1. 



4. 



5. 



6. 



7. 



Table 4.8. CCMP Action Plan Outline for Controlling Metals: 

 Copper, Nickel, Lead 



State the problem, identifying the probable causes and sources. (The 

 matrix was used to help select the problem.) 



• Elevated levels of copper (Cu), nicl<el (Ni), and lead (Pb). 



• Environmental indicator-quahog tissue. 



• Cu levels are believed to be from background, plumbing, and 

 point sources; Ni from electroplating, POTW, and two tributaries; 

 Pb from CSOs, URO, POTWs, and perhaps atmospheric deposition 



State the program goals related to the problem, source, or cause. 



• To reduce levels enough to meet public health-based standards. 

 Set specific objectives to obtain the goals. 



• To eliminate CSOs. 



• To tighten the pretreatment program. 



• To set load reductions (such as by 70% by 1995). 



Determine the universe of management strategies, both new and ex- 

 isting, to consider. 



(The following list might represent the result of brainstorming exer- 

 cises with committees. It includes existing programs and new initia- 

 tives.) 



• 304(1) program (toxics control strategy) 



• hazardous waste disposal program 



• national CSO strategy 



• regional/local CSO strategy 



• stormwater management regulations 



• legislated load strategy 



• tax on dischargers 



• pretreatment program enforcement 



• tax on leaded gas 



• low-cost loans for upgrading factories 



Select the activity that will work, that the public will support, and that 

 can be implemented within reasonable time and resources. 

 (The following are selected as part of a major public participation ef- 

 fort.) 



• Enforce existing pretreatment permits. 



• Create a CSO permit program. 



• Legislate a surtax on leaded gas. 



Establish specific action plans needed to abate and control the prob- 

 lem or protect the resource. Each action plan addresses: 

 WHO: Identify who will act, pay, and enforce; spell out roles and 

 resource commitments for each participating agency, institution, 

 and enterprise. 



• Environmental regulatory agency with oversight authority for 

 POTWs CSOs. 



• State legislature (Agency would draft model law, working with oil 

 industry and station operators; or, petition to referendum): Tax on 

 gas. 



WHAT: Describe what will be done. For example, specify numeri- 

 cally-based load reductions and use-designations in this location; 

 describe what specific activities are necessary to reach them, includ- 

 ing random monitoring and spot checking on effluents. 



• Develop a schedule and monitor compliance with pretreatment: 

 CSOs. 



• Pass law: Tax on gas. 



WHERE: Describe the location this action will affect. 



WHEN: Include schedules. 



HOW: Outline the procedure used to perform this activity. 



HOW MUCH: Cost-out the action and from where the funding could 



realistically come. 



• Develop estimates, such as $5 million over five years, using costs 

 above and beyond normal compliance and oversight costs. 



Implement and monitor results. 



• Implementation would be ensured by signed agreements between 

 the RA and the Governor. 



• Monitoring would include streams as well as larger receiving 

 waters. 



Report on progress, costs and results. 

 Review, re-evaluate, and redirect as needed. 



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