Follow Ups from May 20 Meeting

RWG Discussion

1. Variances

•  Neil: Differences between ALC and HHC -- implications for application need to be reflected in the rule.

•  Neil: search and replace the word “variance” with PMP/Pollution Prevention Plan as a possible solution to the stigma of the word

•  Variance Duration:

◦  Peter said that if a permit is administratively extended, that DEQ can’t legally re-open the permit (I think this had something to do that if during an annual review we found that we needed to adjust something)

◦  Neil: Permits w/ variances would float to the top of the priority list w/in a year of expiration

•  Existing Use

◦  Need to fully define the meaning of existing use—no further degradation and what is DEQ’s “standard of review”?

◦  Ken: Need to clarify capacity of trading w/in watershed to help with this

•  NPS BMPs—Ken: Add language regarding the possibility of using trading (not a requirement because of issues w/ contractual obligations, per Kathryn)

•  Address in the Decision Memo OR’s use of GLI

•  New Facilities

◦  Nina/Peter: Strong objection to “net environmental benefit”. Too open to abuse and misinterpretation

◦  Define what a new facility is—new facility covered by an existing permit, new discharger??

◦  Kathryn/Ken—DEQ should consider other types of industry that could bring business to OR

* RWG members need to send comments/revisions to Andrea by June 3.

2. Pollution Prevention Proposal

•  More rationale is needed from DEQ, EPA, and ACWA before the proposal is brought before the group again in July (will need to meet/discuss beforehand)

•  How does RPA fit the “occasional hit”/Tier I scenario (EPA, DEQ)

3. June/July Meeting

•  Variances (last discussion)

•  De Minimus (last discussion)

•  Status of Tools Matrix

•  Pollution Prevention Plan

•  Delayed Implementation

Non-NPDES Discussion

Sorry folks, but didn’t catch any more specifics than this…

1. ODF/ODA Interactions

•  Follow up Items?

2. Antidegradation

•  Work group members didn’t get to vote on DEQ’s proposal

•  This was the last scheduled meeting on this

3. Implementation-Ready TMDLs

•  Get any comments to proposal to Gene by June 3

4. Division 41

•  Get comments to proposal to Gene by June 3

5. June/July Meeting

•  Pretreatment sub-committee

•  Sediment and toxics

•  Implementation-Ready TMDLs

Developing Agendas—Who, What, When, Where (were we going to propose an alternate location at some point?)