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RMW - May 2017

ROCKY MOUNTAIN WATER MAY 2017 | 19 FEATURE I had a lot of fun working with my staff. The first thing I would say to them was: “These are our customers and we treat them like our customers. Take a look at the global view and do not get caught up in the details. Know your limits as a regulator and use good judgment.” Ultimately, when I left the pretreatment division I had a staff of about four; permit writers and technical staff, performing sampling and fieldwork. The staff is larger today because the focus of their duties has changed somewhat. Pretreat-ment has expanded into such a large opportunity of working with businesses of all kinds. The bottom line is we got to know our community very, very well. Could you give an example of a successful pretreatment collaboration? We worked a lot with metal manufac-turers because Englewood and Littleton was very industrial at one time. There were hundreds of businesses we would work with; small and large, regulated or not. We would offer ideas and pass on information from EPA to help many of them reduce their water consumption, reduce the amount of hazardous waste, or make it non-hazardous. Sometimes this would help reduce the number of regulations they were required to follow. At the very beginning, I was involved in the groundwork of forming CIPCA, the Colorado Industrial Pretreatment Coordinators Association. And I would like to give a shout out to EPA: The pretreatment regulations are very well written and follow a common sense implementation for the most part. The pretreatment section of EPA in Colorado has been very supportive and really outstanding. They recognized the work we do here in Colorado and appreciate our efforts through a national awards program. What motivated you to move into the Environmental Compliance Manager position from there? I had expressed interest to move into the regulatory position and did so in 2004, when my predecessor retired. I was ready to find out more about the watersheds in Colorado and what that meant for our facility. I have to admit this became much more challenging than I had ever expected. The Colorado water rights, compacts, waters leaving the state, reuse, and the water quality regulations, make the situation in our state very complicated. What exactly made your new work so complicated? There was not enough working together between utilities and the state. I got into the field right at a time when discussions with the state became more contentious and difficult. One example is that for many years prior to this time, we had an assigned engineer from the state who came every year to do our inspections. He knew and understood our facility. He watched our expansion and understood our new process and regulations. He was very supportive and helpful. It is comparable to me understanding that each manufacturer and its process is unique. Over time, we started to have different inspectors every year. We needed to explain our process every time from scratch and there were little personal relationships from that time on. In addition to the changes described above, one of the core duties I had was to attend work groups with stakeholders and the state. One day I went to a meeting on temperature just to find out what was going on. Little did we know we would be in a contentious battle along with many other stakeholders on the temperature issue. After the regulation was finalized, L/E was then in front of the Water Quality Control Commission twice to work out a site specific standard for temperature. This is still an ongoing issue. Soon after the temperature work group ended the nutrient work group started. L/E joined the Colorado Nutrient Coalition to try to help develop the nutrient regulation. This was another difficult and long lasting work group. The regulations were finally formalized with the commission. What makes the regulatory situation in Colorado so unique? Colorado tries to get ahead of other states in developing and implement-ing the standards in part because we are a headwaters state, in part because we have some ambitious people at the state. L/E has stood on the position, along with other utilities and industries, that we need to collect more data to justify new regulations before adopting them. That is also what the Colorado Monitoring Framework Group has been emphasizing. Instead of spending money on making regulations that we cannot implement and meet, it makes more sense to come together as a whole and resolve the issues. As a Compliance Manager you obviously were involved in far more than making sure your imme-diate facility is meeting permit. I got involved in organizations such


RMW - May 2017
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