, -


IV.
 

ATTORNEY GENERAL'S STATEMENT
 
REVISION ATTORNEY GENERAL'S
 

STATEMENT FOR FINAL
 

e' AUTHORIZATION FOR CHANGES TO THE 

FEDERAL RCRA PROGRAM THROUGH JULY 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 Amendments of 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. 

Reeulatory Equivalency 

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. 

Federal RCRA Citation State Citation 

State Analog is: 

Equivalent 

More 

Stringent 

Broader 

in Scope 

40 CFR Part 260 

All subparts as of July 1, 1993. 

IDAPA 16.01.05.004 X 

40 CFR Part 261 

All subparts including all appendices as of 

July 1, 1993. 

IDAPA 16.01.05.005 X 

40 CFR Part 262 

All subparts as of July 1, 1993 except that 

advance notification, annual reports, and 

exception reports in accordance with 

262.53, 262.55 and 262.56 shall be flIed 

with the EPA Regional Administrator and 

the Director of IDHW 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 of 2
 
Federal RCRA Citation State Citation 

State Analog is: 

Equivalent 

More 

Stringent 

Broader 

in Scope 

40 CFR Part 263 

All subparts as of July 1, 1993. 

IDAPA 16.01.05.007 X 

40 CFR Part 264 

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 Part 265 

All subparts except Subpart Rand 265.149 

and 265.150 as of July 1, 1993. 

IDAPA 16.01.05.009 X 

40 CFR Part 266 

All subparts except Subpart A and Subpart 

B as of July 1, 1993. 

IDAPA 16.01.05.010 X 

40 CFR Part 268 

All subparts except 268.5, 268.6, 268.42(b) 

and 268.44 as of July 1, 1993. However, 

if the Administrator of EPA grants a caseby-case variance pursuant to 268.5, that 

variance will simultaneously create the 

same case-by-ease variance to the 

equivalent Idaho regulation. 

IDAPA 16.01.05.011 X 

40 CFR Part 270 

All subparts as of July 1, 1993. 

IDAPA 16.01.05.012 X 

40 CFR Part 279 

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 of the Attorney General 

State of Idaho 

Idaho Revised Authorization Application
 

December 1994
 

Page 2 of 2
 
TABLE OF CONTENTS
 

Section 

1.0 PROGRAM DESCRIPTION 

1.1	 Background. .. 1 -01 

1.11	 Scope, Structure, Coverage and Processes of Idaho Program • • • • • • • • • • • • • • • • 1 -01 

1.1I.A State Regulatory, Equivalency •••••••••••••••••••••.•••.••.•• 1 -02 

1.1I.B Organization and Structure •••••••.••••.••..•••••••••••••••• 1 -02 

l.n.C Stafr Job Descriptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -02
 

1.1I.D State Agency Staffing and Funding ••••••.••••••••••••••••••••• 1 -03 

1.11.E Training	 1 -03 

I.II.F Program Funding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -03 

1.11.G Ancillary Staff Support • • • • • • • • • • • • • . • • • • . • • • • • • • • • . • • • • • • • 1 -03 

Lfl.H Operational Procedures	 1 -04 

1.1I.H.1 Scope of Regulated Community •.•.••....•...•••••••••. 1 -04 

1.1I.H.2 Hazardous Waste Handler .•.•.•••.•••.•.•••••••••••• 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 Enforcement Program 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 Permitting Program •••••••••••••..••.•.•.••••..•.• 1 -06 

1.11.1 HSWA Amendments •.••..•..••.••••.•.•.•.••.•••.•.•••.• 1 -07 

1.11.1.1 Wood Preserving Listings 

1.11.1.2. Liners and Leak Detection Systems for Hazardous Waste Land Disposal Units 

1.11.1.3 Hazardous Debris Case-by-Case Variance 

1.11.1.4 Land Disposal Restrictions for Newly Listed 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 Management Units and Temporary Units 

I.II.J Radioactive Mixed Waste	 I -OS 

I.II.K Underground Injection Control	 I -OS 

••	 TABLE OF CONTENTS ENTRIES IN BOLD PRINT HAVE BEEN UPDATED SINCE THE LAST 

REVISION AUTHORIZATION PACKAGE SUBMITTED IN 1991. 

IDAHO REVISED AUTHORIZATION APPLICATION
 

DECEMBER 1994
 
e APPENDICES 

I. Idaho Hazardous Waste Management Act 

II. Idaho Hazardous Waste Rules and Standards 

III. Idaho Program Authorization Status 

IV. Attorney General's Statement 

V. Reference Guide to Cluster Adoption 

VI. Organization Charts 

VII. RCRIS Staff Attended Training 

VIII. Hazardous Waste, Generators and Used Oil Handlers 

IX. RCRIS Standard Operating Procedures 

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 of Health and Welfare. 

The Idaho Administrative Rules 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 of July 1, 1987 and 

interim authorization for the HSWA Corrective Action provisions promulgated as of July 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 provisions promulgated as of July 1, 1990. Appendix III contains a table 

illustrating Idaho's RCRA program authorization status. 

II.	 SCOPE, STRUCTURE, COVERAGE, AND PROCESSES 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 of Health 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 of this 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 of appendices that contain 

improvements to Idaho's RCRA program, which are pertinent to this revised authorization 

package. RCRA Revision Checklists from the State Authorization Manual 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. State Regulatory Equivalency 

Idaho has maintained regulatory equivalency with the federal RCRA program by o

incorporating by 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 structure have 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 staff in a functionally oriented fashion. 

The Bureaus 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. Staff Job Descriptions [40 CFR §§ 271.6 (b) (1)] 

There are no new staff positions which require job 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 FTE that are utilized to implement 

the program. The federal government provides approximately fifty-one percent (51%) 

of the 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 

staff positions. 

Idaho Revised Authorization Application o

December 1994 

2 
E. Training 

Continual staff training 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 of training 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 staff are trained in 

accordance with the State of Idaho, 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 $401,419 has 

remained the same for the last three years. Forty-nine percent (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 of Idaho's authorized RCRA 

program totalled $389,161 in 1994. 

G. Ancillary Staff Support 

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 of Regulated 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 of used 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 

3 
The treatment, 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 1994 Hazardous Waste Annual Report. 

2. Hazardous Waste Handler 

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. If these 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 revision packages. 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 

0 
7. 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/EPA Enforcement 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 of data 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 of Understanding (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 

5 
10.	 Permitting Program 

a.	 Permit Application Review/Decision-Making o

The tracking system of permit 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 

transmit the results of that review within thirty (30) days to the 

applicant. The public participation process 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 of Idaho has completed one 

cleanup. The Department of Lands has completed two cleanups. There have 

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 

6 
2.	 Liners and Leak Detection Systems for Hazardous Waste Land Disposal 

Units (57 FR 3462 - 01129/92) State Authorization Manual Rule Code 100 

The permit modification for expansion at ESII required integration of this 

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 of Requests for Variance has caused a significant increase in 

workload for HW Science Officers. This rule has allowed for less stringent 

management of hazardous 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 of a 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 one thousand (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 of used oil generators. Outreach efforts have 

resulted in training and the generation of a series of used oil brochures to 

educate handlers on the new regulations. Regulated community inquiries have 

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 throughout the state are 

planned for 1995. The prioritization of enforcement efforts for used oil 

handlers follows EPA used oil enforcement policy provided to DEQ. The 

impact of this 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 

Prohibition of biodegradable 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 of this rule has been felt mainly by the regulated community, 

rather than the State program. 

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. 

Radioactive Mixed 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