Public comment submitted to www.regulations.gov

Comment Info: =================
General Comment:The estimates for the amount of time it takes a wastewater
facility to do DMRQA
is understated, in my opinion. At our plant, operators ARE the lab staff, we
don't
have a chemist that does our work.
Specifically:
The packet takes my boss about 30 minutes to read- for me, 30-45 minutes
Planning for the study, because I have to work the extra lab samples with
evrything else I do at the plant, takes me a couple of hours, especially when I
have
to track down the samples from a provider, get cost estimates and deal with our
municipal purchasing rules.
It takes me more than 2 hours to run the samples- all I do is BOD, ammonia,
phosphorus, TSS and chlorine. Residual chorine is always so high so it takes
lots
of dilutions, best guess is a half-day, if not more.
We dont have clerical staff- our clerk makes copies and does the filing, I do
all the
forms and stuff like that, and it takes more than 12 minutes- more like an hour
to
get it together and ready to send out.
I also keep all the lab files in the lab- if it was at the clerk's office and I
had an
inspection I wouldn't be able to get it becuase the clerk is only part-time.
I'm not sure about your labor costs either, I don't make $56/hour including
benefits
and our clerk don't make much over $10/hr.
How come you don't include costs for samples- they cost me almost 300 bucks
every year, more like $550 if I do the qc samples with them as a check like the
providers suggest you do.
The other thing I don't like about this is having to do them on your schedule,
summer is the busiest season fur us, and the boss don't like overtime for lab
work.
Why don't we do this in the winter, when things aren't as hectic, or just let us
do
them someitem between January and October (so then you'd get the results by
the end of year)?