From: LUMPER Bruce

Sent: Thu Aug 02 13:48:32 2012

To: FULLER Brian

Cc: LUMPER Bruce

Subject: CT-RM: FA Housekeeping Rules and CT Rules

Importance: Normal

Hi Brian,

I have just re-reviewed the proposed FA Housekeeping rule additions. Given the process that Loretta recommends that we go through to have these included in the CT Rulemaking process ---- my recommendation would be that we discontinue this effort. The changes are so minor and insignificant, and, as Loretta notes, they can be included in a future, more comprehensive, FA focused rulemaking effort.

What do you think?

Sincerely,

Bruce

From: FULLER Brian

Sent: Wednesday, August 01, 2012 5:00 PM

To: LUMPER Bruce

Subject: CT-RM: FA Housekeeping Rules and CT Rules

Hi Bruce,

Thoughts from Loretta….

From: PICKERELL Loretta

Sent: Wednesday, August 01, 2012 12:44 PM

To: DRUBACK Lissa; FULLER Brian; OBRIEN Audrey

Subject: RE: FA Housekeeping Rules and CT Rules

Here are some thoughts for those of you directly involved in FA to consider. If these are non-controversial “housekeeping” changes, as they appear to be, adding them to this rulemaking seems doable. E.g.,

· Send short email to affected permittees describing proposed rule changes (e.g., correct references) and rulemaking process

· Discuss them briefly with the CT advisory committee - if do this, include in email above. Law/rules do not require advisory committee consideration of these changes, and CT advisory committee was not constituted for this FA issue, but suggest at least mentioning these proposed changes at an Adv Committee meeting (August or September?).

· Include proposed changes in the notice of proposed rulemaking for public comment (written and at hearing) – to satisfy rulemaking notice requirements.

· Tack these on as “housekeeping” changes in the EQC staff report – and file adopted rules w/SOS.

Other considerations – if we do not expect noncompliance with these FA “housekeeping” rule amendments before a likely date for a more comprehensive update of the FA rules, then even this level of effort may not be necessary. But if we want to address FA in closure permits or expect other compliance issues, the effort now may save larger effort later on.

Maggie V can vet the steps needed to tack this rulemaking on.

Loretta

From: DRUBACK Lissa

Sent: Wednesday, August 01, 2012 8:08 AM

To: FULLER Brian; OBRIEN Audrey; PICKERELL Loretta

Subject: RE: FA Housekeeping Rules and CT Rules

The only rule change that might be critical is the first one (where we change the rule from just referencing closure permits to operating or closure permits). However, if we are not opening this division up it may not be worth it considering we would have to do some sort of public outreach for that rule change in addition to the outreach we are doing on the CT rules.

From: FULLER Brian

Sent: Tuesday, July 31, 2012 3:32 PM

To: FULLER Brian; DRUBACK Lissa; OBRIEN Audrey; PICKERELL Loretta

Subject: RE: FA Housekeeping Rules and CT Rules

Proposed changes attached.

From: FULLER Brian

Sent: Tuesday, July 31, 2012 3:30 PM

To: DRUBACK Lissa; OBRIEN Audrey; PICKERELL Loretta

Subject: FA Housekeeping Rules and CT Rules

Your thoughts on not adding the FA housekeeping rules to the CT rulemaking?

Thanks

From: LUMPER Bruce

Sent: Friday, July 20, 2012 12:42 PM

To: RHOADES Cathie

Cc: LUMPER Bruce; BARROWS Bob; FULLER Brian

Subject: CT-RM: Task List

Hi Cathie,

Per the tasks list ----

1) Stephanie and I have completed the meeting summary write-up and posting.

2) I updated the timeline and posted it on sharepoint – yesterday. That might be the last update of the timeline for awhile.

3) I’m going to propose to Brian and Bob that we don’t add the FA housekeeping corrections to this rule effort because the four corrections are in 095 and 064 – which are rule areas that we’ve not opened up so far. Since these are such minor corrections I’m thinking they can wait for a future rulemaking effort. I’ll see what Brian and Bob have to say and to let you know.

4) I’ve reviewed the 4 drafts of our proposed rule changes this morning and made some further minor suggested edits/corrections.

Sincerely,

Bruce

From: LUMPER Bruce

Sent: Tuesday, July 10, 2012 8:06 AM

To: RHOADES Cathie

Cc: LUMPER Bruce

Subject: CT-RM: Task List

Hi Cathie,

I’m a little behind per my Task Deadlines. I did get to work on the draft minutes yesterday and hope to finish my work on that task today. Then I’ll get going on the others – in and around some other projects.

I’ll keep you posted on progress.

I appreciate the task reminders.

Enjoy that sun!

Bruce

From: RHOADES Cathie

Sent: Friday, July 06, 2012 4:17 PM

To: LUMPER Bruce

Cc: RHOADES Cathie

Subject: CT-RM: Task List

Hey Bruce, happy Friday. Just another friendly reminder that these task are due today. You might have already completed them, but the table hasn’t been update if you did. I hope you are having a great Friday. Have a good weekend. Cat

Cathie Rhoades

Department of Environmental Quality

Solid Waste Reduction Analyst

(503) 378-5089

rhoades.cathie@deq.state.or.us