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Mr. Derral Van Winkle - 2 - 03 September 2021 <br /> <br />General Comments: <br /> <br />1. General Comment – Correction on Page A-33, SAP Worksheet #9 <br />Please note that John Murphy stated that the State Water Board has drinking <br />water notification levels for perfluorooctanesulfonic acid (PFOS) of 13 ng/L and <br />perfluorooctanoic acid (PFOA) of 14 ng/L, which reflect nanograms per liter, not <br />micrograms per liter, as currently stated in the Work Plan. Please correct to <br />accurately reflect John Murphy’s statement. <br /> <br />As noted in the Central Valley Water Board’s initial comments, the notification <br />levels were revised in August 2019 to reflect 6.5 parts per trillion for PFOS and <br />5.1 parts per trillion for PFOA. <br /> <br />For easy reference, please find notification levels put forth by the State of <br />California here: PFAS Drinking Water | California State Water Resources Control <br />Board or at the following URL: <br />https://www.waterboards.ca.gov/pfas/drinking_water.html#:~:text=In%20July%20 <br />2018%2C%20DDW%20established,and%205.1%20ppt%20for%20PFOA. <br /> <br />2. General Comment – Data Usability <br />The Central Valley Water Board acknowledges “The Navy ensures that detection <br />and reporting limits meet levels as low as the State’s notification levels to ensure <br />usability of data in the future.” Please note: <br /> <br />1) The Detection Limit (DL) shown in SAP Worksheet #15, page A-70, is below <br />2019 notification levels for groundwater, as identified in General Comment #1. <br />However, the limit of quantification (LOQ) put forth in SAP Worksheet #15 for <br />groundwater is above the stated 2019 notification levels. Therefore, any <br />concentration value detected between the LOD and DL will produce a <br />flagged, estimated quantification, leading to material uncertainty in assessing <br />risk to human health and protecting groundwater quality. <br /> <br />To “ensure usability of data in the future”, the Central Valley Water Board <br />requests the LOQ meet the 2019 notification levels for groundwater, as put <br />forth in General Comment #1. Please also reference General Comment #3. <br /> <br />2) As future reference, the California Office of Environmental Health and Hazard <br />Assessment recently put forth an announcement declaring draft public health <br />goals for PFOS and PFOA. The proposed PHG for PFOA is 0.007 parts per <br />trillion and for PFOS is 1 part per trillion. <br /> <br />For future reference, please find the notification put forth by OEHHA here: <br />Announcement of Availability of a Draft Technical Support Document and <br />Public Workshop for Proposed Public Health Goals for Perfluorooctanoic Acid <br />and Perfluorooctane Sulfonic Acid in Drinking Water | OEHHA or at the <br />following URL: https://oehha.ca.gov/water/crnr/announcement-availability- <br />draft-technical-support-document-and-public-workshop-proposed.