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Oregon Department of Environmental Quality

Part II

Attorney General's Statement

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Portland, Oregon

July 28, 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 Assistant Attorney General and in accordance with Section

3006(b) of the Resource Conservation and Recovery Act, as amended by the Hazardous and Solid Waste

Amendments of 1984 (42 USC 6901 et gg.), and 40 CFR 271 that in my opinion the laws of the State of

Oregon provide adequate authority to carry out the revised program set forth in the revised "Program

Description" submitted by the State of Oregon Department of Environmental 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 supplement previously 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 October 4, 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 of hazardous 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 of July 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 of implementing 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 of corrective action under

the state program.

Federal Authority: RCRA §3004(v)(1).

(3) Corrective action is required beyond a facility's boundary in accordance with

§3004(v) for all landfills, surface impoundments and waste pile units (including

any new units, replacements of existing units or lateral expansions of existing

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

of corrective action under the state program.

Federal Authority.: RCRA §3004(v)(2).

(4) There is evidence of financial 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 groundwater monitoring, unsaturated zone monitoring,

and corrective action requirements applicable to new units at the time of permitting 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 of facilities seeking permits to provide

descriptive information 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

is provided under ORS 183.355, OAR 165-26-010, ORS 466.020 and ORS 466.086.

Federal Authority: RCRA §3004(u); 40 CFR 270.14 as amended December 1, 1987 (52 FR

45788).

D. EQC regulations require that owners and operators of hazardous waste treatment, storage

and disposal facilities (including permit-by-rule facilities subject to 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 Checklist 44B.

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 Checklist 44C.

(1) Hazardous waste injection wells now operating under RCRA interim status may

retain interim status after issuance of a 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 stringent than 40 CFR 144.1(h) as

amended December 1, 1987 (52 FR 45788). OAR 340-44-015 prohibits UfC wells within onequarter mile of an underground source of drinking water. Authority to adopt this 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 'part of the UIC permit process, available information regarding operating

history and condition of the 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 stringent than 40 CFR 144.31(g)

as amended December 1, 1987 (52 FR 45788). OAR 340-44-015 prohibits UIC wells within onequarter mile of an underground source of drinking 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 submit certain 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) and temporary 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

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).

II. REQUIREMENTS FOR PERMITS

A. EQC regulations allow greater flexibility to interim status facilities to make changes

during interim status following director approval as indicated in Revision Checklist 61

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Citation: 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 stringent than 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 stringent requirements include requiring additional information beyond federal requirements

for Part A and Part B applications; a thirty day requirement for submittal of a 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 adopt this 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).

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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

wastewater treatment 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.

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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 adopt these 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 construct an 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 stringent than

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 adopt this

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 §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 of compliance

with applicable groundwater monitoring and financial responsibility requirements

are submitted by 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 stringent provisions 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 of interim status under federal law, or in violation of federal law, is in violation of state

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 of the federal requirements.

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(c) as amended July 15, 1985 (50 FR

28702).

(2) For land disposal facilities in existence on the effective date of statutory or

regulatory changes under this Act that render the facility subject to the

requirement to 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 of compliance

with applicable groundwater monitoring 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 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 stringent provisions 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 of interim status under federal law, or in violation of federal law, is in violation of state

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 of the 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 stringent provisions 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 of interim status under federal law, or in violation of federal law, is in violation of state

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 of the federal requirements.

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(c)(2)(C); 40 CFR 270.73(e) as amended July 15,1985 (50 FR

28702).

(4) Interim status terminates for any facility other than 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 stringent provisions 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 of interim status under federal law, or in violation of federal law, is in violation of state

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 of the federal requirements.

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(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 if they (1) are in existence

on the effective date of statutory or regulatory changes that render the facility subject to

the requirement to 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 stringent provisions 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) if they were previously denied a Section 3005(c)

permit or if authority 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 stringent provisions 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 of interim status under federal law, or in violation of federal law, is in violation of state 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 of the federal requirements.

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(c)(3); 40 CFR 270.70(c) as amended July 15, 1985 (50 FR

28702).

III. MISCELLANEOUS

A. DEQ Relationship with the State Public Utility Commissions (pUC) regarding Regulating

Hazardous Waste Transporters

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B.

C.

D.

E.

The PUC regulates transportation of all materials in the State. The PUC and DEQ jointly

administer the hazardous waste transportation regulations under the same relationship that

exists between the federal Department of Transportation and the EPA, and share

hazardous waste transporter enforcement responsibilities. PUC hazardous waste transport

regulations at OAR 860-66-060 et seq. are in addition to DEQ regulations Basically, if a

transportation issue revolves around generation, storage, treatment or disposal of

hazardous wastes, the DEQ exercises its authority. If the transportation issue is safety

related, the PUC has authority. The DEQ would cooperate fully and enlist the assistance

of the 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 or treatment 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 issue hazardous waste storage permits; rather

these permits are issued by the Department pursuant 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 of the EQC necessary to gain federal authorization of any portion of

the Subtitle C program.

The State's basis for becoming the designated beneficiary of financial instruments andto

administer those 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 of any portion of the Subtitle C program.

State law and regulations authorize continued operation of hazardous waste management

facilities provided the owners and operators of such facilities comply with standards at

least as stringent as the federal standards in 40 CFR 265.

ORS 466.020 gives the EQC authority to adopt rules establishing minimum requirements

for the treatment, storage and disposal of hazardous wastes, minimum requirements for

operation, maintenance, monitoring, reporting and supervision oftreatment, 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 assure that minimum

management standards are always applicable. This is necessary to 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 pursuant to 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 order to be binding.

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Seal of Office

Signature

Larry Edelnan

Name (Type or Print)

Assistant Attorney General, State of Oregon

Title

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