process should be.
In Section 3.2.1, information must be submitted on the primary contaminants removed. The term “primary contaminants“ is not defined. In some instances there could be other contaminants of concern. Water quality data for any detected contaminant should be submitted for review. For instance, the primary contaminant may be benzene; however, the raw water may also contain perchlorate at a detectable level.
I do not see anywhere in #61i78r1 that states the minimum frequency of testing for the retained media.
Section 7.3.3 states, "Transportation containers shall be suitably protected from environmental contamination and suitably cleaned, by evidence of wash-out tickets that are presented to the purchaser or certifying agency on demand. . . Transportation containers are suitably protected from environmental contamination and suitably cleaned prior to use." What about vehicles, equipment, hoses, fittings and ancillary items?
"Reactivation/regeneration facilities shall have written verification from each water system that each shipment of spent media to be processed . . " Is there a standard for what this verification should contain and swear to?
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