Work Plan For Work Group Meetings

WHAT

ADDITIONAL RWG/Non-NPDES DISCUSSION?

RESOLUTION/REMAINING QUESTIONS

TASKS

DUE DATE

RWG ITEMS

Agenda

No

-Draft agenda for Oct. meeting --Send out for 3 govt. review

-9/20 (Donna?)

HHC Schedule

No

-Jane completed the issue paper and was included in the NPDES doc that went out to workgroups—does permitting need to review it?

-Finalize Issue Paper

Variances

No

-Update Issue Paper based on incorporating pollutant reduction plans. The implementation section also needs some updating, unless we include specifics for the IMD

-New source def still needs to be added to reg language

-Respond to comments

- 9/20 (Andrea)

-9/20 (Spencer)

-9/20? (Andrea)

Delayed Implementation of Criteria

No

-Analyze whether or not using a higher risk level in the short term would address compliance issues.

-Finalize section in issue paper by updating RWG discussion section

and analyze 10-5 risk level using 17.5 vs. 175 and fold into the issue paper. Regardless of result, 1) Most likely, there will still be compliance issues, 2) won’t address EPA’s disapproval, 3) would deviate from EQC’s 10-6 risk policy

-9/20 (Andrea)

Background Pollutant Allowance

No

-Need to provide a justification that a 3% increase in concentration is protective of human health. How is this different than the 0.3 increase in temp?

- Rapid and complete mixing question

- Update issue paper

-Calculation scenarios needed?

-9/20 (Deb)

-9/20 (Spencer?)

Human Health Criteria Table

No

-IRT and permit writer review: send both table and issue paper together

- meHg RSC issue needs to be resolved

-Matt S. checking on other questions

-draft final criteria table for review

-Draft section in Issue Paper including FCR info, criteria withdrawn and other actions from EPA’s disapproval

-Finalize issue paper and table

-9/20 (Andrea)

-9/20 (Andrea)

-10/27 (Andrea)

Separate Rulemaking for As, Fe, Mn

No

(Refer to Deb’s timetable)

NPDES Issue Paper

Sections I, II, III

No

-Draft section I, II

-early Oct. (Andrea w/ assistance from Deb)

Antidegradation

No

-finalize issue paper

-draft NPS antideg section in IMD

-XX/XX (Deb)

-XX/XX (Deb)

Other Items

Fiscal Impact Statement

Yes-Oct

- Receive fiscal info from stakeholders 9/10

-Need to involve Jim Roys and others

- Draft final fiscal form

-Conduct comparative analysis

-Draft final for review

-9/20 (Andrea + Koto)

-10/12? (Andrea + Koto)

Other Rulemaking Documents

No

-Land Use Evaluation Statement

-Relationship to Federal Requirements Questions

-Rulemaking Announcement for Notice Package

-Rule Implementation Plan Checklist and Implementation Plan

-Strikeout Rule Revisions

-Other Supporting Documents (Issue Papers, etc.)

-Complete draft docs

-Submit draft docs w/ rule package

-Finalize docs (after internal review) for SOS submission

-10/20 (Andrea + others)

-10/27 (Andrea)

-12/8 (Andrea + others)

Communication Plan

No

-Need to determine our legislative connections

-Draft plan

-done (Andrea)