A	B	C	D	E	F	G	H	I	J
1		Human Health Criteria Rulemaking Work Group Topics - 12/17/08 Draft
3		Work Session	DEQ Task	Discussion Items	Group Task	Meeting Date/Time	Deliverable
4	1	Introduction	Convene group and describe EQC's rulemaking directive. Define the scope of the HHC rulemaking. Describe how this group will contribute to the rulemaking effort and to the overall Toxics Reduction Strategy. Describe process and groundrules. Provide an overview of the current structure of standards and permitting rules and associated guidance documents	Water quality standards overview, Water quality permitting process overview. Workgroup schedule, process and outcomes	Provide input on process, topics, timeline and deliverables. Provide expectations for outcomes. Provide input on what will be addressed via rule language and what will be addressed via permit program guidance (IMDs, etc.)	12/17/2008, 1-5	DEQ will summarize input and revise work plan as needed.
5	2	Making connections outside of the NPDES program - source reduction activities	Provide an overview of DEQ's overall toxics program and the strategies and pathways that appear to be most viable.	Mechanisms for allowing connections outside of the NPDES program. Mechanisms for reductions from non-NPDES sources. Links with SB737 and overall toxics reduction strategy	Identify paths to toxics reduction by sources not regulated under CWA Section 402. Provide comments and suggestions for the use of variances, identify technical and/or policy considerations. Identify actions, programs and policies that could support making connections outside of the NPDES program. Begin laying groundwork / brainstorming for meeting #4.	1/14/09 12:30- 4:30	Summary of the input received, description of the approaches to be used, and/or need for additional input/subgroup discussions. Clearly articulated linkages to overall toxics reduction strategy. Describe components of a source reduction program
6	3	1. Revising the Human Health Criteria. 2. Approaches for "background" pollutants	Describe approach used to update Human Health Criteria tables. Discuss approaches for naturally occurring earth metals. Provide an overview of potential approaches for background pollutants, such as intake credits	Methods and scope for HHC criteria revisions, innovative approaches for addressing background pollutants	Provide input on the overall approach and options for naturally occurring earth metals, identify possible paths forward and follow up actions		Summary of the input received, description of the approaches to be used, and/or need for additional input/subgroup discussions
7	4	Provisions that allow source reduction activities in NPDES permits	Provide an overview of potential permitting tools that allow for source reduction activities	Various permitting tools and approaches that can be used within the "traditional" NPDES permitting process. Discuss what a source reduction program would look like.	Identify legal CWA permitting mechanisms that allow regulated facilities to reduce toxic pollutants by means other than end-of-pipe treatment where that reduction is environmentally beneficial and more cost-effective than a numeric water quality based effluent limit.		Summary of the input received, description of the approaches to be used, and/or need for additional input/subgroup discussions. Describe CWA permitting mechanisms that will be included in the rulemaking
8	5	NPDES Tools: Technical Considerations	Provide an overview of technical NPDES permitting issues that have been identified such as infrequent detections, calculation of interim effluent limits associated with variances, etc.	Quantitation Limits, Interim effluent limits, RPA procedure to account for infrequent detections, offsets, etc.	Provide input on known technical issues and identify any other technical considerations		Summary of the input received, description of the approaches to be used, and/or need for additional input/subgroup discussions
9	6	Economics, cost/benefit and impact on small business	Provide an overview of the work done to date	Consider costs and benefits of proposed rules and policies	Capture what is known, quantitative and qualitative.		Ensure that currently available cost and benefit information informs the criteria and implementation recommendations. Fiscal impact statement will be part of any proposed rulemaking documentation
10	7	Wrap up	Summarize progress made, approaches that will be pursued and path forward	TBD	Provide input and suggestions on outstanding issues and possible paths forward		Summary of input received, approaches endorsed, areas of uncertainty