tasks for SOS submission v3.1

Action Items For Toxics Rulemaking (up to SOS submission)
WHAT	ADDITIONAL RWG DISCUSSION?	RESOLUTION	TASKS	DUE DATE
Intake Credit Rule	No	-DEQ sent e-mail 1/22/10 with final language -Need to change boilerplate language in permits to allow intake credits - Need to determine how to do the calculations in the RPA IMD	-Develop section in policy paper (for general public, EPA, and EQC) -Jane/Les need to review language before going to Larry at DOJ. Jane is checking in w/ Neil about this. We may also want someone from OCE to review. -Update IMD	-Feb. 12 (Spencer) -March 18 (Andrea) -XX/XX? (Spencer)
HHC Schedule	No	-DEQ sent e-mail 1/22/10 with final language based on existing rule language, and does not include new definition language	-Develop section in policy paper -Jane/Les need to review language before going to Larry at DOJ. Jane is checking in w/ Neil about this. We may also want someone from OCE to review.	-Feb. 12 (Deb/Andrea) -Mar 18 (Andrea)
Variance White Paper and Reg. Language	Yes	-How much detail do we want in the White Paper? About the same content, just updated to match reg. language? -Will RWG provide formal comments now or after subsequent revisions? Recommend comments after additional set of revisions… -Will need significant input from EPA on MDV and BCA -Need to look at variance approvals from states outside GLI -Discussed toxics list for current assessment w/ Robb K., but we won’t be able to get info based on 175, unless we are able to plug in numbers ourselves—Karla says he cannot spend any time on this, since he is only w/ us for another month… May need to rely on SAIC and the 2004/2006 IR toxics list which would underestimate scope.	-Revise MDV and BCA based on EPA’s input—also need to slightly revise main variance provisions. EPA will need about a week to review our revisions. -Develop remaining issues list w/ DEQ’s recommendation -Update White Paper based on updated reg language. Deb recommends folding the White Paper into the policy paper --We need to provide more detail on non-contact cooling facilities, scope of pollutants (Michael Campbell may be able to assist), and alternative analysis. Optimally, it would be best to have this done before revisions to the MDV are made, but we can do concurrently given time constraints. -Jane/Les need to review language before going to Larry at DOJ. Jane is checking in w/ Neil about this. We may also want someone from OCE to review the white paper/policy paper ahead of the eventual IMD because of the PMP component. -Donna working with variance subgroup	-Feb. 12 (Andrea) -Feb. 19 (Andrea) -March 18 (Andrea) -Feb. 12 (Spencer) -March 18 (Andrea) -Donna
Other Implementation Tools	Yes	-Based on RWG meeting 1/29/10, RWG will conference call to discuss implementation tools options and set up another face to face meeting on tools -Follow up on Ryan’s offset ideas -Follow up on Myron’s and Michael’s e-mailed comments/suggestions -Follow up on FL restoration plans (Kathryn’s idea)	-Set up conference call for 2/16/10 (DONE). RWG members send tool ideas to Andrea by 2/5/10 -Set up RWG meeting for 2/23/10 (looking into ODOT and OR state office locations—need CC #) -Respond to Ryan’s offset proposals, FL/DE restoration plans, Michael’s and Myron’s comments -Develop sections on remaining tools in policy paper	-ASAP (Andrea) -ASAP (Andrea) -Feb 19: before face to face meeting (Deb, Spencer, EPA?) -March 18 ( Deb?)
Fiscal and Economic Impact	Yes	-Need to work w/ Maggie, Adam, etc. on what is needed here -Set up another RWG and RWG+ face to face meeting to discuss—March—separate meeting from the mid-March RWG+ group? -IRT review	-Complete paperwork	-March 8 (Andrea)
Human Health Criteria Table	Yes	-Most likely RWG review can be accomplished via e-mail -Anticipate taking 3 weeks to complete given criteria complexity, QA, and making the table more user friendly -IRT, RWG, permit writer review	-Draft criteria table -Final criteria table	-March 8 (Andrea) -March 18 (Andrea)
Non-NPDES RWG Rule-making Items	No	-Finalize non-NPDES options and develop language - 2 more meetings remaining--not yet scheduled (mid-March?) -IRT review -We’ll need to further develop this section for specific tasks	-Draft language (for RWG+ and internal review) -Final language (for internal review) -set up small workgroup meeting(s) on pretreatment and mixed media	-March 26 (??--Gene/Koto/Josh, Kevin, Jennifer, Tiffany) -April 28 -Neil?
Rule Package for SOS (May 14)	Yes and No	-RWG doesn’t need to review ALL rule package components—mainly proposed rule language, fiscal impact, criteria table, and policy paper -schedule hearings by end of March	Complete: -federal requirements -notice of proposed rulemaking and hearing dates -statement of need and fiscal and economic impact -land use evaluation -relationship to federal requirements -implementation plan -proposed rule language w/ strikeout -other supporting docs	-Draft: March 26 (interim dates to meet this deadline need to be set) (Andrea) -Final: April 28 (Andrea)