Presentation to Non-NPDES Rulemaking Workgroup
What is the Source Control Small Group?
The Water Quality Standards for Human Health rulemaking is charged with not only changing the standards themselves but also proposing ways that help achieve those standards. Having POTWs work with the industries, commercial businesses and residents to control what is put down the drain is one tool to meet the standards.
Two issue papers were presented to the Rulemaking workgroup that recommended that DEQ look at the existing Pretreatment Program and similar activities. DEQ agreed that this is an area to explore and once I was hired, the opportunity arose for DEQ to staff such an effort.
On March 31, 2010, DEQ’s Pretreatment Coordinator and representatives of POTWs who are also members of ACWA, came to this group to ask to form a small group to explore and propose ideas that are “beyond the current Pretreatment Program”. Members of this group were asked to participate and other stakeholders were approached and participated at different levels. The Group named itself the Source Control Small Group to reflect looking at ideas beyond what is covered under the current pretreatment program.
The Small Group has met four times and corresponded by e-mail. The face-to-face meetings began with information sharing so that group members had a basic knowledge of the current Pretreatment requirements, “Source Control” activities that some POTWs do now, and other information on topics ranging from the population served by current pretreatment program to what are the other programs at DEQ that Source Control can coordinate with.
The Group had read the issue paper submitted previously. To open up the conversation beyond the ideas in those issue papers, a brainstorming session was conducted. That led to some refinement of the ideas and result to date is the issue paper that received for this meeting.
Overarching themes:
In looking at the Source Control ideas presented, some themes emerge. These include:
1. The importance of the POTW to have the legal authority to control discharges
2. Sharing information between POTWs creates more efficient programs
3. Coordinating with other entities is important in order for the POTW to be effective and reach the desired audiences.
4. Smaller POTWs will likely need the most support implementing any source control ideas
Some ideas would lead to rule making others are recommendations for projects or referrals to other entities. The Source Control Small Group’s recommendations could be done, we feel, without impacting the process of this Water Quality Standards Rulemaking. The recommendations could be passed from this larger workgroup to the EQC for action.
The Source Control Small Group itself has differing opinions on whether the rule proposals can be moved forward without impacting the schedule of this rulemaking. It would be useful at this time to know if the larger workgroup would support a proposal from the Source Control Small Group, if group members agree, to ask that the rule proposals be pursued on their own, as separate initiative.
As you noticed, the paper is not yet complete. We have two more meeting scheduled between now and The August meeting of this group during which we will finalize the paper.
As DEQ staff to the Source Control Small Group, I need to know what you here in the larger group would need from us in our Issue Paper to form your rule package. Do you have questions for us about the paper now? Is there further analysis of the ideas that needs to be included? Are you open to moving recommendations to DEQ and other entities forward?
Finally, if the Source Control Small Group decides to put forward ideas that require rulemaking, is there an option to put those forward on their own timeline, not directly tied to this rulemaking?
Thank you.