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Attachment E

DEQ Site Screening for Assignment to Hazardous Waste or Cleanup

(Draft)
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Site Screening for Assignment to Hazardous Waste or Cleanup

The following is a description of the process for determining which newly discovered or

newly assigned sites from the ECSI Database will go to the Hazardous Waste Program

(HW) for cleanup oversight, and which will go to the Cleanup (CU) Program.

New sites will come to the attention of the department through staff in either the HW

section or the CU Section. The specific staff will probably be field staff in the Site

Assessment Section, Voluntary Cleanup Program or HW Compliance Section. They will

be asked to review available information about the site to try to answer the following

categories of questions.

The questions are:

HW Violations

Has the facility been inspected by HW compliance inspectors and been found to be out of

compliance? Have informal (Notices of Noncompliance) enforcement actions been

issued? If so, how many? Have formal actions (orders, civil penalties) been issued? If

so, how many, and have they been finalized, or are they still pending? Are they HPV?

Has a criminal investigation been instigated? Has a HW technical assistance person or

TUR TA provider visited the site? Did they discover "clear and immediate" environmental

problems at the site?

Past TSD History

Has the site ever been considered to be a TSD (treatment storage, or disposal facility) in

the view of the Department or EPA? Has the facility ever applied for a TSD permit

application, or been an interim status facility, or had a permit denied? If yes, what is their

current status? Are they operating under a current order?

Past/Current Generator History

Has the facility operated or did operate gO-day hazardous" waste storage tanks that

were not clean closed? Were the tanks clean closed?

Type of Waste

What is the waste that has contaminated the site? Is it a hazardous waste? Is it, or was

. it, a listed waste? Is it a characteristic waste? (History of site concerning manufacturing

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process, method of waste' generated when generating.) What are the levels of

contamination?

Volume of Waste

How much waste was released or disposed of at the contaminated site? What is the

estimate of the amount (volume) of contaminated material that will need to be

remediated?

The staff will also review the status of the site as to the existence of Regulated and/or

Solid Waste Management Units (SWMUs) using the following description:

HAZARDOUS WASTE MANAGEMENT UNITS (REGULATED UNITS):

Regulated units include any of several possible "units" which are used to store, treat, or

dispose of a hazardous waste and are subject to Subpart F groundwater monitoring, '7

closure, post-closure permitting, financial assurance, and regulated unit corrective

action under RCRA, such as:

o Certain Tanks and Tank System Units

o Container Storage

o Surface Impoundments

o Waste Piles

o Land Treatment Units

o Landfills

o Incinerators

o Temporary Units (TU)

o Drip Pads

o Miscellaneous Units (Subpart X)

o Containment Buildings

o Underground Injection

RCRA definitions and standards for all of these units can be found in 40 CFR 264. Type

of units, number of units, variety of units, complexity of unit-rated issues, potential for

clean closing units, are all factors that will determine which program takes the lead for a

cleanup site. It is very important to properly characterize regulated units.

It is important to recognize that regulated units can be created. Typical examples of

regulated units created in the course remediation include waste piles and processes used

to treat hazardous waste containing media or groundwater.
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SOLID WASTE MANAGEMENT UNITS:

Solid Waste Management Units (SWMUs) are similar to, and include, regulated units,

but are where solid wastes have been managed. Technically, a Regulated Unit is a

SWMU, but Regulated Units are subject to the closure, financial assurance and

corrective action requirements listed above. SWMU corrective action was established

when RCRA was reauthorized in 1984 as a special requirement at all facilities subject to

RCRA permitting to address releases of hazardous constituents from all SWMUs on

a facility-wide basis.

The information summary generated by staff review for any specific site will be provided

to a group consisting of HW and CU managers. The managers will use the included

matrix "Preferred Site Lead/Regulated Authority" to determine the assignment of the site.

For any site that ends up in the part of the matrix marked "Joint Decision" the same

manager group will use the information gathered about the site and the definitions

described above to make the decision as to proper assignment of that site.

GEH:djh/cmp

x:\geh\site.ass
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PREFERRED SITE LEAD I REGULATED AUTHORITY

At Sites with Hazardous Waste Issues

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Unknown!

Unable

Operating

TSD

Subject to

Pennit,

Includes Spills

Systematic

Disoharges of

Hazardous

Waste

Spills Resulting

In Hazardous

Waste, .

Generation

No regulated

units

present