Public Comments Toxic Contaminants StrategyPolicy and Prevention

• 7 commenters • 60+ comments• Coded High, Medium, Low for level of effort

required to resolve

• Draft final strategies due 5/22 for MB review

Issues in Public Comments for Policy/Prevention Strategy• Additional contaminants• PMPs only when WLA exceeded• PCB WLAs in wastewater permits – WQBELs only• More data/Emphasis placed on 1668 –

adequate/more needed, how to fill any gaps (as done by DRBC), legal context for 1668• Suggestion that biosolids may be a source• Clarify the purpose of the site cleanup risk criteria

action

Main Issues in Public Comments for Policy/Prevention Strategy• Improvements to TMDLs• Feds should undertake voluntary phase-out• How do different WQSs impact progress

Additional ContaminantsSeveral commenters, numerous other contaminants mentioned, strategy inadequate addressing only PCBs

Proposed Response• Strengthen the language in both strategies stating that the intention

is to move to other contaminants• Add table to P&P describing example controls• TCW will prioritize other groups based on existing efforts and

available science over next 2 years• Mercury is the highest priority. Team will be formed to write a P&P

strategy.

* Need to build additional capacity to address Hg and other contaminant groups

PMPs only when WLA exceeded

PCB WLAs in wastewater permits – non numeric WQBELs only

Clarity needed on references to wastewater permits

Proposed Response• Review references to “enforceable” for accuracy• Ensure there is no confusion over numeric/non-

numeric standards

More data needed/emphasis placed on 1668 – adequate or more data needed?, how to fill any source gaps (as done by DRBC), legal context for 1668

Proposed Response• Explain that having the right data is essential but

there are limitations due to lack of promulgation• Planned activity is to determine where it is being

used now, where does it need to be used and how can we help to increase use where needed

Suggestion that biosolids and stormwater solids are sources

Proposed Response• Be sure that the words are not presuming biosolids

and sediment from BMPs are a source• Focus on the activity as a literature review followed

by a decision as to whether more information is needed

Clarify the purpose of the assessment of site cleanup risk criteria

Proposed Response• Refine the language to be sure the need and

purpose are better described

Improvements to TMDLs

How will monitoring, PMP guidance, research on methods for track-down studies, new atmospheric data be used to improve TMDLs?

Proposed Response• Look for places to mention how these individual

activities will be used to strengthen TMDLs

Feds should undertake voluntary phase-out

Leadership opportunity for federal government

Proposed Response• Discussions have started with the Federal Office

Directors• Need language on gathering needed information

leading to a decision

How does having different WQSs impact progress?

Mentioned as a factor influencing outcome achievement but little mention in planned activities

Response• Strategy lists action to compile jurisdiction WQSs

and advisory limits• Could add step to assess any limitations or road

blocks that result from different values