Evaluate Your Management System for CAS
Goals and objectives behind assessing and improving the management system for Contract Assurance Services (CAS) to enhance operations, accountability, and relationships with contractors. Focus areas include components impacted by CAS, oversight discussions, contractor interaction, and high-level contractor work.
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Presentation Transcript
Public Comments Toxic Contaminants Strategy Policy 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 Contaminants Several 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
