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SECTION I

·PROGRAM DESCRIPTION

Table of Contents

I. BACKGROUND . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1

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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. Other Requirements 10

7. Availability of Information to the Public 10

8. Revision of State Program . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11

9. Summary ' . . . . . . . . . . . . . . . . .. 12

C. Lead Agency Identification, Agency Structure, Budget; and Resource

Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13

1. Agency Structure and Organizational Responsibility . . . . . . . . .. 13

2. Sources of Funding and Restrictions 18

3. FY95 Hazardous Waste and Toxics Reduction Plan . . . . . . . . .. 18

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III. PERMITTING PROCEDURES 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 of Permits 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
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V. REGULATED COMMUNITY DATA 42

A. Number of Notifiers by Activity Reported 42

B. Amount of Waste 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 of Washington)

1. Chapter 34.05 RCW (Administrative Procedures Act)

2. Chapter 42.17 RCW (Disclosure-Campaign Finances-LobbyingRecords)

3. Chapter 43.21A RCW (Department of Ecology)

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 of the Environmental

Coordination Procedures Act)

VIII. APPENDICES

Appendix A. State 1989 Annual Report Summary

Appendix B. Inspection Checklists

Appendix C. Enforcement Policy

Appendix D. TSD Facilities

Appendix E. Chemical Testing Methods

Appendix F. 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 Toxics Reduction Program- Headquarters 16

Hazardous Waste and Toxics Reduction Program- Regional Staff . . . .. 17

Permit Process for Applications Received Prior to Siting Criteria 33

Integration of Permit, SEPA, and CPN Processes for DW Facilities 34

LIST OF TABLES

Funding Profile for the 1993-95 Biennium 19

FY95 Program Plan- FTE Breakdown Summary for all Regions 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 of the 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 of the State regulations were primarily driven by these two forces, the

mandates of the Washington Legislature and EPA's burgeoning hazardous waste

regulations. Consequently, the current regulations are a combination of Federal and

State hazardous waste directives.

Three main features of the State regulations are derived from the Washington

Legislature's 1976 directive, "the Hazardous 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 is identical to its EPA counterpart. A more

detailed explanation of the three original features follows .

Prior to 1981, Ecology identified dangerous wastes according to the degree of hazard

posed by a waste to the public health and the environment. The waste classification

system implemented by Ecology designated wastes by their level of toxicity, 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 of thousands 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 of the dangerous waste

universe.

Tracking dangerous wastes as they moved from the generator to the disposal site was

based on the use of a 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 of the disposal site and returned

to the generator to signify acceptance of the waste shipment. If the generator does not

receive a signed manifest copy from the disposal site within a specified time, Ecology

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must be notified. Ecology then initiates a search for the missing waste.

Rules for the operation and maintenance of the extremely hazardous waste (EHW)

management facility at Hanford (this was to be the only facility in Washington which

would dispose of EHW) 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 of dangerous 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 of the Dangerous Waste Regulations was most recently amended on

December 8, 1993 to be equivalent, and consistent with, 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 of the 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 of the state of Washington's application for

authorization of the "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 consistent with the Federal RCRA program.

The authorized State regulatory program is intended to operate in lieu of the 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 of the Dangerous Waste Regulations is to protect public health and

the environment from improper management of dangerous waste. The State program,

administered by Ecology, has regulatory authority over nearly all areas of dangerous

waste management, including notification, inspection, monitoring, permitting, compliance

monitoring, manifest tracking, and enforcement.

Some of EPA'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 of the 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 and extremely 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 solid wastes 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 of these lists were 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 Sources List, EPA studied data on various industrial processes and their typical

waste streams, then listed those sources of waste which met the criteria. Ecology 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 of various 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

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list regulated under the toxicity characteristic. The State has been implementing the TC

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 1977 regulations: The

criteria apply to wastes that are not listed or characteristic wastes. The criteria apply

when the generator knows the constituents of the 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 of unlisted wastes who have been required by Ecology, or who choose

voluntarily, to test their wastes against the criteria and designate their waste 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 their waste 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 that wastes

be designated through the lists and characteristics. Designation through the criteria is

required if the generator has "knowledge" that their waste could designate under the

criteria, or if Ecology requires the generator to test their waste.

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 of categorical exclusions, a group of generators 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 if Ecology determines that they do not

otherwise pose a threat to public health or the environment. An entire class of wastes

may be excluded from regulation if all wastes in that class: 1) are not listed; 2) do 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,

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in many cases, exceeding) the requirements of EPA.

Ecology has continued to amend its lists of hazardous wastes (including the Dangerous

Waste Constituents List) to include new federal listings. Listings include wastes from the

production of dinitrotoluene and toluenediamine (Klll, K112, KI13, K114, and K115),

, wastes from the production of toluene diisocyanate (KI16), wastes from primary metals

manufacturing (K064, K065, K066, K088, K090, and K091) and discarded chemical

products of o-Toluidine (U328) and p-Toluidine (U353). A recent 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 of solvent wastes (the ten

percent rule) and does not set a threshold on concentration. Any amount of waste

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 of ecology may regulate all hazardous wastes,

including those composed of both 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 EPA identification number, reporting and recordkeeping, accumulation

of hazardous 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 of the

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 of waste, and its quantity or volume. The manifest must be signed by

the generator and the transporter before the waste leaves the generator's property. The

manifest travels with the transporter to the TSD facility, where the facility

owner/operator signs the manifest and returns a copy to the generator. If the generator

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does not receive a copy of the manifest signed by the facility owner/operator within 45

days of shipment, an Exception Report.mustbesubmitted to -Ecology. When Ecology 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 by RCRA) to

Ecology the quantities and types of dangerous waste which were generated in the past

year, as well as any treatment, storage, recycling, or disposal practices incorporated.

The manifest and annual reporting system provide Ecology with a means to track the

generation, movement, and ultimate disposition of dangerous' wastes in Washington. This

system reduces the amount of uncontrolled dumping and illegal disposal of dangerous

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 exempt from 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 of pesticide) or else manage these wastes according to the pesticide label

instructions. The label instructions vary for each pesticide, but almost always call for the

farmer to spray the pesticide residues in a manner which constitutes a useful purpose.

For example, the farmer may be instructed to spray certain herbicides or pesticides along

fence rows to control weed or insect growth, or 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 of pesticide

wastes elsewhere is subject to Ecology's generator and other dangerous waste

requirements.

Small quantity generators (SQGs) are those generators of dangerous waste who generate

less than 220 pounds per month or batch of dangerous waste (DW) or less than 2.2

pound of extremely hazardous waste (EHW). SQGs have reduced waste management

requirements. They may accumulate listed, characteristic, or criteria wastes on-site;

however, if the amount of waste 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 longer considered an SQG. An SQG is responsible for determining whether their

. waste designates as a dangerous waste and for ensuring that their waste 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 under the Dangerous Waste Regulations, 2) authorized to managed

dangerous waste by another state, 3) permitted to manage moderate-risk waste, 4) .

beneficially uses or reuses, or legitimately recycles or reclaims the dangerous waste, or

treats the waste prior to recycling, 5) permitted to manage municipal or industrial solid

waste, or 6) a publicly owned treatment works (P01W) if the SQG meets the

requirements of the domestic sewage exclusion. These are the only requirements SQGs

must comply with; however, if these 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 of dangerous waste.

Ecology regulates another class of generators with reduced waste management

requirements, those who generate between 220 and 2200 pounds of dangerous waste per

month or batch. 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 comply with all generator requirements except for the following reduced

requirements. They may accumulate waste on-site for up to 180 days, and may be

granted an extension if the waste must be transported over a distance of two hundred

mile or more for off-site treatment, storage, or disposal 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 of Transportation

(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 of dangerous wastes during transport.

Ecology required all dangerous 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 import wastes from

outside the United States beyond the federal requirements. Such transporters must act

as the generator of waste and comply with all applicable generator requirements (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 of the waste and estimated frequency at which the

waste is to be imported, estimated total quantity, and a description of the manner the

waste will be managed). Transporters who export wastes must comply with federal

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requirements 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 of recycling 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-only wastes when they are stored for short time periods

prior to recycling. .

Ecology adopted additional requirements for owners or operators of facilities 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 of TSD 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 of operation, environmental monitoring,

documentation of financial 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 of sites 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 of dangerous wastes. They prohibit facilities from

being located in areas subject to natural hazards such as floodplains and unstable soils,

and environmentally or culturally sensitive areas such as sole source aquifers and

designated historic areas. Minimum setback distances have been established from

identified resources. For example, land disposal facilities must be located at least 1/4

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required to comply with the setback standards in the Uniform Fire Code (see UFC Table

77-201, 1985 Edition). Facilities must also required to satisfy all applicable local, state,

and federal laws (such as local comprehensive plans, air and water pollution laws,

endangered species, etc.).

Companies that generate, treat or store hazardous waste in tanks must comply with tank

standards for: assessing existing tank systems' integrity, the design and installation of

new tank systems or components, containment and detection of releases general

operating requirements, inspections, response to leaks or spills, closure and post closure,

requirements for ignitable or reactive wastes and requirements for incompatible wastes.

The State requirements are identical to most of the Federal requirements, but are more

stringent in some areas such as: the State does not include an exemption from the

requirements for reactive or ignitable waste; the State requires development of a C

schedule of integrity assessments; any release above the reportable quantity must be .

reported; tanks must be located in a manner equivalent to 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 of up to 2200 pounds; documentation is required of the precautions taken

for ignitable, reactive or incompatible wastes; yearly inspections and additional

monitoring are required; a description of marking and lor labeling; and tank design to

prevent escape of vapors and emissions of acutely 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 of chemicals, plus other chemicals specified on a sitespecific basis. The State regional offices have been implementing the groundwater

monitoring requirements for more than three years 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 permit unit located at headquarters, permit modifications are

handled either in Ecology's regional offices or the 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 by regional or

Industrial Section staff.

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The Permits Unit ensures compliance with financial responsibility requirements by all

TSDs except for facllities regulated by the Industrial or Hanford Sections.

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.Ecology adopted many of the TSD requirements directly from the EPA regulations

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

current with EPA changes for Interim Status facilities by updating WAC 173-303-045.

This section provides that any EPA regulations that are adopted by reference in Chapter

173-303 WAC reflect federal rules in place on July 1, 1993. Thus, recent EPA changes

to the interim status tSD facility requirements 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 three years with no need for an increase in resources. Additionally, by updating

. WAC 173-303-045, as above, the expanded corporate guarantee for liability insurance

was included in Chapter 173-303 WAC.

Ecology adopted stringent operating standards for the extremely hazardous waste

disposal site at Hanford. The current status of the site at Hanford is that 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 permit certification

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. Other Requirements

The Dangerous Waste Regulations require all persons who generate, transfer, transport,

treat, store, or dispose of dangerous waste to have an EPNstate 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, petitioning Ecology

for changes and exceptions to the regulations, testing methods (The latest revision of SW846 has been incorporated by reference into the State's test procedures), sampling

methods, and conditions for exemption from the rules (recycling or recovery of dangerous

wastes, triple rinsing of containers, etc.).

7. Availability of Information to the Public

Ecology uses provisions in state law for disclosing information 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 will provide responses in no more

than twenty days (as required by WAC 173-303-901), and, generally, in

much less time than this. Most information is generally available to the

public without the need to submit a formal request for disclosure (e.g.,

regulations, policy statements, 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 (see the Attorney General's Statement), Ecology provides

the fullest possible disclosure of records 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 existing information into new forms

(e.g., preparing brand new reports, conducting studies, correlating computer-based data),

then a fee may be charged. The fees assessable under these two exceptions can be

waived or reduced if Ecology determines that furnishing the information would be of

primary benefit to the public at large;

Ecology can deny requests for information (see Attorney General's Statement). Denials

will include statements of applicable appeal procedures and statutes of limitations. If a

disclosure request is denied because a claim of business confidentiality could not be

resolved within the twenty day response period specified in WAC 173-303-901, then the

response provided to the person requesting such information will specify that failure to

resolve the business confidentiality claim is the cause of denial.

8. Revision of State Program

Whenever Ecology revises its program, EPA will be contacted to determine what

modifications are necessary in the memorandum of agreement, Attorney General's

statement, or other documents. Ecology will modify the documents, as appropriate, and

submit them to EPA for approval. 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 is necessary to amend State laws or regulations

due to EPA's promulgation of new regulations, then the State will proceed as follows:

(a) Statutory changes. Ecology will work with the State Legislature and appropriate

committees to develop the necessary statutory language. The Washington State

Legislature meets every year, so changes to state law should be accomplished within one

year. If the statutory changes are controversial,·two years may be necessary. Ecology.

believes that amendments to State laws can be provided in two years or less in all cases.

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(b) . Regulatory changes. Amendments to State regulations will be made in accordance

with Chapter 34.04 RCW, Administrative Procedures Act, and will generally be accomplished in eighteen months or less. Ecology will prepare proposed regulatory language

and confirm with EPA that it will properly address the changes at the Federal level; this

should require no more than 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 by the Assistant Director

of the rulemaking plan and preparation of draft 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 six months. The first public hearing may be held 20 days after the proposed

amendments are published. The public comment period may end no sooner than one

week after the last public hearing and generally lasts for thirty to forty-five days. Ecology

will then prepare final amendatory 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

as twelve 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 hazardousto public

health and the environment;

(b) Provide for proper management of dangerous wastes until they are recycled,

reclaimed, treated, or disposed of safely;

(c) Provide a manifest system for tracking, reporting, monitoring, recordkeeping,

sampling, and labeling of dangerous wastes;

(d) Establish requirements for the siting, design, operation, and monitoring of dangerous

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

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the Dangerous Waste Regulations.

C. LEAD AGENCY IDENTIFICATION, AGENCY STRUCTURE, BUDGET, AND

RESOURCE ASSESSMENT

1. Agency Structure and Organizational Responsibility

Ecology is the state agency mandated by the Legislature to administer the federally

approved RCRA program. As shown in Figure 1, Ecology is essentially organized along

programmatic lines with the regional offices set up to act as the operating arm of the

agency. Each program functions under an appointed Program Manager who 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 (Nuclear Waste Program) both

located at headquarters.

In 1990, the Hazardous Waste and Toxics Reduction Program (along with the other

Ecology programs) were reorganized to bring staff in 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 of each 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 staff in 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 permit writers 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 of hazardous waste per

year and facilities required to report under SARA Title III, Section 313, are required to

prepare comprehensive hazardous substance use/hazardous waste reduction plans. They

are responsible for collection of pollution prevention plans, computer support, training

opportunities, and legislative tracking. The Hazardous Waste Permits Unit issues permits

for facilities that store, treat or dispose of hazardous wastes. Before a facility can receive

a permit, it must successfully demonstrate that it complies with stringent state and federal

laws and will not harm public health or the environment. The Permits Unit is a

centralized unit in the HWTR Program that was 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 selected TSD facilities.

The regional office staff have the authority and responsibility for all operational aspects

of the HWTR Program (Figure 3). The four Regional offices are located in four·

geographically separated regions of the State with HWfR Program staff located in each

region. The regions cover Southwest, Northwest, Central, and Eastern Washington.

Each regional office has a designated hazardous waste group. The regional staff are

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 all generators, transporters, and some TSD

facilities. Regional staff implement the agency enforcement policy by documenting and

making recommendations for enforcement actions to their Regional Section Supervisor

who has signatory authority for all enforcement actions within their jurisdiction. These

supervisors report directly to the Hazardous Waste and .Toxics Reduction 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 all dangerous/hazardous waste and hazardous waste cleanup program

activities at the Hanford Reservation.

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WASHINGTON STATE DEPARTMENT OF ECOLOGY

SEPTEMBER 1995

•

OFFICE OF ATTORNEY GENERAL DIRECTOR I DEPUTY DIRECTOR SENIOR ASSISTANT

ATTORNEY GENERAl Mary Rlveland I Terry Husseman Jay Menning

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 Joi SI. GlImlaln PROJECT RE...-TIONS

Pet lee KIm Conlrla 407.e218 PROJECT MANAGER DIRECTOR

407-700!i "07-7004 CherGotfl lynn Singleton Bill AIldr.

01_ SchenkIKnty SlIJrw Joan Wolcott 407-81" 407-M10 407-7003

407-7007 <W7-7008 FtJIfh Kelao IIIckIe Van NN4

407-7015 407-700'

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

& I!NPORCEMENT REGIONAl OfIFICE REGIONAl OJlJIICI! ASSISTANT DIRECTOR ASSISTANT DIRECTOR

ASSISTANT DIRECTOR REGIONAl DIRECTOR REGIONAl DIRECTOR Den SIIvef' linda Cren"

D.J.PlIlln Pat Spurgin Claude Sappington 407-7011 407-7013

407-7012 (509) "57-7120 (509) ..58-e1 ..9 Janice JacklIOfI Leua AndrHlIon

FtJIftIKeIso Judy weston Marilyn NeI«In 407·7014 <W7-7018

407-7015 (50") 457-7121 (5tJ,,) 456-2635

AlRQUAlITY CENTRAL PROGRAMS NORTHWEST SOUTHWEIT HAZARDOUS WASTE NUCLEAR WASTI! SHORI!LANDS & WATI!R QUAlITY

PROGRAM MANAGER PROGRAM MANAGER REGIONAl OJl...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 Sue MeUemlllflll MeganWhHe '"'7-1150 C.,o/Fla. '"'7-6405

GeIry Kunkel P9r1rJy HaflJll1ll (206) &49·7010 '"'7-8307 ..ONI702 Tammie IIIcClute ,",7.ee02 Juu.Ruatw

<W7-eB7" 407-6966 NancyGIOlI93 LornaMendez-ConN MIncy HlIutenne 407-7141 Ulla NlIwman <W7-4448

(20B) B4~7012 <W7·B308 407-8705 <W7·tJ«)4

ENVIRONMENTAL LOCAL GOVERNMENT TOXlca CLEANUP

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"5
j -~---

Ii·· I lj ll.l c "2. HAZARDOUS WASTE AND TOXIC REDUCTION

Headquarters

MeganWhtte

Program Manager

(WMS 03) 0836

I

Nancy Hautanne 52 (2334) DIanna teal...... CT3 IT (3162)

I

Tom Cook

Information & Permit Management

(WMS 02) 2692

Artene Kellennen 51 (2237)

Ed Benttey (temp) CIC3 (2801)

Dave Oubnull EP3 (1100)

Lo.... HewItt

Technical Assistance & Policy

(WMS 02) 0902

Cethy Bouge 51 (2680)

Dennl. Bowhay E55 (1123)

Tom Lo,...... EP4 (P302)

I I I I

I

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

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

....A~ ES3 (1147) John Rlduw-y ES3 (2281) Vacant 51 (2832) Jerry Perker EP3 (3052) Bonnie Meyer 0.5 EE0S3 (2868) I

Larry McCallum EP3 (3051) Michelle Elling ES3 (2919) I

c.nne PhlIlIpMn ES3 (2906) Mil.. Kuntz ES3 (2097) .Joan Monte EE1OS2 (3287)

avtdZlnkl ES2 (0156) Tim Gllffney EP3 (2878) DaveOllv'" ES4 (2317) Chipper Hervleux 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) Holly Sullivan . ET (3379) Marty Werner' EE4 (2328) Lynn Halbrecht EP3 (2670) Shlrtey LevIg 0.5 EElpS2 (2381

'-I~ ET (0358) SadIe Whitener ET (3135) Rob Kirkwood EP4 (3398) Hally Johnaon E5 (1083) P.....cl. Jetczak ES4 IT (3023)

d ..... CIC2 (2801) Jig,... P.rikh AI2 (0784) Sr. Volunteer Peggy Morgan ES4 (2081) I I

Stacie Singleton EE2 (2325) Iell Peck CIC2 (3054) Vacant EEIOS3 (2348)

Vacant (3141)

I I

95-HWTft"O'v 95 (101'271'95) I

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

• HAZARDOUS WASTE • TOXIC REDUCTION

Ragrons

•

MeganWh1t8

Program Maneger

(WMS 03) 0836

I

f

Nllncy He........ W DIMna K8IIergM~

52 . (2334) I ICT3 IT (3182) I

I

I ~.

Julie sellick

NWRO

(WMS 02) 2397

K8ySeller

SWRO

(WMS 02) 3405

Jlm ....m

ERO

(WMS 02) 0209

PoIIyZelm

eRO

(WMS 02) 2881

r

I

.....,. CMnon1.

51 (2356) I

r

I

Donna NIchoIeon~

81 (2n9) I AlIhI"" 51 (0222) I

I

RutIIKotynta \

81 (3234) I

1

95-HWTR2JOrg 95 (10127195)

(2997)

u.rtt Benedict ES3 (3117) lind l1m HopIdn..... E52 Temp (3062) report dIrecty 10MdIon~.

Dennie BowMy ES5 (1123) WOfb tor TAPS.

Jim 8Ilohet

HWCompUnlt

E8-28 (3036)

JIm~....

ES3 (3038)

Dlck~

ES3 (2380)

Tom .........

HG3 (2573)

ChrtIidM z.tIr

ES3 (303t)

8.... DIck

. HWComp Unit

eS·2A (2976)

I

DougJ-rne

TR Unit

ES·2B (0302)

I

Demon 0eI1atntty

Toxl (2979)

John Blunt

ES3 (2831)

c.nNIe fnnlldort

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.d 8tMtey

EE5 (0180)

lAee.gley

ES4 (0678)

UzaAormyft _c.on ES2 (2033)

ES2 (2665)

NlcIcyRu....

ES3 (2832)

JCAnnbru8W

E52' (1185)

0.". saundera

ES3 (2946)

o.nWll1ey

ES3 (2679)

oev.MIAo

ES4 IT (0169)

...."ne~

ES3 (2681)

Michelle Undel wood

ES3 (0187)

J. Daivld ttohrNnn

ES3 (1171)

Bob Stone

ES3 (2989)

Don Seeberger

ES3 (1188)

Victoria Sutton

ES3 IT (1083)

DeYid Hovlk

ES1 (3043)

V8C8fIt

AI2

Barb Smith

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)

EIIIon ZIInmeI_

EP3 (2551)
2. Sources of Funding

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 State Toxic 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 of Interior. 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 of numerous 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

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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 of potential new projects;

reallocation decisions by Management. It is envisioned that periodic repetition of this

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 data was divided into three separate levels: the most aggregated level, the

Program-level plan, summarized the number of F'TEs each Region/Section will devote 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 of functions 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 of each

Region/Section.

Work also continued this year to more closely integrate State/EPA Agreement (SEA)

planning into the Program planning process. Intense negotiation with EPA Region 10

resulted in a greatly simplified SEA Workplan. This simplified format will continue to be

used in the future.

Resource Reallocation

The Program planning process is meant to readjust Program objectives and resource

allocations to optimally match 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 of current 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 11.4 FIEs

(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 of Potential 10%

Cuts in FIEs for Reallocation with Costs of New Initiatives). The total estimated FIEs

19
required 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 of New FY95 Projects

The new projects to be undertaken in FY95 and brief descriptions of them 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 of responding to changing business practices with

a minimum of reviews and processing from Ecology. Other Programs will contribute

about .2 FIEs to. the project. The project will produce 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 of the

permit. The document will describe what changes in legislation, rules, policies, and

procedures are required to implement an improved permit process. The document will

include a description of the 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 of permits. Other Programs will contribute about 1.49

FIE. The project will produce a report to the legislature on the pilot project. The

report will include an evaluation of the pilot project, including:

• how it achieved 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 other barriers

• 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 will contribute about .9

FIE. The project will produce a guidance document for permit writers on ways to

increase P2 in closures.ipost-closures, and corrective action.

Implementation of State 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 spinoff work.

(a) Regulation Development - Staff at both HQ and in the regions will be involved in

developing regulations to implement the project's recommendations. This will not

include picking up any new federal rules, used oil rules or small modifications.

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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) Spinoff Work - 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 will contribute about .5 FIE to the project.

Development of Opportunities Database: This project would complete the Pollution

Prevention opportunities Database and make it available to all interested HWTR

Program staff as a technical assistance tool. This will include making final system

decisions, database programming and system documentation, entry of additional P2

opportunities, staff training and system updating/maintenance. No other Program FIE

commitment is needed to complete this project.

Information Systems Training: This project is designed to address the on-going issue of

how to keep regional and headquarter staff fully trained on agency software and Program

/ EPA information system applications. Staff that are productive on their computers are

more efficient and able to provide more service delivery to our clients. Presently, what

little training is provided is sporadic and limited in variety. The project will develop a

training program to keep regional and headquarter staff fully trained on program

applications and agency software..About .3 FIE of other Program staff time will be

needed to fully implement 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 will develop a core curriculum for multi-media regulations and

issues which will be taken "on the road" to the regional offices and HQ. It curriculum

will be designed to provide a framework for understanding site-specific or issue-specific

problems from the air and water perspective. About .4 FIE of other Program staff time

will be needed to fully implement this project.

Table 2. FY95 Program Plan- FTE Breakdown Summary for all Regions

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FY95 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

I

IITE.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.: In the pr.'" ohwt. thM. w.,. MpefIItlt oaceoon- 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~EAND oIoeur.. end oorreodv. eodorw.

COfIRECllVE ACnON WORK

GnoI~ r.c;on.t dooumem 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.. "odon WorIlor"""

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_.

Lt THE NUMBERS IN PARENTHESES INDICATE THE GOAL/ACTIVITY TO WHICH THE FTEs'HAVE BEEN ASSIGNED.FINAL revision of the FTE cetegories for Program Planning 18/30/941 0 o
FYII6 PlANNINO: HAZARDOUa WAlITElTOXlCS REDUCTION PROGRAM

CURRENT FTE 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 on Come, 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'*' uncIot ootltllOtY ....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.MAlNTENANCE WOIUt, lISl , e-: TNo ___tutIonol~.Vendot

_.0__--.-'

OENIIIAL COMPUTEI' 0.00 0.40 0.00 0.00 0.00 0.00 0.40

a~RTIlAN11.1

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) 2
FVII PlANNINO: HAZARDOUI WAITElTOXICI REDUCTIONPROORAM

, CURRENTFTE AI8l0NMENTlBV WORK 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 .nd OMolon Inform.don m_oement workg,oupw

"81 8flR(): Bob Ool.....g·.lnvolvomont In 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

ACnVl 'NIT I WOfUC IAP'flUCAnON 0.00 4.70 0.111 0.00 0.111 0.211 11.211 CRO: Com.,on·_t ooo,d wtlt> Hq. lnaluclng the C_clnedng

flIVIlWI, PII'MIT IIIUANCE. APPEAl Fo"...

,NEOOnAnONII "4' :

I

PBMT MO-=tCAnONI 1'4' 0.00 0.110 0.00 0.00 0.111 0.20 0.111 INFOIPBI: AooIOI..glonol ottloeo In ...wtng pennlt mod__.

:PEI'MlT IlIInATIVU tMULnMEDlA. 0.00 0.60 0.00 0.00 0.00 0.16. 0.86 INFOIPBI: Expecll*l pennlnlng end mul_. pennlnlng.

,IFf'tCIENCY. ETC.I .,41

REGIONALDOCUMENT DEVELOPMENT AND 0.00 0.00 0.00 0.00 0.00 0.00 0.00

REVIEWFOIIJ TI..CATEOOfIY ....4'

; :

OTHER IlELATEDIPLEAIIIPECIFY, 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 AS8IMANCE PlAN 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

, IlATE HAZARDOUS WAITE PlAN .,71 0.80 0.00 0.00 0.00 0.00 0.00 0.80

I POLLlITION 1'IlIVINTI0N IT1UlTEOY "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.

uPTHE NUMBERS IN PARENTHESES INDICATE THE GOAL/ACTIVITY TO.WHICH THE FTEs HAVE BEEN ASSIGNED.fiNAL reyjllon of the UE 9111egorlllll for Progrllm Pfenning 18/391941 0 o
FYII6 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 INlnAL tIITE

VISIT. ,,_w..... vi.... __... _ lot undo< NWRO: 0.1 from FY 94 + 0.5 (Siri Klovstad for 6

com......lEn_lootolJOfYl months); .05 from SEA + .05 from State HW

Plan

+ llntems for 42% of FY 95.

}

OINII'AL POU\IT10N PREVENTlON 0.30 0.00 0.40 1.20 2.00 0.110 4.70

EDUCATION

PlIo.: Thte Inoh.... phone MIle, 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. _1_tOr_ AND PUWCATION. C1no1.-........ oil .......

.. _I~I_,I l~ UJ tIO"'- 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 4
FY8& 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

!IlEOUlATOfIY CHANOU· .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: .3 for Compliance Units; .6 for Toxlcs : Aa8l8TANCE AND COORDINATION 1671

~",- ......................... .. ... Reduction Unlt;.2 for Technical Unit. Also .....-...:.."-'-.-....._-_.... --_...._:.-._....- Includes time for CeoCraphic-based teams. ...----.--................ ~-... 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 o
FV8& PU\NNINO: HAZARDOUS WAaTElTOXlCS 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 _lor 4 Iftt ~-.; 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>In SUPPOrlPool

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 of permitting 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 priority by both EPA and Ecology.

Permitting priorities were determined using procedures which considered national

permitting priorities. These priorities ate describedin the compliance monitoring section

of this document. .

In general, permits fall into two major categories, existing TSD facilities and new TSD

facilities. Completion of permit actions in progress and disposition of EPA-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

were joint 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 of the impacts of a proposed facility, in part to

"promote efforts which will prevent 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 of permits 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 of RCRA 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 if their activities become newly regulated by amendments to state

regulations. To qualify, the owner/operator must submit a Part A permit application

28 o ----------------- ---------- ---~---------------------- ------
•

•

•

within six months of the date the new amendments are adopted (equivalent to 40 CFR

270.1O(e)(l)(i)). Facilities may qualify for state-only interim status if they 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 if EPA amends their rules

in the future. .

Those facilities wishing to receive or ordered by Ecology to receive a final status permit

must submit a completed Part B application as defined in WAC 173-303-806 to Ecology

within six months of its request. Late or incomplete Part B applications will be

processed in accordance with the state's enforcement policy. This is equivalent to 40

CFR Part 270 Subpart B. Appendix D lists all existing TSD facilities in Washington

State.

Permit Modifications. There are three classes of permit 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- cover routine changes, such as changing typographical errors, upgrading plans

and records maintained by the facility, or replacing equipment with functionally

equivalent equipment; Class 2- address common or frequently occurring changes needed

to maintain a facility's capability to manage wastes safely or to conform with new

regulatory requirements.; Class 3- cover major changes that substantially alter the

facility or its 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 by the State: decrease rate of waste application, changes in any condition

for a land treatment unit, and changes to allow a second. land treatment demonstration.

Modifications to existing permits are written at the appropriate regional office or the

Industrial Section of Ecology's Central Programs. Addition of these permit

modifications to the Dangerous Waste Rules in 1991 did not result in a need for

additional resources.

C. New TSD Facilities

New facilities must submit both Parts A and B of the permit application to Ecology six

months before physical construction can begin. 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 of units that treat, store, or dispose of

hazardous waste In miscellaneous units must comply with the general application

requirements, and Part B general and specific requirements. They must ~lso meet

29
environmental performance standards; monitoring, testing, analytical data, inspection, 0

response and reporting procedures; and post-closure care. Permitting of miscellaneous

units will be done by the headquarters permits unit, the Industrial Section of Central

Programs, or the Hanford Section of the Nuclear Waste Program.

Incinerators. New or existing incinerator facilities 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 either conduct a trial burn or submit other information specified in

Federal rules and the State requires both. Incinerators are to be permitted by the

headquarters permits. unit, the Industrial Section, or the Hanford Section.

D. Permit Development Review and Approval 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 of air, 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 (if necessary) or statement of basis of

permit determination. .

Coordinate with EPA during the review process.

Open comment period, issue public notice, hold public hearings when

necessary, and establish administrative record.

Take necessary enforcement actions to ensure application completeness,

and that closure/post-closure and financial requirements are met prior to

permit issuance and in accordance with state enforcement policies.

The appropriate city or county ensures compliance with 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 proper judicial review of permits in cases of applicant appeals.

o

In reviewing applications· and writing permits Ecology will ensure that all appropriate

30 o
• information and conditions are provided. This will be done by appropriate engineering

and hydrogeologic judgments 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 of events, lines of responsibility, and intra and

interagency relationships that will occur in the permit process. Internal operating

procedures and policies will be developed to ensure adequate review and compliance

with state and federal regulations.

E. Permits by Rule (PBR) (See WAC 173.303.802)

Ecology allows PBR for:

1. Ocean disposal barges or vessels. The PBR requirements of the state are identical

to federal standards.

2. Underground injection wells. The PBR requirements prohibit underground

injection of extremely hazardous waste. They require .compliance with 40 CFR

144.14 and all applicable state waste discharge. permits and conditions.

•

3. Publicly owned treatment works (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 POTW has

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 of dangerous 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. If the facilities or units pose a threat or fail to comply with the PBR

conditions, Ecology may require compliance with all the facility standards and

require a full permit.

F. Emergency Permits

Ecology may issue an emergency permit to allow for treating, storing, or disposing wastes

at facilities which either are not permitted (including interim status), or, if permitted, are

not authorized at the time to manage the particular waste. Emergency permits will only

be issued if doing so will alleviate imminent and substantial threats to public health and

31 .
the environment. The requirements for state-issued emergency permits are identical to

the federal requirements of 40 CFR 270.61. .

Research and Development Permits. A research development, and demonstration permit

may be 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 of Permits

WAC 173-303-845 states 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 pursuant to Chapter 43.21B RCW. The Pollution Control Hearings

Board Act, WAC 371-08-255, states that in the event the board determines that a permit

issued by Ecology under Chapter 173-303 WAC is invalid in any respect, the board shall

issue an order remanding the permit to Ecology for reconsideration and appropriate

action consistent with the provisions of said order and federal and state law. Any further

appeals shall be appealed to the superior court of the state of Washington and shall

follow procedures per Chapters 43.21B and 34.05 RCW.

H. Permit Certification Language

Due to changes under Chapter 70.105.215 RCW, Ecology included additional permit

certification language for situations where the owner and operator of a TSD facility are

separate entities (see WAC 173-303-810(13)). However, Ecology and EPA have agreed

to require that TSD applicants sign both the federal and the state certification when

applying for a TSD permit.

·32

o

o

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•

MODIFIED PERMIT PROCESS FOR APPUCATIONS

RECEIVED PRIOR TO NEW SITING CRITERIA

Permit Appllcati0r;"

Demonstration of

Compliance Revlew

Ecofogy Review Public Comment

No

Return Application

I

I Yes -- -- - - -

SEPA

Document

No

CPN Report Prepare D~ft Permit •

Public Comment Period

Issuance

Dental

No Facility

•

EcologyOversees

Construction

Department of Ecology

March 1991

33
.-.-._--~-----

IHn!QAA~ (W ,....,..IIPA. AND CPH PROCESSes

DANOIROUSWASft 'AQunal

o

CNaII""t*-It ..."...., .........00......

""*YAcIt

E~ 8MdI c., 01

NOIIaI 0I1Melll1DLA" • • - • • • •

lOCll ,.",.., IIlll AIItcIl.

lOCllQcwenl_••

~1WnlftI

HelIce 01...... IncIUdng

OIftiOlld'lllOll 01

ComClI- tlftI'IllIng

CItMrlII

NOTES: I.cM* go;;M ..n.nt"'IIClI'IIlIIy" RPA ClI''''' 10 .

II1llere,. nO CPN IN 8EPAs-- UN Ill" ....tiP HIS I!claIoGY .........4hII.....

CPN,."c*lnWyICll'P1opol_OIlt-.nIllCl n. _ .,'Cll'liIclIlWllclftar~"" _

o

o

+ I ..... _ -_ .. ------_..- _.-

-,

34

~.lOCll

P·"'·"lUld~ Pr...-. ColIna ICll'

"wH"*"1I Nllllnduded In

~ntof Ecology

M8Idll991

i

I

I

I

\

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I
• IV. COMPLIANCE MONITORING AND ENFORCEMENT

•

A. Authority

Under the provisions of RCW 70.105.080 and .095, Ecology has been given the authority

to take enforcement action against any violator of the state's dangerous waste laws and

regulations. This authority includes the ability to levy civil penalties up to a maximum of

$10,000 per day of noncompliance 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 of departmental 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 of Initiative 97 amended Chapter 70.105 RCW to

provide for strict liability for knowing endangerment of persons 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 of inspections targeted at Land Disposal (LDF),

Treatment and Storage (TSF), and Generator/Transporter facilities.

EPA has set priorities for the frequency of Treatment, Storage, and Disposal (TSD)

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

•

TSD's

Government TSD's

LDF with Class I Violation

LDF without 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 2 years
RCRA requires the state to commit to inspecting a set percentage of fully regulated 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 priority list.. 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 priority facilities.

Facilities have been ranked according to the following criteria:

Environmental Issues

o Level of Contamination

o Toxicity of Waste Stream (EHW versus Toxic HW)

o Facility Setting

Oversight Issues

o

o

o

o

o

Enforcement History

Financial Status of Facility "

Extent to which the Nature of the Releases are known

Level"of Public Interest

Type and Complexity of Particular Corrective Action Activity

o

A full outline of the Facility Environmental Priority Ranking Criteria is included in the

Northwest ReRA Corrective Action Strategy (the Repoit).

Non-Mandatory Inspections encompasses additional TSF inspections (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 of Ecology of their existence. Nonnotifiers are inspected according to the same priorities outlined in each region for

state/SQG inspections. (Regional priorities are outlined in the "Discussion Papers"

section of the Report).

New-notifiers are those facilities which have recently notified EPA and the

Department of Ecology of their existence, but have yet to be inspected. The

36

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"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 will result in fewer compliance issues being

addressed. The inspection is only to supply the facility with regulatory

information, and requires no formal write up.

Pesticide Waste Compliance Inspections provide a preventative approach to

environmental impacts caused by improper pesticide waste management. A fourpoint strategy for 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 of compliance incentives are the four elements considered in

achieving greater compliance. Establishing education describing health and

environmental threats from improper waste management, how hazardous waste

regulating pertains to pesticide waste, and the presentation of options for

reducing/preventing pesticide wastes is the responsibility of both the regions and

program headquarters. Inspections .are conducted by the regional staff.

The state also commits to complete a number of State/Small Quantity Generator

(SQG) inspections for each region. SQG's includes both notifiers and nonnotifiers. The determination of which facilities to inspect varies based on regional

priorities, needs, and interests. Many inspections are the result of complaints,

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, contact frequency, and measuring

and monitoring compliance. A pilot project to measure compliance at the facility

level was completed. A summary paper of the Point System Pilot Project which

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 of the Point System Pilot Project which discusses

the potential uses of this evaluation tool and recommendations for further action

is available.

A summary paper has also been prepared regarding Ecology's contact frequency

with hazardous waste generators. This paper discusses the various methods used

by Ecology to contact generators to provide technical assistance on regulation

compliance and pollution prevention.

Record Reviews are conducted at hazardous waste facilities to review closure and post37
-------~~-- -----i---~·----

closure plans, financial documents and ground water monitoring/assessment reports.

D. Enforcement Procedures (Enforcement Policy is at Appendix C)

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 violator has fifteen days, from the enforcement action delivery date, to file an

Application for Relief with Ecology. Ecology acknowledges receipt of the Application

within 30 days by letter. In the Application for Relief, the violator states why they feel

the enforcement action is inappropriate, or presents new relevant 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 Relief and determines if the

enforcement action is to be canceled, affirmed, or in the case of penalties, 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 legally required prior to the issuance of the enforcement action. Penalties will only

be canceled or mitigated when additional relevant facts are brought to Ecology's attention.

Formal decisions are comprised of a cover letter and a Notice of Disposition Upon

Application For Relief which either affirms, mitigates or cancels the penalty assessed.

The decision to mitigate, cancel, or affirm should include consideration of the argument

provided by the violator in the Application For Relief.

Appeal to the Pollution Control Hearings Board

Any party feeling 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 of receipt of the action or Ecology's final decision. A copy

of the appeal is sent to Ecology. The PCHB will set a hearing date; at the hearing the

case will be reviewed and the PCHB will make a determination. Both the violator and

Ecology have the right to appeal the PCHB determination through the courts.'

Settlement Procedures

When a violator appeals an enforcement action to the PCHB, the violator has the option

of settling with Ecology prior to the PCHB hearing. The full range of options are

considered during the settlement process. Generally, the violator's attorney will seek

resolution by contacting the assistant attorney general in charge of the case. All

.settlement offers are handled through the state's AG Office in conjunction with the staff

38

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-- - -- - - - --- -- - ---- - ----- -------- -
•

•

•

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

Of the several enforcement options available to the agency the most serious is criminal

'enforcement. The intent of criminal enforcement is to obtain compliance by both the

violating facility and the rest of the regulated community. The operating assumption is

that wilful, knowing violators of environmental laws should be dealt with in the criminal

_court system. This tends to promote compliance by serving as a deterrent to other -

members of the regulated community.

Because of the 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 good judgment. 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 civil and criminal enforcement actions concurrently. One

exception is a situation where injunctions or restraining orders or other judicial 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

civil enforcement should immediately cease unless you have approval from the criminal

section. This does not preclude other regulatory or administrative actions from taking

place, such as inspections" responses to complaints, normal permitting activities, and

other routine 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 EPA require an active

EPNState identification number on manifests that accompany shipments of regulated

hazardous/dangerous wastes. An EPNState Id number identifies the generator

39

1

.1
(originator), transporters, and Treatment/StoragelDisposaJlRecycling Facilities (receivers) 0

who handle regulated dangerous wastes. A dangerous waste handler who needs an

EPNState ID number fills out 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 10 for the actual number assignment and RCRIS data entry.

The Washington Department of Ecology and the EPA work together to manage

information relating to the implementation of RCRA. Both agencies use the Resource

Conservation and Recovery Information System (RCRIS) for the storage, tracking, and

analysis of data relating to state and federal hazardous waste program activities. Those

who generate, transport, store or treat hazardous waste in Washington State are

identified with a uniquely assigned federal ID number. Information obtained from

Notification of Hazardous Waste Activities, applications for Hazardous Waste permits,

inspections, corrective action procedures and enforcement proceedings are entered into

RCRIS by Hazardous Waste and Toxies Reduction section staff located in Ecology's

headquarters and regional offices, and by Ecology staff in 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 of how both agencies use

RCRIS and how the information merges together is descnbed by a Memorandum 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 staff and management for

current, historical and planned activities, as well as EPA Region 10 and EPA

Headquarters for their oversight functions.

HW Annual 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 by March 1st of the following year.

Federal regulations require that this annual report data be submitted to EPA for the

national Biennial Report on every odd numbered year.

Old HW Reporting System (Form 4/Form 5)

From 1982 to 1994 Ecology collected annual report data on two forms: the Form 4 for

generators and transporters of dangerous waste, and the Form 5 for receivers (TSDRs)

of dangerous waste. These reports were originally designed to track 'cradle to grave'

manifest information and to answer questions about waste movements between different

sites. In later years 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, but became increasingly more difficult to fill out. The data elements

needed to answer some basic current waste questions and to meet EPA Biennial

Reporting requirements were still missing.

40

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e·

e

New Reporting System

Beginning in 1995, annual report data will be collected on a set of forms designed to

track the nature, source, and management (both on-site and off-site) of dangerous

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 of generators, 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 of waste generated in the

state and on a national level as well. By inputing 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 six years to the State

Hazardous Waste Plan, 2) regulatory development and change efforts, and 3) technical

assistance to promote waste reduction and the assessment of Hazardous Waste

Generator Fees. An annual report summery is written to analyze each year's data and

for comparison to previous years data for trend analysis.

v. REGULATED COMMUNI1Y DATA - ESTIMATES

A. . Number of Notifiers by Activity Reported

The following information depicts the status of Washington State as of November 1994.

e

Activity

Transporters

Generators (fully regulated).

Generators (includes CESQGs)

TSDs

Number

541

936

11220

64

41
B.

\

Amount of Waste Treated. Stored. and Disposed ,0

Data collected and analyzed for 1993 showed the following:

I WASTE GENERAnON I TONS I

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

treated then discharged under a Permit-by-Rule or a

NPDES Permit)

RECURRENT WASTE (waste from generator's on- 201,462

going production process)

NON-RECURRENT WASTE (waste from clean-up or 82,913

spills)

RADIOACTIVE MIXED WASTES (designated 11,147

dangerous waste that exhibit low level radioactivity)

RADIOACTIVE MIXED WASTE WATERS} - ,

38,093

(Impoundment at Siemens Power Corp.)

ITOTAL I ,,189,452 1

I PERMITTED WASTE MANAGEMENT I TONS I

TREATMEN~ (physical, chemical or biological 7,526,354.

processing)

STORAGE (holding of waste for temporary period) 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

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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