Montgomery County: Confusion caused EPA problems

KeepHealthCare.ORG – Montgomery County: Confusion caused EPA problems

For the second time in a month, Montgomery County notified water customers of concerns raised about the testing of drinking water, most recently about Ohio Environmental Protection Agency (EPA) rules violations.

About 80,000 water customers received postcards from Montgomery County Environmental Services admitting it didn’t correctly test for pH between January 2017 and December 2017. It happened, according to the county, because the rules Ohio EPA enforced in May became confusing over the years.

“The testing parameters were not clearly understood by our staff and neither were the frequency of testing and how you were supposed to test,” said Brianna Wooten, Montgomery County Environmental Services spokeswoman.

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Wooten said some of the details of a 20-year-old letter between the Montgomery County and Ohio EPA agreeing to standards had been lost to time, leading to the enforcement action.

“There were some historical legacy items perhaps, that didn’t get passed down in the organization,” Wooten said. “Nobody knew about it, and the EPA decided to look at it … We were not aware of it, and they had never regulated for this in the past.”

Specifically, Ohio EPA dinged the county for not maintaining an agreed upon minimum pH level of 7.8 at certain points and then for not testing daily thereafter if found not within parameters. The county was out of compliance 70 days during the period, according to the Ohio EPA.

Wooten said the system — which supplies drinking water to about 250,000 residents — was routinely tested for pH during the time in question — just not in the manner mandated by Ohio EPA.

According to the Ohio EPA, Montgomery County was given a minimum pH level in 1998 as the result of a corrosion study in the drinking water system. Recently, the county asked Ohio EPA to reduce sampling for lead and copper to every three years from once a year. As a result of the request, Ohio EPA learned the county had failed to meet minimum pH monitoring results and was not monitoring once every two weeks as required.

On May 23, Ohio EPA issued the violations.

The county ended up spending $20,208 on the postcard to about 80,000 customers. It could have been less expensive tucked into quarterly bills, but the Ohio EPA required the notice go out within 30 days.


Water’s acidity or alkalinity is a secondary indicator of its quality. Low pH can lead to leaching of lead and copper from water pipes, according to the Ohio EPA.

“It is important to note, however, that lead and copper monitoring results have been well below safe drinking water action levels,” said Ohio EPA spokeswoman Dina Pierce.

One violation is for failing to properly monitor for pH at points Dayton water enters the county system.

Part of the disconnect is that Montgomery County operates a distribution system that purchases water from the city of Dayton, Wooten said. The permitting process for a water plant is more detailed and the rules more refined, Wooten said.

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Public water systems serving 50,000 or more people must complete corrosiveness studies and are then given a pH limit by Ohio EPA. The 7.8 limit for Montgomery County and an 8.2 threshold for Dayton are part of lead and copper regulations based on the chemistry specific to their systems and designed to inhibit pipe corrosion, Pierce said.

“The county has addressed the issue and has maintained good pH levels from January through May of this year,” Pierce said.

Earlier in June, both Montgomery County and the city of Dayton notified customers of a potentially dangerous compound first detected in water bound for customers through tests in March. Further testing in April and May show “PFAS” (Per- and Polyfluoroalkyl Substances) in treated water remained between 7 and 12.5 parts per trillion.

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PFAS are in a substance once used as a firefighting foam at Wright-Patterson Air Force Base and at the Dayton Fire Training Center, 200 McFadden Ave. The chemical has infiltrated groundwater and prompted the shutdown of multiple Dayton water wells – also the source of water for Montgomery County customers — as a precaution.

PFAS are currently believed to be safe when below 70 ppt for lifetime exposure, however, a new draft study indicates health risks might be expected at lower levels.

The county spent $32,640 to notify customers by letter after the detection of PFAS in the water supplied by Dayton.


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