811 SW SIXTH AVENUE, PORTLAND, OREGON97204-1390 

# DepartmentofEnvironmentalQuality 

# •

NEILGOLDSCHMIDT GOVERNOR

Robie G. Russell Regional Administrator U.S. Environmental Protection Agency 1200 Sixth Avenue Seattle, WA 98101 

### OCT0 71988**-~-** 

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# MANAG£MENTBRANCH 

## Dei11 1988

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### REGIONALAOf.1INfSTRATOR

## Ko~\> Dear**Mr~sell:** Re: RCRA Program Revision



# • Enclosed is an application for**rev~s~on** ofOregon's authorized RCRA hazardous waste management program. The state received Final Authorization for the program on January 31, 1986. Adraft 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) ofRCRA);
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 ofbetween 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, May2, 1986);
5. Amendments clarifying the listing for spent pickle liquor from steel finishing operations (51 Federal Register 19322, May28, 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); 

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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 enclosedprogram revision application consists of:
1. RCRA Revision Checklists (checklists number 13, 23, 24, 26, 27, 28, 29, 36, 37, 38 andAppendix D, the section 3006(f) checklist;
2. Attorney General's First Supplemental Statement and a revisedAttorney 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);


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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 newAppendix M; and
Aproposed new MemorandumofAgreement between the State ofOregon and EPA.



# • The currentMemorandumofUnderstanding between the Department of Environmental Quality and the Public Utility Commission (PUC) (appendix Aof the ProgramDescription) has been reviewed. Both parties agree that the Memorandum shouldbe updatediand expanded, and draft revisions are under review. With respect to this program revision, however, webelieve that the currentMemorandumwith PUC is adequate and that authorization should not be delayed until a new Memorandumhas 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 SectionManager, at 229-6434 or Kathi Futornick, Hazardous Waste Administration Supervisor, at 229-5826. Sincerely,



# -- Fred Hansen Director FH:wd:f ZF2946 Enclosures cc: Al Goodman, EPA

## i Oregon Operations Office Paul Henry, Pub ic Utility Commission Larry Edelman, Department ofJustice HW Flle 6.15