811 SW SIXTH AVENUE, PORTLAND, OREGON 97204-1390

Department ofEnvironmental Quality

• NEIL GOLDSCHMIDT

GOVERNOR

Robie G. Russell

Regional Administrator

U.S. Environmental Protection Agency

1200 Sixth Avenue

Seattle, WA 98101

OCT 0 7 1988

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MANAG£MENT

BRANCH

Dei 11 1988 .

OFF1Cf.: OF

REGIONAL AOf.1INfSTRATOR

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Dear Mr~sell:

Re: RCRA Program Revision

•

Enclosed is an application for rev~s~on of Oregon's authorized RCRA

hazardous waste management program. The state received Final Authorization

for the program on January 31, 1986. A draft program revision application~

was submitted to your staff on July 24, 1987. Comments were received fromEPA on November 23, 1987. The enclosed application has been amended to

address those comments. Oregon is requesting Final Authorization for the

following program modifications:

1. Public availability of information (Sectton 3006(f) of RCRA);

2. Technical corrections to the definition of solid waste (50 Federal

Register 33542-43, August 20, 1985, and 52 Federal Register 21306-7,

June 5, 1987);

3. illnendments applicable do generators of between 100 kg and 1,000'kg of

hazardous waste in a calendar month (51 Federal Register 10174-76,

March 24, 1986);

4. Amendments pertaining to closure and post-closure care and financial

responsibilities for hazardous waste management facilities (51 Federal

Register 16443-59, May 2, 1986);

5. Amendments clarifying the listing for spent pickle liquor from steel

finishing operations (51 Federal Register 19322, May 28, 1986, and 51

Federal Reeister 33612, September 22, 1986);

6. Amendments pertaining to liability coverage for hazardous waste

management facilities (51 Federal Reeister 25354-56, July 11, 1986);

•

DEQ-1

7.

8.

Amendments concerning hazardous waste storege and treatment tank

systems (51 Federal Register 25470-86, July 14, 1986, and 51 Federal

Register 29L~30-3l, August 15, 1986);

Amendments to the rules concerning identification and listing of

hazardous waste (51 Federal Register 28298-310, August 6, 1986);
Robie G. Russell

U.S. EPA

Page 2

• 9. Amendments to the interim status standards for hazardous waste surface

impoundments (52 Federal Register 8708-9, March 19, 1987); and

10. Amendments to the rules concerning the development of corrective action

programs for hazardous waste land disposal facilities (52 Federal

Register 23450, June 22, 1987, and 52 Federal Register 33936,

September 9, 1987).

The enclosed program revision application consists of:

1. RCRA Revision Checklists (checklists number 13, 23, 24, 26, 27, 28, 29,

36, 37, 38 and Appendix D, the section 3006(f) checklist;

2. Attorney General's First Supplemental Statement and a revised Attorney

General's Statement for Final Authorization;

3. Updated copies of statute and rules (DRS Chapter 466; OAR Chapter 340,

Divisions 100-106, 108-109 and 120; OAR Chapter 860, Division 46, 61-69

and ORS Chapters 756, 757, 758, 760, 761, 763, 764, 767, 771, 772 and

773) ;

•

4.

5.

Updated Program Description and page inserts (Table of Contents,

pages 2.2-2.26, 2.30, 2.33, and 2.35-2.40; Charts 1 (page 2.14),

2 (page 2.15) and 3 (pages 2.16-2.22); and replacement Appendices B, C,

F (pages 7 and 8), K, L; a new Appendix M; and

A proposed new Memorandum of Agreement between the State of Oregon and

EPA.

•

The current Memorandum of Understanding between the Department of

Environmental Quality and the Public Utility Commission (PUC) (appendix A of

the Program Description) has been reviewed. Both parties agree that the

Memorandum should be updatediand expanded, and draft revisions are under

review. With respect to this program revision, however, we believe that

the current Memorandum with PUC is adequate and that authorization should

not be delayed until a new Memorandum has been ·signed. The requested

program revisions do not materially change the' way in which the two agencies

regulate hazardous waste or relate to one ano~her.

The Department looks forward to a favorable decision by EPA on this request.

If there are any questions about the application, please contact Jan

Whitworth, Hazardous Waste Section Manager, at 229-6434 or Kathi Futornick,

Hazardous Waste Administration Supervisor, at 229-5826.

Sincerely,

--Fred Hansen

Director

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ZF2946

Enclosures

cc: Al Goodman, EPAi Oregon Operations Office

Paul Henry, Pub ic Utility Commission

Larry Edelman, Department of Justice

HW Flle 6.15