Monica Leslie added comment Additional comment from Rick Sakaji to the document Combined 60i56r1 ballot & JC memo.pdf in the Joint Committee on DWA - Treatment Chemicals group. Subject : Additional comment from Rick Sakaji Category : N/A Comment M. Leslie forwarded the following comment on behalf of R. Sakaji: I would like to thank Dr. Cotruvo for his comments and the additional information he provided. They will contribute to a more complete discussion on this issue. Prior to this ballot I had a conversation with Dr. Cotruvo discussing some of these same points. I was unable to get a full understanding of the conditions under which much of the 97-98 ICR data had been collected. Information on the strength of the hypochlorite solutions used at the water utilities was not collected (I don?t recall hypochlorite solutions of greater than 12% being readily available in the late 90?s. I recall the 15% strength solutions becoming available only in the early 2000?s.). We also don?t know the dosing and residual levels, which may change due to newer water quality regulations that have come into effect since then. This data was collected three years prior to 9/11 and much of the emergency response preparation and requirements that have been implemented since then. While it might be true that some water quality regulations might be waived in event of a disaster, day-to-day operations must occur within regulatory limits. The SPAC and the MUL limits for the hypochlorite solutions allow a situation to occur that could result in a California water utility having to issue a notice. So while it may true that no one has issued a notice in California (I don?t doubt the word of the former senior health official), the issue is that the standard sets up a situation that could have an adverse impact on a water utility. Yes, the water utilities are responsible for the proper handling and storage of the chemicals they use (they should be following the AWWA standards), but raising the SPAC will put them at a disadvantage for chlorate control from the minute they receive the chemical. With chlorate on the UCMR3 list we will have more information on finished water chlorate concentrations and will have a better idea of how day-to-day plant operations will be affected once the monitoring has been conducted and the data collected and summarized by EPA. Until then, my negative vote remains in favor of the 0.2 mg/L SPAC passed at the last Advisory Committee meeting. Proposal No proposal provided. Comment Number : #03737 Submitter : Monica Leslie Date submitted : 2012-05-25 17:48:18 Status : new View Comment Details View Document Details Download Document