• PROGRAM DESCRIPTION OUTLINE. FOR FINAL AUTHORIZATION APPLICATION

Department of Ecology Dangerous/Hazardous Waste Program

I. BACKGROUND

II. SCOPE, COVERAGE, STRUCTURE, AND PROCESSES

A. Scope

B. Coverage (of the Dang~ruus Waste Regulation, Chapter 173-303

WAC)

1. Waste Desigr~t!nn

2. Generators

3. Transporters

4. Treatment, Stor~~e, and Disposal Facilities

5. Other Recu~rc~e~ts

6. Availability ,):- :n:ormation to the Public

7. Revision of ~-t d:C ?rogram

8. Summary

c. Lead Agency Ide~·~ficlrton, Agency Structure, Budget, and

Resource Asse~c~c~:

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3.

Agency St r uv r', t e .,;,J Organizational Responsibility

Sources of F' :-.':',<, and Restrictions

Resource .\"" .... :-.c:.t - Program Plan

III. PERMITTING PROCEDL'F~:

A. Purpose

B. Existing T~lJ "I, : . , • "- • I ...,

C. New TSD Fac:::t:.·"

D. Permit Deve . ; - .... :. ..'::,,"", AND Approval Process for Existing

and New Fac : '. ' ..'. '"

E. Permits bv lJ, '

F. Emergency r, ...

G.

H.

Judicial Rc. ..

Permit Cert ~:: ." ,I::.:,uage

A. Obj ective

IV. COMPLIANCE MONITI'~

• B.

- ...~. ~' CE~lENT

Facility Def 1n : t : .. ';.' . s t ab LishLng Priorities
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D.

Inspection Procedures

Enforcement Authority and Procedures

1. General Descriptions

2. General Procedures

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E. Information Management

V. REGULATED COMMUNITY DATA - ESTIMATES

A. Number of Notifiers by Activity Reported

B. Amount of Waste

C. Amount of Waste Treated, Stored, and Disposed

VI. FORMS

A. Notification

B. Permit

c. Annual Report

D. Manifest

E. Inspection

VII. STATUTES ~VD REGL~ATIONS

A. RCW (Revised Code of Washington)

1. 70.105

2. 70.105a (repealed)

3. 42.17

4. 34.04

5. 43.21A

B. WAC (Washington Administrative Code)

1. 173-303

2. 173-305 (repealed)

3. 173-03

VIII.Appendices

A. State 1985 Annual Report Summary

B. PIG 82-5

C. Lab Facilities and Capabilities

D. Attorney General's Office Support to Ecology
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Figure 1.

Figure 2.

Figure 3.

Figure 4.

Figure 5.

LIST OF FIGURES

Department of Ecology - Organization Chart

Solid & Hazardous Waste Management Program - Organization

Chart

Operations and Enforcement, Hazardous Waste Staff -

Organization Chart

General Permitting Process

Issuance of Dangerous Waste Permits

LIST OF TABLES

Table l.

Table 2.

Table 3.

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Table 4.

Table 5.

Table 6.

Table 7.

Table 8.

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Budget Estimate for the Dangercus Waste Program

Fiscal Year 1988 Dangerous Waste Staff

State Funded Positions - State Priorities

RCRA Related Positions

a. Fiscal Year 1989 Hazardous Waste Hires

b. 1990-91 Biennial Hazardous Waste Program Hiring

(Estimated)

Washington State Dangerous Waste Program - FTE Summary

Dangerous Waste FY 88 Program Plan

Criteria for Determining the Priority of Major and Non-Major

Facilities
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I. BACKGROUND

The Washington State Legislature designated the Department of

Ecology (Ecology) as the state agency for implementing the Federal

Resource Conservation and Recovery Act (RCRA). Since early 1978,

Ecology has been designating, tracking, and regulating the disposal

of extremely hazardous wastes through the Hazardous Waste

Regulation, Chapter 173-302 WAC. Recent promulgation of U.S.

Environmental Protection Agency (EPA) hazardous waste regulations

has resulted in a need to modify existing state regulations to be

"consistent and equivalent." The state Legislature recognized this

need in 1980 by giving Ecology increased authority in the area of

permitting dangerous waste facilities. Additionally, in 1983,

1984, 1985, 1986, and 1987 the Legislature increased Ecology's

authority to develop and implement a program consistent with RCRA.

Prior to 1981, Ecology identified dangerous wastes according to the

degree of hazard posed by a waste to the public health and the

environment. The waste classification system implemented by

Ecology designated wastes by their level of toxicity, their

persistence in nature, their potential carcinogenic risk, and their

tendency to ignite, corrode, and explode.

This classification system depended, to a large degree, on

established testing procedures, and on current scientific data

regardi~g the toxicity, persistence, and carci~ogenicity of

thousands of chemicals which could be found in a given waste.

Ecology felt that a "degree of risk" approach to designating wastes

was the best method to use considering the enormity of the

dangerous waste universe.

Tracking dangerous wastes as they moved from the generator to the

~isposal site was based on the use of a manifest system. This

manifest, prepared by the generator, states the type, amount,

origin, transporter, and final delivery point for a dangerous waste

shipment. The manifest is signed by the operator of the disposal

site and returned to the generator to signify acceptance of the

waste shipment. If the generator does not receive a signed

manifest copy from the disposal site within a specified time, he

reports this to Ecology. Ecology then initiates a search for the

missing waste.

Rules for the operation and maintenance of the extremely hazardous

waste (EHW) management facility at Hanford (the only facility in

Washington which may dispose of EHW) were adopted late in 1977

under Chapter 173-302 WAC. Standards for the design and operation

of other dangerous waste treatment, storage, and disposal (TSD)

facilities were developed to meet the substantial equivalence

requirements under RCRA at that time.

The current set of dangerous waste regulations, Chapter 173-303

WAC, have been amended to meet the equivalent and consistent

requirements of RCRA for final authorization.

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• II. SCOPE, COVERAGE, STRUCTURE, AND PROCESSES

A. Scope

This document represents the core of the state of Washington"s

application for final authorization of the "Dangerous Waste

Management Program" to be operated by Ecology. The regulatory

program developed for dangerous waste management is

comprehensive and is equivalent and consistent with the

federal RCRA program, it is intended to operate in lieu of.

All persons who generate. transport, transfer, cycle. treat.

store, or dispose of dangerous wastes. defined in the recently

amended June 1987 Dangerous Waste Regulation. Chapter 173-303.

Washington Administrative Code, are affected. The primary

purpose of the regulation is to protect the public health and

environment from improper management of dangerous waste. The

state program. administered by Ecology. has regulatory

authority over all areas of dangerous waste management.

including notification. inspection, monitoring, permitting.

compliance monitoring. manifest tracking. and enforcement.

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B. Coverage

Ecology recently amended its regulations to be consistent and

equivalent to RCRA. ~1any of the concepts developed for the

rules adopted in 1977 are essentially the same. such as the

dangerous and extremely hazardous waste (DW/EHW) two-tier

designation system. Additional methods have grown out of the

work done by EPA. such as a listing approach for dangerous

wastes and the standards for dangerous waste management TSD

facilities. The following descriptions provide a basic

knowledge of the amended Washington State Dangerous Waste

Regulations. Chapter 173-303 WAC.

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1. Waste Designation. The EPA procedures for designating

wastes depend primarily on two lists: the Discarded

Chemical Products List and the Dangerous Waste Sources

List. Both of these lists were developed by EPA and

adopted by Ecology (see WAC 173-303-9903 and 9904). The

criteria for listing was based on the toxicity. persistence. carcinogenicity, ignitability. corrosivity, and

reactivity of waste. For the Discarded Chemical Products

list, EPA considered many common commercial and offspecification manufacturing chemicals and listed those

which met the criteria. For the Sources List. EPA

studied data on various industrial processes and their

typical waste streams. then listed those sources of waste

which met the criteria.

Ecology augments these lists with its own criteria.

developed for the 1977 regulations. Ecology's criteria

have been applied in three ways. First, Ecology assigns

a DW/EHW designation to each waste which appears on the

lists. Second, the criteria applies to unlisted wastes

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about which the generator knows the constituents of the

waste and the constituent concentrations; if this

knowledge shows that the waste meets the criteria, then

it would be designated as dangerous or extremely

hazardous waste. Third, the criteria will be used by

generators of unlisted wastes who have been ordered by

Ecology, or ~ho choose voluntarily, to test their wastes

against the criteria and designate their waste

accordingly.

If a generatur bas a listed waste, he may also apply the

state's c r i t e r i.l to his waste to see if it is so

designated. ! t' t he generator determines that the

criteria du nct designate his listed waste, he must

obtain Eco10~"~ 3~reement that his waste is unregulated.

Before mak i r a i decision, Ecology will review the

generator'~ ,~~ criteria test data, and additional

factors, i~,':'tical to 40 eFR 261. Ll I a ) (3) (evg , , nature

of t ox i c i t v , p,'tential to degrade), as they might apply

to the waste. ;:. after reviewing these factors, Ecology

agrees that :~',l' ·.·,1ste should be undesignated, then the

waste will ~0r h~ subject to regulation. If Ecology

disagrees, t lie » t r.e ..·aste will remain listed and subject

to the a pp l . . k: e regulations. Unless and until Ecology

notifies tre ~e .. er~t0r, such waste will be subject to the

regula t ions, .:-.. .c d i tion, Ecology requires that any

listed ~ast~, e~en though it may be alternatively

designated ~~ .k~ ~tate's criteria, is still subject to

all rec;u:r.:·-:,l'-:" .rpp Lic ab Le to listed wastes.

In add it i o r t· ::,,: ing and criteria as a way of

design~t::. ~l~t~~. a third mechanism is provided. This

is the d:l't't·r•. - v.r s t e characteristics mechanism. Wastes

with till' :,," (....j r z phv s i c a L hazards are designated:

Lgn i r a b i c - ·.·.I,d.·'" ·...-hi ch are highly flammable; Corrosive

- wa s t v . '.: ;,~~ .i r e h i gh Ly acidic or alkaline; Reactive -

was t e s '.' . ,. .r r .. explosive, unstable, or would readily

rele<':f'" . x : '·.::e:;; and EP Toxic - wastes containing

high c"- , :. ,: : ·t· llf various metals and pesticides.

Ec o Loa : .: :'~l':-' procedures for exempting and

exc l uc . :,., : rvm regulation if a generator can petition .,. 1 .'.;~ ~cssful demonstration that his waste

should . :~nated (in the case of categorical

exclu,.'· I.'r '.;;' o f generators must

petit it-:- ',- . ': r a t e tor all wastes of a particular

class) , ... 1-: l''' vh Lch demonstrate any of the

cha r ac t.c: .. ' . z r t t ab t Ltt y , corrosivity, e t c , ) will be

exempt l' : I·.. .:-:, and no waste which is listed or

exhibit" ," .. ' I, t e r i s t Lcs will ever be included in a

c a t e go r : . ., ..... n , Wastes which are listed must pass

the c r i t ...r : t ':'.: ,: .i r a c t e r Lst Lc tests, and must be

de t e rtn i ne c , " 1n~y, to meet the additional factors

for deli~t::.: t~t'~e factors are identical to those of 40

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eFR 261.11(a)(3». Wastes which are not listed and do

not exhibit any characteristics, but are designated by

the state's criteria only may be exempted if Ecology

determines that they do not otherwise pose a threat to

public health or the environment. An entire class of

wastes may be excluded from regulation if all wastes in

that class: 1) Are not listed; 2) do no exhibit any

characteristics; and, 3) are not designated by the

state's criteria, or 4) if designated, do not otherwise

threaten public health or the environment.

The designation approach described above assures that all

federal wastes are properly designated and subject to the

applicable requirements. The state's approach is more

stringent than the federal approach in that more

considerations are taken into account for waste

designation (i.e., the state's criteria, and lower

quantity exclusion limits). Ecology has also provided

mechanisms to assure that any waste regulated at the

federal level will be subject to the same, or more

stringent consideration before it can be exempted from

regulation. The state's approach to designation

incorporates and complements all the elements of the

federal approach, thus assuring equivalency with (or, in

many cases, exceeding) the requirements of EPA .

Ecology includes procedures in Chapter 173-303 WAC for

identifying solid wastes.. These procedures are essentially identical to EPA regulations, with some exceptions

for materials that would not be federal solid wastes

(i.e., state standards are more stringent in some ways).

Ecology's requirements assure than any materials EPA

considers to be solid wastes will te controlled as solid

wastes by the state.

Ecology has continued to amend its lists of hazardous

wastes to include new federal listings. Listings include

wastes from the production of dinitrotoluene and

toluenediamine (K111, Kl12, K113, K114, and KIIS), wastes

from the production of toluene diisocyanate (KI16), and

discarded chemical products of o-Toluidine (U328) and

p-Toluidine (G3S3). The listings include related

additions to the Dangerous Waste Constituents List.

EPA's recent rules on mixtures of solvent wastes (the ten

percent rule) has already been addressed in state regulations, which are more stringent and do not set a

threshold on concentration. Any amount of any of the

listed solvents (FOOl through FOOS) in the listed waste

source designates the waste as hazardous under Ecology's

regulations .

Ecology has existing provisions in state law allowing it

to regulate mixed wastes containing hazardous components

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subject to the Resource, Conservation and Recovery Act

and radioactive components subject to the Atomic Energy

Act (AEA). RCW 70.105.145 states that "Notwithstanding

any other provision of Chapter 70.105 RCW, Ecology is

empowered to participate fully in and is empowered to

administer all aspects of the programs of the federal

RCRA•.• " Ecology's authority is thus equivalent to

EPA's, which generally regulates hazardous radioactive

wastes that do not otherwise meet the exemption for

"source, special nuclear or byproduct material as defined

by the AEA."

Generators. Persons generating dangerous waste will need

to prepare a manifest before sending the waste to a TSD

facility. The manifest includes information on the

generator, transporter, TSD facility, the type of waste,

an~ its quantity or volume. The manifest must be signed

by the generator and the transporter before the waste

leaves the generator's property. The manifest travels

with the transporter to the TSD facility, where the

facility owner/operator signs the manifest and returns a

copy to the generator. If the generator does not receive

a copy of the manifest, signed by the facility

owner/operator within 45 days or shipment, he must submit

an Exception Report to Ecology. When Ecology receives an

Exception Report for wastes designated on the manifest

for out-of-state shipment, then Ecology will notify

either EPA or the authorized state agency with

jurisdiction in the state designated for receiving the

waste. Ecology will, then, initiate a search for the

waste to determine its fate. Ecology is requiring that

after September 20, 1984 all dangerous waste shipments

shall utilize the Uniform National Manifest.

Generators will report annual~y to Ecology the quantities

and types of dangerous waste which were generated in the

past year, as well as any treatment, storage, recycling,

or disposal practices incorporated.

The manifest and annual reporting system will provide

Ecology with a means to track the generation, movement,

and ultimate disposition of dangerous wastes in

Washington. This system will reduce the amount of

uncontrolled dumping and illegal disposal of dangerous

waste which historically has posed a national public

health and environmental hazard.

Generators involved with international shipments are

subject to state requirements that are identical to the

pre-HSWA federal standards, except that copies of exception reports sent to EPA must also be sent to Ecology.

Ecology's regulations allow certain farmer's who manage

their pesticide wastes on their own land to be exempt

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from the generator requirements. To qualify for this

exemption. the farmer must either reuse his.pesticide

residues and rinse waters (e.g., in his next batch of

pesticide) or else manage these wastes according to the

pesticide label instructions. The label instructions

vary for each pesticide, but almost always call for the

farmer to spray the pesticide residues in a manner which

constitutes a useful purpose. For example, the farmer

may be instructed to spray certain herbicides or

pesticides along fence rows to control weed or insect

growth. or he may be instructed to apply his wastes to

certain fallow lands, which are specifically targeted by

the State Department of Agriculture. for controlling

weeds and pests while the land is fallow. In some rare

cases. a label may call for disposal or burial. If such

disposal or burial is done on the farmer's own land, then

Ecology will not regulate him as a generator. Disposal

of pesticide wastes elsewhere is subject to Ecology's

generator and other requirements.

Transporters. The regulation requires transporters to

comply with C.S. Department of Transportation (DOT) rules

under 49 eFR for hazardous materials and substances

transportation. Transporters are, also, responsible for

notifying authorities and assisting in cleanup operations

in the event of a spill or discharge of dangerous wastes

during transport. Ecology is requiring that after

September 20, 1984, all dangerous waste shipments shall

utilize the Uniform National Manifest (UNF). This will

assure that interstate shipments are in accordance with

DOT requirements. Until the UNF goes into effect,

Ecology does not expect (and so far has not encountered)

any problems with the interstate transport of wastes.

The requirements for transporters who import wastes from

outside the United States are identical to federal

requirements. Such transporter must act as the generator

of waste and comply with all applicable generator

requirements (e.g., manifesting, packaging).

Transporters who export wastes must comply with state

requirements that are identical to federal standards: 1)

Indicate on the manifest the date the waste left the

U.S.; 2) sign and date the manifest; and 3) retain the

manifest for three years.

New EPA standards for recycling hazardous wastes are

included in Ecology's regulations. including recycling

constituting disposal. precious metals recovery. battery

recycling, burning for energy recovery. and numerous

regulatory exemptions for certain recycling practices.

Ecology's recycling standards are virtually identical to

EPA's, with the exception of recycling provisions for

state-only dangerous wastes. Less stringent standards

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*

are applied to state-only wastes when they are stored for

short time periods prior to recycling.

Treatment, Storage, and Disposal (TSD) Facilities.

Ecology has essentially adopted EPA standards for the

siting, design, performance, operation, and maintenance

of TSD facilities. In general, these standards ensure

that a facility is properly performing whatever dangerous

waste storage, treatment, or disposal activities are

occurring at the facility.

TSD facilities must have adequate security, personnel

training, inspection schedules, emergency plans and

equipment, records of operation, environmental

monitoring, insurance, closure and post-closure plans,

and reporting before Ecology will grant a permit (or

interim status) to a facility.

Finally, TSD facilities must be sited and operated to

comply with floodplain, fault line, wetland, shoreline,

explosion and fire buffer zones, and monitoring zone

requirements. Any facility managing regulated reactive

wastes will, under state regulations, be handling at

least four hundred pounds. UFC Table 77-201, 1979

Edition, requires minimum distances for 400-500 pounds

of: 1) 320 feet from inhabited buildings; and 2) 130

feet from railways and highways. Larger quantities of

reactive wastes will require correspondingly larger

setback distances. Facilities are, also, required to

satisfy all applicable local, state, and federal laws

(such as local comprehensive plans, air and water

pollution laws, endangered species, etc.).

Ecology is adopting most of these regulations directly

from the EPA regulations. Others are modified to reflect

the differences between dangerous and extremely hazardous

waste management practices. The state rules achieve

EPA's requirements for equivalency.

Interim status standards for TSD facilities are cited in

WAC 173-303-400, and are an adoption by reference of

EPA's 40 CFR Part 265 Subparts F through R. EPA has

recently amended these standards, and Ecology has assured

that the state's reference is current by updating WAC

173-303-045. This section provides that any EPA regulations that are adopted by reference in Chapter 173-303

WAC will reflect federal rules, except those adopted

pursuant to the Hazardous and Solid Waste Amendments

(HSWA) of 1984, in place on July 11, 1986. Thus, recent

EPA changes to the interim status TSD facility requirements have been included in Chapter 173-303 WAC .

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• * Additionally, by updating,WAC 173-303-045, as above, the

corporate guarantee for liability insurance has been

included in Chapter 173-303 WAC.

In addition, Ecology has adopted stringent operating

standards for the extremely hazardous waste disposal site

at Hanford. The current status of Hanford is that the

land has been purchased from the federal government and

is waiting for funds to be allocated from the state

Legislature for its development.

*Due to charg~~ under Chapter 70.105.215 RCW, Ecology

included ad.: it i. -r.a 1 permit certification language for

situations where t~~ owner and operator of a TSD facility

are separate <:1'( i t Le s .

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5. Other Requ1r..rr.e r t s : The Dangerous Waste Regulation also

requires all per~uns who generate, transfer, transport,

treat, store. l'r d . s pos e of dangerous waste to have an

EPA/state :cit'~t i i i c a t Lon number (EPA/state IDII). Those

individua 1:-; r r-cu iring such a number must notify the state

of thei r act i '.: : :. e s before be ing issued a number. The

regulation, ~l,o. establishes procedural requirements for

permit app~::.t~i0~ and issuance, public involvement,

pe t Lt Lon i rg ~\:<,}~:: for changes and exceptions to the

r egul a t t ors , ',c:,;t~r;g, and sampling methods, and

c ond i t i o n. :,:- e x emp t Lon from the rules (recycling or

recovery ,,:' :,I~.•t e r r-us wastes, triple rinsing of

c on t a i n e r s , ,'r .. !

6. Ava i lab i Ii t', "r:' ormat Lon to the Public

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Ecology \;1'''''' :H('vlsions in state ~-" for disclosing

Lnfo rma t t .v- Ct,.,. public. Ecology's attorneys have

c e r t i f i v-: :~, .1;' ,,~~crney General's Statement that

* Ln f o r m.. t : ':', 1 S .j':,~ t l ab l.e to the public in a manner

equiva J,'-' t \ • ~,,," p r ov i s Lons of 40 CFR Part 2. Ecology

will ;;~ ',' :" r.''''p,':,ses in no more than twenty days (as

r equ i r «. " ... \ ',-',-)03-901), and, generally, in much

less t ; :~< I:" ' .• ~. ~ost information is generally

avail~~·. <" ~ublic without the need to submit a

formal' !' Jlsclosure (e.g., regulations, policy

state.... "· : IT,;-t ... (S, annual report summaries, press

r e Le as « • i ,,':' t ion, Ecology provides reasonable

assist ,:'" ; ,·r.;nns requesting information by helping

such ;)0" -: :., .. : :. fv the records sought and, where

ne c e s s a r '. , I. ;'::18 in the preparation of disclosure

request'· ,

Subject: ".;: -::...·:vemptions (see the Attorney General's

Stateffi~rt :~: ~~ ?rovides the fullest possible

d Lsc Lo su r c : •. \ r d s and information sought by the

public. :~::., ::,1_ r na t Lon is always provided free of

charge, ..... ~t!; :'•... x c e p t Lons , First, if extensive copying

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costs are involved, then a fee may be charged. Second,

if the information request involves significant costs

from manipulating existing information into new forms

(e.g., preparing brand new reports, conducting studies,

correlating computer-based data), then a fee may be

charged. The fees assessable under these two exceptions

can be waived or reduced if Ecology determines that

furnishing the information would be of primary benefit to

the public at large.

Ecology can deny requests for information (see Attorney

General's Statement). Denials will include statements of

applicable appeal procedures and statutes of limitations.

If a disclosure request is denied because a claim of

business confidentiality could not be resolved within the

twenty day response period specified in WAC 173-303-901,

then the response provided to the person requesting such

information will specify that failure to resolve the

business confidentiality claim is the cause of denial.

Revision of State Program. If Ecology revises its

program, it will contact EPA to determine what

modifications are necessary in the memorandum of

agreement, Attorney General's statement, or other

documents. Ecology will modify the documents, as

appropriate, and submit them to EPA for approval. At

this time, Ecology does not foresee any significant

program revisions, and does not expect to transfer any of

its authorized functions to any other state agencies.

If Ecology finds that it is necessary to amend state laws

or regulations due to EPA's promulgation of new

regulations, then the state will proceed as follows:

a. Statutory changes. Ecology will work with the state

Legislature and appropriate committees to develop

the necessary statutory language. The Washington

State Legislature meets every year, so changes to

state law should be accomplished within one year.

If the statutory changes are controversial, two

years may, in some rare cases, be necessary.

Ecology believes that amendments to state laws can

be provided in two years or less in all cases.

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b. Regulatory changes. Amendments to state regulations

will be made in accordance with Chapter 34.04 RCW,

Administrative Procedures Act, and will be accomplished in one year or less. Ecology will prepare

proposed regulatory language and confirm with EPA

that it will properly address the changes at the

federal level; this should require no more than two

months. Ecology will then file the proposed

language with the State Code Reviser for publication

in the State Register; this will require about two

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weeks. The first public hearings will be held

twenty days after the proposed amendments are

published. The public comment period may range from

thirty days to three months (but only this long if

significant changes are made and reproposal is

necessary). Ecology will then prepare final

amendatory language (less than one month) and file

the final changes with the Code Reviser. The new

regulation is effective thirty days after adoption.

Thus. simple amendments will take as few as three

months from beginning to the actual effective date.

More complicated changes may take as long as nine

months until the new rules go into effect.

Summary. As a summation. the amended Dangerous Waste

Regulation Chapter 173-303 WAC:

(1) Designates those solid wastes which are

dangerous or extremely hazardous to public health and the

environment;

(2) Provides for surveillance and monitoring of

dangerous wastes until they are detoxified. reclaimed.

neutralized, or disposed of safely;

(3) Provides a manifest system for tracking,

reporting, monitoring, recordkeeping, sampling, and

labeling of dangerous wastes;

(4) Establishes requirements for the siting,

design, operation, and monitoring of dangerous waste

management facilities;

(5) Establishes design. operation. and monitoring

requirements for managing the state's extremely hazardous

waste disposal facility;

(6) Establishes and administ~rs a program for

permitting dangerous waste management facilities: and

(7) Provides for enforcement against persons who

violate the requirements of the act and the Dangerous

Waste Regulations.

C. Lead Agency Identification. Agency Structure. Budget. and

Resource Assessment

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1. Agency Structure and Organizational Responsibility

Ecology is the state agency mandated by the Legislature

to administer the federally approved RCRA program. As

shown in Figure 1. Ecology is essentially organized along

functional lines with the Office of Operations and

Enforcement set up to act as the operating arm of the

agency. Each program functions under an appointed

Program Manager who reports to the Deputy Directors and

the Director of the Department. There are also several

exceptional program responsibilities which for management

reasons report directly to the Director. For purposes of

the Dangerous/Hazardous Waste Program within Ecology

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there are two organizational groups which have program

responsibilities. These are the Solid and Hazardous

Waste Program and the Office of Operations and

Enforcement.

The Solid and Hazardous Waste Program has authority and

primary responsibility for program planning, development,

and management of the state dangerous/hazardous waste

programs (Figure 2). This group is responsible for

establishing all program guidance and policy as well as

regulations. This group also provides technical

assistance to inspectors and permit writers in the

Regional Offices, Central Permits Section, and Industrial

Section. As well as coordinating compliance monitoring

activities and ensuring statewide consistency in the

application of the regulations. Most public involvement

aspects of the program are carried out in this office.

Any necessary tracking and reporting functions, including

the annual report, are also the responsibility of this

group.

The Office of Operations and Enforcement has the

authority and responsibility for all operational aspects

of the Dangerous/Hazardous Waste Program (Figure 3). The

office includes four geographical regions of the state

with an officer and staff located in each region. The

regions cover Southwest Washington, Northwest Washington,

Central Washington, and Eastern Washington. Each

regional office has a designated hazardous waste group.

This group is responsible for carrying out compliance

inspections, overseeing closure activities and writing

storage permits. They are the primary agency contact

with all generators, transporters, and some TSD

facilities. They also implement the agency enforcement

policy by documenting and making recommendations for

enforcement actions to their Regional Manager who has

signatory authority for all enforcement actions within

their jurisdiction. This group maintains a close working

relationship with the Solid and Hazardous Waste Program.

They use the guidance and policy provided by this program

and are responsible for completing the work plan

commitments negotiated by the Solid and Hazardous Waste

Program.

The Office of Operations and Enforcement also includes

the Central Operations Program. The following three

groups in Central Operations have dangerous/hazardous

waste responsibilities:

Industrial Section has major industries as their area of

responsibility (e.g., pulp and paper, oil refining, and

primary metals). This group acts essentially like a

fifth region. The group performs compliance inspections

and writes permits for most of their facilities.

II - 11
•

•

Hanford Section is responsible for all

dangerous/hazardous waste and hazardous waste cleanup

program activities at the Hanford Reservation.

Central Permits is a new group that was organized to

concentrate permitting expertise into one section. They

are responsible for or will be assisting on permits for

many of the more complex TSD facilities in the state.

The Central Permits group will be coordinating permit

activities, performing compliance inspections, as well as

writing permits at selected TSD facilities•

II - 12
Chll~t1I1r. Gr eqou e

M.•" I!IHH

CHART

ORGANIZATION

. --.....

Stevr HUlIlri

A\sist. Diu!clol

l.EGISI.A JIVE

AND INJER·

GOVERNMEN rAI.

AFFAIRS

E,d lowe' I\S51" ()lIP.Cll1J

MANAGEMEN J &

SUPPOR T SEnVIC[ S

MANAGEMENT~ SUPPORT SERVICES '; I -

Pall."" .~

PICHl'am Mdlltltlf ' (

Jim Pharris

F,p.d Otson

A~!d\t DUf!ctOI

LEGAL SERVICES

EXTERNAL AFFAIRS

Assist. Attorney Gener al

DIRECTOR

Figure 1

WASHINGTON STATE

DEPARTMENT OF

ECOL 0 GY

•

n

rilfl

R~911)nal Ma"agl~l

flllss l.tvlrll

CENTRAL REGION

EASTERN REGION

John AflllllJl"t-g"." - .

I ..__. ,.'

f

lPu-n 1~-t~:S'.- oPt RA 'U)lfS .. -

,OJ, ,.AI ,tot, OJ,

". • I •

!I",,·".'.' "' '." •

~~~",.,:, (11"'l ••.•. j. \ ..~.

Plllljl itlll M,1I1,IIJ"! '-"

...._.__.A.

NOR T1IWE S r IlEGION

PIll'll ,I III Mall"~lc,

Car ot rleskes

Nanrv f 111\11"

nf'~JiOlldl Molnaljp.f

1.INrf-4Al fU'III .... II()..

E

----·-_·_-_.._-

J ECIINICAl SF"VICES

I)lClI( Clltllltlltlh:llli

PIP(jI,IIH f'v1.lfI,H!I·'

____ .. _ l~ .,:,"~"""- I

i

e

NII"UAH WA';TI H.\'II\LI HI ~n

~,

t,~.~;;:.~ . .;:.. .. , --Vi

Ca,,,1 Jolly

Program Mall'ler

SHORElANDS III

COASTAl ZONE

MANAGEMENT

PROGRAM

Rod Mack

Proqram Manage'

WATER OlJAl.lTY

PROGRAM

t tedia Adelsman

Program Mall.ge,

WATER RESOURCES

PROGRAM

Siu Clark

Terry Huneman

P,og,am Manager

FINANCIAL

ASSISTANCE

Joe Williams

Program Manager

Phillip J()hn\nn

Ie

PROGRAMS

DEPUTY DIRECTOR

AIR PROGRAM

Proqr arn Manager

SOLID III HAZARDOUS

WASTE PROGRAM
SOLID & HAZARDOUS WASTE MANAGEMENT PROGRAM

Reaha Ander.en-CS]

Jim Bill-ell:

Vacant-C)

Vocont-CT2

..- -----r-·-----------] .- ... _-. ----- -'-, ~---

11(17orc.JOUS Waste Clean Up I

Polir:y & Plonninq Grants

Jerry Je.elt-f~

Conni. Keleey-SlOanSwonlon - [5

Vacant-eT2

---

------.-.----- • Clerical

Unit * Uelen Thu,..ton-S2

uo.i1yn We1pert-CTJ

Oorlene C'oIO-CTJ

Beltho Ponton-OJ

PROGRAM

MANAGER

Terry Hussemon

Voconl-SO

Vocont-EJ

• Waste Reduction ----------

&. Recycling *

Joy Shepo,d-[4

Ch,i, Chopmon-[P1

Vocont-[J

IH~II~O~:~;·- ··~;~:~~~;ii,:g -~...~.~ ....~. -~·~Ia~~;;~;:~;~::,n~=·~·- ..

1_ Tom [010n-[5 Lelohton P,otl-[5 10m Cook- I.~

- ._----- Vocon\-ET2 • Solid Waste

• Program :1:: AI '40nlon-- Sl] Development

* Voconl-[PJ Kir1l: Cook-HG)

Vorn Lloinz-S[J Rondy UOllln· [1'7

Uorl< ruchl -IIG2 Vocant -sr e Kore" Uir.heleno-·r.J

Chino -PI Wnno-HGJ Vocant "';E.:\

HuOh O'Noill-[2 • Recycling ,'~

Oovo Rounlry"·r J Liller Vocont-Sr2

Vocont-(J -]: Rrnl'j Ever son- I.

•Information Rhonda Hunter- f2

Support ond Veronica frnry-f2

Anaylsis

* Oan KrU';1or-[4 Steve Borrett- f2

Dove Soundor.-[] Dol. Cln.k-rJ

Ke,ry Slotlory-[2 • Ash Unit

Gloria Booudoin - ET2 ~~: Jim Knufhon - S(J

Shirley Clinton - n 1

Rebeece Voo,moo-·[2 • Program

Joee K.r,o,-·l.mp Inlo", Management

Vicki (;ill"9~·fenlp f'f,* l.or le .11I.I\t--fl"'.1

'f: l'ru Bullo,··[f'3

Denotes Unit Supervisor

Bonnie S1mm.-Temp cn

• UST Project * Thom Lulkln-(1'2

Koto Pete"en-[l

Jean Wotl-C2

Bill St,ouu-Admln In"Hn

All Rood- Sf 2

• Education &:

Information * Ulke ""moul-f4

Solly Tole"-(3

POOOy UO'90n -.[2

Terence 1()dd··PI01

Jnn tinQenfoll",· rJ

Vacant~· f.-'

vccent- f T]

lim Sclll,,"'1er· GO 1

• Planning

i~ Jim Sod'ol-·[PJ

Voconl·... [P2

Phil Clorlt:-[P7

Vocont--f2

',l11e. t<lmtr-fJ

Bill r..ftlln·-rp7

Dove Ollh'eun--F p, It S. Vrlcnnl· u-z V.lcanl ..... I"]

V~cont·-r,\

Wyn Ilnffmnn· [J

Untt Clart..-rp,

Uik. OrumnQhl··[2

")tevfIJ Robblns ...A,jmin Inl~,n

D<tvid Volbror.ht· lP2

• General Policy

k. Reg Development

:+: Rick IlolI-(PJ

Phylli. BooI-[]

Cud Oohlc;l'en-[P2

Jim ArlftBt-lemp [P2

Tony S_on.on-fP7

Vor.i')nt [P2

VOr'ont rr2

VOf;l')nl fP2

Vacant - 'emp r'1

• Tnchnicol Policy

k. Reg Development * vcccnl -.ff' 3

Bor b IfIJ~ther-£ 1

Don (J.ody-SEJ

Porn Jenj,jlns-Sr 2

SIeve Robb-[4

Voco nt-[P2

Lourie Doviel-Tflmp £1

Joan Pefley- Temp PI2

Bill Jolly-Temp [P3

• Budget &. Planning

*Voconl-[PJ

Dove Ho...ord-EP2

rd Hares - [P2

*

Avery W.III-S[J

Pete Hoskin-E)

Cortnne Cuse-[2

Allen Robbin.-(2

Dione Singer-[3

Pol Oico-[2

JuGe Woodl-U'J

lourol Hoifot2-TW

PolO- Oenllo* - ( 1

1I0bo Odum - (P'

Kathy $eel-EPJ

Vacant

SHWORQ.~

Apt 25. 1988

Figure 2

(e e •
Figure 3 OPERATIONS AND ENFORCEMENT

Hazardous Waste Staff

Deputy Director

....... J.__.._.._.... . _ Central

Operations

Proaram L __

r-' _-

I

I

l...

Howard Steeley

Kay Seller

Toby Mlchelena

Paul Stasch

Susan Milham

r

- - -----.

Southwest

-_.-1 Regional

I Office

Coordination - Gale Blomstrom

Eastern

Regional

Office

iCe~i~;IRegional

Office

JIm Maim

Deborah Cornett

Janice Brzoska

DennIs Bowhay

Hanford Section

Roger Stanley

Larry Goldstein

Mike Gordon

Joe Wltczak

Central Permits

TIm Nord

Cullen Stephenson

LIsa Garner

Dove Polivka

David South

Carol Knudson

Industrial Section

Dick Bur1<halter

Geroge Houck

Greg Bean

Marc Crooks

Don Kjosness

Ted Mix

Kim Anderson

Dove Davies

Kelly Ryan

Fred Fenske

[

_.._--_.. -._.-_.

Northwest --~ Regional

I Office

Julie Sellick

John Conroy

Laurance Ashley

. Barb Smith

ie e

Revised 7-19-88

•
2. Sources of Funding and Restrictions

In 1983 the State Legislature passed a bill establishing a

fee for generators and TSD facilities. Ecology developed

an administrative rule, Chapter 173-303 WAC, to implement

that bill. SUbsequently, the Legislature repealed this

"fee bill" and with it Chapter 173-305 WAC. Fees were

collected through 1986.

Estimated funding levels for Dangerous Waste Program

activities, from state and federal sources, are presented

in Table 1. These FY 1988 figures are estimates based on

past allocations.

Table 1

BUDGET ESTIMATE FOR THE DANGEROUS WASTE PROGRAM (1)

(1) Note: These figures do not include the Underground Storage •

Tank Program.

Fiscal Year

1988

Amount

Percent

Federal

Portion

$407,769

11%

State

Portion

$3,417,931

89%

Grand

Total

$3,825,700

100%

Major funding sources for the Dangerous Waste Program include:

* federal grants; * the state general fund; and

* the state toxics control account.

The state toxics control account is generated by a tax on

hazardous substances in Washington. The Legislature passed

this law (70.105b RCW) in November 1987.

11-16
• Table 2 profiles the resource allocation in Fiscal Year 1988

for the federal grant and state match. The federal grant

requires a 25% match from the state.

TABLE 2

Fiscal Year 1988 Dangerous Waste Staff

Federal/state Funded FTES

(75% fed, 25% state)

Region Name FTE Responsibility

Headquarters

THURSTON

CLARK,M

KRUGER

BEERY

0.13

0.11

0.51

0.47

Clerical

Program Plan/SEA

RCRIS

supervisor/HSWA authorization

Northwest Regional Office

VACANT 0.71

ASHLEY 0.49

• Southwest Regional Office

MICHELENA 0.49

Eastern Regional Office

CORNETT 0.13

Man"'~ester Lab

CARRELL 0.13

Hanford

WITCZAK 0.60

Total SEA/SGF FTEs 3.77

Federal Portion SEA 2.83

State Portion SEA 0.94

•

Permits

Inspections

Permits

Inspections

Chemist/Lab Analysis

Permits

II-17
.-

• Table 3 shows the positions dedicated to our dangerous waste

"state priorities".

TABLB 3

STATE FUNDED POSITIONS - State priorities

•

•

Total

Name

SACHET

KUNTZ

VACANT

GREEN

SCHLENDER

VACANT

VOERMAN

VACANT

AIR TOX ENG

LINGENFELTER

ROUNTRY

MORGAN

BURMARK

TOTEFF

VACANT

VACANT EP2-H2

GILLESPIE

FTEs

1. 00

1. 00

1. 00

1. 00

0.30

0.30

0.50

1. 00

0.33

0.20

1. 00

1. 00

1. 00

1.00

1. 00

1. 00

0.50

13. 13

Functions

state/local haz waste plans

State/local haz waste plans

State/local haz waste plans

state/local haz waste plans

Education/Public Information

Education/Public Information

Education/Public Information

Education/Public Information

Air pollution monitoring of HW

Education/Public Information

Agricultural Chemicals Mgt

Waste minimization

Waste minimization engineer

Household haz.waste planner

State/local haz waste plans

Haz. Waste Siting Criteria

Waste Minimization

II-18
• Table 4 profiles all other dangerous waste positions.

TABLB 4 RCRA RELATED POSITIONS

•

Region Name

Headquarters

HUSSEMAN

HAYNES

ANDERSEN

THURSTON

PONTON

SILVA

GARRETT

HEWITT

COOK

DRUMRIGHT

ROBBINS

HOFFMAN

CLARK,M

KRUGER

SAUNDERS

SLATTERY

BEAUDOIN

EATON

MEINZ

BEERY

MICHELENA

FUCHS

WANG

O'NEILL

VACANT

VACANT

VU

Subtotal Headquarters

FTEs

0.59

0.50

0.96

0.27

0.40

1. 00

0.20

0.39

0.33

0.10

0.40

0.70

0.87

0.46

1. 00

1. 00

1. 00

0.91

1. 00

0.23

0.50

1. 00

1. 00

1. 00

1. 00

1. 00

1. 00

18.83

Function

Program Manager

Haz. Waste Planning/Research

Clerical

Clerical

Clerical

Clerical

Clerical

Program planning/admin/budget

Program planning/admin/budget

Program planning/admin/budget

Program planning/admin/budget

Training

Program planning/admin/budget

Data management/tracking/RCRIS

Data management/tracking/RCRIS

Data management/tracking/RCRIS

Data management/tracking/RCRIS

Program policy/admin

Engineering/Technical Assist

Supervisor/regulatory devel

Regulatory devel/interpretation

Hydro-geo analysis/tech. assist

Hydro-geo analysis/tech. assist

Regulatory devel/interp.

Regulatory devel/interp.

Engineering/Technical Assist

Technical Resource Ctr.

•

Northwest Regional Office

CONROY

SELLICK

VACANT

ASHLEY

MASTERSON

WEIRICH

Vacant SE2

Vacant CHM2

VACANT

Vacant E3-H2

Vacant E3-H2

SMITH

Subtotal NWRO

1. 00

1. 00

0.50

0.51

0.30

0.20

1. 00

1. 00

0.29

1. 00

1. 00

1. 00

8.80

Haz. Waste Specialist

Haz. Waste Supervisor

Hydrogeology/tech assist

Inspector

Clerical

Clerical

Inspections/tech assist

Permits/tech assist

Permits

Permits

Permits

Inspections

11-19
•

•

TABLE 4 - Continued

Region Name

Southwest Regional Office

STEELEY

Vacant SE2

SEILER

STASCH

MILHAM

MICHELENA

HENDERSON

WARNER

Subtotal SWRO

Central Regional Office

PRATT

BOWHAY

HUWE

subtotal CRO

Eastern Regional Office

SAPPINGTON

MALM

BRZOSKA

CORNETT

WEBER

Subtotal ERO

Industrial

BURKHALTER

DAVIES

ANDERSON

FENSKE

CROOKS

HOUCK

MIX

VACANT CT3-H2

ARMY

Subtotal Industrial

FTEs

0.95

1. 00

1. 00

1. 00

1. 00

0.51

0.45

0.20

6.11

0.20

1. 00

0.20

1. 40

0.30

1. 00

1. 00

0.87

0.40

3.57

0.30

1. 00

0.80

0.10

0.10

0.10

0.10

0.50

0.30

3.30

Function

Hazardous Waste Supervisor

Permits/Inspections/Engineering

Inspector

Inspector

Inspector

Permits

Clerical

Clerical

Supervisor

Inspections/Technical Assist

Clerical

Supervisor

Supervisor/Inspections/Permits

Inspections

Inspections

Clerical

Supervisor

Permits/Inspections

Permits

Inspectors

Inspectors

Inspectors

Inspectors

Clerical

Clerical

11-20
- ;-. TABLE 4 - Continued

Region Name FTEs Function

Manchester Lab

HUNTAMER 0.50 Supervisor

ARAKI 0.40 Chemist/Sample analysis

KRAFFT 0.20 Chemist/Sample analysis

TWISS 0.40 Chemist/Sample analysis

SOLBERG 0.30 Chemist/Sample analysis

CARREL 0.37 Chemist/Sample analysis

McCALL 0.30 Chemist/Sample analysis

MIELENZ 0.20 Chemist/Sample analysis

KIRCHNER 0.20 Chemist/Sample analysis

Subtotal Lab 2.87

Central Operations

BLOMSTROM 0.90 Prog Plan/Tracking Sol/Haz Wst

Centralized Permits

NORD 1. 00 Supervisor/permits

• STEVENSON 1. 00 Permits

SOUTH 1. 00 Permits

GARNER 1. 00 Permits

POLIVKA 1. 00 Permits

KNUDSON 1. 00 Permits

Subtotal Cent. Perm. 6.00

Hanford

STANLEY 0.50 Supervisor/Permits

WITCZAK 0.40 Permits

VACANT 1. 00 Permits

VACANT E3 1. 00 Permits

Vacant E3-H2 1. 00 Inspector

Subtotal Hanford 3.90

Total RCRA-related 55.14

Grand Total stateFunded Haz.Waste FTE 67.72

•

II-21
--••

The new positions planned for 1989 are shown in Table 5a.

RCRIS (Resource Conservation and Recovery Information System)

is a comprehensive hazardous/dangerous waste data management

system that will be used by EPA and participating states.

Using the projected increase in funds from the Toxics Control

Act, we expect to hire over 50 new FTEs in the next three

years. As shown in Table 5b, the bulk of these new resources

will be committed to inspections, writing permits, and

enforcement/compliance duties.

TaJ)le 5 Fiscal Year 1989 Hazardous Waste Hires

Region Grade FTEs

Central operations

E3 0.50

Function

RCRIS

Northwest Regional Office

E3 1. 00

E3 0.50

Southwest Regional Office

E3 1. 00

E3 0.50 •

Central Regional Office

E3

Eastern Regional Office

E3

0.50

0.50

Inspections

RCRIS

Inspections

RCRIS

RCRIS

RCRIS

State Funded FY 89 4.50

state-Funded 88-9 Total 72.22

TaJ)le Sa

1990-91 Biennial Hazardous Waste Program Hiring (Estimated)

•

Function

Program Development

Permits

Inspectors

Enforcement

Training

Program Admin.

Clerical

Lab

1990-91 Estim. Hires

FY91 Program Total

TABLE 5 - Continued

FTEs

2.00

5.00

19.00

6.00

3.00

4.00

7.00

5.00

49.00

121.22

11-22
••

The FY 90-91 new FTE's are projected to be supported by the state

toxics account. These projected hires are contingent on:

the revenues in the toxic account actually growing

in accordance with projections;

the state toxics control account funds both our

hazardous waste management and cleanup programs.

Depending on the needs in the cleanup program next

biennium, we may be competing for funds.

An appropriation being made by the legislature

Table 6 is a summary of Dangerous Waste Program resources.

TABLE 6

WASHINGTON STATE

DANGEROUS WASTE PROGRAM

•

•

FY 1988

Federal funds

State funds

FY 1989 hires

FY 1989 FTEs

1990-91 hires

1991 Grand Tot,i 1

FTE Summary

FTEs

2.83

67.72

4.50

72.22

49.00

121.22

II-23

Comments

Includes 8 federally

funded FTEs
•

•

•

3. RESOURCE ASSESSMENT -- PROGRAM PLAN

Ecology's Fiscal Year 1988 Program Plan is shown in Table 7.

Program activities have been defined that reflect the mandated

duties of Ecology staff (RCRA priorities plus state

priorities). Each activity has a desired output. The FTE

level assigned to the acivities determine the effort that can

be made to achieve the desired outputs. In general, the more

FTEs assigned to an activity, the higher the priority.

11-24
••

DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN

SUMMARY SHEET

FUNCTIONAL CATEGORY FTE'S

July 29, 1988

A. PROGRAM PLANNING, MANAGEMENT, EVALUATION

16.39

B. PROGRAM DEVELOPMENT 2.25

C. PERMITTING & LISCENSING 2.65

D. COMPLIANCE MONITORING AND ------- ------

ASSURANCE

7.65

E. INCIDENT INVESTIGATION 1. 53

F. ENFORCEMENT 3.85

G. ENVIRONMENTAL MONITORING 2.93

H. ENGINEERING AND TECHNICAL -------11------

ACTIVITIES

6.72

•

I. PUBLIC EDUCATION AND

INFORMATION

J. GRANTS ADMINISTRATION

5.88

1. 23

K. CONTRACTS ADMINISTRATION 0.03

L. ENVIRONMENTAL REVIEW 0.07

M. SUPPORT SERVICES 4.27

N. EMERGING ISSUES AND

INITIATIVES

2.24

I 57. 691

I---~

DANGEROUS WASTE GRAND TOTAL --

•
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

0.16

0.33

0.01

0.03

0.05

0.07

0.10

0.05

0.20

0.01

0.02

0.00

0.05

0.03

0.06

Headquarters workload analysis model for FY 89.

Headquarters workload analysis model for FY 89.

Headquarters workload analysis model for FY 89.

resources.

Workload control and guidance of program

resources.

Workload control and guidance of program

resources.

Headquarters workload analysis model for FY 89.

Coordinate with central operations on region

workload analysis.

Implement unit spending according to allotments

Budget development activities for biennial and

supplemental budget requests.

Budget development activities for biennial and

supplemental budget requests.

Budget development activities for biennial and

supplemental budget requests.

Spending plans.

Monthly budget and FTE status report.

Monthly budget and FTE status report.

Workload control and guidance of program

IBudget preparation.

IManagement .

IBudget preparation.

IAcc~lish Budget Activities

IBudget preparation.

IManagement .

IBudget monitoring.

IBudget monitoring

IBudget monitoring

IManagement.

A.03.a.

A.04.

A.02.a.

A.02.a.

A.03.a.

A.04.

I I I ~E I ACTIVITY I . OUTPUT OR RESULT I FTE:

.. _-----_._._----_._------------------------------------_._-_.--------------_._._----_._----~._-_._----._-- - - - - - - - - - - - - - - A.Ol. Iprogram Plaming FY 89 Program Plan 0.05

A.Ol. IProgram Plaming FY 89 Program Plan 0.09

A.Ol. IProgram Plaming FY 89 Program Plan 0.09

A.Ol. IProgram Plaming Program plan. 0.10

A.Ol. Iprogram Plaming FY 89 Program Plan 0.02

A.01. Iprogram Plaming FY 89 Program Plan 0.06

A.01. IProgram Plaming FY 89 Program Plan 0.09

A.01. IProgram Plaming FY 89 Program Plan 0.13

A.Ol. Iprogram Plaming FY 89 Program Plan 0.06

A.Ol. Iprogram plaming. FY 1989 program plan. 0.05

A.Ol. Iprogram Plaming FY 89 Program Plan 0.01

A.02.a. IHeadquarters workload analysis model and time Headquarters workload analysis model for FY 89. 0.05

accOlllting.

IHeadquarters workload analysis model and time

accOlIlting.

IHeadquarters workload analysis model and time

accOIIlting•

IHeadquarters workload analysis model and time

accOlIlting•

IHeadquarters workload analysis model and time

account ing.

A.02.b. IRegional workload analysis.

A.02.a.

A.03.b.

A.03.b.

A.03.b.

A.04.

A.02.a.

••

A.04.

A.04.

IHanford management.

IManagement. Workload control and guidance of program

resources.

0.10

0.38

A.04.

A.04.

A.04.

••

IManagement - control and guidance of program

activities

IManagement .

IManagement.

IManagement.

IManagement.

Workload control and guidance of program

resources.

Workload control and guidance of program

resources.

Workload control and guidance of program

resources.

Workload control and guidance of program

resources.

0.10

0.30

0.01

0.20

0.19
DEPARTMENT OF ECOLOGY

DANGEROUS ~ASTE FY88 PROGRAM PLAN July 29, 1988

A.04. IManagement• 0.34

I I I

~~-_!._--------------_._ ..~~~~~~~~--------------------_.~._----_._----------~~~~-~.~~~~~._-----------_._-_!--~~~~------ A.04. IManagement. Workload control and guidance of program 0.02

resources.

Workload control and guidance of program

A.04.

A.04.

A.05.a.

A.05.a.

A.05.a.

A.05.a.

A.05.a.

A.05.a.

A.05.b.

A.05.b.

A.05.b.

A.05.b.

A.05.b.

A.05.b.

A.05.b.

A.05.b.

A.05.c.

A.05.c.

A.OS.c.

A.05.c.

A.05.c.

A.05.c.

A.05.c.

A.05.c.

A.05.c.

A.05.c.

A.05.c.

A.05.c.

A.05.c.

A.05.e.

A.05.e.

A.05.e.

•

e.

0-

A.05.e.

IManagement.

IManagement.

IAttend EPA sponsored training.

IAttend EPA sponsored training.

IAttend EPA sponsored training.

IAttend EPA sponsored training.

IAttend EPA sponsored training.

IAttend EPA sponsored training.

IHazardOus waste training program.

IHazardOus waste training program.

IHazardous waste training program.

IHazardous waste training program.

IHazardous waste training program.

IHazardous waste training program.

IHazardous waste training program.

IHazardous waste training program.

IHazardous waste training program.

IAttend internal training for hazardous waste.

IAttend internal training for hazardous waste.

IAttend internal training for hazardous waste.

IAttend internal training for hazardous waste.

IAttend internal training for hazardous waste.

IAttend internal training for hazardous waste.

IAttend internal training for hazardous waste.

IAttend internal traInIng for hazardous waste.

IParticipate in internal hazardous waste training

IAttend internal training for hazardous waste.

IAttend internal training for hazardous waste.

IAttend internal training for hazardous waste.

IAttend internal training for hazardous waste.

IAttend conferences/workshops and training courses.

IAttend conferences/workshops and training courses. I

IAttend conferences/workshops and training courses. I

IAttend conferences/workshops and training courses. I

IAttend conferences/workshops and training courses. I

resources.

Workload control and guidance of program

resources.

Guidance of program resources and outputs.

Attend EPA sponsored training.

Attend EPA sponsored training.

Attend EPA sponsored training.

Attend EPA sponsored training.

Attend 2 EPA sponsored training sessions.

Attend EPA sponsored training.

~aste prevention/new technology.

Regulation changes training.

HCIC workshop.

General training.

Train unit staff.

HCIC workshop.

General training.

1. Maintain training system. 2. Develop "new"

H.~. employee reference manual. 3. Develop

curriculun.

1. Maintain training system. 2. Develop "new"

H.~. employee reference manual. 3. Develop

curriculun.

Attend training.

Attend training.

Attend training.

Attend training.

Attend training.

Attend training.

Attend training.

Attend training.

Attend training.

Attend training.

Attend training.

Attend internal training.

Develop training plan and attend traInIng based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

0.05

0.10

0.01

0.02

0.01

0.03

0.02

0.06

0.05

0.03

0.01

0.01

0.09

0.04

0.05

0.40

0.10

0.05

0.01

0.02

0.02

0.08

0.01

0.07

0.05

0.10

0.12

0.02

0.01

0.02

0.05

0.14

0.09

0.10

0.05
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

_~ I I I

E I ACTIVITY . I OUTPUT OR RESULT I HE:

- --_._----------------------------._-------------------_.------_.--------------------------------------------------------------

A.OS.e. IAttend conferences/workshops and training courses. I

A.OS.e. IAttend conferences/workshops and training courses. I

A.OS.e. IAttend conferences/workshops and training courses. I

A.OS.e. IAttend conferences/workshops and training coor ses . I

A.OS.e. IAttend conferences/workshops and training cour\e\ . I

A.05.e. IAttend conferences/workshops and training courses. I

A.05.e. IAttend conferences/workshops and training courses . I

.e. IAttend conferences/workshops and train;nQ coo.-C'ie<;.

A.OS.e. IAttend conferences/workshops and train,,'>; c~r<;es . I

A.05.f.

A.05.g.

A.06.

A.06.

A.06.

A.06.

A.06.

A.06.

A.06.

A.06.

A.06.

A.07.a.

IConduct in-house H.W. training

ITraining Coordination

IPerfonm supervisory activities

·IPerfonm supervisory activities

IPerfonm supervisory activities

IPerform supervisory activities

IPerform supervisory activities

IPerform supervisory activities

IPerfonm supervisory activities

IPerfonm supervisory activities

ISupervisory activities.

IPerformance audits

IPerformance audits

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and indiv;dual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

Develop training plan and attend training based

on available courses and individual CQ's for

continued employee develop.

7-10 training sessions

Process forms

Staff hiring, guidance, training, evaluation and

workload control.

Staff hiring, guidance, training, evaluation and

workload control.

Staff hiring, guidance, training, evaluation and

workload control.

Staff hiring, guidance, training, evaluation and

workload control.

Staff hiring, guidance, training, evaluation and

workload control.

Staff hiring, guidance, training, evaluation and

workload control.

Staff hiring, guidance, training, evaluation and

workload control.

Staff hiring, guidance, training, evaluation and

workload control.

Evaluations, staff hiring, job training,guidance,

and workload control.

"id-year audit report of headquarters and

regional implementation of planned activities.

"id-year audit report of headquarters and

0.10

0.05

0.07

0.23

0.19

0.10

0.05

0.04

0.05

0.05

0.15

0.06

0.06

0.11

0.07

0.10

0.14

0.05

0.07

0.25

0.03

0.01
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

A.07.a.

A.07.a.

A.07.a.

A.07.a.

A.07.a.

A.07.b.

A.07.b.

A.07.b.

A.07.b.

A.OS.a.

A.OS.b.

A.OS.b.

A.OS.b.

A.OS.b.

A.OS.b.

A.OS.b.

A.OS.b. •

:

A.OS.c.

A.09.a.

A.09.b.

A.09.c.01.

A.09.c.01.

A.09.c.01.

A.09.c.01.

A.09.c.02.

A.09.c.02.

A.09.e.

A.09.e.

A.09.e.

A.10.

A.10.a.

A.10.a.

A.10.a.

A.10.b.

I

·c.

d.

A ..d.

A.10.d.

IPerformance audits

IPerformance audits

IPerformance audits

IPerformance audits

Iperformance audits

IEPA audits and mid-year review.

IEPA audits and mid-year review.

IEPA audits and mid-year review.

IEPA audits and mid-year review.

IRCRA information system (RCRIS).

100tput reporting.

100tput reporting.

100tput reporting.

100tput reporting.

100tput reporting.

100tput reporting.

100tput reporting.

100tput reporting .

IMaintain reporting.

ITrack local solid and. hazardous waste planning

activities

ISEA preparation.

ISEA Revisions

IQuarterly compliance meetings.

IQuarterly compliance meetings.

IQuarterly compliance meetings.

IQuarterly compliance meetings.

IProvide support for or attend quarterly

compl iance meetinss ,

IProvide support for or attend quarterly

compliance meetings.

IAttend meetings with EPA.

IAttend meetings with EPA.

IAttend meetings with EPA.

Ilegislative Activities.

IFiscal notes, bill analysis.

IFiscal notes, bill analysis.

IFiscal notes, bill analysis.

Ilegislative tracking/clearinghouse.

IConduct legislative briefings.

Ilegislative/regulatory response activities.

ILegislative/regulatory response activities.

ILegislative/regulatory response activities.

regional implementation of planned activities.

Mid-year audit report of headquarters and

regional implementation of planned activities.

Mid-year audit report of headquarters and

regional implementation of planned activities.

Mid-year audit report of headquarters and

regional implementation of planned activities.

Mid-year audit report of headquarters and

regional implementation of planned activities.

Mid-year audit report of headquarters and

regional implementation of planned activities.

Audit reports of SEA commitments.

Audit reports of SEA commitments.

Audit reports of SEA commitments.

Audit reports of SEA commitments.

RCRIS.

Reports.

Reports.

Output reporting (3 per quarter)

Reports.

Reports.

Reports.

Reports.

Reports.

Output reporting.

Develop PC automation system

FY 89 SEA

As needed

Prepare for/attend meetings.

Prepare for/attend meetings.

Prepare for/attend meetings.

Prepare for/attend meetings.

Support for quarterly compliance meetings.

Support for quarterly compliance meetings.

Meetings attended.

Meetings attended.

Bill anal ysis.

Prepare analysis of proposed legislation.

Prepare fiscal notes, bill analysis, technical

assistance, and testimony for 10 bills.

Prepare fiscal notes, bill analysis, technical

assistance, and testimony for 40 bills.

Provide bill tracking service on all program

related legislation (40 to 50 bills)

10 briefings

Responses.

Responses.

Responses.

0.15

0.01

0.06

0.00

0.21

0.07

0.01

0.01

0.07

0.15

0.01

0.01

0.09

0.07

0.02

0.01

0.03

0.04

0.05

0.15

0.22

0.02

0.01

0.02

0.02

0.02

0.02

0.01

0.00

0.02

0.05

0.05

0.01

0.11

0.08

0.10

0.02

0.03

0.03

0.04
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

0.20

0.08

0.09

0.10

0.21

0.03

0.02

0.06

0.02

0.04

0.06

0.09

0.01

0.03

0.01

0.06

0.05

Training committee membership

State waste management plan

State waste management plan

Capacity needs inventory data analysis and

support.

PDU support activities.- Capacity needs inventory.

Waste generation forecast data analysis and

support.

Prepare, review, adopt final plan

PDU support activities.- Waste management

priority plan.

Waste generation forecast

Public participation plan

Final location standards

Negotiation process

A.15.a.

A.14.

A.14.

A.14.

A.14.

A.15.a.

A.12.e.

A.12. f.

A.13.

A.16.

A.16.

A.16.a.

A.16.a. IState hazardous waste nngt. plan

A.16.a. IState hazardous waste nngt. plan

A.16.a. IState hazardous waste nngt. plan

A.16.a. IState hazardous waste mgt. plan

•• IState hazardous waste nngt. plan

IState hazardous waste nngt. plan

... .a. IState hazardous waste nngt. plan

A.16.a. IState hazardous waste nngt. plan

1!JJi.'

~.

I I I

- ~~--~--_..._._._._-----_ ..~~~~~~~~---_ .._----_._._----._~---_._-_ .._--------~~~~-~.~~~~~_._--------- I-_~~~:_._. __ A.11. IStaff meetings. Staff meetings. 0.10

A.11.a. IConcb:t and attend staff meetings. 24 per year. 0.08

A.11.a. IConcb:t and attend staff meetings. Staff meetings attended. 0.02

A.11.a. IConcb:t and attend staff meetings. Meetings. 0.02

A.ll.a. IConcb:t and attend staff meetings. Staff meetings attended. 0.41

A.11.a. IConcb:t and attend staff meetings. 50 per year. 0.03

A.l1.a. IConcb:t and attend staff meetings. Meetings. 0.14

A.11.a. IConcb:t and attend staff meetings. 60 meetings. 0.01

A.l1.a. IConcb:t and attend staff meetings. Staff meetings attended. 0.02

A.11.a. IConcb:t and attend staff meetings. Staff meetings attended. 0.05

A.11.a. IConcb:t and attend staff meetings. Meetings. 0.01

A.11.a. IConcb:t and attend staff meetings. Meetings. 0.04

A.11.a. IConcb:t and attend staff meetings. Meetings. 0.04

A.11.a. IConduct and attend staff meetings. Meetings. 0.02

A.ll.a. IConcb:t and attend staff meetings. 0 0.31

A.11.a. IConcb:t and attend staff meetings. 0 0.05

A.11.a. IConcb:t and attend staff meetings. 0 0.05

A.11.c. IConduct and attend other meetings. Meetings attended. 0.08

A.11.c. IConduct and attend other meetings. Meetings attended. 0.01

A.l1.c. IConduct and attend other meetings. Meetings attended. 0:04

A.12.a. IHW notifications. Notifications (200 per quarter). 0.28

A.12.a. IHW notifications. Notifications (200 per quarter). 0.03

A.12.b. IHWamual reports. Reports (2000 3rd qtr; 1000 4th qtr). 0.45

IHW annual reports. Reports (2000 3rd qtr; 1000 4th qtr) . 1.03

IHW biennial report data collection. HW biennial report data collection. 0.05

IHW annual report. Report (1). 0.12

IHW fee assessment/collection. HW fee assessment/collection (600). 0.43

lUST notifications. UST notifications (50 per quarter). 0.18

Iprepare, manage and coordinate operating grants Anticipate 3 grants and contracts outside of the 0.06

and contracts. SEA.

ICoordinate RCRA activities with other offices. Coordination.

[ccordinate RCRA activities with other offices. Coordination.

ICoordinate RCRA actlvlt1es with other offices. Coordination.

ICoordinate RCRA activities with other offices. Coordination.

IAssociation of State and Territorial Solid Waste Training committee membership

Management Officials (ASTSWMO).

IAssociation of State and Territorial Solid Waste

Management Officials (ASTSWMO).

IDevelop State Waste Management Plan

IDevelop State Waste Management Plan

IState hazardous waste nngt. plan
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29. 1988

0.09

0.31

0.01

0.01

0.01

0.02

0.02

0.02

Intra program coordination (includes superfund).

Intra program coordination (includes superfund).

HW coordination with other agency programs

HW coordination with other agency programs

HW coordination with other agency programs.

HW coordination with other agency programs

HW coordi nat ion wi th other agency programs

Intra program coordination (includes superfund).

A.17.

A.17.

A.17.

A.17.

A.17.

A.17.

A.17.

A.17.

" I I I

AooE I ACTIVITY I . OUTPUT OR RESULT I FTE:

-~-----_._ .. _.._-_...._._._------------_._---------_.-----_._---------------------------------~-------------------------_._--- A.16.a. IState hazardous waste mngt. plan I Waste management priority plan I 0.23

A.16.a. IState hazardous waste mngt. plan I Capacity needs inventory I 0.23

A.16.a. IState hazardous waste mngt. plan I Siting policies . I 0.17

A.17. ICoordinate hazardous waste activities with other I Intra program coordination (includes superfund). I 0.12

programs.

ICoordinate hazardous waste activities with other

programs.

ICoordinate hazardous waste activities with other

programs.

ICoordinate HW activities with other programs

ICoordinate HW activities with other programs

ICoordinate HW activities with other programs.

ICoordinate HW activities with other programs

ICoordinate HW activities with other programs

ICoordinate hazardous waste activities with other

programs.

Grand Total 16.39

•

•
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN Jul y 29, 1988

o. I I I

e COOE I ACTIVITY I OUTPUT OR RESULT I FTE:

.._------------_._.-._.._._-------...-... _------._.-------------------------------------_._-----------------------------------

B.01.8.

B.01.a.

B.01.a.

B.01.8.

B.01.8.

B.01.a.

B.01.a.

B.01.a.

B.01.b

B.01.b.

B.01.b.

B.01.e.

B.01.e.

B.01.g.

B.02.c.

B.02.c.

B.02.d.

B.02.e.

B.03.a

B.03.a.

B.03.a.

B.03.a.

B.03.a.

B.03.a.

B.03.a.

B.03.a.

B.03.c.

B.03.c.

B.04.

B.04.

B.04.

B.04.

B.04.

a.cs.e.

s.es.s.

I c.

c.

..... .a.

B.06.a.

IDevelop/revise core-RCRA regulations and

amnet dnet ItS.

IRCRA base program.

IDevelop/revise core-RCRA regulations &amendments

IDevelop/revise core-RCRA regulations &amendments

IDevelop/revise core-RCRA regulations and

amnet dnents.

IDevelop/revise core-RCRA regulations and

anmet dnents.

IDevelop/revise core-RCRA regulations &amendments

IDevelop/revise core-RCRA regulations &amendments

IDevelop/revise HSWA regulations

IDevelop/revise regulations for HSWA.

IDevelop/revise regulations for HSWA.

IPriority waste.

IPriority waste.

IFinal HW location standards.

IWaste reduction and recycl ing pol icy.

IWaste reduction and recycl ing pol icy.

IAgricultural waste.

IDevelop PWM policies.

IDevelop PWM policies.

Iprogram Development - develop program to revise

and approve local governments hazardous waste

management plans.

IHazardous waste planning.

IHazardous waste planning.

IHazardous waste planning.

IHazardous waste planning.

IHazardous waste planning.

IHazardous waste planning.

IHazardous waste planning.

IDevelop/revise procedures and guidelines.

IDevelop/revise procedures and guidelines.

IDevelop Agency Request Legislation.

IDevelop Agency Request Legislation.

IDevelop Agency Request Legislation.

IDevelop Agency Request Legislation.

IDevelop Agency Request Legislation.

ICore RCRA authorization.

ICore RCRA authorization.

IHSWA authorization.

IHSWA authorization.

IRCRA.

IRCRA.

Plbl ie disclosure ametdnents per EPA

RCRA base program regulation revision.

Regulation review and simplification project

Plblic disclosure amendments per EPA

Core-RCRA changes

Core-RCRA changes

Regulation review and simplification project

Plblic disclosure amendments per EPA

Regulations.

Include HSWA-based regulations.

Include HSWA-based regulations.

Priority waste regulations.

Priority waste regulations.

Final HW location standards.

Policy on RCRA solid waste and hazardous waste

definitions.

Policy on RCRA solid waste and hazardous waste

definitions.

Agricultural waste policies.

Plan for PWM activities startup; SWAC

recommendations to Legislature.

Plan for PWM activities startup; SWAC

recommendations to Legislature.

Procedures for approving local hazardous waste

plans

Local H.W. plan approval and LOI procedure

Local H.W. planning and zoning waivers

Pre-emption of local T and S approval procedure

State Preemption on HW Land Disposal and

Incineration

Local HW Planning Grant Policies and Priorities.

State development of local plans procedure

Citizen-proponent negotiation procedure

Simplified inspection checklist and inspection

report guidance.

Simplified inspection checklist and inspection

report guidance.

Legislation.

Legislation.

Legislation.

Legislation.

Request legislation prepared for the 1988 session.

Core RCRA authorization maintenance activities.

Core RCRA authorization maintenance activities.

HSWA authorization planning activities.

HSWA authorization planning activities.

RCRA strategies

RCRA strategies.

0.02

0.01

0.09

0.01

0.02

0.02

0.08

0.02

0.10

0.01

0.01

0.10

0.05

0.02

0.05

0.05

0.19

0.10

0.10

0.05

0.07

0.04

0.02

0.05

0.07

0.12

0.03

0.03

0.03

0.06

0.06

0.06

0.06

0.06

0.01

0.05

0.01

0.01

0.02

0.02
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN

""- I ~E I ACTIVITY .

~=~_. __ ._-------_.__ ._-------_._--------------------------

OUTPUT OR RESULT

July 29, 1988

HE:

B.06.b.

B.06.b.

B.07.

B.07.

B.07.

B.07.

B.07.

B.07.

B.07.

B.07.

B.08.

B.08.

B.08.

B.09.

B.09.

IHSWA.

IHSWA.

IReview and comnent on major regulations

IReview and comnent on major regulations.

IReview and comnent on major regulations

IReview and comnent on major regulations.

IReview and comnent on major regulations.

IReview and comnent on major regulations.

IReview and comnent on major regulations.

IReview and comnent on major regulations.

IReview and comnent on proposed regulations.

IReview and comnent on proposed regulations.

IReview and comnent on proposed regulat ions.

IReview and comnent on TIMs/RIMs.

IReview and comnent on TIMs/RIMs.

HSWA strategies.

HSWA strategies.

Review/comnent on rules proposed by Ecology

Comnents provided.

Review/comnent on rules proposed by Ecology

Comnents provided.

Review/comnent on EPA regulations

Comnents provided.

Review/comnent on EPA regulations

Comnents provided.

Comments provided.

Comments provided.

Comnents provided.

Comments provided.

Comments provided.

0.03

0.01

0.01

0.02

0.02

0.01

0.02

0.02

0.02

0.02

0.03

0.03

0.01

0.01

0.01

Grand Total 2.25

•

•
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

0.00

0.16

0.02

0.03

0.02

0.02

0.35

0.15

0.27

0.18

0.29

0.10

0.05

0.09

0.45

FMPs developed, reviewed, revised and/or approved.

FMPs developed, reviewed, revised and/or approved.

FMPs approved, reviewed, revised.

FMPs developed, reviewed, revised and/or approved.

Washington Chemical.

FMPs developed, reviewed, revised and/or approved.

Hytek, SeaFab

Texaco, Mobil, ARCO, Shell

Sol-Pro Lillyblad

NW Enviroservice, Crosby &Overton

ESC-Rabanco

Cameron Yakima, Yarl, Masco

Chempro . Lucille St; Chempro - Pier 91.

occidental

C.01.f.

C.01.b.

C.01.a.

C.01.f.

C.01.g.

C.01.e.

C.01.d.

C.01.d.

C.01.d.

C.01.d.

C.01.e.

C.01.c.

C.01.f.

C.01. f.

I I I

~E I ACTIVITY I OUTPUT OR RESULT I FTE:

1IIIIl··--------------------------------------------------------------------------------------------------------------------------

C.01.a. Iprocess Part B Land Disposal Pennits <operating I Bay Chemical I 0.47

only).

Iprocess Part B Land Disposal Pennits <operating

only).

Iprocess Pert B Land Disposal Pennits <operating

only).

Iprocess Land Disposal Closure/Post Closure

Pennits.

Iprocess pennit modifications for treatment

enhancement.

Iprocess additional pennitting priorities.

Iprocess additional pennitting priorities.

Iprocess additional pennitting priorities.

Iprocess additional pennitting priorities.

Iprocess pennits for new hazardous waste treatment

or recycling facilities.

IApprove/review/revise/prepare hazardous waste

facility management plans (FMPs).

IApprove/review/revise/prepare hazardous waste

facility management plans (FMPs).

IApprove/review/revise/prepare hazardous waste

facility management plans (FMPs).

IApproveireview/revise/prepare hazardous waste

facility management plans (FMPs).

IApprove/review/revise/prepare hazardous waste

facility management plans (FMPs).

ICall new part Ss.

e·

Grand Total 2.65

••
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

0.14

0'.24

0.25

1.00

1.00

0.00

0.97

1.08

0.01

0.24

0.20

0.24

0.20

0.06

0.08

0.17

0.30

0.15

0.06

0.17

0.29

0.30

0.20

o

IPCo, OCcidental, McClary Columbia

N:W alloys (state only), Commonwealth (state only)

Cameron

1 TSDs inspected

3 TSDs inspected

5 TSOs inspected

TSDs inspected. Intalco(RCRA)

TSOs inspected. Intalco(RCRA)

5 inspections.

8 inspect ions.

8 generators

PCB inspections.

PCB inspections.

1 TSO inspection.

32 inspections; 16 G/T; 6 NN; 10 01

54 inspections; 20 G/T; 18 NN; 16 01

1 investigation

12/NN/ 3 Gen; 3 SEA generators

Technical assistance and guidance to local

projects. Start-up of 2-5 local plans.

8 inspections.

IPerform TSO inspections of land disposal

facilities with GW.

IPerfonn TSO inspections of land disposal

facilities with GW.

IPerfonn TSO inspections of land disposal

facilities with GW.

IHanford compliance monitoring.

IPerform biennial inspections of TSOs.

IPerform biennial inspections of TSOs.

IPerfonn biennial inspections of TSDs.

IPerfonn biennial inspections of TSDs.

IPerfonn four generator inspections.

IPerfonm biennial inspections of TSDs.

IPerfonn inspections of generators for SEA (target

> 1000 kg/month).

IPerform inspections of generators for SEA (target

> 1000 kg/month).

IPerfonn inspections of generators for SEA (target

> 1000 kg/month).

IAdditional state inspections.

IPerform inspections of firms handling PCBs.

IPerform inspections of firms handling PCBs.

IPerform inspections on additional state TSDs.

IPerform inspections in additional state G/Ts.

IPerform inspections of additional state G/Ts.

IInvestigate non-notifiers.

Iinvestigate non-notifiers/Generators

IComments and approvals of local hazardous waste

plans, evaluation and ranking of local applic.,

project design assist.

IFormal agency comments and approvals on H.W.

plans, zoning,H.H.W. petitions.

D.01.e.

D.01.e.

D.01.b.

D.01.b.

D.01.b.

D.01.c.

D.01.c.

D.01.c.

D.01.c.

D.01.c.

D.01.c.

D.01.e.

D.02.a.

D.01.f.

0.01.9.

D.01.b.

*.

~';.

0.01. i.

D.01.j.

0.01. j.

0.02.

,~ I I I

AcooE I ACTIVITY I . OUTPUT OR RESULT I FTE:

~~-~------_._._----------_._-----------_._------------ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - D.01.a. IHanford CME's I Solar evapo. basins; 300 area trenches; low-level I 0.30

burial grCUlCls.

Bay Zinc, Firing Center

Grand Total 7.65

•
DEPARTMENT OF ECOLOGY

DANGERClIS WASTE FY88 PROGRAM PLAN July 29, 1988

0.18

0.14

0.06

0.06

0.11

0.13

0.05

0.23

0.14

0.09

0.17

3 investigations.

19 investigations.

15 investigations.

responses,

responses,

responses,

27 phone

30 phone

10 phone

Ilnvestigate spills.

Ilnvestigate spills.

Ilnvestigate contaminated sites.

IInvestigate contaminated sites.

Ilnvestigate spills.

Ilnvestigate spills.

Ilnvestigate complaints.

Ilncident Investigation

Ilnvestigate complaints.

Ilnvestigate complaints.

Ilnvestigate complaints.

E.02.

E.01.

E.01.

E.02.

E.02.

E.02.

E.03.

E.03.

E.03.

E.03.

E.03.

-- I I I

. • CODE I ACTIVITY I . ClITPUT OR RESULT I FTE:

-------------_.--------------------------------------- - - - - - - - - - - - - - - - _ . - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - -

E.01. Ilnvestigate contaminated sites. I 6 investigations, 2 GW investigations, 1 I 0.17

enforcement.

5 investigations, 2 GW investigations,

enforcement.

2 investigations, 0 GW investigations,

enforcement.

25 phone responses, 5 field responses, 5

followups.

12 phone responses, 12 field responses, 6

followups.

o phone responses, 4 field responses, 2 followups.

6 phone responses, 2 field responses, 2 followups

45 phone responses, 7 investigations.

Grand Total 1.53

•

•
DEPARTMENT OF ECOLOGY

DANGEROUS ~ASTE FY88 PROGRAM PLAN July 29, 1988

.- I I I

e COOE I ACTIVITY I OUTPUT OR RESULT I HE:

----------------_._----------------------------------------------------------.----------------------_._-----_._--------------

F.01.a.

F.01.a.

F.02.a.

F.02.a.

F.02.a.

F.02.a.

F.02.a.

F.02.a.

F.02.a.

F.03.a.

F.03.a.

F.03.a.

F.03•••

F.03.a.

F.OS.a.

F.OS.a.

F.OS.a.

F.OS.a.

F.OS.a.

F.OS.a.

F.OS.a.

F.00.a.

.46.~: W:.

F.07.a.

F.08.a.

F.OS.a.

F.08.a.

F.08.a.

F.08.a.

F.09.a.

F.09.a.

F.09.a.

F.09.a.

•

ICompliance letter followup.

Iissue compliance/warning letters - Hazardous

Waste.

Iissue administrative orders.

Iissue administrative orders.

Iissue administrative orders.

IHanford enforcement

Iissue administrative orders.

IHazardous Waste

Iissue administrative orders.

Iissue penalties.

Iissue penalties.

Iissue penalties.

IIssue penalties.

Iissue penalties.

IHazardous ~aste.

IHazardous ~aste.

IHazardous ~aste.

IHazardous ~aste.

IHazardous ~aste.

IHazardous Waste.

IHazardous ~aste.

IHazardous waste.

IHazardous ~aste .

IDevelop consent orders/decrees-Hazardous Waste.

IDevelop consent orders/decrees-Hazardous Waste.

IDevelop consent orders/decrees-Hazardous Waste.

IHazardous Waste.

IHazardous Waste.

IHazardous Waste.

IHazardous Waste.

IHazardous ~aste.

IProvide support for administrative hearings.

IProvide support for administrative hearings.

IProvide support for administrative hearings.

IProvide support for administrative hearings.

5 followps.

Review HW actions and enter data.

2 orders &followups, 1 amendment

4 orders &followup

16 orders &followups, 4 amendments

4 orders, followups, &amendments

Review HW actions and enter data.

4 order &followup

2 penalties

1 penalty &followup

18 penalty &6 followup

6 penalty &followup

1 penalty &followup

2 PCHB appeals.

1 PCHB appeal.

4 PCHB appeals.

HW fees appeal support.

Support for PCHB appeals.

1 PCHB .appeal.

Support for PCHB appeals.

Support for court actions.

Support for court actions.

2 orders, 2 followups, 1 amendments.

1 orders, 1 followups, a amendments.

1 orders, 0 followups, a amendments.

1 hearing.

2 hearings.

Assistance on criminal enforcement.

Assistance on criminal enforcement.

Assistance on criminal enforcement.

4 hearings.

2 hearings.

1 hearing.

1 hearing.

0.05

0.04

0.09

0.14

0.63

0.20

0.19

0.03

0.14

O.OS

0.03

0.49

0.22

0.03

0.09

0.02

0.1S

0.02

0.01

0.03

0.05

0.01

0.01

0.25

0.12

O.OS

0.03

0.07

0.05

0.07

0.13

0.18

0.05

0.02

0.05

Grand Total 3.85
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

- I I I

eCOO E I ACTIVITY I OUTPUT OR RESULT I FTE:

-------_._.---._._----------------------._-----------------------------------------------------------------------------------

G.Ot.

G.01.

G.01.

G.02.

G.02.

G.03.

G.03.

G.03.

G.04.

G.04.

G.04.

IConduct tests for designation of hazardous wastes.

IConduct tests for designation of hazardous wastes.

IConduct tests for designation of hazardous wastes.

IConduct tests on groundwater samples.

IConduct tests on groundwater samples.

IProvide technical interpretation of hazardous

waste laboratory results.

IProvide technical interpretation of hazardous

waste laboratory results.

IProvide technical interpretation of hazardous

waste laboratory results.

IUpdate/maintain HW testing procedures.

IAssist in updating hazardous waste technical

testing and analytical procedures.

IUpdate/maintain HW testing procedures.

Tests.

Tests.

Tests.

Tests.

Tests.

Interpretation of lab results for hazardous

substanc:es•

Interpretation of lab results for hazardous

substances.

Interpretation of lab results for hazardous

substanc:es.

Update/maintain HW testing procedures.

Update/maintain HW testing procedures.

0.40

0.20

0.40

0.60

0.40

0.40

0.02

0.02

0.04

0.40

0.05

•

•

Grand Total 2.93
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN Jul y 29, 1988

0.15

0.10

0.21

0.03

0.02

0.09

0.08

0.12

0.18

0.08

0.03

0.09

0.21

etc.

etc.

etc.

etc.

IDevelop TIMs, technical manuals, guidance. etc.

IDevelop TIMs, technical manuals, guidance,

IDevelop TIMs, technical manuals, guidance,

IDevelop TIMs, technical manuals, guidance,

IDevelop TIMs, technical manuals, guidance,

IState hazardous waste planning and sitlng

IHazardous waste.

IHazardous waste.

IHazardous waste.

H.01.a. IDevelop TlMs, technical manuals, guidance, etc.

H.01.a. IHazardous waste.

H.01.a. IDevelop TlMs, technical manuals, guidance, etc.

H.01.a. IDevelop TlMs, technical manuals, guidance, etc.

H.01.a.

H.01.a.

H.01.a.

H.01.a.

H.01.a.

H.01.c.

H.02.a.

I I I

e COOE I ACTIVITY . I OUTPUT OR RESULT I HE:

! --------------------._.-_._._------------------------- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ------------------ H. [reehntcat Assistanc I I 0.23

H.01. Ipotl iner issue I I 0.25

H.01.a. IDevelop TlMs, technical manuals, guidance, etc. I POTW/pretreat guidance I 0.03

H.01.a. IDevelop TIMs, technical manuals, guidance, etc. I Other(unspecified TIMs, additional manuals, etc. I 0.08

H.01.a. IDevelop TIMs, technical manuals, guidance, etc. 'Guidance for targeted businesses/industries, with , 0.21

PWM technical assistance for recyc/reduct help:

Up to 4 documents

Agricultural guidance

HW TIM related to reporting procedures.

Other(unspecified TIMs, additional manuals, etc.

Guidance for targeted businesses/industries, with

PWM technical assistance for recyc/reduct help:

Up to 4 documents

Guidance for targeted businesses/industries, with

PWM technical assistance for recyc/reduct help:

up to 4 documents

Update inspecters manual

drycleaner guidance

Update HCIC guidance

Agricultural guidance

2 T.I.M.s/guidance documents

Hazardous waste responses to public, local govOt

and business.

Responses to public requests for technical

information (5 per quarter).

Hazardous waste responses to public, local govOt

and business.

~a. "a.

H.02.a.01.

H.02.a.01.

H.02.a.01.

H.02.a.01.

H.02.a.02.

H.02.a.02.

H.02.a.02.

H.02.a.02.

H.03.a.

H.03.a.

H.03.a.

H.03.a.

IRespond to information requests from I~~!'·~'

on hazardous waste.

'Respond to information requests from ,~: •. ~~

on hazardous waste.

IRespond to information requests from !~:rle,

on hazardous waste.

·IRespond to information requests fr()fll ·~t r 'e,

on hazardous waste.

IRespond to hazardous waste' informs: ':r .~,:\

from municipalities/agencies.

IRespond to hazardous waste inform.t r ·~,t,

from municipalities/agencies.

IRespond to hazardous waste informsl r '~'l\

from municipalities/agencies.

IRespond to hazardous waste informsl')r .~,:,

from municipalities/agencies.

ITechnical assistance on facility pere'!,

closures

ITechnical assistance on facility per~··,

closures

ITechnical assistance on facility per.",

closures

ITechnical assistance on facility per.,:,

closures

ITechnical assistance on facility permit, and

2050 responses.

290 responses.

410 responses.

131 responses.

44 responses.

6 responses.

320 responses.

85 responses.

work w/ EPA to call in rest of treat/store

facility permits; Log, receive, file new apps

Work w/ EPA to call in rest of treat/store

facility permits; Log, receive, file new apps

Help field staff on technical issues re perm/clos

Help field staff on technical issues re perm/clos

Hanford Grout Facility

0.80

0.45

0.22

0.07

0.03

0.09

0.17

0.07

0.02

0.04

0.04

0.07

0.03
DEPARTMENT OF ECOLOGY

DANGEROUS ~ASTE FY88 PROGRAM PLAN July 29, 1988

0.02

0.03

0.17

0.48

0.08

0.10

0.06

0.01

0.01

0.05

0.05

0.04

0.05

0.02

0.04

0.03

0.05

0.02

0.10

0.02

0.10

0.05

0.30

0.19

0.01

0.10

0.01

0.04

0.15

0.05

Hanford Grout Facility

Hanford Grout Facility

Bay chemical permit.

Bay chemical permit.

Bay chemical permit.

Work w/ EPA to call in rest of treat/store

facility permits; Log, receive, file new apps

Help field staff on technical issues re perm/clos

1 action.

3 site management agreements.

25 requests

Hazardous waste inspector support.

Hazardous waste inspector support.

Hazardous waste inspector support.

Technical help to field staff on enf actions

Technical help to field staff on enf actions

McClary Columbia consent agreement/order

McClary Columbia consent agreement/order

Help on reviewing ground water plans

Single Shell Tank Farm

Hanford: Central HW Landfill

Help on reviewing ground water plans

Hanford: Central HW Landfill

Single Shell Tank Farm

1 petition.

4 petitions.

Hazardous waste petitions/certifications.

Hazardous waste petitions/certifications.

10 financial reviews.

7 bulletins

H.03.a.

I I I

~~~.. _--_..~~~~~~~~ .._-----_.._----------~-------------------~~~~-~-~~~~~------------------~--~~~:_-_._- closures

ITechnical assistance on facility permits and

closures

ITechnical assistance on facility permits and

closures

ITechnical assistance on facility permits and

closures

ITechnical assistance on facility permits and

closures

ITechnical assistance on facility permits and

closures

ITechnical assistance on facility permits and

closures

ITechnical assistance on facility permits and

closures

ILocal hazardous waste planning, zoning, siting

IHazardous waste.

IHazardous waste.

IHazardous waste.

ITechnical assist on enforcement.

ITechnical assist on enforcement.

ITechnical assistance on enforcement

ITechnical assistance on enforcement

IHydrogeological support.

IHydrogeological support

IHydrogeological support

IHydrogeological support.

IHydrogeological support.

IHydrogeological support

IHazardous ~aste.

IHazardous ~aste.

IHazardous ~aste.

IHazardous ~aste.

ITechnical review of financial assurance documents.

IDevelop technical bulletins on H.H.S., H.~./S.W.

planning, zoning, siting for local gov't.,

moderate risk plans.

ICoordinate with local government on siting.

IManage contaminated sites.

IContami nated site

H.03.a.

H.03.a.

H.03.a.

H.03.a.

H.03.a.

H.03.a.

H.06.a.

H.06.a.

H.06.a.

H.07.a.

H.07.a.

H.07.a.

H.07.a.

H.DB.

H.09.

H.03.c.

H.04.a.

H.04.a.

H.04.a.

H.Os.a.

H.Os.a.

H.Os.a.

H.Os.a.

H.l0.

H.l1.

H.l1.

~.

~.

Grand Total 6.72

•
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

0.02

0.01

0.26

0.06

0.02

0.01

0.04

0.10

0.02

0.02

0".01

0.03

0.05

0.01

0.17

0.10

0.01

0.01

0.02

0.39

0.06

0.09

0.06

0.08

0.15

0.02

0.01

0.01

0.01

0.03

0.01

0.06

0.01

0.01

0.01

0.07

0.05

0.06

0.10

0.05

0.07

Responsiveness summary on PWM regs.

News releases.

3 news releases

Curriculum revised.

25 written responses

Conduct publicity campaign.

Conduct publicity campaign.

UST.

Implement computer systems for CRTK, recycling

and litter hotlines.

Up to 2 public hearings on HW reg. ammendments

and land disposal ban regulations for PWM.

10 public notifications

1 hearing.

HW regulations public involvement.

HW regulations public involvement.

Hearings support and public notifications

o

o

Update hazardous waste interested parties list

Informational resource center for PWM; data.

. 300 phone calls, 100 letters.

100 responses.

60 responses.(10 to media)

100 responses.

Responses (100 qtrs 1 &2; 300 qtrs 3 &4).

300 phone calls, 100 letters.

300 phone calls, 100 letters.

30 requests

600 responses.

Responses (laO qtrs 1 &2; 300 qtrs 3 &4).

25 - 30 responses to media inquiries.

25 - 30 responses to media inquiries.

35 responses.

Responses (5 per quarter).

12 inquiries

25 - 30 responses to media inquiries.

Responses (5 per quarter)

15 responses.

25 responses.

Responsiveness summary on PWM regs_

and

IPriority waste management.

IMaintain Community Right-To-Know(CRTK)

hazardous household substance hotl ine.

IRecycling hotline publicity.

ILitter hotline publicity.

lUST.

IAutomation of hotlines.

IPublic participation on RCRA TSO facility permits.

IRCRA permits.

IRCRA permit s •

IHazardous waste regulations.

IHazardOus waste regulations.

IHazardous waste regulations

ILocation standards

IState hazardous waste plan

IMai l ing lists

IDevelop and maintain program resource center.

IRespond to information requests from the public.

IRespond to information requests from the publ i c .

IRespond to information requests from the public.

IRespond to information requests from the public.

IRespond to information requests from the public.

IRespond to information requests from the public.

IRespond to information requests from the public.

IRespond to information requests from the public.

IRespond to information requests from the public.

IRespond to information requests from the public.

IRespond to media inquiries.

IRespond to media inquiries.

IRespond to ·media inquiries.

IRespond to media inquiries.

IRespond to media inquiries.

IRespond to media inquiries.

IRespond to media inquiries.

IRespond to media inquiries.

IRespond to media inquIrIes.

IPrepare written responses to adress public

concerns.

Iprepare written responses to address public

concerns.

IPrepare written responses to address public

concerns•

Iprepare news releases.

Iprepare news releases.

IUpdate 'A-Way With Waste' curriculum.

1.01.b.

1.02.b.02.

1.02.c.02.

1.02.d.

1.02.e.

1.02.a.

1.04.b.

1.00.b.

1.04.b.

1.00.c.

1.00.c.

1.00.e.

1.04. f.

1.04.g.

1.04.i.

1.06.

1.06.

1.06.

1.06.

1.06.

1.06.

1.06.

1.06.

1.07.

1.07.

1.07.

1.07.

1.07.

1.07.

1.07.

1.07.

1.07.

1.08.

1.08.

I.12.a.

1.08.

I

•

I I I

. AcooE I ACTIVITY I OUTPUT OR RESULT I FTE:

~_.._._._._._._-_._-_._-_.._--------------------------------------------------------------------------------------------------

1.0l.a. IHazardous waste. I Hazardous waste workshops and conferences. I 0.08

1.01.a. IHazardous waste. I Hazardous waste workshops and conferences. I 0.05

1.01.b. IPriority waste management. I Priority waste management workshops and I 0.06

conferences.

Priority waste management workshops and

conferences.

Responses to CRTK inquiries (15 per quarter).
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

0.05

0.02

0.03

0.01

0.01

Local, state and out-of-state requests.

Conduct school program - iq:>lement survey.

Develop and print classroom teaching materials in

support of new curriculum.

1.12.f.03. I"A-Way with waste" school program newsletter. Newsletter illustration, layout and printing- 6

I I

E I ACTI VITY I . OUTPUT OR RESULT I HE:

._ ..._----------------_... _--------------------------- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1.12.a. IUpdate 'A-Way With Waste' curriculum. I Curriculum revised I 0.03

1.12.c.Ol. IParticipate in environmental education workshops, I Represent the program at approximately four state I 0.11

meetings and seminars. and national meetings and seminars.

1.12.c.02. IProvide assistance to regional offices relating Troubleshoot regional workshop problems.

to the school curriculum.

1.12.c.03. IRespond to requests for program information and

school curriculum.

1.12.d. IProgram evaluation.

1.12.f.Ol. I"A-Way with waste" school program classroom aids.

1.14.

1.14.

1.14.a.

1.14.c.

I. 14.c.

1.17.a.

I. 17.b.01.

I. 17.b.01.

1.17.b.02.

1.17.b.03.

• c. "'d.

1.17.f.01.

1.17. f .02.

I. 17. f. 03.

1.17.f.04.

1.17.g.01.

1.17.g.02.

I. 1S.c.

1.1S.e.

I. 1S.h.02.

1.1S. i.01.

1.1S. i.01.

I. 1S.j .

I. 1S.k.

1.19.b.

ISWAC activities

ISWAC activities

IQuarterly SWAC meetings

IFacility siting/local guidelines

ISWAC Subcommittee· State HW Plan

IHazardous waste

ICRTK publicity.

ICRTK publ icity.

IDevelop and print CRTK informational material.

IMaintain Community Right-To-Know(CRTK) and

hazardous household substance hotline.

ICRTK presentations.

IHire and work with consultant to develop a

portable public education display.

IAssist 10 local jurisdictions conduct household

hazardous waste programs.

IHousehold hazardous substance program support to

Puget Sound Water Quality Authority.

IUpdate household hazardous substance program

brochure.

IDevelop and conduct presentations/displays.

Iinformation to moderate-risk waste generators.

IDevelop and conduct moderate risk wastes

presentations/displays.

ISupport to Solid Waste Unit.

ISupport to Program Management Unit.

ISpring Rally

[ou recycl ing.

[on recycl ing.

IProduce support material for Recycling and Litter

Control Unit.

IProvide support to regional events.

IMedia equipment coordination.

IMaintain media contact lists.

issues.

Status reports to SWAC, PWM coordination

Status reports to SWAC, P~ coordination

attend 4 meetings

Attend 1 meeting

Provide information.

TV and Radio PSA's.

TV and Radio PSA's.

1 Brochure.

Provide communities, households, businesses,

local gov'tsinformation regarding use, storage,

disposal of haz. sub.

Conduct 4 presentations/displays.

, display

10 hazardous substance programs that may include

collection days and information distribution.

Prepare 6 bulletins about less toxic household

products to be publ i sned by PSIJQA.

Print and distribute 20,000 copies.

Conduct 4; 1 in each region.

Develop and distribute 4 moderate risk waste

bulletins.

Conduct 4 presentations/displays; one per region.

Graphic and production service for unit reports.

Presentation material development.

Guide, TV and Radio PSA's, handouts, posters, bag

designs, news releases.

TV and Radio PSA's.

TV and Radio PSA's.

Coloring posters, buttons, and other novelties

Operation shore patrol- support regional events.

Provide A.V. equipment loan, storage, repair and

purchase. Maintain and distribute orders for

equipment.

Update and maintain media contact lists: radio

news, TV news, newspapers, radio and TV publ i c

0.02

0.01

0.01

0.03

0.07

0.02

0.02

0.08

0.05

1.00

0.10

0.06

0.11

0.12

0.01

0.10

0.12

0.10

0.03

0.02

O.lS

0.01

0.04

0.05

0.05

0.09

0.05
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

'-. I I I

~E I ACTIVITY I OUTPUT OR RESULT I HE:

~:~----------_._---------_._-------------------------- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

1.19.f.03. Iprovide information and support to SWAC.

I. 19.d.

1.19.e.

1.19.e.

1.19.f.

I.19.f.01.

1.19.f.02.

Iprepare materials for agency newsletter.

IMaintain mailing lists.

IMaintain mailing lists.

IProvide Pia liason.

IConduct hearings, public meetings for program.

IDevelop and maintain program resource center.

services, newsletters.

Write 12 articles.

Solid and Hazardous waste.

o

Coordinate speakers for program presentations.

18 public meetings/hearings.

Maintain technical resource center for staff,

publ ic and industry.

Organize and facilitate 4 SWAC meetings.

0.08

0.01

0.02

0.05

0.21

0.10

0.03

•

•

Grand Total 5.88
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

I I I

AcooE I ACTIVITY . I OUTPUT OR RESULT I HE:

~-----------_ .. _... __ ..... __ ._---------------------------- ----_._--~--------_._---------------------------------------------

J.01.c.

J.02.b.

J.02.c.

J.02.f.

J.02.h.

J.02.i.

J.02. j.

J.03.f.

J.03.h.

J.03. i.

J.03.r.

J.05.c.

J.06.b.

e

_e

IHazardous waste

IRef. 39 grants.

IHazardous waste

IHazardous Waste Planning Grants

Isolid Waste Planning Grants

ISolic Waste management and disposal grants.

ISolid Waste Enforcement Grants

IHazardous Waste Planning Grants

ISolid Waste Planning Grants.

ISolid Waste Management and Disposal Grants.

ISolid Waste Enforcement Grants.

IHazardous waste

10

Develop grant guidelines

3 grants

Evaluate grant proposals

Review applications

Review applications

Review applications.

20 applications

Grant award.

Grant award.

Grant award.

Grant award.

10 grants

3 grants

0.29

0.01

0.27

0.05

0.15

0.15

0.05

0.05

0.05

0.05

0.10

0.01

Grand Total 1.23
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

-~ I I I .

~~--~_._._--_._-----------~~~~~~~~_._-----------_ .._----~-------------------~~~~-~-~~~~~-_._-----_._._----~--~~~~------ K.01. IRFP/personal services contracts. I Contract administration. At Kearney, Hydrogeol I 0.01

grant, permit review contracts, Econ analysis

contracts.

K.01. IRFP/personal services contracts. Contract administration. At Kearney, Hydrogeol 0.01

grant, permit review contracts, Econ analysis

contracts.

K.01. IRFP/personal services contract management Performance evaluation 0.01

Grand Total 0.03

•

_e
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

--. I I I ~E I ACTIVITY . I OUTPUT OR RESULT I FTE:

~._--------------------------------------------------- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - . - - - - _ . - - - - L.01.

L.01.

L.01.

L.01.

L.01.

•

IPerform SEPA revievs.

IPerform SEPA revievs.

IPerform SEPA revievs.

IPerform SEPA revievs.

IPerform SEPA revievs.

6 reviews, 3 comments prepared.

Revievs.

Reviews.

10 revi ews, 2 comments prepared.

2 reviews, 1 comment prepared.

0.01

0.02

0.02

0.01

0.01

Grand Total 0.07
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

•

I I I

COOE I ACTIVITY I . OUTPUT OR RESULT I FTE:

----------------------------------------------------------------------------------------------.-------------------------------- M.01. [ctertcat support. Clerical support for staff 0.20

M.01. IClerical support. Clerical support for staff 0.94

M.01. [cterieat support. Clerical support for staff 0.20

M.01. [ctericet support. Clerical support for staff 0.40

M.01. [ctericat support. Clerical support for staff 0.30

M.01. [cterteat support. Clerical support for staff 0.70

M.01. IClerical support. Clerical support for staff 0.35

M.01. [ctericat support. Clerical support for staff 0.60

M.02. IData Processing, Data Entry 0.05

M.02. [nata Processing, Data Entry 0 0.02

M.02. IData Processing, Data Entry 0.05

M.02. IData Processing, Data Entry 0.03

M.02. IData Processing, Data Entry Data needs assessment plan. 0.05

M.02. IData Processing, Data Entry 0.04

M.03.a. [Purchase Tracking Maintain program tracking 0.04

M.05. IReceptionist Staff Rowesix switchboard 0.30

Grand Total 4.27

•

•
DEPARTMENT OF ECOLOGY

DANGEROUS WASTE FY88 PROGRAM PLAN July 29, 1988

N.01.

N.02.a.

N.02.b.

N.03.

N.03.

N.03.

N.03.

N.OS.

N.OS.a.

N.OS.a.

N.OS.b.

N.OS.c.

N.OS.d.

N.OS.e.

N.OS.f.

N.OS.g.

N.OS.g.

•

IEPA regional capacity initiative

ISARA Activities

ISARA Activities

IHW emerging activities.

IUpper management assingments.

IHW emerging activities.

IHW emerging activities.

lUST (federal grant).

IEstablish advisory board.

IEstablish advisory board.

IReport of funding options.

ITank installation procedures.

IIdentify trainers and materials for UST.

IDevelop resource library.

IGrant preparation.

IFuture UST program development.

IFuture UST program development

IProvide information to joint select committee on

preference waste management practices.

o

Agency I iason.

Program dev. and integration.

EPA symposium, ASTSWMO nat'l conference, ag

study, new EPA issues, new faci I ity permit

apps(ECOS), etc.

Respond to public inquiries.

EPA symposium, ASTSWMO nat'l conference, ag

study, new EPA issues, new facility permit

apps(ECOS), etc.

EPA symposium, ASTSWMO nat'l conference, ag

study, new EPA issues, new facility permit

apps(ECOS), etc.

Advisory board established.

Advisory board established.

Report of funding options.

Procedures.

Trainers and materials identified for UST.

Library developed.

Grant preparation.

unanticipated.

Future UST program development tasks.

Assist development of legislative recommendations

on solid waste reduction and recycling.

0.05

0.09

O.SS

0.14

0.06

0.06

0.09

0.00

0.02

0.06

0.03

0.04

0.03

0.11

0.02

0.03

0.86

0.00

•

Grand Total 2.24
'. III. PERMITTING PROCEDURES

A. Purpose

The purpose of permitting treatment, storage, and disposal

(TSD) facilities (on-site and off-site) is to ensure that all

facilities are built and operated in accordance with the

Dangerous Waste Regulations to protect the public health and

environment.

•

In the first severa: years, Ecology will be concentrating on

permitting those f~(': ~ties that are considered high priority

by both EPA and ~cci0g~. Permitting priorities will be

determined us Lng t I:,. ;' r oc e du r e s described in the compliance

monitoring seetio!: cf this document considering national

permitting priorit i rs . In general, permits will fall into two

major categories. exi"ti~g TSD facilities, and new TSD

facilities. COtrr: e t : ,In of permit actions in progress and

disposition of F:' .., i s s ue d permits after final authorization

will generally be i~ ~~cordance with EPA Program

Implementatior Cu t da n rc (PIG) 82-5. It is expected that at

the time of final autj.lrization only condition 5 in PIG 82-5

will apply to \·:.:<:~'::1.:t.·;,.. Any permit actions taken prior to

final au t ho r i z a t i :: vi l l be joint actions by the state and

EPA. The folio~j~~ ~!ece~ts describe, in general, how the

major c a t e go r i e s -: ;';,r;n1ts will be handled and a discussion

of the permit ~l\ ,,: ';"'Cf':",t, review, and approval process as it

will be Lmp l emen t v-: ..; ~'cology,

B. Existing TSD c ,'.," , : :.

All existing : .i ,: : , _ . c, z r an t ed Interim Status under Section

3005 of RCRft ,~r·.· 'n::J;e": t o have an interim status permit

(Part A) in the - : It·- ;-",'gram. The state's regulation

directly re~e~~~~~': G~ i: ffied facilities with interim status

gained under ... t', ~'~, .:~, of RCRA. Hence, any facility

granted lr:tl'r:- ~r,:t\;.., 1-,,: EPA regulations adopted pursuant to

Section 30e: '. ':"~ ;,.l:::'y for state interim status.

.: .

, w- ~w": ing facilities which are not

,~t'a 1ifv for interim status if their

-,' '-.'. ' regulated by amendments to state

: ", ". the owner/operator must submit a

.. ','11 ""i thin six months of the date the

.' ",;', "r. (equivalent to 40 CFR

. ,,:::1 ies may newly qualify for state-only

'. t' •.Ire only affected by state rule

: .. ' : '" do not qualify for RCRA interim

• -r he rwi s e qualify under Section 3005.

: .1: :': ': qualify for state interim status

• "~ ::: t il tus may not accept or manage RCRA

, • ,-I c :: • These facilities are authorized

.' ....1- t e s , and could qualify for RCRA

Ecology a Ls-:

currently rt.

ac t Lv t t Le s :

regulation: ,

Part A pe r rr. ,

new amendrne : :

270. 10 (e) ( I ' ,

interim stat', '

changes; SUL:: :

status unle~' ",

Thus, f acLl I ; : .."

and not f ed e r >

regulated ha za :

to manage statc- •

I I - 49
•

•

interim status under Section 3005 if EPA amends their rules in

the future.

Those facilities wishing to receive or ordered by Ecology to

receive a final status permit must submit a completed Part B

application as defined in WAC 173-303-806 to Ecology within

six months of its request. Late or incomplete Part B applications will be processed in accordance with the state's

enforcement policy. This is equivalent to 40 CFR Part 270

subpart B.

C. New TSD Facilities

New facilities must submit both Parts A and B of the permit

application to Ecology six months before physical construction

can begin. This is covered in WAC 173-303-805 and 806.

D. Permit Development Review and Approval Process for Existing

and New TSD Facilities

Ecology, through its permitting process, will ensure that all

requirements and conditions described in WAC 173-303-800

through 845 are followed. During the permitting process

Ecology will:

1. Provide assistance to applicants.

2. Receive and review applications, including financial

assurance review.

3. Conduct site evaluations.

4. Assure analysis of air, water, and/or soil samples as

necessary.

5.

6.

7.

8.

9.

10.

11.

•••

Call for Part B per.mit applications.

Review and make completeness determinations on Part B

permit applications.

Review and approve closure/post-closure plans.

Review and approve financial assurance documents.

Issue draft permits and fact sheets (if necessary) or

statement of basis of permit determination.

Coordinate with EPA during the review process.

Open comment period, issue public notice, hold public

hearings when necessary, and establish administrative

record.

II - 50
•

•

E.

12. Take necessary enforcement actions to ensure application

completeness, closure/post-closure and financial requirements are met prior to permit issuance and in accordance

with state enforcement policies.

13. Ensure compliance with the State Environmental Policy Act

(see attachment).

14. Issue final permit actions.

15. Process changes to permits, including:

a. Transfers

b. Modifications

c. Revocations

d. Reissuance

e. Terminations

16. Ensure proper judicial review of permits in cases of

applicant appeals.

In reviewing applications and writing permits Ecology will

ensure that all appropriate information and conditions are

provided. This will be done by appropriate engineering and

hydrogeologic judgments and technical expertise, as well as

using checklists and guidance provided by EPA or equivalent

plus any additional checklists necessary to include additional

state requirements. The attached flow charts (see Figures 4

and 5) describe the order of events, lines of responsibility,

and intra and interagency relationships that will occur in the

permit process. Internal operating procedures and policies

will be developed to ensure adequate review and compliance

with state and federal regulations.

Permits by Rule (PBR) (See WAC 173-303-802)

Ecology allows PBR for:

1. Ocean disposal barges or vessels. The PBR requirements

of the state are identical to federal standards.

2. Underground injection wells. The PBR requirements prohibit underground injection of extremely hazardous waste.

They require compliance with 40 CFR 144.14 and all applicable state waste discharge permits and conditions.

3. Publicly owned treatment works (POTW). POTW are subject

to state PBR requirements that are identical to federal

standards, except that POTW may not accept extremely

hazardous waste for disposal.

• 4. Totally enclosed treatment facilities and elementary

neutralization and wastewater treatment units. These

facilities and units are exempted under federal

II - 51
•

•

•

F.

G.

H.

requirements. The state, instead, requires a PBR, which

includes conditions for complying with: security;

contingency plan and emergency procedures; the manifest

system (when applicable); records; reporting; and general

performance standards. If the facilities or units pose a

threat or fail to comply with the PBR conditions, Ecology

may require compliance with all the facility standards

and require a full permit.

Emergency Permits

Ecology may issue an emergency permit to allow for treating,

storing, or disposing wastes at facilities which either are

not permitted (including interim status), or, if permitted,

are not authorized at the time to manage the particular waste.

Emergency permits will only be issued if doing so will

alleviate imminent and substantial threats to public health

and the environment. The requirements for state issued

emergency permits are identical to the. federal requirements.

Judicial Review of Permits

WAC 173-303-845 states that any person who is adversely

affected by a decision of Ecology under WAC 173-303 may appeal

the decision to the Pollution Control Hearings Board pursuant

to Chapter 43.21B RCW. The Pollution Control Hearings Board

Act, WAC 371-08-255, states that in the event that the board

determines a permit issued by Ecology under Chapter 173-303

WAC is invalid in any respect, the board shall issue an order

remanding the permit to Ecology for reconsideration and appropriate action consistent with the provisions of said order and

federal and state law. Any further appeals shall be appealed

to the superior court of the state of Washington and shall

follow procedures per Chapters 43.21B and 34.04 RCW.

Permit Certification Language

Due to changes under Chapter 70.105.215 RCW, Ecology included

additional permit certification language for situations where

the owner and operator of a TSD facility are separate entities

(see WAC 173-303-810(13)) .

II - 52
1 2 3 4 5

Purmit AppUcaUon ~UcaUon

Received --. Reviewed ---. LreftPermlt ------ --... PUblic comment 1------. Flnal permit

Create / modi fy FMP

ldenUfy speciel concerne

Begin SEPA

Review application

Identify lead agency

Threshold determination

Trensmit NOD

Facility r9sLbrnlts appllcation

Begln lEIS Iif requlred)

Preper-o fact sheet

O'eate dreft permit

Trensmlt draft to EPA

FIrlllllzeOETS

Issue pub l1c notice for

Oreft permit &DEIS

Recelve comments

tlo 1d pub 11cheeri ng

Hev lew puu I f c comments

RetJreft permi t

Issue fine 1 EIS

Issue f Inel perml t

Respons 1ve summery

FMP - Facility Management Plan

SEPA- Stete Environmental Pollcy Act

NOO - Permit Appl1cet1on Notice of Deficiency

OEIS - Draft Environmental Impact Statement

t.

Figure 4. General Permitting Pf(lt"CSS

• •
Ecology and EPA .btntcr Indlvl<1Jl1l Ecology and EPA

Pre-requeetMeetlng -. Perml t Requeet by -.. Meet with

Draft FMP Created Eco logy and EPA Adllty

1 2 3

180 Daye

Eco logy and EPA

• Receive Appl1catlon

4

I

I

FacUlty Decides to

Cloee

f.\

Figure 5. Issuance of Dangerous Waste Permits

• •
Ecology end EPA

- PUblic ttJUce of

... Prepere Feet Sheet . or Stetement of Beeis

.. 8 9

D"aft Permi t

--..

Public comments

10 Received

---.,

Comments Reviewed -

Heering Determinetion

11 EICtension of Comments

45 Deys

l'\Jblic ttJtlce or

Heering

12

Public Haering

13 --

..... __.. .. 1

l L---- -~~ Q!JY~_ _.-- "-'- .-. _.- - -----1I

I

I

Figure 5. (cont.). Issuance of Dangerous Waste Permits

e

------------.....

(e

9

PUblic ttJtlce of

B-eftEIS -.

Leed Agency Receives

Co_ments Oil Draft

EIS

10

-.,

COII.ents Rev i ewed

Hearlng Determinetlon 1- - ..

11

•
----"--'

Ecology Conducts

Completeness snd

Techn1calevaluatlon

I EPA Conducts HSWA I

Rev1sw I -------

6

Appllcat 10n Comments

RBcelved by Fac1l1ty;

Fecl11 ty Resubmlts

Ecology and EPA

Prepare Draft

Perm1 t Per FMP

....

EcologyOetermlnes

LsadAgency for

SEPA

5

r-----------....------.--.--...----.----.----- -.-_.. -"--

5

Declaration of

Nons1gn1t1cance

5

Lead Agency Makes

lhrsohold

Determlnation

Scoplng

P,'oeess

·Mit 19a1ed·

Declaration of

~nslgnlfleance

5

7

Lead Agency

Prspares Draft

EIS

I

I

I

I

I

I

1 --.

•

Figure 5. (cont.). Issuance of Dangerous Waste Permits

• •
~. __ .._- -----.

II

Ecology and EPA pre- Iasuance 0' Final

- pare NewStatement 0' - Permi t; Reeponee to

Baele; Feet Sheet; .. 1" RlIvllle [raft Permit

15 Comments

I

I

I

I

I

I

Pollalble Appeala to

-----..-----.-----.1 PCt-e (Ecology):

Federel Court (EPA)

------+

Lead Agancy Preparea

Final EIS

1..

,--.

Lead Agency Ieeuae

Final EIS

15

--------. Agency Declelon on

EIS (7 Days)

•

Figurc S. (cont.). Issuance of Dangerous Waste Permits

• •
•

•

•

IV. COMPLIANCE MONITORING AND ENFORCEMENT

A. Objective:

The objective of the compliance monitoring program is to

ensure the protection of public health and the environment

through active enforcement of the state approved Dangerous

Waste Regulations.

B. Facility Definition and Establishing Priorities:

The compliance monitoring strategy is based upon performing

the greatest number of facility inspections with available

resources. Number of inspections completed each year will be

dependent upon Ecology's resources. Industries will be classified into two categories; major or nonmajor. In general,

those facilities which are the largest, and pose the greatest

potential for pollution will be classified as major. The

criteria for developing a numerical ranking of facilities is

presented in Table 8. Major facilities will have a high

numerical ranking. Minor facilities will, of course, have a

lower numerical assignment. The basic purpose of using

criteria is to develop consistent permitting and compliance

monitoring priorities.

The criteria were derived from an EPA model for ranking Superfund candidates. The criteria consider five factors in establishing human and environmental risks:

1. Major Hazard of Haterials - gives information on the

types of waste being treated, stored, or disposed of at

the facility.

2. Volume of Materials - gives data on the size of potential

environmental problem.

3. Routes for Pollution - provides information on how the

waste rna\' enter the environment.

4. Location of Facility - indicates the size of population

near the facility and proximity to it.

5. Observed Releases or Violations - gives data on history

of the facility's operations.

The decision line or break-point for what is a major or

nonmajor facility is variable and may change depending on

national guidance for defining major/nonmajor priorities.

This line will be negotiated during the annual program plan.

Once the major and nonmajor facilities have been identified in

the annual program plan, then the number of annual compliance

inspections to be completed by the state under final authorization will be negotiated based on the list of major and

II - 58
TABLES.

CRITERIA FOR DETERMINING THE PRIORITY OF

MAJOR AND NON-MAJOR FACILITIES

BASIS OF SITE SITE MAXIMUM

RATING FACTOR INFORMATION RATING MULTIPLIER SCORE POSSIBLE

SCORE

1 ~1AJOR Il-\ZARD OF MATERIALS~': -

EHW 3 6 18

OW 2 5 10

Low Risk 1 3 3

Subtotal 31

2 ..-, L:_"~1F. . IF ~LA.TERIALS -

10 Tons 4 }

J 12 , - 10 Tons 3 1 1 9

400 Ibs - 1 Ton 2 J 6 . .- ._.

~OO Ibs. .3 3

3 HoL T~-. 1. S I ;i)R POLLUTIOW:

• Ground Water 3 3 9

Surface water 3 3 9

Land 3 3 9

Air 2 0

) 6

Subtotal 33

LOCH 1 ~.

i.OO,OOO

iO,OOO-lOO.OOO

10,000

~~::~:7'i (.check only one)

,

.J

2

9

4.

5

6

~lajor

Moderate

Minor

(\BSL~ . ~:. <.. !:.. ~.:,ES OR VIOLATIONS":'

10

6

3

3

3

3

Subtotal

30

18

9

57

142

•

"May have more than " .'-

11 ..59
•

~.

C.

nonmajor facilities. The EPA national inspection scheme,

including 100 percent of major handlers inspected each year,

will be addressed during the annual program plan negotiations.

In addition to the requirements in the EPA national inspection

scheme, each of the state's four Regional Offices and

Industrial Section will identify those facilities/handlers in

their area that represent a high priority need based on

environmental risk. These priorities will be taken into

account in developing the final inspection commitment in the

annual program plan. Through this process, EPA concerns and

state needs and staffing levels can be addressed. Overall

development and review of priorities will be done by Ecology

headquarters dangerous/hazardous waste group to ensure

statewide priorities are begin maintained.

In addition to those planned facility inspections, response to

citizen or local government complaints of hazardous waste

spills and abandoned/inactive hazardous waste sites may

require further field investigation and the dedication of

resources. This may result in a lower than anticipated number

of planned facility inspections. Again, the final number of

industries to be inspected will be dependent upon adequacy of

resources and the management of those resources.

Inspection Procedures:

Dangerous waste handler/facility inspections are conducted and

documented by the hazardous waste inspectors in each of the

four Ecology Regional Offices, Industrial Section, Hanford

Section, and Central Permits Section. These inspectors are

assigned to the dangerous/hazardous waste program to allow

them to develop expertise in this area and become the primary

agency contact with the pertinent facilities and handlers. In

may instances, the inspectors also have the responsibility for

writing any final status permits that may be called and/or

issued by the state. Alternatively, permits are written by

the Central Permits Section staff.

The inspectors are trained to be knowledgeable on regulatory

requirements and interpretation, as well as inspection

procedures and protocol. Because inspections and

documentation of these activities are critical to a successful

enforcement program, it is the intent of the state to develop

specific guidance for field use for hazardous waste

inspections. There is also review of inspection reports and

compliance monitoring performed by the dangerous/hazardous

waste headquarters staff at Ecology to help assure statewide

consistency in documentation and enforcement.

Ecology conducts both announced and unannounced inspections

depending on the given situation. In addition to our own

knowledge of what is happening in each region, we also use the

eyes and ears of local citizens or groups, such as the local

health department and citizen complaints to alert us of any

II - 60
•• possible environmental or public health. Inspections may fall

into one of several categories depending on the concern.

Inspectors may do a compliance inspection on general facility

operations, record review, sampling inspection, or a follow-up

inspection on a particular compliance issue including proper

closure and/or post-closure care.

Field inspectors are given basic training, and when possible,

follow-up training for facility inspection, record review, and

safety. In general, inspections are conducted according to

the following protocol:

1. Conduct a prior research of the files of that facility.

If there is any unusual or important information, they

will incorporate that into their inspection.

2. Conduct personal interviews, if necessary.

3. Talk with owners/supervisors of the facility.

4. Conduct a tour of the plant site, taking photos, drawing

maps, and any other field notes that might be pertinent.

5. If applicable, review manifest and recordkeeping to

ensure regulatory compliance .

• 6 Ask questions about complying with the regulations such

as: Are the standards being complied with? Do you have

a closure plan, a facility plan, contingency plan, postclosure plan, if applicable, correct financial assurance,

etc. In cases where these records have not been reviewed

by Ecology or are nonexistent or inaccurate, the

inspector will require a submittal be given to Ecology

for review and also to ensure Ecology's files contain an

up-to-date copy of the appropriate records.

7. Collect samples if necessary.

An inspection form will be used by our field inspectors and is

included with this application.

D. Enforcement Authority and Procedures:

Ecology has the enforcement authority for the

Dangerous/Hazardous Waste Program as given in Chapter 70.105

RCW specifically cited in RCW 70.105.080, -090, -097. What

follows is a description of general definitions and procedures

as presented in Ecology's Enforcement Policy Manual.

•

1. General Descriptions

Warning Letter - This letter is issued as soon as you

know the circumstances of a violation or environmental

abuse. The letter does five things:

II - 61
a. Establishes an official record of the situation.

•

•

b. Lets the violator know there is a problem and that

the problem needs to be corrected in a prescribed

manner.

c. Requires the violator to let Ecology know what

corrective action will be taken.

d. Informs the violator that failure to correct the

problem voluntarily may result in more stringent

action.

e. Establishes a basis for more stringent action if it

is required.

Warning letters may be approved and signed by the dangerous

waste supervisor in the Regional Office and Industrial

Section.

Notice of Violation - This is the next, more serious action

taken after a warning letter. This notice defines the problem

and specifically describes what actions are required to

correct the problem.

A notice is a quasi-legal document and must be signed and

approved by an assistant director.

A notice of violation requires a response from the violator.

Administrative Order - This is a quasi-legal document. It

must be signed by an assistant director or higher authority.

It will be issued 30 or more days after a Notice of Violation

except in an air quality enforcement action, or a dangerous

waste enforcement action.

No Action Order - After a Notice of Violation is issued, an

order must follow. A No Action Order is issued when the

violator has s0lved the problem prior to issuance of an

Administrative Order.

Civil Penalty - This can be used as an enforcement action

where it is provided for by statute. It is a monetary or

amount of resource damage penalty. In the case of a dangerous

waste violation, it can be in the amount up to $10,000 per day

per violation. It usually occurs where there is a

well-identified, specific violation or there have been

continuing or repeated violations.

The statutory authority for issuing a civil penalty also

provides for the reduction or dismissal of a penalty in some

cases of extenuating or mitigating circumstances.

II - 62
All civil penalty assessments must be assigned and approved by

an assistant director.

Restraining Order - Injunction - Under RCW 70.105.120, Ecology

may request the Attorney General to bring injunction,

declaratory, or other actions to enforce any requirement of

the Hazardous Waste Disposal Act, Chapter 70.105 RCW .. Prior

notification is not required for such action and such action

may be taken for threatened, as well as actual violations.

The Attorney General's statement provided with this document

further clarifies this authority.

Criminal Proceedings - This is the most severe enforcement

action available to Ecology. It may be used only when

statutory provisions allow. Conviction of a crime means

penalties of a fine, prosecution costs, and/or imprisonment.

2. General Procedures

The following procedures do not necessarily in all instances

occur in the sequence outlined below. This information is

intended to represent a general process and may vary according

to the severity of the violation or the immediate threat to

public health and the environment.

•

a .

b.

Someone is not in compliance with the law.

Makes a telephone call and/or a personal visit to assess

the situation and get the facts on the situation.

(1) This will begin the foundation of any needed

enforcement action; or

(2) It can eliminate or correct any problem with noncompliance;

(3) A memo to the files should be completed to document

the situation and any discussions with the violator.

c. If the problem is not solved informally, the next step is

to send a warning letter to the violator. This must be

signed by the section head or district supervisor.

e. The violator has an opportunity to respond within 30

days .

d. If the warning is not heeded and the violation continues,

the next step is to issue a Notice of Violation. All of

the information is sent to the enforcement officer. He

prepares the Notice of Violation and the appropriate

assistant director approves and signs it.

• f. After Notice of Violation, an Administrative Order is

issued by the enforcement officer under the assistant

II - 63
g.

h.

director's signature. This requires an appropriate

response from the violator.

If corrective action is being taken by the violator, the

initiating program staff member can decide that no

further action is necessary.

If corrective action is not being taken, the enforcement

officer and the initiating staff member should decide one

of the following courses of action:

(1) Send a reminder letter. This should come from the

section head nf the initiating office.

(2) Enforcement officer recommends to the appropriate

assistant director that the matter should be

referred to the Assistant Attorney General for

action.

i. If option (1; is chosen and the situation is not

corrected, the next step is option (2).

•

•

j,

k.

The matter :5 re:erred to the Assistant Attorney General

and the enfcrce~ent officer prepares a memorandum from

the assistant d:cector to the Assistant Attorney General,

including the ~J~lowing:

0) A cnrc:,;,-:"c' c f circumstances and conditions causing

the uri~ln.l~ enforcement response, description of

cond it: ,"'''' :-,3 ture of the violations, and corrective

a c t i cn r eq u i r ed .

(2) Copies ,': correspondence, memorandum of record,

inspect:!'n ,eports, monitoring reports, and any

0tb~r ~ucume~tation relating to the situation.

(3) A r . ,.':t>q t ha t the Assistant Attorney General take

app' :-rirtte ~ction to record penalties and/or to

gil I , , mp l \., ret' with the notice or order.

(4) As":~t,,T't Ar r o r r.ey General contacts violator. There

f..: I' ; ;,,:rtullit:1 to settle without court action.

I: .: ;,.', r.: ec , the case is filed in the court of the

Cl'\:r~~ ',' .. I" r e the violation occurred, or in Thurston

r. ' [ t', '. "Ir: .

Waivers I ~.lrldnce~, With the exception of one area,

any waf':":' .. ,r v a r i a nc e s granted by Ecology are

es s en t i a i .'. :,I,~t:c;Jl to federal waiver/variance

proc edu r c . . -"" a r ea s in which waivers/variances could

be gr an t e ! .1[·...; t he conditions or circumstances for

grantin~ t! •. .I'e based completely on those specified in

EPA's r e gu l a t ~,'ns or federal statute. For example: 1)

ground water' ::-.· .. t r or I ng waiver based on use of double

J I - 64
/'e

e

liners; 2) waiver from landfill liner requirements, based

on hydrogeology, waste nature, alternate design and

operations, etc.; and 3) waste exemptions, based on

conditions described in Section II.B.l of this program

description.

Ecology may, under its statutory enforcement authority,

issue a compliance order which includes a schedule for

complying with the regulations. This would amount to a

temporary variance from the state requirements. Such a

variance/compliance schedule would only be provided if

requiring immediate compliance: 1) could result in

further violations of state regulations; 2) could pose a

threat to public health or the environment; or 3) if the

violation is minor (e.g., recordkeeping error, procedural

problems), could resolve the violation in a short period

of time without having to resort to penalties. A

variance/compliance schedule would not be issued if it

would result in a threat to public health or the

environment.

Ecology does vary one requirement which EPA does not.

This is the fifty-foot setback for containers storing

ignitable waste at final status facilities. Ecology

allows compliance with the Uniform Fire Code or NFPA

pamphlet U30 in lieu of the fifty-foot setback. This is

discussed in detail in Section II.B.4.

The following is a general estimate of the process time

required for the various enforcement measures described in the

preceding procedures:

Activity

a,b

c

d

f ,h

j

Timing

0-15 days

0-15 days

15 days

30 days

90 days

•

It is the intent of Ecology to further refine the general

definitions and procedures stated above to provide guidance

and ensure statewide consistency in dangerous waste

enforcement situations. This refinement will include a

definition of "high priority" environmental/health risk

situations and lessor violations. Associated with this

resolution of significance will be specific guidance on level

of enforcement actions, including penalty assessment, and

timing of those actions.

Dangerous waste program compliance and enforcement are

recognized as critical state as well as national importance.

It is recognized that a strong regulatory position is critical

to environmental protection and public health.

II - 65
•

•

•

E. Information Management

The notification and annual report forms, filled out by

dangerous waste generators and TSDs, are the backbone of our

information data base. This data can be used by field and

headquarters staff to obtain notification information such as

types of dangerous waste activities, identification numbers,

etc. Also, we provide an annual report summary (see the 1985

Summary in Appendix A) which profiles annual waste generation,

treatment, and disposal data. This information can be used to

plot trends and identify priorities for other dangerous waste

program activities.

Ecology has designed an automated system to track TSD facility

status. We are currently taking a file inventory and keying

data into the system. This data base will contain Part A and

Part B permit information, facility location. dangerous waste

activities and the status of financial assurance, and closure

and post-closure activities.

For the future. we plan to adopt RCRIS (Resource Conversation

and Recovery Information System). This is a comprehensive

information system devloped for use by both EPA and the

states. We plan to develop an implementation plan within the

next six months and hope to be operational by September 1989.

II - 66
• V. REGULATED COMMUNITY DATA - ESTIMATES

A. Number of Notifiers by Activity Reported

Data estimating the numbers of regulated companies was derived

from EPA's notification data base and submitted Part A permit

forms. The following information depicts the status of

Washington State:

Activity

Generation --------- Transportation -----

TSD ----------------

B. Amount of Waste

Number

623

80

60

•

•

c.

Washington's 1985 Annual Report return resulted in an

accounting of 623 active generators (those which reported site

regulation quantities of waste generation during calendar year

1985). The amount of waste generated during 1985 was 574,713.

(See the 1985 Annual Report Summary attached as Appendix A to

this document).

Amount of Waste Treated, Stored, and Diposed

The state received facility Annual Reports from 77 legitimate

TSD facilities. Of these, 60 actively managed hazardous waste

totalling 642,875 tons during calendar year 1985. (See the

1985 Annual Report Summary attached as Appendix A to this

document) .

II - 67