DEQ-CFW_00024082

From: Godna4]eaica [/O=EXCHANGELA8S/OU=EXCHANG[ADMINISTRATIVE GROUP
(FYD|BOHF2]SPDLT)/CN=REOP|ENTS/CN=754D9266F43445529EF389242OAA44E1-JCGODR[AU]
Sent: 8/4/20I78:28:47PM
To: Zimmerman, Jay [/h=[xchangeLabs/ou=ExchangeAdministrative Group
(FYD|8OHFZ33PDO)/cn=Redpient$cn=56]d8I453bd54ebf8587IIa7b]1d6cdf-sjzimmerman];Cu|pepper,Linda
[/o=ExchangeLabs/ou=ExchangeAdministrative Group
(FYD|8OHFZ33PDO)/cn=Redpient$cn=73d475cbae3Z4a29687eI7IIdc9a79c5'|mcu|pepper]
Subject: Analysis onunregulated contaminant regulation
Attachments Analysis for NCstandard settinXdocx
Sheila asked me for analysis related to setting standards for unregulated contaminants. | gave her aquick bullet list to
meet an immediate deadline, and now have a more thoughtful analysis for her. | think this will also help you infuture
discussions.
The analysis demonstrates the complexity of the issue and the large number of capabilities that would need to be
developed and decisions made. |amsure there are additional issues that would beidentified ifxvewere to
proceed. But we need to move forward with eyes wide open.
The key take away ideas to me are that:
1) We have the authority in current statute to set state specific -standards.
Z) Time is needed to do thorough analysis of what staffing levels and expertise would be needed if the decision is
made tomove forward.
3) This would be a HUGE deal and the resource needs and new staff capabilities would bevery significant.
4) The current water standard setting process on the clean water side is not a model that can be used, because its
values are analogous tothe K4[LGoals, not the M[Lsthemselves. |twould beunlike anything DVVRhas done.
5) The further along in the EPA standard -setting process we can wait, the less burden there will be on DVVR, but
there will still be tremendous burden, as the technical and economic work is usually last and would fall to us.
6) If the requirement is given without sufficient resources to implement, then no regulations will be adopted and
all xvewill have isstate staff doing rule -making and litigation. That isawaste oftime and resources, and will
lead to even greater staff retention problems. department. It would be a disaster.
I think this is an important educational document that I hope will inform policy -makers about the complexity of the
issues we would need to take on.
I'd like to send to Sheila on Monday, but wanted to get it to your first so you can read it first and share any concerns or
ask questions. |twould even begreat ifyou wanted toforward htoher yourself. Let meknow ifyou want metowait
an extra day or two, but given the pace that this issue seems to be on, I'm afraid to wait too long.
Chief, Public Water Supply Section
Division of Water Resources
9197079078 office
0197079100 moinnumbor

1634 Mail Service Center
Raleigh NC 27699-1634
512 U S-?lisbiLLy�,..qleijWmjJC 27604
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DEQ-CFW-00024083