Basic Standards Implementation Work Group


Meeting Summary
August 30, 2000

The work group reviewed each of the major changes to the Basic Standards and Methodologies for Surface Water adopted by the Water Quality Control Commission as a result of the July rulemaking hearing, to identify implementation actions needed for each. The following is a summary of the work group's conclusions:

1. The new site-specific narrative standards provisions and temporary modification provisions will be implemented in individual basin water quality standards as appropriate. No other implementation steps are needed at this time.
   
   
2. The new provisions regarding secondary drinking water-based standards (for manganese, iron, and sulfate) and the revised organic chemical standards require revisions in the water quality standards for individual segments in each of the basins. For the organic chemical standards, this is a matter of specifying class 2 aquatic life segments for which the "water + fish" or "fish ingestion" standards will apply. The work group recommends that these provisions be implemented into individual basin standards during the normal triennial review process, unless site-specific circumstances create a need to address a particular situation earlier than that (e.g. due to permit issuance or TMDL issues).
   
   
3. The revisions to the metals table values need to be implemented by revising the corresponding tables that specify "table value standards" in each of the individual basins. This change will be addressed for the South Platte Basin in the November, 2000 rulemaking hearing and for the Lower Colorado, Gunnison, San Juan and Dolores Basins in the March, 2001 rulemaking hearing. Since this change does not require segment-by-segment revisions, the work group recommends that it be implemented in the remaining basins (Arkansas, Rio Grande, and Upper Colorado) in a May, 2001 written comment rulemaking proceeding, so that the updated table value standards will then be in place in all basins.
   
   
4. The revised antidegradation provisions regarding significance tests do not require any revisions to individual basin standards. However, there is a need to finalize new guidance regarding the implementation of these provisions, for the benefit of permit writers, the regulated community, and the public. The Division's goal is to finalize this guidance by the December 22, 2000 effective date of the new Basic Standards provisions. The Division will attempt to circulate a new draft of the guidance by October 2. A work group meeting to discuss this new draft is scheduled for October 17, 2000 at 1:30 p.m. in the Board Room at CDPHE.
   
   
5. The revised recreation classification provisions (establishing class 1a and class 1b, in addition to class 2) will need to be implemented by revising current recreation classifications in each river basin as appropriate. The work group recommends that this generally occur in the normal triennial review process, unless earlier action becomes necessary, e.g. due to EPA actions regarding previous site-specific water quality standards disapprovals. Therefore, implementation will be addressed first in the November, 2000 South Platte rulemaking hearing. There is also a need to develop a new recreation use attainability analysis work sheet/guidance document to assist in implementation of the new provisions. This guidance needs to address: (1) what factual showing is needed to warrant a class 1b classification; (2) what information is needed for a use attainability analysis to warrant a class 2 classification; and (3) how to address the attainability of numerical standards, even if a class 1 use exists. Because the issues that will be addressed in the guidance will also affect the Division's proposals for the upcoming South Platte hearing, a work group meeting for the Division to explain its approach in the South Platte proposal and prehearing statement is scheduled for October 4, 2000, at 1:30 p.m. in the Board Room at CDPHE. This will assist persons interested in this issue in providing input for the South Platte rulemaking. The work group will then reconvene after the South Platte hearing, to work with the Division on the development of the actual work sheet/guidance documents.
   
   
6. This work group anticipates that the mixing zones work group will address any implementation issues remaining regarding those provisions after the Commission has taken final action on those issues. Persons attending August 30 meeting: Paul Frohardt, Dave DuBois, Lois Rellergert, Jill McConaughy, Tad Foster, Jerry Raisch, Cathy Shugarts, Sarah Johnson, Robert Ray, Barbara Biggs, and Tony Trumbly.