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
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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.
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