# • SECTION I 

### ·PROGRAM DESCRIPTION Table ofContents
I. 

### BACKGROUND
. . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1



# • II. SCOPE, COVERAGE, STRUCTURE, AND PROCESSES
. . . . . . . . . . . . .. 2 A. Scope.
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2 B. Coverage
. . . . . . .. 3 1. 

### Waste Designation 3 2. Generators
.. , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 5 3. Transporters.
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7 4. Recycling Facility Standards
. . . . . . . . . . . . .. 8 5. Treatment, Storage, and Disposal (TSD) Facilities ')' . .
.. 8 6. OtherRequirements 10 7. Availability ofInformation to the Public 10 8. Revision ofState Program
. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11 9. Summary ' . . . . . . . . . . . . . . . .
.. 12 C. Lead AgencyIdentification, Agency Structure, Budget; and Resource Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.. 13 1. 

### AgencyStructure and Organizational Responsibility . . . . . . . .
.. 13 2. Sources ofFunding and Restrictions 18 3. FY95 Hazardous Waste and ToxicsReduction Plan . . . . . . . .
.. 18



# • III. PERMITTINGPROCEDURES 28 A. Purpose
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28 B. 

### Existing TSD Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.. 29 C. New TSD Facilities 29 D. Permit Development Review and Approval Process for Existing and New TSD Facilities
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 30 

### E. Permits by Rule (PBR) (See WAC 173-303-802) 31 F. Emergency Permits 31 G. Judicial Review ofPermits 32 H. Permit Certification Language 32 IV. COMPLIANCE MONITORING AND ENFORCEMENT
.. . . . . . . . . . . . .. 35 A. Authority. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 B. Goal 35 C.**Objectiv~s.** 

### . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 35 D. Inspection and Enforcement Procedures.
. . . . . . . . . . . . . . . . . . . . . .. 38 

### E. Information Management 40

# • V. REGULATED COMMUNITY DATA 42 A. Number ofNotifiers by Activity Reported 42 B. Amount ofWaste Treated, Stored, and Disposed 43



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• VI. FORMS A. Book 1- 1995 Forms and Instructions (generators and transporters) B. Book 1- 1995 Forms and Instructions (TSDF Facilities)
. C. Book 2- Guidebook and Codes (For use with Annual Report Forms and Instructions, beginning in 1995)
. VII. STATUTES AND REGULATIONS A. RCW (Revised Code ofWashington) 1. Chapter 34.05 RCW (Administrative Procedures Act) 2. Chapter 42.17 RCW (Disclosure-Campaign Finances-LobbyingRecords) 3. Chapter 43.21A RCW (Department ofEcology) 4. Chapter**43~21B** RCW (Environmental Hearings Board- PCHB) 5. Chapter 70.105 RCW (Hazardous Waste Management Act) 6. Chapter 70.105D RCW (Model Toxics Control Act)
B. WAC (Washington Administrative Code) 1. Chapter 173-08 WAC (Implementation ofthe Environmental Coordination Procedures Act)
VIII. APPENDICES AppendixA. State 1989 Annual Report Summary Appendix B. Inspection Checklists Appendix C. Enforcement Policy Appendix D. TSD Facilities Appendix E. Chemical Testing Methods AppendixF. Biological Testing Methods

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• Figure 1. 

### Figure 2. Figure 3. Figure 4. Figure 5.

Table 1. 

### Table 2. LIST OF FIGURES Washington State Department of Ecology 15 Hazardous Waste and ToxicsReduction Program- Headquarters 16 Hazardous Waste and ToxicsReduction Program- Regional Staff
. . . .. 17 Permit Process for Applications Received Prior to SitingCriteria 33 Integration ofPermit, SEPA, 

### and CPN Processes for DW Facilities 34

LIST OFTABLES Funding Profile for the 1993-95 Biennium 19 FY95Program Plan- FTE Breakdown Summary for allRegions 20

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# •

• I." BACKGROUND In 1978, the Hazardous Waste Regulation Chapter 173-302 WAC, first empowered Ecology to define, track, and regulate the disposal of extremely hazardous wastes. With promulgation ofthe U.S. Environmental Protection Agency (EPA) hazardous waste regulations, the State regulations had to be revised to be "consistent and equivalent" with the Federal regulations. Chapter 173-302 WAC was repealed and replaced with WAC 173-303 WAC, the Dangerous Waste Regulations. The Washington State Legislature designated Ecology as the agency to implement the Federal Resource Conservation and Recovery Act (RCRA). In 1980, the State Legislature gave Ecology increased authority to permit dangerous waste facilities. In 1983, 1984, and 1985 the Legislature increased Ecology's authority to develop and implement a program consistent with RCRA. Development ofthe State regulations were primarily drivenby these two forces, the mandates of the Washington Legislature and EPA's burgeoning hazardous waste regulations. Consequently, the current regulations are a combination ofFederal and State hazardous waste directives. Three main features ofthe State regulations are derived from the Washington Legislature's 1976 directive, "theHazardous Waste Disposal Act Chapter 70.105 RCW: the "degree of risk" classification system, the dangerous waste tracking system, and rules for the EHW facility at Hanford. The classification system and the EHW facility rules are unique to Washington. The tracking system isidentical to its EPA counterpart. A more detailed explanation ofthe three original features follows . Prior to 1981, Ecology identified dangerous wastes according to the degree ofhazard posed by a waste to the public health and the environment. The waste classification system implemented by Ecology designated wastes by their level oftoxicity, persistence in nature, or potential carcinogenic risk (the three remaining state criteria), and by their tendency to ignite, corrode, and explode. These added to the federal{lists and characteristics resulted in more wastes being classified as dangerous than with the federal approach alone. This classification system depended to a large degree on established testing procedures, and scientific data"regarding the toxicity, persistence, and carcinogenicity ofthousands of chemicals that could be found in a given waste. Ecology felt that a "degree of risk" approach to designating wastes was best considering the enormity ofthe dangerous waste universe. Tracking dangerous wastes as they moved from the generator to the disposal site was based on the use ofa manifest system. The manifest, prepared by the generator, states the type, amount, origin, transporter, and final delivery point for a dangerous waste shipment. The manifest must be signed by the operator ofthe disposal site and returned to the generator to signify acceptance ofthe waste shipment. If the generator does not receive a signed manifest copy from the disposal site within a specified time, Ecology 1must be notified. Ecology then initiates a search for the missing waste. Rules for the operation and maintenance ofthe extremely hazardous waste (EHW) management facility at Hanford (this was to be the only facility in Washington which would dispose ofEHW) were adopted late in 1977 under Chapter 173-302 WAC. However, funds for constructing such a facility were never appropriated. Standards for the design and operation ofdangerous waste treatment, storage, and disposal (TSD) facilities were later developed to be equivalent to RCRA standards. These standards have been revised to keep pace with changes at the Federal level. The current version ofthe Dangerous Waste Regulations was most recently amended on December 8, 1993 to be equivalent, and consistentwith, RCRA. These amendments
. became effective on January 8, 1994. Nearly all of the federal core RCRA requirements have been incorporated into Chapter 173-303 WAC. Many ofthe HSWA rules, corrective action and the Toxicity Characteristic (TC) rule, have also been adopted.
II. SCOPE, COVERAGE, STRUCTURE, AND PROCESSES A. SCOPE 

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This program description represents the core ofthe state ofWashington's application for authorization ofthe "Dangerous Waste Management Program" to be operated by Ecology. The regulatory program developed for dangerous waste management is 

# 0 comprehensive, and is equivalent to and consistentwith the Federal RCRA program. The authorized State regulatory program isintended to operate in lieu ofthe Federal RCRA "base" program and those HSWA portions for which the State is authorized. All persons who generate, transport, transfer, recycle, treat, store, or dispose of dangerous wastes, as defined in the recently amended (January 1994) Dangerous Waste Regulations, Chapter 173-303 Washington Administrative Code (WAC), are affected. The primary purpose ofthe Dangerous Waste Regulations is to protect public health and the environment from improper management ofdangerous waste. The State program, administered by Ecology, has regulatory authority over nearly all areas ofdangerous waste management, including notification, inspection, monitoring, permitting, compliance monitoring, manifest tracking, and enforcement. Some ofEPA's rules promulgated pursuant to the Hazardous and Solid Waste Amendments (HSWA) (amendments to RCRA passed by Congress in 1984) have not yetbeen adopted by the State. Ecology expects to adopt the remainder ofthe HSWA regulations (e.g. Burning in Industrial Furnaces and Boilers and Air Emission Standards) during 1996.



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B. COVERAGE Ecology recently amended its regulations to update the Federal portions of the State rules to be consistent and equivalent to RCRA, and to improve and clarify some of the "State-only" portions of the rules. Many of the concepts developed for the 1980 rules remain essentially the same, such as the dangerous andextremely hazardous waste (DW/EHW) two-tier designation system. Other areas, such as the listing approach and standards for dangerous waste management (TSD) facilities are directly from RCRA. The following descriptions provide a basic framework for the amended Washington State Dangerous Waste Regulations, Chapter 173-303 WAC. Note: Rules for which Ecology is seeking authorization are described in bold type. 1. Waste Designation Ecology includes procedures in Chapter 173-303 WAC foridentifying solid wastes. These procedures are essentially identical to EPA regulations, with some exceptions for materials that would not be federal solid wastes (i.e., the State standards are more stringent in some ways). Ecology's requirements assure that any materials EPA considers to be solid wastes will be also be managed as solidwastes by the State. Washington's designation scheme relies on three mechanisms to designate wastes as dangerous: lists, characteristics, and the State-only criteria. This scheme incorporates and expands upon EPA's waste designation procedures
. The Washington lists are based on EPA's lists. The EPA procedures for designating wastes depend primarily on two lists: the Discarded Chemical Products List and the Dangerous Waste Sources List. Both ofthese listswere developed by EPA and adopted by Ecology (see WAC 173-303-9903 and 9904). EPA's 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 off-specification manufacturing chemicals and listed those which met the criteria. For the SourcesList, EPA studied data on various industrial processes and their typical waste streams, then listed those sources ofwaste which met the criteria. Ecology further assigns a DW/EHW designation to each waste which appears on the lists. The second designation mechanism is the dangerous waste characteristics. Wastes with the following physical hazards may be designated as dangerous: Ignitable

- wastes which are highly flammable; Corrosive

- wastes which are highly acidic or alkaline (the State also regulates solid corrosive wastes); Reactive

- wastes which are explosive, unstable, or would readily release toxic fumes; and wastes which are toxic according to the Toxicity Characteristic (TC)- wastes containing concentrations ofvarious metals, pesticides, or organic chemicals above the regulatory thresholds. The toxicity characteristic was revised by replacing the Extraction Procedure (EP) with the Toxicity Characteristic Leaching Procedure (TCLP). Twenty-five organic chemicals were added to the previous 3list regulated under the toxicity characteristic. The State has been implementing theTC rule for more than three year's with no need for additional resources. 

# 0 Finally, Ecology augments the lists and,characteristics with its own criteria for acute toxicity, persistence, and carcinogenicity, first developed for the 1977regulations: The criteria apply to wastes that are not listed or characteristic wastes. The criteria apply when the generator knows the constituents ofthe waste and/or the constituent concentrations. If

### this knowledge shows that the waste meets the criteria, then it would be designated as dangerous or extremely hazardous waste. The criteria are also used by generators ofunlisted wastes who have been required by Ecology, or who choose voluntarily, to test theirwastes against the criteria and designate theirwaste accordingly. The State also regulates mixtures of waste. This allows generators to ''book designate" waste if they know.some or all of the constituents in theirwaste by adding together known constituents that have been shown to be toxic, carcinogenic, or persistent. To be consistent with the Federal Land Disposal Restrictions [i.e. to ensure that all applicable waste treatment codes will be identified), Ecology's rules require thatwastes be designated through the lists and characteristics. Designation through the criteria is required ifthe generator has "knowledge" that theirwaste could designate under the criteria, or ifEcology requires the generator to test theirwaste. 

### Ecology also provides procedures for exempting and excluding wastes from regulation if a generator petitions Ecology and can make a successful demonstration that his waste should not be designated (in the case ofcategorical exclusions, a group ofgenerators 

# 0 must petition/demonstrate for all wastes of a particular class). No wastes which exhibit any of the characteristics (ignitability, corrosivity, etc.) will be exempted or excluded, and no waste which is listed or exhibits any characteristics will ever be included in a categorical exclusion. Wastes which are listed must pass the criteria and characteristic tests, and must be determined, first by EPA and then by Ecology, to meet the additional factors for delisting (the state factors are identical to those of 40 CFR 261.11(a)(3)). Wastes which are not listed and do not exhibit any characteristics, but are designated by the state's criteria may only be exempted ifEcology 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 not 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 ensures that all federal wastes are properly designated and subject to 

### the applicable requirements. Ecology has 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 is more stringent in some ways than the 'federal approach (e.g., lower quantity exclusion limits). The state's approach to designation incorporates and complements all the elements of the federal approach, thus assuring equivalency with (or, 4 

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in many cases, exceeding) the requirements ofEPA. Ecology has continued to amend its lists ofhazardous wastes (including the Dangerous Waste Constituents List) to include new federal listings. Listings include wastes from the production ofdinitrotoluene and toluenediamine (Klll, K112, KI13, K114, and K115),

,wastes from the production oftoluene diisocyanate (KI16), wastes from primary metals

manufacturing (K064, K065, K066, K088, K090, and K091) and discarded chemical products ofo-Toluidine (U328) and p-Toluidine (U353). Arecent change to the commercial chemical products listing description clarifies that residues, inner liners and containers are regulated unless "empty" (as described in Chapter 173·303 WAC). These

, additional wastes have been regulated by Ecology for over three years with no additional

need for resources. The State is more stringent than EPA regarding mixtures ofsolvent wastes (the ten percent rule) and does not set a threshold on concentration. Any amount ofwaste solvents that meet the listing description in the nonspecific sources list (FOOl through F005) results in waste that is designates as hazardous under Ecology's regulations. Ecology has provisions in State law that allow the State to regulate mixed wastes containing hazardous components subject to the Resource, Conservation and Recovery Act and radioactive components subject to the Atomic Energy Act (AEA). RCW 70.105:109 states that "The department ofecologymay regulate all hazardous wastes, including those composed ofboth radioactive and hazardous components, to the extent it is not preempted by federal law." 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." The State does not have this exclusion. 2. Generators The state program regulates all generators covered by 40 CFR Part 262, including requirements for EPAidentification number, reporting and recordkeeping, accumulation ofhazardous waste for short time periods (including container and tank standards), packaging, labeling, marking, placarding, international shipments, manifesting of hazardous waste for off-site shipment, and notification procedures for interstate shipments. The State requires generators to keep all records for five years instead ofthe three year requirement for some records contained in the federal rules. Persons generating dangerous waste must prepare a manifest before sending waste to a TSD facility. The manifest includes information on the generator, transporter, TSD facility, the type ofwaste, and its quantity orvolume. 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. Ifthe generator 

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### does not receive a copy of the manifest signed by the facilityowner/operatorwithin 45 days ofshipment, an Exception Report.mustbesubmitted to

### -Ecology. WhenEcology 

# 0 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 required all dangerous waste shipments to utilize the Uniform National Manifest after September 20, 1984. Generators must report annually (rather than every two years as required byRCRA) to Ecology the quantities and types ofdangerous 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 provide Ecology with a means to track the generation, movement, and ultimate disposition ofdangerous'wastes in Washington. This system reduces the amount ofuncontrolled dumping and illegal disposal ofdangerous waste which historically posed a national public health and environmental hazard. Generators involved with international shipments (exports) 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 farmers who manage their pesticide wastes on their own land to be exemptfrom the generator requirements. To qualify for this exemption, the farmer must either reuse his or her pesticide residues and rinse waters (e.g., in the 

# 0 next batch ofpesticide) 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 mannerwhich 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 may be instructed to apply 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 the farmer as a generator. Disposal ofpesticide wastes elsewhere is subject to Ecology's generator and other dangerous waste requirements. Small quantity generators (SQGs) are those generators ofdangerous waste who generate less than 220 pounds per month or batch ofdangerous waste (DW) or less than 2.2 pound ofextremely hazardous waste (EHW). SQGs have reduced waste management requirements. They may accumulate listed, characteristic, or criteria wastes on-site; however, ifthe amount ofwaste accumulated equals or exceed the "quantity exclusion limit" (QEL) for that waste- 220 pounds for DW or 2.2 pounds for EHW- the generator is no longerconsidered an SQG. An SQG is responsible for determining whethertheir

. waste designates as a dangerous waste and for ensuring that theirwaste is treated or 

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• disposed of in an on-site facility or is delivered to an off-site facility that is either 1) a permitted facility underthe Dangerous Waste Regulations, 2) authorized to managed dangerous waste by another state, 3) permitted to manage moderate-riskwaste, 4) . beneficially uses orreuses, or legitimately recycles orreclaims the dangerous waste, or treats the waste prior to recycling, 5) permitted to manage municipal orindustrial solid waste, or 6) a publicly ownedtreatmentworks (P01W) ifthe SQG meets the requirements ofthe domestic sewageexclusion. These are the only requirements SQGs mustcomply with; however, ifthese requirements are not complied with, then the SQGs become "fully regulated" under the whole Chapter. Under RCRA, this class of generators is known as Conditionally Exempt Small Quantity Generators and they may accumulate up to 2200 pounds ofdangerous waste. Ecology regulates anotherclass ofgenerators with reduced waste management requirements, those who generate between 220 and 2200 pounds ofdangerous waste per month orbatch. These generators must not accumulate more than 2200 pounds of waste on-site or they become subject to the requirements of the whole Chapter. This is more stringent than the Federal accumulation limit of 6000 pounds. This class of generators must complywith all generatorrequirements except for the following reduced requirements. They may accumulatewaste on-site for up to 180 days, and may be granted an extension if the waste must be transported overa distance of twohundred mile or more for off-site treatment, storage, ordisposal when the waste must remain onsite due to unforeseen, temporary and uncontrollable circumstances. Generators in this category also have reduced requirements regarding contingency plans and emergency procedures, and do not need to comply with the requirement for personnel training. 3. Transporters The regulation requires transporters to comply with U.S. Department ofTransportation (DOT) rules under 49 CFR 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 ofdangerous wastes during transport. Ecology required alldangerous waste shipments to utilize the Uniform National Manifest (UNF) after September 20, 1984. This assures that interstate shipments are in accordance with DOT requirements.: The State has some additional requirements for transporters who importwastes from outside the United States beyond the federal requirements. Such transporters must act as the generator ofwaste and comply with all applicable generatorrequirements (e.g., manifesting, packaging). In addition, the State requires that a notification be sent to the regional office where the waste is being sent. The notification must include information regarding the importer, exporter, and waste (names, addresses, telephone numbers, EPA/state ID number) a description ofthe waste and estimated frequency at which the waste is to be imported, estimated total quantity, and a description ofthe manner the waste will be managed). Transporters who export wastes must comply with federal
7requirements administered by EPA (40 CFR Part 262 Subpart E and export requirements at 261.5, 261.6, 262.41, and 263.20). In addition, copies of forms and reports submitted by transporters to EPA must also be sent to Ecology. 4. Recycling Facility Standards EPA standards for recycling hazardous wastes are included in Ecology's regulations. These include recycling constituting disposal, precious metals recovery, battery recycling, burning for energy recovery, and numerous regulatory exemptions for certain recycling practices. Ecology's recycling standard's are virtually identical to EPA's, with the exception ofrecycling provisions for state-only dangerous wastes. Ecology is moving toward regulating "burning for energy recovery" under separate statute. Less stringent standards are applied to state-onlywastes when they are stored for short time periods prior to recycling.
. Ecology adopted additional requirements for owners oroperators offacilities who do not store recyclable materials prior to recycling. These requirements, which are broader in scope, include: performance standards, required" notices, security, general inspection, personnel training, preparedness and prevention, contingency plan and emergency procedures, emergencies, manifest system, facility" recordkeeping, facility reporting, other general requirements, and some container and tank system requirements. 

## s. Treatment, Storage, and Disposal (TSD) Facilities Ecology adopted EPA standards for the design, performance, operation, and maintenance ofTSD facilities essentially unchanged. Ecology adopted its own rules for siting facilities. In general, these standards ensure that a facility is properly performing the dangerous waste storage, treatment, or disposal activities that are occurring at the facility. TSD facilities must have adequate security, personnel training, inspection schedules,
"emergency plans and equipment, records ofoperation, environmental monitoring,

documentation offinancial responsibility, closure and post-closure plans, and reporting before Ecology will issue a permit to a facility. TSD facilities must be sited and operated to comply with the state's revised siting criteria. The siting criteria serve as an initial screen in the consideration ofsites for dangerous waste management facilities. Their purpose is to immediately disqualify proposed dangerous waste facility sites in locations considered unsuitable or inappropriate for the management ofdangerous wastes. They prohibitfacilities from being located in areas subject to natural hazards such as floodplains and unstable soils, and environmentally orculturally sensitive areas such as sole source aquifers and designated historic areas. Minimum setbackdistances have been established from identified resources. For example, land disposal facilities must be located at least 1/4 

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# • mile from perennial surface water bodies. 

### Facilities managing reactive wastes are required to comply with the setback standards in the Uniform Fire Code (see UFC Table 77-201, 1985Edition). Facilities must also required to satisfy all applicable local, state, and federal laws (such as local comprehensive plans, air and waterpollution laws, endangered species, etc.). Companies that generate, treat or store hazardous waste in tanks mustcomply with tank standards for: assessing existing tank systems' integrity, the design and installation of new tank systems or components, containmentand detection ofreleases general operating requirements, inspections, response to leaks or spills, closure and postclosure, requirements for ignitable or reactive wastes and requirements for incompatiblewastes. The State requirements are identical to most of the Federal requirements, butare more stringentin some areas such as: the State does notinclude an exemption from the requirements for reactive orignitable waste; the State requires developmentofa C schedule ofintegrity assessments; any release above the reportable quantity must be . reported; tanks must be located in a mannerequivalentto the National Fire Protection Associate's buffer zone requirements or as required by State and local fire codes (whichever is more stringent); generators of between 220 and 2200 pounds are limited to accumulation ofup to 2200 pounds; documentation is required ofthe precautions taken for ignitable, reactive or incompatible wastes; yearly inspectionsand additional monitoring are required; a description ofmarking and 

### lor labeling; and tankdesign to prevent escape ofvapors and emissions ofacutely or chronically toxic EHW.

• Groundwater monitoring. All land based hazardous waste treatment, storage, and disposal facilities (including miscellaneous units) must monitor groundwater and analyze for a specified core list ofchemicals, plus other chemicals specified on a sitespecific basis. The State regional offices have been implementing the groundwater monitoring requirements for more than threeyears with no appreciable need for additional resources. In 1991, the state adopted EPA's permit modification scheme (class I, II, and III modifications); standards for Miscellaneous units (Subpart X); groundwater statistical methods; tank system treatment and storage standards; and the rules for research, demonstration and development permits. The State has been implementing these rules for over three years.with no need for new resources. While the initial permits are written in Ecology's permitunit located at headquarters, permit modifications are handled eitherin Ecology's regional offices orthe Industrial Section, as appropriate. Research, demonstration and development permits are to be done primarily by the headquarters permits unit. When appropriate, they may be written byregional or Industrial Section staff. 

# • The Permits Unit ensures compliancewith financial responsibility requirements by all TSDs except for facllities regulated bythe Industrial or Hanford Sections
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### .Ecology adopted many of the TSD requirements directly from the EPAregulations although some were modified to reflect the differences between dangerous and-extremely hazardous waste management practices or to address concerns in Washington State. The state rules either achieve EPA's requirements for equivalency or are more stringent. Interim status standards for TSD facilities, cited in WAC 173-303-400, 

### adopt 40 

### CFR Part 265 

### Subparts F through R by reference. Ecology assures that the state's reference is currentwith EPA changes for Interim Status facilities byupdating WAC 173-303-045. 

### This section provides that any EPAregulations that are adopted by reference inChapter 173-303 

### WAC reflect federal rules in place on July 

### 1, 1993. Thus, recent EPA changes to the interim status tSD facilityrequirements have been included in Chapter 173-303 

### WAC. Closure/post closure care standards for interim status surface impoundments were adopted in this manner. Closure and post-closures are performed in Ecology's regional offices. The regional offices have been implementing the rules adopted in 

### 1991 for over threeyears with no need for an increase in resources. 

### Additionally, byupdating

.WAC 173-303-045, 

### as above, the expanded corporate guarantee for liabilityinsurance

was included in Chapter 173-303 

### WAC. Ecology adopted stringent operating standards for the extremely hazardous waste disposal site atHanford. The current status of the site at Hanford isthat the land was purchased from the federal government and remains in an inactive status. 

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Due to changes under RCW 70.105.215, 

### Ecology included additional permitcertification language for situations where the owner and operator of a TSD facility are separate 

# 0 entities. Ecology and EPA have agreed to require TSD applicants sign both the federal and the state certification when applying for a TSD permit.
. 6. OtherRequirements 

### The Dangerous Waste Regulations require all persons who generate, transfer, transport, treat, store, or dispose ofdangerous waste to have an EP

### Nstate identification number (EPNstate ID#). Those individuals requiring such a number must notify the state of their activities before being issued a number. The regulation also establishes procedural requirements for permit application and issuance, public involvement, petitioningEcology for changes and exceptions to the regulations, testing methods (The latestrevision of SW

### 846 has been incorporated by reference into the State's test procedures), 

### sampling methods, and conditions for exemption from the rules (recycling or recovery ofdangerous wastes, triple rinsing ofcontainers, etc.). 7. Availability ofInformation to the Public 

### Ecology uses provisions in state law for disclosinginformation to the public. Ecology's attorneys have certified the following in an Attorney General's Statement:

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• Information is available to the public in a manner equivalent to the provisions of 40 CFR Part 2.· Ecology willprovide responses in no more than twenty days (as required by WAC 173-303-901), and, generally, in much less time than this. Most informationisgenerally available to the public without the need to submit a formal request for disclosure (e.g., regulations, policystatements, pamphlets, annual report summaries, press releases). In addition, Ecology provides reasonable assistance to persons requesting information by helping such persons identify the records sought and, where necessary, by helping in the preparation of disclosure requests. Subject to certain exemptions (seethe Attorney General's Statement), Ecology provides the fullest possible disclosure ofrecords and information sought by the public. This information is always provided free of charge, with two exceptions. First, if extensive copying costs are involved, then a fee may be charged. Second, if the information request involves significant costs from manipulating existinginformation into new forms (e.g., preparingbrand new reports, conducting studies, correlating computer-based data), then a fee maybe 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 ofapplicable appeal procedures and statutes of limitations. If

### a disclosure request is denied because a claim ofbusiness confidentialitycould 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. 8. Revision ofState Program Whenever Ecology revises itsprogram, EPAwill be contacted to determine what modifications are necessary in the memorandum ofagreement, Attorney General's statement, or other documents. Ecologywill modify the documents, as appropriate, and submit them to EPA for approval. Ecology does not expect to transfer any of its authorized functions to any.other state agencies. Ecology intends to continue picking up Federal rules according to the rulemaking requirements. When Ecology finds that it isnecessary to amend State laws or regulations due to EPA's promulgation of new regulations, then the State willproceed 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 accomplishedwithin one year. If

### the statutory changes are controversial,·two years may be necessary. Ecology. believes that amendments to State laws can be provided in two years or less in all cases. 11,

I**j---~--** - - - I ! (b)

. 

### Regulatory changes. Amendments to State regulations will be made in accordance with Chapter 34.04 RCW, Administrative Procedures Act, and willgenerallybe accomplished ineighteen months or less. Ecology willprepare proposed regulatory language and confirm with EPA that it willproperly address the changes at the Federal level; this should require no more than three months. Ecology has a lengthy,. involved rulemaking process with several steps beyond the Administrative Procedures Act required throughout the process, e.g. a rule development plan must be written and presented to the Agency Rules Coordinating Committee (ARCC). Following approval bythe Assistant Director ofthe rulemaking plan and preparation ofdraft rule language, Ecology files the proposed language with the State Code Reviser for publication in the State Register; once the proposed language appears in the State Register, the amendments should be adopted within sixmonths. The first public hearing may be held 20 days after the proposed amendments are published. The public comment period may end no soonerthan one week after the last public hearing and generally lasts for thirty to forty-five days. Ecology willthen prepare finalamendatory language and file the final changes with the Code Reviser. The new regulation is usually effective thirty-one days after adoption although the effective date may be later, if necessary. Thus, simple amendments will take as few astwelve months from the beginning of the rulemaking process to the actual effective date. More complicated changes may take as long as two years before the new rules go into effect. 9. Summary As 

### a summation, the amended Dangerous Waste Regulations Chapter 173-303 WAC: (a) Designate those solid wastes which are dangerous or extremely hazardoustopublic health and the environment; (b) Provide for proper management ofdangerous wastes until they are recycled, reclaimed, treated, or disposed of safely; (c) Provide a manifest system for tracking, reporting, monitoring, recordkeeping, sampling, and labeling ofdangerous wastes; (d) Establish requirements for the siting, design, operation, and monitoring ofdangerous waste management facilities; (e) Establish design, operation, and monitoring requirements for managing the state's extremely hazardous waste disposal facility; 

### (f) Establish and administer a program for permitting dangerous waste management facilities; and (g) Provide for enforcement against persons who violate the requirements of the act and
12 

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• the Dangerous Waste Regulations
. C. LEADAGENCY IDENTIFICATION, AGENCY STRUCTURE, BUDGET, AND RESOURCE ASSESSMENT 1. AgencyStructure 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 programmatic lines with the regional offices set up to act as the operating arm of the agency. Each program functions under an appointed Program Managerwho reports to an Assistant Director and the Director of the Department. For purposes of the Dangerous/Hazardous Waste Program there are three organizational groups within Ecology that have program responsibilities. These are the Hazardous Waste and Toxics Reduction Program in both the headquarters and regional offices, and the Industrial Section (Central Programs) and the Hanford Section (NuclearWaste Program) both located at headquarters. In 1990, the Hazardous Waste and Toxics Reduction Program (along with the other Ecology programs) were reorganized to bring staffin line with function. Prior to the reorganization, the regional offices were located in and managed by the Central Operations Program. Now, the Regional Office Section Supervisors report to the Program Managers ofeach respective program in the headquarters office. . In 1993, the former Solid and Hazardous Waste Program (SHW) and Waste Reduction and Recycling Program (WRRLC) were reorganized into the new Solid Waste Services Program and the Hazardous Waste and Toxics Reduction Program. Currently, the Hazardous Waste and Toxics Reduction Program Manager supervises two headquarters sections plus the HWTR staffin the Regions, as shown in Figure 2 and 3. The headquarters sections are the Technical Assistance and Policy and Information and Permit Management Sections. The Technical Assistance and Policy Section (TAPS) has authority and primary responsibility for program planning, development, and management of the HWfR Program (Figure 2). The TAPS developed and updates the state hazardous waste plan which includes recommendations for addressing Hazardous waste issues. The TAP Section develops new policies, program guidance, and regulations; it also provides technical assistance, regulatory interpretations, and information for incorporating pollution prevention to businesses and industry. The section works with the EPA to see that RCRA requirements for hazardous waste management are properly carried out on the state level. TAPS provides technical assistance to inspectors and permitwriters in the Regional Offices, Industrial Section, 'and Hanford Section, coordinates compliance

. . monitoring activities and ensures statewide consistency in the application of the regulations. Most public involvement aspects of the program are carried out in the 

### 13

### Headquarter's Sections. The Information and Permit Management Section collects and analyzes data on hazardous waste streams and waste generators (annual reports, etc.) and supplies information on hazardous substances through community right-to-know laws. Any necessary tracking and reporting functions, including the,..annual report, are the responsibility of this Section. They assure compliance with the "Hazardous Waste Reduction Act"whereby generators in excess of 2,640 pounds ofhazardous waste per year and facilitiesrequired to report under SARATitle III, Section 313,are required to prepare comprehensive hazardous substance use/hazardous waste reduction plans. They are responsible for collection ofpollution prevention plans, computer support, training opportunities, and legislative tracking. The Hazardous Waste Permits Unitissues permits for facilities that store, treat or dispose ofhazardous wastes. Before a facility can receive a permit, it must successfullydemonstrate that it complies with stringent state and federal laws and will not harm public health or the environment. The Permits Unitis a centralized unit in 

### the HWTR Program thatwas organized to concentrate permitting expertise into one group. They are responsible for, or assist with, permits for many of the more complex TSD facilities in the state. The Permits group coordinates permit activities and writes permits at selectedTSD facilities. The regional officestaffhave the authority and responsibility for all operational aspects ofthe HWTR Program(Figure 3). The four Regional offices are located in four· geographically separated regions ofthe State with HWfR Program stafflocated in each region. The regions cover Southwest, Northwest, Central, and Eastern Washington. Each regional office has a designated hazardous waste group. The regional staffare responsible for carrying out compliance inspections, conducting closure and post-closure activities (overseeing closures), reviewing plans and permits, providing regulatory interpretations and technical assistance, responding to citizen complaints about such things as hazardous materials spills and illegal dumping, and overseeing corrective action. They are the primary agency contact with allgenerators, transporters, and some TSD facilities. Regional staffimplement the agency enforcement policy bydocumenting and making recommendations for enforcement actions to their Regional Section Supervisor who has signatory authority for all enforcement actions within theirjurisdiction. These supervisors report directly to the Hazardous Waste and .ToxicsReduction Program Manager. They use the guidance and policy provided by the TAPS and are responsible for completing the work plan commitments negotiated by the HWTR Program. 

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The regional office functions are also carried out by the Industrial Section, located in Central Programs. The Industrial Section has major industries as their area of responsibility (e.g., pulp and paper, oil refining, and primary metals). This section essentially acts like a fifth region, performing compliance inspections and writing permits for most of their facilities. The Hanford Section of the Nuclear Waste Program is responsible for alldangerous/hazardous waste and hazardous waste cleanup program activities at the Hanford Reservation.

I I I I I 

### l------.--------

-

__ . __._ I 14 

# o, 

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# • WASHINGTONSTATEDEPARTMENT

## OFECOLOGY SEPTEMBER 1995 

# •

OFFICE OF ATTORNEY GENERAL DIRECTOR I DEPUTYDIRECTOR SENIOR ASSISTANT ATTORNEYGENERAl Mary Rlveland I Terry Husseman JayMenning

459-61511 '- 

### - 

## - 407-7001 I <407-7002 &lvJoIJey**46~8I"B** Tony Montoya t Diann. Pasto,. 407-7010 407-7009 

### I I I ADMINIITRATIV& EDUCATION & eMPLOYE!! IERVlCI!I INf'OfUMnON LeGISLATIVe& SERVICES PUBUC INFORMAnON DIRECTOR INTEGRATION IN11!RGOVERNMENTAl ASSISTANT DIRECTOR DIRECTOR JoiSI.GlImlaln PROJECT RE...-TIONS Pet lee KIm Conlrla 407.e218 PROJECT MANAGER DIRECTOR 407-700!i "07-7004 CherGotfl lynn Singleton Bill AIldr. 01_ SchenkIKntySlIJrw Joan Wolcott 407-81" 407-M10 407-7003 407-7007 <W7-7008 FtJIfhKelao IIIckIe VanNN4 407-7015 407-700'

CENTRAL PROGRAMS CENTRAl EASTERN WASTE MANAGEMENT WATER&**SHORI!~DI**

& I!NPORCEMENT REGIONAlOfIFICE REGIONAlOJlJIICI! ASSISTANT DIRECTOR ASSISTANT DIRECTOR ASSISTANT DIRECTOR REGIONAl DIRECTOR REGIONAl DIRECTOR Den SIIvef' lindaCren" D.J.PlIlln PatSpurgin Claude Sappington 407-7011 407-7013 407-7012 (509) "57-7120 (509)
..58-e1
..9 JaniceJacklIOfI Leua AndrHlIon FtJIftIKeIso Judyweston Marilyn NeI«In 407·7014 <W7-7018 407-7015 (50")457-7121 (5tJ,,) 456-2635
AlRQUAlITY CENTRALPROGRAMS NORTHWEST SOUTHWEIT HAZARDOUS WASTE NUCLEAR WASTI! SHORI!LANDS & WATI!RQUAlITY PROGRAMMANAGER PROGRAM MANAGER REGIONAlOJl

...CE REGIONAl OfI

...ce &TOXICS REOUCnON PROGRAM MANAGER WATER RESOURCes PROGRAM MANAGER JoeWlIllama Greg Sorlie REGIONAl DIRECTOR REGIONAl DIRECTOR PROGRAM MANAGER MlkeWIIaon PROGRAM MANAGER MIleu-tyn

407-M80 407-81177 Mike Rundlelt SueMeUemlllflll MeganWhHe '"'7-1150 C.,o/Fla. '"'7-6405 GeIryKunkel P9r1rJyHaflJll1ll (206) &49·7010 '"'7-8307 ..ONI702 TammieIIIcClute ,",7.ee02 Juu.Ruatw

<W7-eB7" 407-6966 NancyGIOlI93 LornaMendez-ConN MIncyHlIutenne 407-7141 Ulla NlIwman <W7-4448 (20B)**B4~7012** <W7·B308 407-8705 <W7·tJ«)4

ENVIRONMENTAL LOCALGOVERNMENT TOXlcaCLEANUP INVI!SnGATIONS SOliD WASTE PROGRAM MANAGER & ...-BORATORY PROGRAM MIllryBurg

SERVICES PROGRAM MANAGER "07-7177 PROGRAM MANAGER Jim Pendowald Carol Perez Keith Phllilpa 407-8103 407-7173

,",7-Mf19 HeIwIFOI( aayla Lord 407-8105 <W7·8B"5j**-~---** 

# Ii·· I ljll.l c 

### "2. 

## HAZARDOUS WASTE AND TOXIC REDUCTION Headquarters
MeganWhtte ProgramManager

(WMS03) 0836 

# I NancyHautanne 52 (2334) DIannateal
...... CT3 IT (3162) I TomCook Information & PermitManagement (WMS 02) 2692

Artene Kellennen 51 (2237) Ed Benttey(temp) CIC3 (2801) Dave Oubnull EP3 (1100) Lo

....HewItt TechnicalAssistance & Policy (WMS 02) 0902
Cethy Bouge 51 (2680) Dennl. Bowhay E55 (1123) Tom

# Lo,...... EP4 (P302)
I I I I I TyThomaa Darin RIc. I Dan Kruger Bob Lemcke JerryLena..., TAPS TAPS. IW InfolTJainingIData Support Pollution Prevention/CATK Permits ES·2C (2408) ES·2C (3141) I ES·2B (1184) ES-2B (2763) ES·2B (2319) T I I 

### I I I TomCuuck E54 (2383) Dave Rountry ES4 (2355) i

....**A~** ES3 (1147) John Rlduw-y ES3 (2281) Vacant 51 (2832) JerryPerker EP3 (3052) BonnieMeyer0.5 EE0S3(2868) I LarryMcCallum EP3 (3051) Michelle Elling ES3 (2919) I c.nne PhlIlIpMnES3 (2906) Mil
.. Kuntz ES3 (2097) .JoanMonte EE1OS2 (3287) avtd

# Zlnkl ES2 (0156) Tim Gllffney EP3 (2878) DaveOllv'" ES4 (2317) ChipperHervleux E53 (2407)
.........SChleyer ES2 (3023)**atNeen~ES3** (0810) ldell Hanaen E52 (2082) Janet Rhodea EP3 (2327) Bert Ponton ESl (1190) Judy Kennedy EE2 (2788)
, 8CheI

### a.Inona ET (2716) HollySullivan

. ET (3379) MartyWerner' EE4 (2328) Lynn Halbrecht EP3 (2670) ShlrteyLevIg0.5 EElpS2 (2381

### '-I~ ET (0358) SadIeWhitener ET (3135) Rob Kirkwood EP4 (3398) HallyJohnaon E5 (1083) P

.....cl. Jetczak ES4IT (3023) d

..... CIC2 (2801) Jig,... P.rikh AI2 (0784) Sr. Volunteer Peggy Morgan ES4 (2081) I I StacieSingleton EE2 (2325) I ell Peck CIC2 (3054) Vacant EEIOS3(2348) Vacant (3141) 

# I I 95-HWTft"O'v95(101'271'95) I 

# 0 0 0, \ { \,' \ I ( 

# • HAZARDOUS WASTE • TOXIC REDUCTION 

## Ragrons 

# •

MeganWh1t8 ProgramManeger

(WMS 03) 0836 

### I 

# f

NllncyHe........ 

### W DIMna**K8IIergM~** 52 . (2334) 

### I ICT3 IT (3182) 

### I I I**~.** Juliesellick NWRO (WMS 02) 2397 K8ySeller SWRO (WMS 02) 3405 Jlm

....m ERO (WMS 02) 0209 PoIIyZelm 

### eRO (WMS02) 2881

r 

# I.....,. CMnon

## 1. 51 (2356) 

## I r 

# IDonna**NIchoIeon~** 81 (2n9) 

### I**Al IhI** **""** 51 (0222) 

## I I RutIIKotynta \ 81 (3234) 

## I 1

95-HWTR2JOrg95 (10127195) (2997) u.rttBenedict ES3 (3117)lind l1m HopIdn..... E52 Temp (3062) reportdIrecty10MdIon**~.** DennieBowMy ES5 (1123) WOfbtorTAPS. Jim8Ilohet HWCompUnlt E8-28 (3036)**JIm~** .... ES3 (3038)**Dlck~** ES3 (2380) Tom
......... HG3 (2573) ChrtIidMz.tIr ES3 (303t)

8
.... DIck

.HWComp Unit

eS·2A (2976) 

## I DougJ-rne TR Unit ES·2B (0302) 

### I Demon0eI1atntty Toxl (2979) John Blunt ES3 (2831) c.nNIefnnlldort ES3 (3016) JIlnBrydlln ES3 (1188) ..." Ph/l/lpe ES3 (3162)**~IlnTuu** CT3 (3079) EdHllrn HG3 (1173)**VIId~** ES3 (2581) Lynn
..... ES3 (2978) W8peKtetft ES3 (1122) Kelth8tohl HG4 (3065) BobWwren HG3 (2433) Leon WIllhelm EE3 (0144) KalIl

........... HG2 (3447) De". PolIvka HG3 (2083) V

..... HG3 (P261) ttow.d8tMtey EE5 (0180) lAee.gley ES4 (0678) UzaAormyft ES2 (2033) 

# _c.on
ES2 (2665) NlcIcyRu

.... ES3 (2832) JCAnnbru8W E52' (1185) 0.". saundera ES3 (2946) o.nWll1ey ES3 (2679) oev.MIAo ES4 IT (0169)**...."ne~** ES3 (2681) MichelleUndelwood ES3 (0187) J. DaivldttohrNnn ES3 (1171) BobStone ES3 (2989) Don Seeberger ES3 (1188) Victoria Sutton ES3 IT (1083) DeYidHovlk ES1 (3043) V8C8fIt AI2 BarbSmith

HWTech CompUnlt"1**E~·2r. t2~90\**  T Hideo Fullt. HWTechUnlt e8-3A (2591) OeM

..JoIwleon TRUni e8-28 (0425) awtet. EE2 IT (3120) PMear-

.... EE2 (2864)**Ann~** EP2 (3041) SooftLMlb ES4 IT (3027) AIioe

.... EP2 (3119) Rob
..... EE3 (3084) PatLodle ES3 (3028) o.vId--. EP2 (3083) EIIIonZIInmeI_ EP3 (2551)2. Sources ofFunding Table 1. Funding Profile for the 1993-95 Biennium (July 1, 1993 - June 30, 1995)

FUND Fiscal Year Fiscal Year 1993-95· 1994 1995 Biennium 

### (Actuals) (Estimates) Totals General Fund-Federal (1) $1,495,323 $1,384,115 $2,879,437 State/Local Improvements AccountWaste Disposal Facilities 26,244 26,249 52,493 Worker and Community Right to Know Account 163,580 184,725 384,305 State Toxics Control Account 4,807,529 5,467,902 10,275,431 Hazardous Waste Assistance Account 1,036,686 1,355,838 2,392,524 TOTALS $7,529,361 $8,418,829 $15,948,190

Major funding sources for the Dangerous Waste Program include federal RCRA grants, the state genera) fund and the StateToxic and Hazardous Waste Assistance Account. Figures only included costs for the HWTR Programs. Ecology's Program Administration is not reflected in these figures. Their cost is based upon an indirect rate negotiated between Ecology and Department ofInterior. Current rate is 29.5% times (Salaries 

### + Benefits).

(1) Includes several small grants. Ecology's FY94· actuals for RCRA were $1,537,648 (HWTR Program's share was $1,201,212; Program Administration's share was**$33~,436)** Estimates for FY95 will be a similar amount.
3. FY95 Hazardous Waste Toxics Reduction Program Plan The Planning Process This fiscal year the HWTR Program undertook a new and detailed Program planning process consisting ofnumerous iterative steps over a four month period. Steps included: establishing Program-specific goals and objectives; establishing a Resource (FTE) Allocation Baseline; determining mandatory tasks/mandatory FTE allocations and a 18 

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•• "Minimum Credible Program; brainstorming of new tasks/initiatives, tasks to "do less of', and success measures; prioritizing all current non-mandatory resources for possible reallocation to higher priority new projects; detailed scoping ofpotential new projects; reallocation decisions byManagement. It is envisioned that periodic repetition ofthis resource assessment process will be necessary to readjust Program tasks/initiatives and resource allocations to changing internal and external drivers. This year's HWTR Program planning process has become the model adopted by the Waste Management Division for use by all Division Programs beginning in FY96; for details of this process please refer to the September 13, 1994 memorandum from Dan Silver to Waste Division Managers on the subject "Process for Annual Program Resource Assessment/Reallocation". Data Presentation While FY95's Program planning was more intense and involved more meaningful staff involvement, planning process data collection and presentation was greatly simplified. Planning datawas divided into three separate levels: the most aggregated level, the Program-level plan, summarized the number ofF'TEs each Region/Section willdevote to each of eight (8) major Program functional task categories (see attachment "FY95 HWTR Program-Level Plan"); the Section-level plans breakdown FIE allocations in each Region/Section into a number offunctions subcategories (see attachment "FY95 Program Plan- FIE Breakdown Summary for All Regions"); and, the Unit-level plans detail the work loads of individual staff. Detailed Unit-level plans are left to the discretion ofeach Region/Section
. Work also continued this year to more closely integrate State/EPAAgreement (SEA) planning into the Program planning process. Intense negotiation with EPA Region 10 resulted in a greatly simplified SEA Workplan. This simplified format willcontinue to be used in the future. Resource Reallocation The Program planning process is meant to readjust Program objectives and resource allocations to optimallymatch the Program's performance with shifting internal and external requirements and constraints. A major goal of this year's planning process was to reallocate resources to emphasize pollution prevention and increase the efficiency of providing regulatory technical assistance to the public. As a first step towards reallocating a certain percentage ofcurrent resources from less effective current tasks to potentially more effective new initiatives, all SectionslRegions submitted "Potential Cuts in FTEs for Reallocation to New Initiatives" (see attachment). A total of 11.4FIEs (8.9% of total Program FTEs) were identifiedas potentially available for reallocation. An iterative process to identify potential new projects that more effectively further Program objectives culminated with a list of seven new projects which the Management Team decided to undertake in FY95 (see attached table "Comparison ofPotential 10% Cuts in FIEs for Reallocation with Costs of New Initiatives). The total estimated FIEs 19required for the new projects is 5.49 (this includes .3 FIE to do an evaluation of the "Integrated Pollution Prevention/Compliance Site-Visits":projects completed in- FY94).

- 

# 0 Summary ofNew FY95 Projects The new projects to be undertaken in FY95 and briefdescriptions ofthem follow: Green Permitting- Expedited Permitting Process: Conduct a TQM-like process that looks at opportunities for efficiency or improvement in the permitting process. The goal is to develop a process that is capable ofresponding to changingbusiness practices with a minimum ofreviews and processing from Ecology. Other Programs willcontribute about .2FIEs

## to. the project. The projectwillproduce a description of an improved permitting process that will address the administrative process, the resources estimated to process the permit, and the time periods estimated for processing each part ofthe permit. The document willdescribe what changes in legislation, rules, policies, and procedures are requiredto implement an improved permit process. The document will include a description ofthe required changes in the authorization agreement. Green Permitting- Multi-Media Permitting: Conduct a pilot project on coordinated, multi-media, cross-program permitting for TSDs, i.e. implement SHB 1743. This would involve both timing and content ofpermits. Other Programs willcontribute about 1.49 FIE. The project will produce a report to the legislature on the pilot project. The report willinclude an evaluation of the pilot project, including: • how itachieved the project goals and success measures • significant findings, including benefits and problems
• recommendations for Ecology on implementing the concepts pilot-tested
• recommendations to address institutional, legal, or otherbarriers
• legislative recommendations
• recommendations for further study. Green Permitting- Pollution Prevention in Closure/Corrective Action: Develop guidance for permit writers on ways to increase P2 in closures, post-closures, and corrective action. For example, recent amendments to MTCA may allow for more recycling and other alternative management of cleanup wastes. Other Programs willcontribute about .9 FIE. The projectwill produce a guidance document for permitwriters on ways to increase P2 in closures.ipost-closures, and corrective action. Implementation ofState Only Dangerous Waste Regulatory Reform Project: There are three necessary facets to the State-Only project follow-up: the regulation amendment process; guidance document revision; and spinoffwork. (a) Regulation Development

- Staffat both HQ and in the regions will be involved in developing regulations to implement the project's recommendations. This willnot include picking up any new federal rules, used oil rules or small modifications.

20 

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• (b)
. Guidance Development

- There are two aspects to this workload. The first is evaluating the means and methods that we should use to get this information across: TIMs? Training workshops? Videos? The second is actually developing and/or revising these guidance materials
.. (c) SpinoffWork

-The State-Only project is focussing primarily on designation criteria. However, there will likely be some issues raised that can't be resolved through changes to the designation section. Examples of this might be:

. redesigning the petition process, or changing the accumulation standards. Other Programs willcontribute about .5 FIE to the project. DevelopmentofOpportunities Database: This projectwould complete the Pollution Prevention opportunities Database and make it available to all interested HWTR Program staffas a technical assistance tool. This willinclude making final system decisions, database programming and system documentation, entry of additional P2 opportunities, stafftraining and system updating/maintenance. No other Program FIE commitment isneeded to complete this project. Information Systems Training: This projectis designed to address the on-going issue of how to keep regional and headquarter stafffullytrained on agency software and Program / EPA information system applications. Staffthat are productive on their computers are more efficient and able to provide more service delivery to our clients. Presently, what little training isprovided is sporadic and limited in variety. The projectwilldevelop a training program to keep regional and headquarter stafffullytrained on program applications and agency software
..About .3 FIE ofother Program stafftime willbe needed to fullyimplement this project. Multi-Media Training for HWTR Staff: In order to maximize our efforts in technical assistance, compliance assistance, compliance monitoring, permitting, etc.;the HWTR Program needs to have a working understanding of air and water issues and regulations. In this project a team willdevelop a core curriculum for multi-media regulations and issues which willbe taken "on the road" to the regional offices and HQ. It curriculum willbe designed to provide a framework for understanding site-specific or issue-specific problems from the air and waterperspective. About .4FIE ofother Program stafftime willbe needed to fullyimplement this project.
Table 2. FY95 Program Plan- FTE Breakdown Summary for all Regions

21FY95 PROGRAM PLAN- FTE BREAKDOWN SUMMARY FOR ALL REGIONS

FINAl 1,,,,,_: 8/28/941 

# I FYII6 PlANNING: HAZARDOU8 WAarEITOXlC8 REDUCTION PROGRAM I I CURRENT FTE ASSIGNMENT8 BY WORK CATEGORIES I 

# I 

# I I WORK CATEOOftY FTEa I I ! I TAPS INFO/ CRO 910 NWRO IIWRO TOTALa COMMENTS I FYII6 PER FYII6 FYII6 FYII6 FYIII FYeIl I FYII6 ! 1. CLOlluNiPoaT.clOIlUIWCORR£CTlVE ACnON 0.00 1.20 0.78 1.60 6.60 6.06 14.03
I IIITE.aP£iCFlC**CLO.~** "41 0.00 0.30 0.88 1.20 2.76 1.18 8.07 CRO: Com.ron. Che.ron. W.F.II.; YAAll

.."". 1_
......1 INFOIPS\: Aw".t RoQlo
.... oltlooo In r_w 01

_ p...

,**SlTE.aP£iC~C** POIIT**.clOIl~** 0 .. 00 0.00 0.00 0.06 0.16 0.70 0.110 8WRO: UlybIod. 114'
SlTE.aP£iCFlC CORRECnVE 0.00 0.20 0.10 0.20 2.20 3.00 6.70 CRO: Coorclnollon wtth TCP on Com.ron. ACnDN "61 NWRO: p"",.-

..........110 MTCA worll thot 10not CA worlll Not.: Inthe pr.'" ohwt. thM.

### w.,. MpefIItltoaceoon- feN"'e

......110worll

_ CA worll; now rhoy·

.. _nod. IIWftO.: Thi. InoI.- tho .1 01 Howord S

........ I<N W

.... _b .nd

_ ....do CA 1_. INFOJPBI: Conduot oonour,.n1 ,.....w 01 CA dooilm._lor rho Tooom. lldoll

... _Ill•.

I GENERAL INON..,TE-8PECIFlCI 0.00 0.70 0.00 0.06 0.40 0.04 1.111 INFOIPS\: 1""''- time lor now Inilled••-_udon pr••ondon In

CL08W£**P08T.cl08~E** AND oIoeur
.. endoorreodv. eodorw. COfIRECllVE ACnON WORK**GnoI~** r.c;on.tdooumem d.
..elOpmM' end r.vtew for**_~11I41** OTtBl ftELATED IPl£A8E lPECIFYI "41 0.00 0.00 0.02 0.00 0.00 0.16 0.17 CRO: Correod

.. "odonWorIlor""" SWRO: Or
...._nino' ClooutolCA.

2.**COM~ANCE** AND ENFORCEMENT 0.30 0.30 1.76 3.00 6.46 4.30 16.10

I 'NlPECnoNII· EPA AND ITATE PRlORlnES 0.00 0.00 1.02 1.30 3.78 2.16 •.82 NWRO: 111_
.......71_hl

"4'
NEW NOT1Fl9lINIlPECnON8 "31 0.00 0.00 0.38 1.00 0.80 0.66 2.63 NWRO: V101d 8unonJDe•• Mloko.

I COaT RECOVll'Y lCORRECTlVE ACnONI 0.00 0.30 0.00 0.00 0.00 0.00 0.30 &10: I""'udod In Woril C.togorv 1. I 1141 INFOIPS\: ,''''''- II"""'''

# _u_.

THE NUMBERS IN PARENTHESES INDICATE THE GOAL/ACTIVITY TO WHICH THE FTEs'HAVE BEEN ASSIGNED. 

# Lt FINAL revision of the FTE cetegories for Program Planning 18/30/941 

# 0 

# oFYII6 PlANNINO: HAZARDOUa WAlITElTOXlCS REDUCTION PROGRAM CURRENTFTE AallONMENTII BY WORK CATEGORIES
WORK CATBIORY 

# I FT& 

# I

TAPS INFOI CRO**~O** NWRO SWAO TOTALa COMMENTS FYlla PER FYII6 FYII6 FYIII FYIII FYlII FYII6
a.oRC_T 114' 0.10 0.00 0.10· 0.60 0.60 1.00 2.20 CRO: Follow-up onCome, MId Pil

.....nt; eM", ,nor.... b-..d on I

....**~done**

PlTmONS 114' 0.20 0.00 0.00 0.06 0.00 0.00 0.25
FOCUSED INDUSTRY FOLLOW-UP liTE 0.00 0.00 0.26 0.10 0.00 0.10 0.46 CAD: ahop Sw_po Compll"""" Follow-up I

__..do
... VlalTlllFT& lot I"UW

........... ohould be Ie'*' uncIotootltllOtY

....1 1141
REOIONAL DOCUMENT DEVELOPMENT AND 0.00 0.00 0.00 0.06 0.00 0.10 0.16 RiVlEW

_ T

..a CATECIOflY 114' OT_ IlB.ATED CJI'l£AaEaP£CFY, 114' 0.00 0.00 0.00 0.00 0.80 0.00 0.80 NWRO: follow uplEnforo.men1.

I. 'NFOflMAnON MAN_ENT AND IU!PORTlNQ 0.70 14.10 0.20 0.26 1.2S 0.:10 18.110

ANNUAL REPOfmNOINOT1RCAnoNS 118' 0.00 4.60 0.00 0.00 0.21 .0.00 4.71 NWAD: New I"

..,,, April ""

...... J
..... ·al.
ReNS lISl 0.00 1.10 0.10 0.10 0.70 0.16 2.16 I 

### I nil' ."" 1181 0.00 1.60 0.00 0.00 0.00 0.00 1.60 I

# I P2 PlAN 1'f'O_ mAClQNQ AND FEES 0.00 4.60 0.00 0.10 0.20 0.10 4.110 1111 

### I AUTOMATS) DATA AND I_AnoN 0.110 0.40 0.00 0.00 0.10 0.00 1.00 TAPS: l

...tltutIonol M_ory

_ V_0._. MAN_ENT avsTIMa lavaTIM-aPllC1AC I DEVELOPMBilT.MAlNTENANCEWOIUt, lISl 

### , e-: TNo

___**tutIonol~.** Vendot _.0

__--.-' OENIIIALCOMPUTEI' 0.00 0.40 0.00 0.00 0.00 0.00 0.40**a~RTIlAN** 11.1
HAZARDOU8 aUB8TANCU 1- 0.00 1.00 0.00 0.00 0.00 0.00 1.00 _INFOIlMAnoN PHONE UNE 

## 'H'

THE NUMBERS IN PARENTHESES INDICATE THE GOAL/ACTIVITY TO WHICH THE FTEs HAVE BEEN ASSIGNED. thill is tho FINAL revision of tho FTE categories for Program Planning (8/30/94) 2FVII PlANNINO: HAZARDOUI WAITElTOXICIREDUCTIONPROORAM
, CURRENTFTEAI8l0NMENTlBVWORK CATEOORlEI

I i WOfUC CATEOOI'V FTEa I I I TAPa INFO/ CRO ERO NWRO IWRO TOTALI COMMENTI I 'VIII PSI FVIIII FVIIII ,vlle Fvee P'YII I FVIIII I I INFOfNAT1ON IVITIMI POUCV 0.20 0.20 0.10 0.06 0.00 0.011 O.eo TAPa: BUon'. II
.... on oommln
... I WOfUUIROUN INON
..VlTIM 1I'ICIFlC' CRO: ,",oarom .ndOMolon Inform.donm_oement workg,oupw "81 8flR(): Bob Ool
.....g·.lnvolvomontIn the work_. I I OTHln,...TED IPllMl! IJOIC.YI

# "" 0.00 0.60 0.00 0.00 0.00 0.00 0.60 INFOIPBI: CommunI'/' ouu_h .peoIoI p,ojeota. I , I i I 4. PBMTI! 0.00 6.70 0.16 0.00 0.40 0.10 8.111 

## ! I i 0.111 11.211 ACnVl 'NITI WOfUC IAP'flUCAnON 0.00 4.70 0.111 0.00 0.211 CRO: Com.,on·_tooo,d wtlt> Hq. lnaluclng the C_clnedng flIVIlWI, PII'MITIIIUANCE. APPEAl Fo"
... ,NEOOnAnONII "4' : IPBMTMO-=tCAnONI 1'4' 0.00 0.110 0.00 0.00 0.111 0.20 0.111 INFOIPBI: AooIOI

..glonolottloeo In
...wtng pennltmod

__.
:PEI'MlT IlIInATIVU tMULnMEDlA. 0.00 0.60 0.00 0.00 0.00 0.16. 0.86 INFOIPBI: Expecll*lpennlnlng endmul_. pennlnlng.

,IFf'tCIENCY. ETC.I .,41
REGIONALDOCUMENTDEVELOPMENT AND 0.00 0.00 0.00 0.00 0.00 0.00 0.00 REVIEWFOIIJTI
.. CATEOOfIY

....4' ; : OTHERIlELATEDIPLEAIIIPECIFY, 114' 0.00 0.00 0.00 0.00 0.10 0.00 0.10 NWRO: Unenllolpel*l world""'. I I.**P'\AN"~** 2.10 0.00 0.00 0.00 0.10 0.20 2.40

, CAI'ACITY AS8IMANCEPlAN 1171 0.00 0.00 0.00 0.00 0.00 0.00 0.00

I I lEA .,71 0.40 0.00 0.00 0.00 0.10 0.16 0.86 I
, IlATEHAZARDOUSWAITEPlAN .,71 0.80 0.00 0.00 0.00 0.00 0.00 0.80

I POLLlITION1'IlIVINTI0NIT1UlTEOY "71 0.40 0.00 0.00 0.00 0.00 0.00 0.40

,**O~** RElATED IPLEAIIIPECIFYI .,71 . 0.110 0.00 0.00 0.00 0.00 0.011 0.&6 TAPa: InaI_oIll. W.t•. IWflO: _don lpeoitlo world"'" "'-"ng.

THE NUMBERS IN PARENTHESES INDICATE THE GOAL/ACTIVITY TO.WHICH THE FTEs HAVE BEEN ASSIGNED. 

# uP
fiNAL reyjllon of the UE 9111egorlllll for Progrllm Pfenning 18/391941 

# 0 

# oFYII6 PlANNINO: HAZARDOUII WAaTElTOXlCa REDUCTION PROORAM CURRENT FTE AllSlONMENTa BY WORK CATEGORIES
WOflK CATEOOfIY 

# I FT& 

# I

TAPa INFOI CRO ERO NWRO 11_0 TOTALa COMMENTS FYIlII PER FYIlII FYIlII FYIlII FYIlII FYIlII FYII6



# . II. TECHMCAL MlllIITAHCE. P INCENTTVU. 11.40 0.00 3.77 6.80 11.1111 11.70 311.33 EDUCAnON AND TRA/MNO
OINII'AL COMPUANCE EDUCATION • 1.10 0.00 1.20 1.411 2.00 2.00 7.78 TAPa: 1A1tM ••nd phone 0
..... IIEOUlATORY MIllarANCI !Noto: T

.... InoI.-

......... _. Ionon. _hope.•to.1 1131
FOCUSED INDlIaTRY CAMI'A10NII "2' 4.60 0.00 0.3& 0.110 1.1111 0.46 7.BII CRG: llnepoho

.. INCLUDU 'lANMNO. DEVELOPMENT AND INlnALtIITE NWRO: 0.1 fromFY94

### +0.5(SiriKlovstadfor 6 VISIT. ,,_w..... vi

.... __ ... _ lot undo< com......lEn_lootolJOfYl months); .05 fromSEA+ .05 from State HW Plan +llntemsfor42% ofFY95. } OINII'AL POU\IT10N PREVENTlON 0.30 0.00 0.40 1.20 2.00 0.110 4.70 EDUCATION PlIo.: ThteInoh.... phoneMIle, t.n-,., woftl.hope.

....__.....lIon

__••..,.1 "2'
HlADQUMTERa OOcUMENT DlVElOPMENT 2.20 0.00 0.00 0.00 0.00 0.00 2.20 TAPS: TIMe. ahopToIk. Foo
.. 1IMelo. --.e.•lD. AND PUWCATION. C1no1.- oil
....... 

# _1_tOr_
........

..**_I~I_,I l~**  UJtIO"'-

## n,

.....1"'........,....--............................. 

# ..........................--_·I

'

## ...

# ." 

# ...............................,
POUlIT1ON PREVlNnON PlAN TECHNICAL 0.00 0.00 0.116 1.20 11.40 2.40 11.1111 NWRO: PlwAPR Developmonl
. 2.0; _TANCE Review· 1.11; P2 PIon Impl

__ • 1.11. !No
..: T

.... lnoI.-

...... r.vlew."to vi

......to.1 

### '''1
LONG TBlM. INOllaTRY-aPECIRC 0.00 0.00 0.20 0.06 0.30 0.110 1.06 CRG: On""na

_ wtth ffull
........ _ F,ull

_ V.lIOPOLLUTION PREVlNnON WORK "21 "'-
I'UnCIDI RIlATED TECHNICAL 1.10 0.00 0.12" 0.111 0.00 0.00 1.37 cRO: ·Aoluolly hfgNr-oom. _doIdo worllinol.-_ _TANCE.", lne_dono ootolJOfY lNo

..: InoI'- both

_ .......

# _nt _IPMI
POUUTION PREVlNnON INCENT1VEAI TO 1.20 0.00 0.00 0.011 0.00 0.00 1.28 INOUIITRY AND OOVBINMENT THROUGH GRANTS. AWMO•• 'MTNBII

..Pa. nc "21 

### t.LJ THE NUMBERS IN PARENTHESES INDICATE THE GOAL/ACTIVITY TO WHICH THE FTEs HAVE BEEN ASSIGNED. 

## (J\ Ihi. III the FINAL reyielon 91 the FIE oelllgorill. for Program Planning 18/30/911 4FY8& PlANNINO: HAZARDOUS WASTElTOXlCS REDucnON PROGRAM CURRENT FTE ASSIONMENTS BY WORK CATEGORIES

, 

# I 

# I I WOIU( CATEGORY FT& I I I I TAPS INFOI CRO BlO NWRO SWRO TOTAUI COMMENTS , FYII PER FY9& FY9& FYI& FYI& FY91 I FYI&

, I DEVE1.OI' AND I'ftOVlDlIN-HOUSE TlUUNlNO 1.00 0.00 0.00 0.10 0.20 0.110 2.80 CCI\MTCAlClO.lME. ETC.I

...- I mucATION

..**C~CUlUM** DIVILOI'MENT. I PollUTION PRE\I£NT1ON NETWORIONO. 

### frc. 1671 I I ilEoIoNAL DOCUMENT DEVnOI'MENT AND 0.00 0.00 0.10 0.00 0.00 0.0& 0.11 ilEVlPN FOft T'" CATEGORY ltIO% .21**~nl** I I ,0nB RElATm 1621 0.00 0.00 0.41 0.00 0.00 0.00 0.411 CRO: lno._o.-olOf Con_l Projo,>! I I 7.**PRO~** DEVB.OI'MENT 8.110 0.70 0.10 0.81 1.30 0.8& 10.10 I ; 'GRANTS O£ViLoI'MENT. OAANT8 0.20 0.00 0.00 0.00 0.00 0.00 0.20 'MONITORINO. AND BUDGET MONlTORlNO**~1671** I ,lNllPECnON PROCES8 8TREAMUNE 0.00 0.00 0.00 0.00 0.10 0.10 0.20 IMO.IECTS 1671
!IlEOUlATOfIYCHANOU· .TATIIo FmBlAl 2.110 0.10 0.10 0.211 0.10 0.111 3.20 CRO:

..... Only**Ptoj"'l~n** ..r"" Commln- ,1WlD AND M:1lA AUTHONZAnON l'1l INFOIPER: o.v""p oUO_lMI**.~_** roe-clno COf•..,d_ I Aotton end**a~** nomenoletue. I I !l£QIliLAnON 1671 0.30 0.30 0.00 0.00 0.00 0.00 0.80 INFOIPER: Pr_o bII**o~** __

### "** no_. I I I OOlERAl POUCY WORK 1671 2.80 0.00 0.00 0.21 0.00 0.06 2.10 I , ; INTIlA_ AND CRO

...fIROORAM 0.40 0.30 0.00 0.20 1.10 0.31 2.36 NWRO: .3forComplianceUnits; .6forToxlcs : Aa8l8TANCE AND COORDINATION 1671**~",-**

# ......................... 

# .. ... ReductionUnlt;.2 forTechnicalUnit. Also 

# .....-...:.."-'-.-

# .....

# _-_

.... 

# --_....

# _:.-._

....

# - Includestime forCeoCraphic-basedteams. 

### ...----.--..

# ..............**~-...** 8WAD: InoI.- ."'" on lho

__hIo Inldod

__

# 0_

nn I 

### .""'11'0

___•nol o_wl

.. ln tH. pion. I INFOIPER: W"""oroo 2010

_**ADA.o~m1_.**
, I IlEOIONAL DOCUMENT O£VaOPMENT AND 0.00 0.00 0.00 0.18 0.00 0.00 0.18 I IlEVIPN FOft TNS CATEGORY I'll ,


### ..J THE NUMBERS IN PARENTHESES INDICATE THE GOAL/ACTIVITY TO WHICH THE FTEs HAVE BEEN ASSIGNED . this is the FINAL revision of the FTE categories for Program Planning /8/30/94) 5 

# o 0 

# oFV8& PU\NNINO: HAZARDOUSWAaTElTOXlCS REDUCnoN PROORAM**C~ENT** FTE AalIIONMENTSIIV WORK CATEOORlEa WOfU(CAT_V 

# I FTfa 

# I

- TA" INFOI CRO ERO NWRO 6WRO TOTAta COMMENTS FVlI5 PSI FV86 FV86 FV8& FYlI& FYlI& FYlI6

OTHER RELATED 1171 0.&0 0.00 0.00 0.00 0.00 0.00 0.&0



# .. PIlOORAM MANAGEMENT J.IO 4.&0 2.26 2.70 4.00 J.60 

# I 20.411 

# I NWRO: To ...,,_ '0 3.•beginning Nov. 'M.

PROORAM**S~alON** AND 2.&0 2.60 1.26 1.70 3.00 2.&0 U.46 CRO: 0.211 01 linen'. FTE: 1.00 01 Polly'. FTE MANAOIMENT 

## ,ft, NWRO: 1.0lor

_ ... ......S_lor4Iftt**~-.;** Ilftt

___""_CD.'nEIn

........ IIECftET_At AND SUPPORT Iftl 1.00 2.00 1.00 1.00 1.00 .1.00 7.00 CRO: Reok>nel Ach>InSUPPOrlPool
EXa:UT1VE MANAGEMENT 4.00 4.00 lIECnoN

TOTAL HWTR FTEs 4.00 24.110 28.&0 8.00· 13.80 28.88 21.3 

# EJ CRO:

# ·v_. TR ""-'don

# no._uoned 10' In .p--' ACCOUNTED FOR

THE NUMBERS IN PARENTHESES INDICATE THE GOAL/ACTIVITY TO WHICH THE FTEs HAVE BEEN ASSIGNED. thi. is the FINAL levi.ion of the fTE cet!!goril" for Program Planning \8/30/941 6

### III. 

### A. PERMIlTING PROCEDURES Purpose 

# o

The purpose ofpermitting treatment, storage, and disposal (TSD) facilities (on-site and off-site) is to ensure that all facilities are built and operated in such a manner as to protect the public health and environment. In the first several years of the State Hazardous Waste Program, Ecology concentrated on permitting those facilities considered high priorityby both EPA and Ecology. Permitting priorities were determined using procedures which considered national permitting priorities. These priorities ate 

### describedin the compliance monitoring section ofthis document.
. In general, permits fall into two major categories, existing TSD facilities and new TSD facilities. Completionofpermit actions in progress and disposition ofEPA-issued permits after final authorization were generally in accordance with EPA Program Implementation Guidance (PIG) 82-5. At the time of final authorization only condition 5 in PIG 82-5 applied to Washington. Any permit actions taken prior to final authorization werejoint actions by the State and EPA. Ecology must coordinate its evaluation of a proposed facility or facility expansion with other State programs. These include the Siting Criteria for Dangerous Waste Facilities, 

# 0 the State Environmental Policy Act (SEPA), and the Citizen/Proponent Negotiation (CPN) process. Both SEPA and CPN provide opportunities for public participation. SEPA requires broad evaluation ofthe impacts ofa proposed facility, in part to "promote efforts which willprevent or eliminate damage to the environment." CPN is a tool communities can use to mitigate possible impacts of a new facility. The following elements describe, in general, how the major categories ofpermits are handled and a discussion of the permit developmerit, review, and approval process as it is implemented by Ecology. B. .Existing TSD Facilities All existing facilities granted Interim Status under Section 3005 ofRCRA are deemed to have an interim status permit (Part A) in the state program. The state's regulation directly references qualified facilities with interim status gained under Section 3005 of RCRA. Hence, any facility granted interim status by EPA regulations adopted pursuant to Section 3005 would qualify for state interim status. Ecology also allows existing facilities which are not currently regulated to qualify for interim status iftheir activities become newly regulated by amendments to state regulations. To qualify, the owner/operator must submit a Part A permit application 28 

# o

----------------- -----

-----**---~---** ------------------- ------

# •

•

• within sixmonths ofthe date the new amendments are adopted (equivalent to 40 CFR 270.1O(e)(l)(i)). Facilities may qualify for state-only interim status ifthey are only affected by state rule changes; such facilities do not qualify for RCRA interim status unless they can otherwise qualify under Section 3005. Thus, facilities that only qualify for state interim status and not federal interim status may not accept or manage RCRA regulated hazardous wastes. These facilities are authorized to manage state-only wastes, and could qualify for RCRA interim status under Section 3005 ifEPA 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 sixmonths ofits 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. Appendix D lists all existing TSD facilities in Washington State. PermitModifications. There are three classes ofpermit modifications for owners and operators of TSDs which allow flexibility to change specified permit conditions, expand public notification and participation opportunities, and allow for expedited approval if no public concern exists for a proposed permit modification. The three classes are: Class 1- coverroutine changes, such as changing typographical errors, upgrading plans and records maintained by the facility, orreplacing equipmentwith functionally equivalentequipment; Class 2- address common orfrequently occurring changes needed to maintain a facility's capability to manage wastes safely or to conform with new regulatory requirements.; Class 3- cover majorchanges that substantially alterthe facility orits operations. The State differs from the federal rules regarding permit modifications only in that three modifications are considered class 2 rather than class 1 modifications bythe State: decrease rate ofwaste application, changes in any condition for a land treatment unit, and changes to allow a second.land treatmentdemonstration. Modifications to existing permits are written at the appropriate regional office or the Industrial Section ofEcology's Central Programs. Addition ofthese permit modifications to the Dangerous Waste Rules in 1991 did notresult in a need for additional resources. C. New TSD Facilities New facilities must submit both Parts A and B ofthe permit application to Ecology six months before physical construction can begin. A person may begin physical construction of a new facility, or new portions of an existing facility, only after receiving a final facility permit. This is covered in WAC 173-303-805 and 806. Miscellaneous Units. Owners and operators ofunits that treat, store, or dispose of hazardous waste Inmiscellaneous units mustcomplywith the general application requirements, and PartB general and specific requirements. They must**~lso** meet 

### 29environmental performance standards; monitoring, testing, analytical data, inspection, 

# 0 response and reporting procedures; and post-closure care. Permitting ofmiscellaneous units will be done by the headquarters permits unit, the Industrial Section ofCentral Programs, or the Hanford Section ofthe NuclearWaste Program. Incinerators. Neworexisting incineratorfacilities must conduct a trial burn before a permit can be issued to a facility. The State is more stringent than EPA because EPA allows a facility to eitherconducta trial burn or submitother information specified in Federal rules and the State requires both. Incinerators are to be permitted by the headquarters permits.unit, the Industrial Section, orthe Hanford Section. D. Permit Development Review andApproval Process for Existing and New TSD Facilities Ecology, through its permitting process, ensures that all requirements and conditions described in WAC 173-303-800 through ,.845 are followed. During the permitting process Ecology will: 1. 

### 2. 3. 4. 5. 6. 

### 7. 8. 9. 

### 10. 11. 12.
13.
14. 15. 16. Provide assistance to applicants. Receive and review applications, including financial assurance review. Conduct site evaluations. Assure analysis ofair, water, and/or soil samples as necessary. Call for Part B permit 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 

### (ifnecessary) or statement ofbasis 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. Take necessary enforcement actions to ensure application completeness, and that closure/post-closure and financial requirements are met priorto permit issuance and in accordance with state enforcement policies. The appropriate city or county ensures compliancewith the State Environmental Policy Act and Ecology sees that it is done (see attachment). Issue final permit actions. Process changes to permits, including: Transfers, Modifications, Revocations, Reissuance, and Terminations.
. Ensure properjudicial review ofpermits in cases ofapplicant appeals. 

# o

In reviewing applications· and writing permits Ecology willensure that all appropriate 30 

# o

# • information and conditions are provided. This will be done by appropriate engineering and hydrogeologicjudgments and technical expertise, as well as EPA guidance and checklists which include both Federal and State requirements. The attached flow charts (see Figures 4 and 5)describe the order ofevents, lines ofresponsibility, and intra and interagency relationships that will occur in the permit process. Internal operating procedures and policies willbe developed to ensure adequate review and compliance with state and federal regulations. E. Permits by Rule (PBR) (See WAC 173.303.802) Ecology allows PBR for: 1. Ocean disposal barges orvessels. The PBR requirements ofthe state are identical to federal standards. 2. Underground injection wells. The PBR requirements prohibit underground injection ofextremely hazardous waste. They require
.compliance with 40CFR 144.14 and all applicable state waste discharge. permits and conditions. 

# • 3. Publicly owned treatment works (POTWs). POTW are subject to state PBR requirements that are identical to federal standards, except that POTWs may not accept extremely hazardous waste for disposal. State PBR amendments specifically exclude dangerous waste discharges to POTWs, unless the POTWhas an appropriate water quality NPDES permit.



# • 4. Totally enclosed treatment facilities and elementary neutralization and wastewater treatment units. These facilities and units are categorically exempted under federal requirements from the need to obtain a RCRA permit. The state, instead, requires a PBR, which includes conditions for complying with: notification and identification numbers; designation ofdangerous waste; general waste analysis; security; contingency plan and emergency procedures; the manifest system (when applicable); records; reporting; and general performance standards. They must also have either.and NPDES permit, state waste discharge permit, or a . pretreatment permit that covers the waste stream and constituents being discharged. Ifthe facilities or units pose a threat or fail to complywith the PBR conditions, Ecology may require compliance with all the facility standards and require a full permit. F. Emergency Permits Ecology may issue an emergency permit to allow for treating, storing, or disposingwastes at facilities which either are not permitted (including interim status), or, ifpermitted, are not authorized at the time to manage the particularwaste. Emergency permits will only be issued if doing so will alleviate imminent and substantial threats to public health and 31 .

### the environment. The requirements for state-issued emergency permits are identical to the federal requirements of 40CFR 270.61.
. Research and Development Permits. A research development, and demonstration permit maybe issued for any hazardous waste treatment facility which proposes an innovative and experimental hazardous waste treatment technology or process not yet regulated. These permits are to be issued by the headquarters permits unit and have not required any additional resources for implementation. G. Judicial Review ofPermits 

### WAC 173-303-845states that any person who is adversely affected by a decision of Ecology under Chapter 173-303 WAC may appeal the decision to the Pollution Control Hearings Board pursuantto Chapter 43.21B RCW. The Pollution Control Hearings Board Act, WAC 371-08-255, states thatin the event the board determines that apermit 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 consistentwith 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 34.05 RCW. H. Permit Certification Language 

### Due to changes under Chapter 70.105.215RCW, Ecology included additional permit certification language for situations where the owner and operatorof a TSD facility are separate entities (see WAC 173-303-810(13)). However, Ecology andEPAhave agreed to require thatTSD applicants signboth the federal and the state certification when applying for a TSD permit.

·32 

# o

o

o

# • MODIFIED PERMITPROCESS FOR APPUCATIONS RECEIVED PRIOR TO NEW SITING CRITERIA

PermitAppllcati0r;" Demonstrationof Compliance Revlew

Ecofogy Review PublicComment

No
Return Application 

# I I Yes



# --

# -- - - -

SEPA Document No

Prepare**D~ft** Permit CPN Report 

# •

PublicComment Period

Issuance Dental No Facility



# • EcologyOversees Construction

Departmentof Ecology March 1991 

# 33**.-.-._--~----- IHn!QAA~**  (W,....,..IIPA.AND CPH PROCESSes DANOIROUSWASft 'AQunal 

# o

CNaII""t*-It ..."

# ...., .........00...... ""*YAcIt**E~** 8MdIc.,01 NOIIaI0I1Melll1DLA" • • - • • • • lOCll,.",..,IIlllAIItcIl. lOCllQcwenl_••**~1WnlftI** HelIce01
...... IncIUdng OIftiOlld'lllOll01 ComClI-tlftI'IllIng CItMrlII

NOTES: I.cM* go;;M

..n.nt"'IIClI'IIlIIy" RPA 

# ClI''''' 10 . II1llere,.nOCPN IN 8EPAs-- UNIll"
....tiP HIS I!claIoGY

.........4hII
..... CPN,."c*lnWyICll'P1opol_OIlt-.nIllCl n.

_**.,'Cll'liIclIlWllclftar~""** _ 

# o o

+ I


### ....._ 

### -_

# ..------_..

## - 

# _.- -,



# 34**~.lOCll P·"'·"lUld~**  Pr...-.ColInaICll' "wH"*"1INllllndudedIn**~nt** of Ecology M8Idll991 

# i

I 

### I I
\ I I

# I

# • IV. COMPLIANCE MONITORINGAND ENFORCEMENT



# • A. Authority Under the provisions ofRCW 70.105.080 and .095, Ecology has been given the authority to take enforcement action against any violator ofthe state's dangerous waste laws and regulations. This authority includes the ability to levy civilpenalties up to a maximum of $10,000 per day ofnoncompliance per violation, require compliance with the regulations, and impose penalties for noncompliance with such orders. In no case should other enforcement authority be substituted when the violation is clearly a dangerous waste violation. Provision is also made for appeal ofdepartmental actions to the Pollution Control Hearings Board by the directly affected party. RCW 70.105.090 makes certain violations a gross misdemeanor and provides for criminal sanctions. Additionally, Section 15 ofInitiative 97 amended Chapter 70.105 RCW to provide for strict liability for knowing endangerment ofpersons or property and such offenses constitute a felony. The United States Environmental Protection Agency has authorized the Department of Ecology primary responsibility for administering The RCRA program. Administration includes enforcement of the program. Inter-agency agreements are developed regularly; these documents further outline respective roles and responsibilities.

To ensure that facilities are operating in compliance with RCRA's requirements in an effort to reduce environmental risk and protect human health.
. C. Objectives Mandatory Inspections consist ofinspections targeted at Land Disposal (LDF), Treatment and Storage (TSF), and Generator/Transporter facilities. EPA has set priorities for the frequency ofTreatment, Storage, and Disposal (TSD)

.inspections. Inspections are to occur under the following schedule.


# • TSD's Government TSD's LDFwith Class I Violation LDFwithout Class I·Violation Closing LDF
. Closed LDF in Post-Closure Care 35 Once every 2 years Yearly Yearly Once every 2 years Once every 2 years Once every 2yearsRCRA requires the state to commit to inspecting a setpercentage of fullyregulated large quantity generators (LOG) in a given year. CERCLA Offsite (TSF) Every 6 months 

# o

In the absence of national criteria, the Northwest Corrective Action Group has developed regional criteria for determining environmental significance in an attempt to rank known TSD facilities. Existing TSD facilities have been ranked and placed on a high prioritylist.. The ranking focuses on eight areas. The first three areas address environmental issues, and the last five address oversight issues. Environmental issues have been used to determine high priorityfacilities. Facilities have been ranked according to the following criteria: Environmental Issues

o Level of Contamination o Toxicity ofWaste Stream (EHW versus Toxic HW) o Facility Setting Oversight Issues



### o o 

### o o o Enforcement History Financial Status ofFacility " Extent to which the Nature ofthe Releases are known Level"ofPublic Interest Type and Complexity ofParticular Corrective Action Activity 

# o

A full outline ofthe Facility Environmental Priority Ranking Criteriais included inthe Northwest ReRA Corrective Action Strategy (the Repoit). Non-Mandatory Inspections encompasses additional TSFinspections (state only facilities), Non-notifiers, New Notifiers, Pesticide Waste Compliance Inspections, State/SOG inspections, and Criminal Investigations. Non-notifiers are those facilities producing or handling hazardous waste which have yet to notify EPA or the Department ofEcology oftheir existence. Nonnotifiers are inspected according to the same priorities outlinedin each region for state/SQG inspections. (Regional priorities are outlined in the 

### "Discussion Papers" section ofthe Report). New-notifiers are those facilities which have recently notified EPA and the Department ofEcology of their existence, buthave yet to be inspected. The 36 ------"- ---_.- 

# "0

# •

•

• purpose of new-notifier inspections is to provide new-notifiers with the necessary information regarding the regulatory requirements imposed on their facility in the hopes that future inspections willresult in fewer compliance issues being addressed. The inspection is only to supply the facility withregulatory information, and requires no formal write up. Pesticide Waste Compliance Inspections provide a preventative approach to environmental impacts causedby improper pesticide waste management. A fourpoint strategyfor implementing a consistent, active, and successful compliance strategy for pesticide waste generators has been developed. Education and outreach, targeted inspections, industry participation, and development and implementation ofcompliance incentives are the four elements considered in achieving greatercompliance. Establishing education describing health and environmental threats from improperwaste management, howhazardous waste regulating pertains to pesticide waste, and the presentation ofoptions for reducing/preventing pesticide wastes is the responsibility ofboth the regions and program headquarters. Inspections.are conducted by the regional staff. The state also commits to complete a number ofState/Small Quantity Generator (SQG) inspections for each region. SQG's includes bothnotifiers and nonnotifiers. The determination of which facilities to inspect varies based on regional priorities, needs, and interests. Many inspections are the result ofcomplaints, such as dumping antifreeze, solvents, etc. With the county moderate risk waste programs now in place, the counties do many of the SQG inspections in the State.
The State Hazardous Waste Plan developed recommendations for generator and TSD inspections addressing resource availability, contactfrequency, and measuring and monitoring compliance. A pilotproject to measure compliance at the facility level was completed. A summary paper of the Point System Pilot Projectwhich discusses the potential uses of this evaluation tool and recommendations for further action is available. A pilot project of the State Plan to measure compliance at the facility level was completed. A summary paper ofthe Point 

### SystemPilot Projectwhich discusses the potential uses of this evaluation tool and recommendations for further action is available. A summary paperhas also been prepared regarding Ecology's contactfrequency with hazardous waste generators. This paper discusses the various methods used by 

### Ecology to contactgenerators to provide technical assistance on regulation compliance and pollution prevention. Record Reviewsare conducted at hazardous waste facilities to review closure and post37**-------~~-- -----i---~·----** 



### closure plans, financial documents and ground water monitoring/assessment reports. D. Enforcement Procedures (EnforcementPolicy is at AppendixC) Appeals Process Once a penalty or order has been issued, the violator has a right to appeal. An 

### appeal may take one of two forms: 1) an Application for Relief filed with Ecology, and/or 2) an Appeal filed with the Pollution Control Hearings Board (PCHB). Application for Relief A violatorhas fifteen days,from the enforcement action delivery date, to file an Application for Reliefwith Ecology. Ecology acknowledges receipt of the Application within 30 days byletter. In the Application for Relief, the violator states why they feel the enforcement action isinappropriate, or presents newrelevant facts regarding the violation. The violator signs the Application for Relief in the presence of a notary. Ecology considers the information in the Application for Reliefand determines if the enforcement action is to be canceled, affirmed, or in the case ofpenalties, reduced. In conformance with the Enforcement Policy,penalties will not be mitigated based on improvements to facilities or commitments to improve facilities when such improvements were legallyrequired priorto the issuance of the enforcement action. Penalties will only be canceledor mitigated when additionalrelevant facts are brought to Ecology's attention. 

### Formal decisions are comprised ofa cover letter and a Notice ofDisposition Upon Application ForReliefwhich either affirms, mitigates or cancelsthe penalty assessed. The decision to mitigate, cancel, or affirm should include consideration of the argument providedby the violatorin the Application ForRelief. Appeal to the Pollution Control Hearings Board Any partyfeeling aggrieved by a final decision made by Ecology has the right to appeal to the Pollution Control Hearings Board (PCHB). The appeal must be filed directly with the PCHB within thirty days ofreceipt of the action or Ecology's final decision. A copy of the appeal is sent to Ecology. The PCHB will set ahearing date; at the hearing the case will be reviewed and the PCHB will make adetermination. Both the violator and Ecology have the right to appeal the PCHB determination through the courts.' SettlementProcedures When aviolator appeals an enforcement action to the PCHB, the violatorhas the option ofsettlingwith Ecology prior to the PCHB hearing. The full range ofoptions are considered during the settlement process. Generally, the violator's attorneywillseek resolutionby contacting the assistant attorney general incharge of the case. All

.settlement offers are handled through the state's AG Office in conjunctionwith the staff 38 

# o

o

-- - -- - - - --- -- - ---- - ----- -------- -

# •

•

• who originated the action
. Innovative enforcement settlements are considered only during the settlement process. The AG's office, in consultation with the regions/programs, must be involved in all innovative settlements. Criminal Enforcement Procedures Ofthe several enforcement options available to the agency the most serious is criminal 'enforcement. The intent ofcriminal enforcement is to obtain compliance by both the violating facility and the rest ofthe regulated community. The operating assumption is that wilful, knowing violators ofenvironmental laws should be dealt with in the criminal _court system. This tends to promote compliance by serving as a deterrent to other

- members ofthe regulated community. Because ofthe serious consequence$ that a criminal accusation or prosecution may have on an individual, their family, or business, the criminal enforcement remedy should be used with discretion and goodjudgment. In most cases, it will be applied to the recalcitrant company, the repeat violator, the most deliberate and willful acts (such as hazardous waste dumping), and those situations that have serious environmental or human health and safety impacts. Civil and Criminal Actions Ecology can pursue both civiland criminal enforcement actions concurrently. One exception is a situation where injunctions or restraining orders or otherjudicial processes are necessary to halt- an ongoing violation, or stop environmental harm from occurring. However, once a case has been referred to the criminal investigators for action, further civilenforcement should immediately cease unless you have approval from the criminal section. This does not preclude otherregulatory or administrative actions from taking place, such as inspections" responses to complaints, normal permitting activities, and otherroutine administrative matters. Criminal Action

- When willful, knowing or grossly negligent violations occur, Criminal Sanctions should be considered. The Enforcement Section, in Central Programs should be consulted for further guidance when considering criminal action.
E. Information Management The cornerstone for information management in the Hazardous Waste Program is the EPNState ill number notification system. The bOT and EPArequire an active EPNState identification number on manifests that accompany shipments ofregulated hazardous/dangerous wastes. An EPNState Id number identifies the generator 39 1 .1

### (originator), transporters, and Treatment/StoragelDisposaJlRecyclingFacilities (receivers) 

# 0 who handle regulated dangerous wastes. A dangerous waste handlerwho needs an EP

### NState ID number fillsout a Washington State notification form and sends it to the information unit at Ecology Headquarters. It 

### is reviewed for errors, then forwarded to EPA Region 10for the actual number assignment and RCRIS dataentry. The Washington Department of Ecology and the EPAwork together to manage information relating to 

### the implementation ofRCRA. Both agencies use the Resource Conservation and Recovery Information System (RCRIS) for the storage, tracking, and analysis ofdata relating to state and federal hazardous waste program activities. Those who generate, transport, store or treat hazardous waste in Washington State are identifiedwith a uniquely assigned federal ID number. Information obtainedfrom Notification ofHazardous Waste Activities, applications for Hazardous Waste permits, inspections, corrective action procedures and enforcement proceedings are entered into RCRIS byHazardous Waste and Toxies Reduction section stafflocated in Ecology's headquarters and regional offices, and by Ecology staffin the Industrial Section and the Kennewick office of the Nuclear Waste Program. Periodically, the information entered by Ecology into the RCRIS system is merged with similar RCRIS information entered by EPA. The details ofhow both agencies use RCRIS and how the information merges togetheris descnbed by aMemorandum of 

### Understanding, This memorandum allows the two agencies to divide or share the responsibilities for administering and monitoring RCRA compliance. RCRIS information is used to provide feedback to Ecology staffand management for current, historical and planned activities, as well as EPARegion 10and EPA Headquarters for their oversightfunctions. HWAnnual Reporting Sites with an active EPAzState Id number are required by the State to submit an annual report on their dangerous waste activities to Ecology byMarch 1stofthe following year. Federal regulations require that this annual report data be submitted to EPAfor the national Biennial Report on everyodd numberedyear. Old HWReporting System (Form 4/Form 5) From 1982 to 1994 Ecology collected annual report data on two forms: the Form 4 for generators and transporters ofdangerous waste, and the Form 5 for receivers (TSDRs) ofdangerous waste. These reports were originally designed to track 'cradle to grave' manifestinformation and to answer questions aboutwaste movements between different sites. In lateryears additional questions were asked about how waste was being managed on site; for example, 'How much waste is recycled on site?'. The Forni 4 and Form 5 were amended, butbecame increasingly more difficult to fill out. The data elements needed to answer some basic currentwaste 

### questionsand to meetEPA Biennial Reporting requirements were still missing. 

### 40 

# o

o**------~~----** -**-~-** - - -- ------
--------

# e·



# e NewReporting System Beginning in 1995, annual report data willbe collected on a set of forms designed to track the nature, source, and management (both on-site and off-site) ofdangerous wastes. The new forms include: GSI (General Site Information) reports general site location and contact information ' GM (Generation and Management) reports waste generation and management WR (Waste Received) reports waste received from off-site CI (Capacity Information) reports waste management capacity for commercial facilities receiving waste from off-site 01 (Off-site Identification Form) indexes name and address information to the ID numbers ofgenerators, transporters and TSDRs referenced in the other forms Data from the annual reporting system has many uses. It is submitted to EPA to satisfy the Federal Biennial Report requirement, and is analyzed to determine Washington's current and future impact on our ability to treat and dispose ofwaste generated in the state and on a national level as well. Byinputing our data into the Capacity Assurance Plan we have direct input into the national data base. Other agencies and the business community request the data for their planning purposes. Within Ecology, the data is used as the basisfor 1) biennial updates and revisions every sixyears to the State Hazardous Waste Plan, 2) regulatory development and change efforts, and 3) technical assistance to promote waste reduction and the assessment ofHazardous Waste GeneratorFees. An annual report summery is written to analyze eachyear's data and for comparison to previous years data for trend analysis.


## v. REGULATED COMMUNI1Y DATA - ESTIMATES A.
. NumberofNotifiers by Activity Reported The following information depicts the status ofWashington State as ofNovember 1994.



# e Activity Transporters Generators (fully regulated). Generators (includes CESQGs) TSDs Number
541 936 11220 

### 64

41

### B. \


### Amountof WasteTreated. Stored. and Disposed 

# ,0

Data collected and analyzed for 1993 

### showed the following: 

# I WASTE GENERAnON 

# I TONS 

# I

PERMIT-BY·RULEWASTE WATER(Waste waters 6,855,836 

### treated then discharged under a Permit-by-Rule or a NPDES Permit) RECURRENTWASTE (waste from generator's on- 201,462 

### going production process) NON-RECURRENTWASTE (waste from clean-up or 82,913 

### spills) RADIOACTIVE MIXED WASTES (designated 11,147 

### dangerous waste that exhibit low level radioactivity) RADIOACTIVE MIXED WASTEWATERS}

- , 

### 38,093 

### (Impoundment at Siemens Power Corp.) 

# ITOTAL 

# I ,,189,452 1 

# I PERMITTEDWASTE MANAGEMENT 

# I TONS 

# I

TREA**TMEN~** 

### (physical, chemical or biological 7,526,354. 

### processing) STORAGE (holding of waste for temporaryperiod) 41,879 

### DISPOSAL3 

### (discharging, discarding or abandoning of 450,808 

### waste) 

# ITOTAL 

# I 8,019,041

# I

1 

### This waste has been analyzed separately due to it's unique nature.

2

### Treatment.includes

### waste that may have also been stored.

3 

### Disposal includes waste that may have also been stored and/or treated. 42 

# o

o

# •

•

• I WASTE TRANSPORTATION 

# I TONS 

# I IN-STATE 

### (waste transported to in-state TSDR's) 37,456 OUT-OF-STATE 

### (wastes transported to out-of-state 200,339 

### TSDR's) 

## I TOTAL 

# I 237,7951

43