,

# -

IV. ATTORNEY GENERAL'S STATEMENT

### REVISION ATTORNEY GENERAL'S STATEMENTFORFINAL 

# e' AUTHORIZATION FOR CHANGES TO THE FEDERAL RCRA PROGRAM THROUGHJULY 1, 1993 I hereby certify, pursuant to my authority as Deputy Attorney General assigned to represent the Idaho Department of Health and Welfare - Division of Environmental Quality (IDHW-DEQ) and in 

### accordance with Section 3006(b) of the Resource Conservation and Recovery Act (RCRA), as amended by the Hazardous and Solid Waste Amendmentsof 1984 (42 U.S.c. 6901 

### et seq), and 40 CFR Part 271, that in my opinion, the laws of the State of Idaho provide adequate authority to carry out the revised program set forth in the revised "Program Description" submitted by the IDHW. The specific authorities provided are contained in statutes or regulations lawfully adopted and effective at the time this Statement is signed. This certification amends and supplements the Attorney General's Statement dated July 5, 1988 (as amended by letter dated June 3, 1989) as amended and supplemented by the Revision Attorney General's Statement dated February 13, 1992. ReeulatoryEquivalency The Idaho Department of Health and Welfare Rules, Title 1, Chapter 5, "Rules and Standards for Hazardous Waste" incorporate by reference all federal RCRA regulations required for final authorization through July 1, 1993. Accordingly, the State rules are equivalent to the federal regulations. IDAPA 16.01.05.000 

### et seq.

FederalRCRA Citation State Citation State Analog is: Equivalent More Stringent Broader in Scope 40 CFR Part260 All subparts as ofJuly 1, 1993. IDAPA 16.01.05.004 X
40 CFR Part261 All subparts including all appendices as of July 1, 1993. IDAPA 16.01.05.005 X

40 CFR Part262 All subparts as ofJuly 1, 1993 exceptthat advancenotification, annual reports, and exception reports in accordancewith 262.53, 262.55 and 262.56 shall be flIed with the EPA Regional Administrator and the DirectorofIDHW shall be copied. All references to EPA in 262.51 and 262.54(g)(1) shall be defined as EPA and all references to the Regional Administrator in 262.57(b) shall be the EPA Regional Administrator. IDAPA 16.01.05.006 X

Idaho Revised Authorization Application December 1994

Page 1 of2Federal RCRA Citation State Citation State Analog is: Equivalent More Stringent Broader in Scope 40 CFR Part263 All subparts as of July 1, 1993. IDAPA 16.01.05.007 X
40 CFR Part264 All supbarts as of July 1, 1993 except 264.149 and 264.150. All references to the Regional Administrator in 264.12(a) shall be defined as the EPA Regional Administrator. IDAPA 16.01.05.008 X

40 CFR Part265 All subparts except Subpart Rand 265.149 and 265.150 as of July 1, 1993. IDAPA 16.01.05.009 X

40 CFR Part266 All subparts except SubpartA and Subpart B as of July 1, 1993. IDAPA 16.01.05.010 X

40 CFR Part268 All subparts except 268.5, 268.6, 268.42(b) and 268.44 as of July 1, 1993. However, if the Administrator ofEPA grants a caseby-case variancepursuantto 268.5, that variance will simultaneously createthe same case-by-easevarianceto the equivalent Idaho regulation. IDAPA 16.01.05.011 X

40 CFR Part270 All subparts as of July 1, 1993. IDAPA 16.01.05.012 X
40 CFR Part279 All supbarts as of July 1, 1993. IDAPA 16.01.05.015 X
40 CFR Part 124 Subpart A only as of July 1, 1993. IDAPA 16.01.05.013 X

RCRA §3005(j) IDAPA 16.01.05.014 X 

### Dated this 29 day of December. 1994.

Curt A. Fransen Deputy Attorney General Office ofthe Attorney General State ofIdaho

Idaho Revised Authorization Application December 1994

Page 2 of 2TABLEOF CONTENTS

Section

1.0 PROGRAM DESCRIPTION 1.1 

### Background. .. 1 -01 1.11 Scope, Structure, Coverage and Processes of IdahoProgram • • • • • • • • • • • • • • • • 1 -01 1.1I.A StateRegulatory, Equivalency •••••••••••••••••••••.•••.••.•• 1 -02 1.1I.B Organization and Structure •••••••.••••.••..•••••••••••••••• 1 -02 l.n.C Stafr

### JobDescriptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -02 1.1I.D StateAgency Staffing and Funding ••••••.••••••••••••••••••••• 1 -03 

### 1.11.E Training 1 -03 I.II.F Program Funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -03 1.11.G Ancillary StaffSupport • • • • • • • • • • • • • . • • • • . • • • • • • • • • . • • • • • • • 1 -03 Lfl.H

### Operational Procedures 1 -04 1.1I.H.1 Scope of Regulated Community •.•.••....•...•••••••••. 1 -04 1.1I.H.2 HazardousWasteHandler .•.•.•••.•••.•.•••••••••••• 1 -04 I.II.H.3 Manifesting I -Q4 

### 1.ll.H.4 Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -04 I.II.H.5 Hazardous Waste Transportation Authorities . . . . . . . . . . . . . . . . . 1-05 1.1I.H.6 EnforcementProgram Summary •..•.•.•.•......•..•.• . 1 -OS I.II.H.7 Criminal Enforcement Procedures I -05 I.II.H.S Waste Stream Delisting I -05 1.II.H.9 Information Management •.••..••.•••••.•••••.•••••• 1 -OS 1.II.H.10 PermittingProgram •••••••••••••..••.•.•.••••..•.• 1 -06 1.11.1 HSWA Amendments •.••..•..••.••••.•.•.•.••.•••.•.•••.• 1 -07 1.11.1.1 Wood PreservingListings 1.11.1.2.Liners and Leak Detection Systems for HazardousWasteLand Disposal Units 1.11.1.3 Hazardous Debris Case-by-Case Variance 1.11.1.4 LandDisposal Restrictions for NewlyListed Waste and Hazardous Debris 1.1I.I.S Recycled Used Oil Management Standards 1.11.1.6 Liquids in Landfills 1.11.1.7 Corrective Action ManagementUnits and TemporaryUnits I.II.JRadioactive Mixed Waste I -OS I.II.KUnderground Injection Control I -OS

••TABLE OF CONTENTS ENTRIES IN BOLD PRINT HAVE BEEN UPDATED SINCE THE LAST REVISION AUTHORIZATIONPACKAGE SUBMITTEDIN 1991.

IDAHO REVISED AUTHORIZATION APPLICATION DECEMBER 1994

# e APPENDICES I. IdahoHazardous Waste Management Act II. IdahoHazardous Waste Rules and Standards III. IdahoProgram Authorization Status 

### IV. Attorney General's Statement



### V. Reference Guide to Cluster Adoption 

### VI. Organization Charts
VII. 

### RCRIS StaffAttended Training
VIII. 

### Hazardous Waste, Generators and Used Oil Handlers

IX. RCRIS Standard OperatingProcedures

X. RCRA Inspection Forms and Checklists 

### XI. Compliance Enforcement Strategy XII. Compliance Assurance Agreement XIII. 

### Memorandum of Agreement 

### XIV. Idaho Public Records Act

XV. 

### Multi-Year Permitting Strategy

IDAHO REVISED AUTHORIZATION APPLICATION DECEMBER 1994
ii

# 1.0 PROGRAM DESCRIPTION

### PROGRAM DESCRIPTION 

### I. BACKGROUND In 1983, the Hazardous Waste Management Act (HWMA) was promulgated by the Idaho legislature. This was the enabling legislation for the proper management of hazardous waste in Idaho. HWMA was amended in 1984, 1986 through 1991, 1993 and 1994 to include provisions necessary to maintain the State's equivalency to the federal program (Appendix I). This legislation provided the authority for promulgation of hazardous waste rules and standards by the Idaho Board ofHealth and Welfare. The Idaho AdministrativeRules governing hazardous waste are entitled, "Rules and Standards for Hazardous Waste, IDAPA 16, Title 01, Chapter 05." The first set of State regulations became effective on January 1, 1985. Subsequent annual rule updates, corrections and emergency rules have been promulgated since that time (see Appendix II). HWMA instructed the Board of Health and Welfare to promulgate rules and standards which are in substance consistent with RCRA regulations but no more stringent nor broader in scope.	 To qualify to meet the standards of equivalency and consistency with the federal program, Idaho incorporates by reference delegable federal regulations in 40 CFR Parts 124, 260-266, 268, 270, and 279. On April 9, 1990 Idaho was granted final base authorization for those non-HSWA (Hazardous and Solid Waste Amendments) and HSWA requirements promulgated as ofJuly 1, 1987 and interim authorization for the HSWA Corrective Action provisions promulgated as ofJuly 1, 1987. Final authorization for those HSWA Corrective Action provisions was granted on June 5, 1992. On August 10, 1992 Idaho was granted final authorization for those HSWA and non-HSWA provisionspromulgated as of July 1, 1990. Appendix III contains a table illustrating Idaho's RCRA program authorization status. 

### II. SCOPE, STRUCTURE, COVERAGE, ANDPROCESSES OF THE IDAHO PROGRAM [40 CFR § 

### 271.6 (a)) Idaho intends to continue to operate a hazardous waste program that is consistent with the Federal program. Accordingly, the Hazardous Waste Rules and Standards were amended (Appendix II). Annually, the Idaho Board ofHealth and Welfare has adopted by reference all delegable federal requirements so the Idaho Hazardous Waste Rules and Standards, IDAPA 16, Title 1, Chapter 5, remain consistent with RCRA. These documents and the Revised Attorney General's Statement (Appendix IV) support coverage for all delegable RCRA requirements itemized in Appendix V, Reference Guide to Cluster Adoption. The scope ofthis program revision includes the requirements of RCRA Clusters I, II, and III (Appendix V Reference Guide to Cluster Adoption). This Program Description (PD) is in addition to the Revised PD submitted in December 1991 which amended the original PD submitted in July 1988. The format of this document consists ofappendices that contain improvements to Idaho's RCRA program, which are pertinent to this revised authorization package. RCRA Revision Checklists from the State AuthorizationManual have been excluded to avoid redundancy with the Attorney General's Statement and to eliminate approximately 120 pages of duplicative information. This format will allow for a streamlined approach to future program revisions.

Idaho Revised Authorization Application December 1994 1

### A. StateRegulatory Equivalency 

# o Idaho has maintained regulatory equivalency with the federal RCRA program by incorporatingby reference all delegable hazardous waste regulations revised as of July 1, 1990 up to July 1, 1993. Appendix II contains the Idaho Hazardous Waste Rules and Standards applicable through RCRA Clusters I, II, and III. The Revised Attorney General's Statement (Appendix IV) contains a comparison of EPA's 40 CFR citations and Idaho's equivalent state rules. Reference to IDAPA citations now include a period after the chapter; in the past the period was excluded. B. Organization and Structure [40 CFR §§ 271.6 (b)] DEQ's central office is located in Boise, Idaho. Six DEQ regional offices are situated in geographically distinct areas: Coeur d'Alene in the panhandle of north Idaho, Lewiston in north central Idaho, Idaho Falls in eastern Idaho, Pocatello in the southeast, Twin Falls in south central Idaho, and Boise in the Southwest. DEQ is organized into four divisions: Planning and Evaluation, Permits and Enforcement, Community Programs, and Support Services. The Permits and Enforcement Division is responsible for carrying out those functions associated with the RCRA hazardous waste program. Changes in DEQ's internal structurehave been implemented since the last revision package was submitted in December of 1991. Appendix VI represents the current organization for the four divisions within DEQ's Permits and Enforcement Section. The organizational changes have allowed DEQ to align with EPA's policy on multimedia efforts. The Hazardous Materials Bureau referred to in earlier authorization packages has been diversified by organizing staffin a functionally oriented fashion. TheBureaus reflected in the organizational charts are charged with performing 

# o specific functions, such as Operating Permits or Enforcement Bureau. The reorganization did not impact the DEQ's responsibility to implement Idaho's RCRA program. C. StaffJob Descriptions [40 CFR §§ 271.6 (b)(1)] There are no new staffpositions which requirejob descriptions for revision application purposes. Several title changes have been enacted; however, the duties associated with these positions remain unchanged. The organizational chart in Appendix VI includes these changes. D. State Agency Staffing and Funding Idaho's RCRA program currently consists of 12.95 FTEthat are utilized to implement the program. The federal government provides approximately fifty-one percent (51%) ofthe funding for these positions. Federal RCRA funding is allocated for approximately 6.60 FTE. DEQ's RCRA program will continue to focus foremost on permitting, corrective action, and compliance and enforcement efforts. Appendix VI contains the organizational charts for DEQ permits and enforcement including RCRA staffpositions. 

# o Idaho Revised Authorization Application December 1994 2

### E. Training Continual stafftraining is a key element of the State program as RCRA regulations evolve. Training with emphasis on technical criteria, regulations, policies, interagency issues, etc., is scheduled on an as-needed basis. Appendix VII contains examples oftraining sessions attended by members of the RCRA staff during the time-frame applicable to this revision package. In addition to technical training, applicable RCRA program staffare trained in accordance with the State ofIdaho, Worker Health and Safety Program which includes training in the use of personal protective equipment and the requirements of 29 CFR 1910.120. 

### F. Program Funding [40 CFR §§ 

### 271.6 (b)

### (2)&

### (3)] Idaho's RCRA program operates on $790,580 according to FY 94 Work Plan and Idaho's Application for Federal Assistance - Hazardous Waste Management RCRA. In 1994, the DEQ received approximately fifty-one percent (51%) of RCRA program funding through an EPA grant. The federal RCRA grant amount of $401,419has remained the same for the last three years. Forty-ninepercent (49%) of the RCRA program funding is comprised of fees assessed mainly on hazardous waste disposed at commercial TSD facilities and minimally from TSD Siting License applications. Fees collected are managed in the Hazardous Waste Management Account. Hazardous Waste Disposal fees utilized to support the operation ofIdaho's authorized RCRA program totalled $389,161 in 1994. 

### G. Ancillary StaffSupport Ancillary support of the RCRA program is provided by DEQ's Support Services Division. This Division supports all programs within DEQ and receives partial funding through the current indirect rate of fifty-eight percent (58%) assessed on all federal grants. Also, DEQ is assigned 7.33 FTE attorneys through Idaho's Office of Attorney General for all programs. The RCRA program is specifically allocated approximately 1.5 FTE attorneys. 

### H. Operational Procedures [40 CFR §§ 

### 271.6 (c)] 1. Scope ofRegulated Community [40 CFR §§ 

### 271.6 (g)&(h)] The estimated number of hazardous waste or used oil handlers in Idaho is delineated in Appendix VIII. These numbers are based on receipt of hazardous waste or used oil notification forms by EPA or DEQ through accessing the RCRA Informational System (RCRIS). Regulated used oil generators are not required to notify for generator activities; an estimation of this group is also provided in the appendix. The number ofused oil handlers that notify are expected to increase as outreach efforts continue. The actual number of handlers which correspond to the categories listed will remain variable due to changes in production practices, new handlers notifying of hazardous waste or used oil activity, clean-up programs, and many other market variables.

Idaho Revised Authorization Application December 1994 

### 3Thetreatment, storage, or disposal facility (TSD) category is used by those hazardous waste handlers whose activities require a RCRA permit. 

# o Appendix VIII also contains information regarding quantities of hazardous waste managed within the State of Idaho for the calendar year 1994. This information was obtained from the 1994Hazardous Waste Annual Report. 2. Hazardous WasteHandler Hazardous Waste Handler procedures are now referenced in the RCRIS Memorandum of Understanding (1991) (MOU) and the RCRIS Standard Operating Procedures (SOPs). Appendix IX contain RCRIS SOPs updated since submission of the last revision package. When the RCRIS MOU is updated it will be included in a future revision package. 3. Manifesting [40 CFR §§ 271.6 (0] The EPA National Uniform Manifest Form is used, including any subsequent revisions. Idaho adopts manifesting instructions by reference. There are no changes to this procedure. 4. Inspections [40 CFR §§ 271.6 (d)] Most changes in the inspection process can be found in the applicable appendices when the HWMA Civil Penalty Policy, Compliance/Enforcement Strategy, Compliance Assurance Agreement and other documents are updated. RCRA inspection results are detailed in the required inspection reports. The inspection report is derived from the inspector's facility visit, supplemented with field notes. The inspection reports are filed in each facility's file. Changes to inspection protocol may also include upgrading forms and inspection checklists. Ifthese forms are internal (State) documents, upgrades are provided in Appendix X. Federal form upgrades are incorporated into Idaho's RCRA program. Forms and checklists that are EPA generated or site-specific are not included in authorization revisionpackages. A list of EPA and site-specific checklists provided to inspectors is identified in Appendix X. 5. Hazardous Waste Transportation Authorities There are no changes to this part of the program. 6. Enforcement Program Summary The 1987 EPA Enforcement Response Policy and the HWMA Civil Penalty Policy provide the basis for the Enforcement Program. The HWMA Civil Penalty Policy is currently undergoing revision. Operational procedures for the enforcement program are found in the appendices under: Compliance and Enforcement Strategy, Compliance Assurance Agreement, and the Memorandum of Agreement. These appendices are numbered XI, XII, XIII respectively. Each of these documents has been updated since the last revision package.

Idaho Revised Authorization Application 

# o December 1994 4 

# 07. Criminal Enforcement Procedures Idaho's criminal enforcement process will remain as outlined in the original authorization application with the addition of the "Criminal Enforcement Addendum to the Policy Framework for State/EPAEnforcement Agreements" (February, 1993). 8. Waste Stream Delisting There has been no changes to Idaho's delisting process. 9. Information Management [40 CFR §§ 271.6 (e)]

a. Public and Confidential Information In accordance with Idaho's Public Records Act, as amended, IDHW has issued written guidance for processing public information requests. The Idaho Public Records Act can be found in Appendix XIV along with forms utilized for public information requests. b. Biennial Report Idaho utilizes the federal biennial report form. When EPA updates the federal form, Idaho also updates its use. The State RCRA program administers the biennial report system and provides this data to EPA through the National Biennial Report System (BRS). DEQ has access to the BRS mainframe and also operates BRS on a personal computer.

c. Compliance Reporting In January 1991, EPA and DEQ entered into a Memorandum of Understanding (MOU), as amended in December 1991, to provide for administration of RCRIS. In particular, the MOU details (1) the conversion ofdata from the Hazardous Waste Data Management System (HWDMS) to RCRIS, (2) information sharing procedures, (3) implementor of record policies, (4) dispute resolution procedures, and, (5) general RCRIS management issues. As stated earlier in this program description, when the MOU is revised it will be included in future authorization packages. For additional information, access the RCRIS Standard Operating Procedures (SOPs) and the RCRIS Memorandum ofUnderstanding (1991). RCRIS SOPs have been updated since the last revision package was submitted. The updated SOPs can be found in Appendix IX. d. Quarterly Reporting System Section 39-4411 of HWMA requires all hazardous waste generators and disposal facilities to report quantities of hazardous waste produced or received on a quarterly basis. HWMA then requires the Idaho Department of Health and Welfare, through DEQ, to submit an annual report to the governor and the legislature detailing the types and quantities of hazardous wastes handled in Idaho.

Idaho Revised Authorization Application December 1994 

### 510. Permitting Program 

# o a. Permit Application Review/Decision-Making The tracking system ofpermit applications has changed with the use of RCRIS. New hazardous waste permit applications are logged into RCRIS. DEQ will conduct an initial completeness review and transmitthe results of that review within thirty (30) days to the applicant. The public participationprocess used in Idaho is identical to the requirements imposed federally. Arrangements between Idaho and the EPA regarding implementation of both HSWA and nonHSWA regulations are addressed in a Memorandum of Agreement (Appendix XV). b. Permit Modification, Suspension, Revocation, Reissuance, and Termination Permit modification procedures remain consistent with the requirements of 40 CFR § 124 and § 270 as updated. IDAPA 16.01.05.013 and 16.01.05.012 are amended annually to reference changes made to 40 CFR § 124 and § 270.

c. Multi-Year Permitting Strategy [40 CFR §§ 271.6 (g)(3)] The Multi-Year Permitting Strategy is attached as Appendix XV. The Multi-Year Permit Strategy includes all facilities under-going the permit process and permit status information. 

### I. Implementation of HSWA Amendments 

# o Seven rules from RCRA Clusters I, II, and III have been found to have a significant impact on Idaho's regulated community or the State RCRA program. Workload increases to the State RCRA program are balanced and priorities against existing tasks in the RCRA Work Plan and are negotiated annually. Impacts are described below: 1. Wood Preserving Listings (55 FR 50450 - December 06, 1990) State Authorization Manual Rule Code 82 This rule has resulted in numerous cleanups of F032 contaminated soil throughout the state. Pole-treatment facilities were severely affected. Many pole-treating facilities have stopped operation since passage of this rule, resulting in a decrease of that component of the regulated community. Presently, the Army Corp of Engineers is finalizing eight (8) separate cleanups of F032 contaminated sites. Numerous more cleanups are planned by the Army Corp of Engineers. DEQ reviews interim and final reports on each of these cleanups. Pressure Treated Timber (no longer in operation) has been an on-going project for permitting and compliance staff. The Bureau of Land Management has conducted five cleanups. The Department of Fish and Game have completed three cleanups. University ofIdaho has completed one cleanup. The Department ofLands has completed two cleanups. Therehave been numerous private owner cleanups. The DEQ expects there are still many small abandoned pole-treating facilities that may require remediation in the future. Property transactions frequently act as catalysts for remedial activity.

Idaho Revised Authorization Application 

# o December 1994 62. Liners and Leak Detection Systems for Hazardous WasteLand Disposal Units (57 FR 3462 - 01129/92) State Authorization Manual Rule Code 100 Thepermit modification for expansion at ESII required integration ofthis rule. Design efforts and current expansion processes require compliance with this rule. 3. Hazardous Debris Case-by-Case Capacity Variance (57 FR 20766

­ 05/15/92) State Authorization Manual Rule Code 103 Reviewal ofRequests for Variance has caused a significant increase in workload for HW Science Officers. This rule has allowed for less stringent management ofhazardous debris for the regulated community than in the past. This request for variance expired on May 8, 1994. 4. Land Disposal Restrictions for Newly Listed Wastes and Hazardous Debris (57 FR 37194

- 08/18/92) State Authorization Manual Rule Code 109 ESII has applied for a permit modification to utilize a containment building. The permit modification has resulted in the issuance ofa six month temporary authorization following a request for a Class 3 permit modification by ESII. This rule has also resulted in many generator treatment plans for INEL. DEQ reviews and comments on these generator treatment plans. 5. Recycled Used Oil Management Standards (57 FR 41566 - 09110/92) State Authorization Manual Rule Code 112 This rule increased the regulated community significantly. DEQ estimates that over onethousand (1,000) used oil generators are now subject to regulation under 40 CFR Part 279. Appendix VIII contains both RCRIS identified used oil handlers and an estimate ofused oil generators. Outreach efforts have resulted in training and the generation ofa series ofused oil brochures to educate handlers on the new regulations. Regulated community inquirieshave been extensive. HW Science Officers attended an in-house Used Oil Rule Training. HW Science Officers have spoken at numerous conferences to educate the regulated community. More workshops throughoutthe state are planned for 1995. Theprioritization ofenforcement efforts for used oil handlers follows EPA used oil enforcement policy provided to DEQ. The impact ofthis rule is significant to the regulated community as well as DEQ. 6. Liquids in Landfills II (57 FR 54452

- 11/18/92) State Authorization Manual Rule Code 118 Prohibitionofbiodegradable sorbents to prevent liquid release in landfills has impacted virtually all regulated generators as well as land disposal facilities. Sorbent materials are normally used in spill or leak situations. Generators· must choose non-degradable sorbents if final disposal is destined to be a landfill. Sorbent selection should be incorporated into a facility's contingency plan. HW Science Officers must check for sorbent material composition during the routine inspections at ESII. The major impact incurred with promulgation ofthis rule has been felt mainly by the regulated community, rather than the Stateprogram.

Idaho Revised Authorization Application December 1994 7

### 7. Corrective Action Management Units (CAMU) and Temporary Units (58 FR 8658 - 02/16/93) State Authorization Manual Rule Code 121 

# o

J.

K. CAMU rule resulted in the submittal of a Revised Part B for ESII-A. Permit writers were required to review the revised Part B and subsequent revisions after issuance of a Notice of Deficiency (NOD). Also, a CAMU type permit condition was drafted. This rule has set the entire permitting process back approximately one year. 

### RadioactiveMixed Waste There have been no changes to this section of the RCRA Program. 

### Underground Injection Control There have been no changes to this section of the RCRA Program.



# o

Idaho Revised Authorization Application 

# o December 1994 

### 8