Field Office Compliance - Assistance

Assistance ID - 102097

Des Moines Water Works - 310338211

9966 Maffitt Lake Dr Cumming, IA 50061

Dallas County

FO 5

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Attached Files/Reports

File Name	File Type	File Date	Note

Comments

Date	Comment	Commenter
8/1/2018	McCurnin, Mike 9:16 AM (1 minute ago) to me Thank you…….we look forward to discussions on the 15th of August……	JANET GASTINEAU
8/1/2018	Janet Gastineau <[email protected]> 9:12 AM (1 minute ago) to mccurnin I spoke with Taroon in engineering this morning and we agree the control limits for integrity testing can be adjusted in the next permit. For now keeping the LRV above 3.5 will be acceptable without a violation. Discussion of what the LRV looks like in the next permit can be discussed at the August 15th meeting.	JANET GASTINEAU
8/1/2018	On Tue, Jul 31, 2018 at 1:16 PM McCurnin, Mike <[email protected]> wrote: Janet: We are just getting very close again to dropping below 4.0 (we have hovered here before) and this is forcing some additional isolations and repairs. The future discussions w/DNR on this issue will certainly help us budget properly. Another option in the interim might be to bump up our log inactivation in the clearwell to offset values slightly below 4.0 should they arise……….would that resonate in the interim? Appreciate the discussions here.	JANET GASTINEAU
8/1/2018	On Tue, Jul 31, 2018 at 12:50 PM McCurnin, Mike <[email protected]> wrote: Yes, this would be for the MOR direct integrity testing. In our view(and what we communicated years ago) to get permission to lower the threshold to 2.5 was that with some values below 4 the plant still meets 2-log, 3-log, and 4-log treatment requirements for crypto, Giardia, and virus removal/inactivation. What treatment requirement are we failing to meet? We believe Giardia req to be the limiting variable.......An example would be LRV of 3.7.......the Giardia removal for the plant would be 4.2 with a 0.5 log obtained via CT in clearwell. Well above the 3-log requirement. Does this alter your thoughts?	JANET GASTINEAU
8/1/2018	On Jul 31, 2018, at 12:18 PM, Janet Gastineau <[email protected]> wrote: Would this be your direct integrity test result normally reported on the MOR as your LRV? If so, yes it's a violation unless the membrane automatically shut down or you failed to notify the field office within 24 hours. If it remained in service, it would be a violation. Probably a treatment technique violation with a tier 2 public notice requirement--no later than 30 days after the system learns of the violation ( 567 IAC 42.1(3)"b").	JANET GASTINEAU
8/1/2018	Janet: Thank you for the response here. The week of the 13th will be fine. Hopefully we can find some dates that work. Before then, I’m wondering if it is possible for you or others to comment on the consequences of an MIT that is below 4.0? Is there any type of PN or violation? For the sake of this on-line discussion, assume values between 3.5 and 4.0.	JANET GASTINEAU

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