Comment submitted by Alex Gorbounov, North Carolina Public Water Supply Section (PWSS)

Comment on monitoring requirements: 1. Should daily measurement of chlorine residual count toward the maximum residual disinfectant level (MRDL) monitoring and be one of the criteria for reduced monitoring? - From NC experience, daily chlorine readings rarely ever approach MRDL levels of 4.0 mg/L, therefore including this measurement with MRDL requirement would be an extra compliance burden with little to none practical effect. We also do not support inclusion of daily chlorine measuremt as a criterion for reduced monitoring because chlorine is much less indicative of microbial quality than the total coliform measurement. Besides, it is unlikely to become an appealing resource-saving alternative for water systems since it requires daily versus quarterly measurements. 2. Will the reduced, routine, and increased monitoring requirements for NCWSs shift the fixed State resources from CWS oversight to NCWS oversight in those States with large numbers of NCWSs? If so, what might be done to limit the impact? For NC, it would require a tremendous shift, but if this provision is optional for states to adopt (similar to assessment monitoring under the GWR) they will have the flexibility to chose depending on their resource situation. 3.Should EPA develop guidance on how to develop a sample siting plan? Should sample siting plans require State approval? In the light of new siting requirements, new guidance would be helpful. Also, keeping the current language about siting plans approval that says that water systems must have a plan that is "subject" to state approval would make sense: the way we interpreted it was to require plans to be on site available for inspection during a site visit - it has been reasonably protective and easy to implement. Sincerely, Alex Gorbounov alex.gorbounov@ncdenr.gov (919) 715-3238