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I'. Oregon Departmentof Environmental Quality Part II Attorney General's Statement

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## Portland, Oregon July28, 1995

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• ATTORNEY GENERAL'S STATEMENT FOR AUTHORIZATION FOR THE FEDERAL RCRA CORRECTIVE· ACTION PROGRAM I hereby certify, pursuant to my authority as AssistantAttorney General and in accordance with Section 3006(b) ofthe Resource Conservation and Recovery Act, as amended by the Hazardous and Solid Waste Amendments of1984 (42 USC 6901 etgg.), and 40 CFR 271 that in my opinion the laws ofthe State of Oregon provide adequate authority to carry out the revised program set forth in the revised "Program Description" submitted by the State ofOregon Department ofEnvironmental Quality (DEQ). The specific authorities provided are contained in statutes or regulations lawfully adopted at the time this Statement is signed and which are in effect now, or shall be as specified below. These authorities and this certification supplementpreviously certified authorities granted January 30, 1986, FR 51, page 3779, effective January 31, 1986; and March 30, 1990, FR 55, page 11909, effective May 29, 1990, and August 5, 1994, FR 59, page 39967, effective October4, 1994.
I. CORRECTIVE ACTION A. Environmental Quality Commission (EQC) regulations contain the following corrective action requirements as indicated in Revision Checklist 17 L. (l) Corrective action is required for releases ofhazardous waste or constituents from any solid waste management unit at a facility seeking a permit, regardless of when the waste was placed in the unit; in all permits issued after November 8, 1984. Citation: OAR 340-100-002(1), revised May 18, 1995, effective May 19, 1995. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 264.90; 264.101, 270.60 and the amendments ofJuly 15, 1985 (50 FR 28702). The State has adopted 40 CFR 264.90 and 264.101 by reference. The State definition of"waste management unit" in the revised Program Description is a state-only definition, not specifically directed to corrective action for solid waste management units. With respect to the terms "solid waste management unit" and "release", the 40 CFR 264 references to these terms would apply and, for the purposes ofimplementing corrective action, the State will use both the definition of"solid waste management unit" and "release" in 50 FR 28702, pages 28712 and 28713 respectively, pursuant to the regulatory comment in OAR 340-100-002. Authority to adopt these regulations is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §3004(u); 40 CFR 264.90, 264.101 and 270.60 as amended July 15, 1985 (50 FR 28702). (2) Corrective action is required beyond a facility's boundary, in accordance with RCRA §3004(v). (States now may impose these requirements through a permit or a corrective action order. Once EPA promulgates the regulations required by RCRA §3004(v), States will need authority to impose corrective action in a permit following the RCRA §3004(v) regulations.) Citation: ORS 466.020(7), 1993.

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• Comments: ORS 466.020(7) authorizes the EQC to adopt rules and issue orders relating to corrective action beyond a facility's boundary. To the extent that this requirement is mandatory under the federal program regulations, it is mandatory for the purposes ofcorrective action under the state program. Federal Authority: RCRA §3004(v)(1). (3) Corrective action is required beyond afacility's boundary in accordance with §3004(v) for all landfills, surface impoundments and waste pile units (including any new units, replacements ofexisting units or lateral expansions ofexisting units) which receive hazardous waste after July 26, 1982 (see Revision Checklist 17 L). Citation: ORS 466.020(7), 1993. Comments: ORS 466.020(7) authorizes the EQC to adopt rules and issue orders relating to corrective action beyond any facility's boundary, including landfills, surface impoundments, and waste pile units which receive hazardous waste after July 26, 1982. To the extent that this requirement is mandatory under the federal program regulations, it is mandatory for the purposes ofcorrective action under the state program. Federal Authority.: RCRA §3004(v)(2). (4) There is evidence offinancial responsibility for corrective action on- and off-site
. Citation: OAR 340-100-002(1), revised May 18, 1995, effective May 19, 1995. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 264.90 and 40 CFR 264.101 as amended July 15, 1985 (50 FR 28702). Authority to adopt these regulations is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §§3004(a)(6); (u); 40 CFR 264.90 and 264.101 as amended July 15, 1985 (50 FR 28702). B. State statutes and regulations require landfills, surface impoundments, land treatment units, and waste piles that received waste after July 26, 1982 and which qualify for interim status to comply with the groundwatermonitoring, unsaturated zone monitoring, and corrective action requirements applicable to new units at the time ofpermitting as indicated in Revision Checklist 17.L. Citations: OAR 340-100-002(1), revised May 18, 1995, effective May 19, 1995. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 264.90(a) as amended July 15, 1985 (50 FR 28702). Authority to adopt this regulation is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §3005(i); 40 CFR 264.90(a) as amended July 15, 1985 (50 FR 28702)
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# • c. EQC regulations require owners and operators offacilities seeking permits to provide descriptiveinformation on the solid waste management units themselves and all available information pertaining to any releases from the units as indicated in Revision Checklist 44A.



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• Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 270.14 as amended December 1, 1987 (52 FR 45788). Under the State program, facilities must submit identical information as under the federal regulations. In addition, OAR 340-105-014 may at times be more stringent and may at times be broader in scope than 40 CFR 270.14 depending on additional information being requested by the Department. Authority to adopt this regulations isprovided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §3004(u); 40 CFR 270.14 as amended December 1, 1987 (52 FR 45788). D. EQC regulations require that owners and operators ofhazardous waste treatment, storage and disposal facilities (including permit-by-rule facilities subjectto 264.101) institute corrective action beyond the facility boundary to protect human health and the environment, unless the owner/operator is denied access to adjacent lands despite the owner/operator's best efforts, as indicated in Revision Checklist44B. Citation: OAR 340-100-002(1), revised May 18, 1995, effective May 19, 1995. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 264.100(e) and 264.101(c) as amended December 1, 1987 (52 FR 45788). Authority to adopt these regulations is provided in ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS**466.086~** Federal Authority: RCRA §3004(v); 40 CFR 264.100(e) and 264.101(c), as amended December 1, 1987 (52 FR 45788). E. EQC regulations contain the following corrective action requirements for injection wells as indicated in Revision Checklist44C. (1) Hazardous waste injection wells now operating under RCRA interim status may retain interim status after issuance ofa

## mc permit. Until a RCRA permit or a RCRA "rider" to a UfC permit, which addresses Section 30.04(u)corrective action, is issued, the well must comply with applicable interim status requirements posed by §265.430, Parts 144.146 and 147, and any DIC permit requirements. Citation: OAR 3.40-44-015, 1983. Comments: OAR 340-44-015 as adopted by the EQC is more stringentthan 40 CFR 144.1(h) as amended December 1, 1987 (52 FR 45788). OAR 340-44-015 prohibits UfC wells within onequarter mile ofan underground source ofdrinking water. Authority to adoptthis regulation is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086
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• Federal Authority: RCRA §3004(u); 40 CFR 144.1(h) as amended December 1, 1987 (52 FR 45788). (2) As 'partofthe UIC permit process, available information regarding operating history and condition ofthe injection well must be submitted as well as any available information on known releases from the well or injection zone. Citation: OAR 340-44-015, 1983. Comments: OAR 340-44-015 as adopted by the EQC is more stringentthan 40 CFR 144.31(g) as amended December 1, 1987 (52 FR 45788). OAR 340-44-015 prohibits UIC wells within onequarter mile ofan underground source ofdrinking water. Authority to adopt this regulation is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §3004(u); 40 CFR 144.31(g) as amended December 1, 1987 (52 FR 45788). F. UIC facility owners/operators must submitcertain information related to corrective action with their UIC applications. Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 270.60(b)(3) as amended December 1, 1987 (52 FR 45788). Authority to adopt this regulation is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §3004(u); 40 CFR 270.60(b)(3) as amended December 1, 1987 (52 FR 45788). G. EQC regulations contain remediation waste management provisions for corrective action management units (CAMUs) andtemporary units (TUs) at RCRA facilities, as indicated in Revision Checklist 121. Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995
.. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 260.10, 264.3,264.101(b), 264.552, 264.553, 265.1(b), 268.2(c), 270.2 and Appendix I to 270.42, as amended February 16, 1993 (58 FR 8658). Authority to adopt these regulations is provided under ORS 183.355, OAR 165
.. 26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §§1006, 2002(a), 3004(u), 3004(v), 3005(c), 3007, and 3008(h); 40 CFR260.10,264.3, 264.101(b), 264.552, 264.553, 265.1(b), 268.2(c), 270.2 and Appendix I to 270.42, as amended February 16, 1993 (58 FR 8658). II. REQUIREMENTS FOR PERMITS A. EQC regulations allow greater flexibility to interim status facilities to make changes during interim status following directorapproval as indicated in Revision Checklist 61 4Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995; 340-105-001(3), revised March 15, 1991; 340-105-010, revised March 15, 1991; 340-106-002, revised July 25, 1985. Comments: OAR 340-106-002 as adopted by the EQC deletes optional standards 124.1(a), 124.15(b), and 124.19(a); 340-105-001(3) is more stringentthan 270.1(c); OAR 340-105-010 as adopted by the EQC is an analogue to 40 CFR 270.72 as amended March 7, 1989 (54 FR 9596). More stringentrequirements include requiring additional information beyond federal requirements for Part A and Part B applications; a thirty day requirement for submittal ofa Part A application for an existing facility after new wastes become listed; OAR 340, Division 120 siting requirements for facilities; and off-site facilities must have a Part B permit before continuing to accept hazardous wastes. Authority to adoptthis regulation is provided under ORS 183.355, OAR 165-26-0 I0, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §§2002(a), 3004, 3005 and 3006; 40 CFR 270.72 as amended March 7, 1989 (54 FR 9596).


# • B. EQC regulations that classify as Class 1 certain permit modifications requested by owners/operators necessary to enable permitted facilities to comply with the land disposal restrictions as indicated in Revision Checklist 61. Specifically these modifications include I) adding restricted wastes treated to meet applicable 40 CFR Part 268 treatment standards or adding residues from treating "soft hammer" wastes, 2) adding certain wastewatertreatment residues and incinerator ash, 3) adding new wastes for treatment in tanks or containers under certain limited conditions, and 4) adding new treatment processes, necessary to treat restricted wastes to meet treatment standards, that take place in tanks or containers.


# I. Citations: OAR 340- I00-002(1) revised May 18, 1995, effective May 19, 1995. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 27Q.42 as amended March 7, 1989 (54 FR 9596). Authority to adoptthese regulations is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §§2002(a), 3004, 3005 and 3006; 40 CFR 270.42 as amended March 7, 1989 (54 FR 9596). 

# c. EQC regulations allow a facility (1) to constructan approved TSCA facility for burning PCBs without first obtaining a RCRA permit and (2) to subsequently apply for a RCRA permit in accordance with Revision Checklist 17M. Citation: OAR 340.-100-002(1) revised May 18,1995, effective May 19, 1995; OAR 340-105- 010, revised March 11, 1991. Comments: OAR 340-100-002(1) incorporates by reference adopted by the EQC 40 CFR 270.10(f)(3) as amended July 15, 1985 (50 FR 28702). OAR 340-105-010 is more stringentthan 40 CFR 270. 10(f)(3) by requiring Division 120 siting standards be met before construction; and that facilities receive a final permit before managing TSCA wastes. Authority to adoptthis regulation is provided underORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. 5

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• Federal Authority: RCRA §3005(a); 40 CFR 270.10(t)(3) as amended July 15, 1985 (50 FR 28702). D. EQC regulations require that: (1) For land disposal facilities granted interim status prior to 11/8/84, interim status terminates 11/8/85; unless a Part B application and certification ofcompliance with applicable groundwatermonitoring and financial responsibility requirements are submittedby 1118/85, as indicated in Revision Checklist 17 P.
. Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995; OAR 340-105- 115 revised August, 1985; OAR 340-105-010, revised March 11, 1991. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 270.73(c) as amended July 15, 1985 (50 FR 28702). OAR 340-105-115 deletes the optional provisions in 40 CFR 270.70 to 270.73 but 40 CFR 270.71 and 40 CFR 270.72 are replaced with both analogous and more stringentprovisions in OAR 340-105-010 in that existing and new facilities managing hazardous wastes must receive a final pennit and comply with OAR Chapter 340, Division 120 siting standards before continuing to manage such wastes. Any facility subject to loss ofinterim status under federal law, or in violation offederal law, is in violation ofstate law. In addition, since the State program does not include 40 CFR 270.73 no state permit could be issuedunderthe federally delegable program in contravention ofthe federal requirements. Authority to adoptthis regulation is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086 . Federal Authority: RCRA §3005(e); 40 CFR 270.73(c) as amended July 15, 1985 (50 FR 28702). (2) For land disposal facilities in existence on the effective date ofstatutory or regulatory changes under this Act that render the facility subjectto the requirementto have a permit and which is granted interim status, interim status terminates 12 months after the date the facility first becomes subject to such permit requirement unless a Part B application and certification ofcompliance with applicable groundwatermonitoring and financial responsibility requirements are submitted by that date as indicated in Revision Checklist 17 P. Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995; OAR 340-105- 010, revised March 11, 1991. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 270.73(d) as amended July 15, 1985 (50 FR28702). OAR 340-105-115 deletes the optional provisions in 40 CFR 270.70 to 270.73 but 40 CFR 270.71 and 40 CFR 270.72 are replaced with both analogous and more stringentprovisions in OAR 340-105-010 in that existing and new facilities managing hazardous wastes must receive a final permit and comply with OAR Chapter 340, Division 120 siting staridards before continuing to manage such wastes. Any facility subject to loss ofinterim status underfederal law, or in violation offederal law, is in violation ofstate law. In addition, since the State program does not include 40 CFR 270.73 no state permit could be issued under the federally delegable program in contravention ofthe federal requirements,

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• Authority to adopt this regulation is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §3005(e); 40 CFR 270.73(d) as amended July 15, 1985 (50 FR 28702). (3) Interim status terminates for incinerator facilities on 11/8/89 unless the owner/operator submits a Part B application by 11/8/86 as indicated in Revision Checklist 17 P. Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995; OAR 340-105- 010, revised March 11, 1991. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 270.73(e) as amended July 15, 1985 (50 FR 28702). OAR 340-105-115 deletes the optional provisions in 40 CFR 270.70 to 270.73 but 40 CFR 270.71 and 40 CFR 270.72 are replaced with both analogous and more stringentprovisions in OAR 340-105-010 in that existing and new facilities managing hazardous wastes must receive a final permit and comply with OAR Chapter 340, Division 120 siting standards before continuing to manage such wastes. Any facility subject /' to loss ofinterim status under federal law, or in violation offederal law, is in violation ofstate law. In addition, since the State program does not include 40 CFR 270.73 no state permit could be issued under the federally delegable program in contravention ofthe federal requirements. Authority to adoptthis regulation is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086
. Federal Authority: RCRA §3005(c)(2)(C); 40 CFR 270.73(e) as amended July 15,1985 (50 FR 28702). (4) Interim status terminates for any facility otherthan a land disposal or an incineration facility on 11/8/92 unless the owner/operator submits a Part B application by 11/8/88 as indicated in Revision Checklist 17 P. Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995; OAR 340-105- 010, revised March 11, 1991. Comments: OAR 340-100;'002(1) incorporates by reference as adopted by the EQC 40 CFR 270.73(f) as amended July 15, 1985 (50 FR 28702). OAR 340-105-115 deletes the optional provisions in 40 CFR 270.70 to 270.73 but 40 CFR 270.71 and 40 CFR 270.72 are replaced with both analogous and more stringentprovisions in OAR 340-105-010 in that existing and new facilities managing hazardous wastes must receive a final permit and comply with OAR Chapter 340, Division 120 siting standards before continuing to manage such wastes. Any facility subject to loss ofinterim status underfederal law, or in violation offederal law, is in violation ofstate law. In addition, since the State program does not include 40 CFR 270.73 no state permit could be issued under the federally delegable program in contravention ofthe federal requirements. Authority to adoptthis regulation is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §3005(c)(2)(C); 40 CFR 270.73(f) as amended July 15, 1985 (50 FR 28702). 

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### E. EQC regulations allow facilities to qualify for interim status ifthey (1) are in existence on the effective date ofstatutory or regulatory changes that render the facility subjectto the requirementto have a permit and (2) comply with §270.70(a) as indicated in Revision Checklist 17 P.



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• Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995; OAR 340-105- 010, revised March 11, 1991. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 270.70(a) as amended July 15, 1985 (50 FR 28702). OAR 340-105-115 deletes the optional interim status provisions in 40 CFR 270.70 to 270.73 and OAR 340-105-010 replaces 40 CFR 270.71 and 40 CFR 270.72 with both analogous and more stringentprovisions because facilities managing hazardous wastes must receive a final permit and comply with OAR Chapter 340, Division 120, siting standards before continuing to manage such wastes. Authority to adopt these regulations is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §3005(e); 40 CFR 270.70(a) as amended July 15, 1985 (50 FR 28702). F. EQC regulations provide that facilities may not qualify for interim status under the State's analogue to Section 3005(e) ifthey were previously denied a Section 3005(c) permit or ifauthority to operate the facility has been terminated as indicated in Revision Checklist 17 P. Citation: OAR 340-100-002(1) revised May 18, 1995, effective May 19, 1995; OAR 340-105- 010 revised March 11, 1991. Comments: OAR 340-100-002(1) incorporates by reference as adopted by the EQC 40 CFR 270.70(c) as amended July 15, 1985 (50 FR 28702). OAR 340-105-115 deletes the optional interim status provisions in 40 CFR 270.70 to 270.73 and OAR 340-105-010 replaces 40 CFR 270.71 and 40 CFR 270.72 with both analogous and more stringentprovisions because facilities managing hazardous wastes must receive a final permit and comply with OAR Chapter 340, Division 120 siting standards before continuing to manage such wastes. Any facility subject to loss ofinterim status under federal law, or in violation offederal law, is in violation ofstate law. In addition, since the State program does not include 40 CFR 270.70 no state permit could be issued under the federally delegable program in contravention ofthe federal requirements. Authority to adopt these regulations isprovided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086. Federal Authority: RCRA §3005(c)(3); 40 CFR 270.70(c) as amended July 15, 1985 (50 FR 28702).
III. MISCELLANEOUS A. DEQRelationship with the State Public Utility Commissions (pUC) regarding Regulating Hazardous Waste Transporters

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E. The PUC regulates transportation ofall materials in the State. The PUC and DEQjointly administerthe hazardous waste transportation regulations underthe same relationship that exists between the federal Department ofTransportation and the EPA, and share hazardous waste transporterenforcementresponsibilities. PUC hazardous wastetransport regulations at OAR 860-66-060 et seq. are in addition to DEQ regulations Basically, ifa transportation issue revolves around generation, storage, treatment or disposal of hazardous wastes, the DEQ exercises its authority. Ifthe transportation issue is safety related, the PUC has authority. The DEQ would cooperate fully and enlist the assistance ofthe PUC on matters dealing with generators and TSD. The DEQ must comply with the Oregon Administrative Procedures Act (ORS 183), and Public Records Law (ORS 192). Permit Issuance Authority Oregon Revised Statutes (ORS) 466.055 and 466.060 make it clear that the EQC must approve and issue hazardous waste disposal ortreatment site permits. We have construed this to require that the EQC actually signs the permits. Although the existing Oregon Administrative Rules, Chapter 340, Division 100 imply that the Director may be the issuing authority for treatment permits, the statutes are overriding on this question and the Department adheres to the statutory requirements. Oregon statutes do not require the EQC to issuehazardous waste storage permits; rather these permits are issued by the Departmentpursuant to its permitting authority in ORS 466.015 . The State's basis for assuming authority over federal permit provisions for which the State is authorized is ORS 466.086 which authorizes the State to take any action within the legal authority ofthe EQC necessaryto gain federal authorization ofany portion of the Subtitle C program. The State's basis for becoming the designatedbeneficiary offinancial instruments andto administerthose instruments as necessary is ORS 466.086 which authorizes the State to take any action within the legal authority of the EQC necessary to gain federal authorization ofany portion ofthe Subtitle C program. State law and regulations authorize continued operation ofhazardous waste management facilities provided the owners and operators ofsuch facilities comply with standards at least as stringentas the federal standards in 40 CFR 265. ORS 466.020 gives the EQC authority to adopt rules establishingminimum requirements for the treatment, storage and disposal ofhazardous wastes, minimum requirements for operation, maintenance, monitoring, reporting and supervisionoftreatment, storage or disposal sites, and requirements and procedures for selecting such sites. These requirements apply whether or not a site is permitted and is to assurethat minimum management standards are always applicable. This is necessaryto deal with instances beyond a site owner's control where an unpermitted site may be managing a waste which may be**design~ted** hazardous such as when the Department identifies a waste as

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### IV. hazardous. This does not mean, however, that the facility may continue to operate without a permit. Such a facility would operate pursuantto enforcement discretion.
MEMORANDUM OF AGREEMENT (MOA) (1) The State has the authority to enter into an agreement with the United States Environmental Protection Agency, (2) The State has the authority to carry out the agreement, and (3) No applicable State statute (including the State Administrative Procedure Act) requires that the procedure be promulgated as a rule in orderto be binding.



# • Seal ofOffice

Signature

Larry 

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### Assistant Attorney General, State of Oregon Title



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