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• ZB4956 (8/30/85)

SECTION 2

PROGRAM DESCRIPTION
•

PROGRAM DESCRIPTION

TABLE OF CONTENTS

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

B. State Agency Organization and Structure

C. Permitting and State Appellate Review Procedures

D. Forms

E. Compliance Monitoring and Enforcement

• F•

G.

Manifest Program

Generators, Transporters and Management Facilities

Appendices:

•

A -

B -

C -

D -

E -

F -

G -

H -

I -

J -

K -

L -

DEQ/PUC Memorandum of Agreement

DEQ Signature Authorizations

Mailing List for Public Notice of Permits

Land Use Compatibility Statement

DEQ Field Sampling Reference Guide

Compliance Monitoring Strategy

Annual Inspection Schedule

Inspection Checklist and Narrative Report

DEQ Sponsored Hazardous Waste Training

Hazardous Waste Training Attended by DEQ Staff

DEQ Administrative Civil Per:.alt~ Policy for',/J' 11

Hazardous Waste Program - ~.,.~f 6u-,~s

Proposed Amendment to OAR 340-12-040
•

PROGRAM DESCRIPTION

TABLE OF CONTENTS

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

B. State Agency Organization and Structure

C. Permitting and State Appellate Review Procedures

D. Forms

E. Compliance Monitoring and Enforcement

•

•

F.

G.

Manifest Program

Generators, Transporters and Management Facilities

Appendices:

A DEQ/PUC Memorandum of Agreement

B - DEQ Signature Authorizations

C - Mailing List for Public Notice of Permits

D - Land Use Compatibility Statement

E - DEQ Field Sampling Reference Guide

F - Compliance Monitoring Strategy

G - Annual Inspection Schedule

H - Inspection Checklist and Narrative Report

I - . DEQ Sponsored Hazardous Waste Training

J - Hazardous Waste Training Attended by DEQ Staff

K - Enforcement Guidelines and Procedures for the

Hazardous Waste Program

L - Proposed Amendment to OAR 340-12-040 and

Schedule for Adoption
•

•

PROGRAM DESCRIPTION

EDITORIAL NOTE; For purposes of this program description, the terms EPA

"permit" and DEQ "License" shall be considered synonymous and will simply

be referred to as permit.

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

As a result of legislative and administrative actions taken during the

1910's and 1980's, Oregon currently has operational a hazardous waste

management program that is equivalent to the federal program

promulgated by EPA through April 30, 1985. That portion administered by

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

Revised Statutes (ORS) Chapters 459 and 468 and Oregon Administrative Rules

(OAR) Chapter 340, Divisions 12 and 100 through 108. That portion relating

to transportation of hazardous waste by motor carrier and rail is

administered by the Public Utility Commissioner (PUC) and is contained in

ORS Chapters 484,156,161.161 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).

In 1985. House Bill 2145 and Senate Bill 138 (1985 Oregon Law, Chapters 135

and 610 respectively), which amend DEQ and PUC statutes, were passed by the

Legislative Assembly. Copies of these statutes are contained in section

six (6) of this application entitled Statutes and Rules. Senate Bill 138

• ZB2611 -2.2- Rev. 9/20/85
•

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establishes provisions pertaining to the siting of hazardous waste

treatment and disposal facilities. It is the state's opinion that these

new statutory provisions allow for a broader-in-scope state program.

It is noted for the record that two other Oregon agencies have specific

authorities in the area of radioactive waste management:

Department of Human Resources

Health Division

Radiation Control' Section

ORS Chapter 453 - Hazardous Substances: Radiation Sources

OAR Chapter 333

Department of Energy

ORS Chapter 469 - Energy Conservation

OAR Chapter 345

For wastes which are both chemically hazardous and radioactive. these

agencies have regulatory authorities in addition to DEQ and PUC.

At such time as EPA promulgates rules to regulate wastes that are only

radioactive, Oregon will be in a position to evaluate its equivalent

status. DEQ would assume a lead agency role for coordination with EPA and

appropriate Memorandums of Agreement would be signed to identify

interagency coordination of State programs.

• ZB2611 -2.3- Rev. 9/20/85
" .

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

ReRA requirements in 40 CFR Parts 260-266. 270 and 124 oromulgated

prior to May 1. 1985 (see OAR 340-100-002). Divisions 100-106 of OAR

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

requirements; and (2)· additional state requirements pursuant to Oregon

l~.

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

459.410(6)(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

•

ZB2671 -2.4- . Rev. 9/20/85
•

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industry, manufacturing, trade or business or government or recovery

of natural resources" in ORS 459.410(6)(b) is equivalent to the use of

the terms "industrial, commercial, mining and agricultural operations

and from community activities" in HeRA 1004(27).

Oregon provides an exemption from certain administrative requirements

for generators of small quantities of hazardous wastes, and a "small

quantity disposal" exemption which varies by characteristic or listed

waste and is significantly less than the 1000 kilogram or 2200 lb. per

month exemption allowed by EPA (i.e., ignitable - 25 lbs. per month;

corrosive - 200 lbs. per month; reactive - case-by-case but not to

exceed 200 lbs. per month; EP-Toxic - see OAR 340-101-005(5) but not

to exceed 200 lbs. per month; non-specific and specific source list -

see OAR 340-101-005(5) but not to exceed 200 lbs. per month; P -

listed wastes - see OAR 340-101-005(5) - 2 lbs. per month; U listed

wastes - see OAR 340-101-005(5) - 10 lbs. per month; and waste

pesticides (X001) - see OAR 340-101-005(5) - 10 lbs. per month).

Disposal of small quantities must be at a State permitted municipal or

industrial landfill pursuant to OAR 340-101-005. Permission of

landfill operator is required.

Oregon's universe of wastes is broader than the federal universe in

some areas. The ignitable, corrosive, reactive and EP toxicity

characteristics are equivalent to the federal program.

ZB2671 -2.5-
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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 "un-list, is included.

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

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

covered by rules in OAR 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 waste

compared to the EPA rules. In no case is the state less inclusive

than the federal universe.

Both EPA (260.20 and 260.22) and DEQ (ORS 459.430 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-
• 2 • Generator Requirements:

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

their wastes according to equivalent standards for handling,

transportation, storage and disposal, including packaging and labeling

according to federal DOT standards, with the following exceptions:

i. Generators of domestic-use waste, small quantities managed under

OAR 340-101-005, pesticide waste managed under OAR 340- Division

109 or whose waste is subject to regulations under an NPDES

permit or Section 307(b) of the Clean Water Act are exempt from

the rules of this Division, and

•

ii. Generators who produce or accumulate less than 2.2 lbs. of any

one or combination of P-listed wastes or less than 2200 lbs. of

anyone or combination of other hazardous wastes in any calendar

month need only comply with rules allowing access for

inspections, general waste management practices, and compliance

with DOT labeling and shipping requirements.

•

An area where the Oregon standards are more stringent than the federal

program is that generators storing more than 100 containers must

provide secondary containment pursuant to 40 CFR 264.175.

Oregon provides for satellite accumulation at generator facilities,

pursuant to 40 CFR 262.34(c) •

ZB2671 -2.7-
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5.

There are several significant areas where Oregon's management

facilities standards are more stringent than the federal program.

It should be noted that ORS 459.590 requires state ownership of

hazardous waste disposal sites; therefore, non-sudden environmental

impairment insurance is not required. Even though not required by

federal rule, state law requires as a condition of a permit that

non-sudden environmental impairment insurance be provided, at an

amount to be determined by the Department, for disposal sites. DEQ

intends to use the Part 264 reqUirements as guidance in establishing

this amount. Similarly, state ownership is more stringent than Parts

122 and 264 which reqUire a notice in the property deeds records of

the presence of buried hazardous wastes. Nonetheless, DEQ retained

these notice provisions.'

For disposal sites only, OAR 340-104-143 stipulates that at the end of

the pay-in period the only acceptable form of financial assurance is

the closure trust fund.

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 ignitabllity (D001).

Compliance Monitoring:

Adequate statutory and administrative authorities exists to allow DEQ

and PUC personnel to conduct periodic inspections of all generators,

transporters and management facilities.

ZB2671 -2.9-
•

3.

Oregon's rules for hazardous waste which is used, reused or recycled

are equivalent to the federal RCRA requirements as amended on

January 4, 1985.

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•

4.- Owners or Operators of Storage, Treatment and Disposal Facilities:

Persons who store (store beyond 90 days in the case of generators),

treat or dispose of hazardous waste must obtain a permit to establish,

construct or operate hazardous waste management facilities. Permits

contain site specific conditions which implement the rules in 40 CFR

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

identifies permit application and permit content requirements while

Division 106 identifies permit issuance procedures.

Oregon has adopted the interim status standards of 40 CFR Part 265.

These standards are applicable to existing management facilities which

have not been issued a RCRA permit•

ZB2671 -2.8-
•

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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 facilities 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.

6. 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. In reviewing ORS 756.990, 761.994, 767.993, 459.992 and

459.995 and OAR 340-12-068, we believe the enforcement authorities

equal EPA's minimum penalty provisions for final authorization.

ZB2671 -2.10-
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7•

8.

DEQ and PUC will:

i. Investigate and provide written response to all citizen

complaints.

ii. Not oppose intervention by any citizen where permissive

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.

Indian Lands

Having reviewed and considered Oregon's authority to implement a

hazardous waste regulatory program on Indian Lands, it is the

DEQ's position not to regulate hazardous waste and/or hazardous

waste management facilities on Indian Lands. DEQ will be

expecting EPA to implement HCRA Subtitle "C" regulations on

Indian Lands in Oregon.

Underground Injection Wells for Hazardous Wastes

Oregon has been delegated primacy for the Underground Injection

Control (UIC) program. Disposal of hazardous waste via underground

injection wells does not presently occur in Oregon, but would be

regulated under the state's VIC program•

ZB2671 -2.11-
• B• State Agency(ies) Organization and Structure

•

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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 for 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 permit issuance. The DEQ's region and branch offices are

responsible for program implementation including inspecting generators, air

and water transporters, and management facilities, compliance monitoring,

enforcement, complaint investigation and emergency spill response. The

Laboratory Division 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

ZB2671 -2.12-
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Supplements the language in ORS 459 and 468. Signature decisions

represented by 1,2,5,7, 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

Public Utility Commissioner who is responsible for setting policy and

adopting administrative rules. The Assistant Commissioners for the Motor

Carrier and Rail Programs are responsible for program development and

implementation. Inspections, compliance audits, enforcement, complaint

investigations and emergency spill response are handled by the Motor

Carrier Investigations 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. Chart 4 is an estimate of

state program costs and funding sources for the first two years after final

authorization is granted.

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- (Revised 12/85)
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DEPARTMENT OF ENVIRONMENTAL QUALITY

Governor

. Victor Atiyeh !

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Environmental Quality Commission

James Peterson, Chairman

DEQ

Fred Hansen, Director

•

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Management Services

Division

I

Laboratory

Division

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Regional Operations

Division

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Hazardous and Solid

Waste Division

Michael Downs

Administrator

1

Hazardous Waste Section

Jan Whi tworth

Manager

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Air Quality

Division

1

Water Quality

Division

Chart 1
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PUBLIC UTILITY COMMISSIONER

Governor

Victor Atiyeh

Public Utility Commissioner

Gene Maudlin, Commissioner

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Administrative Consumer Assistance Proceedings Motor Carrier Program Rail-Air Program Utility

Services and Bill Bebout David Astle Program

Wea therization Assistant Commissioner Assistant

Programs Commissioner

.

Investigations Division Rail Safety Division

Paul Henry George Hardy

Division Administrator Administrator I

Chart 2
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Administrative Support

•

Chart 3

Manpower and Financial Resources Committed to Oregon's

Federally Related Hazardous Waste Management Effort

•

Staff . _ _ _ ___ ...lhlU...e.s...... £'l'L-------.Co..st

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Michael Downs

Administrator

Solid Waste Division

Joyce Thomas

Management Assistant

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.

0.40

0.40

36,619

15,177

Jan Whitworth

Manager

Hazardous Waste Section

Carol Harris

Clerical Specialist

Betty Froen

Word Processing

Specialist

Richard Reiter

Senior Planner

Personnel supervision (work plans, performance

appraisals); coordination with other local, state

and federal agencies, including EPA and DEQ regional

offices; preparation of permits, fact sheets, compliance

reports.

Receptionist; typing; assist with generators and

TSDF reports and records maintenance and review;

manifest review.

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

reports, etc.

Program planning and budgeting; training coordinator

data base coordinator, rule development.

1.00 78,334

1.00 26,594

0.40 12,690

1.00 78,334
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Administrative Support

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Chart 3 (continued)

Manpower and Financia'l Resources Comm!t ted to Oregon's

Federally Related Hazardous Waste Man~gement Effort

•

Staff ... _ Dut~ __ F'I'E . __Cost

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Lynda Buckley

Data Entry Clerk

Alan Hose

SuperVisor

Laboratory Services

Marlene Miller

Management Assistant

Fred Bolton

Administrator

Regional Operations

Terri Sylvester

Management Assistant

Enter generator quarterly reports, 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; peronnel supervision•

Supervisor and/or arrange for laboratory typing,

filing, appointments; assist with budget preparation;

receptionist.

Regional goals and objectives setting, strategy

and policy setting; budgeting; coordination between

programs and regions and management of enforcement

actions.

Regional Operation's receptionist; typing, filing,

appointments; assist with budget preparation.

1.00

0.05

0.05

0.05

0.05

25,435

2,932

1,408

3,832

1,398
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Technical Support - DEC

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Chart 3 (continued)

Manpower and Financial Resources Committed to Oregon's

Federally Related Hazardous Waste Management Effort

•

Staff ___ DuUe~L _~ FTE Cost

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CD

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Fred Bromfeld

Senior Environmental

Engineer

Eduardo Chiong

Environmental Engineer

Dave Nichol

Environmental Engineer

Steve Sander

Hazardous Waste

Laura Hamil ton

Environmental Engineer

Issuance of disposal permits (landfills, surface

impoundments and waste piles); plan reviews for

for management facilities.

Arlington disposal site compliance inspections and

enforcement follow-up; review for approval/denial

disposal request for use of Arlington disposal site;

assistance with disposal permit issuance; emergency

spill response.

Facility permitting and inspection.

Storage facility permitting and inspection;

generator compliance with manifest.

Facility permitting and inspection.

1.00

1.00

1.00

1.00

1.00

65,200

60,700

Jt5 ,696

55,285

45,690
• •

Chart 3 (continued)

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& Manpower and Financial Resources Committed to Oregon's

Federally Related Hazardous Waste Management Effort .

n Technical Support - DEQ

Staff Dut Les _ __ _ _ FT~ __Cost

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Gary Calaba

Hazardou,s Waste

Specialist

Greg Baesler, Peter

Ressler, Cynthia Parker,

Dennis Belsky, Dick

Nichols, Bob Danko,

Steve Gardels and

Brett McKnight

Hazardous Waste

Specialists--Regional

Offices

Richard Gates

Chemist

Jo Brooks

Public Information

Officer

Generator inspections and enforcement follow-up;

compliance and enforcement reporting to EPA;

assistance to permitting staff on an as-needed basis;

emergency spill response; generator registration and

technical assistance to regulated community, public,

DEQ and other agency staff.

Generator and management facility cqmpliance

inspections, enforcement, complaint investigations,

emergency spill 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.

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.

1.00

4.00

1.00

0.50

52,609

215,914

65,966

22,847
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Technical Support - DEQ

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Chart 3 (continued)

Manpower and Financial Resources Committed to Oregon's

Federally Related Hazar-doua Waste Management Effort

•

Staff _ _D1ltieJiL __ __ . _ FTE _ Cost

Alan Goodman

Assistant to the

Administrator

Prepare application for authorization; develop

program work plans and grant-related documents;

budgeting; rule drafting; policy development.

1.00 24,705

Neil Mullane Review groundwater monitoring programs and plans 1.00 60,250

Hydrogeologist for compliance with Part 265 Subpart F, Part B

permit conditions, or Part 270 permit application

I

I\) requirements; assist in conduct of inspections of .

I\) groundwater monitoring programs• 0

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Linda Zucker, Conducts contested case hearings for EQC and Available Cost proportioned

Hearings Officer reports findings, conducts rulemaking hearings as needed according to current

or permit hearings for Department and prepares case load.

hearings officers' report.

Larry Cwik Prepare enforcement documents and actions based 0.50 25,366

Law Intern upon case referrals.
• •

Chart 3 (continued)

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Manpower and Financial Resources Committed to Oregon's 0\ •

Federally Related Hazardous Waste Management Effort .

n Technical Support - PUC

Staff Dllties _ ~~ FTE Cost

Motor Carrier & Rail

Safety Specialist

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.

1.00 36,908

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1 Technical Support - Department of Justice

Stafi' Du t Les ~_~ ~_ ~_~ FTE_ _ Cos t

Michael Huston,

Arnold S11ver

Assistant Attorney

Generals

Chris Rycewicz

Law Clerk

Advice and counsel on statutes, 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.

Available

as needed

Available to DEQ at an

hourly rate fixed by

Attorney General

(currently $50/hr.)

Technical Support - Water Resources Department

S~aff __ _ Dm ies ___ ____ _ _ FTE Cost

William Robertson,

Hydrogeologist

Advice to Department on geology, hydrology,

monitoring well construction, compliance

of groundwater'monitoring program with

Subpart F requirements.

Available

as needed

up to 1.0

Position funded by

Water Resources Dept.
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Chart 3 (continued)

Manpower and Financial Resources Committed to Oregon's

Federally Related Hazardous Waste Management Effort

Technical Support - County District Attorney

Staff lLuUes_~_~ ~~~~~ FTE ~_CQst

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District Attorney

and/or staff

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

Services funded by

County government
• Chart 4

Estimate of Program Costs and Funding Sources

for the

Oregon Hazardous Waste Program

Program Element

Planning and Development

Program and Information Management

Compliance Assurance

Permitting

TOTALS

Funding Sources

Cost Estimate.

SFY 87 SFY 88

$ 78,110 $ 80,453

106,877 110,083

531,855 547,810

348.980 359.450

$1,065,822 $1,097,796

•

Federal

Other

$ 525,000

540,822

$ 525,000

572,796

·Cost estimates based on FY 86 SEA and application of a COLA factor of 3%

for FY 87 and 88 •

• ZB2671 -2.22.A- (12/85)
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At this time, DEQ does not plan to utilize EPA contractor assistance except

in the area of training for compliance with Subpart F requirements. 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 459.505 and 459.510 provide that no person shall store (storage beyond

90 days 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; 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 in compliance with the hazardous waste rules.

OAR 340 - Division 105 contains the permit application and permit content

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

OAR 340 Division 106 identifies 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-
•

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) notice to be pUblished in one newspaper

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

permit actions requiring notice.

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

• heaping is required to be held in the county or counties where a proposed

hazardous waste disposal site is located and may be held at such other

places as the Department considers suitable (ORS 459.560). 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 459.570).

•

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-
•

•

•

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 Division 106 also identifies 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 459.580 and 459.585) and then

judicial review according to the administrative procedures and rules of

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

Under certain criteria as specified in 40 CFR 270.61 and OAR 340-105-100,

the Department may issue an emergency permit or a letter of authorization

for hazardous waste management facilities receiving waste from small

quantity generators. The Department will not use these authorities in a

manner inconsistent with the federal program in effect at the time of

consideration and has so noted in the MOA.

The Department's current policy is to issue hazardous waste management

facility permits for a period not to exceed ten (10) years. In light of

the rapidly changing nature of hazardous waste management practices, this

policy will remain in effect for the indefinite future.

ZB2671.A -2.25-
•

•

•

In summary, it is the state's opinion that DEQ's permit-issuing authorities

are equivalent and provide reasonable opportunities for the applicant and

the public to comment on the proposed permit conditions.

D.

DEQ and PUC are using EPA's notification form 8700-12. DEQ also intends to

use EPA's Part A permit form 8700-13. As does EPA, DEQ has not designed a

Part B permit application form rather 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 may submit copies of their manifest or the manifest information

on a form of their choice (see OAR 340-102-041). Manifest exception

reporting is also required. On a calendar quarter basis, treaters and

storers are required to submit the information required by OAR 340-104-075

on a form of their choosing. On a monthly basis, disposal facilities shall

submit the information required by OAR 340-104-075 on a form of their

choosing. 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 -
• E. Compliance Monitoring and Enforcement

Oregon's hazardous waste compliance monitoring program is a shared

responsibility between the DEQ' s hazardous waste section; Laboratory;

Regional and Branch offices and PUC. The primary roles of the hazardous

waste section are registration of generators; permitting of hazardous waste

management facilities; inspections of management facilities; records

maintenance; records review; technical assistance and intra-agency

training. The primary roles of the laboratory are environmental monitoring

and sample collection, chemical analysis and data interpretation. The

primary roles of the Regional and Branch offices are compliance monitoring

of generators; complaint investigation and followup, enforcement, technical

assistance and emergency spill response.

• Records maintenance consists of maintaining and routinely updating a

registry of generators, transporters, and management facilities. Records

review consists of comparing quarterly generator reports with entries in

monthly or quarterly management facilities reports for:

i. Submission of required reports by generators and management

facilities

1i. Identification of non-registered generators, transporters, and

management facilities

iii. Identification of discrepancies between wastes shipped off-site

by generators and wastes received for storage, treatment, or .

• disposal by management facilities.

ZB2671 •A - 2 .27 -
•

•

•

Environmental monitoring consists of collecting appropriate samples (i.e.,

groundwater, surface water, soil, animal or plant tissue, ambient air,

etc.) and performing the necessary analytical work to obtain numerical data

to interpret. Technical assistance is provided by the laboratory to the

Hazardous Waste Section and the Regions and Branch offices. Environmental

monitoring data results may be used to support an enforcement action

initiated by the DEQ. While there are no statutes or rules dealing with

"chain of custody," the procedures in Appendix E - Field Sampling Reference

Guide - of this section have been developed for use by DEQ staff.

With the addition of a "GC/MS" during FY 83, the laboratory is capable of

analyzing for most organic hazardous constituents except exotics such as

2,3,7,8-TCDD. An "AA" in the inorganic hazardous constituent area gives

quick and accurate heavy metal analysis. No major new instruments are

needed to implement the hazardous waste program.

Compliance monitoring consists of scheduling field inspections of

generators, air and water transporters, management facilities or

non-registered businesses for any of the follOWing purposes:

i. Routine inspections for compliance with statutes, administrative

rules or license conditions.

ii. Special purpose inspections, such as comprehensive groundwater

monitoring inspections.

iii. Complaint investigation.

ZB2671.A -2.28-
•

•

•

iv. Investigations of non-reg1sterea businesses suspected of being

generators, transporters, or management facilities.

v. Emergency spill response for required spill cleanup actions.

A Compliance Monitoring Strategy for the Hazardous Waste Program has been

developed by DEQ and is included as Appendix F to this section. The

strategy describes the Department's program for monitoring compliance by

the regulated community.

Based on the generators, transporters and management facilities identified

in Section G (as updated regularly), a schedule of compliance inspections

is determined during annual preparation of the State Work Program •

Because of the relatively small number of TSD facilities expected in Oregon

after the Part A list is verified, they will all be identified as either

major or non-major facilities in the SEA and inspected annually depending

on EPA priorities at the time. It is expected that all generators will be

inspected at least once every five years. At the beginning of each fiscal

year, an inspection schedule will be developed identifying facilities to be

inspected by facility type, facility name and responsible inspector (see

Appendix G of this section for an example). For TSD facilities, the

headquarters person responsible for permit issuance will be involved with

the scheduled inspection for ensuring the record review is completed. To

ensure consistency between DEQ Regions and DEQ inspector, standardized

inspection forms have been developed (see Appendix H of this section).

Each completed inspection 1s reviewed for completeness and accuracy by the

ZB2611.A -2.29-
•

•

•

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 per year.

Using the authorities in ORS 459.650 through 459.690; 459.992,459.995,

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

ZB2671.A -2.30-
•

•

•

iv. Department order

v. Commission order

vi. Site operation shutdown order

vii. Injunctive relief

viii. Criminal action

A more complete description of the Department's hazardous waste enforcement

response and civil penalty policies will be included in the Enforcement

Guidelines and Procedures (Appendix K) to be forwarded to EPA in midSeptember.

Notices of Violation are typically handled by the inspector with copies

provided to the hazardous waste program office for information. Notices of

intent to assess a penalty, civil penalty assessments, Department and

Commission orders, site operation shutdown orders and injunctive relief

orders all proceed based on an enforcement referral from the inspector to

Regional Operations' Enforcement Section. The Enforcement Section reviews

the evidence to determine accuracy and completeness, preliminarily

determines the Department's strategy and drafts the necessary documents for

review by hazardous waste program and Department o.f Justice. If

concurrence is received, Enforcement Section processes necessary documents

and delivers by appropriate means (i.e., certified mail, hand delivery,

sheriff's delivery, etc.). Any appeals of Department actions are heard by

ZB2671.A -2.31-
•

•

•

Environmental Quality Commission's hearing officer at which time the

Department is represented by Department of Justice. Adequate Department of

Justice resources appear available to handle their responsibilities,

considering that an additional 0.8 FTE was recently assigned to DEQ (1.8

FTE currently available to DEQ).

If criminal action is pursued,that is not handled by the Department of

Justice; rather, it must be filed with the County District Attorney's

Office in the county where the violation occurred. Once referred via a

formal complaint, the County District Attorney determines what priority

DEQ's case will have. In lieu of proceeding criminally through the County

District Attorney, DEQ will also consider requesting assistance from EPA's

criminal investigation section.

. PUC's compliance monitoring program related to motor carrier and rail

transporters will consist of random spot checks of individual motor

vehicles at locations such as Ports of Entry, truck weighing stations,

generator facilities, hazardous waste management facilities or conducting

comprehensive fleet audits at a carrier's terminal. Using the authorities

in 756.075, 756.990, 761.994, and 767.993, among others, to support its

compliance inspection program for transporters, PUC would approach

violations of any motor carrier or rail statute, rule or PUC order in a

similar manner as described for DEQ above.

At the beginning of each fiscal year, DEQ and PUC meet to identify the

motor carrier and rail carriers to be inspected. PUC makes the selection

based on DEQ documentation of actual shipments the previous year (generator

quarterly reports and TSD monthly reports), amount of waste transported,

ZB2671.A -2.32-
•

•

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 Richard Reiter (DEQ) for follow up.

An examination of ORS 459.992, 459.995,756.990,761.994, and 767.993

identifies adequate levels of civil or criminal remedies to meet the

minimum requirements for final authorization. Pursuant to ORS 468.125 as

amended by Section 3 of HB 2145, no advance notice is required to be issued

by DEQ prior to assessing civil penalties for hazardous waste program

violations. The Department will amend OAR 340-12-040 to incorporate

Section 3 of HB 2145 (see Attachment L). OAR 340-12-068 contains a

Hazardous Waste Management Schedule of Civil Penalties.

Lastly, while 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.

ii.

iii.

ZB2671.A

Investigate and provide written response to all citizen

complaints duly submitted;

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

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.

-2.33-
•

F. Manifest Program

•

•

Oregon rules require use of the national uniform manifest, promulgated by

EPA and DOT. Oregon's manifest program places the major burden of

compliance with the manifesting requirements on the original generator. A

generator shall not ship wastes off-site without preparing and prOViding

sufficient copies of a manifest so that all parties (generator,

transporter(s) and management facility(ies» can retain a copy and stIll

have one returned to the generator from the last management facility. The

manifest is required to contain the following information in addition to

the information required by 40 CFR Part 262:

1. Telephone number of transporter(s).

- 2. Telephone number of designated facility.

3. EPA Waste Code Number.

A generator is responsible for insuring that his waste has been responsibly

managed, and if in doubt, shall take all necessary steps, inclUding

notifying the Department to correct any improper management.

Oregon is prepared to share information on wastes shipped interstate,

however, it seems appropriate that the exact procedure to be followed

should be established on a state-by-state basis.

ZB2671.A -2 -34-
• G. Generators, Transporters and Management Facilities

1•

2.

Generators registered with DEC

Transporters registered with PUC

369

118

3. Treatment. Storage and Disposal Facilities

•

•

Facility Address

Chem-Security Systems, Inc.

Arlington, OR 97812

ORD 089452353

Baron-Blakeslee

Division of Purex Corp.

5920 N.E. 87th

Portland, OR 97220

ORD 061483384

Van Waters &Rogers

Division of UNIVAR

3950 N.W. Yeon Avenue

Portland, OR 97210

ORD 009227398

ZB2671.A

Actiyity

Disposal trenches,

evaporation ponds,

storage buildings,

liquids solidification•

Storage and treatment.

Storage and treatment.

-2.35-

Permit Status

State permit issued.

Part B called.

State permit issued

Part B called by DEQ.

Sta te permit issued.

Part B called by DEQ.
•

•

•

Facility Address

Hewlett Packard Company

Corvallis Division

1020 N.E.Circle Blvd.

Corvallis, OR 97330

ORD 081182180

Tektronix, Inc.

Tektronix Industrial Park

Beaverton, OR 97077

ORD 009020231

u.s. Army

Umatilla Depot ActiVity

Hermiston, OR 97838

ORD 621382917

Safety-Kleen Corp.

550 Shelley Street

Springfield, OR

ORD 00712067

Safety-Kleen Corp.

11843 S.E. Highway 212

Clackamas, OR 97015

ORD 092895481

ZB2671.A

Actiyity

Storage

Surface impoundments,

storage, treatment

Storage

Storage

Storage

-2.36-

Permit Status

Part B permit jointly

issued by EPA/DEQ.

Sta te permit issued.

Part B called.

Part B permit jointly

issued by EPA/DEQ.

State permit issued.

Part B submitted

voluntarily.
•

•

! ..

FaCility Address

Globe Battery.

Div. of Johnson Controls

800 N.W. Third Avenue

Canby, OR 97013

ORD 010746402

Pacific Chemical

Laboratories, Inc.

1290 Industrial Way

Albany, OR 97321

ORD 085979474

Oregon Steel Mills

Div. of Gilmore Steel Corp.

14400 N. Rivergate Blvd.

Portland, OR 97208

ORD 009106055

Permapost Products

25600 S.W. TV Highway

Hillsboro, OR 97123

ORD 009041187

ZB2671.A

Actiyity

Storage

Storage and treatment

Surface impoundment

Surface impoundment

-2.37-

Permit Status

Part B permit jointly

issued by EPA/DEQ.

State permit issued.

Off-site waste no

longer accepted.

Going through

closure•

Sta te permit issued.

Part B called.

State permit issued.

Part B called.
•

••

Facility Address

Continental Can Co.

Plant 87

10200 N. Lombard Avenue

Portland, OR

ORD 009024613

McKesson Chemical Co.

4488 N.W. Yeon Avenue

Portland, OR

ORD 049799232

Teledyne Wah Chang

1600 N. E. Old Salem Road

Albany, OR 97321

ORD 050955848

Electronic Controls Design .

13626 S. Freeman Road

Mulino, OR 97042

ORD 003992518

Boeing of Portland

19000 N.E. Sandy Blvd.

Portland, OR 97230

ORD 054964481

ZB2671.A

Actiyity

Storage

Storage

Incinerator

Surface impoundment

Surface impoundment

-2.38-

Permit Status

Part B called.

Part B called

Part B called.

Part B called.

Part B called.
-.

•

...

Facility Address

Allied Plating Inc.

8135 N.E. Union Ave.

Portland, OR 97211

ORD 009051442

Vel co

3900 w. 1st Avenue

Eugene, OR 97402

ORD 009414400

Borden Chemical

Highway 82

La Grande, OR 97850

ORD 003938628

Georgia-Pacific

Resin Division

2190 Old Pacific Hwy. N.E.

Millersburg, OR 97321

ORD 000405233

L.D. McFarland

Highway 99N

Eugene, OR 97402

ORD 009026600

ZB2671.A

Actiyity

Surface impoundment

Surface impoundment -

Surface impoundment

Surface impoundment

Storage

-2.39-

Permit Status

Part B called.

Part B called.

Part B called.

Part A returned, by

EPA; not regulated.

Part B called.

Part A returned by

EPA; not regulated.

Part A filed.
•

•

Facility Address

John Taylor Lumber

Rods Creek Road

Sheridan, OR 9737 8

ORn 009042532

ZB2671.A

Storage

-2.40-

ActiVity Permit Status

Part A filed.
•

•

•

APPENDIX A
•

APPENDIX A

bctHeen

THE O?2GON D2?A?Tr·S~;T OF E!:'.'IRom·!E:1TF.L QUALITY

a:lC

T:~ ?U3LIC t;TILITY e-:J:'~-iISSIO!"r OF OP.EGON

In order to better control t~e trans?Qrt and disposal of cer~ain

nazardous wastes,

of underst~~ding.

"'ho ........- a=cve na~ed ~arties enter into this rrle~rancu=

THE OREGON DEP;l.RT:·r::~T OF E1NIP.om·!ENTAL QUALITY AGP.E:::S TO:

1. Design a manifest systen to monitor the flow of certain listed

•...ast es . DEQ will supply the necessary fc~s for said

• ..,

..:..

syster:t.

system will be dcta~ined jointly with the PUC•

Supply to the PUC a list of the wastes and known se::i:r3.to~s

that vtill be LncLuded :l.~ 't,.;."-1is sys t ern.

periodically.

:Jpdate the list

3. Eelp i~?le~ent t~e syste~ by notifying t~e generators a:.d

disposal site operators of its require4.~nts.

4. Assu~e ge~e~ator a~ci cis~osal site co~pliance thru

';'59. E90.

•

will be made to tne Enviro~~en~al Quality Commission to adopt

a ~ule re~~iring the listed ge~era~ors to co~?ly with th:

syste:;t.

5. Receive a~c a~alyze ~e?or~s qe~erated by the syste~; ~na t~

-2.25-
o. Assume enforcement res?Qnsibility :or violations of selid

waste or enviro~~entally hazardous waste regulatio~~.

',_0.' ~~ PU3LIC UT!L!TIES CCr~1ISS!ON AG?~ES TO:

1. Hold rule making pr~ceedings to adopt a new rule

transporters of wastes listed by the DEQ to participate in ~~e

manifest system. This would apply to intra and i~ter-state shi~ents.

2. Help impla~ent the system by noti=ying the tr~~sporters of

its requirements.

3. Develop jointly with t.~e' DEQ procedures needed to ioplement

I

!

and operate ~"le systa'tl.

4. ~~force participation in the system by all trans~orters

of such na7.ed wastes.

o

C~arles Davis

Cocmis'siencr

?~lic Utilities Division

-2.26-

Hillia=t H.

Director

Depar't=.ent of Enviro~~~~~al ('\,.." ; ,.-. a::;.---- -.;,
•

•

•

APPENDIX B
· -

•

-

1.

•

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

APPENDIX B

2. Issuance, renewal and modification of Hazardous Waste Disposal

Permits.

3. Notices of Intent to Suspend Sewage Disposal Service Licenses

FRED HANSEN

MICHAEL J. DOWNS

SHERMAN O. OLSON Jr.

HAROLD L. SAWYER

•

JAMES E. PETERSEN

MARY V. BISHOP·

WALLACE B. BRILL

ARNO H. DENECKE

A. SONJA BUIST

FRED HANSEN

MICHAEL J. DOWNS

4. 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

C:;:2GG May 30,

- 1 -
;.

7.

I ,

! ,-

8.

DEPARTMENT OF ENVIRONMENTAL QUALITY C._; SIGNATURE AUTHORIZATIONS _/

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

following:

FRED HANSEN

M!€H1tBEi J. BElHNS

JUDITH L. HATTON

LYDIA R. TAYLOR

Revolving Fund Checks

9.

10.

11.

12.

FRED HANSEN

MICHAEL J. DOWNS

JUDITH L. HATTON

LYDIA R. TAYLOR

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

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

Written Notice of Violations Subject to Civil Penalty

FRED HANSEN

MICHAEL J. DOWNS

FRED M. BOLTON

VAN A. KOLLIAS

FRED HANSEN

LYDIA R. TAYLOR

JUDITH L. HATTON

W"· Ep T T1&JjR

c

MK266

l-1ay 30, 1985

- 2 -
.:

/•'

•

DEPARTMENT OF ENVIRONMENTAL QUALITY

SIGNATURE AUTHORIZATIONS

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

FRED M. BOLTON

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

• 16.

FRED HANSEN

MICHAEL J. DOWNS

FRED M. BOLTON

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)

: ; i I

FRED HANSEN

MICHAEL J. DO~VNS

LINDA K. ZUCKER

18. Appointing authority

FRED HANSEN

MICHAEL J. DOWNS

SUSAN M. PAYSENO

17. Authorized representative to accept filing of documents in contested

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

- 3 -

FRED HANSEN

JUDITH L. HATTON

LYDIA R. TAYLOR

MK266

May 30, 1985

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

1000-297-0 and Checking Account #010-0300-425. Any two of the

following:

, ;

: ;

; l' ;

I

I \

i I I I I j

i !

i )

i 1

! J

I'

I i

'j

1

t

!

!

1

,'.j 1

.

:j I

'1 '

f
I

DEPARTMENT OF ENVIRONMENTAL QUALITY

SIGNATURE AUTHORIZATIONS

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

FRED HANSEN

MICHAEL J. DOWNS

21. 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

SHERRY CHEW

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

MICHAEL J. DOWNS

JUDITH L. HATTON

LYDIA R. TAYLOR

24. Department contact for Worker's Compensation matters

SUSAN M. PAYSENO

MK266

May 30, 1985

- 4 -
•

•

•

APPENDIX C
•

MEDIA, ALL MEDIA/Metro

226 for All the Media

~2 on Metro Section

164 All Others

Tom Alkire

408 SW 2nd, Rm 316

Portland, OR 97204

on top

KBPS RADIO

546 NE 12th

Portland, OR

APPENDIX C

ARGUS

Box 29

Hillsboro, OR 97123

KCNR

Box 197

portland, OR 97201

•

•

ASSOCIATED PRESS

1320 SW Broadway

Portland, OR 97201

CLACKAMAS COUNTY NEWS

Box 549

Estacada, OR 97023

DAILY JOURNAL OF COMMERCE

Box 10127

portland, OR 97210

DAILY SHIPPING NEWS

1221 SW Alder st

Portland, OR 97205

DOWNI'OWNER

Box 4227

Portland, OR 97208

ENTERPRISE-COURIER

Box 471

Oregon City, OR 97045

GRESHAM OUTLOOK

Box 880

Gresham, OR 97030

HERALD

Box 250

Canby, OR 97013

KATU TELEVISION CENTER

Assignment Desk

Box 2

Portland, OR 97207

KBOO

20 SE Eighth

Portland, OR 97214

KEX

Nf?tIsroom

4949 SW Macadam

Portland, OR 97201

KGAR

5620 - H. Gehr Road

Box 4638

Vancouver, WA 98662

KGON-FM

Box 22125

Portland, OR 97222

KGW - RADIO NEWS

1501 SW Jefferson

Portland, OR 97201

KGW-TV

1501 SW Jefferson

Portland, OR 97201

KINK-FM

1501 SW Jefferson

Portland, OR 97201

KJIB-FM

931 SW King Ave.

Portland, OR 97205

KKEY RADIO

Box 5757

Portland, OR 97228

KKSN

Box 3910

Portland, OR 97208

KLLB

2040 SW First

Portland, OR 97201
KMHD

Attn: News

Mt. Hood Community College

26000 SE Stark

Gresham, OR 97030

KMJK

9500 SW Barbur Blvd

Suite 302

Portland, OR 97219

KOAP-FM

2828 SW Front St

Portland, OR 97201

KOAP-TV

2828 SW ·Front

Portland, OR 97201

KOIN-TV

222 SW Columbia

Portland, OR 97201

KPDQ RADIO

5110 SE Stark

Portland, OR 97215

KPTV-TV

Attn: News Driector

Box 3401

Portland, OR 97208

KQFM

4949 SW Macadam Ave

Portland, OR 97201

KRDR

Box 32

Gresham, OR 97030

KRRC RADIO

Reed Coll ege

Portland, OR 97202

KUIK

Box 496

Hillsboro, OR 97123

KUPL

6400 SW Canyon Court

Portland, OR 97221

KWJJ RADIO

931 SW King Ave

Portland, OR 97205

KXL Radio

Box 14957

Portland, OR 97214-0957

KYTE

Box 970

Portland, OR 97207

KYXI

1220 SW Fifth

Portland, OR 97204

KZEL

2100 W 11th Ave.

Eugene, OR 97402-3578

LAKE OSWEGO REVIEW

Box 548

Lake Oswego, OR 97034

McCRAW HILL WORLD NEWS

Rosanne King

Box 40322

Portland, OR 97240

METRO MAGAZINE

1023 SW Yamhill

Portland, OR 97205-2544

THE NEIGHBOR

Box 10889

Portland, OR 97210

OBSERVER

Box 3137

Portland, OR 97208

OREGON LABOR PRESS

1902 SE Morrison St

Portland, OR 97214

OREGON MAGA ZINE

208 SW Stark, Suite 500

Portland, OR 97204

PIONEER

Box 168

Molalla, OR 97038

PORTLAND GUIDE

4475 SW Scholls Ferry Road, #256

Portland, OR 97225

PORTLAND MAGA ZINE

221 NW Second Ave.

Portland, OR 97209

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ST. JOHNS REVIEW

8410 N Lombard

portland, OR 97203

SKANNER

Box 5455

Portland, oR 97228

THE BUS INESS JOURNAL

Box 14490

Portland, OR 97214

THE COLUMBIAN

Attn: John Harrison

701 W 8th St

Vancouver, WA 98660

THE NE.W REVIEW

2919 SE Oak Grove Blvd.

Milwaukie, OR 97222

THE OREGONIAN

Attn: City Desk

1320 SW Broadway

Portland, OR 97201

THIS WEEK

Box 4227

Portland, OR 97208

TIMES PUBLISHING CO.

Box 370

Beaverton, OR 97075

UNITED PRESS INTERNATIONAL

1320 SW Broadway

Portland, OR 97201

VALLEY TIMES

Box 370

Beaverton, OR 97005

WILIAMETTE WEEK

Attn: Linda Keene

320 SW Stark

Portland, OR 97204

THE WASHINGrCN COUNTY

NEWS-TIMES

Box 365

Forest Grove, OR 97116

MEl'RO MEDIA LIST ENDS HERE

APPEAL-TRIBUNE

Box 35

Silverton, OR 97381

ASSOCIATED PRESS

c/o Daily Couri er

409 SE 7th

Grants Pass, OR 97526

BAKER DEMOCRAT-HERALD

Box 807

Baker, OR 97814

BAY NEWS

757 Newmark

Coos Bay, OR 97420

BAY REPORTER

757 Newmark

Coos Bay, OR 97420

BROOKINGS-HARBOR PILOT

Box 700

Brookings, OR 97415

BROWNSVILLE TIMES

Box 278

Brownsville, OR 97327

CAPITAL PRESS

Box 2048

Salem, OR 97058

CENTRAL OREGONIAN

Attn: John Gervais

558 N Main

Prineville, OR 97754

CHIEF

Box B

Clatskanie, OR 97016

CHRONICLE

414 Federal St.

Creswell, OR 97426

CHRONICLE

Box 457

St. Helens, OR 97051

CHRONICLE

Box 902

The Dalles, OR 97058
COLUMBIA PRESS

Box 130

Warrenton, OR 97146

CORVALLIS GAZETTE-TIMES

600 SW Jeff erson

Corvallis, OR 97330

COTTAGE GROVE SENTINEL

Box 35

Cottage Grove, OR 97424

COURIER

Box 268

Reedsport, OR 97467

CURRY COUNTY REPORTER

Box 766

Gold Beach, OR 97444

DAILY ARGUS OBSERVER

Box 130

Ontario, OR 97914

DAILY ASTORIAN

Box 210

Astoria, OR 97103

DAILY TIDINGS

Box7

Ashland, OR 97520

DEAD MT. ECHO

Box 900

Oakridge, OR 97463

DEMOCRAT-HERALD

Box 130

Albany, OR 97321

EAGLE POINT INDEPENDENT

News Director

PO Box 900

Eagle Point, OR 97524

EAST OREGONIAN

Box 1089

Pendleton, OR 97801

EASTERN OREGONIAN

Box 149

Hermiston, OR 97838

EN1'ERPRISE

Box 26

Drain, OR 97435

ENTERPRISE

Box 348

Mill City, OR 97360

EUGENE REGISTER GUARD

Attn: News Editor

Box 10188

Eugene, OR 97401

~TE CITY JOURNAL

Box 785

Nyssa, OR 97913

GAZETTE TIMES

Box 746

Condon, OR 97823

GLOBE-TIMES

Box 746

Condon, OR 97823

GRANTS PASS COURIER

Box 1468

Grants Pass, OR 97526

GRAPHIC

Box 100

Newberg, OR 97132

GREATER OREGON

Box 189

Albany, OR 97321

HEADLIGHT HERALD

Box 232

Tillamook, OR 97141

HELLS CANYON JOURNAL

Box 646

Halfway, OR 97834

HERALD

Box 250

Canby, OR 97013

HERALD

Box 46

Hermiston, OR 97838

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HERALD & NEWS

Box 788

Klamath Falls, OR 97601

ILLINOIS VALLEY NEWS

Box nMn

Cave Junction, OR 97523

JUNCTION CITY TIMES

Box 108

Junction City, OR 97448

KACI

Box 516

The Dall es, OR 97058

KAGI

Box 148

Grants Pass, OR 97526

KAJO

Box 230

Grants Pass, OR 97526

KASH

Box 10767

Eugene, OR 97401

KATR

130 E 13th Ave

Eugene, OR 97401

KBBR

Box 308

North Bend, OR 97459

KBCH

Box 358

Lincoln City, OR 97367

KBKR

Box 110

Baker, OR 97814

KBMC-FM

205 W 8th

Eugene, OR 97401

KBND

News

Box 5037

Bend, OR 97701

KBOY AM & FM

107 E Main, Suite 12

Medford, OR 97501

KBZY

Box 14900

Salem, OR 97309

KCBY-TV

Box 1156

Coos Bay, OR 97420

KCIV-FM

Box 104

The Dall es, OR 97053

KCMX

Box 128

Ashland, OR 97520

KCYX

Box 207

McMinnville, OR 97128

KDRV-TV

John Wooliscroft

Assignment Editor

1090 Knutson Ave •

Medford, OR 97504

KDUN

Box 1470

Reedsport, OR 97467

KOUK

Route 2, Box 502

Eugene, OR 97401

KECH

4923 Indian School Rd., NE

Salem, OR 97305

KEZI-TV

2225 Coburg Rd

Eugene, OR 97401

KFIR

Box 611

Sweet Home, OR 97386

KGAL

Box 749

Albany, OR 97321
KGAY

Box 1430

salem, OR 97308

KGRL

Box 5068

Bend, OR 97708

KHSN

Box 180

Coos Bay, OR 97420

KHUG

240 Fern Valley Rd., Box H

Phoenix, OR 97535

KlHR

Box 360

Hood River, OR 97031

KJDY

Box 399

John Day, OR 97845

KLBM

Box 907

La Grande, OR 97850

KLCC

4000 30th St.

Eugene, OR 97405

KLOO

Box 731

Corvallis, OR 97330

KIAD AM & FM

Box 489

Klamath Falls, OR 97601

KMED

820 Crater Lake Ave.

Medford, OR 97504

KMUN

1129 Commercial

Astoria, OR 97103

KNPT

Box 1028

Newport, OR 97365

KNl'R-TV

Box 7365

Eugene, OR 97401

KOBl-TV

Box 5M

Medford, OR 97501

KOHl

Box 398

St. Helens, OR 97051

KOHU

Box 145

Hermiston, OR 97838

KOTl-TV

Box 2K

Klamath Falls, OR 97601

KPNW AM & FM

Box 1120

Eugene, OR 97440

KQEN

936 SW Medford

Roseburg, OR 97470

KQlK

8C 64 Box 46

Lakevi ew, OR 97630

KRNR

Box 910

Roseburg, OR 97470

KRNS

Box 271

Burns, OR 97720

KROW

Box 396

Dallas, OR 97338

KRSB-FM

829 SE Cass

Roseburg, OR 97470

KSOR

Attn: Tom Olbrick

1250 Siskiyou Blvd

Ashland, OR 97520

KSRV

Box 129

Ontario, OR 97914

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KSWB

Box 24

Seaside, OR 97138

~OO

Box 568

Toledo, OR 97391

KTIL

Box 112

Tillamook, OR 9714l

KTIX

Box 640

Pendleton, OR 97801

KTMr

Box 159

Medford, OR 97501

KTVL-TV

Box 10

Medford, OR 97501

KUMl\

Box 340

Pendleton, OR 97801

KURY

Box 1029

Brookings, OR 97415

KVAL-TV

Box 1313

Eugene, OR 97440

KVAS

1490 Marine Dr

Astoria, OR 97103

KWIL & KHPE

Box 278

Albany, OR 97321

KWRC

555 Pacific Hwy

Woodburn, OR 97071

KWRO

Box 398

Coquille, OR 97423

KWVR

107 SW First St

Enterprise, OR 97828

KYES

829 SE Cass

Roseburg, OR 97470

KYET- WBJ NEWS

Box 157

Ontairo, OR 97914

KYJC

1840 Barnett Rd.

Medford, OR 97504-8250

KZEL

2100 W 11th Ave.

Eugene, OR 97402-3578

rAKE COUNTY EXAMINER

Box 271

Lakevi fi!il, OR 97630

IAMRON

OCE Campus

Monmouth, OR 97361

LEBANON EXPRESS

Box 546

Lebanon, OR 97335

Ml\IL

Box 729

Myrtle Creek, OR 97457

Ml\IL

Box 400

Stayton, OR 97383

Ml\IL TRIBUNE

Attn: Steve Myers

Box 1108

Medford, OR 97501

Ml\LHEUR ENI'ERPRISE

Box 310

Vale, OR 97918

MYRTLE POINT HERALD

410 Spruce st

Myrtle Point, OR 97458

NEWBERG TIMES

Box 68

Newberg, OR 97132
NEW ERA

Box 38

Sweet Home, OR 97386

NEWS

Box 390

Hood River, OR 97031

NEWS

Box 507

North Bend, OR 97459

NEWS

Box "J"

pilot Rock, OR 97868

NEWS

Box 5

Port Orford, OR 97465

NEWS GUARD

Box 848

Lincoln City, OR 97367

NEWS-REGISTER

Box 510

McMinnville, OR 97128

NEWS-RElJIE'l'l

Box 1248

Roseburg, OR 97470

NEWS TIMES

Box 965

Newport, OR 97365

OBSERVER

Box 3170

La Grande, OR 97850

OREGONAODIO NEWS

Attn: Greg Parker

State Capitol Press Room

Salem, OR 97310

OREGON DAILY EMERALD

University of Oregon

Box 3159

Eugene, OR 97403

OREGON PUBLIC BROADCASTING

Attn: John MacDonald

State Capitol, Rm. 400

Sal em, OR 97310

OREGON STATE DAILY BAROMETER

204 Memorial Union

Corvallis, OR 97330

THE OREGONIAN

Pauline Braymen

Star Route 1, Box 101

Burns, OR 97720

PIONEER

Box "W"

Madras, OR 97741

POLK COUNTY ITEMIZER-oBSERVER

Box 108

Dallas, OR 97338

POLK SUN

Box 26

Monmouth, OR 97361

POST

Box 68

Sandy, OR 97055

RECORD

Box 69

Pendleton, OR 97801

RECORD COURIER

Box 70

Baker, OR 97814

REVIEW

Box 330

Jefferson, OR 97352

SCAPPOOSE SPOTLIGHT

Box C

Scappoose, OR 97056

SHERW.N COUNTY JOURNAL

Box 284

Moro, OR 97039

SIGNAL

Box 848

Seaside, OR 97138

SIUSIAW NEWS

Box 10

Florence, OR 97439

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SPOKESM.Z>.N

Box 785

Redmond, OR 97756

STATESM.Z>.N JOURNAL

Attn: News Editor

Box 13009

Salem, OR 97309

STAYTON MA IL

Box 400

Stayton, OR 97383

SUN

Box 68

Sheridan, OR 97378

SUN-TRIBUNE

Box 430

Sutherlin, OR 97479

THE BULLETIN

1526 NW Hill St.

Bend, OR 97701

THE COLUMBIAN

Box 180

Vancouver, WA 98666

THE SPRINGE'IELD NEWS

Box 139

Springfield, OR 97477

THE WHEELER SAGE

Box 305

Fossil, OR 97830

TI MES HERALD

Box 473

Burns, OR 97720

TRIBUNE

Box 68

Dayton, OR 97114

UNITED PRESS INTERNATIONAL

10 State Capitol

Salem, OR 97310

VALLEY SEN!'INEL

#1 Bartan's Valley

Coquille, OR 97423

WALIA WALIA UNION BULLETIN

1st & Poplar Sts

Walla Walla, WA 98362

WALLOWA COUNTY CHIEFl'AIN

Box 338

Enterprise, OR 97828

WEEKLY

Box 248

Bandon, OR 97411

WEST LANE NEWS

Box 188

Veneta, OR 97487

WESTERN WORLD

Box 248

Bandon, OR 97411

THE WORLD

Box 1840

Coos Bay, OR 97420
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MEDIA.IP Releases to Interested

Persons

35 Names ~/7 /~

DEQ

3rd Floor Receptionist

Mary V. Bishop

01520 SW Mary Failing Drive

Portland, OR 97219

Wallace Brill

75 Lozi er Lane

Medford, OR 97501

Dr. Sonja Buist

Health Sciences University

Room 2052, Baird Hall

3181 SW Sam Jackson Park Rd.

Portland, OR 97201

Burlington Northern Railroad

Attn: Michael D. Abbott

1515 W 39 Street

Vancouver, WA 98660

Arno Denecke

3890 Dakota Road, SE

Salem, OR 97302

James E. Petersen, Chairman

Environmental Quality Commission

835 NW Bond Street

Bend, OR 97701

Phil Adamsak

2075 SW 78th Ave.

Portland, OR 97225

Pat Amedee

Governor's Office

160 State Capitol

Salem, OR 97310

Judy VanDyke

Metropolitan Area Communications

Commission (MACC)

12655 SW Center St.

Beaverton, OR 97005

Bob Jacobson

Press Officer

EPA Region X

1200 Sixth

Seattle, WA 98101

KAAR RADIO

Craig Batterson, News Director

6301 NE Hwy 99

Vancouver, WA 98665

KEDO-AM/KLYK-FM

Stephen Knightly

Box 779

Longview, WA 98632

KOIN-TV

Newsroom 6 at Noon

140 SW Columbi a

Portland, OR 97201

LANE REGIONAL AIR POLLUTION

AUTHORITY

Marty Douglass

1244 Walnut Street

Eugene, OR 97403

LEAGUE OF WOMEN VOTERS

Mary Ann Rombach

85782 Springfield-Creswell Hwy.

Pleasant Hill, OR 97455

LE.'WIS RIVER NEWS

Attn: Karen smaalders

Box 39

Woodland, WA 98674

Craig Lucas, Acquisitions Mgr.

EIC/Intelligence

48 W 38th St, 7 Floor

New York, NY 10018

Cindy Mackey

9029 SW 7th Ave.

Portland, OR 97219

Elva McLellan

8410 SW 45th Ave •

Portland, OR 97219
Denny Miles

Governor's Office

246 State Capitol

Salem, OR 97310

Sue Muzik

2104 SE Morrison St.

portland, OR 97214

OREGON ENVIRONMENTAL COUNCIL

John A. Charles

2637 SW Water Ave.

Portland, OR 97201

OREGON SMALL BUSINESS COUNCIL

Attn: Hank Crawford

Box 455

Salem, OR 97308

OREGON STATE HIGHWAY DIVISION

Attn: Bob Bard

Environmental Section

Transportation Bldg., RID 412

Salem, OR 97310

PORTLAND AUTO TRADES

Bill Stewart

3331 SE Milwaukie Ave.

Portland, OR 97202

RADIO NEWS NETWORK

Gussi e McRobert

Box 151

Gresham, OR 97030

Dan Reed

Canby Cable

Box 780

Canby, OR 97013

RESOURCE RECOVERY REPORT

Attn: Frank McManus

5313 38th. st., NW

Washington, DC 20015

Scott Riordan

S-30l

State Capitol

Salem, OR 97310

THE DAILY NEWS

Attn: Andre Stepankowski

Box 189

Longview, WA 98632

UNIVERSITY OF OREGON SURVIVAL CTR.

Media Coordinator

Suite 1 - EMU II

Eugene, OR ·97403

Deborah Janes (MD-5)

USEPA, Mail Drop 50

Research Triangle Park, NC 27711

Wakeman/Walworth, Inc.

Research Department

Box 1939

New Haven, CT 06509

WASHINGTON DEPT. OF ECOLOGY

Attn: Ats Kiuchi

Public Affairs

l1ail Stop PV-ll

Olympia, WA 98504

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PUB2 (Hazardous Waste Rules & Notices) 550 Names

PUB2(0079)

PUB2(0078)

PUB2 (0021)

98421

Airo Services, Inc.

4110 E 11th St.

Tacoma, WA

PUB2 (0038)

PUB2(0047)

PUB2(0084)

Grace Alcala

351 Philps Court

Irving, TX 75038

Carl Reller

Alaska Dept. of Environ. Conservat.

Hazardous Waste Program

Pouch non

Juneau, AK 99811

PUB2(0083)

80217

15317

97056

R.C. Garza

AMO Pollution Services

Rd 2, Box 31lB

Canonsbury, PA

Marge Furukawa

AT&E Corp.

PO Box 419

Scappoose, OR

ANR Freight System

J.D. Turner,

Director of Safety

PO Box 5070

Denver, CO

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PUB2(0074)

PUB2(0082)

PUB2(0025)

PUB2(0081)

98445

PUB2(0088)

James Dille

All Metro Spray

PO Box 648

Clackamas, OR 97015

PUB2(0087)

PUB2(0090)

PUB2(0086)

W.R. Aldworth

316 N 22 Ave.

Yakima, WA 98902

Alliance of American Insurers

Debra G. Wozniak, Associate Counsel

Government Affairs Dept.

1501 Woodfield Rd., Suite 400 W

Schaumburg, IL 60195

Lee D. Allison, P.E.

9917 Portland Ave.

Tacoma, WA

Michael Higgins

Analytical Technologies, Inc.

1932 25 Ave., E

Seattle, WA 98112

97201

97330

Mike Osler

AT&T

PO Box 121

Room 0-515

Pleasanton, CA 94566

PUB2(0080)

Don Bauhofer

Advanced Power Technology, Inc.

15 SW Colorado St.

Bend, OR 97701

The Adhesive & Sealant Council

Kris Anne Monteith

1600 N Wilson Blvd., Suite 910

Arlington, VA 22209

Agri-Business Council

D. Hobbs

1437 SW Columbia

Portland, OR

Paul Cottengim

Ag Air Carea, Inc.

637 NW Walnut

Corvallis, OR

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PUB2(0091) PUB2(0077)

PUB2(0022)

Bruce H. Anderson

Attorney at Law

777 High St., Suite 200

Eugene, OR 97401

PUB2(0100)

98124

o

97814

Baker County Court

Courthouse

Baker, OR

Tom Waite

BeS

PO Box 24346

MiS 7A-52

Seattle, WA

97339

Glenn Woods

Arrow Transportation

PO Box 10106

Corvallis, OR

PUB2(0092) PUB2 (0099)

PUB2 (0095)

Arvensis, Inc.

4000 Bennett Creek

Cottage Grove, OR 97424

J.T. Baker Chemical Co.

Robert T. Quier, Jr.

Seminar Director

222 Red School Lane

Phillipsburg, NJ 08865

PUB2 (0098)

PUB2(0102)

Jean Baker

2607 SE Monroe

Milwaukie, OR 97222

Torn Donaca

Associated Oregon Industries

PO Box 1006

Tualatin, OR 07062

PUB2(0094)

Gordon Fultz

Association of Oregon Counties

PO Box 12729

Salem, OR 97309

Dick Barney

906 Jefferson st.

Oregon City, OR 97045

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PUB2(0093) PUB2(0104)

Kess Cannon

Association of Oregon Counties

PO Box 12729

Salem, OR 97309

Robert L. Teague

Bayliner Marine Corp.

PO Box 24467

Seattle, WA 98124

PUB2(0070) PUB2(0105)

Dick Sirnantel

Atec Co.

911 SE Jannsen Rd.

Clackamas, OR 97015

Sidney V. Grover

Bayside Waste Hauling

PO Box 46108

Seattle, WA 98146

PUB2(0096) PUB2(0056)

BASF Wyandotte Corporation

Ida Fine, Coordinator

Corporate Environmental Protection

PO Box 181

Parsippany, NJ 07054

Beaverton Parts & Manufacturing

1800 NW 216th

Hillsboro, OR 97123

o
PUB2(0050)

PUB2 (0106)

97232

PUB2 (0114)

97207

97440

PUB2 (0113)

Bohemia, Inc.

Hal McCall

PO Box 1819

Eugene, OR

Allan Mick

Boise Cascade Corp.

PO Box 1414

Portland, OR

98225

W.H. Englander

City of Bellingham

Dept. of Public Works

210 Lottie St.

Bellingham, WA

Benchmark Design

815 NE 22nd

Portland, OR

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PUB2(0107) PUB2 (0116)

Benton County Health Dept.

Supervising Sanitarian

530 NW 27th

Corvallis, OR 97330

Allen Willis

Boise Cascade Corp.

PO Box 1414

Portland, OR 97208

PUB2(0023) PUB2 (0115)

PUB2(0109)

PUB2 (0110)

Mike Vossen

Boise Cascada Papers

St. Helens, OR

Boysen Paint Co.

Ken Bleasdell, Production Mgr.

2100 NW 22 Ave.

Portland, OR 97210

97203

PUB2 (0119)

PUB2(0120)

Norman Hutsell

Borden Chemical

PO Box 03127

Portland, OR

97339

64114

97219

Santford Ramsey

Bertea Aviation

PO Box 606

Corvallis, OR

Gerald A. Neely

Black & Veatch

Box 8405

Kansas City, MO

Bob's Sanitary, Inc.

10101 SW Lancaster

Portland, OR

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PUB2 (0111) PUB2(0122)

Boeing Commercial Airplane Co.

Hassan Gazarine

PO Box 20487

Portland, OR 97220

Lanny T. Hubbard

Ministry of the Environment

810 Blanshard St.

Victoria, BC VSv lX5

PUB2 (0112) PUB2 (0061)

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The Boeing Company

Herbert L. Gaskill,

Hazardous Waste Manager

Box 3707, Mail stop 9A-43

Seattle, WA 98124

Marilyn Burwell

Brown & Burwell

100 W Harrison

Seattle, WA 98119
PUB2(0124) PUB2 (0134)

PUB2(0128)

Michael D. Abbott

Burlington Northern Railroad

1515 W 39 St.

Vancouver, WA 98660

PUB2(0127)

PUB2(0126)

95814

PUB2 (0136)

PUB2(0137)

PUB2 (0133)

Peter A. Rogers, Acting Chief

Hazardous Waste Mgmt. Branch

714 P Street, Room 523

Sacramento, CA 95821

Lynne Bolar

California Research

1024 lOth St.

Sacramento, CA

California Envr. Technology

130 Whittier Rd.

Pleasant Hill, CA 94523

California Department of Health

744 PSt.

Sacramento, CA 95814

97701

97223

97440

Brown

& Caldwell

Attn: Library

PO Box 11680

Eugene, OR

The Bulletin

City Desk

Bend, OR

Mrs. Billy O. Burnam

14235 SW 97th

Tigard, OR

PUB2(026l) PUB2(0135)

C.K. Heffner

PO Box 1608

Medford, OR 97501

PUB2(0129)

Martin Haley

Public Affairs Information

State Regulatory Division

1024 10th St., Suite 300

Sacramento, CA 95814

o

PUB2 (0130)

CALINK, Div. Flintink

PO Box 02127

Portland, OR 97202

PUB2(0029)

Kathy Cantrell

Route 1, Box 222

Dufur, OR 97021

PUB2(013l)

Second Floor

97201

PUB2(0054)

PUB2 (0141)

OR

Capitol Body& Fender, Inc.

9741 SW Capitol Hwy

Portland, OR 97219

Cascade Farm Service

PO Box 268

Tangent,

95050

Karen Jarrell

CCA

2800 De La Cruz Ave.

Santa Clara, CA

Mike Kennedy

CH2M Hill

2020 SW 4th Ave.,

Portland, OR

PUB2(0108) PUB2(0142)

Dorothy R. Rice, Consultant

Assembly Committee on

Consumer Protection

State Capitol

Sacramento, CA 95814

Cascade Plating

3790 Cross

Eugene, OR 97402

o
PUB2 (0143)

PUB2(0145)

PUB2(0153)

PUB2 (0159)

98009

Chem-Security Systems

PO Box 1866

97862 Bellevue, WA

Century Chemical Corp.

Route 1, Box 208

Milton-Freewater, OR •

Century West Engineering Corp.

Tom Miller

PO Box 1174

Bend, OR 97709

Chern-Security systems, Inc.

Bill VanDyke

PO Box 1269

Portland, OR 97207

PUB2(0144) PUB2(0156)

PUB2 (0150)

Champion International Corp •

Environmental Affairs

PO Box 10228

Eugene, OR 97440

Century West Engineering Corp.

Carol McMullen

Business Developnent Rep.

PO Box 1174

Bend, OR 97709

•

James Chaffer

2244 N Watts

Portland, OR

PUB2 (0041)

97217

PUB2 (0146)

Chem-Security Systems, Inc.

Dixi e Darrow

Star Route

Arlington, OR 97812

PUB2(0158)

Chem-Secu+ity Systems, Inc.

Patricia Payne Underwood

Public Affairs

PO Box 1866

Be llevue, WA 98009

PUB2 (0157)

Chem-Security Systems, Inc.

Alex Koch

Transportation Manager

PO Box 1866

Be 11 evue , WA 98009

PUB2(0155)

PUB2 (0154)

Leonard D. Toner, Operations Mgr.

Chem Nuclear Systems, Inc.

PO Box 726

Barnwell, SC 29812

97207

43085

92122

PUB2 (0149)

PUB2 (0152)

PUB2(0009)

Chem-Security, Ltd.

l80~1200 W Pender st.

Vancouver, BC V6E 2S9

Robert A. Epler

Chern-Technics, Inc.

5530 Block St.

San Diego, CA

Mark W. Beliczky

ChemLawn Corp.

8275 N High St.

Columbus, OH

97812

Chern-Security systerns

General Manager

Star Route

Arlington , OR

Chem-Security

Joyce Alkastassy

PO Box 1269

Portland, OR

•
PUB2 (0147) PUB2 (0166)

Dennis Stefani

Chemical Processors, Inc.

5501 Airport Way S.

Seattle, WA 98108

M.W. Cooper

Chembond Corp.

PO Box 270

Springfield, OR 97477

PUB2(0148)

Clark's Air Service, Inc.

PO Box 56

Nampa, ID 83651

PUB2(0167)

Clorox Co.

Robin Ferguson

Government Affairs Dept.

PO Box 24305

Oakland, CA 94623

o

PUB2 (0151) PUB2(0060)

Chempro of Oregon, Inc.

2416 N Marine Dr.

Portland, OR 97217

Color & Design Exhibits Int'l, Inc.

3625 N Mississippi

Portland, OR 97227

PUB2(0161) PUB2 (0168)

Chevron Pipeline Co.

W.N. Harmon

201 N Phillipi St.

Boise, ID 83706

Columbia Woman's Club

Annie Lee, President

22494 Spruce Way

Scappoose, OR 97056

PUB2(0160)

Chevron Pipeline Co.

L.J. Siebert

PO Box 25117

Salt Lake City, UT 84125

PUB2 (0170)

Commercial Cartage Co.

Lawrence A. Lewis, V.P.

343 Axminister Dr.

Fenton, MO 63026

c

PUB2 (0162) PUB2 (0171)

PUB2(0163)

PUB2 (0019)

PUB2 (0164)

Bob Christopher

Blodgett, OR 97326

Conoco

Hazardous Materials

Surface Transportation Dept.

PO Box 2197

Houston, TX 77252

PUB2 (0172)

PUB2 (0173)

Continental Can Co., USA

Jerry J. Parson

PO Box 03220

portland, OR 97203

Continental Pipe Line Co.

338 Highway 87 East

Billings, MT 59101

97005

97208

Chloride Western

Toni Reding

11155 SW Denney Rd.

Beaverton, OR

Chevron USA, Inc.

Les Ferdig

PO Box 4168

Portland, OR

The City Club of Portland

730 SW First

Portland, OR 97204 Guy Cooper

Box 2556

Hailey, ID

PUB2(0174)

83333

c
PUB2 (0177)

•

City of Corvallis

Utilities Dept.

PO Box 1083

Cor valis, OR 97339

PUB2(0055)

Dick Ruth

DEQ Lane Pollution Control

1244 Walnut

Eugene, OR 97403

PUB2(0178) PUB2(0187)

PUB2(0182)

PUB2(0180)

PUB2 (0181)

Corvallis Commercial Sprayers

PO Box 743

Corvallis, OR 97339

90040

97133

PUB2 (0189)

PUB2 (0188)

Cuite 500

98125

PUB2(0030)

Daelco, Inc.

T.B. Blair

5909 E Randolph st.

City of Commerce, CA

Dam es & Moore

Ann Toepker

155 NE 100 St.,

Seattle, WA

Dant & Russell, Inc.

Don Johnson, Mgr.

775 SW Hillcrest

North Plains, OR

Sandy Davis

3056 NE Alameda Terrace

Portland, OR 97212

97217

97217

98032

Crosby & Overton, Inc.

Bonnie Boyd

5420 N Lagoon

Portland, OR

Crosby & Overton, Inc.

John Mobley

5420 N Lagoon

Portland, OR

Crosby & Overton, Inc •

John Funderburk

20245 76 Ave., S

•

Kent, WA

PUB2(0183) PUB2(0190)

PUB2(0185)

PUB2 (0186)

Crowley Environmental Services

Operational Supervisor

PO Box 17178

Portland, OR 97217

Crown Zellerbach Corp.

Elven Anderson

Flexible Packaging Div.

PO Box 17128

Portland, OR 97217

PUB2(0076)

PUB2 (0191)

Don Debord

14025 N Rivergate Blvd.

Portland, OR 97203

Sebastian Degens

4515 SE Madison

Portland, OR 97215

Tamara Schaffer

Deschutes National Forest

Ft. Rock Ranger Dist.

1645 Highway 20 E

Bend, OR 97701

98607

Crown Zellerbach Corp.

Dr. J.F. Cormack

Environmental Services

904 NW Drake St.

Camas, WA

•
PUB

2 (0193) PUB2(0202)

Diamond Industries

PO Box 1008

550 SE Mill st.

Grants Pass, OR 97526

EMCON Assoc.

Lee Dooley

90 Archer st.

San Jose, CA 95112

o

PUB2 (0194) PUB2(0204)

PUB2 (0195)

PUB2(0196)

Durametal Corp.

Ken Hall, Product Engr.

Tualatin, OR

Douglas County Public Works

Warren H. Poland

Courthouse

Roseburg, OR 97470

97223

97843

97214

203B

95691

97477

PUB2 (0401)

PUB2(0016)

EnviroData Systems, Inc.

PO Box 723492

Atlanta, GA 30339

Emergency Management Div.

43 Capitol Bldg.

Salem, OR 97310

PUB2(0205)

Ekstrom Farm Chemicals

PO Box 43

lone, OR

PUB2(0207)

PUB2 (0200)

PUB2(0027)

PUB2(0206)

Ecotherm

Eric Peterson

2101 Stone Blvd~, Suite

West Sacramento, CA

Connie Sahm

Emerald POD

PO Box 822

Springfield, OR

Bill Doern

Eastern Oregon Distributing

PO Box 1221

La Grande, OR 97850

Eastside Plating, Inc.

C.W. TAber, Plant Mgr.

310 SE Stephens

Portland, OR

Dr. Craig Eagleson

8900 SW Commercial

Tigard, OR

30365

98216

97202

PUB2 (0201)

PUB2 (0198)

PUB2(0197)

PUB2 (0199)

E.I. DuPont Co.

R.G. Gressel

PO Box 02128

Portland, OR

EG&G Idaho, Inc.

K.F. Downs

Low-Level Waste Mgmt. Program

PO Box 1625

Idaho Falls, ID 83415

ECCO

Jane Baker

1885 SE 104th

Portland, OR

Garden Club

Fern Donovan

32954 Scappoose Vernonia Way

Scappoose, OR 97056

John Dickinson

Residuals Mgmt. Branch

345 Courtland St., NE

Atlanta, GA
PUB2(0209)

PUB2 (0208)

PUB2 (0211)

Environmental Management Corp.

Philip Badame

4211 Seneca St.

West s eneca , NY 14224

97210

93717

PUB2(02l7)

PUB2(02l8)

FMC Corp.

PO Box 1669

Fresno, CA

FMC Corp.

John LaFore

4700 NW Front Ave.

Portland, OR

FMC Corp.

Agricultural Chemical Div.

3675 Brooklake Rd., NE

Salem, OR 97305

PUB2 (0219)

470

20037

Environment Reporter

Patricia Spencer

1231 25 st., NW - Rm.

Washington, DC

Environmental Action Foundation

Lois Florence

724 Dupont Circle Bldg.

Washington, DC 20036

•

PUB2 (0214)

PUB2 (0210)

PUB2 (0213)

Environmental Management and

Compliance

Tom Echikson

135 Stevens Ave.

Little Falls, NJ 07424

97914

97814

PUB2 (0220)

PUB2(0057)

PUB2(0221)

Farmterials, Inc.

PO Box 1006

Baker, OR

Farmers Supply Co-op

514 SW Fourth Ave.

Ontario, OR

Fergusen Auto Body & Paint

2425 E Burnside

Portland, OR 97214

83647

Envirosafe Services

Neil Brill

Box 936

Mounta in Home, ID

•

PUB2(0216)

PUB2 (0215)

Evergreen Helicopters, Inc.

3850 Three Mil e Lane

McMinnville, OR 97128

Evans Products Co.

B.E. Mikulka

PO Box E

Corvallis, OR 97330

97303

PUB2(0223)

PUB2 (0224)

Floatation Application

Kent Hynes

5820 80 Ave., NE

Salem, OR

Forelaws on Board

Lloyd K. Marbet

19142 S Bakers Ferry Rd.

Boring, OR 97009

97440

Eugene Tree Spray

PO Box 10035

Eugene, OR

•
PUB

2 (0225) PUB2(0233)

PUB2 (0036)

Forrest Paint Co.

PO Box 2768

Eugene, OR 97402

General Electric Co.

Robert E. Butler

Vallecitos Nuclear Center

PO Box 460

Pleasanton, CA 94566

PUB2(0228)

PUB2(0229)

GATX Terminals

PO Box 03469

Portland, OR 97203

PUB2(0227)

c

97015

97034

PUB2(0236)

PUB2(0235)

PUB2(0234)

PUB2(0242)

PUB2(0005)

Georgia Pacific

Ronald Betournay

2665 Hwy 99N

Eugene, OR 97477

Geo-Mat, Inc.

PO Box 1425

Lake Oswego, OR

General Tree Service

15601 SE 90th

PO Box 247

Clackamas, OR

Dick webb

Georgia Pacific Chemical

PO Box 1268

Coos Bay, OR 97420

97389

90810

97448

97901

PUB2(0226)

GATX Terminals Corp.

Richard Sandell

PO Box 9007

Long Be ach, CA

Full Circle, Inc.

PO Box 274

Tangent, OR

Sam Fujishin

Route 2, Box 59

Adrian, OR

Larry Freepons

93545 Dorsey Lane

Junction City, OR

PUB2 (0232)

General Battery Corp.

Jeffrey A. Leed

Dept. of Environmental Resources

PO Box 1262

Reading, PA 19603

PUB2 (0097)

PUB2(0230)

o

97321

97223

97204

Georgia Pacific Corp.

Greg Gregory

PO Box 1068

Albany, OR

PUB2 (0238)

Georgia Pacific Corp.

Harvey Ellerbroek

PO Box 23189

Tigard, OR

Georgia Pacific Corp.

Nona M. Soltero

Law Dept.

900 SW Fifth Ave.

Portland, OR

PUB2(0237)

55164

55164

GNB Batteries

Nathan Nissen

PO Box 64100

St. Paul, MN

GNB Batteries, Inc.

E.C. Milton

PO Box 64100

St. Paul, MN
PUB2(024l) PUB2(0250)

•

Georgia Pacific Corp.

Darrell McLaughlin

Toledo Paper Div.

Box 580

Toledo, OR 97391

Good, Procter & Hoar

Betsy Kimball

Legal Assistant

28 State St.

Boston, MA 02109

PUB2 (0239) PUB2 (0251)

Georgia Pacific Corp.

Philip F. Hahn

PO Box 1918

Eugene, OR 97440

Gould, Inc.

F. Stark

6427 NE 59th Place

Portland, OR 97218

PUB2(0243) PUB2(0253)

Georgia Pacific Corp.

Masato Yoshinaka, Mgr.

1754 Thorne Road

Tacoma, WA 98421

John Halver

PUD NO. 1 of Grays Harbor Cnty.

PO Box 480

Aberdeen, WA 98563

PUB2(0067) PUB2(0026)

PUB2 (0244) PUB2(005l)

•

Jack Anderson

Georgia-Pacific Corp.

PO Box 105605

Atlanta, GA

Norma Jean Germond

224 Iron Mt. Blvd.

Lake Oswego, OR

30348

97034

Len Malmquist

Gresham Fire Dept.

1333 NW Eastman

Gresham, OR

H.S.S. Machine

12413 N Portland Blvd.

Portland, OR

97030

97217

Joe Gigliotti

PO Box 607

Eugene, OR

PUB2(0245)

97440

PUB2(0246)

R.E. Haberman

PO Box 907

Portland, OR

PUB2(0254)

97207

PUB2 (0255)

Gilliam County

Planning Dept.

PO Box 427

Condon, OR 97823

Haney Truck Line

Calvin Clayton

PO Box 485

Cornelius, OR 97113

•

PUB2 (0247)

Eugene G. Gjertsen, P.E.

2057 Lawrence

Klamath Falls, OR 97601

PUB2(0248)

Glass Spray Service, Inc •

PO Box 2523

Eugene, OR 97402

PUB2(0256)

Harding-Lawson Assoc.

6300 Westpark, Suite 100

Houston, TX 77057

PUB2(0257)

Harding-Lawson Associates

6300 Westpark, Suite 100

Houston, TX 77057
PUB

2 (0064) PUB2(0062)

PUB2(0048)

Clyde Iverson

Harris Pine Mills

Drawer 1168

Pendleton, OR 97801

Margaret C. Schweitzer

E.F. Houghton & Co.

Technical Center Library

Madison& VanBuren Ave.

Valley Forge, PA 19488

PUB2(0044)

o

PUB2 (0264)

Eric Perlav

Hazardous Materials Technical Ctr.

PO Box 8168

RockviU e, MD 20856

Hewlett-Packard Co.

Jim McDaniel,

Environmental Coordinator

1020 NE Circle Blvd.

Corvallis, OR 97330

PUB2(0270)

o

94553

76021

PUB2(0267)

PUB2 (0271)

PUB2(0268)

Roberta Pence

IASA

PO Box 929

Bedford, TX

ITT - Phillips Drill Div.

Jose ph Spighi

5209 SE International Way

Milwaukie, OR 97222

Idaho Dept. of Health& Welfare

Bill Hartford

Division of Environment

Statehouse

Boise, ID 83720

IT Corp.

Jack Allen

4575 Pacheco Blvd.

Martinex, CA

97208

97501

PUB2 (0262)

PUB2 (0263)

PUB2 (0018)

Hercules, Inc.

John Provost

PO Box 2723

Portland, OR

Rick Reno

Harry& David

PO Box 712

Medford, OR

PUB2 (0265)

PUB2(0042)

Don Walker

Hood River Electric Corp.

PO Box 125

Odell, OR 97044

Hi-Ball Trucking, Inc.

PO Box 1117

Billings, MT

Home Transportation

Adrian McClellan

PO Box 6426, StationA

Mari etta, GA

59103

30065

Idaho Dept. of Health& Welfare

Div. of Environment

Robert P. Olson

Statehouse

Boise, ID 83720

PUB2(0272)

Idaho Hazardous Materials Bureau

Daryl F. Koch

Statehouse

Boise, ID 83720

o
PUB2 (0290)

•

PUB2 (0046)

Morton Dorothy

Illinois Pollution Control Board

PO Box 61354

Ee ru, IL 61354

J.J. Keller & Assoc.

Colleen Olmsted

145 W Wisconsin Ave.

Neenah, WI 54956

PUB2(0266) PUB2(0280)

Independent Resource Service

Ron Graham

2928 SE Hawthorne

Portland, OR 97214

JC Inc.

Liquid Waste Disposal

3650 E 26th St.

Vernon, CA 90023

PUB2(0274) PUB2 (0286)

PUB2 (0277)

PUB2 (0276)

PUB2 (0275)

Industrial Aviation Services, Inc.

6736 Waconda Rd., NE

Salem, OR 97305

PUB2(0282)

Robert Weber

Jackson County Engineer

201 River Heights Way

Grants Pass, OR 97526

PUB2 (0281)

James River Corp.

Joh~Cuthbertson

Director, Environmental Affairs

PO Box 2218

Richmond, VA 23217

Jackson County Weed Control

Don Squire

200 Antelope Rd.

White City, OR 97501

97823

Inland Transportation Co., Inc.

Al Simpson

6737 Carson Ave., S

PO Box 80128

Seattle, WA 98108

Inland Chemical.

PO Box 252

Condon, OR

•

PUB2 (0279)

PUB2(0053)

International Paper Co.

David H. Critchfield

PO Box 809024

Dallas, TX 75380

PUB2(0278)

97526

PUB2(0284)

PUB2(0285)

PUB2(0269)

Jerry Jensen

Attorney General's Office

450 W State St., 7th Floor

Boise, ID 83720

Jones & Henry Engineers, Ltd.

2000 W Central Ave.

Toledo, OH 43606

Josephine County

Environmental Health

Courthouse

Grants Pass, OR

97015

Parkway

97123

98666

Inman 0 u Co.

PO Box 370

Vancouve t , WA

Iso Cast Systems, Inc.

8899 SE Jannesen Rd.

Clackamas, OR

Intel Corp.

John Harland

M!S TOD-03

5200 NE Elam Young

Hillsboro, OR

•
PUB2 (0288) PUB2(0295)

K-Lines, Inc.

PO Box 1549

Lak e Oswego, OR 97034

James A. Kyle

11540 SE 129th

Portland, OR 97236 o

PUB2(0287) PUB2 (0296)

PUB2(0289)

PUB2 (0298)

Lake County Commissioners

513 Center St.

Lakeview, OR 97630

KGW-TV

Paul Hansen

1501 SW Jefferson

Portland, OR

Terrence Kafara, S.I.

PO Box 491

Vancouver, WA

97201

98666

Lake Er i e Trucking

William W. Wooding

251 Rosario

Anacortes, WA 98221

PUB2 (0075) PUB2 (0299)

Nathan A. Graves

Kennedy/Jenks Engineers

4109 Bridgeport Way West

Tacoma, WA 98466

Lake Spray service

Philip H. Lake

78432 Mosby Creek Road

Cottage Grove, OR 97424

PUB2(0292) PUB2(0302)

PUB2(0293)

PUB2(0049)

Joe McBricE

Klamath Environmental Services

200 E Main st.

Klamath FAlls, OR 97601

Klamath County Solid Waste Mgmt.

Keith Read, Director

334 Main st.

Klamath Falls, OR 97601

o

PUB2 (0301)

PUB2(0303)

Lane County

Environmental Health Div.

Harold J. Youngquist, P.E.

125 E Eighth Ave.

Eugene, OR 97401

Lane County Public Services Div.

Craig Starr

125 E Eighth Ave.

Eugene, OR 97401

League of Oregon Cities

PO Box 928

Salem, OR 97308

97056

Kiwanis Club

Dr. Stephen Scheer

33460 SW Chinook Plaza

Scappoose, OR

PUB2(0294) PUB2(0304)

William A. Kucharski

920 SW Sixth Ave., 808 EB

Portland, OR 97204

Jim Watson

Kuni Cadillac

3725 SW Cedar

Beaverton, OR

PUB2 (0073)

Hills Blvd.

97005

League of Women Voters of

Columbia County

Edith BArtel

51270 Bankston Rd.

Scappoose, OR 97056

o
PUB2(0305)

•

Leber Ink Co., Inc.

John A. ARdussi

PO Box 88700

Tukwila, WA 98188

PUB2(0313)

Lilyblad Petroleum, Inc.

Bill C. Walsten

515 116 Ave. NE, sutie 160

Be llevue, WA 98004

PUB2(0307) PUB2 (0314)

PUB2(0309)

PUB2 (0308)

PUB2 (0071)

Leupold & Stevens, Inc.

Jay Vick

PO Box 688

Beaverton, OR 97075

PUB2(0316)

PUB2(0315)

Lincoln County Planning Dept.

Gail Stater

255 SW Coast Hwy

Newport, OR 97365

Linn County

Dept. of Health Services

Environmental Health Div.

PO Box 100

Albany, OR 97321

Linn County Extension Service

Hugh J. Hickerson

PO Box 765

Albany, OR 97321

PUB2 (0317)

Lincoln County Planning Dept.

Lincoln County Courthouse

Newport, OR 97365

97045

97208

Lee Engineering

Walt Mintkeski

708 Main St., Rm. 202

Oregon City, OR

Vernon Bogner

Lew Williams Cadillac

PO Box 4328

Portland, OR

Libby, McNeill, & Libby

L.V. Feldman

200 S Michigan Ave.

•

Chicago, IL 60604

PUB2(0310) PUB2 (0318)

PUB2 (0311)

98409

PUB2 (0312)

Brian Lightcap, Director

Soil & Water Conservation Dist.

13342 NW NeWberry Rd.

Portland, OR 97231

98401

PUB2(0320)

PUB2 (0319)

Litton Industries, Inc.

Neal Hartselle

1001 E Redwood Hwy

Grants Pass, OR 97526

Longview Paint & ~rnish Co., Inc.

W.R. Williams

PO Box 517

Longview, WA 98632

Les Lonning

PO Box 1496

97218 Tacoma, WA

Lige Dickson Co.

3315 S Pine st.

Tacoma, WA

Charles H. Lilly Co.

Richard Oliphant

7737 NE Killingsworth

Portland, OR

•
PUB2 (0322) PUB2 (0329)

Luhr Jensen & Sons, Inc.

C.T. BAll

PO Box 287

Hood River, OR 97031

Marion County

Director of Solid Waste Dept.

220 High st., NE

Salem, Or 97301

PUB2(0323) PUB2(0017)

Lynden Transport, Inc.

Ruth Thorn

PO Box 433

Lynden, WA 98264

Bob Gantenbe in

Marquess & Associates

1120 E Jackson St.

Medford, OR 97501

PUB2 (0324) PUB2 (0330)

MET-TEK, Inc.

15651 SE 125 Ct.

PO Box 414

Clackamas, OR 97015

Martin Marietta Aluminum

Joe Byrne

PO Box 711

The Dalles, OR 97058

PUB2(0325) PUB2(0331)

PUB2(0326)

PUB2 (0058)

PUB2(0332)

Matlack, Inc.

Glenn Woods, Terminal Mgr.

8101 NE 11 Ave.

portland, OR 97211

./

02108

Massachusetts DEQ

Betsy Goggin

One Winter St.

BO?tton, MA

97266

97219

Magic Auto Body

8487 SE Powell Blvd.

Portland, OR

Cindy Mackey

9029 SW Seventh

Portland, OR

Major Spray Service, Inc.

PO Box 19491

Portland, OR 97219

PUB2(0327)

PUB2 (0333)

John Matthews

4540 Singlestrand Ave., SE

Salem, Or 97302

PUB2(0334)

PUB2(0335)

McCall Oil & Chemical Corp.

Gary W. Hahn

808 SW 15 Ave.

Portland, OR 07205

Marine Safety Office

N.K. Swenson, Commanding Officer

6767 N BAsin AVe.

Portland, OR 97217

PUB2 (0006)

Jerry Carter

Marion Co. Dept. of Public Works

300 Senator Bldg.

220 High St., NE

Salem, OR 97301

McCall Oil & Chemical

PO Box 241

Astoria, OR 97103
PUB2(0337)

PUB2 (0336)

McCloskey Varnish Co. of the NW

4155 NW Yeon Ave.

Portland, OR 97210

PUB2(0343)

97501

97302

Medford Corporation

Lynn Newbry

PO Box 550

Medford, OR

Meeker Fertilizer Co.

1795 16 St., SE

Salem, OR

PUB2 (0342)

80228

McCoy & Associates

Janet M. MacNeil

13131 W Cedar Dr.

Lakewood, CO

•

PUB2(0007) PUB2(0344)

Curt McCracken

McCracken Motor Freight

PO Box 10304

Portland, OR 97210

Mercer Industries, Inc.

Jerry Boehm

PO Box 10166

Portland, OR 97210

PUB2 (0338) PUB2(0347)

PUB2 (0340)

PUB2 (0341)

PUB2 (0339)

PUB2 (0013)

97201

97204

97230

97201

PUB2(0346)

PUB2 (0351)

PUB2(0350)

Metro

Dennis O'Neil

577 SW.Hall

Portland, OR

PUB2(0348)

Metropolitan Area Communication

Commission

12655 SW Center, Suite 390

Beaverton, OR 97005

Metro

Solid Waste Dept.

527 SW Hall St.

Portland, Or

Mill er, Nash

Attn: Library

111 SW Fifth Ave.

Portland, OR

Miller Paint Co.

J.P. Buckinger

12730 NE Whitaker Way

Portland, OR

97210

97210

McKay's Truck Line, Inc.

PO Box 634

Albany, OR 97321

McKesson Chemical Co.

James M. Reid

4488 NW Yeon Ave.

Portland, OR

Jim REid

McKesson Chemical Co.

4488 NW Yeon Ave.

Portland, OR

McKesson Environmental Services

Bob Mowers

4488 NW Yeon Ave.

Portland, OR 97210

McKesson Environmental Services

Richard D. Fehler

6363 Clark Ave.

Dublin, CA 94568

•

•
PUB2 (0066) PUB2(0359)

Miller, Nash, Wiener,

Hagen & Car Lsen

Attn: Library

111 SW Fifth

Portland, OR 97204

Multnomah County Library

Jean Barnett

Oregon Documents Librarian

801 SW 10 Ave.

Portland, OR 97205

o

PUB2 (0552) PUB2 (0360)

PUB2(0361)

Kirk M. Mills

Environmental Engineer and

Pollution Control/3M

Box 33331

St. Paul, MN 55133

Sue Muzik

2104 SE Morrison st.

Portland, OR 97214

PUB2 (0028)

PUB2(0354)

PUB2(0362)

Brian Mohondro

17025 SW Vincent Ct.

Aloha, OR

Ken Morse

Box 3243

Central Point, OR

97007

97502

Myers Drum Co.

Roger C. Stavig

8435 NE Killingsworth

Portland, OR

Paul B. Jacoby

NACA

1!55 15 St., NW

Washington, DC

97220

20005

PUB2 (0356) PUB2 (0363)

Mt. Jefferson Group Sierra Club

Harry Demaray

576 Welcome Way, SE

Salem, OR 97302

Paul Parker

NARI

330 Madison Ave.

New York, NY 10017

o

PUB2(0252) PUB2(0365)

PUB2 (0357)

PUB2 (0358)

Mt. Hood Community College

James R. Graybill

Instructor of Fisheries

26000 SE Stark

Portland, OR 97030

Multnomah County Executfve

Dennis Buchanan

Portland Bldg., RM 1500

1120 SW Fifth Ave.

Portland, OR 97204

o

94086

97339

PUB2(0366)

PUB2(0364)

NCH Corp.

PO Box 61264

Sunnyvale, CA

National Paint & Coating Assn.

Robert Nelson

1500 Rhode Island Ave., NW

Washington, DC 20005

Andre L. CAron

NCASI

PO Box 458

Corvallis, OR

97448

Gary Mulkey

PO Box 81

Junction City, OR
•

PUB2 (0367)

National Solid Waste Mgmt. Assn.

Charles Johnson

1730 Rhode Island Ave., NW

Washington, DC 20036

PUB2(0374)

Northwest Pulp & Paper Assn.

Ms. Llewellyn Matthews

1300 114 Ave., SE, Suite 110

Bellevue, WA 98004

PUB2(0368) PUB2(0010)

National Solid Waste Mgmt. Assn.

Mary Reese

1730 Rhode Island Ave., NW

Washington, DC 20036

Dwayne Coble

Northwest Solvent & Supply, Inc.

509 Chambers St.

Eugene, OR 97402

PUB2(0369) PUB2(0375)

Naval Facilities Eng. Command

Gale B. White

Seattle Branch Western Div.

PO Box 2366

Silverdale, WA 98383

Northwest Tank Service

Larry Patterson

PO Box 24282

Seattle, WA 98124

PUB2 (0378)

OSPIRG

Jon Stubenvoll, Director

027 SW Arthur

Portland, OR 97201

PUB2 (0377)

PUB2(0376)

97321

97440

ORCO

PO Box 361

Eugene, OR

OREMET

Jeffrey C. Sprenger

Engineering Dept.

PO Box 580

Albany, OR

PUB2 (0371)

PUB2(0015)

PUB2(0370)

Jerry Goodman

Nordstrom Distribution Center

5703 N Marine Dr.

Portland, OR 97203

Norris Paint Co.

Paul H. Payne

1675 Commercial St., NE

Salem, OR 97303

Northwest Chemical Corp.

4560 Ridge Dr., NE

Salem, OR 97303

•

PUB2(0372) PUB2(0379)

Northwest Food Processors Assn.

Jonathan Schlueter

2828 SW Corbett #229

Portland, OR 97223

OSSI

Roger Emmons

4372 Liberty Rd., S

Salem, OR 97302

PUB2(0373) PUB2(0380)

•

Northwest Pipeline Corp.

Environmental Affairs - 10356

PO Box 1526

Salt Lake City, UT 84110

Oak Grove Disposal

Michael Borg

PO Box 22214

Milwaukie, OR 97222
PUB2 (0381) PUB2(0397)

Arnold W. Odell

Division Engineer

PO Box 547

Hillsboro, OR 97123

Department of Agriculture

Tom Harrison

635 Capitol, NE

Salem, OR 97310 (j

PUB2(0063) PUB2 (0398)

PUB2(0382)

PUB2 (0383)

PUB2(0384)

70692

c

PUB2(0386)

PUB2(0400)

PUB2(0406)

Dept. of Fish & Wildlife - EMS

PO Box 3503

Portland, OR 97208

Oregon Corrections Division

Sid Coleman

2575 Center st., NE

Salem, Or 97310

Oregon Dept. of Agriculture

H. Michael Wehr

Laboratory Services Div.

635 Capitol st., NE

Salem, OR 97310

Oregon Coast Towing Co.

Foot of Newmar k

PO Box 3638 Empire Station

Coos Bay, OR 97420

97222

98057

98057

Ornark Industries

Di ane Hickman

4909 International Way

Milwaukie, OR

Olympic pipe Line Co.

W.D~ Kramer

PO BBox 236

Renton, WA

Dave Booth

Olin Corporation

PO Box 2896

Lak e Charles, LA

Olympic Pipe Line Co.

R.C. Meadows

PO Box 236

Renton, WA

PUB2(0385) PUB2(0043)

Ontario Waste Management Corp.

Michael Newnham

Communications Officer

1 Bloor St., W, 11th Floor

Paul Larson, Supervisor

Oregon Dept. of Geology

1400 Queen St.

Albany, OR 97321

PUB2 (0396) PUB2(0402)

Oregon Aeronautics Div.

Ray Costello

3040 25 st., SE

Sal em, OR 97310

Emergency Services Div.

Archie M. Mustard

43 Capitol Bldg.

Salem, OR 97310

PUB2 (0399) PUB2(0387)

Oregon Dept. of Agriculture

Matt Weimar

Agricultural Resources Coord.

635 Capitol st., NE

Sal em, OR 97310

Oregon Environmental Council

John A. Charles

2637 SW Water Ave.

Portland, OR 97201

o
PUB2 (0391)

PUB2 (0407)

PUB2 (0390)

PUB2(0004)

97207

97310

97310

Oregon Health Division

Drinking Water Program

PO Box 231

Portland, OR

Rob Edgar

Oregon Highway Div.

885 Airport Rd., SE

Salem, OR

PUB2 (0321)

PUB2(04ll)

Oregon Highway Division

Bob Aldrich

PO Box 14030

Salem, OR

PUB2 (0412)

PUB2 (0011)

PUB2(0414)

Kathleen Harbaugh

Citizen's Representative

Governor's Office

Sta te Capitol

Salem, OR 97310

PUB2 (0413)

Oregon Health Division

Kristine Gebbie, Administrator

PO Box 231

Portland, OR 97207

Oregon Landowners & Water Fowlers

Joe Lucas, Director

Soil & Water Conservation Dist.

25023 Oak Island Rd.

Portland, OR 97231

97204

97204

Oregon Fair Share

Bart Diener

518 SW Third

Portland, OR

PUB2(0389)

Dept. of Fish and Wildlife

Jerry MacLeod

PO Box 3503

Portland, OR 97208

PUB2 (0408)

Dan Shostak

Oregon Fair Share

519 SW 3rd, Suite 409

Portland, OR

Oregon Farm Bureau Federation

Manager, NER Division

PO Box 2209

Sal an, OR 97302

PUB2(0405)

Oregon Farm Bureau Federation

Don Shellenberg

PO Box 7209

Sal an, Or 97308

Oregon Dept. of Forestry

Resource Planning

2600 State St.

Sal an, OR 97310

•

•

PUB2 (0410)

Oregon Dept. of General Services

Allan J. Goff, Landscape Supt.

Real Property Division

1225 Ferry St., SE

Salem, OR 97310

PUB2 (0416)

PUB2 (0415)

97310

State of Oregon

Mili tary Dept.

Gerald E. Elliott

2150 Fairgrounds Rd., NE

Salem, OR 97303

Jeanette Holman

Legislative Counsel

SlOl State Capitol

Salem, OR

97310

Ms. Pat Amedeo

Assistant to Governor

254 State Capitol

Salan, OR

•
PUB2 (0392) PUB2 (0421)

Oregon Poison Control Center

Mark Bayer, M.D.

3181 Sam Jackson Park Rd.

Portland, OR 97201

Oregon Steel Mills

Thomas C. McCue

PO Box 2760

portland, OR 97208 C)

PUB2(0464) PUB2 (0418)

Br ian C. Reynolds

Public Utility Commissioner

L & I Bldg., Rm 420

Salem, OR 97310

Bill Bartholomew

Dept. of Water Resources

555 13 St., NE

Salem, OR 97310

PUB2 (0417) PUB2(0422)

PUB2 (0427)

PUB2 (0429)

PUB2 (0423)

PUB2(0428)

o

15144

97402

97030

Pacific Chemical Lab., Inc.

1290 Industrial Way

Albany, OR 97321

Orkin Exterminating

90280 Prairie Rd.

Eugene, OR

PPG Industries

C.M. Babka

PO Box 9, Rosanna Dr.

Springdale, PA

Osmose Wood Preserving

J. Brown

5000 SE 31 St.

Gresham, OR

PUB2(0393)

PUB2(0394)

PUB2 (0040)

Oregon Reg. Primate Research Ctr.

A.O. Toyooka

505 NW 185 Ave.

Beaverton, OR 97006

Anthony Barsotti

Oregon State pipe Trades

1831 NE 28 Ave.

Portland, OR 97212

Oregon Railroad Assn.

Eve rett Cutter

620 SW Fifth Ave., Suite 912

Portland, OR 97204

Paul R. Henry

public Utility Commissioner

L & I Building, Rm. 420

Salem, OR 97310

PUB2 (0420)

Oregon State University

Joseph Capizzi

Extension Entomology

Corvallis, OR 97331

Pacific Motor Trucking Co.

W.R. Dahme

1830 SE Schiller st.

Portland, OR 97202

PUB2 (0431)

PUB2(0035)

Dick Salaz

State of Oregon

Portland Motor Pool

1411 SW Third

Portland, OR 97201

Pacific Northwest Bell

Lori Wakeman

421 SW Oak, Rm. 4N13 1501

Portland, OR 97204

o
•

PUB2(0430)

Pacific Northwest Bell

W.T. Schram

1600 Bell Plaza, Rm. 1501

SEXlttle, WA 98191

PUB2(055l)

Joan Peterfeso

Environmental Engineer and

POllution Control/3M

Box 33331·

St. Paul, MN 55133

PUB2(0436)

PUB2(0432)

PUB2 (0433)

PUB2(0003)

22207

97113

PUB2(044l)

PUB2(0440)

PUB2(0442)

PUB2 (0445)

Phoenix S~fety Associates, Ltd.

PO Box 25859

Seattle, WA 98125

Terry Pe tko

2871 N Clark Ct.

Cornelius, OR

Charles Peterson

4500 N 17 st.

Arlington, VA

PUB2(0443)

Planar Systems

Dave Pennington

1400 NW Compton Dr.

Beaverton, OR 97006

97218

97034

Paramount Pest Control

5207 NE Portland Hwy

Portland, OR

Pendleton Grain Growers, Inc.

L.E. Warner

PO Box 1248

Pendleton, OR 97801

Paul Hopkins

Pegasus Waste Mgmt.

PO Box 1871

Lake Oswego, OR

Pacific Power & Light Co.

Robert W. Towery

Stores Developmnent Dir.

920 sw Sixth Ave.

Portland, OR 97204

•

PUB2 (0437)

PUB2(0438)

PUB2(0439)

Pest Control Operators of Oregon

13275 SW Henry St.

Beaverton, OR 97005 97208

PUB2(0446)

PUB2 (0426)

Pollution Liability Insurance Assoc

James R. Marquess

One E. Wacker Drive, Suite 3720

Chicago, IL 60601

Port of Portland

Jack sabin

PO Box 3529

Portland, OR

polk County

Environmental Health Dept.

Gene Clemens

Courthouse, Rm. 203

Dallas, OR 97338

97123

Permapost Products Co.

A.N. Kinsella

PO Box 100

Hillsboro, OR

Pennwalt Corp.

LL. Hefford

PO Box 4102

Portland, OR 97208

•
PUB

2 (0447) PUB2 (0452)

Portland ANG Base

Base Environmental Engineer

Portland, OR 97218

PUB2 (0450)

Portland General Electric Co.

Bob Hall

Public Affairs

121 SW Salmon

Portland, OR 97204

C)

PUB2(0456)

PUB2(0449)

PUB2 (0455)

PUB2 (0453)

c

97111

PUB2 (0457)

PUB2(0448)

PUB2 (0460)

PUB2 (0459)

Portland State University

Bruce L. Conrad, A.S.P.

PO Box 751 - PERS

Portland, OR 97201

Portland Paint& Coating Assn.

S,teve Norton

2140 NE 54 Ave.

Portland, OR 97213

Portlasnd Glove Co.

Donn Williams

PO Box 429

Carlton, OR

Precision Castparts Corp.

Doug Richardson, Manager

Environmental Affairs

4600 SE Harmy Dr.

Portland, OR 97206

738

97204

Portland General Electric

Lynn Saxton

121 SW Salmon

Portland, OR 97204

Portland General Electric

L.W. Quinn SB-B

121 SW salmon

Portland, OR 97204

City of Portland

Harry G. Edmonds, P.E.

1120 SW Fifth Ave., Rm.

Portland, OR

City of Portland

Delyn Kies

Solid Waste Coordinator

1120 SW Fifth, #726

Portland, OR 97204

Portland General Electric

Stan Katkansky

121 SW salmon St., OMP8

Portland, OR 97204

PUB2 (0451)

PUB2 (0461)

priestley Oil& Chemical

Bud smock

2429 N Borthwick

Portland, OR 97227

PUB2(0462)

PUB2(0463)

Portland General Electric Co.

R.G~ Davis

121 SW salmon

Portland, OR 97204

PUB2 (0454)

Portland General Electric Co.

J.W. Lentsch, Manager

Generation Licensing& Analysis

121 SW Salmon st.

Portland, OR 97204

Product Services Co.

86365 College View Rd.

Eugene, OR

Public Affairs Counsel

Steven R. Huff

PO Box 12945

Salem, OR

97405

97309
PUB2(0466)

PUB2 (0465)

PUB2 (0471)

PUB2 (0470)

83619

Ralston Aviation

PO Box 778

Fruitland, 10

PUB2(0472)

Jacqueline Rams

444 N Capitol st., NW, Suite 375

Washington, DC 20001

97034

97034

Publishers Paper Co.

R.A. Schmall

4000 Kruse Way Place

Lake Oswego, OR

Publishers Paper Co.

Robert E. Gilbert

4000 Kruse Way Pl.

Lake Oswego, OR

•

PUB2(0473)

PUB2 (0553)

R.E. Wilkerson, Plant Engr.

White City Plant/3M

8124 Pacific Ave.

White City, OR 97503

Rasmussen Paint

Chris Rasmussen

12655 SW Beaverdam Rd.

Be ave rton, OR 97005

PUB2(0467)

PUB2 (0032)

PUB2(0033)

PUB2 (0052)

97202

97219

97477

PUB2(0024)

PUB2 (0474)

Cindy Savage

Reed College Chemistry Dept.

3203 SE Woodstock Blvd.

Portland, OR 97203

PUB2(0475)

Reed College Recycling

Reed College

Box 4

Portland, OR

Jerry P. Re

610 S Second St.

Springfield, OR

Mary Reese

01649 SW Greenwood Rd.

Portland, OR

14226

Loren McManus

R.J. Reynolds Industries

Reynolds Blvd.

4C WHQ

Winston-Salem, NC 27102

RCRA Research, Inc.

Robert K. Wyeth

4248 Ridge Lea Rd.

Amherst, NY

Roy Kapahi

Radian Corp.

10395 Old Placerville Rd.

Sacramento, CA 95827

•

PUB2(0469)

Swami Anand Videh

Rajneesh Neo-Sannyas Int'l. Commune

Box 1

Rajneeshpuram, OR 97741

PUB2 (0477)

PUB2(0476)

98401

Reforestation Services, Inc.

5669 Commercial st., SE

PO Box 3197

Salem, OR 97302

Reichhold Chemicals

John Falkowski

PO Box 1482

Tacoma, WA

97214

Rainbow Auto Body

1301 SE Stark

Portland, OR

•
PUB2 (0478) PUB2 (0489)

Reliance Universal, Inc.

John M. Hatfield

PO Box 12336

Salem, OR 97309

Risk Control Systems

Judy Cichowicz

9310 SW 26 Ave.

Portland, OR 97219 o PUB~(0479) PUB2(0490)

PUB2 (0483)

Resource Recovery

5501 Airport Way S.

Seattle, WA 98108

River Road/Santa Clara Citizens

Advisory Group

Vora E. Heintz

1038 Jayne Dr.

Eugene, OR 97404

PUB2 (0487)

PUB2(0485)

Reynolds Metals Co. - EXOLL

S.D. Ryan

6601 W Broad st.

Richmond, 23261

Retro Service

11349 Folson Rd.

Ranco Cordova, CA 95670

PUB2(0037)

James Bi eber

Riviera Motors, Inc.

826 SW 21st

Portland, Or 97205

PUB2 (0491)

Roberts Environmental Services, Inc

PO Box 10093

Eugene, OR 97440

Rhone-Poulenc, Inc. PUB2(0492)

Robert Briggs

Box 10224

Portland, OR 97210

PUB2(0486)

Rodda Paint Co.

R. Hageboeck

6932 SW Macadam -Ave •

Portland, OR 97219

o

Rhone-poulenc, Inc.

Robert Briggs

Box 10224

Portland, OR 97210

PUB2 (0002)

PUB2 (0493)

Rodgers Organ Co.

Al Mahaney, Factory Mgr.

1300 NE 25 Ave.

Hillsboro, OR 97123

PUB2 (0488)

Lee E. Archambeau

Riedel Environmental Services

Portland Division

PO Box 5007

Portland, OR 97208

PUB2(0495)

PUB2(0494)

o

97470

Roseburg Lumber Co.

Mike ~bber

Box 1088

Roseburg, OR

Rollins Environmental Servo (TX)

Donald C. Matter, Plant Mgr.

Box 609,

Deer Park, TX 77536

97214

Risberg's Truck Line

2339 SE Grand Ave.

Portland, OR
PUB2 (0496) PUB2(0508)

PUB2 (0509)

97222

Round Butte Seed Growers

Box 117

• Culver, OR 97734

PUB2(0497)

Round-Up Crop Dusters, Inc.

James C. Shoun, President

Pendleton Municipal Airport

Box 1513

pendleton, OR 97801

City of Scappoose

Mayor Elizabeth Huser

City Hall

Scappoose, OR

L. Schuch

10330 SE 32 st.

Milwaukie, OR

97056

PUB2(0502)

PUB2 (0501)

PUB2 (0498)

Rust International Corp.

Jim Majors

Box 25374

Portland, OR 97225

98004

PUB2(0034)

PUB2(0512)

PUB2(0513)

Sheryl Smith

John sexton Contractors

1815 S Wolf Rd.

Hillside, IL 60162

Shell oil Co.

Anna Sampson

MPD Purchasing N--HW Coordinator

Box 6249

Carson, CA 90749

Shell Oil Co.

Darrell Robinson

400 108 Ave., NE

08098 Bellevue, WA

S & FA Reporting Services

Regulatory Dept.

1101 15th St., NW

Washing ton, DC 20005

S-J Transportation Co.

E. Millbrooke Ave.

PO Box 91

•

Woodstown, NJ

PUB2(0500) PUB2(0514)

PUB2(0499)

PUB2(0516)

S.C.S. Engineers

Fe ter McCormick

1008 140th Ave., NE

Be 11 ellue, WA

SCA Services of Oregon

Dean Lewis

232 NE Middlefield

Portland, OR

98005

97211

Sheridan Grain Co.

147 SW Railroad St.

Sheridan, OR

Shipley Co., Inc.

Shawn A. DeLorey

Safety Coordinator

2300 Washington St.

Newton, MA

97378

02162

PUB2(0504) PUB2(0517)

•

SRTI

8821 SE Lambert

Portland, OR 97266

Si erra Club

Pacific Northwest Chapter

Judy Dehen

2637 SW Water St.

Portland, OR 97201
PUB2 (0518) PUB2(0525)

PUB2(05l9)

PUB2 (0014)

PUB2 (0520)

Doug Larson, Env. Engineer

Simposon Timber Co.

PO Box 17307

Portland, OR 97217

98401

97415

PUB2(0068)

PUB2(0526)

PUB2 (0527)

Sol-pro!Lilyblad, Inc.

Ralph L. Jeuris

Box 1556

Tacoma, WA

Southern Oregon Experiment Stat.

Mike Willett

503 Hanley Rd.

Central Point, OR 97502

Southern Pacific Pipe Lines, Inc.

610 S Main st.

Los Angeles, CA 90014

Tom Long

South Coast Lumber

PO Box 670

Brookings, OR

97351

97217

97217

Simplot Soilbuilders

Box 441

Independence, OR

Simpson Timber Co.

Marc Krieger

2301 N Columbia Blvd.

Portland, OR

Simpson Timber Co.

John H. Ruddick

2301 N Columbia Blvd.

Portland, OR

PUB2(0059)

PUB2 (0528)

PUB2(052l)

Sinclair & Valentine

Alan Kalish

Environmental Safety Dept.

245 E Mari eAve.

West St. Paul, MN 55118

Specialty Enameling

8205 N Mississippi

Portland, OR 97211 o

PUB2 (0523)

PUB2 (0045)

PUB2(0524)

Soci ety of American Wood

Preservers, Inc.

E. DAvid Lewis

7297 Lee Highway, Unit P

Falls Church, 22042

97501

97116

spraymasters Co.

2253 N Pacific Hwy

Medford, OR

PUB2 (0529)

PUB2(0530)

Spencer Environmental Services, Inc

15770 Beaver Glen Dr.

Oregon City, OR 97045

Spiering Spray Service

James Spiering

Route 2, Box 264

Forest Grove, OR

98040

Smith Trucking Co.

William F. SMith

4204 88th Ave., SE

Mercer Island, WA

Bob Balton

Soils Testing Lab

130 W 9th st.

Medford, OR 97501

PUB2(0532)

States Industries, Inc.

R. Gail Overgard

Box 7037

Eugene, OR 97401 o
PUB2(0533)

PUB2(0534)

John Stee1er

633 17th st., Suite 2300

Denver, CO 80202

Stauffer Chemical Co.

Char les E. Henry

Suite 650, Lloyd Bldg.

700 NE Multnomah

Portland, OR 97232

PUB2(0069)

97402

Sweetland Products

W.L. Rossini

1010 Arrowsmith St.

Eugene, OR

Swift Adhesives

Bill Smith

18408 NE San Rafael St.

Portland, OR 97230

PUB2 (0541)

PUB2(0540)

PUB2(0542)

Szepatowski Associates, Inc.

23 Narragonsett Ave.

Jamestown, RI 02835

97217

Stauffer Chemical Co•

J.D. Acree

4429 N Suttle Road •

Portland, OR

PUB2(0535)

PUB2(0537)

•

Stimson Lumber Co.

Bob Sturdivant

Box 68

Forest Grove, OR

Sumas Transport, Inc.

Airport Way

1757 W Bakerview Rd.

Be Hingham, WA

97116

98225

PUB2(0543)

J.C. Taylor Lumber Sales, Inc.

Barney 01berg

Box 567

Beaverton, OR 97075

PUB2 (0544) .

Teamsters & Chauffeurs Local #281

1020 NE Third Ave.

Portland, OR 97232

PUB2 (0072)

PUB2 (0538)

Sun-Diamond Growers

Box 626

Cornelius, OR 97113

PUB2 (0008)

Steve Cooke

Technical Dynamics Aluminum

9124 SE 64th

Portland, OR 97206

PUB2(0545)

PUB2 (0539)

•

Bob Mitche11

Sunohio Co.

1700 Gateway Blvd. SE

Canton, OH

Randy Sweet

Box 328

Kelso, WA

44707

98626

Tektronix Environmental Services

Division, Bldg. Y-6 060

James C. Brown

Box 500

Beaverton, OR 97077

PUB2(0546)

Tektronix Technology Group

William E. COWling 111

Box 500, DS 32-245

Beaverton, OR 97077
PUB2 (0547) PUB2 (0556)

PUB2(0548)

Tektronix, Inc.

Frank L. Deaver

Corp. Environmental Management

Box 500, DS 32-245

Beaverton, OR 97077

PUB2 (0549)

Travenol Laboratories, Inc.

N. Modn 5-3W

1 Baxter Parkway

Deerfield, IL 60015

97338

PUB2(0558)

PUB2 (0559)

Time oil Co.

John Denham, Hazard Control Mgr.

2737 W Commodore Way

Seattle, WA 98199

Towmotor Corp.

Dick Formhals

451 SE Maple

Dallas, OR

97015

97321

Temco, Inc.

Box 382

Clackamas, OR

Teledyne Wah Chang

Thomas E. Nelson

Box 460

Albany, OR

PUB2(0550) PUB2(0560)

PUB2 (0031)

PUB2 (0020)

Jenny Hawkins

The Dalles Disposal Co.

PO Box 498

The Dalles, OR 97058

Jean BOylan

3M Environmental Library

EE & PC 2l-2W-06

PO Box 33331

st. Paul, MN 55133 97202

PUB2(0563)

PUB2(056l)

Treasur e Valle y Community College

Kay Carlson

Library - Weese Bldg.

650 College Blvd.

Ontario, OR 97914

Tube-Lok Products

Larry Halsey

Box 02175

Portland, OR

Tri-State Motor Transit Co.

Eugene Whitaker

Box 113

Joplin, MO 64802

97330

Tetra Tech, Inc.

W.P. Muellenhoff

200 SW 35 St.

Corvallis, OR

PUB2 (0554) PUB2 (0584)

Tillamook County

Board of Commissioners

201 Laurel Ave.

Tillaroook, OR 97141

U of 0 Law School

Jay Manning

Land, Air, Water

Eugene, OR 97403

PUB2 (0555) PUB2 (0573)

Tillamook PUD

C.L. Farrell, Asst. Supt.

Box 433

Tillamook, OR 97141

Bureau of Indian Affairs

Portland Area Office

Box 3785

Portland, OR 97208
PUB2 (0569) PUB2 (0579)

•

u.s. Coast Guard

Ronald Bendixen

915 Second Ave.

Seattle, WA 98174

u.s. Forest Service

Conservation VISTA

Box 3623

Portland, OR 97208

PUB2(0572) PUB2(0570)

u.s. Dept. of the Army

Army Environmental Hygiene Agency

T. Michael White

Aberdeen proving Ground, MD

u.s. Forest Service

Mapleton Ranger District

10692 Hwy 126

Mapleton, OR 97453

PUB2 (0571) PUB2(0580)

u.s. Dept. of the Army

Army Environmental Hygiene Agency

Matthew W. Andrews, Jr.

Aberdeen Proving Ground, MD

u.s. Gypsum Co.

Tom LaHaye

Box Z

pilot Rock, OR 97868

PUB2(0574) PUB2(0581)

PUB2 (0577)

PUB2(0578)

PUB2(0576)

u.s. EPA

Tobias Hegdahl, MiS 530

Chief, RCRA Program Development

1200 sixth Ave.

Seattle, WA 98101

97045

PUB2 (0582)

PUB2(0564)

William R. Spurgeon, I.E.

U.S. Postal Service

Box 14000

Salem, OR 97309

PUB2(0565)

u.s. Insurance Group

Robert J. Sullivan, V.P.

Government Affairs Dept.

Box 2387

Morristown, NJ 07960

PUB2 (0531)

u.S. Water News

Ron Oberg

15594 S Maple Lane

Oregon City, OR

Umatilla Agency

Box 520

Pendleton, OR 97801

98101

97204

u.S. EPA

Environmental Events Calendar

Region 5 - Office of Public Affrs

230 S Dearborn st.

Chicago, IL 60604

u.S. EPA - 000

Al Goodman

522 SW Fifth Ave.

Portland, OR

u.s, EPA

Dave Hanline, MiS 530

1200 Sixth Ave.

Seattle, WA

•

PUB2(0575)

•

u.s. EPA - Region X

Ken D. Feigner

1200 Sixth Ave•

Seattle, WA 98101

Umatilla Electric Cooperative Assn

Wayne L. Stephens

Safety Director

Box 1148

Hermiston, OR 97838
PUB2(0566) PUB2(0589)

Union County SW Service District

1100 L Ave.

La Grande, OR 97850

PUB2 (0567)

Union Oil Co. of California

M.J. Dougherty

Box 7600

Los Angeles, CA 90051

Wacker Siltronics Corp.

Gregg Carr

Box 03180

Portland, OR 97203

PUB2(0591)

George D. Ward & Associates

4440 SW Corbett

portland, OR 97201

PUB2(0568) PUB2(0593)

Union Pacific Railroad Co.

General Solicitor

Box 4265

Portland, OR 97208

PUB2(0583)

University of Oregon

Edward W. Bailey

Environmental Health Dept.

1230 Franklin Blvd.

Eugene, OR 97403

Wasco-Sherman Public Health Dept.

400 E Fifth St.

The Dalles, OR 97058

PUB2(0597)

Washington Dept. of Ecology

Ann C. Werner

Mail Stop PV-11

Olympia, WA 98504

PUB2(0594)

PUB2 (0587)

PUB2(0585)

PUB2 (0352)

Norma Upson

23596 NW st. Helens Rd.

Portland, OR 97231

97217

97302

PUB2(0599)

Waste By-Products

Michael Rouse

8501 N Borthwick

Portland, OR

PUB2 (0596)

PUB2(0598)

Water Lab

Beth Myers

2609 12th St., SE

Salen, OR

washington Dept. of Ecology

Tom Cook

Mail stop pv11

Olympia, WA 98504

97339

valley Landfills, Inc.

Bill Webber

Box 807

Corvallis, OR

The Valspar Corp.

E.J. Moyer

20 Johnson Drive, Bldg. 1

PO Box 625

Raritan, NJ 08869

PUB2 (0588)

Van Waters & Rogers

Jack Johnston

Box 10287

Portland, OR 97210

Storrs Waterman

Box 20481

Portland, OR 97220
PUB2(0065)

PUB2(0600)

West Coast Petroleum Salvors, Inc.

Pony village Mall, Suite 22

North Bend, OR 97459

PUB2(0610)

97309

97424

Westwood Products, Inc.

Box 12245

Salem, OR

PUB2(0608)

Weyerhaeuser Co.

Dan M. Morgan

Box 667

Cottage Grove, OR

98052

West & Hansen Engineers

Warren Hansen

6605 146 Ave., NE

Redmond, WA •

PUB2 (0601) PUB2 (0609)

PUB2 (0602)

PUB2(0603)

West Hills & Island Neighbors

Fe ter Stapl es

Attorney at Law

12847 NW Alderview Dr.

Portland, OR 97231

PUB2 (0611)

98477

97477

PUB2(0612)

weyerhaeuser Co.

R. Jerry Bollen

Box 275

Springfield, OR

White TOp Transport, Inc.

Box 675

McMinnville, OR 97128

PUB2 (0613)

Weyerhaeuser Co.

Ray Westenhouse

CCB4C

Tacoma, WA

97302

94086

Westech Engineering

Steve Downs

3421 25th, SE

Salem, OR

Westak

Frank Decoito

1274 Forgewood Ave.

Sunnyvale, CA

•

PUB2 (0604)

Western Electric Co., Inc.

E.J. Koehler - 081030

1090 E Duane Ave.

Sunnyvale, CA 94086

Widing Transportation, Inc.

Fr ed Be am, Chemi cal Cl eanou t Mg r •

Box 03159

Portland, OR 97203

PUB2 (0614)

sutie 195

94598

PUB2(0605)

Western Farm Service

W.C. Jensen

3075 Citrus Circle,

Walnut Creek, CA

Wilbur-Ellis Co.

Agricultural Services Corp. Office

191 W Shaw Ave., Suite 107

Fresno, CA 93704

PUB2(0615)

•

PUB2(0607)

Western Oil & Gas Assn.

D.J. Fogelquist

2033 Sixth Ave., Suite 255

Seattle, WA 98121

Wilco Farmers

Larry Ferguson

Box 318

Mt. Ange1, OR 97362
PUB2 (0616) PUB2(0039)

Wildlife Federation

Guy Randall

3524 NE 11th

Portland, OR 97212

Glen C. Strachan

Woodward-Clyde Consultants

One Union Square, St. 2520

Seattle, WA 98101

PUB2 (0620) PUB2(0624)

Willamette Industries

Chuck Russell

Box 907

Albany, OR 97321

R.A. Wright Engineering, Inc.

Chuck Kemper

1340 SW Bertha Blvd.

Portland, OR 97219

PUB2 (0012)

Rich Barrett

Willamette Industries

Building Materials Div.

PO Box 907

Albany, OR 97321

PUB2 (0618)

Willamette Industries, Inc.

Merel Jones

Box 339

Albany, OR 97321

PUB2 (0619)

Willamette Industries, Inc.

E.J. Kirkpatrick

PO Box 339

Albany, OR 97321

PUB2 (0621)

Willamette Industries, Inc.

Bill Thompson

Box 907

Albany, OR 97321

PUB2 (0622)

PUB2(0625)

Yakima Indian Nation

Russell Jim, TRibal Councilman

Box 151

Toppenish, WA 98948

Roger S. Wood

2335 E Nob Hill, SE

Salem, OR 97321

PUB2(0623)

Woodburn Fertilizer & Grain, Inc.

868 N Front st.

Box 7

Woodburn, OR 97071

(J
•

•

•

APPDmrx D
•

••

•

APPENDIX D

DEPARTMENT OF ENVIRONME:rrAL QUALITY

~AND USE COMPATIBILITY STAT~~NT P£QUI~~ITS

AIR CONTAMINANT DISCHARGE PER~!TS (ACDP)

INDIRECT SOURCE PERMITS (AIR)

STEP 1 SEWAGE FACILITIES PL:lNS REQtJ~rNG GRANTS AND LOANS REQUIRmG CEQ APP~

SEWERAGE AND WAS~~ATER INDUSTRIAL CONSTRUCTION PLANS

SOLID WASTE PE.~ITS ~~ LE~-RS OF AUTHORIZATION

HAZARDOUS WASTE COLLECTION, TREATMENT AND DISPOSAL LICENSES

WATER POLLOTION CONTROL FACILITY PERMITS (WPCF)

NATIONAL POLLUTANT DISCHARGE ELL~INATION SYSTEM PER~ITS (NPDES)

NOTICES OF INTENT TO CONSTRUCT FOR AIR CONTAMINANT SOfnCES AND

CONFINED ANL'1AL E'1='...EDING OR HOLDING OPERATIONS (NC)

A Statement of Compatibility with applicable local comprehensive land use plans

and Statewide Planning Goals is required for new or expanded facilities/sites.

The local statement must certify that proposals are compatible with LCDCAcknowledged local comprehensive land use plans and implementing ordinan~es,

or Statewide Planning Goals. The Department prefers' that its Land Use

Compatibility Statement form be used, however, it will accept an equivalent

statement in lieu of the form.

In urbanizing areas between city limits and urban growth boundaries, applicants

must provide evidence of both city and county concurrence as to the land use

compatibility of ~~e proposal. This evidence must be:

1. Sign-off by both jurisdictions on CEQ'S Land Ose Compatibility Statement

form, or

2. A copy of the city/county management agreement included in the Orban Area

Plan acknowledged by LCDC, or

3. A written statement covering the applicant's proposal.

If CEQ receives a negative local Statement of Compatibility, an application

for a permit or approval will generally not be considered complete. DEQ would

then expect the applicant to work with the local jurisdiction to obtain the

needed plan or zone change, conditional use permit, variance, or other

modification to produce compatibility with the Acknowledged Plan and ordinances

or the Statewide Planning Goals.

Applicants must submit a completed Statement of Compatibility or an approved

equivalent along with their application or request•

MJ93.AC-3

10(S';
$TAoT&: OF 0RlEG:N

CltPAR"T'MENT OF e:NV 1ROt a.cEN"T'AL. QUAL 1

, Z %. 5'lf F' 1 I'"n-t A.VENUE

P.O. BOX 1150

fIIORT't...»(C • OR 9 1 %0 7

,..dR eita USK SRL'?

L..l..'ID USE CG\G'ATIBILITY STA'TEolEIT

I "'..,.... 1 ~NT

I NAM& "QCRl:;SS

all Tlote NAT\,IRe: ...... c "";~T eN QfI' "Me: p",gP<lSit:J NEW OR s;xp"NQe;O P'ACILoITY SITe:·

(INc:s.uec A_"O~"I'AT"C L.:c:A1. QCS~IPTION ~O :ONIHO OCSIGNATION I

o OUTS I eE URlSAN c;ROWTM BOUNClARY

S!.~ID!ENT OF Ca.lPATI;3IL!TI FRG"1 APPROPRIATE LA'ID USE AlJTriORITI

(An Gqu.ivc:z'ent; at:.::t;.ement rr.ay be pr~-i.d.2d in z..t:au of this fo~)

C~ CHECK ONE OR MORE 0 .. TME "OL.l.O"ING~

CHEc:J( ONE 0.. THE ..0L.1.011 I NG:

O THK P"OPOSAL. I S HOT CONS I STENT "I TH

STATE" I OK PL.ANN I NG GOAL.S

STATEWIDe P~NING GOAL.S ANO STATE HO" TME

is ACXHOwn..S:CGED I

110£ PROPOSE%:) ACT 1V I TY:

, .. THE COMPRCHENSIVE PL.AN

r .. TH&C e:e_RB:HENSIVB: PLAN is not; ACXHOWLZGEO.

O THIt PROPOSAL. I S CeNS I STENT "I TH THE

STATE"leE PL.ANNING GOAL.S

ATTAC1'4 AeeITIONAL. ..INOINGS ,,"ICH REFeRENCE

PROPOSKC ACTIVITY IS COMPATIBLE "ITH TMEM

IS PROHIBITED BV THE PL.AN

IS NOT ACORESSCD O~ CCNTROLL.KD BV TME PLAN

D I S Al..1.0WEO BV TME PLAN BUT IS SUB,JECT TO

"UTURK GOAL. CONSIOERATIONS BV AN AGENCY

o

a IS AL.1.0"EO OUTRIGHT BV TMC P~

o r S AL.L.O'IIfEDBV THe: PL.AN BUT SUB,JECT TO

STANClAROS IN SITING. OCSIGH. CONSTRUCTION ANO/OR OPERATION

D I S Al..1.0"£0 BV TH£ Pl..AH BUT SUB,JCCT TO a

P"UT\IRE GOAl.. CONS I OERAT IONS ISY THe: L.OCAL. ,JURISOICTION

O CURING THE PERIOOIC RltVl!!!:" THE PL.AN "AS HOT FOUNO TO

BCIN COMPL.IANCE WITH THE STATCWIDE PL.ANNING GOAL.S

ATTACH ~nOITl0NAL. FINDINGS WMICH RE"ERENCC THE SPECI .. 'C PLAN POL.ICIES,CRITERIA OR STANDAROS

WHICH ARE REL.IED ON AND STATE WHV THE COMPATIBIL.ITY FINDING IS JUSTI .. EO BASED ON PLAN

POL.ICIES. CRITERIA OR STANDARDS AND WHKTHER AL.1. NECESSARV L.CCAL. APPROVA1.S HAVE BEEN OBTAINED

I" ~E AcrlVITY IS NOT ADDRESSKD BV THe Pl..ANL ATTACH ADDITIONAL. FINDINGS "HICH REFERENCE . STATEWIDE PL.ANNING GOAL.S ANO' STATE HOW THE PRO~SED ACTIVITY IS CDMPATIBL.E "ITM THEM.

TIT1.E OATE

~Cl USE AUTHORITY

SIGHED

USE THE FOl.L.OWING SIGNATURE BOX FOR CITY/CClJNTY C~CURRENa IF INSIDE URBAN GROWTH BOUNDARY

AND OUTSIDE CITY L.IMITS

1 _

~N6 05_ ~a+AORi+y

TITLe: OATE

e e:a / I C I 1 0 / 8 4
/

DEPARTMENT OF ENVIRONMENTAL QUALITY

SIGNATURE AUTHORIZATIONS

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

FR?D HANSEN

MICHAEL J. DOWNS

21. 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

SHERRY CHEW

MICHAEL HUSTON

22. Salary advances

• 23.

FRED HANSEN

MICHAEL J. DOWNS

JUDITH L. HATTON

LYDIA R. TAYLOR

Access to U.S. Bank safe deposit box

FRED HANSEN

MICHAEL J. DOWNS

JUDITH L. HATTON

LYDIA R. "TAYLOR

1

;

i·

24. Department contact for Worker's Compensation matters

SUSAN M. PAYSENO

MK266

May 30, 1985 - 4 -
.:

/ •

DEPARTMENT OF ENVIRONMENTAL QUALITY

SIGNATURE AUTHORIZATIONS

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

FRED M. BOLTON

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

l-1ICHAEL J. DOWNS

FRED M. BOLTON

16.

17.

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. DO~VNS

Authorized representative to accept filing of documents in contested

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

LINDA K. ZUCKER

c

18. Appointing authority

MK266

May 30, 1985

j

I

1

I

1

j

,

I

II

I

19.

FRED HANSEN

MICHAEL J. DOWNS

SUSAN M. PAYSENO

Deposit or withdraw funds from U.s. Bank Safekeeping Account

1000-297-0 and Checking Account i010-0300-425. Any two of the

following:

FRED HANSEN

JUDITH L. HATTON

LYDIA R. TAYLOR

- 3 - ..
•

• APPENDIX E
APPENDIX E

DEPARTMENT OF ENVIRONMENTAL QUALITY

FIELD SAMPLING REFERENCE GUIDE

March 1985

Table of Contents

General Information • . . . • . • • . • . • • • •• Pages 1 - 2

Supply/Container Requests; Shipment; Preservation;

Request Form; Split Samples; Equipment; Groundwater

Samples; Information Contacts; Program Codes

•

Inorganic Parameters •

Organic Parameters •

Bacterial Parameters .

Holding Times

Containers/Parameters

Analyses available from each container type

Organic Analysis Classification . • . •

Specific chemicals available by general test

name

Request For Analysis Form

Example

Groundwater Well Form

Sampling Supply Request Form .

Legal Sample Chain of Custody Procedure

Chemical Safety Information

Pages 3 - 5

Pages 5 - 6

Page 7

Pages 3 - 7

Page 8

Pages 9 -11

Page 12

Page 13

Page 14

Pages 15-20

Pages 21-25
• GENERAL INFORMATION

Sampling Supplies/Container Requests

Send completed "Supply Request" form to Sample Tracker (send in with

samples). If supplies are to be picked up at the Lab or if immediate

shippment is required, call directly to the Sample Tracker.

Shipment

Send all samples to Lab as soon as possible after collection.

ment of Legal samples, refer to "Legal Sample Chain of Custody

Notify the Sample Tracker upon shipment of samples in order to

work/analysis scheduling, advance preparation and/or technical

For shipProcedure".

allow for

assistance.

•

.'

Coliform samples must be received by 1200 hours on thursday. If required,

Fecal Strep. must be specified on the request form and received by 1200

hours on wednesday.

BODS samples must be received by 1200 hours on friday. When the following

monday is a holiday, BOD's can only be set up on thursday and friday.

Preservation

Metals - Aqueous samples, use 250 ml "TM" poly. Nitric acid has been

added in Lab; do not rinse.

Nutrients - Add 12 drops sulfuric acid to 500 ml "R" poly.

Cyanide - Aqueous samples, add 4-5 pellets of potassium hydroxide to

1,Q, "P" poly.

Oil and Grease - Add 'V 15 drops sulfuric acid to glass mason "X" jar.

Phenolics - Add large squirt of methyl orange to glass mason "X" jar,

then add 10% phosphoric acid by drop until sample turns definite red.

Add 'V 1 gram of copper sulfate.

Miscellaneous

Request Form - Include the following information: site name and nearest

town, date and time collected, program to be charged (see page 2), purpose

of collection, sampling point description for each sample, container numbers

used (in spaces provided), specific parameters to be analyzed. If coliform

or BOD samples are collected includeC1 2. Note if samples are split and

date and time they are to be run.

Split Samples - Arrangements should be made so that samples can be set up

and run as close to the same time as possible. Results from outside Labs

should be sent to the Sample Tracker as soon as available .

1
GENERAL INFORMATION

Miscellaneous (continued)

Equipment - Call the Sample Tracker for any additional equipment required.

Some of the equipment available: field filtering apparatus, pH and conductivity meters, pH paper, bailers and ropes, etc.

Groundwater Samples - Initial groundwater well samples must have a "Groundwater Quality Sample Collection Form" filled out. For subsequent samples

note that the well data is on file.

Information Contacts - 229-5983

Sample Tracker - Laurie McCulloch; information regarding: types of containers

for specfic parameters, general inorganic and organic sampling inquiries,

supplies, equipment, progress of analyses, preliminary results.

Organic Laboratory Supervisor - Rick Gates; specific information regarding

organic parameters.

Inorganic Laboratory Supervisor - Ron McCartney: specific information regarding

inorganic parameters.

Program Codes

Indicate on reqest form which program should be charged: o

Air Quality

Ambient - routine

Source

Special

Water Quality

Streams - routine

Lakes

Special

Spill - unknown source

Interagency

Industrial Waste

Municipal Waste

Groundwater - UIC

Hazardous Waste

Superfund

RCRA

Non-RCRA
FIELD SAIIPLIIiG A• D PRESERVATIOII

• TEST SAIPLE CQlTWiR EPi RErnIU!FllJ)ED

PARA!ETER ABBREY. YOLllIIE TYPE PRESERViTIO. W. HOLDIIG mE

I II 0 R GA. I C S

IOI-ErAWCS

Acidity Acidity 100 11 Basic (P) Cool to 4 degrees 14 days

Alkalinity ill 100 al Basic (P) Cool to 4 degrees 14 days

81oc:hft1cal 0rrgeD IleuDd BOD 1000 11 1 liter SIP Cool to 4 degrees 48 hours (EPA)

24 hours (DEa)

BaroD B 5011 Baaic (P) Cool to 4 degrees 48 hours

BroUde Br- 20011 Basic (P) loDe required 28 days

or 91au

CheUcal 0xyql!Il DIuDd am 5011 Iutri8llt (I) Coolto4degreee 28 days

add H2Sl4 pH <2

Chloride Cl- 100 11 Baaic (P) JIoDe required 28 days

Chlorophy1l/PhaeophytiD Chloro 200 to Basic (P) Cool to 4 degrees 24 hours (filtered iJl Lab)

1000 11 Vial Filtered onto 0.45u 7 days (filtered in field)

asbrane filter,

put in Yial c:onta1n-

• in! ft9C031Acetone.

Freeu ,ial v/dry ice.

Diuol'ed 0Iygea 00 30011 llQI) bottle Cool to 4 degrees 8 boura

Alkaline XI: lInS04;

H2SO4

Fluaride F- 5011 Baaic (P) loDe requited 28 days

lIydrogeDion pH 100 11 Baaic (P) Cool to 4 degrees Iued1ate

Iodide 1- 20011 Baaic (P) Coolto4degrees 24 hours

IitrogeD:

AuoDia 5011 lutrient (I) Coolto4degrees 28 days

H2SO4 to pH <2

I]eldahl TO 50 11 lutrient (I) Cool to 4 deqreea 28 days

H2SO4 to pH <2

titrate IlO3-l Botb IlO3+II02-1 and 1102-1 lust be run

titrate t lIitrite K03+I02-I 5011 IIutril!Dt (I) Cool to 4 degrees 28 days - 14 days 1£ nonH2SO4 to pH <2 chlorinated drinkill9 water

litrite 1i02-1 5011 Baaic (P) Cool to 4 degrees 48 hours

• Pearl Benson Index pal 30011 Basic (P) Cool to 4 degrees 7 days

3
FIE L D SAIPLIIG A • D PRESERYATIOI

PWIETEi ABBREY.

TEST SUPL£

YOLOIE

COITAm:R

TYPE PRESERVATIOI W.

EPA REalI!IJ:III\ED

HOLDIE TIlE C~

IIOI-!ETAWCS (c:ant.)

Pboaphate:

Ortho D-P04 100 .1 Basic (P) Coolto4de4Jreea 48 hours

Filter on site

Total T-GlO4 100 11 lutrieDt <R) Cool to 4 degrees 28 days

II2S)4 at pH <2

Silica SJ.02 5011 Basic (P) Cool to 4 degrees 28 days

Sulfate S04 100 11 Baaic (P) Cool to 4 degrees 28 days

Sulfide S- 2SOto BOD bottle Coolto4degreea 7 clays

1000 11 (glaaa> IiD1a1m aeratiOll,

ZD acetate, KOB to

pH >9

PHYSICAL

Color c:olor SOil Baaic (P) Cool to 4 degrees 48 hours

Condnd: alICe CODd 5011 Basic (P) Cool to 4 degrees 28 days

IIardDeu <calculated calc. 20011 Baaic (P) Coolto4dec)rees

frca disa Ca " Icj) hard. filtered

Solids: 0

Settleable Sett. S. 1000 11 Baaic (P) Coolto4degreee 48 hours

Suapeuded 55 20011 Baaic <P) Cool to 4 degrees 7 days

(loD-Filterable Rea1due)

Total TS 100 11 Basic (P) Coolto4degreee 7 days

(Total Residue)

Total D1aaolved TDS 20011 Baaic (P) Cool to 4 degrees 7 days

(Filterable Residue) filtered in Lab

Total Volatile TVS 20011 Baaic (P) Coolto4degreea 7 days

Volatile Diaaolved VDS 20011 Baaic (P) Cool to 4 degrees 7 days

Volatile SuapeJIded YSS 20011 Baaic <P) Cool to 4 degrees 7 days

Turbidity bIrb 5011 Baaic (P) Cool to 4 degrees 48 hours

LIQUID

I1croscopic Exaa lliero ID 100 .1 Plastic or Cool to 4 decJfeft 24 hours <liquid)

SOLID glaaa container

Sgrau £rca Lab only

()
FIELD 5AIIPLIIG AID PRE5ERVATIOI

•

BETALS

la,I,Ca,lIg (diu)

Cbroaiua VI

all others

Solids (dry)

(total nt.ala & EP Taz. est..)

EP Taz. Ext. (liquids)

TEST 5AJIPLE aJlTAIm EPA REa:JDEIDED

ABBHEV. V'OLU!E TYPE PRESEllYAnOi W. BOLDIIG mE

20011 Baaic (P) Cool to 4 degrees

200al !&tala (TIl) Cool to 4 degrees 24 hours

10 PRESEllYATIVE

20011 htala (TI) 11m3 to pH <2 13 days - 7 days OSHD -

drinkiDg vater

200al lIetala (TI) 11m3 to pH <2 6 aontha

200 g. Bag (Z) Cool to 4 degreea ASAP - 3 day. rec:oaeDded

400 11 Sedileat (5) Cool to 4 dl!9ftH ASAP - 3 daya recauended

(200 g.)

200al !etala (m Cool to 4 degrees ASAP - 3 daya rec:oueDded

m PRESEllYATIVE

•

Solids, sludges aDd sed1uDta should be about 250 al volUM if hcmogeDeoua. Larger

UOWlU IlOUld be required to coapoaite repreeeetative areu or if auple ia IlQDt.olOgelleOUa. Tbree (3) day holdiD9 tiM ia recouended aa integrity of rnulta decreases

vith tiM.

ORGAIIC5

LIQUI])

Chlor1Ddated Peaticide Cl Peat 1000 al Glaaa II880D (I) Coolto4degreea 7 daya unW extract.

OIL Al £011 seal 30 days after extract

10 al Vial (8)

SOLID

20 gnu Bag (2)

LlQUI])

Cyanide CI- SOOal Bu1c (P) Coolto4deqreee 14 daya

SOLID KDB to pH >12

20 grua Bag (Z)

LIQlJI])

Herbicides 1000 al Glaaa II880D (I) Cool to 4 degrees 7 day. until extract

OIL u £011 seal 30 days after ertract

10 11 Vial (8)

SOLID

20 gnu Bag (2)

LIQUID

Hydroc:arboD m HCID 1000 al Glaaa Kason (I) Cool to 4 deqrees 7 daya

OIL Ai foil seal

• 10 al Vial (8)

SOLID

20 graa Bacj (2)

L.i~n-Taml1D Ltg-Tan SOal Baaic: (P) Cool to 4 dE!eJreeS

5
FIE L D SAIPLI G AII D PIESEIVATIOII

TEST SAIPLE COITAIIER EPA R£mDF'IIDEI) C/

PARAIIETER ABBIlIN. VOLOIE TYPE PRESERYATIOI W. HOLDIKli TIE

0"1 G AII I C S (COIlt. )

!BAS 250al Baaic (P) Cool to 4 degrees 48llours

LIQUID

Oil & Grease 1000 al Glasa IaaaD (!) Coolto4degreea 28 daya

SOLID Alfo1laeal H2S)4 to pH <2

20 grau Bag (2) Cool to 4 degrees

LIQUID

PCB' a PCB 1000 al Glasa IaaaD (I) Cool to 4 degreea 7 daya until estract

OIL u fo11 aeal 30 daya after erlrac:t

10 al Vial (B)

SOLID

20 grau Bag (2)

LIQUID

Peatac:hlorophelloJ./ 1000 11 Glaaa!aaoD (!) Coolto4degreea 7 daya until estrac:t

TetracIl101'CltlbeaoI SOLID u fo11 seal 30 daya after extract

20 grau Bag (2)

LIQUID

PheIolica Pheaol1ca SOOal Glau IaaclD (!) Coolto4degreea 28 daya

SOLID u fo11 seal H3P04 to pH <4,

20 gnu Bag (2) Bethyl Orange,

1 g. CUS04 C

LIQUID

Polynuclear Arautic PAR 1000 al Glasa IaaoD (!) Cool to 4 degrees 7 daya until ertract

IIydroc:arilou SOLID Alfo11 seal 30 daya after erlrac:t

20 grau 8acJ (2)

UQUID

Priority Pollutant. 1000 11 Glaaa IIaaclIl (!) Cool to 4 degrees 7 daya until extract

Qrq8ll1c Eltractablea SOLID Alfo1laea1 30 daya liter estrac:t

20 grau Bag (2)

LIQUID

Purgeable Aroaat1ca Purge Aro 40al Serua vial with Cool to 4 degrees 14 daya

Teflon-liDed seal•

SOLID .. 110 AIR BUBBLES

20 grau Bag (2)

LIQUID

Purqeable Org8ll1ca Purge Qrq 40 11 Serua vial with Coolto4degreea 14 daya

Teflon-lined seal.

SOlID A 110 AIR BlIBBl.ES

20 gnu Bag (2)

Thiocyaoide SCI SOil Baa1c (P) Cool to 4 degrees

Total Organic Carbon TOe 10 11 llutrieat (i) Cool to 4 degrees 28 daya

H2SO4 to pH <2 0

Total Qrqaoic Halogen _TOJ - Coolto4deqreea 14 daya

Not available until Sept'85 - Contact Lab concerning aupl1ng. . - .-

6
FIE LD SA! P LI GA. D PRE S ERVAT I 0 •

•

oRGAI I CS (cout.)

TEST SAIPLE

ABBR£V. vaLUE

COITAIm

TYPE

EPARECOIIIEIIDID

W. HOLDIHli mE

o THE R 0 RGAHIe S BY S PEe I F ICC HE! I CAL • A! ES :

COITACT W (~983) FOR IIOR£ IIFOWnQl.

BACTERIAL

Total Colifon TC 100 al Chlorinated Eff.: Cool to 4 degrees • ~erlli2ed LEAVE AIR SPACE

wide IOUth bottle.

laD-ehlorinated:

pre-aterlli2ed

narrow aouth bottle.

Fecal Colifan 100 al Chlorinated UI.: Cool to 4 degreea

pre-aterllized LEAVE AIR SPACE

wide urt.b bottle.

loD-chlorinated:

pre-aterllized

narrow urt.b bottle.

Fecal SI:rep. FSI:rep 100 al Chlorinated UI.: Cool to 4 deqreea •

• pre-aterilized LEAVE AIR SPACE

wide aouth bottle.

lIaIH:hloril1ated:

pre-sterllized

aarrov IOUtb bottle.

• SAIIPL£S SBOUlJ) BE WL'lZED AS SOOI AS POSSIBLE AFt'B

OJIJ.ECTIOI AID AS CLOSE TO THE 6 HOUR LIm' AS POSSIBLE.

IIAII!UI HOLDIIG mE IS 30 IKIURS. II THE CASE OF LEGAL

SAJIPLES, THE 6 !lOUR LI!lT !lUST BE ADHERED TO.

•

7
CON T A I N E R S

BASIC POLY - 1 liter "P"

Acidity

Alkalinity

Boron

Bro.ide

Chloride

Chlorophyll

Color

Conductance

Cyanide

Fluoride

Hardness

Iodide

Lignin-Tannin

MBAS

Metals

Calcium

Magnesium

Potassium

SodiuJl

Nitrite

Ortho-phosphate

PBI

pH

Silica

Solids

Settleable

Suspended

Total

Total diasolved

Total volatile

Volatile suspended

Sul£ate

Thiocyanide

Turbidity

NUTRIENT POLY - SOOml "R"

Ammonia

COO

Nitrate + Nitrite

TKN

Total Phosphorus

TOC

STP POLY - 1 liter "0"

BOD

pH

Suspended solids

8

/ PAR A MET E R S

METALS POLY - 2S0ml "TM"

Hg <separate poly)

Cr6+ <no preservative)

EP Toxicity extraction £or

liquids. no preservative

all other aqueous metals

SEDIMENTS POLY - SOOml US"

Inorganic parameters -

semi-aolids & sediments

SOIL BAG "z"

virtually all solida

i£ inorganic and organic

paraaetera required. take

two samples.

GLASS MASON "X" JAR

Cl Pest

HCIO

Herb

O&G

PAH

PCB

Penta

Phenolica

PPOE

PURGE VIAL - 40ml lOB"

Purge Aro

Purge Org

oil samples £or organic

parameters

BACTERIOLOGICAL

Chlorinated samples:

wide mouth. black cap.

presterilized, thio added,

STP 1#

Non-chlorinated samples:

narrow mouth, black cap,

pre-sterilized, no thio,

2.3, or 4 digit 1#

BOD BOTTLE - 300ml glass

BOD <DO titrated in £ield)

DO

Sul£ide

c

o

o
,.-'"

.:J: ( .••.1 ::::!:: OJ -.C)

Z n: z·-· zu.

~: g~~ 8~~ ~t]~ hJ .::J: Z I..l~ =:J r.,) =J ;;-::: I··,· llJO: =l ~I '~]: _~~

UJ LJ _J ':1::' r.Jl LJ.I lJ.J hJ :;:!~ I:':~

t.:t: LL' "-~ ':'J: LJ_Z I..,J ....... ,...M

Lt.. Cll C:.1 (0 td C:J c::t~ I~':I

.' :+: It: -. Ct: lIJ..J:) (.J) 0: Lt' t· ... 0': ..- lit: ,+: ..; hJ tff" r:=:a (':1.. t'J ~~ 1':'1.- ::~ ":t:· :+: Jt: " 0 ...... r·,. ('~~ (X) oo:t" 'S~ C"~ 0 CJ c..~ Z ::.~ UJ (.:) I

"I t.!.J '1" '_of co-.. t·-) .," "tl' ....J .•(] ...0 2: ~:: .,--:::,u <I: ,,""11 (...) ~.' I~ ..'

~:Z~' ~l~'''C~'~'C'''~''C'''''C~'' O~ ... ~- ~._J~- ~'~~(~' 0+1 "'l '~' __ _ ~.. Ct.. _<I C·· .. "tt, 0.. (:r.: I;.f] >- 0.: (1) L~t:: ".1" IJ.I ..n -.•:) :4: I-- :+: to- .::T., C) :Ct7 :tt: :It: I ..·· en ::..... t··- C~J .:') ('I ( ..... I·... ,;--.• ...' V) ..' 't: u: 0:: 0.: cr: Q: Cl: 0: 'r:J: -.. cr: (f) (:J La,J ::J _..J UJ ;;,::. t.r. . .., .,.,. •..• •.• ~~... + C~~~~O~OC~C:J :~~ ~_J_J_.J LIX: (f'~.: ~)

"1 _J "1 _ ..1 __J _~J _~J _.J _~J _-1 __J_ LII cr.: CX') _1 "'·1 _. _1 '':;'.' (~l ,:,t: ':'.: n: (l:

~I* L)~J~JULJ~_JU~] C~~ c~u. ~~~oC~ wa: UJQ:O: Q.~ l=lCl~~l~:J

....1 _~J "I t.J'J r.:) Cl CJ CJ0 c::t c:J C:l r::J _. _J (0 LU ...-.. r::l :> .,~s: r.::) :J:::h, ~_J _.J ....1 •...1 otl <I: otl .:c: ec. CL:: et: a:: (t: ec: Ct: -J '::t: :r: en <J: 0. => ..J _J __I _. 1-. _.1 t<'4 LL' _J r..~) :::..~ CJ 1.'..) I_.J C) * (..l "I t:Q .r-I: "::1: '~1:: <r; <J: 0'1:1: ~T.: .~): :r: (._J Cl :;;~: cc, Ct. _~J LU LLJ 1.1., ll' <I: C) ..... :;EO: Cl (,•.: C::l (;:.1 r.::l C.I 1::1

~§~ ~:~ ~:~:~~~ ~~~~~ ~~~ ~;~~~ ~~~~~ ~::t~~~~~ "1 .::r: :41 ...- en <.J: VJ lJ..J tn .... l.I ..1 * CJ '+: ':1: ":11 :':'1 (rJ 1."1: .•. , ;::1 .. "I tlJ :::n t=1 ::!: _I ~J: I..LJ t.::~

..' c".l ..= _. I.IJ ::;J I:(~ .~.J ..... ;:;':':' "'4

• ~: ~u "-CJ U1 ~JZ

,+: l.I.. :+= .:r;- ':1: o., LI.J Lli U,J .:u ::r: "'~l'" Z~ _IE ~~~ eel:.) ..' LLI ... LLJ r.n :::.... CJ LI,J =:J LLI 01';1: t.t I "I n. It: x: -, >0:: r..J _ ..1 ~.J I...· Ll ~.~

~~Q)": «D:0 >·u~

.. '" ~W ~ZI~. ~C~ .., r." ..: 0,1 I Lt.. .... Cli ;:,.,: t,~· ,•••.-1 C:' I..LJ =+: :> ot: 1 C:::l t.l :>- ,"__ 4 I.I.J =:1 :;... ,:t:: *= +: en 1 "'~1 <1: :-~"t: _.1 1::: ;>. ((1 :r: 1

...' 0: >t: c..'IZ Ct:« '~.r..

>+ LU,., ,:.,.I <t: <J: Cr.:Z (~:: ;r.: ell a:t: 1'_1":' otl t-. + I >. :t: c:~ _1 C::' Z C:I I,t.. -.+: UJ"I c::, I t._~ t.,l I.". Z 1..1.. ::t:: '~r: I..'.~ :::~:

..: X:"'I ::~I 'Cl ::z: t.J =+1 <1:"1 .-.::r.: I l.I.J .. -_ or.r. •._ ....4 (.rl .. -. * Ct: ott I ....- Z t··- r.n t-· tn :x.: ltl r.n ..: '::1: * Ln I <'0 _. ::or.: LU Ltl ::!tt , .•- III til

:+1 0..+ LJ.II LU lit: loll .. ~. CJ ,.... <r; ,.... LlJ

ott "'t C'I Lli ::J u: =>-Z ... ;;;!:: (::J *1 * 1-·4 I ':1: c, G:I LLJ _..J t.., -.:1: r.~l (.1') r::, r.. , '~1;: .0 ... 1 r...... r ... :ott "'''1 t:.,l I 1:::'1 "~4 LU t-· C:J .·_4 ,.... ....~ It_ .. -'. :~,,:' .~I 1:'-' ,.') ",:,. l't. "'1 ,.-, I '::1: _J ;:;r.: (t.: LlJ ~') r,I.• Z LI_ Z -J I.t. : ......: ,-OJ:, ,;"., ("'. 1:--.1 t-. I LJ UJ r.::) :T.: LU <J~ ell (I) "'·4 ....... I-~. 0::): ::) h·1 ,., .-'. ..',

(r)I :::t,: L.l :;.= t:""~l l.1.J .. ~. _J r'.J::l: >~ ...... 'CaI l-lJ r,::1 Ul l.LJ C'tZ I'••l .... r,rJ r..l .1 LI I I r.t't :1.: o::r. C:1 &:::1 c:, ::r: w ::- UJ r... (n C::t .... - % ot:r: I 2: L"C c,: :;~:: Lli La Lt I '~_l 1..1.1 I '.11 o-: .:;': (:r.: L·r,~

':l..IZI LT.)0 CJ r7't C,Z (.....] Z. >.:: :::t: ::, J-- ax)f C) (X) ....4I 1.1.. -:1: UJ .. ~.. :Z:I CL "'-1 t.:l. .-:;1: n: (.I')I a:,.1 I..:':) 1'::1 C:IIJ

c:;a: ~~ ~~ ...~: f~i ....,I ~~: ~~ ~P: ~~ Ci~ -r.: ~r' r-r lJ·~.. ~~:::i~ Z; g~ ~~ ~~ c:~zI (.r' -. r.~, ~~: ~~~ ~i: ".::1 ~;'~ i:~ ~:~ r_",~ ;:~~ l.1.1 , C:, 1':"4 • _4 _I ll~ (,'\. 0.. '::1 o. ';~: ....... ;.....:. ....... ....: t)'l r ..,1- "'T' ..,t- _.1 Cl c.., 1 Ct,: C:'J _ to z I ;;':': Z ::::1 t -. (t:'~:" ..1 1:-:-, CJ (:) 1~:1

~r.: ~~~;;:F.~: f.~j I~~' 0.:" Cl:' E5 ~~ '~j ~~ ~:~ ~:~ ~:I 1"'.1[ .... ("f' c.; ~; ~.;; ~: l6 ~=; ~~ ..~, 0) r.:-I (.tl: .~~~1 !~~~ ~r ~f ~~~ ;;;!:: I l..lJ I , ~J: I , , .:.::::. , I ..... I r::.~ I CJ , L) I ~: I :.-.= I Ct: , I I CJ I , ":J: , r.'"I

C'JI ;~I ,:xli ,:t:f ZI lr"I _~J I '0: I (.t: I Cli I r.tl I '~: I _J I 1:',-, ::t: I >. I LlJ I :>~ I 1'--1 1 ..:r.~ I t ':.. 1 r...J I '~_'1 I :t: I :.."t: I .•. 1 t !';:~ I CJ I "I

•

•

•
PENTACHLOROPHENOL TETR~CHLGRGPHENGLS o ~ON-SPECIF~C TEST FOR PHENOLIC LIKE COMPOUNDS (COLORIMETRIC

PROCEDURE IN WHICH SENSITIVITY IS INVERSELY RELATED TG THE

NuMBER OF SUBSTITUTIONS ON THE AROMATIC RING)

POLYNUCLEAR AROMATIC HYDRGCARBO~S

ACENAPHTHENE

ACENAPHTHYLENE

qNTHRACENE

BENZQ(AlANTHRACENE

3ENZO (;H PYRENE

CHRYSENE

PRIORITY POLLUTANT ORGANIC EzTRACTABLES

HCEtlAPHTHENE

ACENAPHTHYLENE

ALDF:!N

ALPHA-BHC

ANTHRACENE

BENZIDUiE

BENZO(AiANTHRACENE

BENZD u~) PYRENE

BENZO(BjF~UORANTHENE

BETA-SHC

BIS (2-CHLOROETHOXYl METHANE

B!S(2-~HLQROEiHYL)ETHER

BIS(:-CHLOROISOPROPVLJETHEP.

BISr2-ETHYLHEXYL) PHTHALATE

4-3ROMOPHENYL FHENYL ETHER

BUTYL BENZYL PHTHALATE

4-CHLORO-3-METHYLPHENOL

2-CHLGRONAPHTHALENE

2-CHLOROPHENGL

4-CHLOROPHENYL PHENYL ETHER

CHRYSENE

DEL i.A-SHe

0IBUTYL PHTHALATE

:~2-DICHLQROBENZENE

;,3-DICHLOROBENIENE

;,4-uICHLORGBENZENE

3~3'-DICHLGROBENZIDENE

2,4-JICHLDROPHENOL

D:ELDR!N

JIETHYl PYTHALATE

FLUGF:AtHHENE

FLUORENE

NAPTHALENE

PHENANTHRENE

?YRENE

2,4-DINITROTOLUENE

2.6-D!NITROTOLUENE

DI-N-OCTYL PHTHALATE

ENDGSULFAN

ENDOEULFAN II

ENDOSULFAN SULFATE

END/UN

ENDRIN ~lDEHYDE

FLUGRANTHENE

FLUORENE

GAMMA-SHC

HEPTACHLOR

HEPTACHLOR E?OXIDE

HEXACHLOROBENZENE

HEXACHLOROBUTADIENE

HEXACHLGROCYCLGPENTADIENE

HEXACHLOROETHANE

ISOPHORONE

2-METHYL-4,6-DINITROPHENOL

2-METHYLPHENOL

4-METHYLPHENCL

NAPHTHALENE

NITROBENZENE

2-N!TRIJPHENOL

4-NITROPHENOL

N-NITROSOD!METHYLAM!NE

N-NITROSODI-N-PROPYLAMI~E

N-NITRGSOOIPHENYLAMINE

PENTACHLOROPHENOL

PHENANTHRENE

PHE~~DL

PYRENE

2~3!4~5-TE~RACHLQRGPHENOL

1~2~~-TR!CHLQRGBEHZ~~E

T:=:A~4S -:4QNACSL OR

c

()

\0
•

•

•

?URGEABLE AROMATICS

3ENZENE

TOLUENE

ETHYL-BENZENE

PURGEA8LE GRSANICS

3ENZENE

BRGMODICHLGROMETHANE

BROMOFORM

BROMOMETHANE

CARBON TETRACHLORIDE

CHLOR08ENZENE

CHLGROETHANE

2-CHLGRGETHYL VrNYL ETHER

CHLOROFORM

CHLOROMETHANE

CIS-l,3-0ICHLOROPROPENE

DIBROMOCHLOROMETHANE

!~:-DI3ROMOETHANE fEDB}

:,2-uICHLOROBENZENE

i,3-DICHLOROSENZENE

I,4-DICHLOR08ENZENE

M-;{YLENE

Q-XYLENE

P-XYLENE

1.1-DICHLORQETHANE

1.2-DICHLOROETHANE

1,1-DICHlOROETHYLENE

!.2-DICHLOROPROPANE

ETHYL BENWIE

METHYLENE CHLORIDE

1,1,2,2-TETRACHLOROETHANE

1~1,2,2-TETRACHLGRO=THYLENE

fGLUENE

TRANS-l,3-DICHlOROPROPENE

TRANS-DICHLOROETHYLENE

!,l,l-TRICHLORGETHANE

!,1.2-TRICHLOROETHANE

TRICHLOROETHYLENE

TRICHLOROFLUOROMETHANE

VINYL CHLORIDE

\ \
-----.~~- .~-----T---- ----

\)o~1-\a.nd DEPAHW1ENT OF ENVIRONMENTAL QUALITY

Request for Analysis Laboratory No. r--

Location/Site: .Se\;;,o \ndvs'\-!\a....\

Collected By: _~. "'Dee. (t-Ju.)RO)

Date: \ - \ -ens

Prograr:\: wQ -"IW

Date Received Lab:

Date Reported:

Purpose: C:cmp\a\o± \DUf5t'8Q-\-,c n Report Data To:

lab prepared

o . (X) (R) in field 1 Ol added in lab--d i i

Conunents:

.. - - -.

.. r"·

Item No. Sampling Point DeacrLpt.Ion *Sample Container (bottle) 1'5 Test Required Nutr~ents 00 Metals to-c."\.

(include time) . Ba3~C DOD Organic

Up~-\~oc....C'r\ (eso') Doc Cr. Plo\CO ~"" \30 "\20\ P~, No3 '" .uo~· t ~0'2.- N, Pb J -f~orn i pc: 00-\-\e.-\ ca , CJ Pes-t ,C' F<.. I (d\OS) R\35 ><\151

'P'pe. ou-\-\e.t +0 'Doe. c.. Plo4 tr1"\ \8>0 \& ~o.M~

2 (0'\'25) R\S~ )(232

"Down ~-\-<ea.~ (SO J) P'2\b If'"'2d1 L\"3'\ , f <ot'Y\ p; p e C\.l'\ \e."\- ~c..f'n~

3 (O~"?>5 ) R'2.?>o X" \

4

5

6

, B.isic

-

}'l

Laboratory comments ___.,.------------------------------

() o .:
..

Ground Water Quality Sample Collection Form

WRD

Identification _

•

Manda tory Info

Date Time Collected By Owner's Name

Mail ing Address

Source Description t'lell Spring Other

Dug Drill~ Driven Enclosed Open

0 Cl CJ CJ 0

Collection Point

Inside Tap Outside Tap Well Head Tap Dip Sample Spring Orifice Other

0 0 [J CJ 0

Source Location

Street Address

County Nearest City

Js Js Sec T N-S R_E-W

Suspected Contaminant No. of Samples.

.,......-

Static Level ___ )*

Top of Casing

o

Measuring Point

Land Surface

Cl

Other

Well Construction Characteristics

1. Construction Date

2. Driller (

3. Casing: Steel C P.I/.C. C Brick C Other (

Oiameter ( ) , Footage (

4. Annular Seal: Yes 0 No C ( )

Grout a Bentonite a Other (

5. Sanitary Surface Seal Yes C No C ( )

6. Primary Aquifer Alluvial a Basalt C Granite a Met. or Marine Sed C

7. In Use: Yes C , No a ( )/ Domestic c , Irrigation a

Municipal C , Other

( )

. COll1llents:

( )

-----------------------------------_..--

• * (O)-Owner, (l) State Well Log, (M) Measured or Observed, (E) Estimated

... _.-......._.__ ._---.. _.._-- .... - ._-- ------- -- -_. __._---- --
• SAMPLING SUPPLY REQUEST

Name Region Dated Needed -\,r:__

Number

Number

CONTAINERS

Item

1 liter poly (P) - basic

L liter STP poly (STP)

500 ml poly (R) - nutrient

250 ml poly (TM) - metals

300 ml glass BOO bottle

1 qt. glass mason jar - organic

Biological S~~ bottle

Biological black cap

40 ml serum vial

Plastic zip-lock bags (soils)

MISCELLANEOUS

Item

Ice chest (lg., med., sm)

Analysis request form

Groundwater form

Field filtering apparatus

Chemical scoops

Number

PRESERVATIVES

Item

Sulfuric Acid

Phosphoric Acid

Methyl Orange

Copper Sulfate

Potassium Hydroxide

Alkaline iodide azide

Manganous Sulfate

Zinc 1\Cetate

o

O~~er (comments):

Date received: Date sent: via: -------- -------- Initials:

Greyhound

Trailways

Will call o
•

No vemc-e r , 1933

pase 1 0: 6

Legal Sample Ch3in of Cus~ody P~ocedu~e

To provide support for litig~tion, the Labo::atory must demonstrate c~e

reli~ility of its evidence, analytical test results, by showing the

chai~ of possession and cust~dy of the sa~ples which we~e colle~te~ fa::

an.a Ly s Ls •

evid~n=e saoples ar~ col1ec~ed, transeerred, stored, analyzad, or de3~=cyed.

. The primary ocjeccive of these proc~dures is to create an ac~urate ~ritten

re~o~d thac can be used to trace the possession of a sample from the

mcme~t ai its collection through analysis until its intrcduc~ion as

a. In actual physical posseszion .

• b.

A sample is in cU3tody if it is:

In view, after be Lnq Ln physical possession.

In physical poss.e3sion and then locked up so that no one C,,:1

Ir: a secured ar~.3. ~,Il/he~e access is r e s t r Lc t.e d to ,3.utho~:'zec per scnr-e L,

2.0 Pre-s,,:npling

and ~~ain of cus~ody procedures to be followed. This is especially

The potential litigant should

Since the analytisal
Chai~ ~f Cust~dy

P.=',li5i.·~n #0

Nov.:~e.::, 1983

page :2 of 6

3.0 Sasp:e Collection

3.1 A ~inL~~~ n~~e~ of persons should be involved in sa~ple collection

and handling. They should be trained in the pr~pe~ collec~ion ~nd

handling of the tlope of sarnp Le and ana Ly s I's Lnvo Lved .

3) Procedur-es for collection, preservation, and handling t...h i ch are

specific for each sample cy?e and analysLs illu~t ~a :ollowec.

Field Sa~?ling Guide and Sta~dard Saspling ?.::oced~res.)

3.3 FieLd rec~rds should be completed at the time the s~~?le is collected

and must be signed or initialed. Fill out the Request for Analysis

form giving at least the following information:

a. specific sampling location

b. date and time collected

c. purpose

d.

e.

g.

h.

s~~ple container n~~er

prese.::vatives added

analyses required

pertinent field data (e.g., pH, temperature)

n~~e of collector(s)

o

~here this is par~ of an on-going project, a separ~te field log

beok may also be required. The necessity for this, and the specific

in:·or::lation to be recorded, '..ill be deter::'.ined peior to sampling

by the project coordi~atQr.

3.4 The samp Le collector is r e spon s i.b Le for the care~:\d custody 0:

the sa~ples (includi~g doc~~ent~tion) ~,til the s~~ple5 are prQpe.::ly

\10
C~ai~ of CU5tody

P..-::./:'.3 ion ~O

~;;:)'lember , 1983

page 3 of 5

recc~mended to facilitate identification and later re~ollection

by t~e sample collectoc(s). Sig~ and indicate date, time, and

location on the back of each photo. Handle photogr~p~s accordL~g

~Q chain of custcdy pr~cedu~es as well.

4.0 Transfer of Custody

In tr~nsferring the possession of samples, the date and tL~e 0: tr:3.~s:er

must be recorded and each sampler, or custodia~, must sig~ the record.

The s ampLs collector is re spons Ib Ie for proper:'y pack-::.gi::g and trar,;;:;crting

samples to the Laboratorj for analysis. This responsibility includes

prOViding all of t~e necessary sample doc~~entaticn. The Recue5t fc~

.~.a2.·;sis form allows transfer of custody of a group of samples 'Nith

this documentation.

•

4.1 Samples shi?ped to the Laboratory, either by mail or private carrier,

l:'Iust be in a shipping container sealed with a CEQ ?!dlock Securit~

Seal. The numbe z of this seal must be r eco r ded on the Re::;:uest f·:r

Analysis form which accompanies the samples. Once locked, a wi=~

cutter is required to remove the seal, thus assuring .'...ne int=,;!."' ity

of the samples. A copy of the Request for Analysis fo~ should

be =stained by the sample colle~tor. Ccpies of receip~5 frcm P05t

off ices, or bills of ladi.nq , '..ill be ret::.i:-.ed at the L",_ .o r a co ry

?s part of t::'e per:na.nent chaLa of c-.J.sto.:'y dccumen t a t Lon .

4.2 If samples are relinquished to a desig~?ted sample cus~odia~ :cr

tr~nsport to t~e Laboratory, the tr~nsfer ~ust be prope=ly doc~~e:'.ted,

i.e., signatures of both parties, and date ?:1d tL~e of trans:er

recorded on the 2=~uest f0C Analysis fam .

•• c~llactor, a Chain 0: Cu~t~dy form

\1

; - -~ filled out a~~ one copy is
Chdi~ of Custody

Revision #0

:'ioverr~er, 1983

page 4 of 6

given to the sa~ple collector to ack~o~:ed;e receipt of the samples

by the Labor.=.tory.

5.0 ~abor~tory Custody

5.1 The Sample Tracker is the primary custodian of samples in the

Laboratory. T~e QA Chemist, Inorganic and Orgar.ic Laboratory

Supervisors, and Lab,::>r:3.Cory :1anager are also design:3.t:ed to act

as sample custodia~s. Samples should be handled by the m.in Irnum

possible number of persons.

5.2 The Laboratory maintains several locked refrigerators ~hich are

used exclusively for storing legal samples. Eac~ refrigerator has

a log book in which to record sample transfers, and a secure

place to keep Chain of Custody forms.

5.3 Incoming samples are received by the Sample Tracker, or designated

alternate, ~ho indicates receipt by filling out a C~ain of Custody

form. Included on the form are:

a. date and time received

b. number of sample containers receive~

c. date samples were collected

d. name of collector

e. nar,e of person delivering samples

f. description and identification n~~ber of sam~le containers

g. signatures of the person delivering and person receivi~g

the samples

Comments concerning the integrity or condition of t~e samples ~ay

de Live r i.nq the sarap i e s , t.he ~1:ite copy gees to t;"e :"aj:,c~3.t-:;ry

Office ~~~ager f~r filing; t~e Y~llow copy is retained ~ith t~e

c
•

•

•

Chai~ of Custody

Rev:'sion =0

No vemae r , 1983

page 5 of 6

samples.

5.3.1 If the samples have been shipped to the Labvr~tory, the

Pa~lock Security Seal n~~e~ must be recorded on the ChaL~

of Custody for:n. Transportation receipts are atta=hed to the

wnite copy for filing, and the Pink copy is sent to the sample

collector to ~cknowledge receipt.

5.4 5a~ples are then distributed for analysis or secur~d i~ a locked

refrigerator, as appropriate. The Yellow copy of the Chai~ of Custody

for:n must be kept with the samples.

5.5 ALL laboratory doc~~entation and logs are filled ou: as usual, but

the sa-nples are identified as "Legal" to aler-t the analysts of the

need to follow custody procedures.

5.6 The laboratory area shall be maintained as a secured area and access

shall be restricted to authorized personnel.

5.7 Transfers to or from locked storage are recorded in the ref~iger.3.tor

log book. Laboratory personnel are responsible for the care and

custody of the sample once it is in their possession. They shou:d

be prepared to testify that the sample ~as L~ their view, or secured

i~ the Laboratory, at all times while in their cust~dy.

5.3 Approved me~hods of laboratory analysis are used ar.d dcc~"!\ented.

All analytical results are recorded in a notebook and are retained

.3.S a permanent record in the Laboratory.

5.9 Once the sanpie analyses are completed, ~~e ~~used ?orticn of ~~e

saQple is returned to a locked refrigerator until pe~i~sion tc

C8St~OY the sa~ple is ~eceived by the custodi~~.

5.1J Sam?l~s ~r~ dest=cyed ~nly upa~ t~e orde~ of the Labor~tory Man~ge~1

~~ c~nsultation wit~ enfoc~e~ent of:icia15, O~ N~e~ ic is ce~ta~~ t~at
Ch~in of C~st0CY

Re\tision ~:J

Nove,r.ber, 1'~8 3

paqe 6 of 6

they ~re no longer required. The date and tL~e of cestruc~ion is

recorced on the Yell~w copy of the Chain of Custody fo~, which is then

inicialec, anc filed ~ith the Wnite c~py. The Yellow CQPY of the

Chain of Custody form is then filed with the ~~ite copy.

6.0 References

6.1. :iPDES Compli=.:-,ce Sampling M~nual, U.S. =:?A 0-241.-037/44, E:-,forcerr.e::~.

Division, Office of ~-la.ter Enforcement, 1977.

6.2 ~a:-.<ilioo:< for Al'1a1ytical Quality Control in Water a~j ;';=.st.;;:'.."al:e=

. Laboratories, U.S. EPA 600/4-79-019, EMSL - Cincinnati, Office at

Research and Development, March, 1979.

GEL:sd

~o

o

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•

•

•

SULFURIC ACID SFA

Common Synonyms

Oil of vitriol Oily liquid Colorless Odorless

Battery acid

Fertilizeracid

Sinks and mixes violently with water. Irritating mist is produced.

AVOID CONTACT WITH LIQUID. Keep people away.

Wear goggles. self-contained breathing apparatus. and rubber overclothiug.

Stop discharge if possible.

Isolate and remove discharged material.

Notify local health and pofiu·j'Jn control agencies.

Not flammable.

Mav cause fire on contact with combustibles.

FIa~nl11able gas may be produced on contact \\ i th metals.

POISONOUS GAS 'tAY BE PRODUCED IN FIRE.

Fire We:1r goggles.. se-lf-contained breathing upparurus. and rubber overdo thing.

DO NOT USE W.-\TER ON :\DJ.-\CENT FI RES.

Extinguish with dry chemical or carbon dioxide.

CALL FOR \IEDICAL AID.

\lIST

Irritating to eyes. nose and throat.

If inhaled. will cause coughing. difficult breathing. or loss of

consciousness.

:\Iove to fresh air.

IF IN EYES. hold eyelids open and flush with plenty of water.

If breathing has stopped, give artificial respiration.

If breathing is difficult. give oxygen.

Exposure LIQUID

Will burn skin and eyes.

Harmful if swallowed.

Remove contaminated clothing and shoes.

Flush affected areas with plenlY of water.

IF IN EYES. hold eyelids open and flush with plenty of water.

IF SWALLOWED and victim is CONSCIOL'S. have victim drink water

or milk.

DO NOT INDUCE VO\tlTlNG.

~Vater

HARMFUL TO AQUATIC LIFE IN VERY LO\\ CONCENTRATIONS.

:\lav be dauuerous if it enters water intakes. i

No'tifv local lll::llth ;Jl1J wildlife uiTil·j:ds.

Pollution NOlif;' "perawrs .11' ncarbv water inurkc-,

j
~:'. --- '~: ji W$'& Z1

NITRIC ACID NAC

Common Synonyms

Watery liquid Colorless to light brown Choking odor

Sii-ks and mixes with water. Harmful vapor is produced.

o

AVOIO CONTACT WITH LIQUID AND VAPOR. Keep people away.

We:lr chemical protective suit with self-contained breathing apparatus.

Stop discharge if possible.

Isolate and remove discharged material.

Notify local health and potlctlcn control agencies.

Fire

Not flammable.

\Iav cause tire on contact with combustibles.

Flammable uas mav be formed on contact with metals,

Poisonous gasc.; arc produced when heated.

Wear chemical protective suit with self-contained breathing apparatus,

Cool exposed containers with water.

c

CALL FOR \IEDIC,\L AID.

VAPOR

Will burn eves. nose and throa l.

If inhaled, ~vill cause difficult breurhiuu or loss of consciousness.

\love to fresh air. -

If breathing has stopped, give artificial respiration.

If breathing is difficult. give oxygen.

Exposure

LIQUID

Will burn skin and eves.

Harmful if swallowed,

Remove contaminated clothing and shoes.

Fiush affected areas with plenty of water.

IF IN EYES. hold eyelids open and flush with plenty of water.

IF SWALLOWED and victim is CONSCIOUS. have victim drink water

or milk.

UO NOT INDUCE VOMITING.

1

'I 0

•

'1

'm j - 1 ••-£-'-- -natr- .

\;Vater I

, HARMFUL TO AQUATIC LIFE IN VERY LOW CONCEyrR,HIONS.

\lay be dangerous if it enters ::iatl·r!l1tak.:s. .~ .'.;"tlt v IOG,1 !Jc:i11h ::lId ,\ IId!t!.: ;.1lIU:!!.';. I PoHut ion I '-;'Jlil:" 1;1'l.'l"al<lI";,t ,ll.'llruy w.ucr i;l[;::"~'::.

; '. 'P
\ VOIO CONT.\lT \\lTH LIQUllJ. Keep people away .

Wear chemical protective suit.

Stop discharge if possible.

lsolate and remove discharged material.

Notify local health and pollutiou control agencies.

PHOSPHORIC ACID PAC

Common Synonyms

Orthophosphoric acid Thick liquid Colorless Odorless

Sink-, and mixes with water

.

Not flammable.

Flammable uas is formed on contact with metals.

Wear chemical protective suit with self-contained breathing apparatus.

Fire

CALL FOR \IEOIC\L .un.

LIQUID

Will burn skin and eves.

If swallowed, will cause nausea. vomiting. or los.-; of consciousness.

Remove contaminated clothinu and shoes.

Flush affected areas with plenty of water.

IF 1:'Ii EYES. hold eyelids open and flush with plenty of water.

IF SWALLOWED and victim is CONSCIOUS. have victim drink water

ur milk.

DO NOT INDUCE VOMITING.

Exposure

:

n

Dangerous 10 aquatic lifc ill high cuncentruuouv.

Water I

viuv 1Jt: danueruus if il enters water illlak,,·s. ~,;(it\ 100'::il health :1l11J \\ ildlifc qltll·iaL....

Pollution ;\l'lir; .,tll'I';)10"" III nenrhv ,,':111:1' ilil:J."·,,.

•

-·..a" e -2 zI$· + -..'"",'.. ", - .. n
POTASSIUM HYDROXIDE PTH

Common Synonyms

Caustic potash Solid crystals, or watery liquid White solid or Odorless

Lye colorless liquid

Solid sinks and mixes slowly with water. Liquid mixes

with water.

Not flammable.

Flammable gas may be produced on contact with metals.

May cause fare on contact with moisture and combustibles.

Wear rubber overclothing (including gloves).

Fire Flood discharge area with water.

Cool exposed containers with water.

CALL FOR MEDICAL AID.

DUST OR MIST

Irritating to eyes, nose, and throat.

Harmful if inhaled.

Move to fresh air.

If breathing has stopped, give artificial respiration.

If breathing is difficult, give oxygen.

IF IN EYES, hold eyelids open and tlush with plenty of water.

SOLID OR LIQUID

Exposure Will bum skin and eyes.

Harmful if swallowed.

Remove contaminated clothing or shoes.

Flush affected areas with plenty of water.

IF IN EYES. hold eyelids open and flush with plenty of water.

IF SWALLOWED and victim is CONSCIOUS, have victim drink water

or milk.

DO NOT INDUCE VOMITING.

Water

HARMFUL TO AQUATIC LIFE IN VERY LOW CONCENTRATIONS.

May be dangerous if it enters water intakes.

Notify local health and wildlife officials.

Pollution Notify operators of nearby water intakes.--- - - _.-

.. ,--

Avoid contact with liquid. solid, vapor, and dust.

Keep people away.

Wear rubber overclothing (including gloves).

Stop discharge if possible.

Isolate and remove discharged material

Notify local health and pollution control agencies.

CG 446-1

o
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•

COPPER SULFATE (Sf

Common Synonyms

BlueVitriol Solid-granules or crystals White to blue Odorless

Sulfate of copper

Coppersulfate pentahydrate

Cupric: sulfate

Sinks and mixes with water.

Isolate and remove discharued material.

~otify local health :1I1d poiiutiun control agencies.

Not flammable.

Fire

CALL FOR \tEDICAL .\!D.

SOLID

If swallowed. will cause nausea, vomiting or loss of consciousness.

IF SW\LLOWED and victim is CONSCIOUS. have victim drink water or

milk and have victim induce vomiting.

IF S\\' \LLOWED and victim is UNCONSCIOUS OR H.\VING

CO:\VULSIONS. do nothing except keep victim warm.

Exposure

HARMFCL TO AQUATIC LIFE IN VERY LOW CONCENTRATIONS.

\A/ater ,\-lay be dangerous if it enters water intakes.

Notifv local health and wildlife officials.

Pollution Notir;· »perarors of nearby water intakes.

CG 446-1
e.

COMPLIANCE MONITORING STRATEGY

FOR THE

HAZARDOUS WASTE PROGRAM

Oregon Department of Environmental Quality

APPENDIX F
•

.'

APPENDIX F
•

•

•

COMPLIANCE MONITORING STRATEGY

FOR THE

HAZARDOUS WASTE PROGRAM

Oregon Department of Environmental Quality
COMPLIANCE MONITORING STRATEGY

TABLE OF CONTENTS

Section

C~

I. Introduction 3

II. Compliance Monitoring Priorities 4

III. Identifying the Regulated Community 5

IV. Methods for Detecting Violations 6

V. Criteria for Program Quality 8

VI. Inspection Priorities and Practices 10

VII. Evaluating Effectiveness of the Strategy 15 c.

C)

ZC2110 -2-
PART I

•

INTRODUCTION: PURPOSE, SCOPE M~D USE OF THE STRATEGY

Purpose and Scope

The goal of Oregon's hazardous waste compliance monitoring and enforcement

program is to attain and maintain a high rate of compliance within the

regulated community. In order to accomplish this, knowledge of the

compliance status of the regulated community 1s required.

The Compliance Monitoring Strategy describes the Department's approach and

program for assessing the compliance status of Oregon's regulated

• community. This document provides overall direction for the compliance

monitoring program. It establishes a framework for planning and conducting

compliance monitoring activities and evaluating their success in

accomplishing the program's objectives.

Included in this strategy are priorities, quality criteria, and practices

for compliance monitoring. It is expected that periodic refinements of

this strategy may be made as a result of implementation experience or

changes in the scope of the State's hazardous waste program. Also, the

strategy will be reviewed annually, during preparation of the State/EPA

Agreement, and revised if necessary•

•

ZC2170 -3-
Use of the Strategy

The strategy will influence several aspects of the State's hazardous waste

program. Use of the strategy will provide better coordination, greater

consistency, and enhanced quality of a variety of Department hazardous

waste management activities.

The strategy will be used to:

- Define annual commitments contained in the Hazardous Waste Program

Plan of the State/EPA Agreement;

- Evaluate the quality of compliance monitoring activities;

- Measure success in attaining a high rate of compliance; and

- Identify resource and training needs, and assist in resource

allocation.

PART II

COMPLIANCE MONITORING PRIORITIES

The following priority objectives will guide the Department's compliance

monitoring program.

- Abatement of imminent hazards and severe health threats.

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ZC2170 -4-
•

•

•

- Assure hazardous waste is destined for and delivered to appropriate

recycling, treatment, storage or disposal facilities.

- Full implementation of groundwater monitoring requirements.

- Timely submittal of complete Part B permit applications.

- Full implementation of closure, post-closure and financial assurance

requirements.

- Use of the manifest system and adherence to quarterly and exception

reporting requirements.

- Expeditious return to compliance by high-priority violators•

- Response to and investigation of complaints.

The Public Utility Comc1ssion (PUC) will monitor the compliance status of

hazardous waste transporters through its on-going vehicle and carrier

inspection program.

PART III

IDENTIFYING THE REGULATED COMMUNITY

It is important for the Department to be able to identify and characterize

the regulated community in Oregon with a considerable degree of accuracy.

ZC2170 -5-
Although considerable knowledge exists presently, DEQ will continue to

identify regulated persons and assess their compliance status.

The Department is developing and will maintain a computerized data system

which includes identifying information on·hazardous waste generators and

treatment, storage, and disposal facilities. Data entered into this system

is derived from Notification Forms (modified EPA Form No. 8700-12)

submitted to the Department to obtain an identification number.

DEQ also receives information on Oregon waste generators from reports

submitted by.the sole disposal site licensee in Oregon and by treatment

facilities.

Handler inspections provide an important source of information for

characterizing hazardous waste generation and management activities.

DEQ has conducted initial inspections at many existing registered handlers

who have shipped hazardous waste off-site. The Department will conduct

inspections of newly registered handlers on an ongoing basis to

characterize their practices and assess compliance status.

The Department's air, water quality and solid waste inspection programs can

sometimes provide information on potential hazardous waste activities, if

the inspector is familiar with the hazardous waste rules.

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ZC2170 -6-
•

•

•

PART IV

METHODS OF DETECTING VIOLATIONS

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

Revised Statutes (ORS) 459.670 and 459.285 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 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 -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 applications 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

non-registered 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

CRITERIA 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 c

ZC2170 -8-
• resulting enforcement actions. Therefore, the Department believes it to be

appropriate to establish criteria for the quality of its activities.

DEQ recognizes that these criteria specify standards of excellence which

may not be fully attainable in the immediate future. However, the

Department expects these criteria to remain as basic goals for performance

expectations. The criteria will be used as benchmarks to gauge progress

toward realizing a fUlly implemented quality compliance monitoring program.

Compliance Monitoring Quality Criteria

1. Inspections of handlers are thorough and include review of all

applicable hazardous waste requirements•

• 2. Inspection checklists are used correctly and completed fully.

3. All applicable documents and records required to be kept by handlers

are reviewed by DEQ for completeness, adequacy, and accuracy.

4. Copies of handlers' documents, records, and data are requested and

obtained as necessary to document compliance/non-compliance findings.

5. Photographs are routinely taken during inspections.

6. Sampling is conducted when needed to document inspection findir:~s.

•

7 . Sampling and analytical quality assurance/quality control protocols

are followed.

ZC2170 -9-
8. Violations are well documented.

9. Narrative inspection reports supplementing the checklists are

completed in a timely manner.

10. Compliance files are maintained and readily accessible (subject to the

applicability of confidentiality provisions of Oregon law).

PART VI

INSPECTION PRIORITIES AND PRACTICES

The inspection of hazardous waste handlers is a key component of -the

State's compliance monitoring program. The following discussion describes

the priorities and practices the Department will use to conduct handler

inspections.

Establishment of Priorities

Priorities for Department inspections of handlers are developed by the

Department's Hazardous and Solid Waste Division in consultation with DEQ

Regional pffices and EPA Region 10. The following sources of information

are used chiefly:

- EPA guidance (RCRA Implementation Plan, Interim National Criteria,

National Permit Strategy)

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ZC2170 -10-
•

•

•

- State's notification data system

- Compliance monitoring data system (i.e., results of past

inspections)

Priorities are established annually as part of the development of the

Hazardous Waste Program Plan for the State/EPA Agreement. A draft workplan

is developed in March and finalized by June. The priorities established

are for the period July 1 through June 30, which coincides with the State's

fiscal year. The priorities are subject to change.

The State/EPA Agreement identifies by name the major TSD facili~ies,

generators, and transporters which will be inspected annually.

(Inspections of additional handlers are conducted, but not specifically

named in the SEA.)

EX 86 Inspection Priorities

The Department's inspection strategy calls for the yearly review of a

percentage of handlers to ensure all TSD facilities will be inspected

within two years, and all generators will be inspected within (a maximum

of) five years. Those parties identified as major handlers receive yearly

inspections because their activities have the potential to pose the

greatest threat to public health and the environment. Handlers which

experience spills of hazardous waste may be inspected, depending upon the

specific circumstances of the spill•

ZC2170 -11-
The following priorities will be followed in FY 86:

- 100% of all major handlers

- 50% (minimum) of remaining non-major treatment and storage

facilities

- 1% (minimum) of registered generators and transporters

- 100% of all facilities permitted in previous year

- 100% of all facilities which closed in previous year

- 100% of all facilities from which a Part B permit application was

requested in FY 85

MaJor handlers include all operating facilities required to monitor

groundwater, all incinerators, up to 10% of the remaining TSD facilities

and 3% of the generators and transporters.

If resources are sufficient, greater than 1% of generators and transporters

may be inspected.

The Department will also conduct additional inspections on an as-needed

basis, as per the following:

- Follow-up inspections for past violators

- Newly registered handlers

- New TSD facilities

Potential criminal violations may be referred to local county District

Attorneys or to EPA for investigation.

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ZC2110 -12-
•

•

•

Inspection Practices

Inspections of TSD facilities are conducted by staff of the DEQ Hazardous

and Solid Waste Division (HSWD) and Regional Offices (RO). HSWD staff are

responsible for the monitoring compliance with permits issued pursuant to

Division 104 or with the interim status standards of 40 CFR Part 265.

Regional Office staff are responsible for determining compliance with

Division 102 (generator requirements). Overall responsibility for

scheduling these TSD inspections, completing inspection reports, and

initiating necessary enforcement response for these facilities rests with

the RO staff.

Conduct of generator inspections and related enforcement follow-up is the

responsibility of DEQ regional offices. A list of scheduled generator

inspections is developed annually by July 1 for each of the five DEQ

regional offices.

Inspections of TSD facilities include record reviews and reviews of

groundwater monitoring reports (where groundwater monitoring is required).

Record reviews of closure/post-closure plans and financial documents are

generally conducted concurrent with the compliance evaluation inspection

(CEI). Groundwater monitoring inspections are conducted by HSWD staff in

consultation with a hydrogeologist (either DEQ or Water Resources

Department) and Regional Office staff. If sampling is conducted, the DEQ

Laboratory Division may also participate.

TSD facility inspections may be coordinated with permit writer visits to

facilities which have been requested to submit a RCRA Part B permit

application.

ZC2170 -13-
Quarterly commitments for inspections (including record reviews and

groundwater monitoring evaluations) are established in the SEA workplan to

facilitate monitoring of progress toward achieving annual commitments.

The decision as to notifying handlers of scheduled inspections is generally

made by the Department inspector. In order to ensure effective inspections

and promote consistency within the program, the Department will use the

following interim guidelines for inspection notification:

1. Prior notification to handlers of impending inspections will not

be required, but may be provided as discussed in paragraph 2

through 5 below.

o

2.

ZC2170

Prior notification may be appropriate and useful in certain

circumstances, including the folloWing:

a. To ensure essential facility employees will be present

during the inspection.

b. To ensure facility consultants will be present.

c. To provide adequate facility preparation for special purpose

visits such as comprehensive groundwater monitoring

evaluations.

d. To meet legal obligations of the Department where such

exist.

-14-

o

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•

3. If prior notification is given, it will be kept to as short a

period as possible.

•

•

4. A decision regarding prior notification will consider the extent

to which past inspections of the facility, where notice was

provided, resulted in the handler taking actions which would not

have occurred if notice was not provided.

5. Inspectors will consider alternating notice and no-notice of

inspections to handlers.

DEQ utilizes checklists to guide inspections of hazardous waste handlers

and to record compliance with program requirements. Inspection reports

subsequently prepared include a narrative report, copies of checklists,

photographs, documents and other appropriate data.

PART VII

EVALUATING EFFECTIVENESS OF THE STRATEGY

The Department recognizes the importance of program evaluation to achieving

its objectives in compliance monitoring. Therefore, the strategy

explicitly provides for periodically evaluating the strategy's

effectiveness and making refinements as necessary•

ZC2110 -15-
Areas for Evaluation.

o

The primary areas for evaluation are: (1) the extent of compliance by

the regulated community with the State's hazardous waste requirements,

(2) adherence of the Department to its output commitments, and (3) quality

of performance. The assessment of compliance of the regulated community

will focus on the specific priority objectives identified in Part II of

this strategy.

Measures of Success

The Department will utilize compliance rates as one measure of success of

its compliance monitoring program. DEQ's goal is to demonstrate increasing

rates of compliance in the priority areas of groundwater monitoring,

~losure, post-closure, financial responsibility and complete permit 0

applications.

Adherence to output commitments will be measured by the Department's

success in meeting targets established in the annual State/EPA Agreement.

Evaluating the quality of performance is a more subjective yet equally

important effort. The Department will use the criteria in Part V to assess

the quality of its activities. DEQ's goal is to achieve an increasing

level of performance over time. Also the Department intends to use EPA

oversight inspections as a means for measuring performance.

o

ZC2170 -16-
e.

e

e

Eyaluation and Refinement Process

Tracking compliance activities is critical. The Department plans to

enhance its efforts in this area during FY 86. DEQ will continue

completing Hazardous Waste Compliance Monitoring and Enforcement Logs

(CMEL). to track inspections, record reviews, and groundwater monitoring

evaluations. The CMELs will be used also to report and track the

resolution of violations. DEQ will use EPA-generated compliance data

reports until a State computerized reporting system is developed and

operational.

Following Final Authorization, the Department will develop a system for

tracking and reporting progress in hazardous waste permitting.

The performance quality criteria will be used jointly by Regional Offices

and the HSWD to assess the quality of the Department's compliance

monitoring activities. Review and assessment will oocur principally at the

follOWing points:

- Periodic training sessions conducted for hazardous waste program

staff.

- Mid-year and end-of-year reviews conducted pursuant to the State/EPA

Agreement.

- Participation in program audits which may be conducted by EPA.

ZC2170 -17-
It is expected that refinements may be made to this strategy in response to

shortfalls or changes to federal requirements and priorities. However, the

Department's basic goal of sustaining a high rate of compliance remains,

and will guide its compliance monitoring activities.

c

o

ZC2170 -18-
•

•

•

APPENDIX G
• •l.:~.

lIDIl1l1HJ:::.rLJJlli100

._->!illi~ __-f fi.:l!~ ,j1i!l:iilL ._Am:iL __ •

Hl:Kc:J:;on

Cllt:lliit:ul.

PUl'lliill'l1

!1iit..::llt:I'

S&Jnll,~.·

l1i!y. • _J.uu~ __

J(Jhlwou

CulIlt'l,l.

(""t.y

Bai;~Jlt.:'·

~iJnJl:I~

Tcktr-...1II1x ,

Beaver-Len

IJulay

lIa,'lfOl'd

Boclng,

Por-t l and

[)oldY

fh'Coc,fcld

---------- '-JU1Y----r-AUWll--ri"lW.1.~--- --lk:l..L_---+JlQY-~ _

!HaJ'W 1- fillmore Steel Allied Pe'lOa ; t:lectrolll<:

TSD Po,'tland, Plaling, Po"t, I' Cu"t. Dusf gn Porlland lllllsboro ,-tul1no

lIe""I<:r Ressler Re"sl"r 1,"1uy

Heller I IJmmtdd Bmwfehl S:'lldcr

f-----~ +----___+__ , I --1-----..-----·--------·--------

tlu" H:.Ju,'

TSIJ

Conllrenta I

Call.

Por-t Iand

Daesler

Sander

Van I/atvrs

& Ilogerll,

Por'tland

8aesler

lIartford

Uan;m

milkv"te",

Pcrt Iand

Bacsler

lIartf....'d

IIkd"l

II~l' 1.•

Po,'t1"nd

rh~sslel'

Sdudt:"

-IaJ.-.r

icncr'ators

Diamond

C<i1J1r1ll1",

III11eboro

lira I,hi c

A,'ts

Partial""

Floating

POlllt,

Beaver-ton

.Iyc,'s

l)I'tUJI.

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Resslcr [)Olay Rcssler a~;JoJh;:r

lla""ler

lJacs'e,'

l.cluillg,CI'

Puli:;h PloL t •

.'Ol't t"",, H.t~~:JJ CI'

KOI'I>c"",

l'O/'t1a,""

""lcloll01d

Chc.:udwl,

3t. IIclen"

B"c"lcr

""I'C,:I'

Inauatr-Les ,

Bcavcr-t.ou

.ld:ollllICk &

1J,:.;.<ter,

Por-t l ••lh

H"""le"

Pac. St;,lc,-,

Gal vaut "Cl'S,

l)ol't1"nd

UC~S) crSIIlfl

AlUlf.::;!V C:.i,

Port Lanu

SI.auffvr

Clluuical

POl,tland

D"""ler

Rhon"

Poulene,

Portland

Simp~1I

Tlmbc[',

rortland

/lac5lvr

ftv""lcr

Porlland

Wl1lamclte,

Portland

lIe:;"le,'

General

Elcelri".

P,wtlall"

U""slcr

8aesler

lIae"ler

HcClosky,

I'ortland

Port. Indu"

Cnrome ,

Por t Iand

IIcs"IOI'

Savin,

Portland

Gertxw

I.egendary

DIad""

Portland

ftc:;::II.,.'

Pcnnwal t,

h ...tI am!

lJ.:.eGlcr'

l/"stCI'1I

Bat t.ery,

Beavcrtou

B~Jc:ilcr

o.en5

I1linoI5.

Portland

fte"sle,'

Ilacs.er

W"sten.

Kraft,

Beaverton

lIe,-,sler

Td-Het

(Powell) ,

Portland

He""ler

Allicd

Sy::tlem,s.

Sherwood

Uac,,1"r

Herll 011,

l'o,'L1;;nd

IIcssl"r

li'lCl'gy

AIternat Ives

Tllalatin

Tlcr 2 I ColumbIa IElcctronlc Berg:iO<l PSI HI'g, 1~'I-Het Slemenslocnc:l'alor' Amer. Platng SpecIalty, Helals, SL. Hel ena , (Dlvl"lon) , AII1",

Portland Por-t Iand Sl. lle l ena Portland Tigard

Hcssler [)Olay &f:sler Dulay ftessler ftessle,'

------ ------ ------ ------ Electro Crystal TI'I-II"t Dura,

Scientific, Lite Hfg., (Hetro) , IndustrIes,

Portland Sherwood Beaver-ton Por-t Iund

lIe"sler H~331.;r Reasl cr _ Baesl er

RC:J"ler

I I I I I I I I I 1- 1---

b

-- 1 I I I I I I 4 I -/----,---.-----

lror

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~..)

.

--l

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l'o,'t1"nd

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W35qll.1

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o

H

X

C'l
•

•

•

APPENDIX H
• STATE OF OREGON

CEPARTMENT OF ENVIRONMENTAL QUALITY

APPENDIX H

PART 1

INTEROFFICE MEMO

TO: File CATE: June 25, 1985

FROM: Gregory D. Baesler

SUBJECT: H. W. - i

Multnomah County

On May 14, 1985 a hazardous waste compliance inspection was made of

..lIlIlIlIlIlIlIlIlcompany, located a Portland, Oregon.

Inspection participants were:

1 -' Gregory C. Baesler, CEQi

2 - Wayne Pierre, EPA, Region 10i

3 -•••••••••••••••lICompanyi

(Wayne Pierre was present primarily regarding the superfund preliminary •

assessment) •

4 - • .~. .. • J. .: ',_\..- _ # ;-. " \ .... ., .... Company .

Background

1I.IIIIIIIIIIIIIICompany is an industrial chemical distributor. The

chemicals handled are generally food chemicals, additives, preservatives,

drugs and pharmaceuticals. ' has bulk storage of mineral acids,

Le., hydrochloric acid, sulfuric acid, and nitric ac i d r SOlvents, Le.,

methylene chloride, 1,1,1 trichloroethylene, isopropyl alcohol (IPA) ,

glycol ether (EB), trietholamine, propolene glycol, dybutal thiolate,

acetone, diethylene glycol (CEG), caustic potash and triton X-IOO

(surfactant). These products are re-packaged and distributed. Other

products are received in drums and are shipped out without repackaging .

I pa r t A Hazardous Waste Permit Application, November 18, 1980.

" .. r: "-' ::....- . .

{ .. : I • ..: -, • • _. "_ r ..' '., .

'". ';',," -. -:: ,,- .,' '''-

..1I1I1I1I1I1I.....Company is a wholly owned subsidiary of

Incorporated. Their corporate headquarters is located

San Francisco, California, 94104. M

Company began operation at its present location on August 1, 1961. The

facility is leased from

• Portland, Oregon 97210. 1

•
File

June 25, 1985

Page 2

..........IIII......Company was formally called .........IIIIIIII......

Initially, this company dealt with dry chemicals only. Later the company

began storage of liquid chemicals in bulk. The primary means of shipment

into the facility used to be by rail. Due to economic reasons, shipment

by motor carrier has dominated in recent times.

J ,

EPA Waste Code No. Hazardous Waste

FOOl Spent halogenated solvents used in degreasing

F002 Spent halogenated solvents

F003 Hazardous waste spent flammable organic solvents

F004 Hazardous wa.te is spent nonflammable organic

solvents

F005 Hazardous waste is spent flammable toxic organic

solvent

The total designed capacity of the storage area is 7,920 gallons

(144 55-gallon drums) •

Preinsoection Interview

.~~erre and myself explained to? that the purpose of·our visit was

two-fold. One was that DEQ would be conducting a compliance inspection

of hazardous~waste management activities as; a generator and as

a TSD .facility (OAR 340"Division 102 and 40 CFR Part 265) and that Pierre

was present for the purpose of completing the Preliminary Assessment under

the superfund program•

..... began by telling us that the 'i..II"IIIIIIII.. Company had applied

for authority to store hazardous waste and to transport hazardous waste.

II1II went on to explain that it is the intent oflll to collect

o

c
•

•

•

File

June 25, 1985

Page 3

hazardous waste and to ship the hazardous waste to either their own company

in California or to a local facility for recycling. 7Dtold us that

1IIIIIIIltis not presently transporting or storing hazardous waste. .a..... was asked if the company had any storage tanks for hazardous wastes• ........

told us that there were no tanks presently on site for the storage of

hazardous waste. There was a 1500 gallon tank (constructed of cross link

polyethylene) used for elementary neutralization. xplained that

"empty drums" (that at one time contained corrosives) returned to

tI..........~facility were rinsed out and the rinseate drained into the

tank. The tank's contents is neutralized with soda ash to a pH of about 7

and is then discharged to the City of Portland Sanitary Sewer System.

This discharge occurs on the average of once every month. The City of

Portland was contacted concerning the discharge and stated that they

currently do not have under a discharge permit. (The City's

standards for pH discharge would typically be 5.5 to 10.0.)

IIIiI was asked what waste Company generated as a

generator. Reid told us that the company does generate "flush solvent".

This flush solvent would be isopropyl alcohol (IPA) and after use would

contain IPA, plus the solvent that was being flushed from the system, or

solvents being repackaged. These repackaged solvents would be any of the

previously mentioned solvents received in bulk. The next phase of the

inspection was a tour of the facility. Prior to beginning the tour, HI

was asked if he had any objection to our taking photographs. sa told

us that he had no objections.

The tour began with the hazardous waste storage area (he introduced us

to 2 2 A'lho works in the hazardous waste storage and generating

areas). The hazardous waste storage area is located on a raised concrete

dock on the northern side of the warehouse and was reported to be at least

50 feet from ~~e nearest property line. The storage area occupies 520

square feet (20 ft x 26 ft), is surrounded on three sides by a six inch

concrete curb that is sloped toward the east. On the west side of the

storage area is a raised concrete berm. On the northeast corner of the

storage area there is located a blind sump - dimensions of 2 feet by 2

feet by 1 foot deep. The sump was within a couple of inches of being full

of liquid. & told us that he intenged to discharge the liquid in the

sump to the City sanitary sewer. The liquid in the sump in the hazardous

waste storage area was said to be rain water, that apparently rained into

the storage area. This was said to occur even though the storage area

has a roof and a wall on the south side. It appears that rain water

accumulation will be a continuing problem in the sump. There does not

appear to be a procedure on sampling and analysis of the sump. In

addition, it should be pointed out that this facility does not have

laboratory capability on site~ therefore, all analysis except for pH

measurement (that is determined with pH indicator paper) would have to

be sent off site. The following photographs were taken of the storage

facility:
File

June 25, 1985

Page 4

Photo No.

501

502

503

504

505

Description

Picture of the NW corner of the

hazardous waste storage area - the

6-inch concrete curbing and the

collection sump can be seen.

Picture is a closeup of the collection

sump and has a waste storage area.

Liquid can be seen in the sump.

Picture of the 5W corner of the

hazardous waste storage area. The

6-inch curbing can be seen as well as.

a 55-gallon drum of what was described

as resin. The only labels visible were

a red-diamond shaped label with the

words nflamrnable liquid n and tape with

the word nresinn written on it.

Picture lS similar to 503 but from a

different angle.

Picture taken looking toward the west

from within the hazardous waste storage

area. Picture shows 6-inch concrete

berm and storm sewer catch basin.

o

o

The next phase of the tour was the inspection of the lSOO-gallon

neutralization tank. The neutralization tank is located southeast of the

hazardous waste storage area, adjacent to the loading dock. This is the

tank that returned "emptyn 5S-gallon drums that once contained corrosive

liquids are rinsed out. The rinseate is said to be neutralized with soda

ash to a pH of about 7 and then is batch discharged to the City's sanitary

sewage system via a hard plumbed pump and transport pipe. The following

photographs were taken of the tank:

Photo No.

NOI

N02

Description

Located in the center of the picture

can be seen in the white polyethylene

l500-gallon neutralization tank.

Picture of the neutralization tank

looking toward the east - arrow points

toward the rack that the empty drums

are placed on to be rinsed out.

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File

June 25, 1985

Page 5

N03

N04

Picture taken of neutralization tank

looking toward the north. Rinse rack

and plumbing can be seen.

Pictures of neutralization tank from

the north side. Plumbing from the tank

is visible. Under the top portion of

the 55-gallon drum is the pump for

pumping to the sanitary sewer.

•

The next area of the facility toured was the drum-fill area. This is the

area where • would generate their own wastes. The waste would be

generated by flushing lines with IPA after repacking of a particular

product is completed. There is about 4 or 5 feet of line that would

require flushing. The floor of the building where the drums are filled

and the flushing occurs is constructed of concrete. The area around the

filling/flushing area is covered with asphalt. Natural drainage from the

site would appear to be directed to the north. On the north side of the

asphalted area is a sluice gate. The gate of the sluice is constructed

of wooden 2" x 12". On either side of the sluice is an asphalt border

which is bermed and about 6 inches in height. Just north of the sluice

gate there was an absence of vegetation. It was not possible to determine

during the site visit the reason for this condition. The following

photographs were taken of the area where drums were filled and the flushi~g

of the lines occurs and hazardous waste is generated.

•

Photo No.

FOI

F02

F03

Description

Picture taken facing north looking

toward the rear (north)

of the property. Yellow/beige building

is located where drums are filled and

lines are flushed with IPA generating

the facility's hazardous waste.

Picture taken facing to the south.

Loc9tion where the drums are filled

and line flushed is to the right

of the photo. The neutralization

tank is to the left and center

of photo.

Picture is taken inside of the drum

fill building. Arrow points to the

fill line that is flushed.
File

June 25, 1985

Page 6

F04

FOS

F06

F07

Picture is the same description as F03,

except that it is taken at a different

angle.

Picture is similar to FOI. Arrow points

to sluice gate.

Picture is the same as FOI and FOS,

except it is taken closer to the sluice

gate.

Picture is taken near neutralization

tank looking toward the south and the

entrance gate into the facility.

o

The remainder of the tour was a walk from the northe~ portion of the

property to the southern portion. Near the first bay into the product

storage area, three drums were observed (photograph pal). told us

two of the drums were empty and that the third contained soda ash for use

in cleaning up spilled material. A dumpster for the collection of solid

waste was passed and photographed (!WOl). Inside of the dumpster there

was sorbent that was obviously contaminated. ,jd Sttold us that the

material was not hazardous and that it was a surfactant that had spilled

accidently and had been cleaned up.

Manifest Review

IIlIlaawas interviewed concerning the management of the hazardous waste

specifically with regard to manifesting. iii blooked for the manifests

and provided us with those he could find. ' iltold us that no shipments

of hazardous waste occurred in 1984. Four manifests were available for

review for the year 1983. All shipments were made on November 28, 1983.

The manifests (attached) were numbered R-006l, R-0062, R-0063, and MCC-43

(Manifest document numbered 00001 and 00002 were received by mail on

May 31, 1985).

1. Manifest document R-006l

a. The units column of this manifest is not

filled in.

b. The total quantity column of this manifest is not filled in.

c. The proper hazardous class of ethylene glycol monoethyl ether

is combustible liquid, not flammable liquid as shown.

d. Ethylene glycol has hazard class listed in the manifest of

combustible liquid, when there is no hazard class listed for

it in 49 CFR 172.101.

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File

June 25, 1985

Page 7

2. Manifest document R-0062

a. The units column of this manifest is not filled in.

b •. The total quantity column in this manifest is not filled in.

c. The hazardous class of the hazardous materials is not filled in

when required.

3. Manifest document R-0063

a. No listing is found of these materials in 49 CFR 172.101.

b. United Nations (UN) number or North America (NA) number column for

this column lists ORM-E. This is an inappropriate use of the

column.

4. Manifest document MCC-43

a. The generator return copy of this manifest is not available for

review. honly had the generator copy available.

Generator failed to file an exception report for this discrepancy.

b. "TRIETHSNOLAMINE" does not appear to be an appropriate proper

shipping name. There is no hazard class listed, and the UN n~ber

or NA number column has the number L-122 listed which is not

appropriate for this column.

c. Waste ferric chloride is listed~ however, the shipper did not

designate if it was solid or liquid.

d. The UN number for "cn listed above is "UN 252" when it should

have been listed as ON 25~2.

e. Isopropanol Triton X-lOO does not appear to be a correct, proper

shipping name. No hazardous class is designated and the number

listed in the UN number or NA number column is NA 121. It appears

it should have been UN 1219. ,

f. The units column is not filled in.

g. The total quantity column is not filled in.

5. Manifest document number 00001.

a. Item "D." The transporter's phone number was not filled in.

c. The EPA waste number for waste isopropanol mixture was entered

•

as 212 in Item I. The appropriate EPA I.D. number is 0001.

b. Item "F." The transporter's phone number was not filled in.
File

June 25, 1985

Page 8

d. Item ll(b). The proper shipping name is not consistent with

49 CFR 172.101, and the reportable quantity (RQ) is not present.

The hazard class is lIsted as Rcorrosive liquid. R The correct

hazard class should be corrosive material or ORM -A.

e. The EPA waste number for Rwaste ammonium hydroxide solutionR was

entered as 135. The appropriate EPA ID number is 0002.

f. The EPA waste number for "wast.e dichloromethaneR was entered

as 21l. The appropriate EPA ID number is F002.

g. The EPA waste number for RHazardous waste liquidR was entered

as 212. This is not the correct EPA ID number.

6. Manifest document number 00002.

o

a. Page 2 of manifest document number 00001 has the manifest

document number 00002. The shipper should have used the

continuation sheet (Form 8700-22A).

b.

c.

Item D. The transporter's phone number was not filled in.

Item F. The transporter's phone number was not filled in. o

d. Item 11. The proper shipping name is incorrect due to an

apparent misspelling. The correct spelling should be

trichloroethane.

e. Item I. The number 211 was entered. The appropriate EPA ID

number is FOOl.

Manifest document numbered 00001 and 00002 (original manifests) were

returned to the generator unsigned by the TSD facility. Transporter

number 2, Company , failed to obtain the

TSD facility's certification of receipt of the hazardous waste. The TSD

facility, I I failed to sign the

original manifest and returned the generator portion of the manifest to

the generator unsigned. The generator, 2 22

notified transporter 2 by telephone of the discrepancy

during the compliance inspection (within 35 days of shipment). tater the

TSD facility signed copies of the manifest and returned them to the

generator who sent these copies to the Department. No Manifest discrepancy

report has been received by the Department to date.

Waste Analysis Plan

The waste analysis does not include provisions for analysis procedures

to be followed in order to manage liquids that accumulate in the blind

sump located in the hazardous storage area. During the inspection of the

facility, it was noted that the .sump was near_ being full. Although _<;9mpany

representatives believe the contents to be only rain water, it must be

analyzed in order to manage it in an appropriate manner.

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File

June 25, 1985

Page 9

Security

The security of the facility is as described in the company's

Part B Hazardous Waste Permit Application.

General Inspection Schedule

The inspection log of weekly inspections was reviewed and found to be in

conformance with Part B Permit Application. The weekly inspection logs

from the first part of October, 1984 to the end of April, 1985 were

reviewed during the inspection of May 14, 1985 and found to be complete

(During the interview stated that was not currently storing

hazardous wastes). This is consistent with the site tour finding with the

exception of the drum described as a resin which dIIIItold us they intended

to resell. The resin was said to have become viscous, but still useable.

Preparedness and Prevention

The company's provisions do not cover the conditions under which the

"sluice gate" is opened to allow the drainage of impounded liquids. In

Section 5 entitled "General Inspection Schedule" page 8, it is stated" •

water runoff in the designated waste storage areas and the secondary

containment units will not be a consideration because of a roof over the

area." During the inspection it was pointed out that liquid had

accumulated in the sump in the hazardous waste storage unit. We were told

that the liquid was rainwater. Although it appears reasonable on its

surface to assume that the majority if not all of the liquid was rainwater,

without an analysis of the liquid this conclusion must be considered

speculation. Therefore, analysis of this liquid should be included as

part of the provisions for preparedness and prevention procedures.

Provisions for emergency communications have not been made (see comments

under Contingency Plan and Emergency Procedures) .

Contingency Plan and Emergency Procedures

On page 16 of Company's Contingency Plan it is stated

"The Contingency Plan will be reviewed.and immediately amended whenever

the list of Emergency Coordinators change." is the current

Branch Operations Manager, but the Plan lists - as filling this

position. The Department has not received an amended Plan reflecting this

change in personnel.

On page 18 of the Contingency Plan it is stated "The facility has an alarm

system••. " During a follow-up telephone conversation about specifics

of the systa~, the Department was advised that Portland facility

did not have an alarm system installed. This information was confirmed

during an on-site inspection made on June 25, 1985.
File

;~: i~' 1985

II "Company has made copies of their Contingency Plan

available to:

a. The Portland Fire Bureau

b. Good Samaritan Hospital

c. Portland Occupational Medical Center

d. Multnomah County Sheriff's Office

Copies of letters from those acknowledging receipt of the Contingency Plan

are attached.

A revisit was made to _Company on June 25, and the

emergency equipment described in the Contingency Plan was inspected.

All equipment listed on pages 13 and 14 of the Contingency Plan was

present.

Training

The last annual training of employees was conducted on October 5, 1984.

Although a discussion of where the Contingency Plan could be found was

made at this training session, no detailed training discussing Contingency

Plan inplementation was made. A list of employees attending this session

is attached.

Closure Cost Estimate

The Department has not received a copy of an adjusted closure cost

estimate. contacted on June 5, 1985 and asked if an adjusted

closure cost estimate had been prepared since the initial closure cost

estimate that was included in the facility's Part B permit application.

The Department was told that one had not been prepared.

Financial Assurance

Financial Assurance must be adjusted to reflect the change in the

closure cost.

GDB:y

RY528

o
•

DEPARTMENT OF ENVIRONMENTAL QUALITY

Hazardous Waste Management

Inspection Checklist

PURPOSE -- This checklist is designed to serve as a guideline to the major

points of the regulations adopted pursuant to Oregon Revised

Statutes (ORS) 459.410 to 459.690 for inspectors to u~e while

visiting hazardous waste (HW) regulated facilities. This

checklist should not serve as a substitute for a detailed

knowledge of the relevant regulations. The following is the

outline of the checklist.

I. General Information.

II. Small Quantity Generator (SQG) Regulations (OAR 340-101-005)

III. Generator Regulations (OAR 340 Division 102)

IV. Treatment, Storage and Disposal (TSD) Permit Status Regulations

(OAR 340 Division 104)

I. General Information

APPENDIX H

PART 2

A. Inspection Type of inspection: Evaluation ( )j Sampling ( )j

Record Review ( )j Special ( )j Follow-up ( ) Date/time inspection commenced : _

• B. Facility

EPA/State ID ORD

Name &: Addresses, _

1. Mailing

2. Location

Contact, _

Telephone .(_..J-) _

C. Inspector Name (Print) __

Region'-- _

Title. _

Phone, _

•

D. InspectiQn Participants

RC1556.A I-1

Title Phone
E. Compliance Summary

No violations noted

Out of compliance

1. Areas of hazardous waste non-compliance requiring

correction:

2. Expected corrective action for areas of non-compliance items

(including time schedule as appropriate):

3. Are there any additional precautions

which you would recommend to improve

hazardous waste handling procedures at

the facility?

YES NO

c

4. Other areas of non-compliance requiring followup via other

DEQ programs:

DEQ Inspector Generator Representative

Date

RC1556.A I-2

Date o
F. Notification/Permit Information

Date : _

Da te : _

Date: _

Date: _ Date: _

NO

NO

NO

NO

YES

YES

YES

YES Part A: _

Started operation: __

Notification filed:

Part A application filed:

Part B called/date due:

Part B applicatio~:

Changes in Notification or

1 •

2.

3.

4.

5.

6.

•

7. Facility is classified as:

Generator ( )

Transporter ( )

Treatment facility ( )

Storage facility ( )

Disposal facHi ty ( )

Small quantity generator ( )

Recycler ( )

Less than gO-day storage ( )

Wastewater treatment unit exemption (WWTN) ( )

Elementary neutralization unit exemption (ENU) ( )

Comments : _

•

8. Boes facility have a Part A withdrawal

request in?

Status : _

YES NO

G. Hazardous Waste Generation CHW) and Management (List EPA Waste

Code)

1. General information

a. Characteristic HW (DXXX)?

(1) Ignitability (D001) [340-101-021] YES NO

(2) Corrosivity (D002) [340-101-022] YES NO

(3) Reactivity (D003) [340-101-023] YES NO

(4) EP Toxicity [340-101-024] YES NO

List: / / / I I

b. Listed HW?

•

(1) HW from non-specific sources (FXXX) [340-101-031]

----~/ / / / /

(2) HW from specific sources (KXXX) [340-101-032] ___...-.J/ / / / /

RC1556.A 1-3
c. Discarded commercial chemical product (PXXX or UXXX)

(1) PXXX [340-101 -033 (6») I I I C) (2) UXXX [340-101 -033(7») I I I

d. Process manufacturing residue YES NO

(23% of a P listed waste; 210% of a

U listed waste) [340-101-033(3)(a»)

e. Pesticide or pesticide manufacturing YES NO

residue [340-101-034)

f. Pesticide residue or empty containers YES NO

produced by the use of pesticides

[340-109-020 )

g. Has facility petitioned to delist YES NO

waste? [340-101-022)

Date: Comments:

h. Does facility qualify for WWTU or NO

ENU? [340-101-003(2)(d») Comments : _

1. Has a determination been made for each YES

waste generated that it is or is not a

RCRA hazardous waste? [340-102-011)

NO

RC1556.A

(1) What are the wastes generated? __

(2) How was the hazardous waste determination

made for each waste (i.e., lab analyses,

knowledge of waste streams or processes,

waste listed in OAR 340 Division 101)?

Comments: _

I-4

o
• (3) Are records available on the YES NO

determination(s)? [340-102-040 (3)]

(4 ) Are all hazardous wastes noted YES NO

during inspection listed on the

facility's RCRA notification/Part A

application?

If not, explain:

2. Specific information: Provide the following information for

each of the individual HW streams listed above. (Complete a

separate form for each HW and attach.)

•

a.

b •

c.

d.

e.

f.

g.

h.

1-

j.

EPA HW Code

HW description

Composition (including sampling requirements)

Process producing waste

Rate of waste production

Time of storage

Waste handling prior to disposal

Waste disposal practice and manifest

Reporting and recordkeeping

Comments

•

H. Miscellaneous Notes:

RC1556.A I-5
•

Facility Name ___

EPA/State ID ~O~RD~ ___

II. Small Quantity Generator (SQG) Regulations OAR ~40-1Q1-00?

A. General

1. Has the generator ever accumulated more YES NO

than 2,000 lb. of D, F, K or U listed h~ or

2 2 lb. of P listed HW (OAR 340-101-033(6))1

a. If YES, is the waste stored in

containers or tanks? (circle one)

b. Is any HW stored in waste piles or

surface impoundments?

YES NO

B. Small Quantity Generator (SeG) Regulations

1. Has generator determined if he generates

a hazardous waste (OAR 340-102-011)?

[340-101-005(7)(a)(A)]

NO

2. Which of the following describes the SQG's

treatment and/or disposal of his HW?

•

a •

b.

Occurs on-site [340-101-005(7)(c)]

Ensure delivery to an off-site facility,

either of which is [340-101-005(7)(c)

or (d)]:

NO

(1) Permitted under OAR 340

Division 105, or 40 CFR Part 270

[340-101-005(7)(c)(A) or

340-101-005(7)(d)(A)(i)]

Y~ NO

(2) In interim status under OAR 340 YES NO

Division 104 and 105, or 40 CFR

Part 270 and 265 [340-101-005(7)(c)(B)

or 340-101-005(7)(d)(A)(ii)]

(3) Authorized to manage HWby an NO

authorized state [340-101-005(7)(c)(C)

or 340-101-005(7)(d)(A)(iii)]

•

RC1556.A

(4) Permitted, licensed or registered YES

by a state to manage municipal or

industrial solid waste [340-101-005-

(7)(d)(A)(iv)]

If YES, was permission obtained YES

from waste collector or landfill

permittee to dispose of small

quantity of HW?

[340-101-005(7)(d)(B)(ii)]

II-1

NO

NO
RC1556.A

(5) A facility which:

(a) Beneficially uses, re-uses, YES NO 0 recycles or reclaims his HW

under 340-102-052

[340-101-005(7)(d)(A)(v)(I)]

(b) Treats his waste prior to YES NO

beneficial use, re-use,

recycle or reclamation

[340-101-005(7)(d)(A)(v)(II)]

3. Does generator manifest his wastes? YES NO

[340-101-006 ]

(required (not required ,

J

4. Does generator use shipping paper for YES NO

beneficial use of wastes? [ 340-1 01-006 ]

(required (not required )

o

o

II-2
• Facility Name _

EPA/State ID ~O.... F.Do:.- _

III. Generator Regulations OAR ,llQ Division 102

A.

B.

Is the facility or does facility claim to be a

small quantity generator (under 340-101-005)?

Comments: _

Does generator transport its own waste?

If NO, what is transporter's EPA ID, name,

address and phone

YES

YES

NO

NO

EPA ID, _

Name _

Address, _

Telephone, _

• c. Does generator use the manifest system?

[340-102-020 ]

Does generator substitute shipping papers for

the manifest for wastes shipped off-site for

benefi~ial use or reuse? [340-102-020(5)]

YES

YES

NO

NO

1• Does the generator ever offer his hazardous YES

waste to transporters or to TSD facilities

which do not have an EPA ID number?

E340-102-020( 2)]

What transporters or TSD facilities?

NO

2. A generator transporting or offering for

transport hazardous waste for off-site

TSD must first prepare a manifest.

[340-102-020(1)]

'.

RC1556.A

3. If the waste is undeliverable to the primary

or alternate facility, the generator must

either designate another alternate facility

or instruct the transporter to return the waste.

[340-102-020 (4)]

III-1
Does the manifest contain the following

information: [340-102-021(1)]

a.

b.

c.

d.

e.

Manifest document number Y!S

[340-102-021(1)(a)]

Generator's name, mailing address, ~...s

phone number and EPA ID number

[340-102-021(1)(0)]

Name and ID number of each transporter YES

[340-102-o21(1)(c)]

Name, address and EPA ID number of YES

the designated and alternate !SD

facilities; if any [340-102-o21(1)(d)]

Description of waste(s) required oy YES

DOT regulations in 49 CFR 172.101,

172.202, 172.203 [340-102-02l(1)(e)]

NO

NO

NO

NO

NO

..

- Proper shipping name - Hazard class

- Identification number

NO

NO

NO

f. Total quantit1 of hazardous waste YES

by units of weight or volume and type

and number of containers placed aboard

transport Vehicle [340-102-o21(1)(f)]

so

4. Does the manifest contain the certification YES

attesting to proper classification,

description, packaging, labeling, marking

and condition in accordance with DOT and

DEQ regulations? [340-102-021(2)]

NO

5. Does the manifest contain an adequate

cumber of copies to provide one copy for:

[340-102-022]

6. Does the generator use the manifest properly by:

[340-102-023 ( 1)]

RC1556.A

a.

b.

c.

d.

e.

a.

Generator's records

Records of each transporter

TSD facility owner or operator's

records

Signature by each transporter and

return to generator

Signature by TSD facility and return

to generator

Signing the certification

[340-102-023(1)(a)]

III-2

NO

NO

NO

NO

NO

..
• b. Obtaining signature and date of

acceptance from initial transporter

[340-102-023(1)(b)]

YES NO

c. Retaining one copy of the trans- yt;'-S

porter's signed manifest for 3 years

or until receipt of a signed copy

from disposal facility [340-102-023(1)(c)]

NO

d. Giving transporter the remaining

copies of the manifest

[340-102-023 (2)]

YES -NO

7. Does the generator contact the transporter YES NO

and/or the designated TSD facility to

determine the shipment status in the event

that a signed copy from the designated

facility has not been received within 35 days?

[340-102-042( 1)]

If a Manifest Exception Report was submitted,

did it include the following: [340-102-042(2)] •

8. Does the generator submit an Exception

Report to the DEQ in the event that a

signed copy of the manifest has not been

received from the designated TSD facility

within 45 days? [340-102-042(2)]

9.

YES NO

• •

a.

b.

•

A legible copy of the manifest, and

[340-102-042(2)(a)]

A letter of explanation describing

efforts and results of status investigation [340-102-042(2)(a)]

• TSD FACILITIES SKIP TO MODULE rv •

YES

YES

• •

NO

NO

•

D. Does generator operate a specific area on-site

for container handling or storage?

NO

1. Does generator comply with the requirements YES NO

set forth in governing on-site waste

accumulation? [340-102-034(1)(a)]

3. What quantities of HW are stored?

Are incompatible wastes segregated?

[340-1 04-177( 3)] •

2.

a.

b.

c.

Labeled and marked with words YES

"Hazardous Waste" [340-102-034(1)(d)]

Date period of accumulation begins YES

[340-102-034(1)(c)]

Inspections (weekly for containers) YES

[340-104-174]

YES

NO

NO

NO

NO

RC1556.A III-3
4.

5.

What is the longest period that it has

been stored?

Were there any hazardous wastes stored YES

on-site at the time of inspection? (9Q-day

storage allowance is allowed only if the

waste is stored in accordance with OAR

340-102-034; i.e., must be stored in

containers or tanks. Thus, need to make

note if storing in waste pile, etc.)

NO

a. If YES, do they appear properly

packaged (if in containers) or, if

in tanks, are the tank3 secure?

[340-102-o34(a) or (0)]

NO

RC1556.A

o. If not properly packaged or in

secure tanks, please explain.

c. Are containers clearly marked and YES NO

labeled? [340-102-034 (1) (d)]

d. Do any containers appear to be 1eaking? YES NO (; (340-104-174] '----./

e. If YES, how many?

6. Generators may store hazardous waste fer

less than 90 days without a permit or TSD

status providing certain requirements have

been met. [340-102-o34( 1)]

a. Are the containers made of or lined YES NO

with materials which will not react

with and are compatible with the

hazardous waste to be stored in them?

[340-104-172]

b. Are the containers always closed, YES NO

except to add or remove waste?

[340-104-173( 1)]

c. Are container storage areas inspected rss NO

weekly for leaks and container

deterioration? [340-104-174]

III-4
• d. Are precautions taken to prevent YES NO

accidental ignition or reaction of

ignitable or reactive waste?

[340-104-017( 1)]

e. Are containers holding ignitable or YES NO

reactive waste located at least 50 feet

from the facility's property line?

[340-104-176 ]

f. Is the facility aware of and complying

with the following requirements for

incompatible wastes:

(1) Incompatible wastes must not be YES NO

placed in the same container,

unless in compliance with OAR

340-104-017 (2) • [340-104-177(1)]

(2) HW must not be placed in an YES NO

unwashed container that previously

held an incompatible waste.

[340-104-177(2)]

(3) Are storage containers holding HW YES NO

that are inco~patible with any

•

waste or other material stored

nearby separated from or protected

from them by means of a dike,

berm, wall or other device?

[340-104-177( 3)]

Explain:

g. Before transport, are containers YES NO

marked or labeled in a manner

equivalent to 49 CFR 172?

[340-102-031 and 340-102-032]

h. Is secondary containment provided YES NO

for storage of more than 100 drums

(reqUired after January 1, 1985) ?

[340-102-034(1)(f)]

1- Comments:

•

RC1556.A III-5
1. a. Does the generator import or export HW? YES

(340-102-050 ]

NO ()

b. If YES, has notification of this

activity been submitted to the

Department and the EPA Regional

Administrator? (340-102-050(2)(a)]

NO

c. Is a copy of that notification

available? (If YES, obtain copy.)

NO

d. If a copy is not available, or cannot NO

be obtained, determine: (1) when the

notification was submitted; (2) for

what waste type; and (3) for what

foreign facility (name and address).

8. Preparedness and Prevention (OAR 340-104 Subdivision C)

(340-102-o34(1)(c)]

a. Is facility maintained and operated YES

to minimize the hazards of fire,

explosion, and sudden or non-sudden

releases to the environment? [340-104-031]

NO

b.

c.

Is internal emergency communication YES

equipment or alarm systems installed'?

What type? (340-104-032(1)]

Is a device (e.g., telephone) iMmedi- YES

ately available for summoning emergency

assistance? (340-104-032(2)]

NO

NO o

d. Are fire extinguishers or other

emergency equipment immediately

available on-site? [340-104-032(3)]

NO

e. Is emergency communications and YES

response equipment tested?

How often? [340-104-033]

NO

f. Is aisle space adequate for emergency y-~

response? What is aisle spacing?

[340-104-035 ]

NO

g. ( 1) Have any arrangements been made !ES

with local emergency response

organizations? (340-104-031(1)]

NO

(2) Which organizations?

RCi556.A !:!-6

o
• (3) If local organizations have

declined to enter into response

agreements, is this documented in

the facility's operating record?

[340-104-037(2)]

9. Contingency Plan/Emergency Procedures (OAR 340-104

Subdivision D) [340-102-034(1)(e)]

NO

•

a.

b.

c.

d.

Has contingency plan been developed? YES

(It may be a modified spec plan.)

[340-104-051(1)]

Have incidents occurred where the plan YES

has been implemented?

Have incidents occurred where the plan YES

should have been implemented but was

not? [340-104-051(2)] Explain:

A copy of the plan should either be

obtained for post-inspection office

review or it should be examined during

inspection for the following:

NO

NO

NO

(1) Does the plan describe actions to YES NO

be taken by personnel in response

to fire, explosion or releases to

the environment? [340-104-052(1)]

•

RC1556.A

(4)

Does the plan describe arrangements YES

made with external emergency

response organizations?

[340-104-052(3)]

Does the plan list those qualified YES

to act as emergency coordinator

including their name, address and

phone? [340-104-052(4)]

Is the plan current? YES

Is all emergency equipment YES

available at the facility listed

in the plan?

[340-104-052(4) and 340-104-054]·

(a) Is the location and a descrip- YES

tion of the equipment included?

[340-104-052(5)]

III-7

NO

NO

NO

NO

NO
(b) Are capabilities described for YES

each piece or equipment unit?

[340-104-052(5) ]

NO (J

(5) Does the plan include evacuation YES NO

procedures including a description

of signals to initiate evacuation

(and routes and alternate routes)?

[340-104-052 (6) ]

(6) Is a copy of the plan maintained

at the active facility (vs. main

office)? [340-104-053(1)]

NO

(a) Has a copy been supplied to YES NO

appropriate off-site emergency

response organizations? 'o'1h1ch?

[340-104-053( 2)]

(7) Is at least one designated person YES NO

always available to respond to

emergencies (i.e., of those on the

coordinator list)? (340-104-055]

How are they available? [340-104-055]

Are there limits of this person's YES

authority to respond to emergencies

(i.e., resource commitments)?

[340-104-055]

NO

o

(8) Has an emergency occurred?

Was the plan implemented?

(~f YES, describe incident and

attach if not already reported).

10. Personnel training (OAR 304-104-016)

[340-102-o34(1)(e)]

YES ~lO

NO

a.

b.

Has a training pr~gram been developed? YES

What type? ·(Classroom? On-the-job?)

[340-104-016(1)(a)]

Does the program include contingency ~~

plan and response training?

[340-104-016(1)(b)]

!IO

RC1556 •.'1

c. Does the program include measures to

familiarize personnel with emergency

response equipment, procedures and

systems, including: [340-104-016(1)(c)]

!II-8

o
• (1) Procedures fer using and

maintaining equipment?

[340-104-016(1)(c)(A)]

NO

(2) Key parameters for automatic waste!ES NO

feed cut-off? [340-104-016(1)(o)(B)]

(3) Communications or alarm equipment? YES NO

[340-1 04-016( 1) (c)( C)]

(4) Response to fire and explosion? YES NO

[340-104-016(1)(c)(D)]

(5) Response to groundwater contami- YES NO

nation incidents?

[340-104-016(1)(c)(E)]

(6) Facility shut-down? YES NO

[340-104-016(1)(c)(F)]

d. Are records available at the facility

for the following: [340-104-016(4)]

(1) Job title for each position related YES NO

to hazardous waste management and

maintaining equipment?

[340-104-016(4)(a)]

• (2) Written job description for each

job title? [340-104-016(4)(b)]

YES NO

(a) Does the job description YES NO

include the skill, education

or qualifications required fer

the position?

[340-104-016(4)(b)]

(b) The duties assigned to that YES NO

position? [340-104-016(4)(b)]

(3) A written description of the type YES NO

and amount of training to be given

to those in each job position?

[340-104-016(4)(c)]

(4) A record of training completed or YES NO

experience obtained for each job

position by employee?

[340-104-016(4)(d)]

•

RC1556.A

(5) Was the required training obtained YES

within 6 months of employment by

each individual involved in

hazardous waste management

aotivities? [340-104-016(2)]

III-9

NO
E. Is generator familiar with Generator Reporting Procedures? O. 1- Quarterly ~eports (340-102-041 ] YES NO

a. Fo~ wastes shipped in-state YES NO

b. Fo~ wastes shipped out-or-state rss NO

c. For wastes shipped for beneficial YES NO

use or ~ecycling

.~. Exception ~eports (340-102-042 ] YES NO

3. Spills and discharges to the environment !""'J:.S ~IO

(340-108-020]

4. Comments:

F. Is generator aware of and complying with YES NO ~egulations concerning the preparation of

hazardous waste for transport?

1• Packaging 49 CFR 113, 118, 119 and with YES NO

~equ1rements of state (340-102-030]

2. Labeling 49 CFR 112 (340-102-031] YES NO

3. Marking 49 CFR 112 (340-102-032] rss NO

4. Placarding 49 CFR 112 Subpart F YES NO

(340-102-033 ]

5. Containers of hazardous waste must be marked

with the following, or essentially equivalent,

words and information displayed in accordance

with 49 CFR 112.304 (340-102-032(1)]:

HAZARDOUS WASIE -- Federal law prohibits improper

disposal. I.f found, contact the nearest police or

public safety authority, and the O.S. Enviror~ental

Protection Agency.

Generator I S name and address _

Manifest document no.

(340-102-032(2) ]

6. Comments:

o

G. Are any wastes generated at this facility being Y!S

transported or stored prior to being recycled,

reclaimed or recovered?

NO

If YES, '.rhat are they, .;... _

RCi556.A

1-

2.

3.

4.

SlUdge

Characteristic HW

Listed HW

Comments:

III-l0

(

(

(

o
•

H,\ZARDOUS \·jASiE GEilEFAr ro:J AND r·W:AGEf.1ENT

',·1 as te No.

1. l·/aste name:

2. Hazard classification:

3. Process producing waste:

4. Rate of waste production:

5. Waste handling prior to disposal:

•

6. Waste disposal practice and manifest:

•

7. Reporting arid recordkeeping:

6/82
Facil ity Name _

EPA/Sta te In .::::O~R"",D _

TANKS USZD TO STORE HAZA.1iDOUS 'r'iASTE C_-.-)' [340-102-034(1)(b)J _

a. Is storaga in tanks conducted such that:

[340-104-017(2)(a)J

(1) It does not generate heat, YES NO

pressure, fire, explosion or

violent reaction? (If NO, explai n, )

(2) It does not produce uncontrolled

toxic mists, fumes, dusts or

gases? (If NO, explain.)

[340-104-017(2)(b)J

(3) It does not produce uncontrolled

flammable fumes or gases?

[340-104-017(2)(c)]

::ES

YES

NO

NO

(4) It does not damage the tank? YES NO

[340-104-017(2)(d)J

(5) It does not threaten the environ- YES NO

ment in other ways (i.e., leaks,

spills)? [340-104-017(2)(e)J

Comments: c

b. Is 2 feet of freeboard maintained in

uncovered tanks? [340-102-034(1)(c)J

YES NO

If NO, is secondary contairEent used? YES NO

Explain:

c. Is the tank(s) continuously fed?

If YES, is there a means to stop

inflow? [340-102-034(1)(b)(D)J

Explain:

YES

YES

NO

NO

d. Are inspections of the following conducted:

[340-102-034(1)(b)(E)J

(1) Discharge control equipment? YES NO

How often? [340-102-034(1)(b)(E)(i)]

(2) Waste feed cut-off systems? YES NO

How often? [340-102-034(1)(b)(E)(i)]

RC1556.A

(3) Data from tank monitoring

equipment? How often?

[340-102-034(1)(b)(E)(ii)J

III-11

YES NO

c
•

(4) The level of waste i~ the tank?

How often?

[340-102-034(1)(b)(E)(iii)]

YES NO

(5) The structural integrity of the YES NO

tank? How often?

How are inspections conducted?

What is observed (leoked for)?

[340-102-034(1)(b)(E)(iv)]

(6) The immediate area around the YES NO

tank for signs of leaks and the

integrity of secondary contair~ent

(if any)? [340-102-034(1)(b)(E)(v)]

•

e.

f.

(1) Have any tanks once used for

storage of hazar deus waste been

closed or their function changed?

When? [340-102-034(1)(b)J

(2) Were all hazardous wastes and/or

residues re=oved? [340-104-197J

(3) What was the disposition of the

wastes or residues (i.e., where

did it go)?

(4) When shipped?

Are ignitable or reactive wastes

placed in tanks? [340-104-198J

YES

YES

YES

NO

NO

NO

g.

h.

If YES, what measures are used to prevent

ignition or reaction? [340-104-198]

Have wastes been placed in a tank YES

which previously contained potentially

incompatible waste or residue?

[340-104-199J

(1) If reactive or ignitable wastes YES

are stored in covered tanks, are

they in compliance with the National

Fire Protection Association's buffer

zone requirements? [340-104-198(2)J

NO

NO

•

RC1556.A

(2) Are "No Smoking" signs posted?

(3) Have other measures been adopted

to reduce hazards associated with

storage of ignitable or reactive

waste in tanks? [340-104-017(2)

and 340-104-198(1)(b)J

Explain:

III-12

YES

YES

NO

NO
Faci~itj Name

•

SPA/State ID ORD

IV. Treatment. Storage and Disposal (ISD) 1"acilities OAR 31.10 Pi-"1sion 104

A. Type of Activitv

1. Storage

a. Containers

b. Tanks

(1) Above ground (

( 2) Below ground (

c. Surface impoundments (

d. WaBte piles (

e. Other (

2. Treatment

a. Settling ( )

b. Evaporation ( )

c. Filtration ( )

d. Energy recovery ( )

e. Incineration ( )

f. Thermal treatment ( )

g. Recycling/recovery ( )

h. Chem/phys/biological ( )

i • Other ( )

• 3. Disposal

a. Landfill ( )

b. Land treatment ( )

c. Surface impoundment ( )

d. Incineration ( )

e. Other ( )

4. Comments:

s. Are hazardous waBtes accepted from YES NO

"outside" (off-site) sources (wastes not

generated on-site)?

a. If YES, has a chemical and physical YES NO

analysis of a representative sample

been obtained in accordance with OAR

340-104-013?

b. Does the facility confirm that each YES NO

hazardous waste received at the

facility matches the identity of the

waste on the manifest?

• c • How does the facility determine this?

RC15S6.B IV-1
B. Subdivision 3 -- General Facil+ty Standards.rQAR ~UQ-1QU-QJQ

through 3UQ- 1QU- Ql 1 ) o

1.

2.

Does the facility obtain a detailed

analysis of his waste prior to storing,

treating or disposing of it?

Describe:

Does the facility follow a written waste

analUis plan?

Does the plan include?

NO

NO

a.

b.

c.

d.

Parameters to be tested? YES

Methods of analysis? YES

Methods to get representative samples? YES

Testing frequencies? YES

NO

NO

NO

NO

Comments:

3. Did inspector collect a copy of the plan YES NO

for a thorough review of it at DEQ offices?

4. Security

Have site owner/operators taken appropriate!ES NO

measures to ensure against unauthorized entry?

a.

b.

c.

Are signs posted at each entrance to YES

active portion, and at other locations,

in sufficient ~bers to be seen by

any approach?

Are they legible from a distance of YES

25 feet or more?

Does the facility have a 24-bour YES

surveillance system or artificial or

natural barrier, or combination of

both, to control access to the active

portion?

Comments:

~10

NO

NO

o

5. Does the facility follow a written

inspegtion sghedule (OAR 340-104-015)?

a. Does it include inspecting all:

NO

(1) Monitoring equipment?

(2) Safety and emergency equipment?

(3) Security devices?

(4) Detecting equipment?

(S) Dangerous waste storage areas?

NO

NO

NO

NO

NO

RC~S56.3

b. Is this inspection schedule maintained YES

at the facility?

rT-2

NO

u
• c. Is an inspection log maintained? YES

(i) Is the log, or its summary, kept YES

at the facility for at least three

years from the date of inspection?

(2) Does the log include:

NO

NO

(a) Date and time of inspection?

(b) Inspector's name?

(c) Observations?

(d) Date and nature of repairs?

YES

YES

YES

YES

NO

NO

NO

NO

Comments:

6. Personnel Training (OAR 340-104-016)

•

a.

b.

c.

Has a training program been developed? YES

What type? (Classroom? On-the-job?)

Does the program include contingency YES

plan and response training?

Does the program include measures to

familiarize personnel with ecergency

response equipment, procedures and

systems, including?

NO

NO

•

RC1556.B

(1) Procedures fer using and YES NO

maintaining eqUipment?

(2) Key parameters for autocatic waste YES NO

feed cut-off?

(3) Communications or alarm equipment? YES NO

(4) Response to fire and explosion? YES NO

(5) Response to groundwater contami- YES NO

nation incidents?

(6) Facility shut-down? YES NO

d. Are records available at the facility

for the following:

(1) Job title for each position related YES NO

to hazardous waste management and

maintaining equipment?

IV-3
(a) Does the job description YES NO

include the skill, education

or qualifications required ror

the position?

(2) Written job description ror each

Job title?

YES NO

C)

RC1556.3

(b) The duties assigned to that YES NO

position?

(3) A written description of the type YES NO

and amount or training to be given

to those in each job position?

(4) A record of training completed or YES NO

experience obtained for each job

position by employee?

(5) Wa3 the required training obtained YES NO

within 6 months of employment or

by May 19, 1981, by each individual

involved in hazardous Wa3te

management activities?

G

o
Subdivision C -- Procedures and Prevention (OAR 34Q-104-030

through 340-1Q4-Q37) •

c.

2.

Is facility maintained and operated to

minimize the hazards of fire, explosion,

and sudden or non-sudden releases to the

environment? Explain:

Is internal emergency communication

equipment or alarm systems installed?

What type?

YES NO

NO

Is a device (e.g., telephone) immediately YES

available for summoning emergency assistance?

NO

•

•

RC1556.B

4.

5.

6.

7.

8.

Are fire extinguishers or other emergency

equipment immediately available on-site?

Is emergency communications and response

equipment tested? How often?

Is aisle space adequate for emergency

response? What is aisle spacing?

Have any arrangements been made with local

emergency response organizations?

Which organizations?

If local organizations have declined to

enter into response agreements, is this

documented in the facility's operating

record? Explain:

IV-5

YES

YES

YES

YES

YES

NO

NO

NO

NO

NO
D. Subdivision p -- Contingency Plan and Emergengv

(OAR 3UO-JOU-Q50 through ~UO-1QU-Q56)

J. Has contingency plan been developed?

(It may be a modified SPCC plan.)

Orgcedures

NO

2.

3.

Have incidents occurred where the plan

has been implemented?

Have incidents occurred where the plan

should nave been implemented but was not'1

Explain:

NO

NO

~. A copy of the plan should either be obtained

for post-inspection office review or it

should be examined during inspection for the

following:

a.

b.

Does the plan describe actions to

be taken by personnel in response to

fire, explosion or releases to the

environment?

Does the plan describe arrangements

made with external emergency response

organizations?

YES

NO

llO

c.

d.

Does the plan list those qualified to YES

act as emergency coordinator inclUding

their name, address and phone?

Is the list current?

Is all emergency equipment aVailable

at the facility listed in the plan?

NO

NO

NO

o

(1) Is the location and a description

of the equipment inclUded?

(2) Are capabilities described for

each piece or equipment unit?

YES

YES

NO

NO

RCi556.3

e.

f.

Does the plan include evacuation YES

procedures including a description of

signals to initiate evacuation (and

routes and alternate routes)?

Is a copy of the plan maintained at YES

the active facility (vs. main office)?

(1) Has a copy been supplied to

appropriate off-site emergency

response organizations? Which?

I:V-6

NO

NO

NO
•

5. Is at least one designated person always

available to respond to emergencies (i.e.,

of those on the coordinator list)?

How are they available?

NO

6. What are the limits of this person's authority

to respond to emergencies?

a.

b.

Has an emergency occurred?

Was the plan implemented?

NO

NO

•

•

RC1556.B

c. Describe the incident:

IV-7
Subdivision E -- Manifest Svstem. Becordkeeoing and

(OAR 3UO-10U-070 through 3UO-10U-077)

1. Manifest System

Reporting

a. Upon receipt of a manifested hazardous YES

waste shipment, does the TSD facility:

NO

(1) Sign and date each copy of ~-S NO

manifest receipt of certifying

waste?

(2) Note any discrepancies on eacb YES NO

copy?

(3) Give delivering transporter one YES NO

signed and dated copy of the

manifest?

(4) Send a SID copy of the manifest to YES NO

the generator within 30 days

after delivery?

(5) Retain a copy of each manifest at YES NO

the facility for 3 years from

delivery?

b. If the TSD facility initiates a YES

hazardous waste shipment, does it

comply with generator requirements in

OAR 340 Division 1021

NO

c

RC15S6.B

c. Does the TSD facility examine manifests

and wastes received to detect any

significant discrepancies in quantity

or type of waste, such as:

(1) Bulk waste -- quantity variation

of 10 percent or greater

(2) Batch waste -- any variation in

piece count

(3) Waste type -- obvious differences

discernible by inspection or

waste analysis

d. If significant discrepancies are found,

does the TSD facility:

(1) Reconcile discrepancies with

generator or transporter within

15 days? -orIV-a

NO

NO

NO

NO

o
•

(2) Immediately submit to DEQ a YES

disorepancyreport describing the

disorepancy and attempts to resolve

it and a copy of the manifest

involved?

e. TSO facilities must keep a written

operating record documenting the

following details:

(1) Waste description and quantity

reoeived

(2) Methods and dates of its treatment,

storage and disposal

(3) The looation and quantity of each

HW at the facility

2. Operating Reoord

NO

a. Does the owner/operator of the

facility maintain an operating record

at the facility (OAR 340-104-073)?

NO

•

b. Does the record contain the following

information:

(1) A description of and the quantity

of each HW reoeived, and the

methodes) and date(s) of its

treatment, storage or disposal

at the facHi ty?

NO

(2) The location of each HW within YES NO

the facility and its quantity?

(3) A map showing disposal sites? YES NO

(4) Summary reports and details of all YES NO

incidents that require implementing

the contingency plan?

(5) Records and results of inspections YES NO

as required (need only be kept

three years)?

(6) All closure and post-closure cost YES NO

estimates required for the facility?

•

RC1S56.B

(7) The results of testing and waste

analysis?

IV-9

YES NO
3. racility Reporting Procedures

RC1556.B

a.

b.

c.

Has the owner/operator prepared a~d ~-S

submitted a single copy of the quarterly

report to the Department?

Is owner/operator familiar with

procedures for emergencies?

If a TSD facility accepts a regulated

hazardous waste shipment without the

req~red manifest or shipping paper,

does it file an WUnmanifested Waste

Report n within 15 days of receipt?

rv-ro

NO

~10

80

o

o

o
311 0- 1011 - 10 1 )

Subdi-,ision F Groundwater Monitoring (OAR 3uO- l 04- 090 through

•

F.

1. Are groundwater (GW) monitoring regulations YES

required at this facility?

NO

2. If YES, what is the relevant process unit?

a.

b.

c.

d.

e.

Surface impoundment

Waste pile

Land treatment

Landfills

Other

Describe:

( )

( )

( )

( )

( )

3. Has the owner/operator implemented a

groundwater. monitoring plan?

YES NO

4. If NO, has the facility implemented one of the following:

5. Does the GW monitoring program consist of the following:

•

a.

b.

c.

d.

a.

b.

c.

d.

e.

f.

g.

h.

i.

j.

GW waiver

Alternate GW monitoring system

Neutralization waiver

Other

Describe:

At least 1 upgradient and 3 downgradient wells

GW sampling and analysis plan

GW sampling quarterly first year

GW sampling semiannually after that

Drinking water standards parameters

Sampling frequency ___

GW quality parameters

Sampling frequency ___

GW indicator parameters

Sampling frequency ___

GW elevation parameters

Outline GW quality assessment program

Statistical analysis of indicator

parameters

Results:

YES

YES

YES

YES

YES

YES

YES

YES

YES

YES

(

(

(

(

NO

NO

NO

NO

NO

NO

NO

NO

NO

NO

•

RC1556.B

6. Has the facility implemented GW quality

assessment program?

a. Date, _

b. Results:

IV-l1

YES
7. Does the facility mai.ntain the necessary

roecords C) a. Initial background parameter concen- rss NO

trations?

b. SUbsequent parameters concentrations? YES NO

c. Statistical evaluation? rss NO

8. Has the facility roeported necessary

int'ormation

a. DW standards for first year YES NO

b. GW indicator parameters annually YES NO

c. Statistical evaluation YES NO

9. Comments:

o

RC1556.3 IV'-12 o
•

G. Subdivision G -- Closure and Post-Closure (OAR 340-104-110

through 340-104-12Q)

Closure

1. Has the facility developed a closure plan

which outlines all necessary steps to

safely close the facility?

a. Description of how and when the

facility will be partially closed

(if applicable) and finally closed?

YES NO

b. Estimate of the maximum inventory of YES

wastes in storage and in treatment at any

time during the life of the facility?

NO

c. Description of the steps needed to

decontaminate the facility equipment

during closure?

YES NO

•

d. Comment:

Post-Closure

2. Has the facility developed a post-closure plan

which contains the following steps to safely

care for the facility after closure/post-closure

of the facility? (OAR 340-104-117)

•

RC1556.3

a. Description of how post-closure will

be carried out for the next 30 years?

b. .Notice to the local land authority

within 90 days after closure is

completed?

c. Notice in deed to property?

IV-13

YES

YES

NO

NO
H. Subdivision H -- Financial Requirements rOAR ~I1Q-1QI1_1I1Q

through 3 c; 11 0- 1011- 151 )

1- Liability

a. (1) Does facility ca1ntain liability YES NO

insurance for sudden occurrences

in the a=ount of at least $1 million

per occurrence with an annual

aggregate of at least $2 million?

( 2) By what Method did the owner/operator

demonstrate sudden liability coverages?

(a) HW facility liability endorseMent(s) (

('0) HW facility certificate(s) of (

liability insurance

(0) Financial test (

(d) Corporate guarantee (

(e) Multiple MechaniSMs (specify) (

b. (1) If a surface iMpoundMent, landfill YES NO

or land treatMent exists at the

facility, does facility maintain

l1ability insurance for non-sudden

occurrences in the amount of at least

$3 million per occurrence with an

annual aggregate of at least $6 1II1l11on?

(2) By what Method did the owner/operator 0

demonstrate non-sudden liability coverages?

(a) BW facility liability endorsement(s)

(b) HW facility certificate(s) of

liability insurance

(0) Financial test )

(d) Corporate guarantee ( )

(e) Multiple mechaniSMs (specify) ( )

o. Has owner/operator submitted an YES NO

originally signed duplicate of liability

coverage demonstration?

d. I3 wording 0 f l1ability coverage YES

instruments identical to that specified

in OAR 340-104-151?

NO

RCi556.3

Comment:

IV-14
• 2 • Assurance

a. Closure

(1) Has facility prepared a written YES NO

estimate of the cost of closing the

facility in accordance with the

closure plan (OAR 340-104-112)?

(2) Has this cost estimate been YES NO

adjusted annually for inflation?

(3) Has facility established financial YES NO

assurance for the closure of the

facility (OAR 340-104-143)?

(4) By what method has this been achieved:

(a) Trust fund ( )

(b) Surety bond (with standby trust) ( )

(c) Letter of credit (with standby trust) ( )

(d) Insurance ( )

(e) Financial test ( )

( f) Corporate guarantee ( )

(g) Multiple mechanisms ( )

• ( 5) Has facility submitted an YES NO

originally signed duplicate of

financial assurance?

(6 ) Is wording of the financial YES NO

assurance statement identical to

that specified in OAR 340-104-1511

(7) Comment:

b. Post-Closure (Disposal Facilities)

(1) Has facility prepared a written YES NO

estimate of the cost of post-closure

monitoring and maintenance of the

facility (OAR 340-104-144)?

( 2) Has this cost estimate been YES NO

adjusted annually for inflation?

(3) Has facility established financial '[1='-3 NO

assurance for the post-closure care

of the facility (OAR 340-104-145)?

•

RCi556.B rv-rs
(4) By what method has this been achieved:

(a) Trust fund ( ) 0

(b) Surety bond (with standby trust) ( )

(0) Letter of oredit (with standby trust) ( )

(d) Insurance e )

(e) Financial test e )

et') Corporate guarantee e )

(g) Multiple mechanisms e )

( 5) Has owner/operator submitted an YES NO

originally signed duplicate of

financial assurance?

(6 ) Is wording of the financial YES NO

assurance statement identioal to

that specified in OAR 340-104-1511

(7) Comment:

o

o

IV-16
•

I. Subdivision I -- Use and Management of Containers

(OAR ~4Q-1Q4-17Q through ~llQ-1Q4-178)

Does this section apply to this facility? YES NO

2.

3.

4.

s.

Are the containers made of or lined with YES

materials which will not react with and

are compatible with the hazardous waste to

be stored in them7

Are the containers always closed, exqept YES

to add or remove waste?

Are container storage areas inspected YES

weekly for leaks and container deterioration

(OAR 340-104-174)7

Are precautions taken to prevent accidental YES

ignition or reaction of ignitable or

reactive waste?

NO

NO

NO

NO

7. Is the facility aware of and complying with the

following requirements for incompatible wastes:

Are containers holding ignitable or YES

reactive waste located at least 50 feet

from the facility's property line?

•

6.

a. Incompatible wastes must not be YES

placed in the same container, unless in

compliance with OAR 340-104-017(2).

NO

NO

b. HW must not be placed in an unwashed

container that previously held an

incompatible waste.

YES NO

c. Are storage containers holding HW r:-...s

that are incompatible with any waste

or other material stored nearby separated

from or protected from them by means of

a dike, berm, wall or other device?

Explain:

NO

8. Are containers marked or labeled in a

manner equivalent to 49 CFR 172?

YES NO

•

RC1556.B

9• Comments:

IV-17
J. Subdivision J -- Tanks (OAR 3~Q-1Q4-1aQ thrgugh ~~Q-1Q~-1aa)

2.

Does this section apply to this facility?

Do tanks on the faclli ty hold hazardous

waste?

If YES, what are their contents? _

NO

NO

o

3. Is storage in tank3 conducted such that:

Comments:

Is 2 feet of freeboard ll1a1ntained in

uncovered tanks?

4.

a.

b.

c.

d.

e.

It does not generate heat, pressure,

fire, explosion or violent reaction?

(If NO, explain.)

It does not produce uncontrolled

toxic usts, f'umes, dusts or gases?

(If NO, explain.)

It does not produce uncontrolled

flammable fumes or gases?

It does not damage the tank?

It does not threaten the environment

in other ways (i.e., leaks, spills)?

YES

NO

NO

NO

NO

NO

NO o

5.

6.

If NO, is secondary contair.ment used?

Explain:

Is the tank(s) continuously fed?

If YES, is there a means to stop inflow?

Explain:

Are hazardous waste storage tanks operated YES

in a manner which minimizes the possibility

of overfUling? How:

Waste feed cut-off

Bypass system to another tank

High-level alarm Other _

(

(

(

NO

NO

NO

NO

1. Are inspections of the following conducted:

RC1556.3

a. Discharge control equipment?

How often?

!V-18

NO

o
•

b.

c.

d.

e.

f.

Waste feed cut-cff systems?

P.ow often?

Data from tank monitoring equipment?

How often?

The level of waste in the tank?

How often'?

The structural integrity of the tank?

How often?

How are inspections conducted?

What is observed (looked for)?

The immediate area around the tank

for signs of leaks and the integrity

of secondary containment (if any)?

YES

YES

YES

YES

YES

NO

NO

NO

NO

NO

8. Have any tanks once used for storage of

hazardous waste been closed or their

function changed? When?

YES NO

b. What was the disposition of the wastes

or residues (i.e., where did it go)?

•

a.

c.

Were all hazardous wastes and/or

residues removed?

When shipped?

YES NO

9. Are ignitable or reactive wastes placed in

tanks?

If YES, what measures are used to prevent

ignition or reaction?

YES NO

•

RC1556.B

10.

11 •

12.

13.

Have wastes been placed in a tank which YES

previously contained potentially

incompatible waste or residue?

If reactive or ignitable wastes are stored YES

in covered tanks, are they in compliance

with the National Fire Protection

Association's buffer zone requirements?

ArenNo Smoking" signs posted? YES

Have other measures been adopted to reduce YES

hazards associated with storage of ignitable

or reactive waste in tanks?

Explain:

IV-19

NO

NO

NO

NO
14.

15.

Waste Analysis and Trial Tests

Before treating and storing of hazardous YES

waste in a tank, 1s a detailed chemical

and physical analysis of the waste obtained?

Does the company have and follow a ~ritten

waste analysis plan?

NO

NO

a.

b.

Does the plan identify parameters U3ed? YES

Explain:

Sampling method? YES

Explain:

NO

NO

c. How frequently is analysis repeated?

d. Are resul ts of waste analysis and

trial tests placed in the facility's

operating record?

NO

· itC1556.3

16. Are waste analyses done when a tank is U3ed YES

to treat or store a aw which is substantially

different or treated differently from waste

previoWlly treated or stored in the tank?

I7-20

NO

o

o
Subdivision K -- Surface Impoundments (OAR ~40-104_22Q through

140-104-230) •

K•

1.

2.

3.

4.

5.

Does this section apply to this facility? YES

Does the surface impoundment maintain YES

enough freeboard to prevent any overtopping

of the dike by overfilling, wave action or

a storm?

Are the surface impoundments designed and YES

operated to allow 2 feet of freeboard?

Do earthen dikes have a protective cover YES

which minimizes erosion (grass, rock, shale)?

Is a waste analysis or trial test conducted YES

whenever a surface impoundment is used to

chemically treat a HW which is substantially

different or treated differently from waste

previously treated or stored in the surface

impoundment?

NO

NO

NO

NO

NO

Are results of waste analyses documented YES

in the facility's operating record?

•

6.

1•

8.

Are the surface impoundments inspected on

a routine basis? How often?

Are ignitable or reactive wastes held in

a surface impoundment (OAR 340-104-229)?

YES

YES

NO

NO

NO

•

RC1556.B

9. Comments:

IV-21
•

•

•

APPENDIX I
9TATE OF OREGON

DEPARTMENT OF ENVIRONMENTAL QUALIIY INTEROFFICE MEMO

APPE~mIX I

Richard Reiter, Supervisor

Hazardous Haste Operations

TO: Fred Bolton, Reg.

John Borden, WVR

Gary Grimes, SHR

Dick Nichols, CR

Steve Gardels

FROM:

Opr-s , & m'1R DATE: May 31, 1984

In order to maintain the schedule, it is important that we adhere to the

times shown. While the speakers will plan to leave time for questions, it

is unlikely all questions will be answered in the time shown. Therefore, I

would recommend that you bring your questions in writing, ask them if time

is available, otherwise leave them with us and we'll get back with an early

written response (circulated to all participants).

SUBJECT: Training-Session

Hazardous Waste Rules

June 6 & 7, 1984

On May 7, 1984, a memo was circulated

training session on June 6 & 7, 1984.

Agenda. The training will be held in

522 s.w. 5th, Portland). To keep the

extremely ambitious schedule has been

announcing a hazardous waste rules

Attachment I contains a Final

DEQ's conference room (Room 1400,

number of days to a minimum, an

arranged.

If you have any general questions before the session, please call

Fred Bolton or me.

RPR:b

ZB3469

cc: Fred Hansen, Office of the Director

Stan Biles &Staff, Public Affairs

Al Hose & Staff, DEQ Lab

Robb Haskins, Department of Justice

Paul Henry & Barbara Rowland, Public Utility Commission

Ernest Schmidt, Administrator, Solid Waste Division

Harold Sawyer, Water Quality Division

Tom Bispham, Air Quality Division

Richard Reiter &Staff, Hazardous Waste Operations

Ken Feigner, EPA - Region 10 - Seattle

Al Goodman, EPA - 000

Kristine Rogers, Assistant U.S. Attorney
•

FINAL AGENDA

Wednesday, June 6. 1984

Attachment I

•

1: 00 - 1: 30

1: 30 - 2: 00

2:00 - 2:30

2:30 - 3:00

3: 00 - 3: 15

3:15 - 5:00

5:00 - 7:00

7:00 - 9:00

Director's Comments

EPA Region 10's

Expectations & Oversight

Principles of Criminal

Investigation

Definitions & Petitions

Division 100

- BREAK -

Waste Classification

Division 100

- DINNER - (will be provided)

Transporters and

DOT Proper Shipping Name

(Division 103)

Fred Hansen

Ken Feigner, Chief

Waste Management Branch

Kristine Rogers,

Assistant U.S. Attorney

Fred Bromfeld

Fred Bromfeld

Fred Bolton/

Ernest Schmidt

Dale Smith,

PUC

Thursday. June 7. 1984

•

8:00 - 9:00

9: 00 - 10: 00

10: 00 - 10 : 15

10:15 - 11:15

11 : 15 - 12: 00

12: 00 - 1: 00

Generators & Beneficial Use

(Division 102)

TSD Facilities

(Division 104)

- BREAK -

Permit Application & Permit

Processing

(Division 105 and 106)

Spills

(Division 108)

- LUNCH - (will be provided)

Steve Sander

Bill Hartford

Richard Rei ter

Ed Chiong

Fred Bolton/

Ernest Schmidt
HAZARDOUS WASTE TRAINING

"LEARNING BY DOING"

Dates: January 30 & 31, 1985

Time: 1:30 p.m.-5:00 p.m., 1-30-85

9:30 a.m.-4:30 p.m., 1-31-85

Place: Room 1400

Subject

January 30, 1985

Presenter

1:30-5:00 p.m.

January 31, 1985

9:30-10:30 a.m.

10:30-12:00 a.m.

Management of Cyanide Bearing

Waste as it Relates to Mining

Short SUbjects

o gO-day Storage &

30-day Extensions

o Manifest Violations

o Ground Water Monitoring

o Real Property Owners

Beneficial Use

Case Study

Steve Gardels

Dennis Belsky

Gary Calaba

Gary Calaba

Janet Gillaspie

Greg Baesler

Gary Calaba

Greg Baesler o

12:00-12:30 p.m. - LUNCH -

12:30-2:00 p.m.

2:00-2:45 p.m.

2:45-3:30 p.m.

3:30-4:00 p.m.

4:00-4:30 p.m.

RPR:b

2B4170

Closure Requirements

Case Study

Spill Rules

Case Study

Sap-Stain (anti-stain)

Waste Management Program

Best Management Practices

Resources, Commitments &

RCRA Reauthorization

Final Authorization &

Program Strategy

Richard Reiter

Charles Clinton

Richard Reiter

Rene Dulay

Richard Reiter

Richard Reiter

Fred Hansen

()
•

•

•

8:30-9:30

9:30-10:00

10:00-10:30

10:30-10:!15

10:45-11:00

11:00-noon

Uoon-12:30

12:30-1:30

1:30-2:00

2:00-2:30

2:30-3:00

3:00-1.1:00

RC2133

HAZARDOUS HASTE TI\AINmG

Thur-sday , April 18, Ig '5S

P.oom 'I}~ 00 - DEQ

HOH to RevieH Conti ngency Pl.ana,

Preparedness and Personnel Plans

Revietv of checklist

trIor!e through Hacker plans

Sampling of Hazardous Wastes

Review of EPA course highlights

Spill Cleanup

t'ihat tV'e learned in the Hacl:er

situation

Other issues (manifests, ID no.)

Break

Safety Equipment and Gear

Review of Beneficial Use

3M example

Questions

Small quantity reuse/recycle

Lunch

Generator/TSD Distinction

Documenting the violations

Writing the NOV (need example)

Areas of Improvement

EPA mid-year review audit

1. Pictures

2. Narrative for violations

Bioassays

Superfund/Past Practices

Policy

Example: Gould Battery

HCRA Reauthorization Issues

Steve sancer

Greg Pettit

JAGillaspie

Gary Calaba

Greg Baesler

Sue Payseno

Dennis Belsky

All

Gary Calaba

Rich Reiter

Gary Calaba

Gerry Bell

Rich Reiter

Rich Reiter
__________--........--=os=..-..-..,=-.~.-__. =

HAZARDOUS WASTE TRAINING

Thursday, July 18, 1985

Room 1400 -- DEQ

o

9:00 a.m. to 10:00 a.m. Final Authorization - RCRA

EPA Relationship

Mike Downs

10:00 a.m. to 10:30 a.m. Legislative Overview - 1985 Session

Hazardous Naste

Rich Reiter

10:30 a.m. to 10:45 a.m. Break

10:45 a.m. to 11:15 a.m. Recycling Rules

11:15 a.m. to 11:45 a.m. Small Quantity Generator Requirements

and Other RCRA Amendments

Al Goodman

~,

Dave Hamline

EPA

11:45 a.m. to 12:45 p.m. Lunch (will be brought in for participants)

12:45 p.m. to 1:15 p.m. Current Happenings - Joseph Forest Products

Enforcement-Bankruptcy Issues

Brett McKnight

Larry ewik

Madras Airport (Disposal of pesticide Gary calaba

residues)

1:45 p.m. to 2:15 p.m. PCP Update - Special Dioxin Study by EPA/DEQ Larry Patterson 0

1:15 p.m. to 1:45 p.m.

2:15 p.m. to 2:45 p.m. Enforcement Van Ko11ias

2:45 p.m. to 3:00 p.m. Break

3:00 p.m. to 3:30 p.m. Safety Equipment Greg Baesler

Sue Payseno

3:30 p.m. to 4:00 p.m. Compliance Inspections - EPA Oversight Gary Calaba

[End of Session]

()
•

•

•

APPENDIX J
•

APPENDIX J

Extramural

Hazardous Waste Training

Attended by DEQ Staff

January 1984 - July 1985

•

•

Training

Expert Witness in Litigations

Hazardous Materials in

Transportation Incidents

Chemistry of Hazardous

Materials

Designt Installation and

Sampling of Groundwater

Monitoring Wells

Procedures for Shipping

Hazardous Waste for Disposal

RCRA Inspection Workshop

Sampling Procedures &

Protocol

Soil Sampling QA

Well Drilling Training

Closure of Hazardous

Waste Facilities

Groundwater Contamination

by Organic Compounds

Hazardous Waste Sampling

Site Inspection Training

Hazardous Waste Enforcement

Workshop

Inspector/Investigator

Training

AL:b

ZB4968

Dates

6/12/84

4/17/84

5/7-18/84

3/19-21/84

9/20/84

12/12/84

12/7/84

12/14/84

12/3-6/84

11/7-9/84

2/6/85

3/5-7/85

6/24-27/85

6/27-28/85

7/10-11 /85

Sponsor

EPA

Multnomah County

Multnomah County

National Water Well

Association

Washington Department

of Ecology

EPA

EPA

EPA

EPA

EPA

Oregon Graduate

Center

EPA

EPA

Environmental Law

Institute

EPA
•

•

•

APPENDIX K
•

•

•

ZB4956

APPENDIX K

ENFORCEMENT GUIDELINES AND PROCEDUR~

HAZARDOUS WASTE PROGRAM

DEPARTMENT OF ENVIRONMENTAL QUALITY

SEPTEMBER 1985
ZB4956.2

EHFORCEMEBT GUIDELINES AND PROCEDURES

HAZARDOUS WASTE PROGRAM

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

NOVEMBER 1985

-1-
TABLE OF CONTENTS

Section

1- Introduction

2. General Principles

3. Violation Categories

4. Timely and Appropriate

Enforcement Response

5. Types and Descriptions

of Enforcement Responses

6. Priorities

7. Assessment of Administrative

Civil Penalties

Appenaix I. Calculating the Economic

Benefit from Noncompliance

Appenaix II. Examples of Classification of

Hazardous Waste Violations

o

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3

4

5

6

0

10

13

13

23

24

ZB4956.2 -2-
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 to 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 practices. The Department may

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

and rules, that is deemed appropriate or necessary.

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.

o

2. Responsibility for compliance rests with those persons conducting

actiVities covered by these statutes and rules and with permits

and orders issued pursuant thereto. o

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 documented 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;

results in the failure to assure that groundwater will be

protected or that proper closure and post-closure actiVities

will be undertaken; or

involves the failure to establish and maintain financial

assurance mechanisms

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 damage; 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 classification

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 evaluated 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 tne date of violation discovery, this shall be interpreted as the date

that the 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

Appropriate Enforcement Response: 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, ~nstallation of surface impoundment liner, etc.), DEQ may

issue an Order in lieu of the Notice of Intent.

If Department staff have reason to believe that 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 enforcement

action.

o

o

ZB4956.2 -6-
• Enforcement Action Time

a. Civil Penalty Assessment 45 days after violation

discovery.

b. Notice of Intent 45 days at'ter violation

discovery.

o. DEQ order 45 days after violation

discovery.

d. Referral to Department of 45 days after violation

Justice for court action discovery.

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 Manager.

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 oases where correction of Class 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.

o. DEQ order 90 days after 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 -1-
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:

o

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 resolved

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 Response

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.

c

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 .is 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-

()
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 timefr~es.

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

Time'

30 days

45 days

60 days

90 days

. i

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 w~th 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 I~

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.

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

ZB4956.2 -9-
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 compliance 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 the 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 Department approval. 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 D~partment within 14 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.

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ZB4956.2 -10-
In determining the amount of a civil penalty, 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 wi~l be assessed against persons with 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 violator 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 issued 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 referral 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.

ZB4950.2 -11-
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 investigation to determine if

the operation of any generator, transporte~ or hazardous waste management

facility 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

civil 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 Department 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 pursuant 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 p~tential

criminal actions to EPA for investigation.

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ZB4956.2 -12-
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 compelled; (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 Violat~ons, 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.

RelatioDship to Statutory and Regulatory Provisions

These guidelines do not substitute for consideration of existing provisions

in Oregon Revised Statutes (ORS) and Oregon Administrative 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 liability 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.

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ZB4956.2 -14-
Summary ot Penalty Determination

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

be thought ot 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 ot 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 violator 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(l)(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 history 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 aCCident, or

negligence, or an inten~ional 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 receives

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 ot the Gravity-Based Penaltl

In determining the gravity-based component of a civil penalty, the

following aspects of a violation are considered:

o Potential tor harm; and

o Extent of deviation from a statutory or regulatory requirement.

Potential tor 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 MODERATE - The violation poses a moderate adverse effect on

public health or the environment.

o MINOR - The violation poses a minor adverse effect on public

health or the environment.

Extent ot 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.

G

()

ZB4956.2 -16-
Gravity-Baaed 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 ot Deviation from Requirement

Potential

.!:2r.

l!!!:!!

MAJOR MODERATE MINOR

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

3.200 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 element of proof not needed by the others. In many cases,

Violations ot 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-
It is also possible that different 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 moving 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 violations 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 complaint, but one penalty,

rather than 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.

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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

failure to comply With the requirements. The violator eventually will have

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

equivalent of capital costs. 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 monitoring

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.

ZB4956.2 -19-
Because the savings that are derived from delayed costs differ from those

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

costs are calculated in a different manner. Guidance on calculating

delayed and avoided costs ts 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 the 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) identifies 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 maximum 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 coming into

compliance without demonstrated promptness.

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

There may be instances of culpability for nknowing n Violations which do not

meet the criteria for criminal action. In cases where 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.

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ZB495b.2 -20-
/

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 tpe 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:

o How similar the previous violation was;

o How recent the previous violation was;

o The number of previous violations;

o 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 complianc~ 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 st~aight 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.

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ZE4956.2 -~-
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.

G

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 and 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 monitoring 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 and

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

I

I

I

c

ZB4956.2 -24-
Example

Failure of a post-closure'plan to 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

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

waste.

Failure to use a manifest for off-site shipments of

hazardous waste.

Failure to designate on the manifest an authorized

storage, treatment, disposal or reclamation facility.

Exceeding the designated time limit for on-site

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

Waste" or with the accumulation date.

Failure to comply with the preparedness and prevention

requirements of Subpart C of 40 CFR Part 265.

Storage of wastes in containers that are not in good

condition or have begun to leak.

Failure to submit a manifest exception report.

II

II

II

II

II

II

II

II

ZB4956.2 -25-
Example

Violation

Class c

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 complete 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 facllity •

Failure to provide required notice to DEQ of foreign

shipments of waste.

. "'......,,~- \.

/"'" -. <> . ....~._... . ', \

" .." :.:" '... \ ....... )

.c·'" .:; J

"..

III

III

..:-~..'

ZB4956.2 -26-
•

f

•

•

APPENDIX L
•

•

'.

Proposed Amendment to

OAR 340-12-040

Notice of Violation

340-12-040 (1) Except as provided in [sub]section (3) of this [section]

~, prior to the assessment of any civil penalty the Department shall

serve a Notice of Violation upon the respondent. Service shall be in

accorda~ce with rule 340-11-097.

(2) A Notice of Violation shall be in writing, specify the violation and

state that the Department will assess a civil penalty if the violation

continues or occurs after five days following receipt of the notice.

(3)(a) A Notice of Violation shall not be required where the respondent

has otherwise received actual notice of the violation not less than five

days prior to the violation for which a penalty is assessed.

(b) No advance notice, written or actual shall be required [where]

under sections (1) and (2) of this rule if:

(A) The act or omission constituting the violation is intentional;

(B) The violation consists of disposing of solid waste [hazardous waste]

or sewage at an unauthorized disposal site;

(C) The violation consists of constructing a sewage disposal system

~ithout the Departmentrs permit;

ZE4967 (8/85)

APPE~mIX I.
•

•

•

(D) The water pollution, air pollution, or air contamination source would

normally not be in existence for five days; [or]

(E) The water pollution, air pollution or air contamination source might

leave or be removed from th~ jurisdication of the Department[.J~

(F) The penalty to be imposed is for a violation of PHS 459.410 to 459.450

and 459.460 to 459.690. or rules adopted or Qrders or permits issued

pursuant thereto.

ZE4967 (8/85)
•

August 28

September 4

SCHEDULE FOR ENFORCEMENT RULE AMENDMENT

OAR 340-12-040

Agenda Title Due

Staff Report Due

September 9-10

September 20

September 27 (Bend)

October 1

• October 16

October 23

October 30

November 4-5

November 22 (Eugene)

ZB4991

•

Staff Report Review

Secretary of State Receipt of Public Notice

EQC Meeting - Authorize Public Hearing

Mail Public Notice to Mailing List

Secretary of State Bulletin

Public Hearing

Agenda Title Due

Staff Report Due

Staff Report Review

EQC Meeting - Adopt Rule