Kirk Leifheit

Assistant Chief - Division of Drinking & Ground Waters at Ohio EPA / EPA

6

Emails

Dec 2010–Jan 2011

Archive range

6 emails found.

RE: FInal draft DW Administrators letter to EPA

Jerry, Thanks again for pulling this final together. Indiana is OK with sending this version. | have one suggestion for the last paragraph: should we put in a contact in case EPA wants clarification of one or more of our points? Since | bought it up, PH volunteer to be a contact and would work with all of you to answer any question EPA may have. I’m aiso open on this and will go along with what we all decide on a inserting a contact. i'm OK either way on letterhead: blank or the collective logos. Pll send our logo if we decide to go that way. i'd vote for some sort of electronic signature, but will go along with what the group decides. As soon as we ail approve of the final, we should give it to Region § My signature block is: Patrick Carroll, Chief Drinking Water Branch Office of Water Quality indiana Department of Environmental Management Pat

RE: Final draft DW Administrators letter to EPA

Gerry, Please use Liane Shekter-Smith for the signature for Michigan on this letter. As the Chief of the Environmental Resource Management Division of MDNRE (io be MDEQ again in about 60 days), Liane is the State Drinking Water Administrator. We can provide a signature block for Liane and the state logo electronically and we prefer these options. If you decide to go this route, let me know and | will see that we get them to you. i don’t have a problem with sending an advance copy to Region 5 but defer to what the majority decides. ii has also been suggested ihat we consider placing the more technical elements of our comments in an attachment to a submittal fetter, but again, | defer to the majority or even to the state completing this document. Thanks for al your work. Richard Benzie

Final draft DW Administrators letter to EPA

Importance: High Good morning all Attached is the final draft (yeah and a toss of confetti). The letter still needs formatting and that task has been given to our support staff. The track change is still on in case there are still changes to be made. Can everyone please send me their signature block. if you have already done so can you please resend as a couple of my archive email files were lost and | have someone trying to recover therm. {ft will be faster if you resend the signature block. Do we want the letter to go out with out a letterhead? One option would be to paste the logo from each state at the top of the letter. Do the directors want to route the letter for signature or use electronic signatures? Are we okay to send an advance copy of the letter to Region 5? Thanks xxxEND_PAGE:deq26_b020_0323_0326_1 Jerry

RE: Recap REduxp

FH AIL, Yes, we are okay with dropping the 2nd sentence in #2 es suggested by Beth. Locking forward to seeing ihe final draft. Happy 2044 everyone. Jt Jill D. Jonas, Director Bureau of Drinking Water and Groundwater Wisconsin Department of Natural Resources 101 South Webster, PO Box 7921 Madison, WI 53707-7921 phone: (608) 267-7545 fax: (608) 267-7650 jill jonas@wisconsin. gov

RE: Recap REduxp

Happy New everyone [have changed the leiter io incorporate Beth’s comment in paragraph 3. Regarding the Section 2 comment, | need to defer to JiH and Lee as this was language from their December 15 and 16 email attachments. | am good with dropping from the second bullet “What is needed Is a compliance response path for total coliform positives that focuses on GVWR responses for the initial confirmed total coliform positive and nas an escalated response for additional confirmed total coliform positive results” Jill/Lee are you okay with dropping this sentence? If not can you please address Beth/Mike’s questions. | suggest keeping “state actions” in the first bullet under Section 2. | had not thought about this until Jil sent me her electronic signature, | am wondering do all the drinking water administrators want to sign the letter electronically or route the letter and sign? if there are no further comments | will send the final draft to everyone Wednesday for one last review and okay. Thanks xxxEND_PAGE:deq26_b020_0323_0326_2 derry

RE: Recap - MI Comments

Hey All, Mike is out this week, but | got his input on this via email and I've combined our comments. The comments are tracked in the attached. The first comment in paragraph 3 is pretty straightforward. The other comments are in Section #2. We weren't sure what it was trying to say. | think if you remove the sentences, it still gets the point across. Also in the first bullet under #2, we don't think it needs to refer to state actions again since it's in the above paragraph. Mike would like to see the final version before sign off. Thanks, Beth >>> "Overmyer, Rich (DNRE)" <[email protected]> 12/27/2010 3:26 PM >>> All, Yes, thanks to everyone for their work on this especially Jerry & Beth. Pat's last draft to Mikes revision looks good. Just note we should be consistent in the "1000 or less" population cutoff (eliminate the "less than 1000"). Also the 3rd bullet under item 4 should be: Maintain baseline monitoring as quarterly for all groundwater systems serving 1000 or less. (Not all pws). 1. Is this a draft that we can now share with the Region? YES 2. Is this proposal all or nothing? What happens if US EPA is okay with the simplified monitoring process but does not consider dropping the monitoring and reporting from clean compliance history? NO, NOT ALL OR NOTHING BEING ABLE TO KEEP OUR FIND & FIX PROCESS IS VERY IMPORTANT. HOWEVER, MI ESTIMATES A 60-70% VIOLATION RATE IF MONTHLY MONITORING STAYS IN AS PROPOSED. | SUSPECT THAT WOULD MEAN MASS REFERRALS TO EPA FOR ENFORCEMENT OF MOST M&R VIOLATIONS. . By using “significant deficiency” as part of reduced monitoring are we saying it is not necessary to define “sanitary defect’? WE DON'T NEED ANOTHER DEFINITION. cay 4. Is it okay to drop the following in #2? “Failure to follow Ground Water Rule would trigger a RTCR Level 1 Assessment. A second Level 1 trigger within a rolling 12-month period would trigger Level 1 Assessment and a xxxEND_PAGE:deq26_b020_0323_0326_3 third Level1 trigger would require a Level 2 assessment’ If not, | need clarification of what is meant by failure to follow GWR? MIKES VERSION WORKS. 5. Do we need to provide comments or proposed definition of season system, clean compliance history, sanitary defect? NO, NOT AT THIS STAGE. LET'S NOT MAKE THIS OVERLY DETAILED. 6. Is it possible to open up the reduced monitoring to NTNCWS as well as TNCWS? The reason | ask is based on my conversation last week with Miguel. In this case we may be able to get a little more. It is still possible that through the rule negotiations that we may need settle for only transient noncommunity systems. Miguel just needs to know our initial and fall back positions. MI HAS ALMOST 1500 NT'S BUT IT IS DIFFICULT FOR US TO ARGUE VERY CONVINCINGLY TO JUSTIFY ANNUAL COLIFORM MONITORING FOR THEM. WE UNDERSTAND IT'S A LITTLE DIFFERENT FOR MN'S PROGRAM THAT IS SET UP BASED ON ANNUAL SITE VISITS & MONITORING FOR THE SYSTEMS. OUR TAKE ON THIS IS MONTHLY MONITORING IS NOT AN EFFICIENT USE OF SCARCE PUBLIC HEALTH RESOURCES. IF WE NEED TO CONCEDE ANNUAL MONITORING FOR NT'S TO MAKE MONTHLY FOR EVERYONE GO AWAY, WE SHOULD. PUTTING IT ON THE TABLE NOW AND BEING FIRM ON IT WOULD BE MI'S VOTE. Happy New Year! Rich Ohio Environmental Protection Agency Unless otherwise provided by law, this communication and any response to it constitutes a public record. xxxEND_PAGE:deq26_b020_0323_0326_4