Action Items to Prepare for February RWG Meeting | ||||
WHAT | ADDITIONAL RWG DISCUSSION | RESOLUTION | NEXT STEPS | COMMUNICATION |
Intake Credit Rule | No | -DEQ going forward w/ existing rule language
-resolve/justify legal issue: Why doesn’t EPA consider the ICR as a standards provision? EPA: Not a standards provision as long as the WQS is met at the end of pipe or MZ if not WQL. DEQ: need to revise the boilerplate language in the permit to allow intake credits in meeting QBELs.
| Call Michael—Deb--DONE E-mail RWG—Melinda/Jannine provide response?
Wrap up remaining revisions--Spencer | e-mail RWG w/ final language in a separate e-mail (along w/ other final products) indicating no other action needed--Andrea
Work w/ Larry/Jane on permit language--Spencer
|
HHC Schedule | No | -Proceed with Option #3 (separate HHC sched. Language)
-Check existing reg lang for consistency
-Check gaps for implementation for pre-TMDL timeframe and pre WQS effectiveness
| - Confirm Neil wants to proceed w/ this option—Spencer/DONE
-Call Michael—Deb
-call Nina—Neil/DONE
-call Deb Smith (CA) for input on what they’ve been doing—Deb/Jennifer-DONE
-revise language to reflect current reg. language, but only refer to HHC -- Spencer
| e-mail to RWG w/ final language in a separate e-mail (along w/ other final products) indicating no other action needed--Andrea
Find out if Jane needs to review our rule language before going to Larry at DOJ—what’s her role? Andrea/Spencer |
Variance White Paper and Reg. Language | Yes | -How much detail do we want in the regulation, IMD, and white paper?
-Does DEQ want to pursue a MDV?
-specific issues and questions that still need resolution | -Meet w/ Nina to get her opinion and discuss her concerns ASAP—Andrea - DONE
-Receive RWG comments by 12/18 and incorporate if applicable—Andrea
-Incorporate comments, as needed, from IRT meeting on Jan 6 —Andrea
-incorporate revisions as needed in the regulation and white paper
-Schedule 3 govt meeting for 1/8—Andrea DONE
-Issues to bring forward to EPA HQ? IN PROGRESS—waiting to hear on NPS and existing use questions
-Develop an options paper for a RWG variance conference call and provide opportunity for comments
| -e-mail straw poll: send reg language ASAP to RWG and ask for support (1 – 5). If 4 or 5, explain hesitation/concerns—Andrea-- DONE
-Enables DEQ to understand major issues and evaluates ability to address them.
-send conference call e-mail to RWG for Jan. 13 or 15—Andrea-DONE |
Background Concentration Allowance | Yes | -implementation plan for DEQ and EPA approval
-what does 5 yr review mean?—Melinda & Jannine (MI MDV—EPA needs to do a review every 5 yrs.) | -ID likely pollutant categories (303d list?)—Deb
-develop 1 pg. paper describing process 12/31—Andrea/Melinda--
-EPA to explore justification based on HH use—Melinda DONE/IN PROGRESS
-develop multiple pass cooling alternatives 1 pg. paper 12/31—Spencer
-determine approximate number of multiple pass cooling systems in OR 12/18—Spencer (sent out e-mail request 12/11) DONE
| -call Michael to help w/ ID of pollutants—Deb
|