From: Gerald Fisher
Sent: Wed Jan 09 15:15:16 2019
To: Ryan Hepler
Cc: Andy Peters
Subject: RE: Preliminary Draft permanent Cyanotoxin monitoring rules
Importance: Normal
OK. If we are not required to sample then we should not unless there is a good reason to do so. This is likely the knee jerk reaction that was originally taken has now been refined to address those water providers who have an actual risk for cyanotoxins. Go ahead and continue to perform normal testing as required by OHA. I have money in the budget for next year just in case they do a 180 and require us and other jurisdictions to do the added testing.
Regards,
Gerald Fisher, P.E. | Public Works Director
City of Molalla
117 N Molalla Ave. | PO Box 248 |Molalla, OR 97038
Office: 503.829.6855 | Direct: 503.759.0218
CONFIDENTIALITY NOTICE: The information contained in this email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient and have received this communication in error, please contact the sender by reply email and destroy all copies of the original message. Thank you.
From: Ryan Hepler <rhepler@cityofmolalla.com>
Sent: Wednesday, January 09, 2019 2:26 PM
To: Gerald Fisher <gfisher@cityofmolalla.com>
Cc: Andy Peters <apeters@cityofmolalla.com>
Subject: RE: Preliminary Draft permanent Cyanotoxin monitoring rules
Gerald,
Just a follow up on some of the rule changes regarding Cyanotoxins that we talked about over the summer. I contacted OHA regarding the recent rule change for Cyanotoxins and Harmful Algal Blooms (HAB's). The response from James Nusrala 971.673.0459 via a phone call was that the adopted rules only reference "Susceptible" Water Sources and that the City of Molalla is not currently under that category so we do not have to sample for Cyanotoxins at this time. I referenced an email draft that we received on 09/18/18 listing us as a "Potentially Susceptible" Water Source and he said that is not included under the new rule. If we choose to sample on our own for whatever reason he asked that we contact him or OHA because they will want to receive that data. We will be doing some sampling per the EPA UCMR4 requirement in 2020 and we will forward those results to OHA. I have attached some info relating to the public comment period if you are interested and the original draft rules. I have documented this in the work order system for future reference.
Ryan Hepler | Water Treatment Operator
City of Molalla
117 N Molalla Ave. | PO Box 248 |Molalla, OR 97038
Office: 503.829.5408 I Fax: 503.829.3676
From: Gerald Fisher <gfisher@cityofmolalla.com>
Sent: Tuesday, September 18, 2018 9:56 AM
To: Ryan Hepler <rhepler@cityofmolalla.com>
Cc: Andy Peters <apeters@cityofmolalla.com>; Ryan Quigley <rquigley@dyerpart.com>
Subject: RE: Preliminary Draft permanent Cyanotoxin monitoring rules
Yes please. For now what I will need is information about how fast the DWP wants an action plan in place or if they have a standardized one we can adopt at a local level until we tailor our own. I included Andy and Ryan Q on this so it is on their radar. Thanks.
Regards,
Gerald Fisher, P.E. | Public Works Director
City of Molalla
117 N Molalla Ave. | PO Box 248 |Molalla, OR 97038
Office: 503.829.6855 | Direct: 503.759.0218
CONFIDENTIALITY NOTICE: The information contained in this email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient and have received this communication in error, please contact the sender by reply email and destroy all copies of the original message. Thank you.
From: Ryan Hepler
Sent: Tuesday, September 18, 2018 8:59 AM
To: Gerald Fisher <gfisher@cityofmolalla.com>
Subject: FW: Preliminary Draft permanent Cyanotoxin monitoring rules
Gerald,
I wasn’t sure if you were included on this email, but here are the proposed rule changes for Cyanotoxins. We will be working on our sampling schedule and get in touch with the lab to work out those lab details. We will also need to work on a response plan in case we exceed the action level. Is this something you would like us to include Jaimee on?
Ryan Hepler | Water Treatment Operator
City of Molalla
117 N Molalla Ave. | PO Box 248 |Molalla, OR 97038
Office: 503.829.5408 I Fax: 503.829.3676
From: Salis Karyl L <KARYL.L.SALIS@dhsoha.state.or.us>
Sent: Monday, September 17, 2018 1:27 PM
To: Salis Karyl L <KARYL.L.SALIS@dhsoha.state.or.us>
Cc: Emme David H <DAVID.H.EMME@dhsoha.state.or.us>
Subject: FW: Preliminary Draft permanent Cyanotoxin monitoring rules
As promised, here is the preliminary list of susceptible and potentially susceptible systems. We look forward to your comments on the rules and this list by 9/25. Let us know if you have any questions!
Kari
Kari Salis, PE
Technical Manager
Drinking Water Services
Oregon Health Authority
971-673-0423
From: Salis Karyl L
Sent: Friday, September 14, 2018 9:50 AM
To: Salis Karyl L <KARYL.L.SALIS@dhsoha.state.or.us>
Cc: Emme David H <DAVID.H.EMME@dhsoha.state.or.us>
Subject: Preliminary Draft permanent Cyanotoxin monitoring rules
Potentially affected systems:
As you’re aware, the Drinking Water program has been working on preparing draft cyanotoxin monitoring rules to replace the existing temporary rules which expire at the end of the calendar year. Attached for your review is our current draft of proposed permanent rules. We ask that you review this preliminary draft and provide any initial feedback to me by September 25. We will plan to revise the draft in response to comments, then present a revised proposed rules to the Drinking Water Advisory Committee at the October 17 meeting. A formal 30 day public comment period will commence on or around Nov 1, with a public hearing on Nov 27. We hope to file final rules by the end of December.
Here’s a brief overview of the key new features of the draft permanent rules:
Applicability. We attempt to define risk tiers and associated monitoring requirements by defining “Susceptible” water suppliers and “Potentially Susceptible” water suppliers. Susceptible systems include those with documented cyanotoxin detections, documented algal blooms in source water or source water on CWA 303(d) list for algae and aquatic weeds. Potentially susceptible systems have sources impaired for other CWA 303(d) list parameters. We will send a list of which systems we believe are in each category on Monday. I apologize for not having it ready today but wanted you to have as much time as feasible to review the draft rules.
Monitoring. We propose to incorporate sampling and analysis for cyanotoxin producing genes using the qPCR method, in addition to toxin monitoring using ELISA. qPCR is used by Ohio, EPA, USGS and others as a genetic screen for the presence of toxin producing cyanobacteria. It can provide an early warning of potential toxin generation in ambient and raw waters. Susceptible systems would monitor for toxins biweekly during the algal bloom season, May 1 to Oct 31. Large systems would also collect qPCR samples on alternate weeks. Monthly samples for qPCR analysis would then be collected over the winter, Nov 1 to April 30. Potentially susceptible systems would only be required to sample raw water monthly for qPCR analysis. Our intention is to integrate with DEQ’s plans for a State HAB monitoring network, so the draft allows upstream monitoring of recreational waters to substitute for the system’s requirement to monitor raw water for cyanotoxin producing genes, i.e. if DEQ or another entity is monitoring source water upstream the system doesn’t need to sample raw water, if approved by OHA.
Lab Methods. Specifies EPA Method 546 (ELISA) for microcystins. DEQ ELISA method is specified for cylindrospermopsin, but if there are detections >0.3 ug/L additional samples are analyzed using EPA Method 545 (LC MS/MS). Analysis for cyanotoxin producing genes is by qPCR per DEQ Method.
DEQ has indicated they anticipate sufficient budget for cyanotoxin lab capability through next June. Beyond that, it is dependent on the Legislative/Budget process. They also anticipate they will be able to offer qPCR analytical services, in addition to toxin analyses. Please let me know if you have questions.
Kari Salis, PE
Technical Manager
Drinking Water Services
Oregon Health Authority
971-673-0423
Oregon Drinking Water Services