Date: Wed, 16 Apr 2008 09:02:05 -0800

From: "Toby M. Schield"

Subject: RE: complying with the EPA IDSE

To: "'Mike Keegan'" <keegan at bookcase.com>

Mike

I went back to the EPA website and tried to use their IDSE tool to refresh

my memory as to why I didn't use it. The main reason was that when I tried

to download the IDSE Tool Wizard all I would get is a logo saying "Powered

by Macromedia" That's it. I waited and waited to see if something was

downloading in the background as was just going to take time. It never

loaded after several times. Checked my firewall and virus settings and

still could not get page to download.

I had downloaded the regulation, which was about an inch thick, and began

digesting what I needed to do to comply. I spent the better part of a day

just making notes and diagrams of our system all the while concerned that I

didn't want to miss something or not compile report correctly.

At that time I remembered that SEMS had a new tool, SEMS Suite, that would

assist in completion of IDSE and help me comply with regulation. I was

hesitant at first to use the SEMS product because of the $100 a month

subscription. I made a deal with SEMS to let me try out the software for a

month for $100.00 and if I found it useful and helpful in the completion of

my IDSE and compliance requirements, I would pay for a years subscription.

When I received the SEMS Suite I found that all the effort put into earlier

Vulnerability assessment and EOP was importable to the new software.(I used

the SEMS software for both my VA and EOP 4-5 years ago) I imported the

data..about 5 minutes and found that my IDSE compliance requirements were

about 75% complete. All I had to do was enter a few water sample results

and dates of testing and was immediately sent to the 40/30 waiver. I was

done! I thought it was too easy so I went back and tricked the

software(entered TTHM and HAA5 results above the MCL)and walked through the

further data input requirements. The software then lead me with a drag and

drop tool to diagram my water system and it suggested monitoring sampling

sites. Thought it was pretty cool and thought that if I had not qualified

for the 40/30 waiver would have saved a lot of time and money to complete to

comply with regulation.

All in all if I hadn't used the SEMS software I would probably have spent a

lot of time and money generating the report and still had a pit in my gut

that I might not have crossed all the t's and dotted all the I's..

The main reason I even considered the SEMS software was because of my

experience with trying to complete my VA and EOP.

I had flown to Anchorage to attend the RAM W training to learn how to assess

vulnerabilities and assign risk priorities.

I spent the better part of a month coming up with a draft that I still

wasn't sure would meet the requirements. I had suggested to the Utility

manager that we may want to contract it out to ensure it was completed

properly and would comply with Regulation.

At that time our State DEC was offering on-site training in Nome for all

regional water systems using the SEMS software and I took advantage of it.

Two days later my VA was done and I began working on the EOP. Two days

after that I was done with my EOP.

In both cases (completing VA/EOP and IDSE) I have saved a lot of time and

money as well as worry that I might have missed something, using the SEMS

software. If you are helping other Rural water systems with compliance I'd

steer them towards SEMS. The EPA tool and Regulations are too overwhelming

to digest let alone comply with. Especially small rural systems with

limited resources, experience and education.

One last item, I had a few compliance questions and ideas for how the

software might be enhanced and found the SEMS people very helpful and

responsive. Neither EPA or Alaska DEC could help with questions. DEC

because they didn't have primacy responsibility and weren't up to speed on

it themselves. It was nice to have a live person to bounce questions off

of.

Toby Schield

NOME JOINT UTILITY SYSTEM

P.O. Box 70

Nome, Alaska 99762

-----Original Message-----

From: Mike Keegan [mailto:keegan at bookcase.com]

Sent: Tuesday, April 15, 2008 6:43 PM

Cc: Hilary Currey

Subject: complying with the EPA IDSE

Hi Toby, I am interested in your experiences with EPA's tool to complete your IDSE

(under the disinfection by-products rules). At a meeting with the state

rural water associations' staff, it was my understanding that you attempted

to use the EPA tool for compliance.

I would appreciate any comments you have on your experiences, and what you

did to finally comply with the IDSE.

Thank you for your consideration and any comments you may have.

Mike Keegan, Analyst

National Rural Water Association

Washington, DC

[t] 202-294-4785

[f] 866-385-3160

keegan at ruralwater.org

http://www.ruralwater.org