A.

PROGRAM DESCRIPTION

Scope. Structure. Coverage. and Processes of State Progn .~

Oregon currently has an operating hazardous waste management

that is equivalent to the federal program promulgated by EPA

April 30, 1985. Additionally, for purposes of authorization,

has adopted all federal regulations promulgated by EPA throug

1987; a non-HSWA regulation promulgated September 9, 1987 (PJI and the federal small quantity generator regulations (HSWA) Po

March 24, 1986. That portion of the state's pr~gram adminisJ

the Department of Environmental Quality (DEQ) is contained iJ

Revised Statutes (ORS) Chapters 466 and 468 and Oregon Admin~I

Rules (OAR) Chapter 340, Divisions 12, 100 through 110 and 12

portion relating to transportation of hazardous was~e by mot1

and rail is administered by the Public Utility Commission (PU

contained in ORS Chapters 484, 756, 761, 767 and OAR Chapter I

Divisions 66 and 46. Both Agencies must comply with the Admi

Procedures Act (ORS 183) and Public Records Law (ORS 192).

\)

A.

B.

C.

D.

E.

F.

G.

Scope

State 

Perm

Forms

Comp

Mani

Gene

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ZB2671 -2.2- Rev.
PROGRAM DESCRIPTION

A. Scope, Structure, Coverage, and Processes of State Program

Oregon currently has an operating hazardous waste management program

that is equivalent to the federal program promulgated by EPA through

April 30, 1985. Additionally, for purposes of authorization, Oregon

has adopted all federal regulations promulgated by EPA through June 30,

1987; a non-HSWA regulation promulgated September 9, 1987 (FR 33936);

and the federal small quantity generator regulations (HSWA) promulgated

March 24, 1986. That portion of the state's program administered by

the Department of Environmental Quality (DEQ) is contained in Oregon

Revised Statutes (ORS) Chapters 466 and 468 and Oregon Administrative

Rules (OAR) Chapter 340, Divisions 12, 100 through 110 and 120. That

portion relating to transportation of hazardous waste by motor carrier

and rail is administered by the Public Utility Commission (PUG) and is

contained in ORS Chapters 484, 756, 761, 767 and OAR Chapter 860,

Divisions 66 and 46. Both Agencies must comply with the Administrative

Procedures Act (ORS 183) and Public Records Law (ORS 192).

ZB2671 -2.2- Rev. 9/22/88
It is noted for the rea>rd that two other oregon agencies have specific

authorities in the area of radioactive waste managenent:

Department of Human Resources

Health Division

Radiation control section

ORS Olapter 453 - Hazardous SUbstances: Radiation sources

OAR Olapter 333

Department of Energy

ORS Olapter 469 - Energy o:mservation

OAR Olapter 345

For wastes which are both dlemi.ca1ly hazardous am radioactive,

radioactive mixed hazardous wastes, .these agencies have regulatory

authorities, as well. '!he DEX;;?'s authority overlaps the authorities of

these agencies.

At this time, the Department has not deteDni.ned the universe of mixed

waste han:ll.ers in Oregon. To detennine the universe of mixed waste

harxllers in oregon, the Department will utiliz.e the follCJWi.IXJ Sources:

1. '!he oregon Health Department l~ of licensees;

2. '!he NRC's lists of licensees;

3. Infonnation on generators shippirg to the low level

disposal facility in Washi.n;Jton (per NW compact); am

4. Info:rmation fram the Department of Energy lists of

licensees.

By D=>cPmber 1989, the Department expects to have deteDni.ned the

universe of mixed waste han:llers.

DEX;;? will assmne a lead agency role in regulatirg mixed waste handlers.

Memorandums of Agreement will be signed to identify interagency

coordination of state proqrams, In the meantime, the Department has

infonnally infonned other state agencies that DEX;;? has jurisdiction

ZB2671 -2.3-
over the hazardous cOIiIlIJl'lellt in a mixed waste stream am by January

1990 will fonnal.ly request the roE am IX>H to Inform the Department if,

duri..rx] oversight activities new mixed waste harrllers are identified or

when violations of the hazardous waste regulations occur.

ZB2671 -2.3a-
The significant provisions of the state program are outlined below (see

the equivalent checklists for a more detailed section by section

analysis):

1. General:

Oregon Administrative Rules adopt by reference all applicable

federal RCRA requirements in 40 CFR Parts 260-266, 270 and Subpart A of 124, promulgated prior to July I, 1986, and additional

requirements promulgated by EPA on July II, 1986, July 14, 1986,

August 6, 1986, August 8, 1986, August 15, 1986, September 22,

1986, October 1, 1986, October 24, 1986, March 19, 1987, April 13,

1987, June 5, 1987, June 22, 1987, and September" 9, 1987 (see OAR

340-100-002). Divisions 12, 100-110 and 120, of OAR

Chapter 340, contain: (1) modifications to the federal RCRA

requirements; and (2) additional state requirements pursuant to

Oregon law.

2. Definition and Waste Classification:

Oregon's statutes" and administrative rules contain definitions for

solid waste and hazardous waste. At this time, these definitions

contain the same categorical exemptions (i.e., domestic sewage,

utility wastes, crude oil and natural gas exploratory wastes,

etc.) that the EPA definitions do, except that the mining

exemption does not include wastes generated during the processing

of ores.

It is the state's opinion that the use of the term "residue" in

ORS 466.005(7)(a) and (b) can be construed to cover all wastes

intended to be covered by EPA's definition in RCRA 1004(27) and

defined in 40 CFR 261.2. Also, it is the state's opinion that the

terms "any process of industry, manufacturing, trade or business

ZB2671 -2.4- Rev. 9/22/88
•

or government or recove.ry of natural resou!ces" in ORS

466.005(7)(b) is equivalent to the use of the terms "industrial,

commercial, mining and agricultural operations and from community

activities" in RCRA 1004(27).

Oregon/s universe of wastes is broader than the federal universe

in some areas. However, the ignitable, corrosive, reactive and EP

toxicity characteristics are identical to the federal program.

ZB2671 -2.5- Rev. 9/22/88
In addition to the P and U listed commercial chemical substances,

the Department also has a rule (OAR 340-101-033) which covers all

other pesticides and pesticide manufacturing residues, based on

aquatic toxicity.

DEQ's listing of specific source wastes (OAR 340-101-032) is more

inclusive than the federal list, in that spent potliner from

primary aluminum reduction is specifically included.

DEQ's listing of commercial chemical substances (OAR 340-101-033)

is more inclusive, in that any other waste having a 3% or greater

concentration of any substance or mixture of substances on the

"P"-list and 10% or greater concentration of any substance or

mixture of substances on the "U"-list is included.

Waste pesticides (excess spray mixture, rinse water, wash waters,

etc.) not covered by the federal rules or by OAR 340-101-033 may

be covered by rules in OAR Chapter 340, Division 109 regarding

pesticide waste management.

In summary, it is the state's opinion that Oregon hazardous waste

definitions and characteristics cover a broader universe of wastes

than do the EPA rules described above. In no case is the state

less inclusive than this federal universe.

Both EPA (40 CFR 260.20 and 260.22) and DEQ (ORS 466.015) and OAR

340-100-020, -021 and -022) have procedures to declassify

substances from their respective hazardous waste characteristics

and/or lists.

ZB2671 - 2.6 -' Rev. 9/22/88
3. Generator Requirements:

OAR 340-100-002 and Division 102 require all generators to manage

their wastes in a manner equivalent to federal standards for

handling, transportation, storage and disposal, including

packaging and labeling according to federal DOT standards.

In addition, OAR 340, Division 109 imposes requirements on

generators of waste pesticide and pesticide containers who may not

be subject to the federal rules.

Oregon has adopted by reference, the March 24, 1986 federal small

quantity generator rules and has allocated two FTE to conduct

inspections. Small quantity generators are identified in their

8700-12 notification and selected for inspection based on waste

types, quantities and other factors such as the probability of

environmental hazards from inadequate operation. Inspection

results are recorded and appropriate enforcement action taken

pursuant to the Department's Enforcement Guidelines. In addition,

the Department has .5 FTE devoted to developing and implementing a

technical assistance/education program for the regulated

community, including small quantity generators. Currently, the

Department is conducting a survey to identify hazardous waste

generators and to register them if they generate greater than 220

Ibs./mo. of hazardous waste. Also, Oregon's rules for hazardous

waste that is used, reused or recycled are equivalent to the

federal RCRA requirements as amended on January 4, 1985,

August 20, 1985, and June 5, 1987.

Oregon rules (OAR 340-102-065) require all generators, except

conditionally-exempt small quantity generators, to pay annual

fees, based upon the amount of waste generated.

OAR 340-102-041 mandates that all registered generators must

submit quarterly reports to the DEQ. The reports must specify the

types and amounts of wastes generated and the final disposition.

In addition, information on waste minimization activities must be

submitted annually. OAR 340-102-045 requires that conditionallyZB2671 -2.7- Rev. 9/22/88
•

4.

5.

exempt generators, who periodically receive an information survey

form from the Department, must complete the form and return it to

the Department.

Oregon rules (OAR 340-102-034) require that generators subject to

the 90-day storage limit, in 40 CFR 262.34 (i.e., generators of

more than 1,000 Kg of hazardous waste or 1 Kg of acute hazardous

waste in a calendar month), must provide secondary containment,

pursuant to 40 CFR 264.175, if storing more than 100 containers.

Also, Oregon has .adopted by reference the July 14, 1986 hazardous

waste storage and treatment tank standards, as amended on

August 15, 1986.

Transporter Requirements:

Transportation of hazardous wastes by motor carrier or rail is

regulated by PUC in a manner equivalent to federal DOT rules (PUC

has adopted DOT rules by reference - see OAR 860 - Divisions 46

and 66). Transportation of hazardous wastes by air or water will

be. regulated by DEQ pursuant to OAR 340-100-002 and OAR 340-

Division 103. Oregon rules are "equivalent to EPA Part 263 rules,

since the latter are adopted by reference.

Owners or Operators of Storage, Treatment and Disposal Facilities:

Owners or operators of hazardous waste storage, treatment and

disposal facilities must obtain a permit from the DEQ. Permits

contain site specific conditions which implement the rules in 40

CFR Part 264 and in OAR 340- Division 104. OAR 340- Divisions 105

and 120 identify permit application and permit content

requirements while Divisions 106 and 120 identify permit issuance

procedures and siting requirements.

Oregon has adopted, by reference, the federal hazardous waste

management facility standards promulgated through July 1, 1986,

and additional federal rules pertaining to management facilities

ZB2671 -2.8- Rev." 9/22/88
v.

•

promulgated on July 11, 1986, July 14, 1986, August 15, 1986,

March 19, 1987, June 22, 1987 and September 9, 1987.

Oregon's management facilities standards are more stringent than

the federal program, as it existed on the dates listed above, in a

number of administrative areas, including but not limited to the

following:

i. OAR 340-105-040 prohibits the transfer of permits;

ii. OAR 340-105-013 requires that Part A of a permit application

include a Land Use Compatibility Statement;

iii. OAR 340-l05-0l0(6)(b) requires that the owner/operator of an

existing management facility with a state-issued, non-RCRA

permit must comply with the conditions of that permit, as

well as with applicable state and federal ,regulations, until

a RCRA permit is issued;

iv. OAR 340-104-143 requires that the owner/operator of a

disposal facility must choose the trust fund option to

establish financial assurance for closure of the facility;

and

OAR 340-l05~110 requires facility owners/operators to pay

annual fees, based upon the design capacity of the facility

'or the amount of waste handled.

Oregon rules are also more stringent or more comprehensive than

the federal rules, as they existed on the dates listed above, in

some technical areas. For example, OAR 340-104-314 prohibits from

being landfilled, liquid wastes and wastes which result from the

soil stabilization of liquid wastes that are hazardous only

because they are listed on the basis of or meet the

characteristic of ignitability (D001). Also, OAR 340-105-020

prohibits the growing of crops intended for direct human

consumption at land treatment sites. EPA allows such crops to be

grown, if certain requirements are met .

• ZB2671 -2.9- Rev. 9/22/88
6. Compliance Monitoring:

Adequate statutory and administrative authorities exist to allow

DEQ and PUC personnel to conduct periodic inspections of all

generators, transporters and management facilities.

In addition to compliance audits, investigations or inspections at

a carrier's home base, PUC's Motor Carrier Division conducts

random driver/equipment compliance inspections at places such as

Ports of Entry, truck weighing stations and at management

facilities.

DEQ conducts periodic inspections of non-generators, generators,

air and water transporters and management faci~ities based on

factors such as waste types, waste quantities, geographically or

environmentally sensitive areas, and probability of serious public

health or environmental hazards due to uncontrolled releases of

hazardous waste.

7. Enforcement:

For violations of motor carrier and rail transporter regulations,

penalties can vary from uniform traffic citations issued by the

Oregon State Police under ORS Chapter 484, to civil penalties

($10,000 per day), criminal penalties ($10,000 per day or year in

jail) or suspension or revocation of operating authority by PUC

under ORS Chapters 756, 761 and 767.

Violation of statutes or rules pertaining to generators, air and

water transporters and management facilities is punishable, upon

conviction, by a fine of not more than $10,000 or imprisonment for

not more than one year or by both. Each day of violation shall be

deemed a separate offense. The enforcement authorities in ORS

756.990, 761.994, 767.993, 466.900, 466.995 and 466.880 and OAR

340-12-068 equal EPA's minimum penalty provisions for final

authorization.

2B2671 -2.10- Rev. 9/22/88
DEQ and PUC:

i. Investigate and provide written response to all citizen

complaints.

ii. Do not oppose intervention by any citizen where permiss~ve

intervention may be authorized by statute, rule, or

regulation.

iii. Publish and provide at least 30 days for public comment on

any proposed settlement of a state enforcement action.

8. Indian Lands

Oregon lacks clear statutory authority to implement a hazardous

regulatory program on Indian Lands. Accordingly, the state

expects EPA to implement RCRA Subtitle "C" regulations on Indian

Lands in Oregon.

9. Underground Injection Wells for Hazardous wastes

Oregon has been delegated primacy for the Underground Injection

Control (UIC) program. Disposal of hazardous via underground

injection wells does not presently occur in Oregon, and is

essentially prohibited by OAR 340-44-015. Any disposal that did

occur would be regulated by the DEQ.

ZB2671 -2.11- Rev. 9/22/88
B. State Agency(ies) Organization and Structure

The DEQ and PUC are the executive branch agencies responsible for

administration of the State's hazardous waste management program. DEQ

is responsible for regulating and insuring compliance "by generators,

air and water transporters, owners and operators of management

facilities and coordination with EPA. PUC is responsible for

regulating and insuring compliance by motor carrier and rail

transporters. Appendix A of this section is the Memorandum of

Understanding outlining each agency's role in administration of the

state hazardous waste program.

Chart 1 is an organizational chart for the DEQ. As an executive branch

agency, the Governor is ultimately responsible for DEQ's administration

of the hazardous waste program. The Governor appoints the EQC, a

5~member lay commission who set policy and adopt administrative rules.

The Commission appoints the Director who is responsible fo~ program

implementation. The Hazardous Waste Section is located within the

Department's Hazardous and Solid Waste Division and is responsible for

establishing goals and objectives, budgeting, drafting rules, issuing

permits, training, technical assistance and inspection of management

facilities. The DEQ's region and branch offices are responsible for

program implementation, including inspecting generators and air and

water transporters, compliance monitoring, enforcement, complaint

investigation and emergency spill response. The Laboratory D~vision is

responsible for environmental monitoring, sample analysis and data

interpretation. To ensure actions of the Department are not subject to

procedural challenges, the Department has established an authorized

signatures list (see Appendix B of this section) that

2B267l -2.12- Rev. 9/22/88
supplements the language in ORS 466 and 468. Signature decisions

represented by I, 2, 5, 7, 11, 13, 16, 17, 18 and 21 are most directly

applicable to hazardous waste program.

Chart 2 is an organizational chart for the PUC. As an executive branch

agency, the Governor is ultimately responsible for PUC's administration

of the hazardous waste transportation program. The Governor appoints

the 3-member Public Utility Commission who are responsible for setting

policy and adopting administrative rules. The Assistant Commissioner

for the Transportation Program is responsible for program development

and implementation concerning motor vehicle and rail transportation of

hazardous waste. Inspections, compliance audits, enforcement,

complaint investigations and emergency spill response are handled by

the Motor Safety Division and Rail Safety Division.

Chart 3 is a description of the DEQ and PUC staff currently assigned to

administer the state's hazardous waste program.

In addition, the 1985 Oregon Legislative Assembly created a Hazardous

Material Emergency Response Fund which includes staffing in DEQ to

handle most of the oil and hazardous spill reporting and response

program now handled by the DEQ Hazardous Waste and Enforcement

Sections. The legislature also significantly increased PUC resources

to inspect hazardous material and waste transporters.

PUC appears to have adequate resources to meet their annual commitments

to the program.

ZB2671 -2.13- Rev. 9/22/88
e

DEPARTMENT OF ENVIRONMENTAL

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Public Utility Commissioner

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Safety Division

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Chart 2
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Administrative Support

Staff

Administrator

Hazardous and

Solid Waste Division

Management

Assistants

!'l

.....

0'\ Manager

Hazardous Waste Section

Clerical Specialist

Word Processing

Specialist

Environmental

Supervisor

-

Chart 3

Resources Committed to Oregon's

Hazardous Waste Management Program

Duties.

Goals and objectives setting, strategy and policy

setting, budgeting, coordination with other DEQ

programs, coordination with EPA, and coordination

with Attorney General.

Receptionist; supervise and/or arrange for typing,

filing, appointments; assist with budget preparation.

Personnel supervision (work plans, performance

appraisals); coordination wi~h other local, state

and federal agencies, including EPA and DEQ regional

offices; preparation of permits, fact sheets,

compliance reports.

Receptionist; typing; assist with gerierators and

TSDF reports and records maintenance and review;

manifest review, data systems support.

Typing of letters, permits, fact sheets, memos, charts,'

reports, etc.

Program planning and budgeting; training coordinator

data base coordinator, rule development; Administration;

Grant Development.

FTE

0.40

0.50

1.00

1.00

0.40

1.00

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Administrative Support

Staff

Hazardous Waste

Specialist

Hazardous Waste

Specialist

Data Entry Clerk

Administrator

Laboratories Division

Administrator

Regional Operations

Division

-

Chart 3 (continued)

Resources Committed to Oregon's

Hazardous Waste Management Program

Duties

Fee tracking, budget tracking, permit tracking including

preparation of reports and charts. Generator registration

and assistance.

Follow-up on generator inspections and enforcement;

compliance and enforcement reporting to EPA;

assistance to permitting staff on an as-needed basis;

generator registration and teqhnical assistance to

regulated community, public, DEQ and other agency

staff.

Enter generator quarterly repprts, monthly TSDF

reports, inspection and enforcement reports and

other hazardous waste management data into computer

files. Produce data reports from computer files.

Laboratory Management; coordination with other state

and federal labs;.personnel supervision.

Regional goals and objectives setting, strategy

and policy setting; budgeting; coordination between

programs and regions and management of enforcement

actions.

FTE

1.00

1.00

1.00

0.05

0.05

e
i')

00

e

Administrative Support

Staff

Public Information

Offtcer

Hearings Officer

Senior Environmental

Analyst

Technical Support - DEQ

Senior Environmental

Engineers

e

Resources Committed to Oregon's

Hazardous Waste Management Program

Duties

Develop and implement public participation for rule

making, permit issuance, goals and objectives

setting, budget, and grant applications. Develop and

publish fact sheets, reports, newsletters, slide/tape

show, posters, etc. to assist regulated community,

public, other agencies and DEQ staff to understand

hazardous waste management program.

Conducts contested case hearings for EQC and

reports findings, conducts rulemaking hearings

or permit hearings for Department and prepares

hearings officers' report. .

Prepare applications for program revisions; rule

development; technical assistance to regulated

community, public and DEQ staff.

Issuance of disposal permits (landfills, surface

impoundments and waste piles); plan reviews for

management facilities; Arlington disposal site

compliance inspections and enforcement follow-up.

FTE

0.50

Available

as needed

1.00

3.00

e
""

e

Technical Support - DEQ

Staff

Permitting Supervisor

Environmental

Analyst

Environmental

Engineers

Hazardous Waste

Specialists --

Regional Offices

, Chemist

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Chart 3 (continued)

Resources Committed to Oregon's

Hazardous Waste Management Program

Duties

Supervises facility permitting and inspection.

Storage facility permitting and inspection;

generator compliance with manifest.

Facility permitting and inspection; review for

approval/denial disposal request for use of Arlington

disposal site.

Generator compliance inspections, enforcement, complaint

investigations, emergency spi~l response; assist with

permit drafting on request; and technical assistance

to regulated community, public and other state agency

staff.

Environmental monitoring 'at storage, treatment and

disposal sites; laboratory analytical work and data

analysis; emergency spill response, technical

assistance to regulated community, public and DEQ

and other state agency staff..

FTE

1.00

1.00

3.00

11. 00*

2.45

e

*Two FTEs are devoted to SQG inspectio~s.

*Three FTEs are devoted to Spill Response.
e

Technical Support - DEQ

Staff

Hydrogeologist '

Environmental

Specialist

Technical Support - PUC

o

Motor Carrier & Rail

Safety Specialist

---

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Chart 3 (continued)

Resqurces Committed to Oregon's

Hazardous Waste Management Program

Duties

Review groundwater monitoring programs and plans

for compliance with Part 265 Subpart F, Part B

permit conditions, or Part 270 permit application

requirements; assist in conduct of inspections of

groundwater monitoring programs.

Prepare enforcement documents and actions based

upon case referrals.

Conducts motor and rail transporter inspections,

including compliance with manifest requirements;

conducts random vehicle transporter inspections,

including compliance with hazardous waste rules; ,

complaint investigation; enforcement; provide

technical assistance to motor carriers and railroads;

investigates hazardous material/waste 'incidents;

and technical assistance to regulated community,

public and DEQ and other state agency staff.

FTE

1.00

'1.90

1.00

e
e

Technical Support - Department of Justice

Staff

e

Chart 3 (continued)

Resources Committed to Oregon's

Hazardous Waste Management Program

Dutii es ' FTE

e

Assistant Attorney

Generals

Law Clerk

Advice and counsel on statute~, rules,

administrative policies and procedures,

enforcement orders and civil penalty'

assessments; represents Department when

contested case hearings are requested on

permit actions, enforcement orders or

civil penalty assessments.

1.2

Technical Support - Water Resources Department

N

N

t-' Staff

Hydrogeologist

Duties

Advice to Department on geology, hydrology,

monitoring well construction, compliance

of groundwater monitoring program with

Subpart F requirements.

FTE

Available

as needed

up to 1.0
e

Technical Support - County District Attorney

Staff

e

Chart 3 (continued)

Resources Committed to Oregon's

Hazardous Waste Management Program

Duties FTE

e

N

N

N

District Attorney

and/or staff

ZB2671.TCl

Official in Oregon responsible for filing

criminal enforcement actIons. Advice and

counsel to Department on evidence gathering,

case documentation, subpoenas, witness

preparation and plea bargaining.

Available

as needed
At this time, DEQ does not plan to utilize EPA contractor assistance, except in

the area of training for compliance with Subpart F requirements and the land ban

requirements and inspections. DEQ also expects to make occasional referrals of

criminal enforcement actions to EPA's criminal enforcement section.

C. Permitting and State Appellate Review Procedures

ORS 466.095 and 466.100 provide that no person shall store (storage beyond

specified time periods in the case of a generator), treat or dispose of

hazardous waste, except at a permitted hazardous waste management facility.

These statutes further provide that no person shall establish, construct or

operate a hazardous waste management facility without a permit.

Oregon has adopted by reference the permitting standards in 40 CFR Part

264, promulgated prior "to May 1, 1985, and those standards promulgated on

May 2, 1986 and July 11, 1986. Additional state permitting requirements are

included in OAR Chapter 340, Division 104. These standards are used to develop

management facility permits. Compliance with a management facility permit is

deemed to be compliance with the hazardous waste rules.

OAR 340, Divisions 105 and 120 contain the permit application a~d permit content

provisions, which are in addition to those in 40 CFR part 270.

OAR 340, Divisions 106 and 120 identify the permit issuance procedures that are

in addition to the permitting provisions of the federal program. For all permit

actions, a draft permit, fact sheet or statement of basis, public notice and

Response to Comments are prepared. Following preparation, the draft

permit, fact sheet and public notice are mailed to the applicant for

ZB2671.A -2.23- Rev. 4/27/88
review and comment. The applicant has 14 days to submit written comments,

if his comments are to receive consideration prior to further action on the

application.

Following applicant review, public notice is sent to news media (newspaper,

radio,TV) in the area affected, as well as to persons on a mailing list

maintained by the Department. Forty-five (45) days is provided for public

review. Appendix C of this section contains copies of the public notice

mailing lists used for a hazardous waste permitting activity. The

Department will cause (i.e., pay for) notice to be published in one newspaper

of general circulation and be aired on at least one radio station, for all

permit actions requiring notice.

In the case of proposed action on a disposal site permit application, a public

hearing is required to be held, in the county pr counties where the hazardous

waste disposal site is proposed to be located, and may be held at such other

places as the Department considers suitable (ORS 466.130). A 30-day public

notice of the hearing will be provided.

It should also be noted that, in the case of disposal site applications,

other affected state agencies shall receive copies of the application

(Health Division, PUC, Fish and Wildlife, and Water Resources) and that the

Health Division can cause a permit to be denied (ORS 466.135).

Informal public hearings on proposed storage or treatment site permits will

be held, if an "interested person" makes a written request during the 45-day

public notice period. An "interested person" is defined as one who would

ZB2671.A -2.24- Rev. 4/27/88
e·

be able to appeal a permit action under 7006(b) of RCRA. If public

hearings are held on proposed storage or treatment site permits. a 30-day

public notice period will be provided.

OAR 340. Divisions 106 and 120 also identify the procedures to be followed

during permit renewals, modifications, suspensions or revocations.

Oregon rules allow DEQ to modify a permit, to incorporate newly promulgated

requirements subsequent to permit issuance, without requiring the permittee

to make a request for such action.

Should any permit application be denied, such denial action is appealable

to the Environmental Quality Commission (ORS 466.140 and 466.145) and then

subject to judicial review, according to the administrative procedures and rules

of state agencies in ORS Chapter 183 (see statutes and rules Section 6).

ZB2671.A -2.25- Rev. 4/27/88
In summary, it is the state's opinion that DEQ's permit-issuing authorities

are equivalent to EPA's and provide reasonable opportunities for the applicant

and the public to comment on the proposed permit conditions.

O. Forms

DEQ and PUC are using EPA's notification form 8700-12. DEQ also uses EPA's Part

A permit application form 8700-13. Like EPA, DEQ has not designed a Part B

permit application form. Rather, the DEQ specifies the information to be

submitted. One State-only permit application requirement is submission of a land

use compatibility statement (see Appendix D of this section).

DEQ requires use of the uniform national manifest, as promulgated by EPA and

DOT, and requires additional information be included on the manifest (see

OAR 340-102-060). Oregon does not supply a state manifest form.

Generators and storage, treatment and disposal facilities are required to

submit periodic reports on their activities. On a calendar quarter basis,

.generators must submit copies of their manifests and other information

describing the type and amount of waste generated and its disposition

(see OAR 340-102-041). Manifest exception reporting is also required. On a

calendar quarter basis, permitted treaters and storers are required to submit the

information req~ired by OAR 340-104-075, on a form approved by DEQ. On a

monthly basis, permitted disposal facilities shall submit the information

required by OAR 340-104-075, on an approved form. In addition, management

facilities must submit periodic reports on unmanifested waste receipts, accidents

and facility closures, as specified in 40 CFR 264 and 265.

ZB2671.A -2.26- Rev. 4/27/8~
headquarters staff person assigned to prepare the monthly compliance and

enforcement log submitted to EPA. This headquarters person also prepares a

monthly non-compliance log which is circulated back to the regions staff to

ensure enforcement followup.

All DEQ inspectors have either bachelor of engineering (civil, chemical or

environmental) or science degrees (biology, chemistry or physics). Most

have been employed as inspectors in one or more environmental programs for

3 to 10 years. Because of the complexity of the hazardous waste rules,

frequent in-house training sessions are held (see Appendix I of this

section). DEQ staff also participate in EPA-sponsored training and courses

offered by professional and trade organizations (see Appendix J). Training

for those staff involved with hazardous waste work is expected to occur two

to three times.pe~ year.

Using the authorities in ORS 466.185 through 466.210; 466.995, 466.880,

468.125 through 468.140 to support its compliance inspection and

environmental monitoring programs for generators, air and water

transporters, and management facilities, DEQ's enforcement options in

response to violations of hazardous waste statutes, rules, or permit

conditions include the the following:

i. Notice of violation

ii. Notice of violation with intent to assess civil penalty

iii. Assessment of civil penalty

ZB267l.A -2.30- Rev. 4/27/88
type of waste transported and previous compliance and safety records. PUC

provides DEQ with copies of completed inspections which are then reported

to EPA on the monthly compliance and enforcement log. If either DEQ or PUC

observes violations that are more appropriately the responsibility of the

other, that information is immediately transmitted verbally or in writing

between Paul Henry (PUC) and Jan Whitworth (DEQ) for follow up.

An examination of ORS 466.995,466.880, 756.990, 761.994, and 767.993

identifies adequate levels of civil or criminal remedies to meet the

minimum requirements for final authorization. Pursuant to ORS 468.125 and

OAR 340-12-040, no advance notice is required to be issued by DEQ prior to

assessing civil penalties for hazardous waste program violations. OAR 340-12-068

contains a Hazardous Waste Management Schedule of Civil Penalties.

Lastly, ·whi1e Oregon is not in a position to allow citizen intervention as

a right in any. state enforcement action brought in a court of the State of

Oregon it will:

i. Investigate and provide written response to all citizen

complaints duly submitted;

ii. Not oppose intervention by any citizen in an enforcement action

brought in a court of the State of Oregon where permissive

intervention may be authorized by statute or rule; and

iii. Publish notice of and provide at least 30 days for public

comment on any proposed settlement of a state enforcement action

brought in a court of the State of Oregon.

ZB2671.A -2.33- Rev. 4/27/88
G. Generators. Transporters and Management Facilities

1. Total Number of Generators registered with DEO 1,848

2. Small guantity. including conditionally-exempt,

generators registered with DEO. 1,022

3. Transporters registered with PUC 234

4. Treatment. Storage and Disposal Facilities 28

e·

Facility Address

Chern-Security Systems, Inc.

Arlington, OR 97812

ORO 089452353

Baron-Blakeslee

Division of Purex Corp.

5920 N.E. 87th

Portland, OR 97220

ORO 061483384

Van Waters & Rogers

Division of UNIVAR

3950 N.W. Yeon Avenue

Portland, OR 97210

ORO 009227398

ZB2671.A

Activity

Disposal trenches,

evaporation ponds,

storage buildings,

liquids solidification.

Storage and treatment.

Storage and treatment.

- 2.35 -

Status

State permit issued. t

State permit issued

Part B called.

Closing.

Rev. 9/26/88
Facility Address

Van Waters & Rogers

Division of UNIVAR

4488 N.W. Yeon Avenue

Portland, OR 97210

ORD 049799232

Tektronix, Inc.

Tektronix Industrial Park

Beaverton, OR 97077

ORD 009020231

.u.s. Army

Umatilla Depot Activiey

Hermiston, OR 97838

ORD 621382917

Safety-Kleen Corp.

550 Sh~lley Street

Springfield, OR

ORD 00712067

Safety-Kleen Corp.

11843 S.E. Highway 212

Clackamas, OR 97015

ORD 092895481

ZB2671.A

Activity

Storage.

Storage and disposal.

Storage, treatment

and incineration.

Storage.

Storage.

- 2.36 -

Status

Part B called.

State permit issued.

Part B called, postclosure permit pending.

Storage permit. issued.

Part B permit

application called.

Part B application

submitted.

State permit issued.

Part A filed.

Part B under review.

Part B submitted

voluntarily.

Rev. 9/26/88
!e

Facility Address

Permapost Products

25600 S.W. TV Highway

Hillsboro, OR 97123

ORD 009041187

Evanite Battery Separator

1115 S.E. Crystal Lake Dr.

Corvallis, OR 97339

ORD 009023466

Oregon Regional Primate

Center

505 N.W. l85th Avenue

Beaverton, OR 97006

ORD 054263595

Western Compliance,

Services, Inc.

11330 S.W. Clay Street

Tualatin, OR 97062

ORD 009049198

Activity

Closed surface

impoundments.

Closed landfill.

Incineration.

Storage.

Status

Post-closure permit

to be issued early

1989.

Post-closure permit

to be issued early

1989.

Permit status being

reviewed. Part B

called.

Part A filed.

PartB being reviewed

by DEQ & EPA.

Environmental Pacific Corp. Storage and recycling. Part A filed.

111 West Fourth Street Part B called.

Amity, OR 97101

e ORD 980977334

ZB2671.A - 2.37 - Rev. 9/26/88
e Facility Address

Bergsoe Metals Corp.

444 Port Avenue

St. Helens, OR 97051

ORD 991281460

Columbia Helicopters Inc.

Activity

Disposal.

Disposal.

Status

In bankruptcy. Closure

in litigation.

Part A called. Consent

P.O. Box 3500 order being negotiated.

Portland, OR 97208

ORD 009673609

Arnav

4740 Ridge Drive N.E.

Salem, OR 97303

ORD 106072010

Velco

3900 W. 1st Avenue

Eugene, OR 97402

ORD 009414400

Montezuma West

11884 Ehler Road N.E.

Aurora, OR 97002

ORD 044113827

ZB2671.A

Disposal.

Storage.

Disposat.

- 2.38 -

Site cleanup progressing.

Status being reviewed.

Site cleanup progressing.

Rev. 9/26/88
Facility Address

Great Western Chemical

808 S.W. 15th Avenue

Portland, OR 97205

ORD 980981278

City of Madras

416 6th Street

Madras, OR 97741

ORD 025919739

Western Farm Service

(Athena)

1st & Sherman Road

Athena, OR 97813

ORD 095001731

Activity

Storage.

Disposal.

Storage.

Status

Facility status being

reviewed.

Facility status being

reviewed.

Facility status being

reviewed.

Mew Data Arms Disposal.

1120 Spring Street

Klamath Falls, OR 97601

ORD 034595355

Facility status being

reviewed.

Potter Manufacturing

415 River Road

Eugene, OR 97404

ORD 009049545

ZB2671.A

Disposal.

- 2.39 -

Facility status being

reviewed.

Rev. 9/26/88
Facility Address

Riedel Environmental Servo

N. Portsmouth Avenue

Portland, OR 97208

ORD 980980023

Martin Marietta

3313 West 2nd Street

The Dalles, OR 97058

ORD 052221025

Technical Images

2206 Mt. View Drive

Newberg, OR 97132

ORD 009414673

Transco Northwest Inc.

5530 N.E. l22nd Blvd.

Portland, OR 97220

ORD 009020298

Valley Plating Building

3905 W. 12th Avenue

Eugene, OR 97402

ORD 052227568

Cascade Wood Products

14th and H Street

White City, OR 97503

ORD 092894351

ZB2671.A

Activity

Disposal.

Storage.

Storage.

Waste pile.

Disposal.

Disposal.

- 2.40 -

Status

Closing.

Permit issued.

. Closing.

In bankruptcy.

Facility being

reviewed.

Facility status being

reviewed.

Facility status being

reviewed.

Rev. 9/26/88
1.

Appendix B

DEPARTMENT OF ENVIRONMENTAL QUALITY

SIGNATURE AUTHORIZATIONS

Issuance, renewal and modification of the following: National

Pollutant Discharge Elimination System (NPDES) Permits; Water

Pollution Control Facilities Permits; Air Contaminant Discharge

Permits; Indirect Source Construction Permits; and Solid Waste

Disposal Site Permits; and Hazardous Waste Storage and Treatment

Permits:

FRED HANSEN

MICHAEL J. DOWNS

2. Issuance, renewal and modification of Hazardous Waste Disposal

Permits:

GENEVIEVE P. SAGE

EMERY N. CASTLE

WALLACE B. BRILL

WILLIAM W. WESSINGER

WILLIAM P. HUTCHISON, JR.

FRED HANSEN

MICHAEL J. DOWNS

3.

4.

Notices of Intent to Suspend Sewage Disposal Service Licenses:

FRED HANSEN

MICHAEL J. DOWNS

SHERMAN O. OLSON Jr.

HAROLD L. SAWYER

Federal Sewage Works Construction Grant Priority Certificates:

FRED HANSEN

MICHAEL J. DOWNS

5. Agency Allotment Plans:

FRED HANSEN

MICHAEL J. DOWNS

LYDIA R. TAYLOR

6. Pollution Control Bond, Grant and Loan Agreements:

FRED HANSEN

MICHAEL J. DOWNS

LYDIA R. TAYLOR

MK266.A

September 21, 1988

- 1 -
DEPARTMENT OF ENVIRONMENTAL QUALITY

SIGNATURE AUTHORIZATIONS

7. Draw on Federal grant through a letter of credit. Anyone of the

follOWing:

FRED HANSEN

JUDITH L. HATTON

LYDIA R. TAYLOR

8. Revolving Fund Checks:

FRED HANSEN

MICHAEL J. DOWNS

JUDITH L. HATTON

LYDIA R. TAYLOR

JOHN RIST

9. Central Stores Orders; Purchase Requests; Purchase Orders; Contract

Release Orders; Property Disposition Requests; Telephone Service

Orders; Claims against Restoration Fund; Restoration Fund

Classification; Space Request Forms, Printing Order and Data Sheets;

and Copy Center Work Orders:

FRED HANSEN

LYDIA R. TAYLOR

JUDITH L. HATTON

ROY L. FRITZLER

10. Sign for and request permanently assigned vehicles or other motor

pool services from Portland Motor Pool, Eugene Motor Pool, and Salem

Motor Pool:

FRED HANSEN

LYDIA R. TAYLOR

JUDITH L. HATTON

ROY L. FRITZLER

lOA. Sign for and request motor pool trip tickets from the Salem Motor Pool:

LYDIA R. TAYLOR

ROY L. FRITZLER

DAVE ST. LOUIS

MK266.A

September 21, 1988

- 2 -
DEPARTMENT OF ENVIRONMENTAL QUALITY

SIGNATURE AUTHORIZATIONS

lOB. Sign for and request motor pool trip tickets from the Portland Motor

Pool:

FRED HANSEN

LYDIA R. TAYLOR

JUDITH L. HATTON

ROY L. FRITZLER

lOCo Sign for and request trip tickets from Eugene Motor Pool:

LYDIA R. TAYLOR

ROY L. FRITZLER

DAVE ST. LOUIS

11. Written Notice of Violations Subject to Civil Penalty:

FRED HANSEN

MICHAEL J. DOWNS

THOMAS R. BISPHAM

VAN A. KOLLIAS

12. Approve State Claims (a voucher):

FRED HANSEN

LYDIA R. TAYLOR

JUDITH L. HATTON

JOHN RIST

13. Agreements, Contracts and Leases:

FRED HANSEN

MICHAEL J. DOWNS

JUDITH L. HATTON

LYDIA R. TAYLOR

14. Actions relating to Subsurface Sewage Disposal Systems:

FRED HANSEN

MICHAEL J. DOWNS

THOMAS R. BISPHAM

MK266.A

September 21, 1988

- 3 -
DEPARTMENT OF ENVIRONMENTAL QUALITY

SIGNATURE AUTHORIZATIONS

15. Findings of Fact, Conclusions of Law, and Final Orders related to

a Default subsequent to Notice of Intent to Suspend Sewage Disposal

Service License and Opportunity for Hearing:

FRED HANSEN

MICHAEL J. DOWNS

THOMAS R. BISPHAM

16. Notices of Civil Penalty Assessments; Findings of Fact, Conclusions

of Law, and Final Orders relative to defaults on civil penalty

assessments; time extensions to the parties in a contested case

hearing to file written exception and arguments to a Proposed Final

Order pursuant to OAR 340-11-132(4):

FRED HANSEN

MICHAEL J. DOWNS

17. Authorized representative to accept filing of documents in contested

case matters pursuant to OAR 330-11-005(5) and (6):

LINDA K. ZUCKER

18. Appointing authority:

FRED HANSEN

MICHAEL J. DOWNS

DONNY R. ADAIR

19. Deposit or withdraw funds from U.S. Bank Safekeeping Account

#000-297-0 and Checking Account #010-0300-425. Any two of the

following:

FRED HANSEN

JUDITH L. HATTON

LYDIA R. TAYLOR

20. Authorized to sign Service Order Requests in excess of $10,000:

FRED HANSEN

MICHAEL J. DOWNS

MK266.A

September 21, 1988

- 4 -
21.

DEPARTMENT OF ENVIRONMENTAL QUALITY

SIGNATURE AUTHORIZATIONS

Certificate and Order for Filing Administrative Rules with the

Secretary of State; applies to both permanent and temporary

(emergency) rules:

FRED HANSEN

MICHAEL J. DOWNS

LINDA K. ZUCKER

CHRISTIE NUTTALL

MICHAEL HUSTON

22. Salary advances:

FRED HANSEN

MICHAEL J. DOWNS

JUDITH L. HATTON

LYDIA R. TAYLOR

23. Access to U.S. Bank safe deposit box:

FRED HANSEN

JUDITH L. HATTON e LYDIA R. TAYLOR

24. Department contact for Worker's Compensation matters:

JOHN H. LOEWY

MK266.A

September 21, 1988

- 5 -
ADDR40.R Address List

AP.ffNJUXC- '1"5" JUL 88 Page 1

BENTON BULLETIN

Box 351

Philomath, OR 97370

county - -

x

x

On 01-JAN-Ol

'P-tl'M

75745 Updated By Jacquard MEDIA

PA:PGE SSL

MEDIA: PAL

75815 Update~ On Ol-JAN-Ol

By Jacquard "i:)

MEDIA r

Updated on 99-XXX-99

By xxxxxxxxxxxxxxxxxxxx

Ke ord

K ord

yword

eyword.

Keyword

Keyword

Keyword

Keyword

75817 Updated On Ol-JAN-Ol

By Jacquard MEDIA r

AQ:PN BAKER

75997 Updated On Ol-JAN-Ol

By Jacquard MEDIA . AQ:PN BENT

80687 Updated On l5~JUL-88

By Meissel

PA:BERGSOE

PA:LEGIS TRACK

PA:PLANET . MEDIA

75814 Updated On 01-JAN-01

By Jacquard MEDIA

75746 Updated On 01-JAN-01 . By Jacquard. . MEDIA

~~bi~7 pllL 1> or PM

PA:RECY NEWS

MHALPH

AQ:PN INDIV

AQ:PN MULT

WQ:PN

SWCG:PR LIST

WQ:PN STATE

75816 Updated On 01-JAN-Ol

By Jacquard MEDIA

97123

Suite 540

97258-2006

Holly Duncan

Adler & Blount

1 SW Columbia, Portland, OR

county - -

APPEAL':TRIBUNE

Box 35

Silverton, OR 97381

county - -

ARGUS

Box 29

Hillsboro, OR

county - -

Name

Title

Organization

SUDorganization

Address 1

Address 2

City, State Zip Country

County

Phone 1

Phone 2

Tom Donaca

Association of Oregon Industries

PO Box 12519

Salem, OR 97309

county - -

BAKER DEaOCRAT-HERALD

Box 807

Baker, OR 97814

county· -

ARGUS OBSERVER

Box 130

Ontario, OR 97914

county - -

ASSOCIATED PRESS

.1320 SW Broadway Portland, OR· 97201

county
ADDR40.R Address List 15 JUL 88 Page 2

d

an ace Brill

196 Century Way Medford, OR 97504 . county - -

En.,,·,rOl'\MudcJ. &u.cUi~CeMmi~;~

BROWNSVILLE TIMES

Box 278

Brownsville, OR 97327

county - -

CAPITAL PRESS

Box 2048

Salem, OR 97058

county - -

75510 Updated On 01-JAN-01

By Jacquard OD:EQC AGENDA

~~:N :::::ed On Ol-JAN-Ol

acquard

M

OD:EQC DIA AGENDA 1)r rt r

OM

MHALPH

AQ:PN INDIV

PA:PLANET

75818 Updated On 01-JAN-Ol

By Jacquard MEDIA

75819 Updated On Ol-JAN-Ol

By Jacquard 'D

MEDIA r

»:

x.

x

75820 Updated On Ol-JAN-01

By Jacquard MEDIA

75823 Updated On 01-JAN-Ol

By Jacquard p MEDIA

WQ:401 CERT

75822 Updated On 01-JAN-01

By Jacquard MEDIA

CHRONICLE

Box 902

The Dalles, OR 97058

county - -

CHRONICLE

Box 428

Creswell, OR 97426

county - -

CENTRAL OREGONIAN

558 N Hain

Prineville, OR 97754

county - -

uS te ce Beilu Editor P - 75821 Updated On Ol-JAN-Ol

~Z~~~L ~ttteEY4JiESse g~ $t. ~tDi:cq~ard -6cut!'al PoiM! I OR 97iQ2- MEDIA:VIP MEDFORD

county - - ~-ts 1Q.SSJ Ota. cn52-lo- ?>b20

CHRONICLE.. 75747 Updated On 01-JAN-01

Box 1153 By Jacquard . St. Helens, OR 97051 MEDIA·

county - -

CLACKAMAS COUNTY NEWS

Box 549

Estacada, OR 97023

county - -

CLATSKANIE CHIEF

Box 8

Clatskanie, OR 97016

county - -

75748 Updated On 01-JAN-Ol

By Jacquard MEDIA

PA:PGE SSL

75749 Updated On Ol-JAN-Ol

By Jacquard MEDIA

COLUHBIA PRESS

Box 130

Warrenton, OR 97146

county - -

75824 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN CLAT

"
ADDR40.R Address List 15 JUL 88 Page 3

97467

1_

Linn-Benton Community College COM.HUTER

6500 SW Pacific Blvd.

Albany, OR 97321

county - -

Corvallis Gazette-Times k All Cof5 Box 368

Corvallis, OR 97339

county - -

COTTAGE GROVE SENTINEL

Box 35

Cottage Grove, OR 97424

county - -

COURIER

Box 268

Reedsport, OR

county - -

CURRY COASTAL PILOT

Box 700

Brookings, OR 97415

county - -

Curry County Reporter -e:AI \ ~~ 518 NecrElai Ellezisburg Aveiiue IP.O.Box 766

Gold Beach, OR 97444

Curry county - 8 -

(503) 247-6643

DAILY ASTORIAN Box 210 .

Astoria, OR 97103

-oountry - -

DAILY BAROMETER

Memorial Union EastA #105

Corvallis, OR 973~1

county - -

Portland Business Today DAILY JOURNAL OF COMMERCE

Box 10127

Portland, OR 97210

county - -

DAILY TIDINGS

Box 7

Ashland, OR 97520

county - -

DEAD MT. ECHO

Box 900

Oakridge, OR 97463

county - -

DEMOCRAT-HERALD

Box 130

Albany, OR 97321

county - -

75987 Updated On Ol-JAN-01

By Jacquard MEDIA

75538 Updated On Ol-JAN-Ol

By Jacquard OD:EQC AGENDA

MEDIA

75826 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75827 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN DOUG

75828 Updated On Ol-JAN-Ol

By Jacquard MEDIA_

34870 Updated On 22-MAR-88

By Meissel

UST:DENT

MHALPH

MEDIA

75830 Updated On Ol-JAN-Ol

By Jacquard MEDIA . AQ:PN CLAT

75831 Updated On Ol-JAN-Ol

By Jacquard' MEDIA

75750 Updated On Ol-JAN-Ol

By Jacquard MEDIA

PA:PGE SSL

MEDIA: PAL

75832 Updated On Ol-J~-Ol

By Jacquard MEDIA

MEDIA:VIP MEDFORD

AQ:PN JACK

75833 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75834 Updated On 01-JAN-01

By Jacquard MEDIA

WQ:401 CERT

x
15 JUL 88 Page 4

On Ol-JAN-Ol )(

On 01-JAN-Ol

ADDR40.R

DOUNTmmER

Box 4227

Portland, OR 97208

county - -

NevIS Director

EAGLE POINT INDEPENDENT

PO Box 900

Eagle Point, OR 97524

county - -

EAST OREGONIAN

Box 1089

Pendleton, OR 97801

county - -

ENTERPRISE

Box 26

Drain, OR 97435

county - -

ENTERPRISE

Box 348

Mill City, OR 97360

county - -

ENTERPRISE-COURIER

Box 471

Oregon City, OR 97045

county - -

James E.

Address List

75742 Updated

nI) By Jacquard

rA~1>~.f"MEDIA

oJ~O Yf'-

75751 Updated By Jacquard MEDIA

PA:PGE SSL

AQ:PN MULT

75835 Updated On 01-JAN-Ol

By Jacquard . MEDIA

WQ:PN

WQ:PN JACK

75836 Updated On 01-JAN-Ol

By Jacquard . MEDIA

MEDIA: PAL

WQ:401 CERT

75837. Updated On 01~JAN-Ol By Jacquard MEDIA

AQ:PN DOUG

75838 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN BENT

75752 Updated On 01-JAN-Ol

By Jacquard MEDIA

MEDIA:VIP 'M:~BFe~ J>.b~ AQ:PN MULT

79419 ~tedn 01-JAN-Ol· By Jacqua d

MEDIA

x

YBob Jacobson6 Press Officer

EPA Region 1

1200 Sl.xth Ave.

Seattle, UA 98101

county - -

GATE CITY JOURNAL

Box 1786

Nyssa, OR 97913

county - -

Gail Achterman

Governor's Office

160 State Capitol Salem, OR 97310

county

75753 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75839 Updated·On Ol-JAN-Ol

By Jacquard MEDIA

75738 Updated On 01-JAN-Ol

By Jacquard MEDIA

M€"bl:A x
ADDR40.R Address List 15 JUL 88 Page 5

97132

Floyd McKay Governor's Office

160 State Capitol Salem, OR 97310

county - -

GRAlJTS PASS COURIER

Box 1468

Grants Pass, OR 97526

county - -

GRAPHIC

Box 110

Newberg, OR

county - -

75739 Updated On 01-JAN-01

By Jacquard MEDIA

75840 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN JOSE

75841 Updated On 01-JAN-01

By Jacquard MEDIA

HEADLIGHT HERALD

·Box 232

. Tillamook, OR 97141

county - -

HERALD

Box 250

Canby, OR 97013

county

HERALD

Box 46

Hermiston, OR

county - - 97838

75842 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75754 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN"MULT

75844 Updated On 01-JAN-01

By Jacquard !'lEDIA

HOOD RIVER NEWS "2lJD

489 (;lith St. :50)'0 \J1

Hood River, OR 97031

cO':ffity - -

ILLINOIS VALLEY NEWS

Box "M"

Cave Junction, OR 97523

county - -

News Director

K103

12655 S\.] Center

Beaverton, OR 97005

county - -

KAAR Rad~. -". \ Q.;-\Q.J <, 5411 E. HI Plain Blvd. ~1J-.L,f\.) Vancouver, 98661 1~~~~LP\v county - - U~ .......

KACI

Box 516

The Dalles, OR 97058

county

HERALD & NEWS

Box 788

Klamath Falls, OR

county - - 97601

75845 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN KLAM

WQ:401 CERT

75846 Updated On 01-JAN-01

By Jacquard MEDIA

79116 Updated On 01-JAN-01

By Jacquard AQ:PN JOSE

MEDIA

WQ:401 CERT

75756 Updated On 01-JAN-Ol

By Jacquard MEDIA

75755 Updated On 01-JAN-OI

By Jacquard MEDIA

75848 Updated On 01-JAN-01

By Jacquard MEDIA

MEDIA: PAL
ADDRLIO .n Address List IS JUL 88 Page 6

97526

97232

97214

KAC1

Box l~, S

Grants Pass, OR 97526

couu ty - -

Hike \.,Tilson KAGO Radio

Box 1150

Klamath Falls, OR 97601

county - -

KAJO

Box 230

Grants Pass, OR

county - -

Assignment Desk

KATU TELEVISION CENTER

Box 2

Portland, OR 97207

county

KBBR

Box 308

North Bend, OR 97459

county - -

KBCH

Box 358

Lincoln City, OR 97367

county - -

KBKR

Box 110

Baker, OR . 97814

county - .-

KBHC-FM 5285 S.W. s Road, #264

Lake Oswego, 97034

Clackamas c ty - 3 -

ce:Jack 'flte!l!R~liR p...

KBND/KLRR News

Box 5037 .

Bend, OR 97708-5037

county - -

KBOO ~O -Hr S.E. 8th

Portland, OR

county - -

KBOY AM & FM

107 E Main, Suite 12

Medford, OR 97501

county - -

KBPS RADIO

546 NE 12th

Portland, OR

county - -

75849 Updated On 01-JAN-Ol

By Jacquard MEDIA

AQ:PN JOSE

75850 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75851 Updated On Ol-JAN-Ol

By Jacquard MEDIA . AQ:PN JOSE

76226 Updated On Ol-JAN-Ol

By Jacquard MEDIA: PAL

MEDIA

PA:PGE SSL

AQ:PN MULT

75852 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN COOS

75853 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN LINC

75854 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN BAKER

75855 Updated On 05-APR-88

By Meissel

MEDIA

75856 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75758 Updated On 22-MAR-88

By Meissel

MEDIA

PA:PGE SSL

MEDIA:VIP MEl'F6R:B- -P:bX

MEDIA: PAL

75857 Updaced On Ol-JAN-Ol

By Jacquard MEDIA

75759 Updated On Ol-JAN-Ol

By J acquazd MEDIA

PA:PGE SSL

MEDIA: PAL

MEDIA:VIP -tmBro~ "Pl> X

AQ:PNo MULT
75998 Updated On 01-JAN-Ol

By Jacquard MEDIA

.-

ADDR40.R

News Direc tor

l:BV!\ Rl\DIO & TV

Oregon State University NU Eo.st

Corvallis, OR 97331

county - -

Address List 15 JUL 88 Page 7

KBZY

Box 14900

Salem, OR 97309

county - - KCBY-TV

Box 1156

I ..

Coos Bay, OR 97420

I county - - KCCS

4303 Market Street, NE

Salem, OR 97301

county - -

75858 Updated On 01-JAN-01

By Jacquard MEDIA

75859 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN COOS

75985 Updated On Ol-JAN-Ol

By Jacquard MEDIA

97440

75860 Updated On 01-JAN-01

By Jacquard MEDIA

MEDIA:VIP MEDFORD

AQ:PN JACK

75861 Updated On Ol-JAN-Ol

By Jacquard . MEDIA

75863 Updated On Ol-JAN-Ol

M DIA

B

t Jacquard )<

MEDIA:VIP MEDFORD

AQ:PN JACK

75865 Updated On Ol-JAN-01

B

t Jacquard M DIA

75866 Updated On Ol-JAN-Ol

B

t Jacquard M DIA

75984 Updated On Ol-JAN-Ol

B

t Jacquard M DIA .

75862 Updated On Ol-JAN-Ol

By Jacquard . MEDIA

MEDIA:VIP MEDFORD

AQ:PN JACK

75864 Updated On Ol-JAN-Ol

By Jacquard MEDIA

Editor

97520

KCYX

Box 207

McMinnville, OR 97128

county - -

KDOV

Box 520

Ashland, OR

county - -

Newsroo

KDRV-Ch.

1090 Knut;:KJI~

Medford OR

county. • -

Jehu W'ooli!!Je5Qfts-1A"rsignment KDRV-TV

1090 Knutson Ave.

Medford, OR· 97504

county - -

KEIZER TIMES

680 Chemawa Road NE

Keizer, OR 97303

county - -

KDUN

20th & Winchester

Reedsport, OR 97467 . county - -

KEED

Box 10767

Eugene, OR

county . -

e·
· I Address List 15 JUL 88 Page

8

KEX- News room

4949 S\~ Hac a dnm

Port13nJ, OR 97201

county

KEXI

112 NE Fifth

Milton-Freewater, OR 97862

county - -

KEZI-TV

2225 Coburg Rd. Euge~e, OR 97401

county - -

KFLS Radio

Box 1450

Klamath Falls, OR 97601

county - -

News Director

KFLY/KEJO RADIO

Box K

Corvallis, OR 97339

county - -

KFHJ 1215 NE¥v; nth

Grants Pa OR

county - -

KGAL

Box 749

Albany, OR 97321

county - -

KGAR

5~20- n. SeQX' RBa~ Box 4638

Vancouver, WA 98662

county - -

KGON-FM

Box 22125

Portland, OR 97222

county - -

KGRL

Box 5068

Bend, OR 97708

county--

KGW-TV

1501 SW Jefferson

Portland, OR 97201

county--

K6\\J- R~di0

\SD\ 'SVV cre.We..r~ev\.

'Portl~) Df<- Q1;l.O\

76007 Updated On 01-JAN-Ol

By Jacquard HEDIA:VIP -flEDFORQ- PJ)¥ HEDIA

HEDIA:PAL

75980 Updated On 01-JAN-Ol

By Jacquard MEDIA

80091 Updated On Ol-JAN-Ol

By Jacquard SWCG:PR LIST

.• MEDIA

75868 Updated On nl-JAN-01

By Jacquard MEDIA

75999 Updated On 01-JAN-01

By Jacquard MEDIA

75869 Updated On 01-JAN-01

By Jacquard MEDIA

_

75870 Updated On Ol-JAN-Ol

By Jacquard

.. MEDIA '. . AQ:PN LINN

75762 Updated On Ol-JAN-Ol

By Jacquard MEDIA

MEDIA:VIP oM!:l'F6ne PJ)'/..

75763 Updated On Ol-JAN-Ol

By Jacquard MEDIA

MEDIA: VIP KEBFOR&- 'Pb

75871 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN DESC

75764 Updated On 01-JAN-Ol

By Jacquard MEDIA

PA:PGE SSL

MEDIA: PAL

MHALPH

AQ:PN MULT

SWCG:PR LIST
ADDR40.R Address List 15 JUL 88 Page 9

KHUG 240 Fern V ey Rd., Phoenix, 97535

county - -

KHSP-TV

4923 Indian School Road, NE

Salem, OR 97305

county - -

x

75872 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN COOS

75765 Updated On 01-JAN-Ol

By Jacquard MEDIA

75874 Updated On 01-JAN-01

By Jacquard MEDIA

MEDIA:VIP MEDFORD

AQ:PN JACK

75875 Updated On Ol-JAN-01

By Jacquard MEDIA

75876 Updated On 01-JAN-01

By Jacquard MEDIA

75766 Updated On 09-MAR-88

By Meissel

MEDIA

PA:PGE SSL

75877 Updated On 01-JAN-01

By Jacquard . MEDIA

75988 Updated On 01-JAN-01

By Jacquard MEDIA' .

97031

97420

97845

KHSN

Box 180

Coos B3Y, OR

county - -

KICE

Box 751

Bend, OR 97709

county - -

KIHR

Box 360

Hood River, OR

county - -

KINK- FM 9-- e leo-ve. '"", =lSOl 8.H. 6Bff9l?e6li

P. B. Be.t ~~12§ --A 4!S:-" biUcz..-k..

Portland, OR 97201

county - -

KIQY

743 Main Street

Lebanon,. OR 97355

ccuncy "- -

KJDY

Box 399

John Day, OR

county - -

;e

KKSN

P.O. Box 9791

Portland, OR 97207

Multnomah county - 26

KJIB-FM

931 SW King Ave.

Portland, OR 97205

county - -

KKEY RADIO

Box 5757

Portland, OR

county - - 97228

75767 Updated On Ol-JAN-Ol

By Jacquard MEDIA

PA:PGE SSL

MEDIA: VIP UEBFOR:B P j) X.

MEDIA: PAL

AQ:PN MULT

75768 Updated On 01-JAN-01

By Jacquard MEDIA

PA:PGE SSL

MEDIA:VIP UEBFOR:& t>:b X.

MEDIA: PAL

75769 Updated On 09-MAR-88

By Meissel

MEDIA

PA:PGE SSL

AQ:PN MULT

MEDIA:VIP ~&QFQ1iU) "PbX.

MEDIA: PAL

x
ADDR40.R Address List 15 JUL 88 Page 10

75880 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75760 Updated On Ol-JAN-Ol

By Jacquard MmU _. MEDIA:VIP MmFORD

75881 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN BENT

75981 Updated On Ol-JAN-Ol

By Jacquard MEDIA

Add·.

e

KLAD AN & FM

Box 489

Klamath Falls, OR 97601

county - -

KLBH

Box 907

La Grande, OR 97850

county . -

KLCC

4000 30th St.

Eugene, OR 97405

county - -

KLITE¥ Box 197

Portland, 97207

county - -

KLOO

Box 731

Corvallis, OR 97330

county - -

KUJJ

Box 1410

Umatilla, OR 97882

county- -

KMCQ

400 E. Scenic Dr.

The Dalles, OR 97058

county - -

KMED

P.O.Box 388

Gold Hill, OR 97525

Jackson county - 15-

KMFR

Box 159

Medford, OR 97501

county - -

KMJK 1!>\"d. 9500 S.W. Barbur Boaleoa?&, Suite 302

Portland, OR 97219

county - -

KMTR-TV

Box 7308

Eugene, OR 97401

county - .

KMUN

1129 Commercial

Astoria, OR 97103

county - -

KNPT{KYQT

Box 430

Newport, OR 97365

county - -

75878 Updated On Ol-JAN-Ol

By Jacquard NEOlA

75879 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75978 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75882 Updated On 05-APR-88

By Meissel

MEDIA . . MEDIA:VIP MEDFORD

75883 Updated On Ol-JAN-Ol

By Jacquard MEDIA

MEDIA:VIP MEDFORD

75771 Updated On 09-MAR-88

By Meissel

MEDIA

PA:PGE SSL

75885 Updated On Ol-JAN-Ol

By Jacquard MEDIA .

75884 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN CLAT

75886 Updated On OI-JAN-Ol

By Jacquard MEDIA

x

»:
KOAP- EI 28~8 SO,? Frent

Po r t Larid , OR

county - -

Address List 15 JUL 88 Page 11

\1"

1'--

KOAP-TV d .4. 4-828 .lim none- 7tlf0 SW (1..1"\ r.\Je..

Portland, OR ~2EH: 91 ~,q- 3013

county - -

KOBI-TV

Box 5M

Medford, OR

county - - 97501

75773 Updated On 01-JAN-Ol

B

t Jacquard M DIA

PA:PGE SSL

MEDIA: PAL

AQ:PN MULT

75887 Updated On 01-JAN-01

B

t Jacquard M DIA

KODL

Box 741

The Dalles, OR 97058

county - -

KOHl

Box 398

St. Helens, OR 97051

county - -

KOHU

Box 145

Hermiston, OR 97838

county - -

KOIN-TV

222 SW Columbia

Portland, OR 97201

county - -

KOTI-TV

Box 2K

Klamath Falls, OR 97601

county - -

KPDQ RADIO

5110 SE Stark

Portland, OR 97215

county

News Director

KPIC-TV

PO Box 1345

Roseburg, OR 97470

county - -

KPNt.J AH & FM

Box 1120

Eugene, OR 97440

county ." -

75979 Updated On 01-JAN-01

By Jacquard MEDIA . MEDIA: PAL

75775 Updated On 01-JAN-01

By Jacquard MEDIA

75888 Updated On 01-JAN-Ol

By Jacquard MEDIA

MEDIA: PAL

75776 Updated On 01-JAN-01

By Jacquard . . MEDIA

MEDIA: PAL

SWCG:PR LIST

AQ:PN MULT

75889 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN KLAM

75777 Updated On 01-JAN-01

By Jacquard .MEDIA

PA:PGE SSL

MEDIA:VIP Uf:BPO~ ?J»( AQ:PN MOLT

75890 Updated On 01-JAN-Ol

By Jacquard MEDIA

AQ:PN DOUG

75891 Updated On Ol-JAN-01

By Jacquard MEDIA

x
ADDR40.R Address List 15 JUL 88 Page 12

KQEN

936 sv Medford

Roseburg, OR 97470

county - -

KQFM. 4949 SW Macadam Ave

Portland, OR 97201

county - -

x

75780 Updated On 01-JAN-01

By Jacquard MEDIA

MEDIA:VIP MEDFORD

AQ:PN MULT

75989 Updated On 01-JAN-01

By Jacquard MEDIA

75892 Updated On 01-Jk~-OI

By Jacquard MEDIA

75778 Updated On OI-JAN-01

By Jacquard MEDIA

PA:PGE SSL

MEDIA: PAL

AQ:PN MULT

75893 Updated On Ol-JAN-O!

By Jacquard MEDIA

AQ:PN DOUG

75779 Updated On 01-JAN-01

By Jacquard MEDIA

PA:PGE SSLX

MEDIA:VIP -+tEfiPORB fl>

MEDIA: PAL

AQ:PN MULT

75894 Updated On 01-JAN-Ol

By Jacquard MEDIA

.

75895 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN DOUG

75781 Updated On Ol-JAN-01

By Jacquard MEDIA

MEDIA: VIP oMEfiPOf.tl}oPb X.

AQ:PN MULT

75896 Updated On Ol-JAN-Ol

By Jacquard MEDIA

lA\t~~75995 Updated On 01-JAN-01 \: By Jacquard . MEDIA . .

~"'~J< v{\O\j~fJ~

·

97754

97630

97202

97470

97470

97756

KPRB- News

Box 12'10

Redmond, OR

county - -

Ne\oJs Director

KPTV-TV

Box 3401

Portland, OR 97208

county

KQIK

8C 64 Box 46

Lakeview, OR

county - .-

ffiH W~E:· Albany, OR 97321

county - -

KRNR

Box 910

Roseburg, OR

county - -

KRRC RADIO

Reed College Portland, OR

county - -

KRSB-FM

Box 5180

Roseburg, OR

county - -

KRCO/KIJK

Box 1<

Prineville, OR

. county - -

~R32 Gresham,)097030

county - -

.e
ADDR40.R Address List 15 JUL 88 Page 13

KRVC

107 E !-lain, #12

Medford, OR 97501

county - -

KRHQ

Box 388

Gold Hill, OR 97525

county - -

Ksgo At \ Caf5

Box 22125

Portland, OR 97222

county - -

KSHR

Box 250

Coquille, OR 97423

county - -

KSLM/KSKD

Box 631

Salem, OR 97308

county - -

KSOR

1250 Siskiyou Blvd

Ashland, OR 97520

county - -

75897 Updated On 01-J&~-01

By Jacquard !-lEDlA

MEDlA;VlP MEDFORD

75991 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN JACK

75782 Updated On Ol-JAN-Ol

By Jacquard MEDIA .

75898 Updated On 01-JAN-Ol

By Jacquard MEDIA ...

75986 Updated On OI-JAN-OI

By Jacquard MEDIA

75899 Updated On OI-JAN-Ol

By Jacquard MEDIA

x

97391

97914

KSRV

Box 129

Ontario, OR

county

KSWB

Box 24

Seaside, OR ·97138

county - -

KSYS-TV JL34 S. fit .

Box 4688

Medford, OR 97501

county - -

KTDO

Box 568

Toledo, OR

county - -

KTEG Radio

Oregon Institute of Tech.

Klamath Falls, OR 97601

county - -

75900 Updated On OI-JAN-OI

By Jacquard MEDIA

·75901 Updated On 01-JAN-Ol

By Jacquard MEDIA

AQ:PN CLAT

75992 Updated On OI-JAN-OI V

By Jacquard /'...; MEDIA

MEDIA:VIP MEDFORD

AQ:PN JACK

75902 Updated On OI-JAN-Ol

By Jacquard MEDIA

AQ:PN LING

75903 Updated On 01-JAN-Ol

By Jacquard MEDIA

KTIL

Box 112

Tillamook, OR

county - -

KTIX

Box 640

Pendleton, OR

county - -

97141

97801

75904 Updated On OI-JAN-Ol

By Jacquard MEDIA

75905 Updated On OI-JAN-Ol

By Jacquard MEDIA
ADDR40.R Address List 15 JUL 88 Page 14

75906 Updated On 01-Jfu~-01

By Jacquard MEDIA

MEDIA:VIP MEDFORD

AQ:PN JACK

75907 Updated On 01-JAN-Ol

By Jacquard f'.-,

MEDIA

Q

97501

97501

KTHT

Box 159

Nedford, OR

county - -

Box 10

Medford, OR

county - -

KTVL-TV

RossHIiley Blfi"8

97123

KTVZ-TV - News

Box 149

Bend, OR 97709

county - -

News Director

KUIK

Box 566

Hillsboro, OR

county - -

75908 Updated On 01-JAN-Ol

By Jacquard MEDIA

75783 Updated On 01-JAN-01 ."

By Jacquard MEDIA

KUMA

Box 340

Pendleton, OR

county - - 97801

75909 Updated On 01-JAN-01

By Jacquard MEDIA

KUPL

6400 SW Canyon Court

Portland, OR 97221

county

KURY

Box 1029

Brookings, OR 97415

county - -

KVAL-TV

Box 1313

Eugene, OR 97440

county

KVAS

1490 Marine Dr

Astoria, OR 97103

county - .

Gregg Hirakawa

KVER-TV

601 N Edison

Kennewick, WA 99336

county - -

KWIL & KHPE

Box 2.78

Albany, OR 97321

county - -

75784 Updated On 01-JAN-01

By Jacquard MEDIA

PA:PGE SSL

MEDIA:VIP ~Q.QRf1 Pb~ AQ:PN MULT

-75910 Updated On 01-JAN-01

By Jacquard MEDIA . AQ:PN CURRY

76997 Updated On 01-JAN-01

'~Hquard

MEDIA

SWCG:PR LIST

75912 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN CLAT

75913 Updated On 01-JAN-01

By Jacquard MEDIA

75914 Updated On 01-JAN-01

By Jacquard. MEDIA

AQ:PN LINN
Address List 15 JUL 88 Page 15

K\nl'

Box I:\.JI l'

Dallas, OR

county - - 97338

75915 Updated On 01-Jfu~-01

By Jacquard MEDIA

Kt.JJJ RADIO

931 SW King Ave

Portland, OR 97205

county - -

KWRC

Box 158

Woodburn, OR 97071

county - -

KWSI

PO Box 489

Warm Springs, OR 97761

county - -

KWVR

107 SW First St

Enterprise, OR 97828

county - -

KXIQ - News

Box 5068

Bend, OR 97708

county - -

KXL Radio

Box 14957

Portland, OR 97214-0957

county - -

Dale Sakamoto

KXL Radio

Box 14957

Portland, OR 97214-0957

county - -

Todd To1ces

KXYQ/Q105

111 S.W. 5th, Suite 1550

Portland, OR 97204

county - -

~~~/~~!~C[ Rlb ,~5'" tJ. 1\t\ltrside) ~lC Medford, OR -9L5'=h 825e '1750I

county - -

KYKN

Box 1430

Salem, OR 97308

county - -

75785 Updated On 01-JAN-Ol

By Jacquard MEDIA

PA:PGE SSL 'x

MEDIA:VIP it6DF~ 'f>l>~ MEDIA: PAL

AQ:PN MULT

75916 Updated.On 01-JAN-01

By Jacquard MEDIA

75917 Updated On 01-JAN-Ol

By Jacquard MEDIA

75918 Updated On 01-JAN-01

By Jacquard MEDIA

75919 Updated On 01-JAN-Ol

By Jacquard MEDIA

75786 Updated On 0~-JAN-01

By Jacquard- MEDIA

PA:PGE SSL " MEDIA:VIP -Mf:I'Fffim PJ)'X. rMEDIA: PAL

AQ:PN MULT

SWCG: PR LIST·

75787 Updated On Ol-JAN-Ol

By Jacquard MEDIA

MEDIA: PAL

75788 Updated On 01-JAN-01

By Jacquard MEDIA

MEDIA: PAL

75920 Updated On 01-JAN-01

By Jacquard MEDIA

MEDIA:VIP MEDFORD

75921 Updated On 01-JAN-Ol

By Jacquard MEDIA

K"Z.:z.. 'R ~O">L .:2-1 \

'Bu..V'rt5) D~ ·~11 ~O x
75789 Updated On Ol-JAN-Ol

By Jacquard MEDIA

PA:PGE SSL

MEDIA: VIP HEBFeftfr'PJ)'X.

MEDIA: PAL

75996 Updated On 01-JAN-01

By Jacquard MEDIA

•

ADDR40.R

KYTE

2040 S\~ First

Portland, OR 97201

county - -

Ray Penny KYTT

455 N. Broadway Coos Bay, OR 97420

county - -

Address List 15 JUL 88 Page 16

LAMRON

Western Oregon State College Monmouth, OR 97361

county - -

•

j

1

1

KZEL

2100 W 11th Ave.

Eugene, OR 97402-3578

county - -

LAKE COUNTY EXAMINER

Box 271

Lakeview, OR 97630

county - -

LAKE OSWEGO REVIEW

Box 548

Lake Oswego, OR 97034

county - -

LEBANON EXPRESS

Box 459

Lebanon, OR 97355

county - -

MAIL TRIBUNE

Box 1108

Medford, OR 97501

county - -

MALHEUR ENTERPRISE

Box 310

Vale, OR 97918

county -

. 75922 Updated On 01-JAN-01 o By Jacquard

n MEDIA 1)Q..te-~ -w-o" h this. UE~I2\. 'JU' !l!~P'Otm 9

\\1)~ • AQ : PN MULT

75923 Updated On 01-JAN-01

By Jacquard . MEDIA

AQ:PN lAKE

75790 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN MULT

75924 Updated On 01-JAN-01

By Jacquard MEDIA

75925 Updat-ed On Ol-JAN-Ol

By Jacquard 0

MEDIA

75926 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75927 Updated On Ol-JAN-Ol

By Jacquard MEDIA _

x

75770 Updated On Ol-JAN-Ol

eollege By Jacquard MEDIA

o'

J

Pacific Northwest Edition

MONTHLY

603 Stewart #1020

Seattle, WA 98101

county - -

tQO..)Jf.. KMHD - News ... \)u..+ -.:, Wt; Hood 681~flit, ,~~ 26000 SE Stark 8~r+an Gresham, OR 97030 ~o 2 \It'\£5 county - - ~,..- b'~

50 It~~~MYRTLE POINT HERALD 4h(t c.,,"~ 0 410 Spruce St ~~~. Myrtle Point, OR 97458 f\l county - -

Mooo... M.Q..dta..

A%~ <ru.d ith 0

1'D 56')C 4-lo5:3

'PoY'+10J'\d, DR.. ql~og

75928 Updated On Ol-JAN-Ol

By Jacquard , MEDIA

75929 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN COOS

x
15 JUL 88 Page 17

75933 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75935 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN LINC

75934 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN DOUG

WQ:401 CERT

75792 Updated On Ol-JAN-Ol

By Jacquard MEDIA . PA:PGE SSL

MEDIA: PAL

AQ:PN MULT

75936 Updated On Ol-JAN-Ol

By Jacquard MEDIA

WQ:401 CERT

75937 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75930 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN LINN

75931 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN CURRY

75932 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75938 Updated On Ol-JAN-Ol

By Jacquard MEDIA

77026 Updated On Ol-JAN-Ol

By Jacquard MHALPH

MEDIA

PA:LEGIS TRACK

NOISE:HEAR

AQ :ANNUAL REP

NOISE:ADV

WQ:HEAR SS

PA:PLANET

WQ:401 .CERT

ADDR40.R Address List

OBSERVER

Box 3137

Portland, OR 97208

county -. -

NEIlS

Box 5

Port Orford, OR 97465

county - -

NEIJS GUARD

Box 848

Lincoln City. OR 97367

county - -

NEWS REGISTER

Box 727

McMinnville, OR 97128

county - -

NEWS TIMES

Box 965

Newport, OR 97365

county - -

NEIlS -REVIEW

Box 1248

Roseburg, OR 97470

county - -

NEIl [1::\

Box 3 t~

SHeet lIome, OR 97386

county

OBSERVER

Box 3170

La Grande, OR 97850

county - -

Greg Parker

OREGON AUDIO NEWS

State Capitol Press Room

Salem, OR 97310

county - -

OREGON DAILY EMERALD

University of Oregon Box 3159

Eugene, OR 97403

county - -

John Charles, Director

OREGON ENVIRONMENTAL COUNCIL

2637 SW Water Ave

Portland, OR 97201

county - -

85955 1

By Meii

PA:PLAl

MEDIA

I

75794 1

By .Jac:

MEDIA

75797 1

B

t Jaci M DIA

MEDIA:] ,) 75798

Jac DIA

75941

~JacIA

75942 1 B

t Jac,

M DIA

75994 ] B

t JaC

I

M DIA

75564 ]

Bt; Jac

o :EQCI MEDIA

MEDIA:]I

75800 1

Bt Jacl M DIA

PA:PGE

AQ:PN.l

I /

] . I ,_~J

I

I

I 75795 l

By !-lei!

MEDIA l

PA:PGE

AQ: PN ,

75796 1

By Jace

MEDIA :

i

I

75939

By Jacc

MEDIA

Address List

Suite 1290

Suite 520

ADDR/IO. R

Assignment Editor

OREGON NEIJS NETWORK

9 S.W. Monroe Parkway 1

Lake Oswego, OR 97034

county - -

John McDonald

OREGON PUBLIC BROADCASTING

State Capitol, Press Room

Salem, OR 97310

county - -

OREGON HAGAZINE

421 s .v. 5th Avenue, Portland, OR 97205

Multnomah county - 26

( 503) 274- Lf393

\J ,

9 19 0

.v-c-r-C OY\ a..Y\oth.e.r ns+ fh~ are.-:J.. Pori

fVV I t;;. de.l~-\-e.. 91"£.. V\.U-t'Vlbere.c\ 15; c; -rt~ . .,_. "'-_I ...._-- ........ -., ,-"""'''' ,

c:Jr . Emery Castle C/o Q~8/;e!'\ Seati9 YliioefSit'l, e: l~t i t"\

307 Ballard Hall

Corvallis, OR 97331

Benton county -, 2. - .. .. . ~V·lrot'\WlV'\.1oJ.. ~a...L'i~ c...erwtMoI ,-S I

OREGON/WASHINGTON LABOR pRtss B01 !:IE Her r iSQft ~t 12·

P.O. Box 1~3Hl \'S\50

Portland, OR "g,7214 111f)12

county - -. "" v

OUTLOOK

Box 880

Gresham, OR 97030

county - -

PIONEER

Box 168

Molalla, OR 97038

county - -

PIONEER

Box "W"

Madras, OR 97741

county - -

POLK COUNTY ITEMIZER-OBSERVER

Box 108

Dallas, OR 97338

county - -

PORT ORFORD NEWS

Box 5

Port Orford, OR 97465

county - -

Robert Goldfield

Portland Business TodayC:'An CP-p'll. 2014 N.W. 24th Avenue

Portland, OR 97210

county - -

PORTLAND MAGAZINE

221 NW Second Ave.

Portland, OR 97209

county - -

'e
ADDR40.R Address List 15 JUL 88 Page 19

POST

Bo:.;. GS

S<Jncly, OR

county

97055

75943 Updated On 01-JAN-Ol

By Jacquard MEDIA

George Smith, Editor

PULSE BEATS OF THE ENVIRONMENT

PO Box 3006

Savannah, GA 31402

county

75944 Updated On 01-JAN-01

By Jacquard MEDIA

PA:RECY NEWS

RECORD

Box 69

Pendleton, OR

county

97801

75945 Updated On 01-JAN-01

By Jacquard MEDIA

97352

RECORD COURIER

Box 70

Baker, OR 97814

county

REVIEW

Box 330

Jefferson, OR

county - -

d

enev i eve Sage 834 Yvonne . Medford, OR 97504

Jackson county. - 15 - , en.."if'O)/\Men+Q..( Qu.oJ.i~CeMm;$sl~

SCAPPOOSE SPOTLIGHT

Box C

Scappoose. OR 97056

county - -

SHERMAN COUNTY JOURNAL

Box 284

Moro, OR 97039

county -

SIGNAL

Box 848

Seaside, OR 97138

county - -

SIUSLAI.] NE\.]S Box 10

Florence, OR 97439

county - -

SPOKESi-iAN

Box 788

Redmond, OR 97756

county _. -

ST. JOHNS REVIEW

8410 N Lombard

Portland, OR 97203

county - .

75946 Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN BAKER

75947.Updated On 01-JAN-01

By Jacquard MEDIA

AQ:PN LINN

80525 Updated On 15-JUL-88

By Meissel

AQ :ANNUAL REP

PA:PLANET

MEDIA

75801 Updated On 01-JAN-Ol

By Jacquard MEDIA

MEDIA: PAL

75948 Updated On 01-JAN-01

By Jacquard MEDIA

MEDIA: PAL

75949 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN,CLAT

75950 Updated On 01-JAN-01

By Jacquard MEDIA .

75951 Updated On Ol-JAN-Ol

By Jacquard MEDIA

76262 Updated On Ol-JAN-Ol

By Jacquard MEDIA: PAL

MEDIA

x
ADDIU,0 .R Address List 15 JUL 88 Page 20

101

News Eelitor STl"\TES~l.fI.N JOURNAL

Box 13009

Salem, OR 97309

county - -

STAYTON MAIL

Box 400

Stayton, OR 97383

county

SUN

Box 68

Sheridan, OR 97378

county - -

SUN-ENT"ERPRISE

Box 26

Monmouth, OR 97361

county - -

SUN-TRIBUNE

Box 430

Sutherlin, OR 97479

county - -

THE BULLETIN

1526 m~ Hill St.

Bend, OR 97701

county--

THE BUSINESS JOURNAL

Box 14490-

Portland, OR 97214

county

THE COLUMBIAN

PO Box 180

Vancouver, WA 98666

county - -

THE NEIGHBOR

1714 N.W. Overton

Portland, OR 97209

county--

Paul Koberstein l\ The Oregonianc=-- A

1320 S.Q. Broadway Portland, OR 97201

county--

Pauline Braymen THE OREGONIAN

Star Route1

A Box

Burns, OR ~7720

county - -

75952 Updated On 01-JAlJ -01

By Jacquard HEDIA

WQ:401 CERT

75953 Updated On 01-JAN-01

By Jacquard MEDIA

75954 Updated On 01-JAN-01

By Jacquard MEDIA

75955 Updated On 01-JAN-01

By Jacquard MEDIA

75956 Updated On 01-JAN-01

By Jacquard MEDIA

75957 Updated On 01-JAN-Ol

By Jacquard MEDIA

SWCG : PR LIST'

AQ:PN DESC

WQ:PN

WQ:PN CROOK

WQ:PN DESC

WQ:PN JEFF

75803 Updated On 01-JAN-01

By Jacquard

. MEDIA

PA:PGE SSL

MEDIA: PAL

AQ:PN MOLT

75804 Updated On Ol-JAN-01

By Jacquard MEDIA

76252 Updated On 01-JAN-Ol

By Jacquard MEDIA: PAL

.MEDIA

75592 Updated On 01-JAN-01

By Jacquard OD:EQC AGENDA

MEDIA

75940 Updated On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN HARN
ADDR40.R Address List 15 JUL 88 Page 21

J.:1llct Coctze

TilE OREGONIAN

1320 S.W, Broadway Portl.:1lld, OR 97201

county - -

City Desk

THE OREGONIAN

1320 SW Broadway Portland, OR 97201

county - -

Deedee Harrington THE OREGONIAN - HILLSBORO ' BUREAU

115 S.E. Second

Hillsboro, OR 97123

county - -

News Editor

THE REGISTER GUARD

Box 10188

Eugene, OR 97440

county - -

THE SPRINGFIELD NEWS

Box 139

Springfield, OR 97477

county - -

'THE TIMES

Box 278

Brownsville, OR 97327

county - -

~SHING'PEl~WS-TIMES Box 408

Forest Grove, OR 97116

county - -

The World All t!.t::Ln.~ Box 1840 -~~rCoos Bay, OR 97420

county - -

TIMES HERALD

Box 473

Burns, OR 97720

county - -

TIMES PUBLISHING CO.

Box 370

Beaverton, OR 97075

county - -

75806 Updated On Ol-JM1-0l

By Jacquard HEDIA

HEDIA:PAL

PA:BERGSOE

76255 Updated On 01-JAN-01

By Jacquard MEDIA: PAL

MEDIA

~~6i~7v~~LHEBFORD- r1:>'1-.

75807 Updated On OI-JAN-Ol

By Jacquard MEDIA

MEDIA: PAL

75958 Updated On 01-JAN-Ol

By Jacquard MEDIA

AQ:PN LANE

SWCG:PR LIST

WQ:401 CERT

75959 Updated On Ol-JAN-Ol

By Jacquard MEDIA

76000 Updated On 01-JAN-Ol

By Jacquard MEDIA

AQ:PN BENT

AQ:PN LINN

75813 Updated On OI-JAN-Ol

By Jacquard MEDIA , MEDIA: PAL

76212 Updated On 01-JAN-Ol

By Jacquard AQ:HEARINGS

MEDIA

WQ:40I CERT

AQ:PN COOS

NOISE:HEAR

75960 Updated On 01-JAN-Ol

By Jacquard MEDIA

75808 Updated On 01-JAN-Ol

By Jacquard MEDIA

PA:PGE SSL

MEDIA: PAL

MEDIA:VIP -KKQFe~ 'P2)( AQ:PN MULT

x

THE OKE:(;DN BUt"l\Jl'IST

'PO r2>e)L .230.11.()

lt~d) OR.., '11~23

x
ADDR40.R Address List 15 JUL 88 Page 22

Lane

97045

THiES-JOURNAL

Box 746

Condon, OR 97823

county - -

William P. Hutchison, Jr.

cluooze, Marshall, Shenker,," ~J::~. -Hollo.JAy...Q. I;hi88R (L.,

333 S.W~ Taylor Street

Portland, OR 97204

ce;Jtr~\"\~U\.+ol &uo1ih*Con'\rn·l~~iOh.. TRI-COUNTY NEWS

Box 395

Junction City, OR 97448

county - -

TRIBUNE

Box 68

Dayton, OR 97114

county - -

Ron Oberg U.S. WATER NEWS

15594 S.W. Maple Oregon City, OR

county - -

UMPQUA FREE PRESS

Box 729

Myrtle Creek, OR 97457

county - -

United Press International ,Alt C!llfS

1320 SW Broadway . . Portland, OR 97201 . county - -

VALLEY HERALD

Box 230

Milton-Freewater, OR 97862

county - -

VALLEY SENTINEL

#1 Barton Alley Coquille, OR 97423

county - -

VALLEY TIMES

Box 370

Beaverton, OR 97005

county - -

,Add', UNIQUE MAG-AllPJe

1.04-35 1JE. l<&~

PCY'tlCU'"\cl) DIZ 912\ \

75961 Updated On 01-JAN-Ol

By Jacquard MEDIA

AQ:PN GILL

WQ:401 CERT

79426 Updated On Ol-JAN-Ol

By Jacquard PA:PLANET

PA:LEGIS TRACK

EQC

MEDIA

75990 Updated On 01-JAN-Ol

By Jacquard MEDIA

75962 Updated On 01-JAN-Ol

By Jacquard MEDIA

75810 Updated On 01-JAN-Ol

By Jacquard MEDIA

PA:TUAL STUDY

75993 Updated On 01-JAN-Ol

By Jacquard MEDIA

75716 Updated On 01-JAN-Ol

By Jacquard OD:EQC AGENDA

PA:PGE SSL

MEDIA

MEDIA: PAL

AQ:PN INDIV

WQ:PN

AQ:PN MOLT

SWCG:PR LIST

WQ:PN STATE

75982 Updated On Ol-JAN-Ol

By Jacquard MEDIA

75963 Updated On Ol-JAN-Ol

By Jacquard MEDIA

76269 Updated On Ol-JAN-Ol . By Jacquard MEDIA: PAL

MEDIA

AQ:PN MULT
ADDR40.R Address List 15 JUL 88 Page 23

WALLOWA COUNTY CHIEFTAIN

Box 338

Enterprise, OR 97828

county - -

Ats Kiuchi, Public Affairs

WASHINGTON DEPT. OF ECOLOGY

Mail Stop PV-ll . Olympia, WA 98504

county - -

William Wessinger 0

133 W. Burns1de

Portland, OR 97209

Mw.tnomah coulltY, - 26 -,._ .. ..~

b\vlro~~ QWa..li'\-"\ \,.prt'lt'\l\C.l6• ....''-

WEST LANE NEWS o

Box 188

Veneta, OR 97487

county - -

WESTERN WORLD

Box 248

Bandon, OR 97411

county . -

WILLAMETTE WEEK

.2 NW Second

Portland, OR 97209

county - - .

WOODBURN INDEPENDENT

Box 96

Woodburn, OR 97071

county - -

Sara Laumann

Department of Environmental Quality Environmental Cleanup Division

811 SW Sixth Avenue

Portland, OR 97204

Multnomah county - 26 -

(503) 222-9641

Coos Bay Branch Office

Department of Environmental Quality 490 N Second St.

Coos Bay, OR 97420

county - -

75964 Updated On Ol-JAN-Ol

By Jacquard MEDIA

WQ:PN

WQ:PN WALL

75965 Updated On Ol-JAN-Ol

By Jacquard MEDIA

85956 Updated On l5-JUL-88

By Meissel

PA:PLANET

MEDIA

75966 Updated On Ol-JAN-Ol

By Jacquard . MEDIA

75967 Updated.On Ol-JAN-Ol

By Jacquard MEDIA

AQ:PN COOS

75812 Updated On Ol-JAN-Ol

By Jacquard MEDIA

PA:PGE SSL

MEDIA: PAL

75983 Updated On Ol-JAN-OI

-By Jacquard MEDIA .

56479 Updated On lS-JUL-S8

By Meissel

UST :REQUEST _ UST:l<NT

REMACT :ADV COMM

MP: INDIVIDUALS

PUB2

PUBl

PUBWES

PA:PGE SSL

MHALPH

REMACT

AQ:HEARINGS

AQ:PN INDIV

UST:INS FUND

PA:PLANET

MEDIA

7S972 Updated On OI-JAN-Ol

By Jacquard MEDIA _
ADDR40.R Address List 15 JUL 88 . Page 24

Eastern Region'Office De pa r r me nt; of Environmental Quality 700 SE Emigrant St.

Pendleton, OR 97801

county - -

Willamette

De~artment

-e S dUtIllC l'

Salem, OR

county - -

Southwest Region Office

Department of Environmental

201 WMain St., Suite 2-D

Medford, OR 97501

county - -

Quality,

75973 Updated On Ol-JAN-Ol

By Jacquard HEDIA

75977 Updated On 01-JAN-01

By Jacquard MEDIA

75976 Updated On 01-JAN-01

By Jacquard MEDIA

x

Roseburg Branch Office

Department of Environmental Quality 1937 W Harvard Blvd.

Roseburg, OR 97470

county - -

Northwest Region Office

Department of Environmental Quality 811 S.W. Sixth Avenue

Portland, OR 97204

county - -

Astoria Branch Office

Department of Environmental Quality PO Box 869

Astoria, OR 97103 ~6unty - .-

Central Region Office

Department of Environmental Quality 2150 NE Studio Road

Bend, OR 97701

county -'-

Regional Operations Office

Department of Environmental Quality 811 S.W. Sixth Avenue

Portland, OR 97204

county - -

266 entries were retrieved

75975 Updated On 01-JAN-01

By Jacquard MEDIA

75974 Updated On 01-JAN-01

By Jacquard MEDIA

75970 Updated On Ol-JAN-01

By Jacquard MEDIA

75971 Updated On 01-JAN-01

By Jacquard MEDIA

75969 Updated On Ol-JAN-Ol

By Jacquard MEDIA
- PART IV

METHODS OF DETECTING VIOLATIQn~

A multi-faceted approach to violation detection is employed by DEQ. Oregon

Revised Statutes (ORS) 466.195 and 459.385 provide the Department with

authority to enter upon premises, inspect, copy records, sample and request

information be submitted. by a regulated party. This authority provides the

primary means of detecting non-compliance. DEQ's goals are to ensure that

as many regulated facilities as possible are inspected and to concentrate

first on handlers whose activities pose the greatest actual or potential

threat to public health and the environment. Inspections of facilities and

generators and responses to hazardous waste spills are a significant

component of DEQ's compliance monitoring program. The Department's

e priorities,' criteria, and plans for inspections are described in Parts V and

VI.

The Department also uses the requirement for self-reporting by handlers as a

means to detect violations. Quarterly reporting is required from Oregon

hazardous waste generators and TSD facilities (monthly reporting by CSSIArlington) for waste received or shipped off-site. The quarterly reports

submitted by generators, treatment and storage facilities consist generally

of copies of manifests. Thus, the DEQ review of the report constitutes

review of the manifest for completeness.

The reports from Oregon generators are cross-checked against Oregon TSD

facility reports to assure TSD reports of waste receipts are accurate.

..:~ .'.

. /.,

,. -

ZC2170 (9/22/88) - 7 -
Non-notifiers (waste handlers without proper registration) are also

identified from review of TSD facility reports.

Citizen complaints are often received by the Department and sometimes result

in detection of hazardous waste violations upon investigation. The

Department's policy is to respond to citizen complaints as quickly as

possible considering the potential for environmental or public health harm.

The Department also utilizes the permit application review process to

identify violations of program requirements. Permit writers, who are

familiar with TSD facility requirements, evaluate applica~ions for

completeness and identify deficiencies for followup resolution.

Two additional methods are used. Investigations of past waste handling

practices occasionally identify violations of hazardous waste rules or nonregistered handlers. Inspections conducted under the State's air and water

quality control programs can also lead to detection of hazardous waste

violations, depending on the inspector's level of knowledge of the hazardous

waste rules.

PART V

CRITERI.4 FOR PROGRAM QUALITY

The Department is committed to carry out a quality compliance monitoring

program. The accuracy and thoroughness of information gathered from

compliance monitoring affects the use of the data and success of

ZC2170 (9/22/88) - 8 -
•

••

ZB4956.2

ENFORCEMENT GUIDELINES AND PROCEDURES

HAZARDOUS WASTE PROGRAM

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

NOVEMBER 1985

-1-

Appendix K
SECTION 1

INTRODUCTION

Purpose and Scope

The Enforcement Guidelines and Procedures (hereafter "enforcement

guidelines") presents a framework for enforcement of the Oregon Department

of Environmental Quality's (DEQ) Hazardous Waste Program. This document

sets forth DEQ's approach to responding to documented instances of

noncompliance. Requirements pertaining to hazardous waste handlers are

contained in: (1) Oregon Revised Statutes (ORS) 459.410 to 459.450 and

459.460 to 459.690; (2) Oregon Administrative Rules (OAR), Chapter 340,

Divisions 100-106; (3) permits (licenses) issued pursuant to applicable OAR

and ORS; and, (4) orders of the Department and Commission.

The goal of enforcement is to obtain correction of environmental or public

health impacts resulting from noncompliance and expeditious resolution of

hazardous waste program violations.

The purpose of this document is to provide gUidelines to Department staff

to ensure·effective state enforcement of hazardous waste requirements. The

enforcement guidelines identify the state's enforcement authorities and

contain procedures for determining categories of violations and associated

timely and appropriate enforcement responses.

Priorities are established to ensure that those violations Which cause or

have the potential to cause serious environmental harm or' public health

hazards are addressed by the Department with higher priority than

violations of an administrative nature. Timelines are also established for

initial and subsequent escalated enforcement responses to provide for

resolution of noncompliance in the shortest practicable time period.

When administrative civil penalties are assessed by the DEQ Director, the

guidelines in this document may be consulted in conjunction with OAR

340-12-045 t~ ensure that: (1) penalties are assessed fairly and consistently;

(2) penalties are appropriate to the gravity of the violation; and (3) economic

incentives for noncompliance are reduced as much as possible.

The enforcement guidelines are intended for use only by Department

personnel involved with administering DEQ's Hazardous Waste Program. The

guidelines are based upon existing authorities granted by and procedures

and considerations contained in Oregon Revised Statutes and Oregon

Administrative Rules. This document is not intended to limit in any way

the state's enforcement authorities or practioes. The Department may

initiate any aotion or seek any relief, as provided for in Oregon statutes

and rules, that is deemed appropriate or neoessary.

ZB4956.2 -3-
These guidelines are not intended and should not be relied upon to create

rights, substantive or procedural, which are enforceable by any party

contesting or appealing a Department action.

The enforcement guidelines will be used by the Department beginning

January 1, 1986. In general, enforcement actions initiated by DEQ after

January 1, 1986, in response to hazardous waste violations detected after

this date, are intended to be gUided by this document. Except as noted

below, violations which are detected prior to January 1, 1986, and for

which an enforcement action is taken after January 1, 1986, may, but are

not necessarily required to, be addressed by these gUidelines.

The provisions of this document pertaining to escalation of enforcement

responses (Part B of Section 3) apply to all enforcement actions taken

after January 1, 1986, regardless of when the violation was detected.

SECTION 2

GENERAL PRINCIPLES

Enforcement of tne Department's hazardous waste program will be guided by

the following general principles:

1. The objective of enforcement is to attain and maintain compliance

with hazardous waste statutes and rules administered. by DEQ.

2. Responsibility for compliance rests with those persons co~ducting

activities covered by these statutes and rules and with permits

and or~ers issued pursuant thereto.

3. DEQ enforcement actions will be appropriate to the gravity of the

Violation; pursued to resolution in a timely manner, and applied

consistently statewide.

4. Enforcement actions will be escalated to an appropriate level

when violators fail to comply with established compliance

schedules.

5. DEQ will endeavor, by conference, conciliation and persuasion, to

solicit compliance prior to and following issuance of enforcement

action.

6. All enforcement actions will clearly identify each and every

documented violation, establish compliance schedules if

appropriate and require the violator's certification that

compliance is achieved.

7. Compliance schedules established will be for the shortest

practicable time and may include interim mitigating measures to

minimize adverse effects of noncompliance.

8. Resolution of Violations shall be doc~ented through an

appropriate means.

ZB4956.2 -4-
SECTION 3

VIOLATION CATEGORIES

Each documented violation of a statutory requirement, rule, or condition of

an order or permit will be categorized according to the seriousness of the

violation and other relevant factors identified in this section. Each

instance of noncompliance is considered a separate violation and should be

classified separately. Using the guidelines in Section 4, a single

enforcement response, which addresses all of the violations, should be

selected.

Violations will be classified into one of three categories as described

more fully below:

Class I Violation A violation which:

creates.a likelihood for harm or for significant environmental

damage, or has caused actual harm or environmental damage;

involves the unauthorized disposal of hazardous waste;

re~ults in the failure to assure that groundwater will be

protected or that proper closure and post-closure activities

will be undertake.n; or

involves the failure to establish and maintain financial

assurance mechanis~s

Class II Violation A violation which:

results in a release or creates a threat of release of

hazardous waste to the environment but does not create a

likelihood for harm or environmental ~amage; or,

involves the failure to ensure hazardous wastes are destined

for and delivered to a permitted, interim status or designated

facility.

Class III Violation Any other violation of hazardous waste rules,

permits or orders.

Examples of Class I, II, and III violations, using this classificati~n

scheme, are included in Appendix II.

While there are some hazardous waste requirements whose violation would, in

almost all situations regardless of the circumstances, clearly meet the

Class I criteria, cases may arise in which a particular violation's

"likelihood for harm" is superficially unclear. Therefore, potential

Class I violations should be eValua~ed in consideration with other relevant

factors in order to determine the likelihood for harm. These additional factors

may include, but are not limited to, the following:

ZB4956.2 -5-
the type and duration of the violation;

the degree of deviation from the requirement;

precautions, actions or measures taken bY,the violator which would

mitigate potential adverse impacts of the handler's operation;

the hazard characteristics and quantity of the hazardous waste; and

specific characteristics of the site where the violation occurred.

SECTION 4

TIMELY AND APPROPRIATE ENFORCEMENT RESPONSE

This section identifies the options for appropriate enforcement actions in

response to violations. A more detailed discussion of these actions is

contained in Section 5.

Timeframes for DEQ enforcement actions are also included. The timeframes

described herein are considered the maximum allowable -- enforcement

actions should proceed more quickly if possible. Where timeframes begin

with the date of violation discovery, this $hall be interpreted as the date

that tne Department inspector determines through review of the inspection

report ana/or data (e.g., laboratory reports) that a violation has

occurred.

In general, initial DEQ enforcement actions for Class II and III violations

will be at the lowest appropriate level and subsequently escalated if

violators fail to achieve compliance or meet established compliance

schedules. There are-exceptions, however, as noted below.

A. INITIAL ENFORCEMENT RESPONSES

CLASS I VIOLATIONS

Aporopriate Enforcement Resoonse: The Department generally intends to

assess civil penalties for Class I violations through issuance of a Civil

Penalty Assessment.

DEQ will also establish compliance schedules to return violators to

full compliance, through issuance of either a Notice of Intent to

Assess Civil Penalty (hereinafter "Notice of Intent") or an Order. If

correction of the Class I violations will require an extended period

of time and substantial effort (e.g., development of Part B

application, installation of surface impoundment liner, etc.), DEQ may

issue an Order in lieu of the Notice of Intent. -

If D~partment staff have reason to believe tttat either of these DEQ

administrative actions will be ineffective in obtaining the violator's

full compliance, direct court action may be recommended.

Timeliness of Enforcement Response: The times indicated below

pertain to the state's enforcement response options. They

include the writing, processing and issuance of the enforcecent

action.

Z~956.2 -6-
ie

a.

b.

c.

d.

Enforcement Action

Civil Penalty Assessment

Notice of Intent

DEQ order

Referral to Department of

Justice for court action

Time

45 days after violation

discovery.

45 days art.er violation

discovery.

45 days after violation

discovery.

45 days after violation

discovery.

e'

-,

CLASS II VIOLATIONS

Appropriate Enforcement Response: In general, the initial DEQ

enforcement response to Class II violations will be a Notice of

Violation (NOV) issued by the Regional ~~ager.

Alternately, a Notice of Intent should be issued if: (1) correction

of the violations will take longer than 90 days; (2) the violator has

a large number of Class II violations; or (3) the Department has

reason to believe the NOV will be ineffective.

In cases where corre.ction of Clas's II violations will· require an

extended period of time and substantial effort, issuance of.an Order

may be recommended.

Timeliness of Enforcement Response: The times indicated below

include the writing, processing and issuance of the respective

enforcement responses.

Enforcement Action Time

a. Notice of Violation 30 days after violation

discovery.

b. Notice of Intent 60 days after violation

discovery.

c. DEQ order 90 days af.ter violation

discovery

CLASS III VIOLATIONS

Appropriate Enforcement Response: A violator with only Class.III

violations will normally be issued a Notice of Violation as the

initial enforcement response.

ZB4956.2 -7-
If there are a large number of Class III violations or if the

violations will require more than 90 days to correct, a Notice of

Intent should be issued initially.

Issuance of an Order or Civil Penalty Assessment as ·an initial

enforcement response generally will not occur unless there are

significant aggravating circumstances.

Timeliness of Enforcement Response:

Enforcement Action

a. Notice of Violation

b. Notice of Intent

B. ESCALATION OF ENFORCEMENT RESPONSES

Time

30 days after violation

60 days after violation

discovery.

While the Department expects the majority of violations to be resolv€d

with an initial enforcement response, DEQ will closely monitor

compliance schedule dates and expeditiously take subsequent actions if

such dates are not met or if full compliance is not achieved.

Appropriate Enforcement Response: Subsequent enforcement actions

taken in response to a violator's failure to comply with an

initial enforcement action normally will be escalated as

indicated below:

Initial Enforcement Response

a. Notice of Violation

b. Notice of Intent

c. Assessment of Civil Penalty

d. DEQ order

Subsequent Enforcement Resoonse

Notice of Intent.

Assessment of Civil Penalty.

Additional Assessment of Civil

Penalty or Department order.

Assessment of Civil Penalty or

referral to Department of Justice

for court action.

ZB4956.2

However, these guidelines should not be interpreted to preclude

DEQ from taking a subsequent enforcement action which may be more

than one level higher than the intitial action. For example, if

a Notice of Violation 1s issued as the initial response to

Class II violations, and compliance is not achieved with 90 days,

DEQ may assess a civil penalty without first issuing a Notice of

Intent.

-8-
• SECTION 5

TYPES AND DESCRIPTIONS OF ENFORCEMENT RESPONSES

Notice of Violation is a written notice that identifies the violations and

specifies a date when the violator must return to full compliance. Interim

compliance dates may be included if appropriate.

Notices of Violation are used when there are Class II or III violations

which can be corrected within 60 days of the notice. A Notice of Violation

should not be considered a prerequisite to issuance of a Notice of Intent

or a civil penalty if it is thought that either of those actions will

eventually be needed to obtain comp~iance by the violator.

Notices of Violation are issued by the Regional Managers or their staff.

The notice shall require a written response from the violator noting how

and when the violations were corrected. The Department may conduct a

followup inspection to verify compliance.

Notice of Intent to Assess Civil Penalty is a written document which warns

a violator that civil penalties may be assessed for violations cited

therein without further notice from the Department. The Notice of Intent

cites t~e particular violations and describes the factual findings upon

.which the Violations are based.

The letter accompanying the Notice of Intent shall either specify a

schedule, 'if appropriate, for the violator to return to compliance or

require the violator to submit a compliance schedule by a specified date

for Departcentapproval. A compliance schedule should contain interim

requirements and dates for their achievement if final compliance will

exceed 120 days. A compliance schedule should require that progress

reports be submitted to the Department within 1~ days following each

scheduled date.

Notices of Intent are issued for all Class I violations and for Class II or

Class III violations which require more than 60 days after the notice to

correct. Notices of Intent are issued by the Administrator of the Regional

Operations Division, based upon a referral to the Enforcement Section. The

Hazardous Waste Section Manager and the appropriate Regional Manager shall

be consulted for concurrence prior to issuance of Notices of Intent.

Failure to comply with the compliance schedule in a Notice of Intent should

result in an escalated action such as civil penalty, Department order or

referral to Department of Justice for court action.

Civil Penalty Assessment means the administrative levying of a monetary

penalty by' the Director of the Department. A hazardous waste management

schedule of civil penalties is contained in OAR 340-12-068 and varies from

not less than $100 to not more than $10,000 for each violation. Each day

the violation continues may constitute a separate offense.

Z~956.2 -10-
Timeliness of Enforcement Response: Subsequent enforcement

actions taken in response to a violator's failure to comply with

the initial enforcement action will proceed according to the

following timeframes.

Enforcement Action

a. Notice of Intent

b. Assessment of Civil Penalty

c. DEQ order

d. Referral to Department of Justice for

Court Action

C. CHRONIC OR REPEATED VIOLATIONS

30 days

45 days

60 days

90 days

If the Department finds that a person is a chronic violator of

hazardous waste program requirements, or repeatedly violates the same

requirements, this is an indication that the past enforcement actions

were not successful in deterring the violator. In such cases, it may

be appropriate for DEQ to escalate the initial enforcement actions for

the newly documented violations above the level normally indicated for

an initial response.

"For example, if a violator has repeated Class III violations, DEQ may

issue a Notice of Intent or a Civil Penalty Assessment for the new

violations, rather than begin with a Notice of Violation.

D. COMBINATIONS OF CLASS I, II AND III VIOLATIONS

When a violator has violations of more than one classification, it is

desireable to issue one consolidated enforcement response which COVers

all of the violations.

For example, if a person has several Class I and Class II Violations,

a single Notice of Intent should be issued, citing all of the Class I

and Class II violations. (The accompanying Civil Penalty Assessment,

which is the appropriate enforcement response for Class I Violations,

would only cite and cover the Class I violations.)

Although dual enforcement actions should be minimized, they may be

appropriate in some cases. For example, a person with both Class II

and Class III Violations could receive a penalty assessment for the

Class II violations and a separate NOV or Notice of Intent for the

Class III violations. This might occur when the circumstances

surrounding the Class II violations justified a penalty, but the

Class III violations did not.

JBegins on the first day after a compliance schedule date is not met.

\

'~ ..-

ZBA956.2 -9-
e··

In determining the amount of a civil pe~~lty, the Director may consider the

criteria in OAR 340-12-045. (Section 7 of these guidelines restates OAR

340-12-045 and provides guidance for determining the amount of a penalty.)

Pursuant to ORS 468.125, the Department is not required to provide advance

notice prior to assessing a civil penalty for a violation of hazardous

waste program reqUirements (ORS 459.410 to 459.450 and 459.460 to 459.690).

As indicated in Section 4 of these guidelines, civil penalties normally

Will be assessed against persons wi;h Class I violations and may be

assessed against persons Who fail to comply with a Notice of Intent or

Department order.

Assessments of civil penalty grant the vj jlator the right to request a

contested case hearing before the Environmental Quality Commission or its

hearings officer. Under certain circumstances, the civil penalty may be

mitigated in whole or in part by the Commission. Contested case decisions

may be appealed to the Commission and are subject to judicial review.

Failure to comply following an assessment of civil penalty should result in

the assessment of an additional penalty, Department order, site operation

shutdown order or referral to Department of Justice for court action.

Department Order means an order iss~ed by the Department pursuant to ORS

459.660. Whenever the Department believes a violation has occurred, it may

investigate and issue an order requiring changes or compliance without

notice or hearing. The Order takes effect 20 days after the date of its

issuance, unless a hearing is· requested before the 20-day period has

expired. .

If the Order is appealed, a contested case hearing is held by the

Environmental Quality Commission or its hearing officer and is subject to

judicial review. Failure to comply with the Order is enforceable through

the assessment of civil penalties or criminal action.

Department orders may be used to respond to persons with Class I violations

which require an extended period of time and substantial effort to correct

or persons who do not adequately respond to initial enforcement actions.

Compliance schedules may be included in Orders if appropriate. (See

discussion of Notice of Intent in this section for guidance on compliance

schedules.) In general, the Department's desire in issuing an Order is to

obtain the respondent's consent to the terms of the Order. Therefore, if

it appears likely that an order would be contested, use of a Notice of

Intent to establish compliance requirements may be preferred.

Department orders shall be prepared by the Enforcement Section of Regional

Operations based upon an enforcement ref.erral from the Regional Manager.

Department orders will require the concurrence of the Manager of the

Hazardous Waste Section and the Administrator of the Hazardous and Solid

Waste Division before being issued by the Director.

ZB4956.2 -1'-
Commission Order means an order issued by the Environmental Quality

Commission pursuant to ORS 459.650. Upon receipt of a complaint made to it

by any person, the Department shall make an investiga~ion to determine if

the operation of any generator, transporter or hazardous waste management

facili ty is unsafe or is in violation of a statute or regulation.

Following the investigation, if the,Department is satisfied that sufficient

grounds exist to justify a hearing, it shall give 10 days' written notice

of the time and place of the hearing. Within 30 days of the hearing, the

Commission shall make a specific order as it considers necessary. Any

Order is subject to judicial review. Failure to follow the order, once

final, may subject the violator to a Notice of Intent, assessment of a

civ,il penalty, site operation shutdown order, injunctive relief or criminal

action.

Commission orders are issued by the EQC or its hearing officer following a

hearing. The results of the inspector's investigation will be reviewed by

the Administrator of the Hazardous and Solid Waste Division, the Director

and the Attorney General's Office before a hearing is scheduled for

Commission action. The Department will not ordinarily use this authority

unless initiated by a complaint, since ultimate enforcement of the Order

would revert to an assessment of a civil penalty, site operation shutdown

order, injunctive relief or criminal action.

Site Operation Shutdown Order means an order issued by the 'Department

pursuant to ORS 459.680 without prior notice or hearings. The Department

must establish reasonable cause that a clear and immediate danger to public

health, welfare, safety or the environment eXists from the continued

operation of the activity, or site. The,Order shall be served on the site

superintendent. Within' 24 hours, the- Departmerit must appear-in circuit

court to petition for the equitable relief required to protect public

health, welfare, safety or the environment.

Injunctive Relief means actions or proceedings p~"suant to ORS 459.690 for

equitable remedies to enforce compliance or restrain further violations

whenever it appears to the Department that any person is engaged or about

to engage in any acts or practices that cause or threaten to cause a

substantial violation or threat to public health, safety, welfare or the

environment. No prior administrative hearing is required.

Criminal Action means proceedings under, ORS 459.992(4). Criminal actions

are handled by the local District Attorney for the county in which the

violations occur. Referrals to the local District Attorney by inspectors

shall not occur Without the approval of the Director of the Department.

The Administrators of the Hazardous and Solid Waste Division and Regional

Operations Division shall confer with the Director on the merits of

proceeding with criminal action in lieu of the other administrative

remedies described in this policy. The Attorney General's Office may also

be consulted. The Department may also consider referral of potential

criminal actions to EPA for investigation.

ZB4956.2 -12-
e····

The following types of cases or situations may warrant criminal action:

(1) a hazardous waste handler violates the terms of a Notice of Intent,

Commission order or Department order and does not respond to the assessment

of a civil penalty; (2) a hazardous waste handler is a frequent and

recalcitrant Violator; (3) long-term specific conduct by a violator is to

be compelleq; (4) deterrence of others situated similarly to the violator

is a main goal; and (5) intentional disposal of hazardous waste at an

unauthorized disposal site.

Occasionally, local agencies (i.e., city police or fire, county sheriff)

may be involved in investigating hazardous waste violations along with the

state. Local government has the right and opportunity to seek a criminal

action with or without DEQ concurrence and/or knowledge.

SECTION 6

PRIORITIES

All violations documented will be addressed with an appropriate enforcement

response. In general, the Department's priority targets will be, 'first,

Class I Violations, then Class II Violations, and then Class III

Violations.

Within each category of violations, enforcement priorities may need to be

set. In doing so, Department staff should consider the following factors:

o The magnitude and imminence of the actual or potential public health

or environmental threat.:

o The duration of the handlers noncompliance -- if two similar

noncompliance scenarios eXist, the one which has existed longer

should generally be addressed first.

o Length of time needed to achieve compliance -- violators requiring

long-term remedies should be addressed first, except for imminent

threat situations.

o Strength of case -- when all other considerations are equal, the

stronger case should receive higher priority.

o Expression of uncooperativeness or willingness by violator to

correct violations.

o Potential for the enforcement action to set an important precedent.

ZB4956.2 -13-
SECTION 7

ASSESSMENT OF ADMINISTRATIVE CIVIL PENALTIES

As indicated in previous sections of these enforcement guidelines,

assessment of civil penalties by the DEQ Director is one enforcement tool

available to DEQ. A civil penalty may be an appropriate enforcement

response depending upon the nature of a violation and its surrounding

circumstances. •

This section focuses on considerations which may be relevant when

determining the proper amount of a civil penalty once a decision has been

made that a civil ·penalty is the appropriate enforcement remedy to pursue.

Relationshio to Statutory and Regulatory Provisions.

These gUidelines do not substitute for consideration of existing provisions

in Oregon Revised Statutes (DRS) and Oregon Administrati~e Rules (OAR)

pertaining to assessment of civil penalties. This document does not

establish any new authorities or require any action be taken which

conflicts with provisions of existing state law. The guidelines are

intended solely to help staff understand the applicable ORS and OAR

provisions.

ORS 459.995 establishes the l1ability of hazardous waste violators for

civil penalties. In· particular, ORS 459.995(2) states·that:

"(2) In addition to any other penalty provided by law, any person who

violates ORS 459.410· to 459.450 and 459.460 to 459.690, a license

condition or any commission rule or order pertaining to the

generation, treatment, storage, disposal or transportation by air

or water of hazardous waste, as defined by ORS 459.410, shall

incur a civil penalty not to exceed $10,000 for each day of the

violation."

Additionally, ORS 459.995(3) states that:

"(3) The civil penalty authorized by subsections (1) and (2) of this

section shall be established, imposed, collected and appealed in

the same manner as civil penalties are established, imposed and

collected under ORS 448.305, 454.010 to 454.040, 454.205 to

454.255, 454.405 454.425,454.505 to 454.535, 454.605 to 454.745

and ORS chapter 468."

Due to the references in ORS 459.995(3), Chapter 459 does not stand alone.

The principal reference for consideration is ORS Chapter 468 which, in

part, authorizes establishment of civil penalty schedules, and specifies

considerations for imposing penalties (see ORS 468.130,468.135, and

468.140). These statutory provisions have been codified by the Commission

and comprise Division 12 of OAR Chapter 340. OAR 340-12-068 includes a

hazardous waste management schedule of civil penalties. OAR 340-12-045

identifies factors which the Director may consider in establishing the

amount of a civil penalty.

ZB4956.2 -14-
•

Summary of Penalty Determination

When a penalty is to be assessed by the Director, penalty determination can

be thought of as proceeding along a component approach. First, a "gravitybased" penalty component is determined. Next, the economic benefit of

noncompliance may be calculated if it is expected to be significant.

Finally, other relevant factors of OAR 340-12-045 may be considered, where

such information is available, to adjust the penalty.

The graVity-based component of a penalty considers "The gravity and

magnitude of the" violation" factor of OAR 340-12-045. This factor can be

displayed as a matrix (discussed later).

Where a vi"olator has derived significant savings by its failure to comply

with hazardous waste requirements, the Director may calculate the amount of"

economic benefit from noncompliance gained by the violator and add this

amount to the gravity-based penalty. Consideration of the economic benefit

of noncompliance is provided for in OAR 340-12-045(1)(j), i.e., "any other

relevant factor."

"The Director may adjust the gravity-based penalty upwards or downwards to

reflect consideration of other factors as provided for in OAR 340-12-045,

if sufficient information is available. These factors include:

(a) Whether the respondent has committed any prior violation,

regardless of whether or not any administrative, civil, or

criminal proceeding was commenced therefore;

(b) The hi"story of the respondent in taking all feasible steps or

procedures necessary or appropriate to correct any violation;

(c) The economic and financial conditions of the respondent;

(d) Whether the violation was repeated or continuous;

(e) Whether a cause of the violation was an unavoidable accacent , or

negligence, or an intentional act of the respondent;

(f) The opportunity and degree of difficulty to correct the

violation;

(g) The respondent's cooperativeness and efforts to correct the

violation for which the penalty is to be assessed;

(h) The cost to the Department of investigation and correction of the

cited violation prior to the time the Department receiv.es

respondent's answer to the written notice of assessment of civil

penalty; or

(i) Any other relevant factor.

A penalty may be calculated for each separate and independent violation

documented by the Department. In no case can the total penalty for any

single Violation exceed the statutory maximum of $10,000 per day.

ZB4956.2 -15-
Determination of the Gravity-Based Penalty

In de t.ermi ni.ng the gravity-based component of a civil penalty, the

following aspects of a violation are considered:

o Potential for harm; and

o Extent of deviation from a statutory or regulatory requirement.

Potential for Harm

The Department's requirements for hazardous waste handlers were promulgated

in order to prevent harm to human health and the environment. Thus,

noncompliance could create actual harm or a potential for harm.

The potential for harm in a particular situation can be classified as

major, moderate, or minor. The degree of potential harm represented by

each category is defined as:

o MAJOR - Violation poses a major adverse effect on public

health or the environment.

o l40DERATE - The violation poses a moderate adverse effect on

public health or the environment.

o MINOR - The violation poses a mL~or adverse effect on public

health or the environment.

Extent of Deviation from ReqUirement

The "extent of deviation" from the Department's statutes or regulatory

requirements (i.e., magnitude of violation) is an important factor in

determining the amount of a civil penalty. Violators may be substantially

in compliance with the provisions of the requirement or they may have

totally disregarded the requirement (or a point in between). As with

potential for harm, extent of deviation may be either major, moderate, or

minor. In determining the extent of deviation, the folloWing definitions

should be used:

o MAJOR - the violator deviates significantly from the requirements

of the regulation or statute to such an extent that almost none

of the requirements are met.

o MODERATE - the violator deviates from the requirements of the

regUlation or statute, but some of the requirements are

implemented as intended.

o MINOR - the violator deviates somewhat from the regulatory or

statutory requirements but most of the requirements are met.

ZB4956.2 -16-
Gravity-Based Penalty Matrix

Consideration of a violation's "gravity and magnitude" may be facilitated

by referring to a matrix whose two axes are; 1) the potential for harm, and

2) the extent of deviation from a requirement. The matrix has nine cells,

each containing a penalty range. The specific cell is chosen after

determining which category (major, moderate or minor) is appropriate for

the potential for harm factor, and which category is appropriate for the

extent of deviation factor. The complete matrix is illustrated below:

Extent of Deviation from Requirement

Potential

for

Harm

MAJOR MODERATE HINOR

MAJOR $10,000 $ 7,999 $ 5,999

to to to

8.000 6.000 4.400

MODERATE $ 4,399 $ 3,199 $1 ,999

to to to , 200 2 000 1.200

MINOR 1,199 599 199

to to to

600 200 100

The highest cell (major potential for harm/major extent of deviation) is

limited by the maximum statutory penalty allowance of $10,000 per day of

violation.

Assessing Multiple Penalties

In certain situations, a particular violator may have violated several DEQ

hazardous waste rules. A separate penalty may be calculated for each

violation that results from an independent act (or failure to act) by the

violator and is substantially distinguishable from any other violation for

which a penalty is to be assessed. A given violation is independent of,

and substantially distinguishable from, any other violation when it

requires an el~ent of proof not needed by the others. In many cases,

violations of different rules constitute independent and substantially

distinguishable violations.

For example, failure to implement a groundwater monitoring program and

failure to have a written closure plan are violations which result from

different sets of circumstances and which pose separate risks. In the case

of a firm which has violated both of these rules, a separate count would be

charged for each violation. For penalty purposes, each of the violations

would be evaluated separately and the amounts totalled.

ZB4956.2 -17-
e'

It is also possible that 9ifferent violations of the same rule could

constitute independent and substantially distinguishable violations. For

example, there are two separate violations in the case of a firm which has

open containers of hazardous waste in its storage area and which also

ruptured different hazardous waste containers while coving them on site.

The violations result from two sets of circumstances (improper storage and

improper handling) and pose separate and distinct risks. In this

situation, two violations with two separate penalties would be appropriate.

For penalty purposes, each of the violations would be assessed separately

and the amounts totalled.

Multiple penalties also may be assessed where a person has violated the

same requirement in substantially different locations. An example of this

'type of violation is failure to clean up hazardous waste discharged during

transportation. A transporter who did not clean up waste discharged in two

separate locations during the same trip should be charged with two

violations. In these situations, the separate locations present separate

and distinct risks to public health and the environment. ThUS, separate

penalty assessments are justified.

In general, multiple penalties would not be appropriate where the

violations are not independent or substantially distinguishable. Where a

violation derives from or merely restates another violation, a separate

penalty is not warranted. For example, if an owner/operator of a storage

facility failed to specify in the waste analysis plan the parameters for

which each hazardous waste will be analyzed and failed to specify the

frequency with which the initial ,analysis of the waste "will be repeated,

the owner/operator has violated the requirement that they develop an

adequate waste analysis plan. The violatioQs result from the same factual

event (failure to develop an adequate plan), and pose one risk (storing

waste improperly due to inadequate analysis). In this situation, both

requirements violated would be cited in the cocplaint, but one penalty,

rather tha~ two, would be assessed. The fact that two requirements were

violated may be taken into account in choosing higher "potential for harm~

and "extent of deviation" categories on the penalty matrix.

Assessing Multi-Day Violations

The Director has authority to assess civil penalties of up to $10,000 per

violation per day, with the potential of assessing each day of

noncompliance as a separate violation. Multi-day penalties would generally

be calculated in the case of continuing'flagrant violations. However, per

day assessment may be appropriate in other cases.

In the case of continuing violations, the Director has the authority to

calculate penalties based on the number of ,days of documented violation

since the effective date of the requirement and up to the date of coming

into compliance. The gravity-based penalty derived from the penalty matrix

may be multiplied by the number of days of documented violation, when a

decision has been made to assess for multi-day violations. -

ZB4956.2 -18-
••

Economic Benefit from Noncompliance

The Director may consider the economic benefit of noncompliance to a

violator when assessing penalties. An "economic benefit component" may be

calculated and added to the gravity-based component of a penalty when a

violator acquires a significant economic benefit from violating state . hazardous waste program requirements. (The total penalty cannot exceed

$10,000 per violation per day.)

The following regulatory areas are candidates for an economic benefit

analysis:

o Groundwater monitoring

o Financial requirements

o Closure/post-closure

o Waste determination

o Waste analysis

o Clean-up. of discharge

o Part B application submittal

o Disposal at unauthorized location

Two types of economic benefits from noncompliance may occur:

o Benefit from delayed costs; and

o Benefit from avoided costs.

Delayed costs are expenditures which have been deferred by the violator's fai~ure· to comply with the requirements. The violator eventua~ly will have

to spend tne money in order to achieve compliance. Delayed costs are the

equivalent of capital cost~. Examples of violations which result in

savings from delayed costs are:

o Failure to install a groundwater monitoring program;

o Failure to submit a Part B permit application; and

o Failure to develop a waste analysis plan.

Avoided costs are expenditures which are nullified by the violator's

failure to comply. These costs will never be incurred. Avoided costs are

the equivalent of operating and maintenance, costs. Examples of violations

which result in savings from avoided costs are:

o Failure to perform annual and semi-annual groundwater monitorin~

sampling and analysis;

o Failure to follow the approved closure plan in .removing waste

from a facility, Where removal is not now possible; and

o Failure to perform waste analysis before adding waste to tanks, .

waste piles, incinerators, etc •

Z~956.2 -19-
Because the savings that are derived from delayed costs differ froc those

derived from avoided costs, the economic benefit from delayed and avoided

costs are calculated in a different manner. Guidance on calculating

delayed ana avoided costs is presented in Appendix I.

Adjustment Factors

As mentioned earlier, the gravity and magnitude of the violation is

considered in determining the gravity-based component of a penalty. The

reasons tne violation was committed, the intent of the violator, and other

potentially relevant factors are not considered in choosing the appropriate

penalty from the matrix. However, OAR 340-12-045(1) identif.ies relevant

factors which the Director may consider in establishing the amount of a'

civil penalty.

The adjustment factors can increase, decrease or have no effect on the

penalty amount to be assessed to the violator. However, no upward

adjustment can result in a penalty greater than the statutory maximUQ of

$10,000 per day of violation. Adjustment of a penalty may take place after

determining the gravity-based component of the penalty but prior to issuing

the penalty assessment, if the necessary information is available to the

Director.

In general, these adjustment factors are applied to the gravity-based

penalty component derived from the matrix, and not to the economic benefit

component (if calculated).

Application of the adjustment factors. is cumulative, i.e., more than one

factor may apply in a case.

(1) Cooperativeness and efforts to correct the violation.

Cooperativeness can be demonstrated by a violator promptly reporting its

noncompliance. Assuming such self-reporting is not required by law,

regulation, or permit, this behavior may result in adjustment of the

penalty. Prompt correction of environmental problems also can indicate a

violator's cooperativeness. Lack of cooperativeness, on the other hand,

can result in an upward adjustment of the penalty. No downward adjustment

would be made if the efforts to comply primarily consist of cocing into

compliance without demonstrated promptness.

(2) Degree of willfulness, negligence, and/or nonavoidability

There may be instances of culpability for "knowing" violations which do not

meet the criteria for criminal action. In cases wher,e administrative civil

penalties are sought for actions of this type, the penalty may be adjusted

upward for willfulness and/or negligence. Conversely, there may be

instances where penalty adjustment downward may be justified based on the

lack of willfulness or negligence, or the presence of unavoidable

circumstances.

ZB495b .2 -20-
e- In assessing the degree of willfulness and/or negligence, the following

factors may be considered, as well as any others deemed appropriate:

o How much control the violator had over the events constituting the

violation;

o The foreseeability of the events constituting the violation;

o Whether the violator took reasonable precautions against the events

constituting the violation;

o Whether the violator knew or should have known of the hazards

associated with the conduct;

o Whether the violator knew of the legal requirement which was

violated.

The amount of control which the violator had over how qUickly the violation

was remedied also is relevant in certain circumstances. Specifically, if

correction of the environmental problem was delayed by factors which the

violator can clearly show were not reasonably forseeable and out of their

control, the penalty may be reduced.

(3) Past Compliance History

Where a party preViously has violated hazardous waste requirements at the

same or a different site, this is usually evidence that the party was not

deterred by the previous enforcement response. Unless the previous

violation was caused by factors entirely out of the-control of the.

Violator, this is an indication that the penalty should be adjusted

upwards. If a violator otherwise has a record of substantial compliance,

the-penalty may be adjusted downward.

Some of the factors to be considered are the follOWing:

0 How similar the previous violation was;

0 How recent the previous violation was;

0 The number of previous violations;

0 The violator's response to previous violation(s) in .regard to

correction of problem.

A violation generally should be considered "similar" if the Department's

previous enforcement response should have alerted the party to a particular

type of compliance problem.

(4) Economic and financial conditions of the violator.

The Director generally does not intend to assess penalties that are clearly

beyond the ability of the violator to pay. Therefore, the Director may

consider the economic and financial conditions of a violator.

ZB4956.2 -21-
When it is determined that a violator cannot afford the penalty prescribed

by these guidelines, or that payment of all or a portion of the penalty

will preclude the violator from achieving compliance or from carrying out

remedial measures which DEQ deems to be more important than the deterrence

effect of the penalty (e.g.! payment of penalty would preclude proper

closure/post-closure), the folloWing options may be considered:

o Consider a delayed payment schedule. Such a schedule might even be

contingent upon an increase in sales or some other indicator of

improved business.

o Consider an installment payment plan with interest.

o Consider straight penalty reductions as a last recourse •

. The amount of any downward adjustment of the penalty is dependent on the

individual financial facts of the case.

(5) . Other relevant factors

These gUidelines allow an adjustment for other relevant factors which may

arise on a case-by-case basis. The Director may make adjustments to the

gravity-based penalty for such reaSons.

ZB4956.2 -~-
•

••

APPENDIX I

CALCULATING ECONOMIC BENEFIT FROM NONCOMPLIANCE

The following formula is provided to help calculate the economic benefit

component:

Economic

Benefit = Avoided Costs x (1-T) + (Delayed Costs x Interest Rate)

In the above formula, T represents the firm's marginal state tax rate.

Interest is calculated by using the interest rate charged.by the State

Department of Revenue for delinquent accounts.

The economic benefit formula provides a reasonable estimate of the economic

benefit of noncompliance. If a violator believes that the economic benefit

derived from noncompliance differs from the estimated amount, it may

present information documenting its actual savings to the Director at the

settlement stage or to the Environmental Quality Commission at the hearing

stage.

For avoided costs, the economic benefit equals the cost of complying with

the requirement, adjusted to reflect income tax effects on the violator.

The economic benefit for delayed costs consists of the amount of interest

on the unspent money that reasonably could have been earned by the violator

during noncompliance •

ZB4956.2 -23-
APPENDIX II

EXAMPLES OF CLASSIFICATION OF HAZARDOUS WASTE VIOLATIONS

The classifications listed below are examples of the types of

violations which may be classified as either Class I, II or III. This list

is illustrative, not exhaustive.

Example

Disposing of hazardous waste at a location other than

at a permitted hazardous waste management facility.

Failure to report a'discharge of hazardous waste and

take immediate action to protect human health and the

environment.

Construction ana operation of a new treatment, storage

or disposal facility without a permit.

Installation of grossly inadequate groundwater

monitoring wells such that groundwater samples

are not representative of background quality in the

uppermost aquifer near the facility.

Failure to install, any groundwater monitoribg wells.,

Installation of ,grossly inadequate groundwater monitoring wells such that they do not immediately detect any

statistically significant amounts of hazardous waste

or hazardous waste constituents that migrate from the

waste management area to the uppermost aquifer.

Failure 'to develop and follow a groundwater sampling

and analysis plan.

Failure to develop a complete and written closure

plan.

Failure of a closure plan to describe the steps needed

to decontaminate facility equipment during closure.

Failure of a tank closure plan to provide for the

removal of all hazardous waste and hazardous waste

residues from tanks, discharge control equipment ~~d

discharge confinement structures.

Failure of a disposal facility owner/operator to

have a written post-closure plan.

Violation

Class

I

I

I

I

I

I

I

I

r

I

I

ZE4956.2 -24-
e.' Example

Failure of a post-closure plan t~ identify

planned groundwater monitoring activities or

activities to ensure the integrity of the cap

and final cover, during the post-closure period.

Failure to prepare a written estimate of the cost

of closing a facility in accordance with the

facility's closure plan.

Failure to establish and maintain a financial

assurance mechanism for closure of the facility.

Failure of a disposal facility owner/operator to

prepare a written estimate of the cost of postclosure monitoring and maintenance of the facility

in accordance with the facility's post-closure plan.

Failure to establish and maintain a financial

assurance mechanism for post-closure care of the

facility.

Violation

Class

I

I

I

I

I

Ie·

•.,

Note: 'The following examples of Class II violations are not absolutely

Class II in all cases. Depending on individual circumstances, these

violations could be classified as·Class I if they create a likelihood for

harm or otherwise meet the Class I criteria identified in 'Section 3.

Failure to determine if a solid .waste is a hazardous II

waste.

Failure to use a manifest for off-site shipments of II

hazardous waste.

Failure to designate on the manifest an authorized II

storage, treatment, disposal or reclamation facility.

Exceeding the designated time limit for on-site II

accumulation of hazardous wastes without receiving a

permit, qualifying for interim status, or receiving an

emergency extension.

Failure to mark each container with the words "Hazardous II

Waste" or with the a9cumulation date.

Failure to comply with the preparedness and prevention II

requirements of Subpart C of 40 CFR Part 265.

Storage of wastes in oontainers that are not in good II

oondition or have begun to leak.

Failure to submit a manifest exception report. II

ZB4956.2 -25-
Example

Violation

Class

Failure to develop and follow a written inspection II

schedule.

Failure to remedy equipment deterioration or malfunction II

revealed by an inspection.

Failure to retain a copy of the manifest. II

Failure to take precautions to prevent accidental II

ignition or reaction .of ignitable or reactive hazardous

waste.

Failure of owner/operator to submit a timely and c~mplete III

Part B permit application.

Failure to completely fill out a manifest. III

Failure to submit a quarterly report of all off-site III

shipments of hazardous waste.

Failure to maintain personnel training documents and III

records.

Failure to maintain a copy of the closure plan at

the facility.

Failure to provide required notice to DEQ of foreign

shipments of waste.

III

III

... :"..:

Z34956.2 -26-
Appendix K

STATE OF OREGON

DEPARTMENT OF ENVIRONMENTAL OUALITY INTEROFFICE MEMO

Ed Woods, NWR DATE: September 15, 1988

Dave St. Louis, WVR.

Gary Grimes, SWR

Bruce Hammon, ER

John Hector, CR

Jan Whitworth, Hazardous Waste Section

Van Kollias, Enforcement Section

Larry Edelman, Department of Justice

Brett McKnight, Hazardous Waste Section

Kathi Futornick" Hazardous Waste Section

'.' . ;/,., ...... Tom Bispham, 'Regional Operations Div. Administrator and

Stephanie Hallock, Hazardous and Solid Waste Div. Administrator

FROM:

TO:

SUBJECT: Changing Procedures in Hazardous Waste Enforcem~nt

In response to Fred·Hansen's directive to streamline enforcement and in

response to enforcement changes recommended by the Department of Justice, a

work group consisting of Jan Whitworth, Ss:ndy Anderson, Larry Edelman,

Van Kollias and Tom Bispham met on several occasions earlier this year to

develop changes to the RCRA enforcement procedures. As a result, a set of

hazardous waste administrative enforcement documents '(enclosed) was

developed which represents a series of escalating enforcement actions

including a Regional Notice of Noncompliance, a Notice of Violation and

Compliance Order, and Assessment of Civil Penalty.

We have: 1) eliminated the hazardous waste Notice of Intent to Assess Civil

Penalty (NOI) , as the NOI is not required by statute for hazardous waste

violations, 2) streamlined the format for each type of action, 3) prepared a

sample cover letter which standardizes the wording, and 4) replaced the

Regional Notice of Violation with a Notice of Noncompliance to avoid name

confusion between the Regional Notice of Violation and the new Notice of

Violation and Compliance Order.

A Notice of Violation and Compliance Order will replace the NOI in hazardous

waste actions: The Department will still be using the NOI in air, water,

solid waste and other program areas where it is required by statute. The

NOI is not an order and, therefore, it is not appealable. The Notice of

Violation and Compliance Order is an Order and, as such, is appealable to

the. Environmental Quality Commission. The Director will sign the Notice of

Violation and Compliance Order.

e.
Re: Changing Procedures to HW Enforcement

September 15, 1988

Page 2

The following is a comparison summarizing the former and new hazardous waste

enforcement actions:

Former IDl

Enforcement

Action Type

Notice of Violation

(signed by field staff)

Notice of Intent to

Assess Civil Penalty

(signed by Regional

Operations Division

Administrator)

Civil Penalty (signed

-by the Director)

New HW

Enforcement

Action Type

Notice of Noncompliance

(signed by field staff)

Notice of Violation and

Compliance Order (signed

by the Director)

Notice of Violation,

Compliance Order and

Assessment of Civil

Penalty (signed by

Director)

Prepared by -

IDl regional and

program staffs;

reviewed by

Supervisor/

Manager

Enforcement

staff on

referral by

regional staff.

HW program

staff for

headquarter's

cases. Reviewed

by Supervisor/

Manager

Enforcement

staff on

referral by

region or HW

program staff.

Reviewed by

Supervisor/

Manager

Comments

Change in name only.

Changed to a Notice of

Violation and

Compliance Order

issued by the

Director. NOI - no

longer used.

Change in name wi th

addition of Compliance

Order when needed.

The use of the above former actions is described in the Department's 1985

Hazardous Waste Enfoicement Policies and Guidelines. In future use of that

Policy and Guideline, substitute the new enforcement actions for the former

ones, as shown in the table.

In order to reduce confusion between programs, please begin immediately to

change over all Notice of Violation formats to Notice of Noncompliance

formats. Also, please start using the attached example Notices of

Noncompliance for applicable hazardous ~aste generator and ISD facility

violations, so that we will have statewide consistency in that program.

Finally, attached is an enforcement referral guideline for hazardous waste

violations that has been in effect since December 27, 1985. Please continue

using it. Since many formal enforcement actions will now include a

Compliance Order, the information asked for in #6 of that memo is critical.
e·

·e

e·

Re: Changing Procedures to HW Enforcement

September 15, 1988

Page 3

Please share this information with all of your staff in the hazardous waste

program. If you have any questions regarding this memo, please call either

Van Kollias or Tom Bispham.

TRB:vk:b

GB7805
••

.'

CERTIFIED MAIL NO. AC__ (l)__

AC__(2) (ADDRESSEE) __

Re: Notice of Violation and

Compliance Order, HW_ AC__(3) __

Enclosed is a Notice of Violation and Compliance Order relating to the

AC__ (4) __ , inspection by the Department of Environmental Quality at the

C__ (S) __ facility in AC__ (6) __ , Oregon.

The Department found violations of our hazardous waste management "c "e;

A ( "'lioLo.."h'o'1 a-'.:z.at:)V'· regulations. Those violations included C_"_(7)__. S""~"'V"I"~ w -u

The Notice formally cites the violations and orders you to correct the

violations within a specified time period. Appeal procedures are outlined

in the Notice.

Also enclosed is a copy of Oregon Admin~strative Rules, Division 12, Civil

Penalties. Please note that any person violating a hazardous waste rule,

statute or order is liable for a civil penalty of up to $10,000 for each day

of each violation.

If you have any questions with regard to the Notice, or any other matter

concerning compliance with Oregon's hazardous waste laws, please contact

AC__(8)__ of the Department at AC__(9)__ .

Sincerely,

Fred Hansen

Director

FH:AC

AC (DOC. NO.)(NVCO.l 8/31/88)

Enclosure(s)

cc: U.S. Environmental Protection Agency

Oregon Department of Justice

Hazardous Waste Section, DEQ ~C__ (lO) __ Region, DEQ
BEFORE THE ENVIRONMENTAL QUALITY COMMISSION

OF THE STATE OF OREGON

DEPARTMENT OF ENVIRONMENTAL QUALITY,

OF THE STATE OF OREGON,

Department,

v.

)

)

)

)

)

)

)

NOTICE OF VIOLATION AND

COMPLIANCE ORDER

NO. HW-"C (1)

"C_(2)_COUNTY

3.

"C_(3)_, )

)

Respondent. )

This Notice of Violation and Compliance Order is issued by the

Department of Environmental Quality (DEQ) pursuant to Oregon Revised

statutes (ORS) 466.190.

FINDINGS .J' [Na."", eo 4Ntd. -ht.i~ &f ;CKCO,.. ~e>t" Q,~C(1~

1. Respondent "C_(4)_ owns and operates a facility located in

"C_($)_. Oregon.

2. Respondent "C_(6)_

Respondent is involved in the following regulated hazardous waste

. ~CV',,'bti1 I I.

activities "C_(7)_ and generates the following hazardous wastes "C_(8")_, f1>, Was;;

4. Representatives of DEQ conducted a compliance inspection at

'Respondent's facility on·"C_(9)_.

DETERMINATION OF VIOLATIONS

Based upon the above noted inspection, Respondent has violated

provisions of Oregon hazardous waste laws and regulations applicable to the

facility as set forth and incorporated in OAR 340-100-002. Specific

violations includes the following:
COMPLIANCE ORDER

Based upon the foregoing FINDINGS AND VIOLATIONS, Respondent is hereby

ORDERED TO:

1. Immediately initiate actions necessary to come into full

compliance with Oregon's hazardous waste laws.

2.· "C_(ll)_C~ r...J.- p.,/~

3. Notify the Department in writing by "C__(12)__ of Respondent's

intent to comply with .this Order and indicate how compliance will

be achieved.

OPPORTUNITY FOR HEARING

This Notice of Violation and Compliance Order shall become final

unless, within 20 days of issuance of the notice and order, Respondent

requests a hearing before the Environmental Quality Commission pursuant to

ORS 466.190.

The request must be made in writing to the Director, must be rece~ved

by the Director within twenty (20) days from the date of mailing of this

notice (or if not mailed, the date of personal service), and must be

accompanied by a written "Answer" to the allegations contained in this

notice. In the written "Answer", Respondent shall admit or deny each

allegation of ,fact contained in this notice and Respondent shall

affirmatively allege any and all affirmative claims or defenses to

violations and order that Respondent may have and the reasoning in support

thereof.

Following receipt of a request for hearing and an "Answer", Respondent

will be notified of the date, time and place of the h~aring. If Respondent.

fails to file a timely "Answer" or request for hearing, the Order shall

2 - NOTICE OF VIOLATION AND COMPLIANCE ORDER

(NVCO 8/31/88)
ieI .

I

become a final and enforceable order of the Environmental Quality Commission

by operation of law without any further action or proceeding. If the order

becomes final be operation of law, the right to judicial review, if any, is

outlined within ORS 466.190(5).

If violations continue or recur, or if Respondent fails to comply with

the Compliance Order, the Departm~nt may impose civil penalties.

Date Fred Hansen

Director .

•••

3 - NOTICE OF VIOLATION AND COMPLIANCE ORDER

(NVCO 8/31/88)
CERTIFIED MAIL NO. A C__ (l)__

A C__(2) (ADDRESSEE)__

Re: Notice of Violation, Compliance

Ord~r, and Assessment of Civil

Penalty No. HW- AC__(3) __

Enclosed is a Notice of Violation, Compliance Order, and Assessment of Civil

Penalty relating to the A C__ (4) __ , inspection by the Department of

Environmental Quality at the C__ (S) __ facility in AC__ (6) __ , Oregon. The

Compliance Order and Civil Penalty Assessment are a result of hazardous

waste management violations identified during the inspection. Those ~_ht~ALJ

violations included A C__ (7) . C~~~~ Vto-tairp? ~-r...,- •

. A civil penalty of up ~o $10,000 may be assessed for each day of each

violation. I have set your penalty at a total of $AC__(8)__ for the

violations cited in the enclosed notice. In determining the amount of the

penalty, I considered aggravating 'and mit~ting factors which are -/,"c;'.J..-::-7

suuunarized in the NO,tice. A C__ (9) C).JM=£ ti,p ?hr ~"'.4V'~ 'J f&qtJr>J

The penalty is due and payable to the Department. Appeal procedures are

outlined within Paragraph AC__ (lO)__ of the enclosed notice. If you fail to

either payor appeal the penalty within 20 days, a Default Order and

Judgment will be entered against you.

The Department looks forward to your cooperation and full compliance with

Oregon's environmental regulations. We are prepared to assist you with

questions regarding rule interpretation or the applicability of specific

regulations to your facility. We expect you to comply with the hazardous

waste reg~lations at all times.

Please be informed that you are liable for additional civil penalties if you

violate the Compliance Order or if you have additional violations of the

hazardous waste regulations.
-e

"c (ADDRESSEE)

"c (NOTICE #)

"c (DATE)

Page 2

If you have any questions about this action , please contact "C__ (ll)__ of

the Department's Enforcement Section at "C__ (12)__ or call our toll-free

call-back number at 1-800-452-4011. .

Sincerely,

Fred HansenDirector

FH:"C

"c (DOC. NO.)(NVCO.2 8/31/88)

Enclosure(s)

cc: U.S. Environmental Protection Agency

Oregon Department of Justice

Hazardous Waste Section, DEQ

"C__(l3)__" ~egion, DEQ·
BEFORE THE ENVIRONMENTAL QUALITY COMMISSION

OF THE STATE OF OREGON

DEPARTMENT OF ENVIRONMENTAL QUALITY,

OF THE STATE OF OREGON,

Department,

v.

)

)

)

)

)

)

)

NOTICE OF VIOLATION,

COMPLIANCE ORDER, AND

ASSESSMENT OF CIVIL PENALTY

NO. HW-"C (1)

"C_(2) COUNTY

2. Respondent

"C_(S)_, Oregon.

"C_(3)_, )

)

Respondent. )..

This Notice of Violation, Compliance Order and Assessment of Civil

Penalty is issued by the Department of Environmental Quality (DEQ) pursuant

to Oregon Revised statutes (ORS) 466.190, 466.880, 468.130; and Oregon

Administrative Rules (OAR) Chapter 340, Divisions 11 and ~2.

FINDINGS

1. Respondent "C_(4)_ owns and. operates a facility located in

4 ["h~ doA {;~.~]

"C_(6)_ [~.~ "-f1u J.

3. Respondent is involved in the following regulated hazardous waste

activities "C_(7)_ L, J and generates the

r- /) 'or+- ~"."""At-:..AI following hazardous wastes "C_(8)_ , ~~

-- 4. Representatives of DEQ conducted a compliance inspection at

Respondent's facility on "C_(9)_.

III

1 - NOTICE OF VIOLATION, COMPLIANCE ORDER, AND ASSESSMENT OF CIVIL PENALTY

(NVCO.3 8/31/88)
DETERMINATION OF VIOLATIONS

Based upon the above noted inspection, Respondent has violated

provisions of Oregon hazardous waste laws and regulations applicable to the

facility as set forth and incorporated in OAR 340-100-002. Specific

violations includes the following:

Based upon the foregoing FINDINGS AND VIOLATIONS, Respondent is hereby

ORDERED TO: .

1.

2.

Immediately.initiate actions necessary to come into full

compliance with Oregon's hazardous waste laws.

3. Notify the Department in writing by ~C__ (12)__ of Respondent'~

intent to comply with this Order and indicate how compliance will

be achieved.

ASSESSMENT OF CIVIL PENALTY

Pursuant to OAR 340-12-068, the Director hereby imposes upon the

Respondent a civil penalty of $~C__ (13)__ for each of the violations cited

in paragraphs ~C__ (14)__ for a total of $~C__ (15)__ in civil penalties.

2 - NOTICE OF VIOLATION, COMPLIANCE ORDER, AND ASSESSMENT OF CIVIL PENALTY

(NVCO.3 8/31/88)
~.

e"

A C__ (16) __ The above cited violations involve aggravating factors which

support the assessment of a civil penalty larger than the minimum

established in the civil penalty schedule. The mitigating and aggravating

factors considered by the Director in establishing the amount of the penalty

are attached hereto and incorporated herein by this reference.

A C_ ( 17)_ The "c i v il penalty assessed against Respondent is the minimum

which may be assessed pursuant to the schedule of civil penalties contained

in OAR Chapter 340, Division 12. In setting this penalty at the minimum

amount, the Director considered the mitigations and aggravating factors

listed in that Division.

The penalties are due and payable immediately upon receipt of this

notice. Respondent's check in the amount of A C_ (18)_ should be made

payable to bState Treasurer, State of Oregonb and should be sent to the

Director of the Department of Environmental Quality. " . "

OPPORTUNITY FOR HEARING

This Notice of Violation, Compliance Order and Assessment of Civil

Penalty sh~ll become final unless, within 20 days of issuance Respondent

requests a hearing before the Environmental Quality Commission pursuant to

ORS 466.190, ORS 468.135(2) and (3); and OAR Chapter 340, Division 11.

The request must be made in writing to the Director, must be received

by the Director within twen~y (20) days from the date of mailing of this

notice (or if not mailed, the date of personal service), and must be

accompanied by a written "Answer" to the allegations. contained in this

notice. In the written "Answer", Respondent shall admit or deny each

allegation of fact contained in this notice and Respondent shall

affirmatively allege any and all affirmative claims or defenses to

3 - NOTICE OF VIOLATION, COMPLIANCE ORDER, AND ASSESSMENT OF CIVIL PENALTY

(NVCO.3 8/31/88)
violations and assessment of any civil penalty that Respondent may have and

the reasoning in support thereof.

If Respondent fails to file a timely "Answer" or request for hearing or

fails to appear at a scheduled hearing, the Director on behalf of the

Environmental Quality Commission may issue a default order and judgment

based upon a prima facie case made on the record, for the relief sought in

this notice. Following receipt of a request for hearing and an "Answer",

Respondent will be notified. of the date, time and place of the hearing.

If violations continue or recur or if Respondent fails to comply with

the Compliance Order, the Director may impose additional civil penalties.

e·

·Date Fred Hansen, Director

Department of Environmental Quality

4 - NOTICE OF VIOLATION, COMPLIANCE ORDER, AND ASSESSMENT OF CIVIL PENALTY

(NVCO.3 8/31/88)
e'

e.

SAKPLE NOTICE OF NON-COMPLIA~CE TO GENERATOR

_______, 1988

CERTIFIED MAIL

RETURN RECEIPT REQUESTED

Facility XYZ

[Generator]

Re: Notice of Non-Compliance

NO.

Dear Mr.

On ,19 ,an authorized representative of the

Department of Environmental Quality conducted a hazardous waste

compliance inspection at your factility in , Oregon.

Th~ inspector noted that there specify the minor

violations. or deviati.ons from the regulations, ~,

Manifests dated were not completely

filled out as required by OAR 340-100-002 and 46 CFR

262.23. In particular, the wastes were not described as

to hazard code.

Please submit a description of the manifested waste to the

Department within 10 days of receipt of this Notice. Failure

to comply with Oreg~nls hazardous waste laws may result i~

add~tional enforcement action including the assessment of civil

penalties.

If you have any questions regarding this Notice,

contact at (503)

Thank you for your cooperation.

Sincerely,

Authorized DEQ Official

ys

2098H
••

SAMPLE NOTICE OF NON-COMPLIANCE TO STORAGE FA~ILITY

_______, 1988

CERTIFIED MAIL

RETURN RECEIPT REQUESTED

Facility ABC

[Storage faci.lity]

Re: Notice of Non-Compliance

No.

Dear Mr.

On , 19 , an authorized representative of

the Department of Environmental Quality conducted a hazardous

waste compliance inspection at your hazardous waste storage

facility in , oreg~n.

The inspector noted that:

·[Here specify the minor violations.or deviations from the

·regulations identified, e.g.,

(1) There was no written schedule for inspection of

monitoring equipment and structural equipment as required

under OAR 340-100-002 and 40 CFR 265.15;

(2) There was no written description of continuing

personnel training as required by OAR 340-100-002 and 40

CFR 265.16.]

Please notify the Department no later than

that these deficiencies have been corrected. Failure to comply

with Oregon's hazardous waste laws may result in additional

enforcement action including the assessment of civil penalties.

If· you have any questions regarding this Notice,

contact at (503)

Thank you for your cooperation.

Sincerely,

Authorized DEQ Offi~ial

ys

2098H
DEPARTMENT OF ENVIRONMENTAL QUALITY INTEROFFICE MEMO

TO:

FRCJo1:

Steve Gardels, ER

Janet Gillaspie, tIWR

Gary Grimes, SWR

Dick Nichols, CR

Dave St. Louis, WVR

Jan Wh1 tworth t HSW

1 ,~

Van Kolllaa \J/

(

DATE: December 27, 1985

.. SUBJEC'1': Enforcement Referrals for Hazardous Waste Violations

We have now had enough experience working with hazardous waste referrals to

know what information we generally need to draft five-day warning and civil

penalty notices in a timely manner. While we appreciate the many welldocumented hazardous waste referrals we have received, work on some recent

referrals has been unnecessarily delayed because of missing or confusing

information. If the follOWing information is included in future referrals,

we should be able to more quickly help you with your enforcement requests:

A brief overview of the company, its operation, the sources of

its hazardous waste; and its compliance history.

2. A copy of any current applicable permit, or a description of the

status (ad~quacy, timeliness) of any pending permit application.

3. A detailed, descriptive list of violations. This should include

citations of specific rules (section and subsection) as Yell as a

brief description of the nature of the violation. For example,

ftthe company violated 40 CFR 265.13(a)(1), by not obtaining a

detailed chemical and physical analysis of its chrome plating

sludge. ft .

4. Evidence that there actually is a violation of a rule or statute.

Each violation needs to be coupled with evidence/facts adequate

to support the allegation that a violation occurred. Describe

where the evidence used to support each alleged violation may be

found in the referral package (e.g., ftSee inspector's memo, page

2, paragraph 3ft or ftSee narrative with photo number fourft or ftSee

Manifest No. 234Sft).

5. The evidence should include, where applicable:

. '. e ·,.r

...;.,/

\

a • The staff memo summarizing the inspection of the company's

hazardous waste management practices. If more than one

staff makes the inspection, each should prepare a memo of

what he or she observed.
. -

...

Enforcement Referrals for Hazardous Waste Violations

December 27, 1985

Page 2

b. Copies of relevant hazardous waste manifests or laboratory

data sheets which establish why the waste is considered a

hazardous waste.

c. Highlight the portions of the documents which auppor-t, the

violation, such as lab results which exceed listed standards

.' or manifests that have missing or incorrect information.

d. Please describe in detail where each sample that exceeded

listed standards was taken, e.g., na sample of waste sludge

from an uncovered barrel at the northeast end of your main

treatment building.n A rough map or sketch of the site

showing sample locations is helpful. .

e. Dated and labelled photographs of the site, if available,

showing any violations that can be documented visually

(e.g., insufficient aisle space, uncovered containers, no

signs posted). Also, key in the photographs to the sketch

of the facility above.

,:-......

.

::/

6. Identity 'what specific action the company must take to correct

its Violations, and indicate the time frame that will be allowed

for corrections' (i.e., number of days to correct starting from

the date the notice is received).

7. For violations involving the unauthorized disposal of hazardous

waste, we need a copy of the tax lot map and ownership records

for the site. These are generally obtainable from the assessor's

office. Also, please indicate the location of the disposal site

on the map. We need this information so we can inform the

property owner that hazardous waste has been disposed of on the

property if the property owner is not the owner/operator of the

facility.

Please give each of your staff that works with the hazardous waste program

a copy of this memo and remind them of the importance of inclUding the

above information with future referrals. During your review and clearance

of enforcement referrals, please confir.m that all nece~sary information is

included before ~ubmitting the referral to Enforcement.

We all want enforcement actions to go out as quickly as possible and so

will appreciate your assistance in providing this information with future

referrals.

Thank you.

LC:b

GB5274

cc: Mike Downs, Hazardous and Solid Waste Division

Fred Bolton, Regional Operations
Appendix L

OREGON ADMINISTRATIVE RULES

CHAPTER 340, DIVISION 12 - DEPARTMENT OF ENVIRONMENTAL QUALITY

DIVISION 12

Consolidation of Proceedings

340-12-035 Notwithstanding that each and every vioNotice Provisions

340-12-010 (DEQ 33. f. 12-17-71. ef. 1-1-72;

Repealed by DEQ 78.

f. 9-6-74. ef. 9-25-74)

Classification and Schedule for Violation of Water Quality

340-12-020 (DEQ 33.1: 12-17-71. ef. 1-1-72;

Repealed by DEQ 78.

f. 9-6-74. ef. 9-25-741

Mitigating and Aggravating Factors

340-12-045 (11. In establishing the amount of a civil

penalty to be assessed. the Director may consider the following factors:

(a) Whether the respondent has committed any prior

violation. regardless of whether or not any administrative.

civil. or criminal proceeding was commenced therefore:

(b) The history of the respondent in taking :lll feasible

steps or 'procedures necessary or appropriate to correct anv

violation:

(c) The economic and financial conditions of me

respondent:

(d) The gravitv and magnitude of the violauon:

(e) Whether the Violation was repeated or continuous:

(f) Whether a cause of the VIolation was an unavoiuaore

accident. or negligence. or an mrenuonal act of the

respondent:

(g) The opporturuty and degree of difficulty :0 correct

the violation:

Ih) The respondent's cooperativeness and efforts to

correct the violation tor which the penalty IS LO be assessed:

Notice of Violation

340-12-040 (I) Except as provided in section (3) ofthis

rule. prior to the assessment of any civil penalty the Department shall serve a Notice of Violation upon the respondent.

Service shall be in accordance with rule 340-1 1-097.

(2) A Notice of Violation shall be in writing. specify the

violation and state that the Department will assess a civ ii

penalty if the violation continues or occurs after tive days

following receipt of the notice.

(3)(a) A Notice of Violation shall nOI be required where

the respondent has otherwise received actual nouce or" the

violauon not less than five days prior LO the violauon for

which a penalty is assessed.

(bl No advance notice. written or actual shall be

required under secuons (11 and (2) of this rule if:

(Ai The act or omission consututing the violation is

intentional:

(8) The violation consists of disposing ofsolid waste or

sewage at an unauthorized disposal site:

(C) The violation consists of constructing a sewage

disposal system without the Department's permit:

(D) The water pollution. air pollution. OT air contarninauon source would normally not be in existence for five davs:

IE) The water pollution. air pollution or air coniarninalion source might leave or be removed trorn the jurisdiction

of the Department: or

(F) The penalty to be imposed is for a violation ofORS

459.410 to 459.450 and 459.460 to 459.690. or rules adopted

or orders or permits issued pursuant thereto.

SIal•.-\Ulh.: ORS Ch. J59 & J/>.'l

Hisl.: DEQ '8. I: 9./>.7~ . .:L 4·~5· 7J: DEQ ~5· ;<IN. f. &:d. 7.;.7Q:DEQ

~~·1984. f. & et, 11-6-64: DEQ !(l.1<l65. (. & cL 12'.:·85

lation is a separate and distinct offense. and in cases of

continuing violation. each day's continuance is a separate

and distinct violation. proceedings for the assessment of·

multiple civii penalties for multiple violations may be consolidated into a single proceeding.

SI:1I. Auth.; ORS Ch. ~68

Hisl.:OEQ 78. C9·/)_7J. ':1: ~·~5·7J

CIVIL PENALTIES

(DEQ 33. f. 12-17-71. ef. 1-1-72;

Repealed by DEQ 78.

f. 9-6-74, ef. 9-25-74]

Introduction

340-12-005

Classiflcation and Schedule for Violation of Air Quality

340-12-015 (DEQ 33. f. 2-17·71. ef. 1-1-72:

Repealed by DEQ 7S.

f. 9-6-74. ef. 9-25- 74]

Classification and Schedule for Violation of Solid Waste

340-12-025 [DEQ 33. f. 12-17-71. ef. 1-1-72:

Repealed by DEQ 78.

f. 9-6-74. ef. 9-25-741

Definitions

340-12-030 Unless otherwise required by context. as

used in this Division:

( 1) "Ccmmissicn" means the Environmental Quality

Commission.

(2) "Director" means the Director ofthe Department or

the Director's authorized deputies or officers.

(3) "Department" means the Department of Environmental Quality. .

(4) "Order" means:

(a) Any action satisfying the definition given in ORS

Chapter 183: or

(b) Any other action so designated in ORS Chapter 454.

459.467. or 468.

(5) "Person" includes individuals. corporations. associations. firms. partnerships, joint stock companies. public and

municipal corporations. political subdivisions. the state and

any agencies thereof. and the Federal Government and any

agencies thereof. .

(6) -Respondent" means the person against whom a

civil penalty is assessed.

(7) "Violation" means a transgression of any statute.

rule. standard. order. license. permit. compliance schedule.

or any pan thereof and includesboth acts and omissions.

Stat...\ulh.: ORS Ch. J/>B

.,

.A: Hisr.: DEQ is. (.<).".7J. cf 4·~5·7J: DEQ ~~·14KJ. I:&: ct. 11·8·;;4 "

·e

I - Div, 12 (November. 1986)
OREGON ADMINISTRATIVE RULES

CHAPTER 340. DIVISION 12 - DEPARTMENT OF ENVIRONMENTAL QUALITY

(i) The cost to the Department of investigation and

correction of the cited violation prior to the time the Department receives respondent's answer to the written notice of

assessment of civil penalty: or

lj) Any other relevant factor.

(~) In imposing a penalty subsequent to a hearing. the

Commission shall consider factors (a), (b). and (c). ofsection

\ I) of this rule. and each other factor cited by the Director.

The Commission may consider any other relevant factor. .

(3) Unless the issue is raised in respondent's answer to

the written notice of assessment of civil penalty, the Commission may presume that the economic and financial conditions of respondent would allow imposition of the penalty'

assessed by the Director. At the hearing, the burden of proof

and the burden of coming forward with evidence regarding

the respondent's economic and financial condition shall be

upon the respondent.

Sun. Auth.; ORS Ch. .l68

Hist., DEQ 78. C ~-6-;4. ef 4·:5·7-1: DEQ ~~·I 484. ,: & ~t: II·ll·ll4

Air Quality Schedule of Civil Penalties

34o-12.()50 ln addition to any liability. duty. or other

penalty provided by law. the Director. or the director of a

rezional air qualitv control authoritv, rnav assess a civil

penalty for any violation pertaining to air Quality by service

of a written notice of assessment of civil penalty upon the

respondent. The amount of such civil penalty shall be

determined'consistent with the following schedule:

(I) Not less than one hundred dollars ($100) nor more

than ten thousand dollars ($10,000) for violation of an order

of the Commission. Department, or regional air Quality

control authority.

(2) Not less than tiftv dollars ($50) nor more than ten

thousand dollars ($10.000) for:

(a) Violating any condition any Air Contaminant Discharge Permit. Hardship Permit. Letter Permit. Indirect

Source Permit. or variance:

(b) Anv violation which causes. contributes to. or threatens the emission or' any air contaminant into the outdoor

atmosphere:

(c) Operating any air. contaminant source without first

obtaining an Air Contaminant Discharge Permit: or

(d) Any unauthorized open burning.

(3) Not less than twenty-five dollars ($25) nor more than

ten thousand dollars ($10.000) for any other violation.

Stal. AUIB.:ORS ('h. -168

His!.: DEQ 78. f. 9-6-74. c( 9-:!5-74: DEQ 5-1980. i. & ef. 1·28080: DEQ

:!:!·1984. f. & cf. 11·8-84

~oise Conrrol Schedule of Civil PenaJties

340-12-052 In addition to any liability, duty, or other

penalty provided by law. the Director may assess a civil

penalty for any violation pertaining to noise control by

service of a written notice ofassessment ofcivil penalty upon

the respondent. The amount of such civil penalty shall be

determined consistent with the following schedule:

( I) Not less than one hundred dollars ($1 om nor more

than five hundred dollars ($500) for violation' of an order of

the Cornrrussion or Depanment.

(2) Not less than fiftv dollars (S50) nor more than live

hundred dollars 1$500) for any violation which causes. substantially contributes to. or will probably cause:

(a) The emission of noise in excess of levels established

by the Commission for any category of noise emission

source; or

(b) Ambient noise at any type of noise sensitive real

property' to exceed the levels established therefor by the

Commission.

(3) Not less than twenty-live dollars (S25) nor mere than

five hundred dollars ($500) for any other violation.

SiaL Autb.: ORS Ch, 467 & 468 .

Hist.: DEQ 101. r. & ef 10-1·75: DEQ :!:!-1984. r. & cf. 11-8-84

Water Pollution Schedule of Civil Penalties

340-12'()55 In addition to any liability, duty. or other

penalty provided by law..the Director may assess a civil

penalty for any violation relating to water pollution by

service ofa written notice of assessment ofcivil penalty upon

the respondent. The amount of such civil penalty shall be

determined consistent with the following schedule:

(I) Not less than one hundred dollars ($ 1001 nor more

than ten thousand dollars 1$10.000) for anv .... iolarion or an

order of the Commission or Department.

(2) Not less than fifty dollars (S50) nor more than ten

thousand dollars ($10.000l for:

(a) Violating any condition of any National Pollutant

Discharge Elimination System (NPDES) Permit or Water

Pollution Control Facilities (WPCF) Permit:

(b) Any violation which causes. contributes to. or threatens the discharge of a waste into any waters of the state or

causes pollution of any waters of the state:

(c) Any discharge of wastewater or operation of a disposal system without first obtaining a National Pollutant

Discharge Elimination System (NPDES) Permit or Water

Pollution Control Facilities (WPCF) Permit.

(3) Not less than twenty-five dollars ($25) nor more than

ten thousand dollars (510.000) for any other violation.

(4)(a) In addition to any penalty which may be asessed

pursuant to sections ( I) through (3) of this rule. any person

who intentionally causes or permits the discharge of oil into

the waters of the state shall incur a civil penalty of not less

than one thousand dollars ($l.OOOl nor more than twenty

thousand dollars ($20.000) for each violation.

(b) In addition to any penalty which may be assessed

pursuant to sections (I) through (3) of this rule. any person

who negligently causes or permits the discharge ofoil into the

waters of the state shall incur a civil penalty 01' not less than

five hundred dollars ($5001 nor more than twentv thousand

dollars ($20.000) for each violation. .

Stal. Autb.: ORS Ch. 468

Hisl.: DEQ 78. r. 9-6-74. er. lj·25-74: DEQ ~1·1984. f. & ef I I·~·X-l: DEl)

17.1986. f. & cf. <1·11>-86

On-Site Sewage Disposal Systems Schedule of Civil Penalties

34o-12.()60 In addition to any liability. duty, or other

penalty provided by law. the Director may assess a civil

penalty tor any violation pertaining to on-site sewage disposal systems by service of a written notice of assessment of

civil penalty upon the respondent. The amount of such civil

penalty shall be determined consistent with the following

schedule:

( 1) No less than one hundred dollars ($ 100) nor more

than.five hundred dollars ($500) upon any person who:

.(

,

i

'-.

(November. 1986) 2 - Div. 12
OREGON ADMINISTRATIVE RULES

CHAPTER 340, DIVISION 12 - DEPARTMENT OF ENVIRONMENTAL QUALITY

(a) Violates a final order of the Commission requiring

remedial action:

tb) Violates an order of the Commission limiting or

prohibiting installation of on-site sewage disposal systems in

an area:

(c) Performs. or advertises or represents one's self as

being in the business ofpertorming, sewage disposal services.

without obtaining and maintaining a current license from the

Department. except as provided by statute or rule:

(d) Installs or causes to be installed a subsurface alternative or experimental sewage disposal system or any part

thereof. without first Obtaining a permit from the Agent:

(e) Fails to obtain a permit from the Agent within three

days after beginning emergency repairs on a subsurface.

alternative or experimental sewage disposal system.

(f) Disposes ofseptic tank. holding tank. Chemical toilet.

privy or other treatment facility sludges 'in a manner or

location not authorized by the Department:

(g) Connects or reconnects the sewage plumbing from

any dwelling or commercial facility to an existing system

without tirst obtaining an Authorization Notice from the

Agent:

(h) Installs or causes to be installed a nonwater-carried

waste disposal facility without first obtaining written

approval from the Agent therefor:

.Ii) Operates or uses an on-site sewage disposal system

which is failing-bydischarging sewage or septic tank effluent

onto the ground surface or into surface 'public waters:

(j) As a licensed sewage disposal service worker. performs any sewage disposal service work in violation of the

rules of the Department.

(2) Not less than twentv-five dollars ($25) nor more than

five hundred dollars ($500) upon any person who:

(a) Installs or causes to be installed an on-site sewage

disposal system. or any part thereof which 'fails to meet the

requirements for satisfactory completion within thirty (30)

days after written notification or posting of a Correction

Notice at the site;

(b) Operates or uses a nonwater-carried waste disposal

facility without first obtaining a letter of authorization from

the Agent therefore:

(c) Operates or uses a newly constructed. altered or

repaired on-site sewage disposal system. or part thereof.

without first Obtaining a Certificate of Satisfactory Completion from the Agent. except as provided by statute or rule:

td) Fails to connect all plumbing fixtures from which

sewage is or may be discharged to a Department approved

system:

(e) Commits any other violation pertaining to on-site

sewage disposal systems:

SIal. AUlh~ ORS Ch, J68

Hisl.: DEQ 78. f. 9-6-7J . ef 9·25·7J: DEQ ~1981. t. & ef. 2-6-81: DEQ

22·11/84. f. & ef I 1·8-114

Solid Waste Management Schedule of Civil Penalties

340-12-665 In addition to anv liabiiitv, dutv. or other

penalty provided by law. the Director may assess a civil

penalty for any violation pertaining to solid waste management by service of a written notice of assessment of civil

penalty upon the respondent. The amount of such civil

penalty shall be determined consistent with the following

schedule:

( I) Not less than one hundred dollars ($1 OOl nor more

than live hundred dollars ($ 500) for violation of an order of

the Commission or Department.

(2) Not less than fiftv dollars ($50) nor more than five

hundred dollars ($5001 for:

(a I Disposing of solid waste at an unauthorized site:

(bl Establishing. operating or maintaining a solid waste

disposal site without first obtaining a Solid Waste Disposal

Permit:

(c) Violating any condition of any Solid Waste Disposal

Permit or variance:

(3) Not less than twenty-five dollars ($25) nor more than

five hundred dollars ($5001 for any other Violation,

SIal. AUlh.:ORS Ch. J5'l

Hisl.: DEQ 18. f. '1-6.7J. ef 9·25·7J: OEQ I·IQ~:. r. & d. I·:~·~:: DEQ

:~. I'l~4. I: & d I 1.~.8-l.

Hazardous Waste :\Iana~emenl Schedule of Civil Penalties

340-12-068 In addition to any liabilitv. duty. or other

penalty provided by law. the Director may assess a Civil

penalty for any violation pertaining to hazardous waste

management by service of a written Notice at".Assessment of

Civil Penalty upon the respondent. The amount ofsuch civil

penalty shall be determined consistent with the following

schedule:

("Il Not less than two thousand five hundred dollars

($2.500) nor more than ten thousand dollars ($10.000l" for

each day of the violation upon any person who:

(a) Establishes. constructs or operates a geographical site

in which or upon which hazardous wastes are disposed

without first obtaining a license from the Commission,

(b) Disposes of a hazardous waste at anv location other

than at a licensed hazardous waste disposal site.

(c: Fails to Immediately collect. remove or treat a

hazardous waste or substance as required bv ORS "+06.205

and OAR Chapter 340 Division 108. .

td) Is an owner or operator of a hazardous waste surface

impoundment. landfill. land treatment or waste pile facility

and tails to comply with any ofthe following:

(A) The groundwater monuoring and protection

requirements of Subpart F of 40 eFR Part 264 or Part 265:

(8) The closure plan requirements of Subpart G of 40

CFR Part 264 or Part 265:

(C) The post-closure plan requirements ofSubpart G of

40 CFR Part 264 or Part 265:

(D) The closure cost estimate requirements of Subpart

H of 40 CFR Part 264 or Part 265:

(E) The post-closure COSt estimate requirements of Subpart H of 40 CFR Part 264 or Pan 265:

(F) The financial assurance for closure requirements of

Subpart H of 40 CFR part 264 or Part 265:

(0) The financial assurance for post-closure care

requirements ofSubpart H of.w CFR Part 264 or Part 265:

or

! HI The ::nJr1('lJi ::~hii1t~ rccuircmcrus ,·,(Suop:lrt f-tlJf

40 CFR Part 264 or Part 205. .

(2) Not less than one thousand dollars ($1.000) nor more

than ten thousand dollars (S 10.000) (or each dav ot rhe

violation upon anv person who: .

(a I Establishes. constructs or operates a geographical site

or facility upon which. or in which. hazardous wastes are

3 • Div. 12 (November. 1986)
OREGON ADMINISTRATIVE RULES

CHAPTER 340. DIVISION 12 - DEPARTMENT OF ENVIRONMEl\iTAL QUALITY

stored or treated without first obtaining a license from the

Department.

(b) Violates a Special Condition or Environmental

Monitoring Condition of a hazardous waste management

facility license.

(c) Dilutes a hazardous waste for the purpose of

declassifying it.

(d) Ships hazardous waste with a transporter that is not

in compliance with OAR Chapter 860. Division 36 and

Division 46 or OAR Chapter 340. Division 103 or to a

hazardous waste management facility that is not in compliance with OAR Chapter 340. Divisions 100 thru 106.

(e) Ships hazardous waste without a manifest.

(f) Ships hazardous waste without containerizing and

marking or labeling such waste in compliance with OAR

Chapter 340. Division 102.

(g) Is an owner or operator of a hazardous waste storage

or treatment facility and fails to comply with any of the

following:

(,l.) The closure plan requirements of Subpart G of 40

CFR Part 264 or Part 265:

(B) The closure cost estimate requirements ofSubpart H

of 40 CFR Part 264 or Part 265:

(C) The financial assurance for closure requirements of

Subpart H of 40 CFR Part 264 or Part 265, or .

(D) The tinancialliability requirements oiSubpart H of

40 CFR Part 264 or Part 265.

(3) Not less than one hundred doUars ($100) nor more

than ten thousand dollars ($'10.000) for each day of the

violation upon any person who:

(al Violates an order ofthe Commission or Department.

(b) Violates any other condition of a license or written

authorization or violates anv other rule or statute.

(4) Anv person who .has care. custody or control of a

hazardous waste or a substance which would be a.hazardous

waste except for the fact that it is not discarded. useless or

unwanted shall incur a civil penalty according to the scheduie set forth in this section lor the destruction. due to

contamination of food or water supply by such waste or

substance, cfany orthe wildlife referred to in this section that

are the property of the state.

ia) Each game mammal other than mountain sheep.

mountain goat. elk or silver gray squirrel. $400.

tbl Each mountain sheep or mountain goat. $3.500.

IC) Each elk. 5750.

rd) Each silver gray squirrel. $10.

Ie, Each game bird other than wild turkey, $ IO.

If) Each wild turkey, S50.

(g.l Each game fish other than salmon or steelhead trout.

55.

(h) Each salmon or steelhead trout, S125.

ri) Each fur-bearing mammal other than bobcat or

tisher.550.

iji Each bobcat or fisher, S350.

tk) Each specimen ofany wildlife species wnosesurvival

is snecified bv the wildlife laws or the laws of the United

States as threatened or endangered. 5500.

(n Each specimen of any wildlife species otherwise

protected bv the ·...·ildlife laws or the laws of the United

States. bUI not otherwise referred ,0 in this section. $25.

SI~I. Auth.; ORS Ch. ~;'1 oS. ~I>I>

Hisl.: DEQ I·' '1o~. f. & d. 1-!8,~~: DI::O ~~·I QX4, f .I< cr. I j.~.~4: DEQ

9.I'I~6. f. &cC5·j·Xn: DEO 17,19Mb.f 8< ct. 'I. I1l·1l6

Oil and Hazardous Material Spill and Release Schedule of

Civil Penalties

340-12-069 In addition to any liability. duty. or other

penalty provided by law. the Director may assess a Civil

penalty lor any violation pertaining to oil or hazardous

material spills or releases or threatened spills or releases by

service of a written Notice of Assessment of Civil Penalty

upon the respondent. The amount ofsuch civil penalty shall

be determined consistent with the following schedule:

(I) Not less than two thousand Ii ve hundred dollars

($2.500) nor more than ten thousand dollars ($10.000) for

each day of the violation upon any person owning or having

control over oil or hazardous material who fails to immediately cleanup spills or releases or threatened spills or releases

as required by DRS 466.:05. 466.645. 468.795 and OAR

340· Divisions 47 and 108.

(2) Not less than one thousand dollars (51.0001 nor more

than ten thousand dollars ($ 10.0001 lor each day of the

violation upon any person owning or having control over oil

or hazardous material who tails to immediately report all

spills or releases or threatened spills or releases in amounts

greater than the reportable quantity listed in rule 340-108-

010 to the Oregon Emergency Management Division.

(3) Not less than one hundred dollars ($100) nor more

than ten. thousand dollars ($10.000) tor each day of the

violation upon any person who:

(a) Violates an order ofthe Commission or Department:

(b) Violates any other rule or statute.

SI:II. Auth.: ORS en. -VJ"

Hist.; DEQ 17·1986. C& ~f. 9.18·li6

Written Notice of Assessment of Civil Penalty: When

Penalty Pavaole

340-12-tl70 (I i A civil penalty shall be due and payable

when the respondent is served J written notice of assessment

of civil penalty signed by the Director. Service shall be in

accordance with rule 340-11-097.

(2) The written notice of assessment ofcivil penalty shall

be in the form prescribed by rule 340-11-1 on tor a nonce or'

opportunity for a hearing in 3 contested case. and shail state

the amount ofthe penalty or penalties assessed.

(3) The rules prescribing procedure in contested case

proceedings contained in Division 11 shall apply thereafter.

Stat. Autb.: ORS Ch. ~8

Hisl.; DEQ 78. I: '1-b- 74. ~l: 'I·~5-701

Compromise or Settlement of Civil Penalty by Director

340-12-075 Any time subsequent to service of the wn l -

ten notice of assessment of civil penalty. the Director is

authorized to seek to compromise or settle any unpaid civii

penalty which the DIrector deems appropriate..~ny comprormse or settlement executed bv the Director shall not be .inal

until approved by the Commission.

Star, AUlh.: <)RS Ch. ~6B

Hist.: DEl..-c) ':"S. f. lJ.,...:4. et. ·j-25·7": OEQ ::·:9H..l. r. 1.'1. i I.S.';~

(November. 1986) 4 - Div. 12
-e e

OFFlCf Of TIlE DIRECTot

0001 .0Irector

(Prlncipat Executive Manager H)

·e

ADM INISTRATlOII

0002 Prog. Exee. 0

(PE Hgr. E)

0455 Prog. Exee. 0

(PE Hgr. E)

0188 Hgt. Asst. C

(Executive Asst.)

OOAUOC (6/88)

PUBLIC AFFAIRS

0011 Prog. Exec. 0

(PE Mgr. E)

0569 Info. Rep. 3

(Pub. Info. Rep.)

0537 Info. Rep. 1

(Pub. Info. Rep.)

0636 Info. Rep. 3

(Pub. Info. Rep.)

0379 Info; Rep. 2

(Pub. Info. Asst.)

0266 Info. Rep. 2

(Pub. Info. Asst.)

0018 Mgt. Asst. A

(Exee. Sup. Spec. 1)

0282 Clerical Spee.

(Pub. Servo Rep. 2)

o,20 Clerical Spee.

(Pub. Servo Rep. 2)

( ) = Proposed New Class

PERSOINEl

0274 Prog. Exec. C

(PE Hgr. 0)

0658 Prog. Exec. A

(Training Spec.)

0560 Prog. Exec A

(Pers. Officer 2)

0588 Prog. Exec A

(Pers. Officer 2)

0279 Mgt. Asst. C

(Pers. Officer 1)

0358 Exel. Clerical Spec. . (Office Spec. 2)

0673 Exct. Secretory

(Office Coord.)

IIEAJtIIIGS

0275 Supv. Hearing Referee

(PE Mgr. E)

a

~.

:s:
-, e

tuIIAGBEIIT S£RVICES DIVISlat

0016 Program Executive E

(Principal Executive Manager G)

e

Atr.mnSTMTHJI IIJSINESS OfFICE ClDGET SlJ'fl(JlT SfRVICES DATA PROCESSING

0009 Admin. Asst.

(Exec. SS 1)

0587 librarian 3

(librarian 3)

0136 Prog. Coord. 3

(Mgt. Analyst 3)

0021 Fiscal Mgr. C

(PE Mgr. E)

0511 Fisc. Coord. 1

(Fisc. Coord; 2>

0075 Prog. Coord. 1

(Fisc. Coord. 1)

0024 Accountant 2

(Accountant 1)

0337 Accountant 2

(Accountant 1)

0602 Accountant 1

(Accountant 1>

0023 Accountant 1

(P/R Tech.)

0586 Accounting Clerk 2

(Accounting Tech.)

0025 Clerical Specialist

(Cashier 2)

0638 Clerical Specialist

(Cashier 2)

0065 Clerical Specialist

(Accounting Asst.)

0015 Business Ngr. B

(PE Mgr. 0)

0053 Prog. Coord. 1

(Budget Analyst)

0067 Prog. Coord. 1

(Budget Analyst)

0637 Prog. Coord. 1

(Budget Analyst>

0656 Mgt. Analyst 3

(Mgt. Analyst 3)

0028 Management Asst. C

(PE Hgr. A)

0068 Administrative Asst.

(Uord Proc. Tech. 3>

0132 Uord Proc. Spec.

(Uord Proc. Tech. 2)

0135 Uord Proc. Spec.

(Uord Proc. Tech. 2)

0019 Clerical Specialist

(Office Asst. 2)

0030 Clerical Assistant

(Office Asst. 2)

0118 ADP Ngr. B

(PE Mgr. E>

0404 Sys. Analyst

(Sys. Software Anal.)

0657 Sr. Sys. Analyst

(Sr. Sys. Analyst)

0601 Prog. Coord. 1

(Sr. User Sup. Anal.)

0041 Progreirmer

(Prog. Analyst>

0066 Progrenmer·

(Prog. Analyst)

0296 Progrenmer

(Prog. Analyst)

0558 Progrenmer

(Prog. Analyst)

0039 Computer operator 1

(Computer Operator)

,I,SDAllOC (6/88) ( ) =Proposed New Class
··e e'

AIR QUAliTY DIVISIOU

0007 Program Executive E

(Principal Executive Manager G)

e

AO~UtfISTRATlm

0008 Mgt. Asst. B

(Sup. Servo Supv. 2)

0105 Clerical Spec.

(Pub. Servo Rep. 2)

0029 Secretory

(Office Spec. 1)

0276 \lord Proc. ~pec.

(\lord Proc. Tech. 2)

0333 Uord Proc. Spec.

(\lord Proc. Tech. 2)

0070 Clerical Spec.

(Dota Entry Oper.)

PLAIIJIIHG & DEVELCl'M:NT

0076 Env. Mgr. B

(PE Mgr. E)

0049 Sr. Env. Engr.

(Env. Engr. 2)

0038 Sr. Env. Engr.

(Env. Engr. 2)

0040 Sr. Env. Engr.

(Env. Engr. 2)

0085 Sr. Env. Engr.

(Env. Engr. 2)

0528 Env. Spec. 3

(Env. Spec. 3)

0042 Env. Spec. 2

(Env. Spec. 2)

~odheatin9 Program

0166 Env. Supv. B

(PE Mgr. B)

0445 Env. Spec. 2

(Env. Spec. 2)

Air Monftorlng/Eval.

0034 Prog. Exec. C

(PE Mgr. C)

0512 Env. Spec. 4

(Env. Spec. 4)

0059 Env. Spec. 2

(Env. Spec. 2)

0551 Env. spec. 2

(Env. Spec. 2)

0347 Meteorologist

(Meteorologist)

O'ERATIOIS '

0027 Env. Mgr. B

(PE Mgr. E)

0071 Env. Engr.

(Env. Engr. 1)

0141 Env. Spec. 3

(Env. Spec. 3)

0061 Env. Spec. 3

(Env. Spec. 3)

0043 Env. Spec. 2

(Env. Spec. 2)

0168 Env. Tech. 3

(Env: Spec. 1)

Asbestos Control

0523 Supv. ES B

(PE MRr. C)

0674 Env. Spec. 3

(Em. Spec. 3)

0519 Env. Spec. 2

(Em. Spec. 2)

Source Control

0037 Supv. Env. Engr.

(PE Mgr. C)

0045 Sr. Env. Engr-~

(Em. Engr. 2)

0047 Sr. Env. Engr.

(Em. Engr. 2)

0036 Sr. Env. Engr.

(Em. Engr. 2)

FIElD BlRIIIIG

0343 Env. Mgr. A

(PE Mgr. 0)

0391 Env. Tech. 4 , (Env. Spec. 2)

0334 Env. Tech. 1

(FO Tech.)

0035 Env. Tech.

(FB Tech.)

0336 Env. Tech.

(fB Tech.)

0346 Admin. Asst.

(Office Coord.)

0301 Clerical Asst.

(Office Asst. 2)

1101Sf CXJITIKI.

0054 Env. Mgr. A

(PE Mgr. D)

0425 Env. Spec. 3

(Env. Spec. 3)

0056 Env. Spec. 3 , (Env. Spec. 3)

VERIQ.E INSPECTllJI

0225 Supv. PHE 0

(PE Mgr. E)

0224 Prog. Exec. B

(PE Mgr. D)

0496 Prog. Exec. A

(PE Mgr. A)

0300 Prog. Exec. A

(PE Mgr. A)

0222 Prog. Exec. A

(PE Mgr. A)

0057 Sr. Env. Engr.

(Em. Engr. 2)

0058 Env. Engr.

(Env. Engr. 1)

0257 Malnt. Foreman

(lrd/Htc Crd)

0255 Elec. Tech. 2

(lrd/Mtc \Irk 2)

0266 Bldg. Trd. Hlpr.

(lrd/Mtc \Irk 2)

0248 Elec. Tech. 1

(lrdlMtc \Irk 1)

Various VEl

(VE Tech. 1)

Various VEl

(VE Tech. 2)

0497 Admin. Asst.

(Office Coord.)

0284 Admin. Asst.

(Office Coord.)

AOALLOC (6/88) ( ) = Proposed New Class
·e

ADM 1111 STPJ\TIo:t

0087 Mgt. Asst. B

(Sup. Servo Supv. 2)

0655 Clerical Spec.

(Pub. Servo Rep. 2)

0280 Clerical Spec.

(Off. Spec. 2)

0083 Clerical Spec.

(Off. Spec. 2)

0485 Clerical Spec.

(Off. Spec. 2)

0367 Clerical Spec.

(Off. Spec. 1)

0484 Clerical Spec.

(Off. Spec. 1)

0665 Clerical Spec.

(Data Entry Op.)

0097 Clerical Spec.

(Data Entry Op.) ,

0584 Uord Proc. Spec.

(Yord Proc. Tech. 2)

0223 Yord Proc. Spec.

(Uord Proc. Tech. 2)

0089 Uord Proc. Spec.

(Yord Proc. Tech. 2)

\.IJAlLOC ,(61GB)

-

\lATER QlJIU.ITY DIVISICII

00~6 Program Executive E

(Principal Executive Manager G)

11IlUSTR1Al. VASTl: PUalaG aJISTIM:TUIt OWITS

0094 Env. "gr. B 0106 Env. Mgr. B 0478 Env. Mgr. B

(PE Hgr. E) (PE Mgr. E) (PE Mgr. &I>

0120 Sr. Env. Engr. 0461 Env. Engineer 0~79 Env. Engineer

(Env. E~r. 2) (Env. Engr. 1) (Env. Engr. 1)

. 0098 Sr. Env. Engr. 0458 Env. Spec. 4 0578 Env. Engineer

(Env. Engr. 2) (Env. Spec. 4) (Env. Engr. 1)

0092 Env. Engineer 0126 Prln. Env. Analyst 0577 Env. Engineer

(Env. Engr. 1) (Env. Spec. 4) (Env. Engr. 1)

0125 Prln. Env. Analyst 0669 Env. Spec. 3 0576 Env. Engineer

(Env. Spec. 4) (Env. Spec. 3) (Env. Engr. 1)

0640 Env. Spec. 3 0482 ~nv. Engineer

(Env. Spec. 3) (Env. Engr. 1)

0585 Env. Spec. 3 0480 Env. Engineer

(Env. Spec. 3) (Env. Engr. 1)

0368 Env. Spec. 3 0582 Env. Spec. 1

(Env. Spec. 3) (Env. Spec. 1)

0357 Env. Spec. 3 0583 Env. Spec. 1

(Env. Spec. 3) (Env. Spec. 1)

0641 Env. Spec. 2 0193 Prog. Coord. 3

(Env. Spec. 2) (Env. Spec. 4)

0632 Env. Spec. 3 0091 prog. Coord. 2

(Env. Spec. 2) (Env. Spec. 3)

0464 Env. Spec. 2 0~83 Prog. Coord. 2

(Env. Spec. 2) (Env. Spec. 3)

0380 Env. Spec. 2 0580 Prog. Coord. 2

(Env. Spec. 2) (Env. Spec. 3)

0128 Env. Spec. 2

(Env. Spec. 2)

0659 Cartographer

(Cartographer 1)

) =Proposed t1ew Class

....ICIPAl. ElUiIIlEIRIIG

0581 Env. Mgr. 8

(PE Mgr. E)

e

S8Wi£ DISPOSA1.

0130 Env. Mgr. B

(PE Hgr. E)

0479 Sr. Env. Engr.

(Env, Engr. 2)

0117 Sr. Env. Engr.

(Env. Engr. 2)

0575' Env. Engineer

(Env. Engr. 1)

0481 Env. Engineer (Env. Engr. 1)

0107 Env. Spec. 4

(Env. Spec. 4)

0111 Soil Scientist

(Env. Spec. 4)

0664 Env. Spec. 3

(Env. Spec. 3)

0565 Env. Spec. 3

(Env. Spec. 3)

0370 Env. Spec. 3

(Env, Spec. 3)

0191 Env. Spec. 3

(Env. Spec. 3)

0663 Env. Spec. 2

(Env. Spec. 2)

01'4 Eny. Spec. 2 (Eny. spec. 2)

0564 Env. Spec. 2

(Eny. Spec. 2)

0563 Admin. Asst.

(Off. Spec. 2)
·e e

HAZARIXIJS Am SOliD UASTE DIVISUl:1

0086 Supervising Public Health Engineer C

(Principal Executive Manager G)

e

~INISTIU\TlOlI

0134 Mgt. Asst. 0

(Sup. Servo Supv.2)

0591 Mgt. Asst. A

(Sup. Servo Supv. 1)

0510 Clerical Spec.

(Pub. Servo Rep. 2)

0649 Clerical Spec.

(Pub. Servo Rep. 2)

0362 Clerical Asst.

(Pub. Servo Rep. 1)

0441 Clerical Spec.

(Of f. Spec. 1)

0516 Clerical Spec.

(Off. Spec. 1)

0603 Clerical Spec.

(Off. Spec. 1)

0612 Clerical Spec.

(Off. Spec. 1)

0618 Clerical Spec.

(Off. Spec. 1)

0626 Clerical Spec.

(Off. Spec. 1)

0633 Clerical Spec.

(Off. Spec. 1)

0473 Clerical Spec.

(Of f. Spec. 1)

0031 Yord Proc. Spec.

(Uord Proc. Tech. 2)

0093 ~ord Proc. Spec.

(Uord Proc. Tech. 2)

0589 ~ord Proc. Spec. (~ord Proc. Tech. 2)

SO:ID UASTE

0137 Env. Mgr. B

(PE Hgr. E)

0625 Prog. Coord. 2

(Prog. Tech. 2)

. 063,. Geologist 4

(Hydrogeologist 2)

0143 Sr. Env. Engr.

(Env. Engr. 2)

0378 Sr. Env. Engr.

(Env. Engr. 2)

0630 Sr. Env. Engr.

(Env. Engr. 2)

0520 Env. Spec. 4

(Env. Spec. 3)

0624 Env. Spec. 2

(Env. Spec. 2)

0627 Env. Spec. 2

(Env, Spec. 2)

HAlAJl:IXIJS MATERIALS

0471 Env. Mgr. B

(PE Mgr. E)

0592 Sr. Env. Engr.

(Env. Engr. 2)'

0472 Enil. Spec. 3

(Env. Spec. 3)

0514 Env. Spec. 3

(Env. Spec. 3)

0593 Env. Spec. 3

(Env. Spec. 3)

0595 Env. Spec. 2

(Env. Spec. 2)

0596 Env. Spec. 2

(Env. Spec. 2)

0600 Env. Spec. 2

(Env. Spec. 2)

HAZARIXlJS WASTE

0359 Env. Mgr. B

(PE Mgr. E)

O4B8'Geologlst 4

(Hydrogeologist 2)

0517 Sr. Env. Engr.

(Env. Engr. 2)

Il\I Pro9. Adnin.

0619 Supv. ES B

(PE Mgr. C)

0361 Env. Spec. 4

. . (Env. Spec. 4)

0298 Env. Spec. 3

(Env. Spec. 3)

0606 Env. spec, 3

(Env. Spec. 3)

0604 Env. Spec. 2

(Prog. Tech. 2)

0509 Env. Spec. 1

(Prog. Tech. 1)

Il\I Perml ts

0643 Supv. Env. Engr.

(PG Mgr. C)

0101 Env. Engineer

(Env. Engr. 2)

0140 Env. Engineer

(Env. Engr. 2)

0607 Env. Engineer

(Env. Engr. 2)

0139 Sr. Env. Engineer

(Env. Engr. 2)

WlSTE IlBU:TImi

0559 Prog. Exec. C

(PE Mgr. D)

0605 Env. Engineer

(Env. Engr. 1)

0014 Env. Spec. 3

(Env. Spec. 3)

0628 Env. Spec. 3

(Env. Spec. 3)

0012 Env. Spec. 2

(Env. Spec. 2)

0446 Env. Spec. 2

(Env. Spec. 2)

REJ6)IAI. ACT I(II

0622 Env. Hgr. B

(P~ Mgr•. G)

0532 Env. Spcc. 3

(Env. Spec. 3)

Site Assessment

0571 Env. Mgr. A

(PE Mgr. E)

0667 Prog. Coord. 2

(Prog. Tech. 2)

0648 Env. Engineer

(Env. Engr. 1)

0566 Env. Spec. 2

(Env. Spec. 2)

0567 Env. Spec. 2

(Env. Spec. 2)

0568 Env. Spec. 2

(Env. Spec. 2)

0645 Env. Spec. 2

(Env. Spec. 2)

0590 Env. Spec. 3

(Env. Spec. 3)

0620 Env. Spec. 3

(Env. Spec. 3)

Site Response

0570 Env. Hgr. A

(PE Hgr. E)

0644 Geologist 4

(Hydrogeologist 2)

0533 Sr. Env. Engr.

(Env. Engr. 2)
"e e'

REG I0lCAl. (J>ERATIOIlS

0175 Program Executive E

(Principal Executive Manager G)

e

ffllU II1STruTIcrl

0176 Admin. Asst.

(Exec. Sup. Spec. 1)

ElIFORCBl{1IT

0194 Prog. Exec. C

(PE "gr. C)

0205 Prog. Coord. 1

(Env. Law Spec.)

0288 Prog. Coord. 1

(Env. Law Spec.)

0597 Prog. Coord. 1

(Env. Law Spec.)

0614 Prog. Coord. 1

(Env. Law Spec.)

IIOOTlIVEST REGIQIf

0063 Eny. "gr. B

(PE "gr. E)

0127 Supv. ES B

(PE "gr. C)

0192 Supv. Env.' Engr.

(PE "gf. C)

0615 Supv. Env. Engr.

(PE Mgr. C)

0113 Sr. Env. Engr.

(Env. Engr. 2)

0204 Env. Engr.

(Env. Engr. 1)

0651 Env. Engr.

(Env. Engr. 1)

0293 Env. Spec. 3

(Env. Spec. 4)

0543 Env. Spec. 3

(Env. Spec. 4)

0609 Env. Spec. 3

(Env. Spec. 4)

0069 Eny. Spec. 2

(Env. Spec. 3)

0082 Env. Spec. 2

(Env. Spec. 3)

0050 Env. Spec. 2

(Env. Spec. 2)

0077 Env. Spec. 2

(Env. Spec. 2)

0448 Eny. Spec. 2

(Env. Spec. 2)

0598 Eny. Tech. 3

(Eny. Spec. 1)

0103 Admin. Asst.

(Office Spec. 2)

0202 Clerical Spec.

(Office Spec. 1)

UI LlNETTE VALlEY

0278 Eny. Mgr. B

(PE "gr. E)

0206 St.pY. ES B

(PE Hgr. C)

0610 SI..pV. ES B

(PE Mgr. C)

0201 Sr. Env. Engr.

(Env. Engr. 2)

0208 Env. Engr.

(Env. Engr. 1)

0292 Env. Engr.

(Env.' Engr. 1)

0652 Env. Engr.

(Eny. Engr. 1)

0052 ErN. Engr.

(Eny. Spec. 4)

0616 ErN. Spec. 3

(Env. Spec. 4)

0110 Env. Spec. 3

(Env. Spec. 3)

0599 ErN. Spec. 2

(Env. Spec. 3)

0542 ErN. Spec. 2

(Eny. Spec. 2)

0562 ErN. Tech. 3

(Env. Spec. 2)

0290 Admin. Asst.

(Office Spec. 2)

0203 Clerical Spec.

(Office Spec. 1)

salTlMST REGION

0210 Eny. Hgr. B

(PE Mgr. E)

0211 Sr. Eny. Engr.

(Env, Engr. 2)

0051 Env, Engr.

(Eny. Engr. 1)

0594 Env. Engr.

(Eny. Engr. 1)

0653 Eny. Spec. 2

(Eny. Spec. 3)

0216 Admin. Asst.

(Off ice Coord.)

Coos Bay

0131 Env. St.pv. B

(PE Hgr. C)

0212 Eny. Spec. 2

(Eny. Spec. 2)

0177 Clerical Spec.

(Office Coord.)

Roseburg

0213 Env. St.pv. B

(PE "gr. C)

0544 Eny. Spec. 2

(Eny. Spec. 3)

0398 ~aste Mgt. Spec.

(Env. Spec. 2)

0016 Clerical Spec.

(Office Coord.)

C:BITRJU. REGIl:It

0217 Env. Mgr. B

(PE Mgr. 0)

0219 Eny. Engr.

(Eng. Engr. 1)

0189 Eny. Spec. 3

(Env. Spec. 3)

0365 ErN. Spec. 2

(Env. Spec. 3)

0654 Env. Spec. 2

(Eny. Spec. 3)

0218 Clerical Spec.

(Office cecrd.)

EAS1ERti REGIO!

0214 Eny. Hgr. A

(PE Hgr. 0)

0474 Eny. Engr.

(Env. Engr. 1)

0639 Eny. Spec. 2

(Env. Spec. 3)

0180 Usste Mgt. Spec.

(Env. Spec. 2)

0190 Eny. Spec. 2

(Env. Spec. 2)

0081 Eny. Spec. 2

(Errv, Spec. 2)

0104 Clerical Spec.

(OffIce Spec. 2)

0207 Clerical Asst.

(Office Spec. ')

'll.J I r-r- ? i.'~O \. L. \. _ Dr-.....nnr-M Uou r-r o e c

AS'oria

Qi,n Clerical Asst.

(Off ice Coord.)
~------- 

•

e

e

I.J\IOV\ICIlY

0144 Program Executive E

(Principal Executive Manager G)

•

WATER lIJAlin 'OnTOOUIG

0169 Supv. ESB

(PE "gr. 0)

Ambient Monitoring

0463 Env. Tech.4

(Env. Spec. 2)

0156 Env. Tech. 3

(Env. Spec. 2)

O~O Env. Tech.2

(Env. Spec. 1)

0573 Env. Tech.3

(Env. Spec. 1)

0661 Env; rech.3

(Env. Spec. 1)

!!.!.2!2!

0129 Env. Supv.A

(PE Mgr. B)

0153 Fish&Uildlife 8io.2

(Env. Spec. 2) •

0161 Microbiologist 2

(Microbiologist 2)

Groundwater Monitoring

0170 Env. Tech.4

(Env. Spec. 2)

0635 Env. Tech.3

(Env. Spec. 2)

0439 Env. Tech.2

(Env. spec. 1)

ORCAIIIC LAD

0157 Supv. ES0

(PE "gr. 0)

0634 Chemist2

(Env. Spec. 2)

0339 Lab Tech.2

(Chemist 1)

0167 Chemist3

(Chemist 3)

GC/NS Systems

0381 Supv. Chemist

(Supv. Chemi st)

0475 Chemist1

(Chemist 1)

0158 Chemist2

(Chemist 2)

0617 Chemist2

(Chemist 2)

ItlORGAIIlC LAB

0145 Supv. ES8 (P~ Mgr. 0)

~.

0159 Chemist2

(Chemist 2)

0465 Chemist2

(Chemist 2)

0160 Chemist2

(Chemist 3)

0660 Lab Tech.2

(lab Iech, 2)

Non-Metals

0574 Supv. Chemist

(Supv. Chemist)

0155 Env. Tech.1

(Chemist 1)

0437 Lab Tech.2

(Chemist 1)

0332 Lab Tech.2

(Chemist 1)

0561 Chemist1

(Chemist 1)

0329 Chemist2.

(Chemist 2)

0150 Chemist2

(Chemist 2)

0165 Chemist3

(Chemist 3)

0553 Lab Tech.2

(lab Tech. 2)

ClJALITY ASSlJIWlCE

0447 Env. Supv.A

(PE Mgr. D)

0545 lab Tech.2

(Env. Spec. 1)

0152 Env. Tech.3

(Chemist 2)

0459 Chemlst2

(Chemist 3)