# •

•

• RCRA CLUSTERS VII AND VIII REVISED AUTHORIZATION APPLICATION ADDENDUM TO PROGRAM DESCRIPTION FEBRUARY 2001 I. SCOPE, STRUCTURE, COVERAGE, AND PROCESSES OF THE IDAHO HAZARDOUS WASTE PROGRAM [40 CFR § 

### 271.6 (a)] Idaho Department ofEnvironmental Quality, (Idaho DEQ), intends to continue to operate a hazardous waste program that is consistent with the federal program. Accordingly, the Idaho Hazardous Waste Rules and Standards are amended annually using an adoption by reference process for all delegable federal requirements with approval bythe Idaho Legislature, so that the Idaho Hazardous Waste Rules and Standards, IDAPA 16, Title 1, Chapter 5, remain consistent with federal RCRA hazardous waste regulations. The Revised Attorney General's Statement, (Appendix I), supports coverage for all delegable federal hazardous waste regulations promulgated as ofJuly 1,1998. The structure and organization ofthe Idaho.Dlit) was changed to department status by SB 1426 as ofJuly 1, 2000 and is described in more detail in the Revised Attorney General's Statement (Appendix I). In that change, the newly created Idaho Department ofEnvironmental Quality was delegated continuing authority to promulgate equivalent hazardous waste rules and standards for all delegable federal requirements with approval bythe Idaho Legislature
. The scope ofthis program revision includes the requirements ofRCRA Clusters VII and

## vm as well as the Organic Air Emission Standards for Tanks, Surface Impoundments and Containers, (CC Rule), (5·9 FR 62896). This Program Description Addendum (PD) modifies the September, 1996, Program Description and 1997 RCRA Cluster VI Program Description Addendum. (Appendix II) 

### II. ORGANIZATION AND STRUCTURE [40 CFR § 

### 271.6(b)] The Idaho DEQ Waste Management and Remediation Division is responsible for continued implementation ofthe Idaho Hazardous Waste Program. This is 

### an internal restructure ofthe Idaho DEQ Permits and Enforcement Division listed in the September, 1996, Program Description. The organization ofIdaho DEQ was changed to department status by SB 1426 and is described in more detail in the Revised Attorney General's Statement (Appendix I). 

### A. Staffing arid Funding [40 CFR § 

### 271.6(b)(l)(2)(3)] Organization charts have been included in Appendix 

## m. The 2000 annual RCRA Hazardous Waste Grant Workplan and budget sheets have been included in Appendix IV to outline staff, sources offunding and planned hazardous waste activities
.

# c III. STATE PROCEDURES [40 CFR § 

### 271.6(c)] 

### See Appendix V, Hazardous Waste Program Summary, dated April, 2000 1
, 

### and the RCRA Memorandum ofAgreement, (MOA), revised 3/14/01, (Appendix 

### VD, for a complete description ofhazardous waste permitting procedures. Any effects ofSB 1426, effective July 1, 2000, on the State ofIdaho's permitting, judicial, and administrative procedures are documented in more detail in the Revised Attorney General's Statement (Appendix 

## D.

IV. FORMS [40 CFR § 

### 271.6(d)] 

### Idaho DEQ uses federal forms for hazardous waste permits, biennial reporting, notification of hazardous waste activity and manifesting ofhazardous waste. V. COMPLIANCE TRACKING AND ENFORCEMENT [40 CFR § 

### 271.6(e)] 

### There have been no substantive changes to compliance tracking and enforcement. A complete description ofthe Idaho DEQ Hazardous Waste Compliance Tracking and Enforcement Program can be found in Appendix V, Hazardous Waste Program Summary, dated April, 2000 and in the RCRA MOA, revised 3/14/01, (Appendix 

### VD as modified by SB 1426 and described in the Revised Attorney General's Statement (Appendix 

### D. 

# c VI. MANIFESTING [40 CFR § 

### 271.6(t)] 

### There are no changes to this portion ofthe program. The Idaho DEQ continues to incorporate by reference and enforce federal manifesting requirements.

1 

### The Hazardous Waste Program Summary (Appendix V) is submitted for the purpose of background information. Many ofthe references in the document have been modified by the passage ofSB 1426, effective July 1, 2000. For example, (page 2), references to the Board of Health and Welfare, should be the Board ofEnvironmental Quality; (page 6) references to the Department ofHealth and Welfare, should be the Department ofEnvironmental Quality; (page 17) references to the Director ofHealth and Welfare or Administrator ofDEQ, should be the Director ofEnvironmental Quality.

# • VII. GENERATORS, TRANSPORTERS, TSD FACILITIES [40 CFR § 

### 271.6(g)(1)(2)(3)] The Idaho Handler Count Activity Report dated August 14,2000has been included in Appendix 

## vn to define the numbers ofhazardous waste generators, transporters and treatment,storage and disposal (TSD) facilities. The Permitting Six Quarter Plan dated August 28, 2000, has been included to define types and status ofhazardous waste permitted facilities operating in Idaho. (See Appendix VITI). 

### VIII. ANNUAL QUANTITIES OFHAZARDOUS WASTE [40 CFR § 271.6(h)] The Idaho Hazardous Waste Management Report, 2000, is the most recent document that describes hazardous waste generation and management in Idaho. It

### has been included in Appendix IX. Please refer to the Revised Attorney General's Statement (Appendix I) 

### for any modifications caused by SB 1426. 

# •

•

## PROGRAM DESCRIPTION

# ~". I. BACKGROUND
r , 

### In 1983, 

### the Hazardous Waste Management Act (HWMA) 

### was promulgated by the Idaho legislature. This was the enabling legislation for the proper management ofhazardous waste in Idaho. This legislation provided the authority for promulgation ofhazardous waste rules and standards by the Idaho Board ofHealth and Welfare. HWMA was amended in 1984, 1986 

### through 1991, 

### and 1993 

### through 1996. 

### These revisions were necessary to maintain the State's equivalency to the federal program (Appendix I) and to modify certain portions ofthe Statute that are broader 

### in scope than the Federal RCRA program. The 1995 

### amendment to HWMA significantlyreduced hazardous waste disposal fees collected by the State. The 1996 

### amendment changed the frequency ofIdaho's reporting requirement from quarterly to annual. The Idaho Administrative Rules governing hazardous waste are entitled, "Rules and Standards for Hazardous Waste, IDAPA 16, 

### Title 01, 

### Chapter 05." 

### The first set ofState regulations became effective on January 1, 1985. 

### Annual rule updates and corrections have been promulgated subsequently (see Appendix II). HWMAinstructs the Board ofHealth and Welfare to promulgate rules and standards which are in substance consistent with RCRA regulations but no more stringent nor broader 

### in scope. To meet the standards ofequivalency and consistency with the federal program, Idaho incorporates by reference delegable federal regulations in 40 

### CFR Parts 124,260-266,268,270, 273 

### and 279. 

### On April 9, 1990, 

### Idaho was granted final base authorization for those non-HSWA (Hazardous and Solid Waste Amendments) and HSWA requirements, promulgated as ofJuly 1, 1987, 

### and interim authorization for the HSWA Corrective Action provisions promulgated as ofJuly 1, 1987. 

### Final authorization for those HSWA Corrective Action provisions was granted on June 5, 1992. 

### On August 10, 1992, 

### Idaho was granted final authorization for those HSWA and non-HSWA provisions promulgated as of July "'1, 1990. 

### On March 30, 1995, 

### Idaho was granted final authorization for HSWA and non-HSWA provisions promulgated as ofJuly 1, 1993. 

### Appendix ill contains a table illustrating Idaho's RCRA program authorization status. 

### IT. SCOPE, STRUCTURE, COVERAGE, AND PROCESSES OF THE IDAHO PROGRAM [40 

### CFR §" 271.6 

### (a)) Idaho intends to continue to operate a hazardous waste program that is consistent with the federal program. Accordingly,
..

### the Hazardous WasteRules**~~.~.!andC1!:d~were~end_e.~.cApp~~dix** 

### II). Annually, the Idaho Board ofHealth and Welfare has adopted by reference all delegable federal requirements so the Idaho Hazardous Waste Rules and Standards, IDAPA 16, 

### Title 1, 

### Chapter 5, 

### remain consistent with RCRA. These documents and the Revised Attorney General's Statement (Appendix IV) 

### support coverage for all delegable RCRA requirements itemized in Appendix V, Reference Guide to Cluster Adoption.



### I

### Idaho Revised Authorizatiori Application September, 1996 Page 2 The scope ofthis program revision includes the requirements ofRCRA Clusters IV and V (Appendix V, Reference Guide to Cluster Adoption). This Program Description (PD) is in addition to the 1994 PD which amended the original July 1988 Program Description. The format ofthis document consists ofappendices that contain improvements to Idaho's RCRA program, which are pertinent to this revised authorization package. RCM Revision Checklists from the State Authorization Manual have been excluded to avoid redundancy with the Attorney General's Statement and to eliminate approximately 120 pages ofduplicative information. This format will allow for a streamlined approach to future program revisions. 

### A. State Regulatory Equivalency Idaho has maintained regulatory equivalency with the federal RCRA program by incorporating by reference all delegable hazardous waste regulations revised between July 1, 1993 and July 1, 1995. There is one exception to Idaho's traditional adoption by reference ofall delegable hazardous waste regulations in RCRA Cluster V. 

### AnEPA Headquarters memorandum dated January 26, 1996 reconirnended States defer adoption ofthe Organic Air 

### Emission Standards for Tanks, Surface Impoundments, and Containers (59FR 62896) until revisions are made. Idaho has followed this recommendation. Appendix II contains the Idaho Hazardous Waste Rules and Standards which include RCRA Clusters IV and V. The Revised Attorney General's 

# ell
Statement (Appendix IV) 

### contains a comparison ofEPA's 40 CFR citations and Idaho's .­ equivalent State rules. Also included in the Attorney General's statement are the Idaho Hazardous Waste Management Act authorities and corresponding rules. Idaho's Rules and Standards for Hazardous Waste were significantly lengthened during 1995 by the inclusion ofa conditional exclusion for a newly delisted wastestream. 

### B. Organization and Structure [40 CFR 

### §§ 271.6 (b)] Permits and Enforcement is the division responsible for implementation ofIdaho's hazardous waste program. Minor reorganizations did not impact these responsibilities. C. 

### StaffJob Descriptions [40 CFR 

### §§ 271.6 (b)(l)] There are no new staffpositions which require job descriptions for**th~PJ~!l'Qses** 

### ofthis revised -application.--Severariitlechanges-liave-bee-nenacted; however, the duties associated with these positions remain unchanged. The organizational chart in Appendix VI includes these changes. 

### D. StateAgency Staffing and Funding Idaho's RCRA program currently consists of 12.95 FTE that are utilized to implement 

# c-\ the program. The federal government provides approximately forty-nine percent (49%)· / ,. ofthe funding for these positions. Federal RCRA funding is allocated for :c- __•• 

### 2

### Idaho Revised Authorization Application September, 1996 Page 3 approximately 6.4 FTE. DEQ's RCRA program will continue to focus foremost on permitting, corrective action, enforcement and compliance assistance efforts. Appendix VI contains the organizational charts for DEQ Permits and Enforcement division including RCRA staffpositions. 

### E. Training Continual stafftraining is a key element ofthe State program as RCRA regulations evolve. Training with emphasis on technical criteria, regulations, policies, interagency issues, etc., is scheduled on an as-needed basis. Appendix 

## vn contains examples of training sessions attended by members ofthe RCRA staffduring the time-frame applicable to this revision package. In 

### addition to technical training, where appropriate, RCRA program staffare trained in accordance with the State ofIdaho Worker Health and Safety Program, which includes training 

### in the use ofpersonal protective equipment and the requirements of29 CFR 1910.120. 

## F. Program Funding [40 CFR §§ 271.6 (b)(2)&(3)] Idaho's RCRA program operates on $826,311 according to FY 95 Work Plan and Idaho's Application for Federal Assistance

- Hazardous Waste Management RCRA. The DEQ receives approximately forty-nine percent (49%) ofRCRAprogram funding through an EPA grant. The federal RCRA grant amount of$401,419 has remained the same for the last five years. Fifty-one percent (51%) ofthe RCRAprogram' funding is comprised offees assessed on hazardous waste disposed at commercial TSD facilities. Fees collected are managed in the Hazardous Waste Management Account. Hazardous Waste Disposal fees, utilized to support the operation ofIdaho's authorized RCRA program, totaled $424,892 in 1995. Recent decreases in fees coupled with potential reductions in federal funding could seriously affect the program. The next revised authorization package may reflect recent efforts that are underway for Idaho to enter into a Performance Partnership Agreement and Performance Partnership Grant with 

### EPA 

### G. Ancillary StaffSupport Ancillary support ofthe RCRA program is provided by DEQ's Planning and Support Services Division. This Division supports all programs within DEQ and receives partial funding through the current indirect rate offifty-eight percent (58%) assessed on 

# (e all federal grants. Also, DEQ is assigned 6.33 FTE attorneys and one paralegal through Idaho's Office ofAttorney General for all programs. The RCRA program is allocated approximately 1.5 FTE attorneys.
-, 

### 3Idaho Revised Authorization Application September, 1996 

# c: Page 4 

### H. Operational Procedures [40 CFR §§ 271.6 (c)) 1. 

### Scope of Regulated Community [40 CFR §§ 271.6 (g)&(h)] The estimated number ofhazardous waste or used oil handlers in Idaho is delineated 

### in Appendix VITI. These numbers are based on receipt ofhazardous waste or used oil notification forms by EPA or DEQ through accessing the RCRA Informational System (RCRIS).

-Regulated Used Oil generators are not required to notify for generator activities; an estimation ofthis group is also provided in the appendix. The actual number ofhandlers, which correspond to the categories listed, will remain variable due to changes in production practices. The treatment, storage, or disposal facility (TSD) category is used by those hazardous waste handlers whose activities require a RCRA permit. The Idaho National Engineering Laboratory (INEL) is considered a single facility. It is anticipated that approximately 25 partial permits will be issued within the next six years to address activities at the INEL, including mixed waste thermal treatment and other specialized waste treatment. These partial permits are reflected in the RCRIS system as a singular effort. Evaluation ofIdaho's 

# C regulated community must include factoring in the complexity ofthe INEL. - The Permitting Six QuarterPlan better illustrates projects underway at the INEL (Appendix XV). Appendix VITI also contains information regarding quantities ofhazardous waste managed within the State ofIdaho for the calendar year 1995. This information was obtained from the 1995 Hazardous Waste Annual Report which is also included in Appendix VITI. 

### 2. Hazardous Waste Handler Hazardous Waste Handler procedures are now referenced in the RCRIS Memorandum ofUnderstanding (1991) (MOD) and the RCRIS Standard Operating Procedures (SOPs). Appendix IX contains RCRIS SOPs updated

. _"sincesubmission ofthe lastrevision package. 

# TIleR-cros MOUhas been amended, and an attachment is included under Appendix IX. 

### 3. Manifesting [40 CFR §§ 271.6 (I)] There are no changes to this portion ofthe program.

# (~**~----** .. 

### 4

# • Idaho Revised Authorization Application September, 1996 Page 5 

### 4. Inspections [40 CFR §§ 271.6 

### (d)] Most changes in the inspection process can be found in the applicable appendices when the HWMA Civil Penalty Policy, CompliancelEnforcement Strategy, Compliance Assurance Agreement, and other documents are updated. RCRA inspection results are detailed in the required inspection reports. The inspection report is derived from the inspectors facility visit, supplemented with field notes. The inspection reports are filed in each facility's file. Changes to inspection protocol may also include upgrading forms and inspection checklists. 

### Ifthese forms are internal (State) documents, upgrades are provided in Appendix X. 

### Federal form upgrades are incorporated into the State RCRA program. Forms and checklists that are EPA generated or site-specific are not included in authorization revision packages. A list ofEPA and site-specific checklists provided to inspectors is identified in Appendix X. 

### Idaho's Hazardous Waste Inspectors have begun a pilot program to provide Compliance Assurance/Technical Assistance (CATA) inspections to generators on a voluntary basis. Details regarding this program can be found in the 1996 Workplan.

:

# .• 5. Hazardous Waste Transportation Authorities There are no changes to this part of the program. 

### 6. EnforcementProgram Summary The 1987 EPAEnforcement Response Policy and the HWMA Civil Penalty Policy have provided the basis for the Enforcement Program. Idaho is also adopting the 1996 Revisions to the EPAEnforcement Response Policy. The 

### HWMA CivilPenalty Policy is scheduled to be reviewed this year; incorporation into a multi-media enforcement policy is planned. Operational procedures for the enforcement program are found in the appendices under: Compliance and Enforcement Strategy, Compliance Assurance Agreement, and the Memorandum ofAgreement. These appendices are numbered XI, XII, XIII respectively. These have not been updated since the last revision package. 

### 7. Criminal Enforcement Procedures There have been no changes to this portion ofthe program.



### 5

### Idaho Revised Authorization Application 

# '" September, 1996 

# C .: Page 6 

### 8. ' Waste Stream Delisting Idaho received its first petition to delist a hazardous waste from EnviroSafe Services ofldaho, Inc. (ESII) on July 18, 1995. The final rule was made effective March 17, 1996 after review by the Idaho Legislature. Chemically stabilized electric arc furnace dust was delisted. ESITs parent company, EnviroSource, has extensive experience utilizing their patented treatment process. EPA granted a multiple site exclusion for thirteen EnviroSource facilities throughout the country that will utilize'the treatment process. EPA could not grant a delisting for ESII because Idaho is authorized to implement delisting. The delisting rule increased the text ofldaho's Hazardous Waste Rules and Standards by fifty-percent (50%). ' 

### 9. Information Management [40 CFR §§ 271.6 

### (e)]
a. Public and Confidential Information There have been no changes to this portion ofthe program. 

### b. Biennial Report 

# o Idaho's DEQ has performed all data entry and QNQC work for both the 1993 and 1995 BRS cycles. Idaho's DEQ intends to continue these activities. 

### c, RCRIS Reporting In 

### January 1991, EPA and DEQ entered into a Memorandum of Understanding (MOD), as amended in December 1991, to provide for administration ofRCRIS. In 

### particular, the MOD details (1) the conversion ofdata from the Hazardous WasteData Management System (HWDMS) to RCRIS, (2) information sharing procedures, (3) implementor ofrecord policies, (4) dispute resolution procedures, and (5) general RCRIS management issues. The MOU was amendedin 1995

, withthe addiiioiiofAttachmentzas providedIn Appendix IX. The

MOU was updated to reflect our information sharing agreement and Idaho's new responsibility to assign RCRA ID Numbers. RCRIS SOPs have been updated since the last revision package was submitted. The updated SOPs can also be found in Appendix IX.



### 6

# '. Idaho Revised Authorization Application September, 1996 'Page 7 

### d. ,Annual Reporting System As a result ofan amendment during the 1996 legislative session, Section 39-4411 ofHWMA now requires all hazardous waste generators and disposal facilities to report quantities ofhazardous waste produced or received on an annual basis. HWMA then requires the Idaho Department ofHealth and Welfare, through DEQ, to submit an annual report to the Governor and the Legislature detailing the types and quantities ofhazardous wastes handled in Idaho. 

### In the past, generator and TSD reporting was required quarterly. The 1996 Idaho Legislature revised this requirement to reduce the paperwork burden. 

### 10. Permitting Program
a. Permit Application ReviewlDecision-Making Permitting activities are projectedin a Six QuarterPlan. Arrangements between Idaho and the EPA., regarding implementation ofboth HSWA and non-HSWA regulations, are addressed in

# a Memorandum of Agreement (Appendix XV). 

### b. Permit Modification, Suspension, Revocation, Reissuance, and Termination Permit modification procedures remain consistent with the requirements of40 CFR 

### § 124 and 

### § 270 as updated. IDAPA 16.01.05.013 and 16.01.05.012 are amended annually to reference changes made to 40 CFR 

### § 124 and 

### § 270.


### c. Six QuarterPlan [40 CFR §§ 271.6 

### (g)(3)] The Multi-Year Permitting Strategy has been integrated into the Six Quarter Plan attached as Appendix XV. The Six QuarterPlan includes' all facilities under-going the permit process and permit status information. 

### Implementation ofHSWA Amendments ' L Two rules in RCRA Clusters IV and V have been found to have a significant impact on Idaho's regulated community or the State RCRA program. Workload increases to the State RCRA program are balanced and prioritized against existing tasks 

### inthe RCRA WorkPlan and are negotiated annually. Impacts are described below:


### 7

### Idaho Revised Authorization Application September, 1996 Page 8 

# c·
1. 

### 59 FR 47982 Land Disposal Restrictions Phase IT

- Universal Treatment Standards, and Treatment Standards for Organic Toxicity Characteristic Wastes and Newly Listed Wastes RULE CODE: 137 The Universal Treatment Standards (UTS) has simplified LDR for the' regulated community. Workload increase has been experienced while staff gained knowledge on this new rule. Most of our RCRA staffparticipated in a McCoy LDR satellite training offered through Oregon's DEQ. As staff become familiar with the new rule, workload should stabilize. 2. 60 FR 25492 Universal Waste Rule Hazardous Waste Management System; Modification ofthe Hazardous Waste Recycling Regulatory Program RULE CODES: 142 A-E The Universal Waste Rule (UWR) required additional training, and may require significant additional work in the future. This rule contains a petitioning for rulemaking process. Rulemakings are resource intensive; the increased workload will depend on the amount ofpetitions the Department receives. Additionally, the regulated community has already requested and received several training sessions from DEQ staff. 

# 0
J. Radioactive Mixed Waste Permits and Enforcement's Operating Permits Bureau (OPB) implements Idaho's Site Treatment Plan in accordance with the Federal Facilities Compliance Act. OPB approves 'and revises mixed waste stream and treatment unit plans. 

### K. Underground Injection Control There have been no changes to this portion ofthe program.

!**-~._.** 

# Q

.. 8

## ( ADDENDUM TO THE 1996 PROGRAMDESCRIPTION BACKGROUND 

# teL

On September 17, 1996, the Administrator ofthe Idaho Division ofEnvironmental Quality submitted a revised application to obtain final authorization for those non-HSWA and HSWA requirements promulgated as ofJuly 1, 1995. This application was determined complete on October 10, 1996. On October II, 1996 a petition was submitted to EPA asking that EPA initiate withdrawal proceedings of Idaho's authorization to administer Subtitle C ofRCRA The petition claimed that Idaho Environmental Audit Protection Act warranted program withdrawal. Although no formal action was taken directly in response to the petition, Region X halted all further action on the pending revised authorization
. approval. Idaho's Environmental Audit Protection Act will sunsetDecember 31, 1997. Region X has agreed to proceed with Idaho's 1996 application so thatfull authorization for non-HSWA and HSWA requirements, promulgated as ofJuly I, 1995, may be granted immediately upon sunset ofthe Idaho Environmental AuditProtection Act. In an effort to mitigate the delay, Region X will accept Cluster VI rules as an addendum to the 1996 package. 

## n, SCOPE, STRUCTURE, COVERAGE, AND PROCESSES OFTHE IDAHO PROGRAM [40 CFR 

### §**2~1.6** 

### (a)] Idaho intends to continue to operate a hazardous waste program that is consistent with the federal program. Accordingly, the Hazardous Waste Rules and Standards were amended (Appendix

### TI). Annually, the Idaho Board ofHealth and Welfare has adopted by reference all delegable federal requirements so the Idaho Hazardous Waste Rules and Standards, IDAPA 16, Title I, Chapter 5, remain 

# e / consistent with RCRA These documents and theRevised Attorney General's Statement (AppendixIV) support coverage for all delegable RCRA requirements itemized in Appendix V, Reference Guide to Cluster Adoption. The scope ofthis program revision includes the requirements ofRCRA Clusters N, V, and VI (Appendix V Reference Guide to Cluster Adoption). This partial Program Description and appendices serve as an addendum to the 1996 application. 

### A. StateRegulatory Equivalency Idaho has maintained regulatory equivalency with the federal RCRA program by incorporating by reference all delegable hazardous waste regulations revised between July I, 1993 and July 1, 1996. There is one exception to Idaho's traditional adoption by reference ofall delegable hazardous waste regulations in RCRA Clusters V and VI. 

### An EPA Headquarters memorandum, dated January 26, 1996, recommended.States defer adoption ofthe Organic Air Emission Standards for Tanks, Surface Impoundments, and Containers (59FR-62896)-until revisions are made. Idaho has followed this recommendation. Appendix II contains the Idaho Hazardous WasteRules and Standards which includeRCRA Clusters N, V, and VI. The Revised Attorney General's Statement (Appendix IV) contains a comparison ofEPA's 40 CFR citations and Idaho's equivalent state rules. Also included in the Attorney General's Statement are theIdaho Hazardous Waste Management Act authorities and corresponding rules. 

# • Section J.II.B-J.II.H.

- Reserved 1 Addendum tothe 1996Program Description October 1997

## ( ( Implementation ofHSWA Amendments, L 

# ( Three rules in RCRA Cluster VI have been found to have a significant impact on Idaho's**(--~.** regulated community or the state RCRA program. Workload increases to the state RCRA

### ~/ , program are balanced and prioritized against existing tasks in the RCRA WorkPlan and, '

are negotiated annually. Impacts are described below: 1. 60 FR 63417 RCRA Expanded Public Participation Rule RULE CODE: 148 This new regulation will provide the public with earlier opportunities to participate in the permitting process. TheExpanded Public Participation Rule, will require both the applicant and the State Agency to perform several new steps to initiate the permitting process. DEQ permitting staffhave undergone internal training to prepare for implementation ofthis rule. Staffat the INEEL were also provided training due to the large number ofpartial permits that are expected to be submitted by that facility. This rule also requires the applicants and regulating agency to expend additional funds to comply with the public notice, informational meeting, and mailing list notification requirements. 2. 61 FR 15566 Land Disposal Restrictions Phase ill

- Decharacterized Wastewaters, Carbamate Wastes, and SpentPotliners RULE CODE: 151 This rule clarifies that waste waters that are subject to regulation underthe Clean WaterAct would not be subjectto Land Disposal Restrictions standards provided the hazardous constituents are addressed under the Clean WaterAct regulations. 

# ( 

# C. Although there have not been many inquiries received, this clarifying language has been determined to be very important to generators thatdischarge**wastewaters~** to Clean Water Act systems. . This rule also codified EPA's enforcement policy on the use ofcombustion as treatment ofinorganic metal-bearing wastes. Several'combustion projects are underway at the INEEL. Staffwill implement this newrule when reviewing waste analysis and characterization information associated with wastes that are destined for combustion. 3. 51 FR40572 and 53 FR 31138 Land Disposal Restrictions for the First Third Scheduled Wastes On April 29, 1996 (61 FR 18828), EPA published the decision that states may seek delegation for this section, "Variance from a Treatment Standard." This portion ofthe Land Disposal Restrictions may be implemented for various mixed raaio-active'hazaraouswciStestreamsat llie--INEEI: Approvirig'or-dis'approving-'

-­ waste-specific variances may be time consuming for agency staff. Historically, Idaho has omitted 40 CFRpart 268.44 from its rules. This section has now been incorporated into Idaho's Hazardous Waste Rules and Standards. . 

### Sections l.II.J.-l.II.K. Reserved

2 Addendum to the }996 Program Description October 1997

----- -1Department of 1 tel Quality Administr. .vices

Environmental Trainee Bret BerryM Management Assistant Rosin Alonzo(4648) DEQ Direcor Steve Allred(5600) Assignment to GEMStars Helen Rime )5769) DEQ Quality Director

Don Bledsoe (56991 Chief of Staff

Jan Sandoval (51991 Staff Resource Officer

JessByrn(57571 Safety Desk Officer Jim Hollenbeck (P/Pl Safety Desk Officer Rov Guerrero (P/1) Administrative Assistant B Debra Cline (4598)
Fiscal Officer Dewy Sande (11371 Human Resource Officer Kathy Os¢om (2751) Chief Information Officer Phil Banly (3616) Management Analyst Jason 3edrv (40251 Gov Relations Specialist Todd Mootcomcrv (40141 Admire Assistant 1 Carol W ocgon (2753) L IT Resource Tenn Leader DoueJas Fowler(4690) Aron Krone (12291

IT Network Analyst Nicholas Powers (45911 IT Network Analyst Sandy Nave (1209) TI Systems Inurg. Analyst Bob Mowrey (40211 IT Systems int. Analyst Mark Gross (45901

IT Support Technician

BobMcCracken (T) Office Specialist II - PIT Chris Roberts ( 55421

Office Specialist B Marie Jolley (2769) Administrative Assistant I Jean Francis (5327) Tech. Records Specialist 1 Delores Gaskell (40681 Budget/Finance Financial Specialist Sr. Brenda Malone (27601 Budget/Finance Financial Specialist Sr. Bill Hart (28771 Budget/Finance Financial Specialist Sr. VACANT (33891 Budget/Finance Financial Specialist Sr. Claudia Clark (0703) Budget/Finance Financial Specialist Sr. Ryan Butler (46741 Budget/Finance Office Specialist I VACANT (9051) Budget/Finance Financial Tech. VACANT Accounting Financial Technician Michele Carstengen (18671 Accounting Financial Support Tech Marcia Todd 1191 11 Accounting Financial Support Tech Sue Zumwalt (13041 Purchasing Senior Buyer Bch Perkins {27301 Grants Management Grants/Contracts Officer Ken Grimmer' (4393) Grants Management Grants/Contracts Officer Tine KJarmt (20371 Organizational Development Team Team Lead, HR Specialist, Sr Workforce Development Doug McRoberts (1215) HR Specialist, Sr Classification & Recruitment Nancy Ouirk (12161 HR Specialist { Training & Development Chris Davenport (5320) IIR Assistant/Records HRIS/Remrds Jeff Kmfanta (T) Admin. Assistant I Paula Kiehl {34121
Customer Relations Team Team lead, HR Specialist, Sr, Employment & Labor Law Dionne Doering (1214) HR Specialist ,-JI Compensation & BeneEr Paul BI as (19(19)

I Tech_ Records Specialist EIS Specialist Sharon Hewlett(4248) iCoordination with Fiscal Office
Facilities Management Team Leader Rick FQrd (4595) IT Systems Technician

ReNne Hardy (1906) Environmental Trainee - P/I Derrik Woodbury {71 Environm null Trainee - PIT Pita Berman IT) Environmental Trainee - PIT Kyle Bclnap (T) Environmental Trainee - P/I VACANT M Ted. Records Specialist I VACANT (4957) Grants Management Env. Program Analyst Mary Grandiean (1820) Grants Management Env. Policy Analyst Kirby Famer (3009) 1- 

## J Env. Education Coordinator Patti Best (40191

Receptionist - P/T Deena CraskellM Web Information Specialist Laura Loftus (2764) Small Business Advocate Sally Tarowsky (4593)

Customer Service Rep. Janet Trumbull (22001

IT Support Technician Amon Burnett M IT Support Technician Brian Prisock (T-Traina)

Working Titles 04/26/01

## o i rbz 1 fA IIIi 

### Ou..,. 

# _ .......



# .... ........ 

# -....**Ew.~** I

lcloho f

.... 

### Ro:P-I0fiI01 

### .ra ": ' l' ._

fNW..o.• .•" ......._ rd'

:**s,ecIoi _~**  

# DMoi.-I I I

# • •**Depmmnentof~'nmenmIQuwi~** StateAir

## .~ Division StateAir Quality Division Administrator



### - Katherine Kelly(5776) PlannerAssigned to State Planning& SpecialProjects 

# H

----- Administrative AssistantII phyllisHeitman (597) Division - Temp.Assign.

, Alison Miller(2755) 

# ---1 Administrative AssistantI Johnna Stewart(1712) 

# I
! 

# ---1 Administrative AssistantI Marilyn Seymore (1929) 

# I

; 

### I I 

# I AQ Program Manager RobertWilkosz (5771 ) 

# I AQEnforcement & Compliance

. Program Manager Air Quality Permit Program Manager 

### I
, DavePisarski (3408) Marjorie MartzEmerson (5775) Air Quality Analyst lAir Quality Monitoring & 

### I I SmokeManagement I--- Emissions Manager Regional Enforcement Permitto ConstructManager DianeRiley (5774) VACANT Coordinator Mike Simon (1961) TimTrumbull (1872) Air QualityAnalyst I----- Air Quality Analyst 

### I

Trans/Conformity I--- Monitoring Guidance Compliance Analyst Mike Edwards(1815) Bruce Louks(4018) VACANT (1880)
, Air QualityAnalyst ---;- Air Toxics RuleslProgram Analyst { "--- Program Analyst Gary Reinbold(2283) Tim Teater(2564)

04/26/01 Working Titles.-=' Department of**Em(~** 

# )1ta1 Quality StaleWasteManagement**~mediation** Division

Division Administrator OrvilleGreen (4246) I Office Specialist II I 

# , Melissa Purcell (5020) 

# ---1 OfficeSpecialist Amber BiaelowIT)I MineWaste Program Manager RobHanson (3031 ) I I . Hazardous Waste Assigned to StatePlanning

WasteProgram Planner Program Manager & Special Pro**~ects** Division BrianMonson (3952) DaveLu ft (5205) Hazardous WasteRegulation & Policy Coordinator I-- JohnBrueck (4431) Hazardous Waste Enforcement Coordinator I--

MikeGrezorv (4646)

Hazardous Waste PermitCoordinator ....-- BobBullock (4430) Hazardous Waste Analyst 

## - ReneAnderson (4064) 

# I
Administrative Assistant I

TeriGreserv(\921l

I SiteRemediation Program Manager Dean Nvzard (4515) I INEEL Remediation Coordinator Darvl Koch (4846) I Remediation Program Manager :JoeNlIl!el (4594) MineProject USTILUST Program Coordinator 

# - Coordinator BruceSchuld(5680) RickJarvis(3788)

I-- OnSiteCoordinator Kellogg ScottPeterson (4043) I 

## -

I-- OnSiteCoordinator Kellog JanOlsenMatranl!a rn I 

## - SolidWasteProgram Coordinator Dean Ehlert(4592) Emergency & Disaster Management Coordinator

DaveGeoraiades (T)



## - OnSiteCoordinator Kellog NickZilka(2732) '-- USTILUST Program Analyst Heather Timothv (\ 42J) ;

'--- Receptionist Kellog LoriHallerCTl

Working Titles 04126/01

# • • Department 0ementalQuality StateWa ity Division

Planner Assigned to State Planning & Special Projects Division Nate Fisher (2748) WQ Planner Assigned to State Planning & Special Projects Division DaveHovland(J 838)

Working Titles 04/26/01

### ---------



## ---------

--------- 

# o Department ofEnOnental Quality 

# o State Planningand SpecIal ProjectsDivision



## I Environmental Planner Senior Liisa Itkonen(3750) 

## I

.Environmental Program Planner Pam Smolczynski (2756) 

## I

.Environmental Program Planner Julia Achabal (1859) State Planningand Special Projects Administrator

Larry Koenig(3440) Administrative AssistantII f--- 

### Linda Clark (5593) Office SpecialistII f--- 

### ElisabethJenkins (5642)
Environmental Planner WastePrograms Assigned Da State Air Air Programs Environmental Planner Divisio n - Temp. Assign. Assigned Alison Miller 2755 Environmental Planner Surface WaterPrograms 

## ---------. Assigned Nat Environmental Planner Groundwater Programs . Assigned Dave

WorkingTitles 04/26/01

# • • Department of .nmentalQuality StateTechnic rvices Division



### I Life Sciences Discipline Lead BarrvBurnell(5422) I

I



## I StateTechnical Services DivisionAdministrator Bill Gale (J 926) 

# H Administrative Assistant II HeleneWolfzram (4958) 

### I Administrative Assistant I

.JoleneCarroll(4931) 

### I OfficeSpecialist I Phil Ferauson(1759) I Administrative Assistant I LindaSmith(5607) 

### I OfficeSpecialist II SherrvThomas (3413) I OfficeSpecialist II SherrvDavis(922) 

### I Administrative Assistant I BelindaMcFarland (1207) 

### I ProcessEngineering

Discipline Lead Dan Salaado(5770) 

### I Environmental Resources Discipline Lead JohnLawson (5660) AttorneyGeneral 

# I I i I I I 

### I I Enforcement Support DisciplineLead Barrv Burnell Actlna (4307) Geosciences CivillEnvironmental Engineering Data/GIS Applications DisciplineLead Discipline Lead DisciplineLead Gerrv Winter(1849). Paul Wakazawa(2111) Will Wall (3421)

Working Titles 04/26/01

### I \ · Department of**E~'** "rental Quality State Technicai"-.../l:es Division 

## '0

StateTechnical Services Division Administrator BillGale I ProcessEngineering Discipline Lead

DanSalgado 

# I I StafTEngineer Associate Engineer 

### I I ShawneeCben(5539) KenHanna(5538) 

### I 

# I AirQualityPermitWriter I I HarbiElshafei (3409) I I 

# I AirQualityPermitWriter I I TomAnderson (3414) I 

### I 

# I Associate Engineer I I SteveOale (1920) I I 

# I Meteorologist I I MarvAnderson (341

### n I , I MichaelDubois(4596) 

# I StafTEngineer I I DanPitman(4960) I 

# I Biologist DoU2 Abderhalden (1923) 

# I Entomologist BillClark(4645) 

# I Toxicologist 

# I JefTFromm (1172) Biologist MarkShumar(4800) LifeSciences Discipline Lead BarrvBurnell I I I I I I I I I I I I I I I I Fisheries Biologist DonZaroban(542)) Limnologist VACANT (5323) Environmental Analyst DinahReanev (1913) Scientist n Darcy Sharp (4245) 

# I
Associate Engineer DarrinMehr(3020) 

# I
Associate Engineer VACANT (1884) 

# I

Meteorologist YaviDona (4959) 

# I Air QualityAnalyst 

# I Air QualityAnalyst I VACANT (}l96) 

# I

Working Titles 04/26/01

# • • Department o.nmentalQuality

State Techni rvlces Division

StateTechnical Services DivisionAdministrator BillGale


# I I I 

# I AttorneyGeneral 

# I

, 

# I

I I I I I Enforcement Support

DisciplineLead VACANT

- BarrvBumel1 Acting 

# I Environmental Compliance Analyd I Environmental ComplianceAnalYS1 JR Fuentes(S772) I I BeckvGoehrina (4962) I HW ScienceOfficer BrianGaber(4291) I HWScienceOfficer I I MattGarringer (3830) 

# I I HW ScienceOfficer Col1een Sweenev(S22l) I Environmental Compliance Analyd I NatalieMcLeod(4490) 

# I I AnalystII EileenLoerch(5S00) 

### I I Curtis Stoehr('11 Remediation ProjectOfficer I 

# I Environmental Resources DisciplineLead

John Lawson HW PermitOfficer I I HWPermitOfficer BrianEmdish(4864) I I BethMcPherson (S497) HW PermitOfficer I I HW PermitOfficer PeteJohansen(1914) 

### I I Garv Adamson(4489) Environmental Technician 

### I I Technical Writer ScottPitzer11839) 

### I I Amv Luft (SS6S) Environmental Scientist Ted Livieratos(J 149)

04/26/01 WorkingTitlesDepartmentof

### E,(~nental Quality State Technieal"--"'ees Division 

# o o

StateTechnical Services Division Administrator Bill Gale I Geosciences Discipline Lead

GerrvWinter Environmental Hydrogeologist MarkJeffers(\874) 

# I Environmental Hydrogeologist I I I I I I I 

### I I I I I I I I I I I I I I I I 

# 1- I 

# I Associate Engineer I , 

### I AssociateEngineer AllanJohnson(\834) I I CaroleZundel (3021) Staff Engineer 

### I I EngineerTech. I Larrv Waters(5678) 

### I I DickRogers (4017) AssociateEngineer I ·1 EngineerIn Training BiIIRogers (\840) 

### I I Zach K1otovich (410) Environmental Scientist I I AssociateEngineer

MarkClouah (1145) I I VivienHall(3672) 

# I
Environmental Hydrogeologist TomNeace(229)) Environmental Hydrogeologist 

# I BruceWicherski (1568) RobertTavlor(5608) 

# I Geoscientist U WQProgram Specialist ToddM82uire-(l154) AaronScheff(5726) 

# I 

# I
Environmental Hydrogeologist Environmental Hydrogeologist Joe Baldwin(4187) . ToniaMitchell (4022) 

# I I Environmental Hydrogeologist SeniorWaterQualityAnalyst EngineerIn Training ClvdeCodv (4928) MikeCook(4184) Eric Antrim(2289) 

# I 

# I Environmental Scientist Environmental Hydrogeologist MeraieEnalish(\ 153) DoUIl Davidson (4586) 

# I WQScienceOfficer Jerry West(5634) CivilJEnvironmental Engineering Discipline Lead PaulWak82awa

WorkingTitles 04/26/01

# • • Department of.onmental Quality State Technical Services Division

State Technical Services

Division Administrator Bill Gale Data/GIS Applications Discipline Lead

, . Will Wall ! I Project Controls Lead Project Controls Specialist 

### AlmerCasile (1833) Angela Fisher (1743) GIS Analyst, Senior Data Entry Specialist Jim 

### Szpara (3007) Dottie Martin (3004) Data Entry Specialist AIRS Database Coordinator Brenda Valverde (5595) Pat Rayne (5362) GIS Analyst AQ Monitoring Analyst VACANT (2735) Mary Walsh (4632)
; : GIS Analyst GIS Specialist , Sean Coyle (T) William Kelley (1843) ! GIS Specialist Gerry Smith (1210) IT Programmer Analyst Richard Lee (T)

Working Titles 04/26/01'-

II

# c

r Regional Manager Engineering Grell Eaaer(2750) StaffEngineer William Teuscher (2765)
WaterQuality

Engineer RvanUrbanec (1764) WaterQuality

Engineer CarlinFeisthamel (2742) DrinkingWaterQuality Analyst Rochelle Mason(222) SourceWater



### ...... Assessment Analyst TonvTinoco(T) III­

"­

"- Department of .Env(lental Quality Idaho Falls**Re~.aal** Office Regional Administrator

JimJohnston (953) 

# I I
Administration Assistant I Tammy Gallion (1314) ; 

# H OfficeSpecialist II DiannaWinkled5661l

, 

# H OfficeSpecialist I - PT LisaCawlev (T) 

# y OfficeSpecialist I - PT ; , VACANT(T) ! 

### I Regional Manager

WaterQuality Trov Saffle(5592)

WaterQuality Monitoring Program Officer SteveRobinson (5344) Surface Water Program Officer Sheryl Hill(2744)

Surface Water Program Officer TomHerron (2745)

Blackbird Mine Program Officer EltonModroo (431) BURPCrew
Working Titles 

### I Regional Manager Remediation & Waste BarbaraJewell(2749) Remediation roo- Science Officer MelissaThompson (5653)

"- Remediation Science Officer SteveHeaton (4026) , 

### I Regional Manager lNEELCoordinator & i Air Quality Rensav Owen(3026) Air Quality '- Analyst Jorze Garcia(1841)

LAir Quality Analyst AaronSwift(2271) i

04126/01

# • • Department .onmentalQuality Pocate onal()ftr.ce

AQMonitoring

Coordinator Tom Edwards(2255) SIP/Airshed Coordinator MelissaKeller(1848) InpectionlCompliance Coordinator Rick Elkins(3780) Regional Administrative Administrator Assistant MarkDietrich (2683) NikkiCarrenter (J952) Administrative Administrative Support Support JeanRobinson m Tai Koehlerrn I I AirQuality WastelRemediation Administrative Engineering Administrative Manager I-- Support I-- Manager Manager I-- Support I-­ TiffanvFlovd(5183) DoUIl.Tanner(4247) JohnKirknatrick (5671) StenhenieLords(5721) JaniceWinward (5695) I I Drinking Water Coordinator USTILUST Coordinator GrellMlandenka (4657) BarbamJones(0346) WaterQuality Manager Lvnn Van Everv(2754) NPSCoordinatorlWater QualityProject()tTicer

Dave Hull(088) I T I TMDLlWatershed Drinking WaterlWastewater Hazardous WasteInpectorl : Analyst BovdRoberts (5510) Engineer Emergency Response Coord. Mike Rowe(2737) ChuckKetterman (010) I T I WaterQuality Coordinator SourceWaterAssessment

Selenium Technician JessiBrunson[T]
. Coordinator SeanScott(2758) Richard Clesa (5502) T I Wastewater Land Application Coordinator TomHepworth (3303) T HydrogeologistlSolid WasteCoordinator TomMullican (1816) I SourceWater

Analyst Michelle Bvrd(T) MultimedialSpecial 

# I

Project Teams PermitIMonitoring Coordinator LarrvSims(1882) I Monitoring Technician KatvKoehler(T)

WorkingTitles 04/26/01Department ofEQmental Quality 

# o 

# o Twin Falls Regional Office

Office Specialist 2 Andrea Cox 2757)

Pollution Prevention, Remediation & Air Quality Regional Manager Bill Allred 5509 Water Quality Protection Regional Manager VACANT 3439 Drinking Water, Waste Water & Facility Management Regional Manager Mike McMasters 1842

WQ Science Officer Sean Woodhead (1814 AQ Science Officer Steve Vanzandt (2294)

Working Titles / 04126/01

# • • Deputment Of.mentalQuality Boise Office

Environmental Science Specialist Sell50naI
. Environmental Trainee Seasonal Receptionist LeslieNelson OfficeSpecialist I VickiEverhart (T)

Wor!cing Titles 04126101/ "\ Department ofEnOental Quality 

# u 

# u Lewiston Regional Office

Multimedia/Special Project Teams
Working Titles 04126/01

I I,

# • • Department or_mentalQuality Coeur d' Ale eglonal Office
OfficeManagement Office Manager VACANT 5604

WorkingTitles 04126/01

# •

STATE OF IDAHO, DIVISION OF ENVIRONMENTAL OUALITY IDEQ) HAZARDOUS WASTE MANAGEMENT PROGRAM Goal: To maintain a federally authorized hazardous waste program capable ofassuring proper. managementof hazardous waste to protect human health and the environment in the State ofIdaho. Preface: 1. 

### The following workplan represents total resources expended by DEQ to implement and maintain a Hazardous Waste Management Program in the State ofIdaho. (22.6 FTEs) The total budget of $1,805,036 is included. Sources ofthis funding include 22% or $393,500 from the U.S. EPA; 25% or $451,136 from the U.S. DOE, INEEL; and 53% or $960,400 from the State ofIdaho, General Fund. 

# • 2. The attached budget for $1,337,400 represents U.S. EPA and State funding to support the Hazardous Waste Program Grant, (16.6 FTEs)
.



# •

### ---­ .. j\

..'c r:. .;.,

STATE OF IDAHO DIVISION OF ENVIRONMENTAL QUALITY


## _-_._-_.

_ .. 

## _ . 1.110 North Hilton • BOIse. Idaho 83706·1255 • (208) 373..0502 December 6, 1999

Ms. Debbie Flood Grants and Acquisitions Unit Environmental Protection Agency 1200 Sixth Avenue (OMP-145) Seattle, WA 98101 Dear Ms. Flood: Enclosed please find an application requesting funding for the FYOO Idaho Hazardous Waste Management RCRA Program. The budget and project periods would be from 01/01/00 to 12/31/00. If you have questions regarding this application, please contact Project Officer Brian Monson (208) 373-0490 or Grant Officer Kirby Farner

Quality DS/kf

cc: GC/RF SS/SF #85730EOO (lcc Enclosure) Kirby Farner, DEQ Mark Masarik, EPA (IOO) (lcc Enclosure) Brian Monson;-DEQ: (lcc Enclosure) John Brueck, DEQ (lcc Enclosure) L./-J" , I ,_/.4(. .r**/.~**



### ......... , ',_.**!~_** .. 1
.. Li.

...:



# • at at(208) 373-0100
.



# •

# --

-- - ;Apphc.nl Identifier APPLICATION FOR 

### i FEDERAL ASSISTANCE 1. TYPE OF SUBMISSION 13 DATE RECEIVED BY STATE ;State Apphcabon Identifier

Application Preapplicahon I

Ccnstrucncn : Construction 14. DATE RECEIVED BY FEDERAL AGENCY !Federalldentlfi&f 

### i X Non Construction Non-Construetlon I I i 5. APPLICANT INFORMATION I Legal Name: ;Organlzational Unit CMslon of Environmental Quality i I ! Idaho Dept. of Health & Welfare I I , Address (gll/e City. county. state. and zip code). :Name and telephone number of the person to be contacted on 

## i 1410 NoM Hilton jmatters involving this application (g,...8 area code) I I Kirby Famet. BUdget Officer (208) 373.(1100 Boise. Idaho 83726,'255 !. i ! 6. EMPLOYER IOENTIFICATION NUMBER (EIN): 17.TYPE OF APPLICANT: (enter appropriate lelter in box) 82-6000995 A. State 

# I B. County 8. TYPE OF APPLICATION: I C. Municipal New Continuation Revjsjon D. Township K. Indian Tribe

X E. Interstate L Individual " Revision. entet appropriate letter(s) in bex(es) F. Intermunicipal 

# CD G. Special Dislrict A. Increase Award B. Decrease Award C. Increase Duration D. Decrease Duration Other (specify): 9. NAME OF FEDERAL AGENCY: Environmental Protection A9ency 10. CATALOG OF FEDERAL DOMESTIC 11. DESCRIPTIVE TTTLE OF APPUCANrS PROJECT:

ASSISTANCE NUMBER: 88.606 RCRA TITLE: RCRA

12. AREAS AFFECTED BY PROJECT (cities. counties. stales. etc.): STATEWIDE

13. PROPOSED PROJECT: U. CONGRESSIONAl OISTRICTS OF

Start Date Ending Date e.AgpIcll'll

### Ib.~ 01101/00 12/31/00 2 15. ESTIMATED FUNDING: le. ISAPPLICATION SlJBJECTTO REVIEWBY STATEEXECUTIVE ORDER lnn PROCESS? a. Federal S393.5OO e. YES THISPREAPPlICAnONIAPPUCATION WAS MADEAVAlLA8lE TOTHE b. Applicant SO STATE EXECUTIVE ORDERInn PROCESSFORREVIEWON

c. State S943.9OO OATE

d. Local S SO b. NO X PROGRAM IS NOTCOVERED BY E.O.Inn

e. OlIIer 

### so Is OR PROGRAM HAS NOT BEEN SELECTED BY STATEFORREVIEW I.-Program Income • 17.IS THEAPPLICANT DELINQUENT ON ANYFEDERAL 0E8T? 

### Is -_ ... .._­ .... SO ,-•._-_ ... ­
g. TOTAL $1,337.400 Yo. If '"'Yet,-attaenenexplanation. No X
18. To ttle best of my knowledge and :elief..all data in ttlis application are lNe and eerreet The document has been duly authorized bv the aovernina bodv of the aeeueanr and the acclicant will comelv with the attached assurances it the assistance is awarded a. Typed Name of·Authorized Representative lb. Title

C. Stephen Allred Administrator j H. Independent SChool Disl' I. St Controlled Inst 01 HIgher Leaming J. Private University

M. Profit Organization N. Oth.... (Specify):

# (~

Slilowide**~-~~~.**

..**~-~---.-_.**
.

I
, ---' ic. Telephone number I i (208) 373-0240 

## i I 0 . .. d.**Sign~/;ryrz;~ed** R2entative 

## i e ,/',;1-**~~'\** 

## fAltl-.u, cI1

## <a'r~ .,

### ;t~/~!ed~ "'l 

# ( II U I Previoul4ditions NotUsable Standard Form 424 (REV 4-88)

__ ...__F'rescribedby

..OMBCircular.A.102 ---."--- ..._ ...-

Authorized for Local Reproduction

# • • • OMB App,oval No_0348·0044

- --- ..__ . __ 

### ._-------------------------------------_._-------_...._._-----_... -.- BUDGET INFORMATION NON-CONSTRUCTION PROGRAMS SECTION A - BUDGET SUMMARY Catalog of Federal Domestic Assistance Estimated Unobligated Funds Number Federal Non-Federal (e)

(b) (c) (d $393,500 66.606

$0 $0 $393,500 SECTION B - BUDGET CATEGORIES 

### 1--'-----..-.-..**~-----** Total GRANT PROGRAM, FUNCTION OR ACTIVITY 1) RCRA-EPA 2) RCRA -DOE (3) (4) 1 6:**.~.Ej.!~! _~.!.ass**  Categories $860,414 $34,500

__**.CI:.!'l:!!~_C?.!l_~eJ_~~~'_e _t-------=:~::.:....:.....:.........I-----:...:....:~:..:...+-----**  __

### -+_-'-- _ b. $0 $0 I $10,000 $0 

### I c.**Tra~~** .**~---...:.........~-~------~~------~~...:.........----** $20,000 $0 $20,000 ',

.. d. Equip,-m_en_t

## -------------t----.....:..::~:....:...:-1-------~_1_------_t--------I----.....:..::.:..!..::..::..:..j e. Operating $58,100 $0 $58,100**t------'---"'------------------\----....::..::...:..!....:.~I_-----....::..::._I__------_l______;i__-----1_---~:!...:..::~** I f. Contractual $0 $0 $0 I' - .-
.. --- ..- ...--.------**---------------+-----......::.-=+------~-1---------I---'-------I------_'_J** 

### I.

_ g:.

__**Co~_struction** $0 $0 $0 h. Other 

# I $0 $0 $0

. .j, Total Direct Charges (sum of 6a-6h) $948,514 $34,500 $0 $0 $983,014 

## l j. Indirect Charges $354,386 $0 $354,386 $1,337,400 $1,302,900 $34,500 

## I k. TOTALS (sum of 61 and 6j)

Authorized for Local Reproduction**~t1ndard** Form 424A 14-881 Prescribed by OMS c,rfu,arA-102

# Q 

# .. o

8. ..._ .....__._ ...

### - ---------------_.. _ .... ".._---- -- SECTION C NON-FEDERAL RESOURCES

.... ._.. '......_-- , (a) Granl Program (b) Applicant (c) State (dl Other Sources (e) Totals

.. -._-_._- $0 $943,900 $0

__. ______ ._____**J9_~~~9~~** ------_ .. ,-- -_.

_ ..

## __.-**------~---**
, $0 

### ._-----_. .. 

### _--- $0 ---_._-_.. $0 ._--- AlS (sum of lines 8-11) $0 $943,900 $0 $943,900 SECTION D FORECASTED CASH NEEDS , .!

--------- ; Total-fst Year 1st Quarter 2nd Quarter 3rd Quarter 41hQuarter eral $393,500 $98,375 $98,375 $98,375 $98,375 Federal $943,900 $235,975 $235,975 $235,975 $235,975 

### , Al (sum of lines 13 and 14) $1,337,400 . $334,350 $334,350 $334,350 $334,350 SECTION E - BUDG!=T ESTIMATES OF FEDERAL FUNDS NEEDED FOR BALANCE OF THE PROJECT ------._----

_.

## __ ._- FUTURE FUNDING PERIODS (YEARS)

.. -.. ---- ..**(~.t~~ant** Program (b) First (c) Second (d) Third (e) Fourth

-

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

---.-**----_.~-,---** --, ..

----**AlS~um _~fUnes**  16.19) $0 $0 $0 $0

-- SECTION F OTHER BUDGET INFORMATION RCRA

I 9. i· I 10. 11. 12. TOT

# I~ed I r4. Non ! ,. 15. TOT i'

I 

### !, 16. 17. 

## I' I, 18. I 19. 20. TOT (Attach additional sheets If necessary) ...•

-_._ .... _-- .......... ­ 21. Dire ct Charges: $983,014 22. Indirect Charges: $354,386 23. Remarks: ,

._----- 

## _._-
Authorized for local Reproduction SF424A (4-88) Page 2 Prescribed by OMB Circular A·102

# •

STATE OF IDAHO. DIVISION OF ENVIRONMENTAL OUALITY (DEO) HAZARDOUS WASTE MANAGEMENT PROGRAM
Goal: To maintain a federally authorized hazardous waste program capable of assuring proper management of hazardous waste to protect human health and the environment in the State of Idaho.

Preface: 1. 

### The following workplan information represents total resources expended by DEQ to implement and maintain a Hazardous Waste Management Program in the State of Idaho (22.6 FTE's). 

# • 2. The attached budget represent U.S.EPA and State funding to support the Hazardous Waste Program Grant (16.6 FTE's).



# •-- --- --- - --- 

# 0 T'OTAL lD.-\HO DEQ HAZARDOUS WASTE PROGR.-\.\[ 22.60 FTE TotJ.l • State HazardousWaste ProgrJ.IT1 Office-6.50 FTE Objective: To maintain an authorized permitting, closure and corrective action program for new and existing treatment, storage and disposal facilities which satisfies federal and state hazardous waste rules and standards. Objective: To maintain a rulernaking , authorization. and technical data management program necessary to continue operation of the federally authorized hazardous waste program. Objective: To insure treatment and management of hazardous waste at INEEL is done in compliance with the RCRA Land Disposal Restrictions Program. Objective: To maintain a hazardous waste enforcement and compliance program as provided 

### by federal and state hazardous waste rules and standards. StafflActivities State Waste Program Administrator. 0.5 FTE Responsible for the overall implementation of DEQ State Waste Program Office functions, including oversight of the DEQ Hazardous Waste Program. TaskslDeliverables: A. Output: Supervision ofthe RCRA HW Program Manager Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 B. Output: Participate 

### in all DEQ Senior Management Meetings to represent State Waste Program concerns and issues. Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 C. Output: Participate 

### in all Senior Management Meetings with EPA Region 10 to represent DEQ Hazardous Waste Program concerns and issues. Milestone: Target Dates: 4100, 7/00, 10/00, 1/01 D.Output: Interface with WGA, NGA, ASTSWMO, Industry, Environmental and Citizen Groups on Regional and National Hazardous Waste Management issues. Milestone: Target Dates: 4100, 7100, 10/00, 1/01 E.Ouput: Represent the State WasteProgram Office at the Idaho Legislature. Milestone: Target Dates: 4/00,7/00, 10/00, 1/01 F. Output: Participate in drafting. reviewing arid approving the overall DEQ H\V Budget and Workplan. Milestone: Target Dates: 4100, 7/00, 10/00, 1/01 G. Output: Participate in drafting. reviewing and approving the overall DEQ HW Strategic Plan and Planning Process for the future. 

# - - 

# o Milestone: Target Dates: 4/00, 7/00. 10/00, 1/01
2 

# c-Hazardous Waste Program Manager:.. 1.0 FIE Responsible for maintenance of primacy for the DEQ RCRA Hazardous Waste Program 

# •**Tasks/D~liverables:** A. Output: Supervision ofRCRA. H\V Coordinators to ensure timely completion of Authorization,Rulemaking,HW Technical Data.Permitting and Enforcement Milestone: B. Output: Milestone: C. Output: Milestone: D. Output:· Milestone: E. Output: Milestone: ' F.Output: Milestone: 

# • G. Output: Milestone: H.Output: Milestone: 

### 1. Output: Milestones: 

### J. Output: Milestones: Tasks Target Dates: 4/00,7/00, 10/00, 1/01 Negotiate EPA/State HW Workplan Target Dates:8/00-12/00 Ensure Implementation Consistency of RCRA HW Program 'Target Dates: 4/00, 7/00, 10/00, 1/01 Maintain Federal Facility Compliance Act/Site Treatment Plan Target Dates: 4/00, 7/00, 10/00, 1/01 Prepare total DEQHW Program Budget Target Dates: 4/00, 7/00, 10/00, 1/01 Evaluate/Calibrate HW Permit Issuance Target Dates: 4/00, 7/00, 10/00, 1/01 Oversee Consent Order DevelopmentlEnforcement Referrals Target Dates: 4/00, 7/00, 10/00, 1/01 Participate 

### In EPNDEQ Quarterly Sites MeetingslWorkplan Reviews Target Dates:Target Dates: 4/00. 7/00, 10/00. 1/01 Interface with WGA, NGA and ASTSWMO on Regional and National Hazardous Waste Issues Target Dates: 4/00. 7/00, 10/00. 1/01 Make presentations to Idaho Legislature on HW Issues Target Dates: 1/00-3/00 Hazardous Waste Permit Coordinator: 1.0 FTE Responsible for the coordination of RCRA permitting and corrective action resources and

.activities." Tasks/DeliverabIes: 

### RCRA. TSDF's Permit Coordination 

# • A. Output: Monitor and evaluate program accomplishments/priorities. Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01------ -- 

# C 8. Output: Ensure scheduled dates fur corrective actionand**r<':~i1i[[in~** acti vit ics**~-H:<** implemented into RCRlS. Milestone: Target Dates: 4/00, 7/00. 10/00. 1/01 

### C. Output: Milestone: D. Output: Milestone: E. Output: Milestone: F. Output: .Milestone: Participate in "quarterly sites meetings," the mid-year. end of year. and annual program reviews. ./ Target Dates: 4/00, 7/00. 10/00. 1/01 

# '

Integrate multi-media approach. Target Dates: 4/00, 7/00, 10/00, 1/01 Assure integration of waste minimization consideration into permitting. Target Dates: 4/00, 7/00, 10/00, 1/01 Ensure permitting and corrective action data is maintained and updated in accordance with the RCRA MOA, the RCRlS MOU, and RCRIS SOP's. Target Dates: 4/00, 7/00, 10/00, 1/01 Hazardous Waste Regulation & Policy Coordinator:


### ............................... 1.0 FTE

- Responsible for the coordination and implementation ofRCRA/HWMA Authorization Development, Rulemaking, Regulatory Analysis, Technical Assistance, Training and Data Management activities and resources. Tasks/Deliverables:

A. Output: Milestone: 

### B. Output: Milestone: 

### C. Output:. Milestone: D. Output: Milestone: E. Output: Milestone: 

### F. Output: Milestone: G. Output: Milestone: Monitor and evaluate program accomplishments/priorities/resources. Target Dates: 4/00, 7/00, 10/00, 1/01 

# c: Participate in quarterly "sites" meetings, mid-year and end of year reviews and the annual "EPNStates Planning" meeting. Target Dates: 4/00, 7/00, 10/00, 1/01 Participate in the planning and preparation of the FY 01 RCRA Grant! Work plan. Target Dates: 6/00
- 12/00 Produce information necessary for the completion of the RCRA Work plan Quarterly Reports. Target Dates: 4/00, 7/00, 10/00, 1/01 Implement and participate in RCRAIHWMA Authorization, Rulernaking, Regulatory Analysis, Technical Assistance, and Training activities. Target Dates: 4/00, 7/00, 10/00, 1/01 Review, and participate in RCRAlHWMA Data J\lana2:ement activities. Target Dates: 4/00, 7/00', 10/00, 1/01 - Obtain Idaho Legislature approval of 1998/1999 RCRAIH\VMA rulernaking 

# C-" update. Target Dates: 1/00-3/00**-----~------** ._-- -­ > 4

### I-I. Output: Obtain Board of Health andWelfare approval of 1999-2000**RCR.·\/HW~{A** 

### rulernaking package. Milestone: Target Date: 

### 11/00 

# • 1. Output: Review, comment, and advise management and staff on proposed amendments to the Idaho Hazardous Waste Management Act. Milestone: Target Dates: 

### 4/00, 7/00, 10/00, 1/01 J. OUrpUL Review, comment, and advise management and staff on proposed EPA regulations, guidance, and statutory revisions. Milestone: Target Dates: 

### 4/00, 7/00, 10/00, 1/01
Hazardous Waste Enforcement Coordinator 

### 1.00 FTE Coordination and oversight of RCRNHWMA Compliance Assurance and Enforcement Program. Coordination of all compliance inspection and enforcement activities. Track compliance and enforcement activities to assure timely and appropriate actions are taken 

### in accordance with the Compliance Enforcement Strategy, Compliance Assurance Agreement, Enforcement Response Policy, and the (MOD, MOA). Develop program interpretations, procedures, and guidelines and implement same. Develop a Compliance Assistance program which incorporates technical assistance as another tool with which to achieve compliance. 

# • Tasks/Deliverables:

- Budget and Work plan activities and planning. A. Output: Develop budget related to compliance and enforcement activities. Milestone: Target Dates: 

### 4/00, 7/00, 10/00, 1/01 B. Output: Assist 

### in development of 

### FY'Ol work plan. Milestone: Target Dates: 

### 3/00 - 9/00 C. Output: Coordinate compliance and enforcement actions with DEQ and EPA Offices. Develop inspection schedules on a quarterly basis and provide to DEQ and EPA Regional offices prior to the beginning of each quarter (Attachment B). 

### Milestone: Target Dates: 

### 4/00,7/00, 10/00, 1/01 D. Output: Participate in DEQIEPA "Quarterly Sites" meetings, mid-year and end-of­

-year reviews and the annual "EPNStates Planning" meeting. Milestone: Target Dates: 

### 4/00, 7/00, 

### 10/00, 1/01 E. Output: Coordinate and oversee the development of inspection and enforcement work products in accordance with RCRA MOA. Milestone: Target Dates: 

### 4/00, 7/00, 10/00, 1/01 

# • F. Output: Assure all required compliance and enforcement data is entered into RCRIS in accordance with the ReRA MOA, RCRIS MOU, and RCRIS SOP'S. Milestone: Target Dates: 

### 4/00,7/00, 10/00, 1/01 

### 5G. Output: Implement newly adopted provisions upon effective date. Milestone: Target Dates: 4/00. 7/00. 10/00, 1/01 H. Output: Coordinate and oversee compliance essisunce/rechmcat assistancepilot program which addresses 

### community based protection. regional sectors. and measures compliance. Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 

### Hazardous Waste Analyst , . . . . . . . . . . . .. 1.00 FTE - As the DEQ RCRlS/BRS/Annual Report Technical Project Officer, provide critical technical assistance and information management for the RCR..AIHWNIA program for Idaho and the U.S. EPA. Tasks/Deliverables: RCRlS A. Output: Revise the RCRIS MOU to reflect changes in the operation and utilization of RCRIS due to transition to Oracle'from 

### Focus. Milestone: Target Date: 6/00 

### B. Output: Process and 

### maintain generator, compliance and permitting 

### information in RCRIS according to RCRlS Standard Operating Procedures. Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 C. Output: Draft RCRIS Handlers Handbook to compliment CM&E and Permitting and CA Handbooks to complete DEQ RCRIS Program Compendium. 

### Milestone: Target Dates: 9/00 D. Output: Assign EPA 

### 1.0. numbers using Handler module ofRCRIS. Milestone: 

### Tarzet Dates: 4/00, 7/00, 10/00, 1/01 . o '. E. Output: Insure smooth operation of the shared RCRIS database with Region 10. Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 

### F. Output: Participate 

### in the RCRIS/BRS National Users Conference and RCRIS Oracle System Transfer Meeting sponsored by the EPA. 

### Milestone: Target Dates: 10/99, 6100 

### G. Output: Collect federal 1999 Biennial HW Reports from Idaho Large Quantity Generators and TSDs. Milestone: Target Date: 3/00 

### H. Output: Review and perform 

### QNQC on 1999 federal Biennial HW Reports. Submit data to EPA Region 10. Milestone: Target Date: 3/00-6/00 Manage Idaho Annual Report System

--- --,**~-** --- ---,---**~-----** ----_.-.**---_._-----_._-~** 

### 6 

# c1. Output: 

### Provide technical assistance, collect and Q.-\/QC generator and commercial TSO information for the 1999 

### Idaho Hazardous 

### Waste Annual report. Milestone: 

### Target Date: 1/00 

# • J. 

### Output:
Milestone: K. 

### Output: Milestone: Prepare and compile the 1999 

### Hazardous Waste Annual Report to be 

### delivered to the Governor, legislature, regulated community and citizens of Idaho in 

### accordance with Idaho Code §39-4411 (6). 

### Target Date: 3/00 Prepare anddistribute the 2000 

### Hazardous Waste Annual Report Forms to 

### the regulated community in 

### accordance with Idaho Code §39-4411(4). 

### Target Date: 10/00



### - Outreach/Technical and Compliance Assistance L. 

### Output; Provide information and technical assistance to other state agencies, businesses, general public, educationorganizations and the media regarding Idaho's hazardous waste program. Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01


### Office Specialist II · ···.·····.·.·······················.··.· 

### i.oo FTE -As the Office Specialist II assigned to the State Waste Program Office, provide clerical support for all activities conducted through this office. 

# • A. Output:
Milestone: B. Output: Milestone: C. Output:


### Milestone: D.Output: Milestone: Design layout, format and compile high quality technical reports, letters and documents complete with graphs, tables and charts for the State Hazardous WasteProgram Office. Target Dates: 4/00, 7/00, 10/00, 1/01 

### Provide specialized, comprehensive support for the RCRIS, BRS and Annual Report functions of the State Hazardous Waste Program Office. Target Dates: 4/00, 7/00, 10/00, 1/01 

### Responsible for Monthly Time and Performance Indicator Tracking and development and compilation of the State Hazardous Waste Program Monthly Report. Target Dates: 1/00-12/00 

### Participate in development of the State Hazardous Waste Program Operation Manuals. Target Dates: 4/00, 7/00. 10/00, 1/01 

# • State Planning & 

### Special Projects 

### Office-Lf'O FTE Staff/Activities: Waste Program Planner : 1.00 

### FTE

7Responsible for coordination of all State Waste Program Planning for incorporarion into a DEQ long tarn. multi-media, environmental quality approach to 

### protect human health and the environment in Idaho for the next 25 years and beyond. Tasks/Deljverables**~.** A. Output: Represent State Waste Program Planning efforts in the State Planninz and**'--~** Special Projects Office. - Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 

### BiOurput: Complete State Waste Program related special projects as assigned. Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 - State Technical Services Program/Regional Office Staff-15. 00 FTE Staff! Activities: Hazardous Waste Technical ServiceslRegional Permitting Staff

......................... 6.00 

### FIE

- Responsible for the successful completion ofthe specific tasks identified below. Tasks/Deliverables: A. Output: Complete the permitting and corrective action tasks as outlined in the attached
..6 Quarter Plan". Attachment A. Milestone: Target Dates: 4/00. 7/00. 10/00. 1/01 

### B. Output: Provide permitting and corrective action data in accordance with. the RCRA MOA. the RCRIS 

### MOV, and RCRIS SOP's. Milestone: Target Dates: 4/00. 7/00, 10/00, 1/01 Staff Activities 

### TechnicalServices Environmental Hydrogeologist : .1.00 FTE

- Responsible for groundwater issues at hazardous waste facilities in Idaho. Tasks/Deliverables 

### A. Output: Review and provide comments on groundwater monitoring reports, permit applications, site characterization reports and groundwater studies. Provide expertise in 

### QNQC and sample collection activities. Perform site visits of HWMAIRCRA facilities, including assisting on**C~fE'** sand O&NI inspections when necessary. Milestone: Target.Dates: 4/00, 7/00, 10/00, 1/01 .. Staff! Activities Technical Services Hazardous Waste Program Specialist
. . . . . 1.00 FTE

- Responsible for insuring compliance with Applicable, Relevam and Appropriate Requirements of the federal and state hazardous waste rules regarding Superfund activities. Tasks/De

### 1 iverables 

# o

____**A~~utput:** _**Revie~~nd** provide comments**on~~I.** plan.s.**fo~ Supe~nd** **)~.emedi~~** _ 

### 8Activities at the 

### 10iEEL. Bunker Hill, and 

### Mountain Horne Air 

### Force Base**(~[HAFB)** to insure 

### that federal and 

### state hazardous waste 

### rules are identified as Applicable or Relevant and Appropriate Requirements 

# • (ARAR)

. Milestone: Target Dares: 4/00, 7iOO, 10/00, 1/01 LDR Secricn-Idaho Falls Office-I 

### FTE SrafflAcriviries: Environmental Scientist

_ .. 1.00 

### FTE Tasks/Deliverables A. Output: Activities are conducted to insure that treatment and management of hazardous waste at the INEEL 

### is done 

### in compliance with the RCRALand Disposal Restriction Program. Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 StafflActivities: Hazardous Waste Science Officer
.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6.00 PTE IaskslDeliverables: A. Output: Milestone: 

# • B. Output: Milestone: 

### C. Output:

Milestone: D. Output: Milestone: E. Output: Milestone:

F. Output: Trains new and less experienced inspectors. Target Dates: As necessary Researches, reviews and comments on technically and regulatorily complex issues. Target Dates: 4/00, 7/00, 10/00, 1/01 Conducts compliance assurance and evaluation inspections at permitted and interim status TSD facilities, generator and transporter facilities, and investigates complaint .referrals, in accordance with quarterly inspection schedule; finalizes inspection report. Target Dates: 4/00, 7/00, 10/00, 1/01 Develops enforcement actions as appropriate for facilities in non­ compliance. Participates in Consent Order negotiations. Target Dates: 4100, 7/00, 10100, 1/01 Provides all RCRIS compliance and enforcement data to the State Waste Office Specialist II for data review and processing. Target Dates: 4100, 7100, 10100, 1/01

Researches and responds to public information requests, and provide regulatory interpretations to the public and regulated community. 

# • Develops and distributes Compliance and Technical Assistance Guidance Documents. Develops workshops on specific topics
. Milestone: Target Dates: 4/00, 7100, 10/00, 1/01

9

# -------- G. Output: Provide emergency response assistance: initiates enforcementacuora 

### 11 necessary . Milestone: Target Dates: As necessary H. Output: Participates in training. seminars. and conferences. Assists in the implementation of the technical/compliance assistance inspection program. 

# c

Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 I. Output: Oversees Clean-up/Closure Activities pursuant . to Consent Order Agreements and RCRA Permits. 

### Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01
State Fiscal Office-.lO PTE Staff!Activities: Environmental Policy Analyst 0.10 FTE -Responsible for supportin drafting the federal RCRA HW GrantIWorkplan and all necessary State Fiscal Office and federal documents for submittal and approval of this grant. TaskslDeliverables A. Output: Completes federal grant application and RCRA HW Grant budget documents for submittal and approval by EPA. Milestone: Target Dates: 8/00-12/00 B. Output: Coordinates Quarterly RCRA HW GrantIWorkplan/Sites Meetings and Reviews between EPA Region 10 and DEQ Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01 C.Output: Assists with other ReRA HW administrative projects. Milestone: Target Dates: 4/00, 7/00, 10/00, 1/01



# .. L - -**---------~--------- --~-----I**  i

### •



# . ". 

# • FY 2000 INSPECTION SCHEDULE

RCR.A.. Compliance Work Plan - 6/1/99 - 12/31/00 Remainder of 2nd Quarter FFY 99 June 

### 1999 Coeur d' Alene NavalSurface Warfare Center, Bayview - FF, SQG (ID4170062182) DarwinDavis, Post Falls - TechnicalAssistance (none) Lewiston Boise Heritage EnvironmentaV Crystal Clean, Boise - Complaint (none) 

# • ESII-A, Bruneau - O&M, TSD (IDD000773952) MotivePower, Boise - O&M (IDD980976831) Twin 

### Falls Pocatello Idaho Falls 

# •

### •

3rd QuarterFFY 99 July-September Coeur d' Alene


### Lewiston Blount CCI, Lewiston - O&M (IDD009066481)

Boise

Twin Falls
Pocatello Brite-Sol Services, Pocatello - LQG (IDROOOOO0273) Idaho Falls INEEL - FF, LQG, TSD (lD4890008952)

1st Quarter FFY 00 December-March 4th Quarter FFY 99 October-December 

# 0 3-4 Re-inspections for Technical Assistance (Shop Sweep) Blount Southport, Lewiston - LQG (IDD984669424) 3-4 Re-inspections for Technical Assistance (Shop Sweep) ESII-B, Grand View - TSD 3-4 Re-inspections for Technical Assistance (Shop Sweep) 3-4 Re-inspections for Technical Assistance (Shop Sweep) 3-4 Re-inspections for Technical Assistance (Shop Sweep) 3-4 Re-inspections for Technical 

# 0 Assistance (Shop Sweep)

2nd Quarter FFY 00 April-June 

# o**~-~~----- -~-** **-------~-~- ---~--** 

# • 3rd Quarter FFY 00 4th Quarter FFY 00 July-September October-December

# ., •



# o

------------ ---**--~--~--** -**-------~~-** - ---.._- .. - .. - - '-". ----- 

### ---_. - -----------------------­ • I I Project Period: Jan'OO tnru Dec'OO I



# .. I .Position Personnel I Total FTE I azardous Waste Pro ram Administrator O.SOi 

### IHazardous Waste Program Manager 1.00 

### I I Hazardous Waste Permit Coordinator 1.001 

### IHazardous Waste Regulation & Policy Coordinator 1.001 

### IHazardous Waste Enforcement Coordinator 1.00 I I Hazardous Waste Analvst 1 001 Salarv S34.320; 562,296! 546,883 

### ! S50,606i , 550,1281 $339661 

### IOffice Specialist II 1.001 $20,800 IWaste Proaram Planner 1.00 $380851 Hazardous Waste Permit Officer (4) 4.00 S146,348 Hazardous Waste Science Officer (4) 4.00 5143,437 

### IEnvironmental Hvdrooeolooist 1.00 542640 IEnvironmental Policv Analvst 0.10 53 536 TOTAL 16.60 $073,04'5 Personnel S673,04s Frinoe Benefits (Q) 31% 

### I $208,644 Total Personnel & Frinoe 

### I $881689 

### IProiected 3% SaJarv Increase.Julv 1 

### I $13.225 Total Personnel 

### I S894 914 II Indirect 39.6% 5354386 III Suoolies\Ooeratina Rent @ $3 500 oer FTE $58100 $10 000 $20 000 $88,100

Reouired State Match (25%) 

### I 5131,167 Prooosed Budcet summarv Reouested Federal Grant $393,500 IState Contribution 

### I $943,9001**~Total** Fundlno

.... S1,337,4001 

### I v Totals 

### I I Personnel 

### I S894914 ISuoolies S88,100 [lndlrect 5354,386; Other
- 

## .sot I Total Budaet S1 ,337,400 

### ! I I I Expenses for Inspections of INEEL and MHAFB ($34,500) are captured in Personnel• 

# •v 

### • 

## 2000 

## RCRA Hazardous Waste Total Program Effort 

# • Proiect Period: Jan '00 thru Dec '00
, Total Position Personnel FTE Salarv Hazardous Waste Prourarn Administrator $34,320 0.50 Hazardous Waste Program Manager 1.00 $62296 1.00 $46883 Hazardous Waste Reaulation & Policy Coordinator Hazardous Waste Permit Coordinator 1.00 $50606 Hazardous Waste Enforcement Coordinator 1.00 $50128 Hazardous Waste Analyst 1.00 $33966 1.00 Office Specialist II $20800 $38085 Hazardous Waste Permit Officer (6) Waste Proqrarn Planner 1.00 6.00 $216778 Hazardous Waste Science Officer (6) 6.00 $216154 Environmental Hvdroaeolooist 1.00 $42640 Environmental Scientist 1.00 $45906 Technical services Hazardous Waste Pronrarn Specialist 1.00 $41,600 Environmental Policy Analyst 0.10 $3,536 22.60 $903,698 TOTAL $903698 Fringe Benefits 31% Personnel $280146 Total Personnel & Fringe $1,183844 Projected 3% Salarv Increase July 1 $17,758 $1,201 602 Total Personnel $475834 Indirect 39.6% Supplies\Operating Rent $3,500 per FTE $79100 Travel (Non-Federal Facility Inspections, Training, etc). $12,000 Supplies $1 000 Equipment $1 000 Total Supplies/Operatina $93100-
IV Other Reimbursement for Inspections of INEEL and MHAFB $34,500

:-:.'-"

.. ::::::.:::;::::::::::::::::::::::::;::::: .... .:."'"
­**·g¢~iWtQt1.lI:eiaorijijfl:Effdrt:¢b"5t$U:** :::

.......... -.....................:.:.:.:-: :':';':';';':';';'::.'.:.;. ??\:\t?}(t? ::::::::;**:::::::::::::::::::::'::}}~{** :**?}}~{: U$1~Q.$·U~**  Required State Match (25%) $131 167 Proposed Budget Summary Requested Federal Grant· ._._. - .. . '. ._-

­ . . $393,500 State Contribution $960,400 $451 136 

### i:i::r:$MSO!:Voa6 Totals Personnel $1,201,602 Supplies &Operating $93100 $475834

$34,500 Other

. :. :**:::}$.M~l)$t)a$:** VSTATE OF IDAHO DIVISION OF ENVIRONMENTAL QUALITY

Dirk Kempthorne. Governor 1410 North Hilton· Boise, Idaho 83706-1255 • (208) 373-0502 . C. Stephen Allred. Administrator 

# MEMO

To: Mark Masarik, EPA John Brueck, DEQ . From: Kirby 

### 1. Farner, DEQ 

## K'.I.J· Subject: 2000 RCRA Expenditures Date: May 26, 2000
This memorandum serves as formal documentation to the Environmental Protection Agency (EPA) that the Idaho Division ofEnvironmental Quality (IDEQ) will not be purchasing any equipment related items costing $5,000 or more 

### in calendar year 2000 

### in its RCRA program. 

# • Ifthere is a change 

### in regard to this matter, IDEQ will submit a requestto EPA for a work plan amendment that appropriately addresses this type ofexpenditure
.



# •f



### . 

# I I 0 J 

## I· • 

### ARTMENT OF HEALTH AND WELFARE



# DIVISIONI OF EN1vIRONMENTAL QUALITY

I 

# I 

# I r 

# I I 

# I**~,** J 

# \tDAHO HAJAa,DOUS WASTE 

# :. . V 1, 

# PROGRAM**~MMARY** 

# ( 

# .:»:**~.** 

# ' 1 

# I ( I

State Waste Management & Remediation Program Office April 2000 

# 1 

# ,1 

# • I I 

# .' 1 'I--I**~,**1 

# • IDAHODEQ HAZARDOUS WASTEPROGRAM SUMMARY

. CHAPTER I - HAZARDOUS WASTE STATUTES, RULEMAKlNG, AND AUTHORIZATION 1. Hazardous Waste Statutes 1 2. Hazardous Waste Rulemaking ; '. 

### 1 3. Authorization ' " 1 CHAPTER II

- STATE OFFICEIREGIONAL OFFICERESPONSIBILITIES 2 

### 1. Purpose ofHWMA and the Hazardous Waste Program , 2 2. Regional Office Responsibilities
.. ; : 2 3. State Program Responsibilities ; : , 3 CHAPTER III

- HAZARDOUS WASTE INSPECTioNS 4 1. INTRODUCTION 4 2. Summary ofMinimum Qualifications for HWMAIRCRA Inspectors 4 A. Experience 4 B. Rules Knowledge " ; 4 C. Geology and Hydrogeology Knowledge 4 D. Training " : 5 E. Other Qualifications and Abilities 5 " 3. INSPECTION PROTOCOL '.' - : .. ; 5 • 4.INSPECTIONCHRONOLOGY · 7 CHAPTER IV

- HAZARDOUS WASTEENFORCEMENT ' '
.. : 9 1. INTRODUCTION " " : 9 2. WARNING LETTERS " " ' ' 10 3. NOTICE OF VIOLATION ' 10 4. CONSENT ORDER " " 10 5. CIVIL REFERRAL 11 6. EPA'S RETENTION OF RIGHTS 12 7. TYPES OF AND EXTENT OF VIOLATIONS 12 8. PENALTY ASSESSMENT , 13 9. REPORTING OF INSPECTIONS AND ENFORCEMENT 14 10. ENFORCEMENT TRACKING LOG 14 CHAPTER V - HAZARDOUS WASTE--TECHNICAL DATAMANAGEMENT AND TRACKlNG 15 1. RCRIS " 15 2. REPORTS " ' ' 15 3. BIENNIAL REPORT SYSTEM (DRS) 16 CHAPTER VI - HAZARDOUS WASTEPERMITTING 17 

# • 1. PERMITWORK FLOW PROTOCOLS 17 2. DOCUMENTATION RESPONSIBILITY AND SIGNATORY AUTHORITY 17 A. Introduction " 17

# c B. 

### Receipt ofSubmittals ' , 17 C. Delegation ofResponsibility 17 'D. State Office Document Review , 18 

### E. Administrative Records 19 3. MINIMUM OUALIFICATIONS FOR PERMIT OFFICERS AND WRITERS 19 

## A. Knowledges,$kills, and Abilities 19 'B. Typical Duties 20 4. INTERIM STATUS PERMITS ; 20 A. Applicability ' 20 C. Modification and Termination oflnterim Status ; 21 

### D. Siting License Application 21 , 

### 5. TSD FACILITY PERMIT APPLICATION 21 

### A. Applicability '
.." 21, 

### B. Completeness Review : : '.' ". 22 C. Technical Review ' 22 

### D. Permit Drafting .: : 22 "E. Public Notice " 23 F. Final Permitting Decisions 23 6.'CLASS 1 PERMIT MODIFICATIONS , 23 ' A. Degreesffypes of Class 1 Modifications 23 B. 

### Prescriptive Time Frames 23 C. Reviews and Responses " 23 

# C) D. Tracking and Permit Maintenance 24 7. CLASS 2 PERMIT MODIFICATIONS 24 A. Applicability " 24 B. Prescriptive Time Frames 24 C. Reviews, Responses, and Tracking .............•....................... 24 D: Public Notice Requirements 25 E. Permit Maintenance , " 25 8. 

### CLASS 3 PERMIT MODIPICATIONS 25 A. Applicability 25 B. DEO Level ofResponsibility : 25 D. 

### Public Notice Requirements : 26 9. TEMPORARY AUTHORIZATIONS 26 A. Applicability ' " 26 ,B. l!evie,,:**a~d t\pp'li~atio.n**  

### . "
..**_~ :.~:**  

### _ : '. '.' . 26 C. Extensions : .- "
.. 26 10. TSD FACILITY CLOSURE

- INTERIM 8TATUS 26 A. Applicability " 26 B. Plan Review and Comment .....................................•..... 27 C. Public Notification 27 D. Follow Through , 27 E. Post-Closure
. ' " 28 

### 11. ISD FACILITY CLOSURE

- APPROVEDIPART B PERMITTED 28 

# .: A. Applicability ' "
. 28

11

# • B. 

### Plan Review and Comment
_ : .. 28 C.

_ 

### Public Notification

- - 28 D. Follow Throu&h - 28 E. HWMA Corrective Action - 29

Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Table 

### 1- Appendix 6

• Appendix 7 Appendix 8 LISTOF ApPENDICES 

### Memorandum ofAgreement between the United States Environmental Protection Agency, Region 10, and the Idaho Division ofEnvironmental Quality Hazardous Waste Inspection and Enforcement References Notice ofViolation and Consent Order Routing Processes DEQ Enforcement Tracking Log Permit Processing Timelines Permitting Flow Chart Management ofRemediation Waste Under RCRA Road Map Interim EPA Region 10 Policy for Corrective Action CleanupUndera State NonRCRA Authority in States Authorized for Corrective Action Complaint Response Policy and Flowchart



# •

111

# • CHAPTER 

### I - HAZARDOUS WASTE STATUTES, RULEMAKlNG, ANDAUTHORlZATION 

### 1.Hazardous Waste Statutes The Idaho Hazardous Waste Management Act of 1983 (HWMA), Idaho Code 

### §§ 39-4401,**~.,** 

### provides statutory authority for the regulation ofhazardous waste in Idaho. This statute provides for the adoption ofthe Idaho Rules and Standards for Hazardous Waste, and requires the rules be consistent and no more stringent than federal hazardous waste regulations. The purpose ofthe statute is to establish a hazardous waste program that will enable the State to assume primacy over hazardous waste,regulation in lieu ofthe federal government. In addition to the HWMA, the Idaho Hazardous Waste Facility Siting Act of 1985, Idaho Code 

### §§ 39-5801,**~.,** 

### was enacted to provide' a process for evaluating and establishing potential sites for the safe disposal of hazardous waste. It also provided for a State Hazardous Waste Siting Management Plan, which was approved by the Idaho Legislature on March 9, 1987. 

### 2. Hazardous Waste Rulemaking Idaho DEQ employs an incorporation by reference process to adopt federal hazardous waste regulations as State rules. Using this process, the intent ofthe Idaho Legislatureto be consistent and no more stringent than federal hazardous waste regulations is efficiently implemented. 

# • Idaho's hazardous waste rules are kept current through an annual hazardous waste rulemaking update, by which all 

### final federal hazardous waste regulations are tracked from July through June. These rules are placed into a rulemaking docketestablished by the DEQ rulemaking coordinator in the Attorney General's Section ofDEQ. This docket is presented to the DEQ Administrator inthe following July for approval and subsequent publication in the September Idaho Administrative Bulletin. The docket is then presented to the Idaho Board ofHealth and Welfare for approval as a pending rule 

### inNovember. Upon approval by the Board, the rule is 

### publishedin.the January Idaho Administrative Bulletin. The rule is then presented to the Idaho Legislature's Senate Health and Welfare Committee and House Environmental Affairs Committee. If

### no objections are made by the . Legislature, the rule becomes final and effective upon the last day ofthe Idaho legislative session.



### 3. Authorization Authorization is the process by which EPA Region 10 evaluates the equivalency of Idaho's --hazardouswasteprogram-The

### AuthorizationstatusofIdaho'sprogram is updated every two to three

years. Authorization Applications submitted to EPA by the State include many documents, among them the Program Description,the Resource Conservation and Recovery Act (RCRA) Memorandum ofAgreement between EPA Region 10 and Idaho DEQ; and the Idaho Attorney General's Statement confirming that Idaho's hazardous waste statutory and rule authority is equivalent to the federal government. At 

### thispoint, Idaho has received full Authorization from EPA Region 10 to implement 

# • all aspects ofthe program through June 30, 1996.

Idaho Hazardous Waste Program Summary

-- March 2000 1CHAPTER 

### II - STATE OFFlCEIREGIONAL OFFICE RESPONSIBILITIES 

### 1.Purpose ofHWMA 

### and the Hazardous Waste Program The goal ofthe Idaho Hazardous Waste Management Program is to ensure that hazardous waste is properly managed, stored, treated, transported, and disposed. Proper handling will prevent harmful releases to the public and environment ofIdaho. The laws in place ensure that when hazardous waste releases do occur, they are mitigated by HWMAlRCRA Corrective Action, emergencyresponse, and compliance measures. The goal ofan enforcement action is to return the facility to compliance as quickly

### as possible and deter future violations. The removal ofeconomic advantage or savings accruedby noncompliance is part ofthe goal ofpenalties. 

### 2. Regional Office Responsibilities The DEQ Regional Offices (RO) are responsible for completion of their assigned Work Plan inspections and complaint response in their area ofthe State. Inspections can be conducted by RO staffwho meet the minimum requirements for a HW Inspector or by contracting with Technical Services (TS) for appropriate inspection 

### staff. The RO stafforcontracted TS personnel conduct inspections in accordance withapproved inspection

# C~ protocol. The inspector(s) completes a narrative inspection report and determines ifany and what. specific type.ofviolation were observed at the facility. Based on the findings ofthe inspection, a recommendation is made in a memorandum from the inspector through the appropriate RO managementto the State Office (SO) Hazardous Waste (HW) 

### Enforcement Coordinator. Enforcement options may be discussed among RO staff, TS, and SO staffpriorto settling on a final recommendation. Ifnecessary, discussions should include a Deputy Attorney General (DAG). Ifno violations are observed, the appropriate recommendation is for no enforcement. If violations are observed, many factors need to be considered in the enforcement discussion. Such factors are the numbers ofviolations, types ofviolations, recalcitrance, and the facility's hazardous waste status (i.e., Conditionally Exempt Small Quantity Generator, (CESQG),Small Quantity Generator,(SQG), Large Quantity Generator (LQG),Treatment Storage or Disposal (TSD) facility, HW transporter).

____... RQ**~~ff ar~** **re~ponsible** 

### for**tiInelY_J~view_and_comments-on_alL** 

### enforcement-documents-for-their regions according to the enforcement review chart (see Appendix 3). RO staff may suggest Supplemental Environmental Projects (SEPs) for facilities interested in penalty mitigation. RO staff 

### are responsible for overseeing implementation ofthe terms and conditions ofConsent Orders once they are signed. When the facility has completed the work required under the Consent Order, RO staffnotify the State HW Program Manager to have the Consent Order 

### terminated, Ifa facility does not meet its obligation under the Consent Order, the RO staffis responsible for referring the facility (; to the SO for further action. .../ )

Idaho Hazardous Waste Program Summary

-- March 2000 2

# • 3. State Program "Responsibilities The SO is responsible for negotiating EPAlState inspection targets and schedules after consultation with the regional offices. When an enforcement recommendation is received by the HW Enforcement Coordinator, the recommendation is reviewed to determine further action. 

### Ifthe Coordinator disagrees with the recommendation or needs more information, the appropriate RO will be contacted for discussion. The SO's enforcement decisions will consider ensuring statewide consistency and compliance with EPA requirements
.. Once a decision is made to proceed with enforcement, the HW Enforcement Coordinator contracts with TS to develop the enforcement documents and oversees the development and review ofthe enforcement documents. Review ofthe enforcement documents is conducted by the HW Program Manager, RO staff, and a DAG. If a Notice ofViolation (NOV) is issued, the HW Program Manager conducts the compliance conference and leads the negotiations. The RO Will participate in all activities up to and including the compliance conference and participate in the proposed resolution ofthe enforcement action. All RO contacts with the facility regarding pending or ongoing" enforcement action shall be "communicated to the SO. 

# • Consent Orders are developed by TS, under contract, and reviewed by the HW Program Manager, RO "staff, and a DAG. The terms and conditions or:the Consent Orders are negotiated with the facility by the SO and the DAG. When the Consent Order becomes effective, copies are sent to the facility and the appropriate RO for oversight. Terminations ofConsent Orders are performed by the State HW Program Manager. The SO is also responsible for Legislative and Rulemaking activities as well as Authorization and Grant/Work Plan activities with EPA Region 10. Technical HW Data Management and Tracking activities are also the responsibility ofthe SO. The SO solicits input from TS and the RO for all of these activities, and depends on these groups to supply necessarydata entry forms for theRCRA activities tracked in the Resource Conservation and Recovery Information System, ( RCRIS)
.


# •
Idaho Hazardous Waste Program Summary

-- March 2000 

### 3CHAPTER

### III - HAZARDOUS WASTE INSPECTIONS 

# c 1.INTRODUCTION ROs are responsible for initiating and completing hazardous waste inspections as agreed to in the Work Plan negotiated with EPA, investigating hazardous waste complaints received by DEQ, and other special projects determined to be necessary forprotection ofhuman health and the environment in the region. Protocols and requirements for inspectors, inspections, report writing, enforcement referrals, and enforcement procedures are outlined in many documents and agreements (see references in Appendix 2). Time frames for the inspection and enforcement procedures are established by many ofthese same documents. The following is a general summary ofthe inspection requirements. Enforcement requirements are discussed in Chapter IV ofthis summary. 

### 2. Summary ofMinimum Qualifications for HWMA/RCRA Inspectors A. Experience A candidate inspector must have a minimum oftwo years.full-time, experience in conducting HWMA and/or RCRA inspections, or a minimum of30 facility inspections including five TSD facilities, five LQG, and ten SQG inspections. Technical Assistance must have beenprovided to half the 30 facilities in whole or part ofthe inspection. Ifthe candidate inspector does not meet the minimum inspection experience, a minimum oftwo years, full-time, mentoring by a HWMAlRCRA inspector must be obtained. The mentor must have at least three years, full-time (/""'/' experience. The mentoringmust include the above minimum numbers and types ofinspections , and the candidate inspector must lead two TSD facility, two LQG, and five SQG inspections while being rnentored: Based on recommendations ofthe mentor, the mentoring period may be shortened or lengthened as appropriate. The two years, full-time, experience may be 

### accumulated over a period ofseveral years. 

### B. Rules Knowledge A candidate Inspector must have a good working knowledge ofthe Idaho.Rules and Standards for Hazardous Waste,IDAPA 16.01.05.000 to .999, the HWMA, Idaho Code, Title 39, Chapter 44, the Idaho RCRA Program Documentation manual, the federal RCRA regulations, 40 CFR Parts 260'-279, the Enforcement Procedures Manual, and any appropriate HWMAJRCRA authorized facility operating permit. The candidate inspector must be able to apply all appropriate .policies, rules, standards and regulations to afacility

### duringaiiinspection and 

### the report writing phase including generator standards, interim status or permit conditions, transporter standards, recycling standards, Land Disposal Restrictions, Universal Waste standards, and Used Oil Management standards. The candidate inspector must be able to cite 'the appropriate applicable rules and regulation(s) with the supporting statement offact. C. 

### Geology and Hydrogeology Knowledge A 

### candidate inspector must have some knowledge of geology and hydrogeology principles relative to dispersalofhazardous waste, planning and conducting environmental audits, scientific 

# C'''\ '

4 

### Idaho Hazardous Waste Program Summary

-- March 2000

- ---,

### studies, developing action plans, industrial standards and waste stream determination, and treatment methods for hazardous waste. 

### . D. 

### Training A candidate inspector must have attended the following training courses or courses covering the following or their equivalent:

• Personal Safety and Protection [OSHA 1910.120] 40-Hour Course, with annual 8-Hour Refresher courses • Radiological Protection and Measurement • Basic Inspector. Course • Advanced RCRA Inspector Course • Air Surveillance for Hazardous Materials Course • Sampling for Hazardous Materials • Sampling Techniques, including Chain-of-Custody procedures • Pollution Prevention for Inspectors Training Course • Land Disposal Restrictions Course • EPA Publication SW-846 Training • The Resource Conservation and Recovery Act Inspection Manual Having training in the following is beneficial for candidate inspectors also: 

# • • Dealing with Upset Citizens • Negotiations • . Dealing with the Media (press) • Report Writing • Risk Communications • Explosives/Drug Lab 

### E. Otber Oualifications and Abilities A candidate inspector must have baseline and periodic medial monitoring, conduct inspections using ·DEQ or EPA developed checklists, perform field work, report all findings in a written document including citations for violations, serve as an expert witness in either civil or criminal court proceedings, recommend DEQ enforcement or facility response actions, provide technical reviews ofenvironmental docwnents and reports, provide technical assistance to the public and DEQ staff, have a valid driver's license, and act as liaison and 'coordinate with other agencies, - .the media, and the regulated public. 

### 3. INSPECTION PROTOCOL. At DEQ, six (6) Hazardous Waste (HW) 

### Inspectors and the HWEnforcement Coordinator are devoted to fieldinspection activities. Prior experience ofstaffincludes, on the average, several 

# • years of RCRA, SuperfundlCERCLA, and general environmental sampling and inspection experience. As part ofinitial training, new inspectors are paired with senior compliance officers for the purposeofmentoring. This allows for the maintenance ofconsistency in the interpretation Idaho Hazardous Waste Program Summary

-- March 2000 5

# C and application of the HWMAlRCRA regulations and familiarizes new staff with DEQ's

.inspection and enforcement role. HW Inspectors gain access to facilities or sites upon a presentation ofcredentials signed by the Director ofIdaho Department ofHealth and Welfare. 

### [34] DEQ's HW Inspectors have the authority to inspect a facility for the purpose ofascertaining compliance with the hazardous waste laws. All inspections include evaluation ofprocesses and their associated waste streams in addition to the review of product data to determine characteristic properties ofthe waste. Often samples ofwaste streams are collected for analysis to verify the accuracy ofthe generator's waste characterization. Inspections also include the evaluation of quantities of wastes generated, accumulated, or stored on-site to determine regulatory status. [12,32] The most comprehensive inspection presently performed by DEQ HW Inspectors are at land disposal facilities (e.g., Envirosafe Services ofIdaho.Inc., (ESII ) - Site B) and federal facilities (e.g., Idaho National Engineering and Environmental Laboratory, (lNEEL). At these facilities, an annual inspection is performed by DEQ to scrutinize all aspects ofoperation including, but not limited to: waste identification, analysis and record keeping, contingency and emergency planning, personnel training and protection, spill containment, equipment integrity, operational procedures, groundwater data assessment and sampling, manifest checking, and waste disposal record keeping. Where the regulated unit has a permit, the annual inspection also includes verification ofcompliance with all permit-specific requirements. [32] At least biennially, DEQ inspects every interim status or permitted non-federal TSD facility. Inspections that reveal violations of EPA regulations the State has not yet adopted will be referred to EPA for further action, the exception being for State-issued warning letters that request compliance with the noted EPA regulations. [5] Each year, designated EPA and DEQ personnel actively-participate in selectedjoint inspection processes. In such cases, the DEQ HW Inspectortakes the lead, except when mutually agreed otherwise. [21] Compliance inspections are conducted to respond to a complaint or as part of the regularly scheduled inspections negotiated annually with EPA through the State Grant Work Plan. 

### [32] Inspection priorities are determined by EPA's RCRA Implementation Plan (RIP), current EPA policy directives, and DEQ-established initiatives or priorities. Situationsin which DEQ must initiate 

## an immediate response to a release or possible release ofhazardous waste that may impact human health or the environment are given an immediate priority. Non-emergency -insp-eCfion .activities**~e** 

### negotiated -lif"the begInning of each-federal- fiscal year.---These·

negotiations include the identification and scheduling ofTSD facility inspections and the total number of(unnamed) generator inspections. One month prior to the beginning ofeach federal fiscal year quarter, all scheduled generator inspections are identified by DEQ and submitted to EPA-Idaho Operations Office. [33]

Idaho Hazardous Waste Program Summary

-- March 2000 6

# • 4. INSPECTION CHRONOLOGY A facility inspection may 

### beconducted 

### in a few hours or over several days. The first day ofthe inspection is considered Day Zero and many time frames are established from that date. An 

### inspector should give the facility as much writteninformation as possible describing known or suspected violations and concerns by the final day ofthe inspection. This information may be in the form of prepared and completed inspection checklists. Although a more complete inspection report will be completed and further violations may be identified later, DEQ is committed to giving the facility as much written information as soon as possible to assist in a prompt return to compliance. Day 0 - The first day ofthe facility inspection, or the first date that DEQ knew ofor should reasonably have known ofa violation. This is the date ofinspection entered into the RCRIS database for tracking ofinspections and enforcement
.. After a field inspection, the HW Inspector assures the inspection checklists are complete, prepares the Narrative Inspection Report, develops and catalogues photographs, submits samples for analysis, requests additional information and documentation from the facility as necessary, reviews the additional documentation upon receipt, and determines violations. [37] 

# • Day 35 - A draft inspection report will be completed within 35 days from Day Zero. [21] pay 45 - Within 45 days from Day Zero, the written inspection report will he finalized. [21, 60, 64] 

### Ifno violations are .observed a finalized copy ofthe inspection report is mailed to the facility for their records. Ifviolations are observed a fmal copy ofthe inspection report is mailed to the facility later with the enforcement document.

. . 

### Upon finalization of the inspection report, the lead inspector makes an initial determination ofthe compliance status ofthe facility based on his or her evaluation of the information collected through the inspection process. The lead inspector prepares a written summary of all apparent or potential violations, describing the factual evidence supporting the violations(s), and recommending appropriate enforcement action to the HW Enforcement Coordinator using established memorandum format. [68] -v-Day 50- A draft WarningLetter (WL) or Notice ofViolation (NOV) is prepared for the SO by contracting with 

## TS. The draft is circulated to the appropriate RO and Attorney Generals' Office (AG's Office) by the SO for review. Day 53 - All responses from the appropriate RO, the AG's Office and SO for the WL or NOV areincorporated, as appropriate. 

# • Day 55 - The final WL or NOV is submitted to SO upper management for signatures. [38]
Idaho Hazardous Waste Program Summary

-- March 2000 7

### Day 56 - A fmal WL is signed by the HW Program Manager and sent, by certified mail from. the SO with a copy ofthe inspection report, to the facility. A fmal NOV is circulated to the DEQ Administrator for signature. [38]

### C~· /' Day 59 - A final NOV, signed by the DEQ Administrator, with a cover letter, and copy ofthe final inspection.report are sent from the SO, by certified mail, to the facility. The Facility is required to respond within 15 days ofreceipt ofthe NOV. [38] At this point, the date ofreceipt ofthe WL or the NOV becomes Day Zero and determines the

. time frames for both the facility and DEQ to complete the enforcementprocess (See ChapterIV ­

Hazardous Waste Enforcement).

Idaho Hazardous Waste Program Summary

-- March 2000. 8

# • CHAPTER

### IV

- HAZARDOUS WASTE ENFORCEMENT 

### 1. INTRODUCTION 

### DEQ has agreed to take timely and appropriate enforcement action in accordance with specific time lines as projected in the Compliance Assurance Agreement and annual State Grant Work Plan with EPA. Enforcement actions are brought against all persons in violation ofgenerator and transporter standards (including manifest requirements), facility standards, permit requirements, compliance schedules, and all other program requirements. [5] It

### is understood the State will address all violationsofthe HWMA and the Hazardous Waste Rules within the State'sjurisdiction. It 

### is further understood that while the State's authority, policy, and procedures for enforcement are not identical to EPA's, any State action will be consistent with the EPA Enforcement Response Policy and the HWMA Civil Penalty Policy. [22] . The identification, processing; and final resolution ofan enforcement action follows a step-by-step chain ofevents that is repeated for every instance ofnon-compliance. These events are listed in chronological order. 

# • Post Inspection Records and Information Review: After a field inspection, the HW Inspector assures the inspection checklists are complete, prepares the Narrative Inspection Report, develops and catalogues photographs, submits samples for analysis, requests additional information or documentation from the facility; as necessary, reviews the additional documentation upon receipt, and determines violations. FacilityNotification: In accordance with EPA's Enforcement Response Policy of 1996 (ERP) guidelines, a facility is notified ofnon-compliance by the following: a WL, NOV, orjudicial complaint. [36] Warning Letters are drafted by IS for signature and sending by the DEQ SO. NOVs are drafted by ISfor signature and sending by the SO. Judicial complaints are drafted and filed by the AG's Office. The decision as to which ofthese.enforcement mechanisms should be used in a particular case rests with the SO with input from ROs and AG's Office. The lead role in 

### compliance conference negotiations is held by the HWProgram Manager. File notes are drafted by the HW Inspector to document negotiations and additional information provided during the compliance-conference. 

### All enforcement activities aretrackedbytheHW Inspector and documented in RCRIS. [42] UnderIdaho's statueoflimitations, nocivil or administrative proceeding may be brought to recover . for a violation more than two years after DEQ had knowledge or ought reasonably to have had knowledge ofthe violation. [17, 43] I .



# •
Idaho Hazardous Waste Program Summary

-- March 2000 9

### 2. WARNING LETTERS 

# (j Day 0 - The WL is received by the facility. This date is determinedby the "green card" indicating the date and signature for the certified mail. Day 15 - The WL provides that DEQ shall receive a written response within a specified time frame. If 

### the written response is not adequate, further written or verbal correspondence will be initiated by DEQ. [70]
. Day 60 - Ifthe response does not result in expeditious compliance, normally within 30-60 days ofissuance, DEQ State Waste Management 

### & Remediation staffwill consider whether the violation warrants issuing an order or NOV. -[62] 

### 3. NOTICE OF VIOLATION The Notice ofViolation (NOV) shall identify the alleged violation Withspecificity, with citations ofeach provision ofthe act, rule, regulation, permit or order that has been violated, and state the amount ofcivil penalty claimed for each violation. [14] Day 0 - The NOV is received by the facility. This date is determined by the "green card" indicating the date and signature for the certified mail. Day 15- The NOV shall inform the person to whom it is directed ofan opportunity to confer with the DEQ in a compliance conference concerning the alleged violations. A response may be required within 15 days of receipt ofthe NOV by the person to whom it was directed. [8, 14,41, 70]
. Day 20 - If

# arecipient ofa NOV contacts the department within 15 days ofthe receipt ofnotice, the recipient shall be entitledto a compliance conference. The conference shall be held within 20 days ofthe date ofreceipt ofnotice, unless a later date is agreed upon between the parties. If

### a compliance conference is not requested, DEQ may proceed with a civil enforcement action. [8, 15, 70, 71] 

### 4. CONSENT ORDER Timeframes for**C~n~_ellt** 

### Orders**.~<:mtiI1uet<?** 

### initiate from 

### the dateofthe Facility's receipt ofthe NOV.
. Day 25 - A draft 

### Consent Order (CO) is prepared by TS 

### forthe SO. The SO distributes the draft 

### document to the appropriate RO and the Attorney Generals' Office for review and comment. . Day 28 - The CO is revised and, finalized with input from ROs, AG's Office and SO as**C~'\** 

### appropriate.
. 

### --.---I
Idaho Hazardous Waste Program Summary

-- March 2000 10

# • Day 30 - A final CO and cover letter is submitted to the SO uppermanagement for review.· [39] Day 31 - A final CO cover letter is signed by the HW Program Manager and sent, by certified mail by the SO, to the facility for review and comment. [38] At this point, the date ofreceipt ofthe CO for review by the facility sets some ofthe time frames. Day Zero becomes the date the CO was received by the facility for review. Day 0 - The CO, for review, is received by the facility. This date is determined by the "green card" indicating the date and signature for the certified mail. Day 15 - The facility sends a written response to DEQ. [70] Day 18 - The SO reviews the facility's response and solicits comment from the appropriate RO and the Attorney Generals' Office, as appropriate. Day 21 - The CO is revised, as appropriate. Day 24 - A signature CO and cover letter is submitted to the SO upper management for review. [39] Day 25 - A signature CO cover letter is signed by the HWProgram Manager and sent, by certified mail by the SO, to the facility for signature. [38] ..• Day 30 - The signed CO is returned to the SO from the facility. Day 31- The facility-signed CO is submitted to the DEQ Administrator for signature. [70]· Day 34 - The signed and effective CO is returned to the SO. A copy ofthe effective CO is sent to the facility by the SO and to 

### the appropriate RO for oversight. Day 180 - The 180-day [from the date of the compliance inspection] time frame has been established by the SO as an outside limit to the negotiation process In an effort to establish what the SO believes is a reasonable time frame for negotiation ofa CO. This 180-day time frame is also consistent with EPA's April 15, 1996, Civil Enforcement Response Policy (ERP) for the RCRA Program. [70] In most cases, these time frames should be met. In the current ERP, a ceiling of 10% per year is established as the number ofcases allowed to exceed standard ERP time frames. [63] 

### 5. CIVIL REFERRAL 

# • Day 0- Ifthe parties cannot agree on a consent order withiri 60 days after the receipt ofthe NOV, or ifthe recipient does not request a compliance conferencepursuantto Idaho Code § 39-
Idaho Hazardous Waste Program Summary

-- March 2000 11- - 4413 (A)(1)(b), the AG's Office may commence and prosecute a civil enforcement action 

# C) in district court. [9, 16,42, 70] _ Day 60:- Ifajudicial referral is made to the AG's Office, it is expected that the case will be filed within 60 days ofreferral. [60,61,66] Day 731 - No civil or administrative proceeding may be brought to recover for a violation of HWMA or any permit, standard, regulation, condition, requirement or order issued or promulgated pursuant to HWMA more than two years after DEQ had knowledge or ought reasonably to have had knowledge ofthe violation. [17,43]

- ­ 

### 6. EPA'S RETENTION OF RIGHTS EPA has a right to inspect any hazardous waste generator, transporter or TSD facility or bring enforcement action against any person believed to be in violation ofthe state or federal hazardous waste program or believed to have a release of hazardous waste or constituent. If a person is determined to be in violation ofHWMA, in accordance with 3008 (a)(2), EPA may directly bring an enforcement action upon request by the State or upon determining that the State has not taken timely and appropriate enforcement action. [4,22] IfEPA determines that DEQ is not adequately administering and enforcing a program, the authority for DEQ to implement the program may be withdrawn after aprocess is followed. [4,56] 

### 7. TYPES OF AND EXTENT OF VIOLATIONS EPA's RCRA Enforcement Response Policy classifies individual facility violations into oneoftwo categories. Class 1 Violations

- Deviations from regulations, or provisions ofcompliance orders, consent agreements, consent decrees, or permit conditions that could result in a failure to: a) assure that hazardous waste is destined for and delivered to authorized TSD facilities; or b) prevent releases ofhazardous waste or constituents, both during the active and any applicable post-closure periods ofthe facility operation where appropriate; or c) assure early detection ofsuch release; or d) perform emergency cleanup operation or other corrective action for releases. Class 2 Violations

- Any violation ofaHWMA requirement that does not meetthe criteria listed above for Class 1 violations.**[5~,** 

### 69] The hazardous waste handler is classified as a violator based upon the nature ofthe violation(s)

-**_~** along with a numberof**~~er** factors**J~~g~,_c<:>mpli_~~~e N:s~~ry,_pre~ious_re~alciJt:~!J:>~hav!Qr,-etc.).**  The EnforcementResponse Policy establishesthree categories ofviolators

- High, Medium, and Low Priority Violators. I. High Priority Violator (HPV) • Caused actualor substantial likelihood ofexposure • Chronic or recalcitrant violator • 'Deviates from timely meeting ofrequirements in a permit, order, or decree -• Substantially deviates from statutoryorregulatory requirements. 2. Medium Priority Violator (MPV) • A handler with one or more Class 1 violations who does not meet the criteria for HPV. Idaho Hazardous Waste Program Summary

-- March 2000 12

# • Handlers with only Class 2 violations may also be MPV when the compliance officials deem an administrative action is appropriate. 

# 3: LowPriority Violator (LPV) A handler with only Class 2 violations who is not an HPV or MPV. An 

### LPV will normally receive a WL as the initial response. [59, 69] Facilities designated as Significant Non-Compliers (SNC) are the first violators subject to enforcement action, followed by other HPVs. HPVs represent the most serious violators and consequently should receive the swiftest and most stringent enforcement response available. Every - HPV should be the object ofa formal enforcement action as well as penalized with an economic

sanction or penalty. Examples ofappropriate HPV enforcement response actions includejudicial or administrative impositions ofcivil penalties against the corporation as well as, where appropriate, responsible corporate officials or temporary or permanent shutdown of the hazardous waste management activities at the facility. [59,69] 8. PENALTY ASSESSMENT

­ 

# • The HWMA Civil Penalty Policy is used to calculate penalties for all HWMA administrative actions instituted. The purpose ofthe Policy is to assure that HWMA civil penalties are assessed fairly and consistently, that penalties are appropriate for the gravity ofthe violation committed, that economic incentives fornoncompliance with HVfMA are eliminated, and that compliance is achieved; [24,69] Idaho Code 

### § 39-4414 states that the seriousness ofthe violation must be taken into account in assessing penalties. The seriousness ofthe violations is measured by potential for harm and extent ofdeviation from a statutory or regulatory requirement. [25,69] In certain situations, DEQ may fmd that aparticularfacility has violated several HWMAregulations. A separate penalty is assessed for each violation that results from an independent act (or failure to act) by the violator and is subsequently distinguishable from any other act (or failure to act) in the NOV. A given act is independent of, and subsequently distinguishable from, any other-act when it requires an element ofproofnot needed for the others. In many cases, violations ofdifferent sections ofthe regulations constitute independent and subsequently distinguishable violations. 1t is also .possible that different violations ofthe same section ofthe regulations could constitute independent and distinguishable violations. Multiple penalties should be assessed when one facility has violated the same requirement in different locations. HWMA provides the authority to assess maximum civil penalties ofup to $10,000 per violation per day, with each day that noncompliance continues to be assessed as a separate violation. The HWMA Civil Penalty Policy mandates the consideration ofthe economic'benefit ofnoncompliance to 'a violator-when penalties are assessed. [26, 69] An administrative penalty may be adjusted upward for willfulness or negligence. In assessing the - degree ofwillfulness or negligence, the following factors should be considered, as well as others

deemed appropriate: how much control the violator had overthe events constituting the violation, the foreseeability ofthe events constituting the violation, whether the violator took reasonable 

# • precautions against the events constituting the violation, whether the violator knew or should have known ofthe hazards associated with the conduct, and whether the violator knew ofthe legal requirement that was violated. It should be noted that this last factor; lack ofknowledge ofthe legal Idaho Hazardous Waste Program Summary

-- March 2000 13

### requirement, should never be used as a basis to reduce the penalty. To do so would .encourage () ignorance ofthe law. Rather, knowledge ofthe law should serve onlyto enhance the penalty. [28] Where a party has previously violated hazardous waste requirements at the same or different site, this is usually clear evidence that the party was not deterred by the previous enforcement response, unless either violation was caused by factors entirely out ofthe control ofthe violator. Recalcitrance is a basis for upward adjustment of.a penalty. 

### [29,69] DEQ generally will not insist on the payment ofpenalties that are clearly beyond the means ofthe violator. DEQ may consider the ability ofthe violator to pay the penalty. At the same time, it is importantthat the regulated communitynot see the violation ofenvironmental requirements as a way to aid a fmancially troubled business. It

### is unlikely, for example, that DEQ wouldreduce a penalty for a facility refusing to correct a serious violation with a long history ofprevious violations: [30, 

### 69] 9. REPORTING OFINSPECTIONS AND ENFORCEMENT DEQ has agreed to classify and report violators, including high priority violators, in accordance with EPA's Enforcement Response Policy. All State inspection and enforcement activity is reported by the State in the RCRIS database. Timely and thoroughreporting ofHWMA activitiesby the regional offices to the State Program is critical to this process. [23]. 

# C) 10.ENFORCEMENT TRACKING LOG The Enforcement Tracking Log is a internal data log that tracks ongoing enforcement actions and consent orders. It is maintained by the HW Enforcement Coordinator. An example ofthe logis attached as Appendix 4.



# ()

Idaho Hazardous Waste Program Summary

-- March 2000 14

# • CHAPTERV - HAZARDOUS WASTE TECHNICAL DATA MANAGEMENT AND TRACKING 

### 1. RCRIS RCRlS is a technical database that tracks hazardous waste generators and hazardouswaste permitted facilities by their HW Identification Numbers. 

### It also tracks', and can provide reports about, hazardous waste permitting, inspections, and enforcement at these facilities. Hazardous waste generatorsmust obtain a hazardous waste identificationnumberwhenthey generate and dispose more than 

### 220 pounds ofhazardous waste in a month. The 

### form for obtaining this number can be obtained by contacting the SO HW Analyst and requesting the EPANotification of Regulated Waste Activity Booklet, EPA Form 

### 8700-12. DEQ provides assistance in completing the form and then assigns an EPA Hazardous Waste Identification Number to the hazardous waste generator. A hard copy acknowledgment letter is sent to the generator for confirmation. HW Inspectors and Permit Officers are responsible for completing RCRIS data entry forms for submissionto the SO HW Analystto record their inspection, enforcement, permitting, and corrective action activities. ROs may call the SO for any guidance,"fonns and information they may need. Trainingwill be provided to the ROs when necessary for completion and submittal ofthese 

### forms, 2. REPORTS 

# • As required by the HWMA, Idaho Code 

### § 39-4411, by January 

### 30 of each year, generators of hazardous waste (large and small quantity), must submit to DEQ an annual report that details the types and quantities ofhazardous waste generated, stored, treated, landfilled, incinerated, or recycled and whether these activities occurred in or 

### out-of-state. Also, commercial disposal facilities must furnish an annual report detailing thetypes and quantities ofwaste received and its origin. Annual Report Forms with instructions are mailed from the SO in October. Reminder letters and assistance are provided to the generators to help them complete their reports on time. Once the 

### Annual Reports are received by DEQ they are checked for accuracy. and compiled into the annual DEQ Hazardous Waste Management Report. Idaho Code 

### § 39-4411 directs this report be submitted to the Governor and Legislature by March 1. This report details types and quantities of hazardous wastes generated, stored, treated, landfilled, incinerated or recycled in this state, types and quantities wastesgenerated in Idaho and shipped out of state, and types and quantities ofwaste --generated inother-states sent to-Idahofor 

### treatmentanddisposal, 3. BIENNIAL REPORT SYSTEM (DRS) The BRS is a federal report that tracks hazardous waste generation, storage, treatment, and disposal activities in odd numbered years. his required ofLQGs and TSD facilities. EPA Form 

### 8700-13A/B 

# • is sent to the LQGs and TSD facilities by the SO in Decemberofthe odd numbered year and is due by March 1 ofthe next even numbered year. DEQ provides assistance to LQGs and TSD facilities in completing their federal Biennial Reports. Once completed reports are received, DEQ checks the Idaho Hazardous Waste Program Summary

-- March 

### 2000 15

# 0 reports for accuracy, compiles the data, and submits the informationto EPA Region 10 by July 1 for incorporation into the EPANational Biennial Hazardous Waste Report.



# ()

Idaho Hazardous Waste Program Summary

-- March 2000 16CHAPTER

### VI - HAZARDOUS WASTE PERMITTING 

# e· 1. PERMIT WORK FLOW PROTOCOLS The HWMA permitting staffare specifically trained and have sufficient experience in hazardous waste management to review submittals, draft permits, and responses and conduct other required activities associated with HWMA permitting. However, due to the interpretive nature ofthe HWMA and the various expectations ofEPA in accordance with the Memorandum ofAgreement between the State"ofIdaho andthe United States EPA Region 10 (MOA), the HW Permit Coordinator must review and approve all substantive correspondence generated by TS and the responsible RO to assure regulatory, policy, and procedural consistency. The MOA is included as Appendix 1 to this summary. A procedure for review ofHWMA permitting documents is presented in the section entitled 

### State Program Document Review. Regional offices with HWMA responsibilities are expected to coordinate management ofadministrative records and files (to be maintained at the State Office) relative to any HWMA involvement. This type ofdocumentation can be maintained by HWMA permitting staffavailable through TS. 

### 2. DOCUMENTATION RESPONSIBILITY AND SIGNATORY AUTHORITY 

# • A. Introduction Idaho's HWMA permitting program; since its authorization inception on April 9, 1990, has operated as a centralized program. Recently, the SO has transferred specific components of responsibility associated with implementation ofIdaho'spermitting program to the ROs. Due to the complexities associated with 

### HWMA implementation, the SO will continue to be involved in the day-to-day implementation ofHWMA permitting intheState ofIdaho. This section ofthe Summary is intended to define the roles ofthe SO, ROs, and the subcontractors.
. 

### B. Receipt of Submittals Nearly all correspondence required by the HWMA, and the respective permits, must be submitted to the Director ofIdaho's Department ofHealth and Welfare (DHW). This submittal requirement hasbeen delegated from the Director ofthe DHW to the Administrator ofDEQ. Generally, permit and regulatory required documents are received by either the Program Administrator or the HW Program Manager. Upon receipt, the documents will be 

### date stamped, .and forwarded through the HW Permit Coordinator for work assignment (in the case ofINEEL permitting) or distribution to 

### -theresponsible RO staff. Due to the many prescriptive time frames, and the tacit approvals that may result, responsible staffwill need to make themselves aware ofany applicable time frames. In the event technical staffor consultants are not able to provide such input, the SO can assist. 

# • C. Delegation ofResponsibility The Six Quarter Plan is a work plan managed by the SO and EPA Region 10. It identifies completed work and outlines future work for specific TSD facilities in the State. Although this Idaho Hazardous Waste Program Summary

-- March 2000 

### 17

### plan generally identifies much ofthe anticipated work for a given facility, it does not identify 

# ( J

# ) all ofwhat may come from the permittee in the way ofpermit modification requests and requests for regulatory assistance. Often these efforts are recorded as completed activities in the Six Quarter Plan, but that is not always the case. SO staffand EPA Region 10 representatives meet quarterly to discuss funding-related commitments, program implementation concerns, and revision ofcommitments documented in the Six Quarter Plan. The resources for completion ofall HWMA permitting activities for TSD facilities in Idaho have, with the exception ofINEEL, been passed to the RO where those facilities are located
.

.Therefore, it is the responsibility ofRO staffto ensure that all Six Quarter Plan commitments

and any other TSD facility permit-related activities are completed in a timely fashion, in accordance with the requirements ofthe HWMA, and as agreed to between the SO and EPA Region 10. 

### D. State Office Document Review All HWMAIRCRA permitting related letters, permits, modifications, or any other written materials for public distribution, produced by or at the direction ofRO staffis subject to review by the SO. This review will ensure consistent State policy regarding the HWMA, adherence to regulatory requirements, and work prioritization consistent with any commitments made to EPA Region 10. To ensure timely response to the regulated community, materials subject to review by the SO must be provided in advance ofresponse deadlines. This will allow for comprehensive review and any necessary modification prior to DEQ action. The following is a general guideline as to

### (~\ _/ the time necessary for such review:

Draft Permits

.Class 3 Modifications Class 2 Modifications Class I Modifications Draft Closure Plans Temporary Authorizations Report Reviews . . 30 days

30 days 10 days 10 days 30 days 10 days

7 days To ensure responsiveness to the regulated community and understanding of constraints associated with lengthy or technically burdensome documents, adjusting thesetime frames case­ by-case may be necessary. The SO will conduct monthly or bimonthly reviews of expenditures associated' with implementation ofall DEQ HWMA permitting activities in the State ofIdaho. Reallocation of HWMA permitting funds may be necessary based on the level ofactivity in each region. Due to the fact that HWMAIRCRA funding has remained static, the SO may need to reduce or even halt permitting activities within regions to ensure that the overall statewide HWMA program 

# ·C). ' budget is not exceeded. Such decisions will consider EPA grant commitments, protection of

­ human health and the environment, as well as political and policy objectives. Idaho Hazardous Waste Program Summary

-- Mmch 2000 18

# eE: Administrative Records IDAPA 16.01.05.013 [40 CFR 

### § 124.9] requires that an Administrative Record (AR) be made available during public comment periods for permit actions. An 

### AR is housed and currently maintained at the SO for past and present TSD facilities. The Code ofFederal Regulations does not provide specific guidelines as to the maintenance of ARs. However, all official correspondence pertaining to HWMA permitting and corrective action projects must be retained in an agreed upon location. The AR also must include a chronological listing of included docwnents. In addition to official correspondence, the AR may include phone records, meeting notes, applicable internal memos, and all correspondence received from the regulated entity. The AR is open for public review under the Idaho Public Records Act. It is the responsibility ofthe RO to ensure that these records are maintained. EPA Region 10 reviews these records to ensure they are kept current and are inclusive of the requisite . information. 

### 3. MINIMUM QUALIFICATIONS FOR PERMIT OFFICERS AND WRITERS The responsibility for accomplishingvarious tasks associated with hazardous waste permitting has been shifted to· certain Regional Offices (RO). It is not expected that each Region will maintain HWMA staff capable of completing those tasks. However, if RO or Technical Services (TS) personnel anticipate hiring or contracting with personnel not previously tasked with HWMA
. 

# • permitting responsibilities, the following basic skill and experience requirements must be considered. 

### A. Knowledges. Skills. and Abilities • Good knowledge of principles and techniques employed in effectively researching, compiling, and writing complex regulatory documents. • Good knowledge of hazardous waste administrative and regulatory requirements and procedures pertaining to hazardous waste facility permitting and closure and the ability to effectively communicate those principles orally as well as in Writing to a variety of audiences, i.e., facility representatives, other state and federal agency representatives;the general public, or as expert testimony to ajudge orjury. • Good knowledge ofchemical engineering principles as applied to industrial processes and designs and the subsequently generated wastes. • Good knowledge ofinvestigatory and inspection principles and techniques to determine if past releases have occurred or ifthe potential for release presently exists. ..	 Goodknowledgeof'characterization principles and techniques used to determine the extent ofcontaminationofvarious media, i.e., surface water, atmosphere, soil, and/or groundwater. • Good knowledge ofthe processes involved in the development ofhealth risk-based criteria for carcinogensand systemic toxicants to coordinate and develop policy decisions regarding "acceptable" levels ofcontaminants remaining after affecting cleanup strategies. 

### • 'Good knowledge of long-term groundwater monitoring techniques as applied to the 

# • regulation ofhazardous wastes. • Considerableknowledge ofstate and federal hazardous waste laws and regulations.
Idaho Hazardous Waste Program Summary

-- March 2000 19

### B. Typical Duties 

# 0-\' Following are the typical duties associated With hazardous waste permitting. Experience or relevant' training in these areas is required for individuals conducting HWMA permitting activities. Issue and administer hazardous and mixed (hazardous and radioactive) waste storage, treatment, disposal, and incineration facility permits. • Review and analyze permit applications for applicability ofthe Idaho Hazardous Waste, Facility Siting Act, Idaho Code §§ 39-5'801, 

### et seq. • Review and analyze permit applications for administrative completeness. Notify each permittee of deficiencies so as to develop a complete application 'that meets all the requirements and applicable provisions ofthe Idaho HWMA, Idaho Code §§ 39-4401, 

### et seq., the Rules and Standards for Hazardous Waste, IDAPA 16.01.05.000, 

### et seq, and the applicable federal regulations incorporated by reference into the 

### Rl.lks. • Review and analyze permit applications for technical completeness through the evaluation oftechnical plans and engineering reports associated with hazardous and mixed (hazardous and radioactive) waste management facilities • When Corrective Action is necessary at a permitted' facility to control a release at a solid waste management unit, require correction measures to be taken to control this release with specific timeframes in the HW Permit. • When Consent Order Cleanups are necessary at unpermitted HW facilities, work with ROs, TS HW Inspectors, SO HW Program Manager, and AG's Office, to be sure cleanup is**C--~!** 

### completed to meet all necessary substantive requirements ofRCRA Corrective Action. _ Develop Public Participation Packages. • Develop and monitor all public relations relative to the proposed hazardous waste permit. • Consult and educate the general public on existing or proposed scientific and engineering methodologies as applied to hazardous waste management practices and procedures. Conduct financial assurance review. • Review corporate financial data for assurance of long-term financial and liability responsibilities in the operation and closure or post-closure of specific hazardous waste facilities. 

### 4. INTERIM STATUS PERMITS A. 

### Applicability"

----- - Interim status regulations establish minimum standards that define the acceptable management ofhazardous waste during what is termed the "interim status period." Interim status continues, until a unit's Part A and Part B permits are approved, certification offinal closure or, ifthe facility is subject to post-closure requirements, until post-closure responsibilities are fulfilled. Requirements applicable to qualifying for, operation during, -changes during, and termination of interim status can be found at IDAPA 16.01.05.012 [40 CFR Part 270, Subpart G]. The interim 

# C)
status standards for owners and operators ofhazardous waste-treatment, storage, and disposal Idaho Hazardous Waste Program Summary

-- March 2000 20

# • (TSD) facilities can be found at IDAPA 16.01.05.009 [40 CFR Part 265]. These standards are very similar to the standards for permitted units at IDAPA 16.01.05.008 [40 CFR 

### § 264] and include such requirements as financial assurance, contingency planning, and training. However, the differences, regardless ofhow subtle they may appear, can mean the difference between compliance and non-compliance for the interim status facility. Outside the INEEL, interim status standards are most often applicable in situations where unpermitted hazardous waste treatment, storage, or disposal has occurred. Generally speaking, the illegal activity has ceased, and the current owner (and perspective permittee) are subjectto post-closure permitting requirements under corrective action. Additional information regarding HWMAlRCRA corrective action isdiscussed later in this chapter. 

### Note: Recentlypromulgated (HSWA) EPA rules allow the requirements of post-closure and necessary corrective action permitting to be conducted under alternative authorities such as consent orders. 

### B. Review ofRequests for Interim Status Interim status facilities were more common shortly after the inception ofRCRA. Interim status was made available primarily for those TSD facilities already operating when the RCRA was promulgated, providing an interim period to achieve permitted or closed status. Interim status might be requested in the event regulations are promulgated that render previously nonhazardous wastes to be hazardous.

### Anyrequestfor interim status shouldbe considered unusual andmust-be 

### brought to the attention of the State Program. 

# • C. Modification and Termination ofInterim Status IDAPA 16.01.05.012 [40 CFR Part 270, Subpart G] outlines qualification, operation, changes, and terminationrequirements for interim status. Changesunderinterim status can be complicated as the procedural requirements associated 

### withreview and comments (or non review) varies in its prescription depending upon what change is proposed. 

### D. Siting License Annlication In accordance with the Idaho Hazardous Waste Facility Siting Act; 

### a siting license must be obtained prior to submission of a commercial RCRA Subtitle C TSD Facility Permit Application: 

### 5. TSD 

### FACILITY PERMIT APPLICATION A. Annlicability Except-as specifically provided-otherwise in the applicable regulations, owners and
.operators'of all facilities that treat, store, or dispose of hazardous waste are required to obtain permits
.. Permits establish minimum standards for acceptable management ofhazardous waste. In some instances, illegal disposal and/or waste management practices will subject an entity to the requirements ofinterim status closure, which leads to post-closure permitting under IDAPA 16.01.05.008 [40 CFR Part 264]. Appendix 5 depicts time lines (estimated) associated with 

# • processing HWMAlRCRA permit applications for hazardous waste treatment and storage units.

Idaho Hazardous Waste Program Summary

-- March 2000 21

### B. Completeness Review 

# 0 Table 1 ofAppendix 5, 

### Flow Chart for RCBA Permitting Procedures, is

# avisual depiction of the prescriptive steps ofIDAPA 16.01.05.008, 012 [40 CFR Parts 264, 270] for processing hazardous waste management permit applications. The Completeness Review ofthe permit application is done to determine whether the application includes all ofthe required components associated with the particular activity being proposed. DEQ is allowed 30 days to conduct initial completeness review of applications for new units and 60 days 

### for completeness review of applications for interim status units. The "effective date" ofthe application is the date'when DEQ determines that the application is complete. 

### C. Technical Review The technical review process, as depicted in Table 1, does not include prescriptive time frames for D:gQreview. The reason for this is the broad range ofdetail that could be required depending upon what is being permitted. For example, the amount ofinformation submitted in a permit application for a hazardous waste incinerator would be significantly more than that for a drum storage unit. For any unit subject to hazardous waste permitting requirements, specific subparts within the regulations identify the necessary information requirements. However" proper application of such requirements involves the use of EPA guidance documents, Federal Registers, the RCRA Compendium (a compilation ofEPA responses to questions), and eventhe RCRA hotline (11800/424-9346). ' 

### Iftechnical deficiencies are identified in the permit application, DEQ'will provide specific ' comments identifying the deficiencies. It 

### is expected that DEQ will identify all deficiencies in 

# .. j 

### the initial notice of deficiency (NOD). The importance of this expectation is that future' comments associated with the technical review should only address materials submitted in

, response to DEQ'sprevious NOD.

A. T. Kearney developed several checklists that are helpful guidelines for review ofpermit applications. These checklists are available in the HWMA permitting library. 

### D. Permit Drafting When DEQ has determined that the application is 

### technicallycomplete, 

### it is the responsibility of DEQ to prepare a draft permit. The draft permit is expected to consist of modules and attachments that establish the minimum standards with which the Permitter must comply. Examples are available in the .form ofIdaho's current, approved Part B 

### permits and specific guidance produced by EPA. It 

### is 

### expected thatduringthetechnical reviewprocess, permit Writerswill workwith'the PermIttee to develop documents (within the application) to be used as specific permit attachments such 

### as Waste Analysis Plans, Contingency Plans, Inspection Forms, etc. 

### E. Public Notice When the draft permit is complete, DEQ must notify the public and make the draft 

### permit available for review and.comment during a 45-day public comment period. The entire public**(~)** 

### notice process for hazardous waste management permits is codified atIDAPA 16.01.05.013.[40 \---. CFR Part 124]. The requirements for public notice are detailed and require very strict adherence. 22 Idaho Hazardous 

### Waste Program Summary

-- March 2000 'I 

# • Adequate public notification for draft hazardous waste managementpermits is the responsibility

.ofDEQ and is the public'sprimary opportunity to provide inputto the development ofoperating

. permits for facilities and units operating in their respective communities. F. 

### Final Permitting Decisions When the 45-day public commentperiod is complete, it is the responsibility ofDEQ to respond to comments"received. All comments must be addressed, even ifthe response is simply to state. that the commentwas considered and no action will be taken. If, based uponthe comments,DEQ determines that changes will be made to the draft permit, it is.then necessary to determine whether such changes warrant additional public notification. Ifnot, DEQ will notify the facility mailing list and the permittee that the permit is being approved with any changes made. The public and the permittee then have 30 days to appeal the draft permit before it is made effective (fmal). In the event no comments are received,

# the permit will be made effective on the datethat the facility mailing list and the facility are notified.
. . 

### 6. CLASS 1 PERMIT MODIFICATIONS 

# • A. 

### Degreesffypes ofClass 1 Modifications IDAPA 16.01.05.012 [40 CFR 

### § 270.42, Appendix 1] provides guidelines for determination of the class applicable to a permit modification. Two basic types ofClass 1"permit modifications exist. One is a general Class 1 modification subject only to the procedural requirements found at IDAPA 16.01.05.012 [40 CFR 

### § 270.42(a)]. The othertype is subject to the stated procedural requirements, but is also subject to prior approval ofthe DEQ 

### Administrator. B. 

### Prescriptive Time Frames Except where prior Administrator approval is required, the permittee must notify the Administrator ofClass 1pennitmodifications within seven calendar days afterthe change is put . into effect. In addition, within 90 days after the change is put into effect, thepermitteemust send

a notice ofthe modificationto all persons on the facility mailing list. 

### Note: The Facility Mailing List is maintained by DEQ in accordance with the requirements ofIDAPA 16.01.05.013 [40

. CFR 

### § 124.10(c)(viii)]. C. 

### Reyiews and Responses. Unless a Class 1permitmodificationrequirespriorAdministratorapproval, modificationsof this type do not require specific approval from DEQ. However, conducting a review ofa requested modification, either at its own discretion or at the request ofan interested party, is possible for

--- .-----**~DEQ;If;-** ·based-on-such-a--review;-the-Administrator-identifies·-cause-for-rejection of-the-- :.- .. --.- ­ modification,the Administratormustinform thePermitteebycertified mailthatthemodification has been rejected explaining the reason for rejection. In this case, previous permit language is applicable. 

# n Tracking and Permit Maintenance 

# • All correspondence associated with permit modifications must be maintained as part ofthe Administrative Record for the respective facility or 

### unit. In addition, changes must be incorporated into the final permit document maintained by DEQ. Idaho Hazardous Waste Program Summary

-- March 2000 23

### 7. CLASS 2 PERMIT MODIFICATIONS 

# () A.. Applicability IDAPA 16.01.05.012 [40 CFR Part 270.42, Appendix 1] provides guidelines for determination ofthe class applicable to a permit modification. Class 2 permit modifications tend to be more detailed than Class I modifications and are subject to substantially different procedural requirements. B. 

### Prescriptive Time Frames Class 2 modifications involve very detailed time frames, as prescribed in the applicable regulations. DEQ must be responsive to these time frames to assure the necessary level of regulatory oversightofwaste management activities
. . Within seven days before or after the date ofsubmission ofa Class 2 modification request, the

permittee must publish notice ofthe modification request in a major local newspaper ofgeneral circulation, as specified at IDAPA 16.01.05.013 [40 CFR 

### § 124(c)(ix)]. The notice must include announcement ofa 60-day commentperiod in accordance with IDAPA 16.01.05.012 [40 CFR 

### § 270.42(b)(5)] and announcement ofthe date, time, and place for a public meeting to be held in accordance with IDAPA 16.01.05.012 [40 CFR 

### § 270.42(b)(4)]. The permittee must hold a public meeting no earlier than 15 days after the publication ofthe required notification and no later than 15 days before the close ofthe required 60-day comment period. No later than 90 days after receipt ofthe notification request, the Administrator must take action, as specified at IDAPA 16.01.05.012 [40 CFR 

### § 270.42(b)(6)]. Ifthe Administrator fails to take action. by day 120 after receipt of the modification request, the permittee is automatically authorized to conduct the activities described in the modification request for up to 180 days, without formal DEQ action. Subsequent time frames may apply ifthe Administrator fails to take

. further action on the requested modification (see IDAPA 16.01.05.012 [40 CFR 

### §

270.42(b)(6)(iv)]). A permittee may perform any construction associated with a Class 2 permitmodification request beginning 60 days after the submission ofthe request unless the Administrator establishes a later date for commencing construction and informs the permittee in writing before day 60.

- - _. ppo. __ •

__ "
_ 

### C. Reviews. Responses. and Tracking. Because ofthe litany ofprescriptive time frames associated with Class 2 permit modifications, it is imperative that there be a single responsible HWMA permitting 

### contactcapable of conducting a review ofthe request and developing draft responses to them. IDAPAI6.01.05.012 [40 CFR 

### § 270.42(b)] should be the starting.point for review and.schedule developmentfor DEQ response to a Class 

### 2 permit modification. The review of a Class 2 permit modification request can, depending upon the .nature ofthe proposed permit chariges, involve a significant amount ofeffort. As with the initial TSD facility Idaho Hazardous Waste Program Summary

-- March 2000

- - ----.., 

### 24

# • permit application, changes to an approved permit must be considered in light ofthe applicable regulations. 

### D..Public Notice Requirements
. Unless the Administrator takes action necessary to reclassify the modification as a Class 3 modification, public notification requirements associated with a Class 2 modification are the responsibility ofthe Permittee. As stated in previous sections, many prescriptive requirements are involved in a Class 2 permitmodification request. Many ofthoserequirements involvepublic notification. 

### E. Permit Maintenance As with any other HWMA permit-related action, correspondence pertaining to a Class 2 permit modification request must be retained as part ofDEQ's Administrative Record for the 

### facility, The individual responsible for this documentation will also be expected to make the necessary page and electronic changes to DEQ's copy ofthe permit to ensure it is kept current. 

### 8. CLASS 3 PERMIT MODIFICATIONS 

# • A. Applicability IDAPA 16.01.05.012 [40 CFR Part 270.42, Appendix 1] provides guidelines for 

### determination ofthe class applicable to a permit modification. Class 

### 3 permit modifications tendto be the most substantial ofthe modifications provided for at IDAPA 16.01.05.012 [40 CFR 

### § 270.42]. 

### B. DEQ Level.ofResponsibility The permittee is required to provide an announcement ofa 60-day commentperiod including the name and address ofa DEQ contact to whom comments must be sent.

### After the conclusion of the comment period, the Administrator must grant or deny the permit modification request according to the permit modification procedures ofIDAPA 16.01.05.013 [40CFR Part 124]. In addition, the Administrator must consider and respond to all significant written comments received during the 60-day comment period. C. 

### Reviews. Responses. and Tracking Many prescriptive time frames are associated with the submittal, public notice, public hearing, and response to Class 

### 3 permitmodifications. As for Class 2 modifications, 

### it is imperativethat there be a single responsible HWMA permitting contact capable ofconducting a review ofsuch a request and developing draft responses to them. IDAPA 16.01.05.012 [40 CFR 

### § 270.42(c)] should be the starting point for review and schedule development for DEQ response to a 

### Class 

### 3 permit modification. Class 

### 3 permit modifications generallyinvolve a significant amount ofeffort for both DEQ and the 

### Permittee, As with the initial TSD facility permit application, changes to an approved permit must be considered in light ofthe applicable 

### regulations. 

# •
Idaho Hazardous Waste Program Summary

-- March 2000 25

# 0 D. Public Notice Requirements With the exception ofDEQ responsibility associated with comment response and acting as a designated DEQ contact as specified in the Permittee's 60-day public comment period,public notification requirements associated with Class 3 modifications are the responsibility ofthe 

### Permittee. 

### 9. TEMPORARY AUTHORIZATIONS A. Applicability Upon request ofthe Permittee, the Administratormay, without priorpublic notice and comment, grant the permittee a temporary authorization. Subject to specific conditions identified at IDAPA 16.01.05.012 [40 CFR 

### § 270.42(e)(2)], a Permittee may request a temporary authorization for

. activities associated with certain Class 2 and Class 3 permit modification requests. 

### B. Review and Application Temporary Authorizations require a detailed review ofproposed the activities by DEQ. The activities must be in compliance with all applicable requirements ofIDAPA 16.01.05.008 [40 CFR Part 264]. Because the technical review of such an authorization request can vary in complexity, the Administrator need only approve or deny the temporary authorization request as quickly as practical. IDAPA 16.01.05.012 [40 CFR 

### § 270.42(e)(3)) includes specific findings that must be made by the Administrator priorto granting a request for temporary authorization. 

### C. Extensions 

# () A temporary authorization may be reissued for one additional term ofup to 180 days provided the 

### Permittee has requested a Class 2 or 3 pemiit modification for the activity covered in the temporary authorization and the Administratorhas made any determinations required by IDAPA 16.01.05.012 [40 CFR 

### § 270.42(e)(4)]. 10. 

### TSD FACILITY CLOSURE

- INTERIM STATUS A. Applicability The requirements of interim status closure can be applied to units that have documentation meeting interim status, as well as those without such documentation. Therefore, units that have engaged in illegal treatment, storage, or disposal ofhazardous wastes may be required to meet the requirements ofHWMA closure. Interim status closure requirements, in the case ofclosure 

### where wastes**ar~~fL"iI).p-Ia~c::," ID~h14~**  

### directingthepermittee to_the.IDAPAJ_6.01.05.008 [40 CFR Part 264] requirement to obtain a 

### post-closure permit. 

### B. Plan Review and Comment For interim status closure, a facility or unit is required to have a written closure plan. A copy of the most current plan must be furnished to the Administrator upon request In addition, for facilities without approved plans, a closure plan must be provided during site inspections, on the day ofinspection, to any officer, employee, or representative ofDEQ who is duly designated by 

# f) the. Administrator. The closure plan must meet the requirements ofIDAPA 16.01.05.009 [40

### ~_ CFR Part 265, Subpart G].
. . Idaho Hazardous Waste Program Summary

-- March 2000 26

# • In cases where a facility does not have an approved plari, the facility must submit a closure plan to-the Administrator within a prescribed time (depending upon the type ofwaste management involved)priorto the date on which final closure will begin. Many otherprescriptivetime frames apply to interim status closure plan submittal, review, response, completion, etc. These requirements can be found at IDAPA 16.01.05.009 [40 CFR Part 265]. Depending upon the type ofunit being closed, specific closure requirements are often included

. within the applicable subparts ofIDAPA 16.01.05.009 [40 CFR Part 265]. The closure plan

approval process is expected to result in a closure plan that minimizes the need for further maintenance, controls, minimizes or eliminates post closure escape ofwaste constituents, and complies with the closure requirements of the applicable subparts. Extensive guidance is available through eitherthe DEQ HWMAlRCRA Permitting Library and from EPA. Perhaps the mostimportant negotiated component ofthe interim status closureplanis the closure performance standard. This essentially answers the often asked question (in ReRA circles) of "how clean is clean?" A variety of considerations go into the development of unit-specific closure performance standards, not the least ofwhichis sample collection, sample analysis, and the objectives sought to be achieved by sampling and analysis. 

# • The prescriptive requirements of Subpart G include identification of disposal facilities and options for closure-generated wastes, post-closure care and use ofproperty, certification of closure by a professional engineer, cost estimation, and much more. 

### Note: As with HWMA permits, HWMA closure plans are subject to financial assurance requirements. However, these requirements db not apply to federal facilities. 

### C. Public Notification Although the requirements ofIDAPA 16.01.05.013 [40 CFR Part 124] may be used as guidance for public notification of a closure 

### plan, IDAPA 16.01.05.009 [40 CFR 

### § 265.112(d)(4)] specifies the public notification requirements for an interim status closure plan. These provisions include newspaper publication, possibility ofpublic hearing, and amendment response times. 

### D.. Follow Through An approved closure plan is comparable to a hazardous waste permit in that it mustbe precisely adhered to and the conditions ofthe plan are subject to HWMA enforcement authorities. Unless specified differently withinthe approved plan, completion ofclosure activities is subjectto the time and 

### proceduralrequirements of IDAPA 16.01.05.009 [40 CFRPart 265, Subpart 

### G]. . Subsequent amendment ofthe approved plan is also subject to the modification requirements of

IDAPA 16.01.05.012 [40 CFR § 270.42]. Within. 60 days of completion of closure, the owner must submit to the Administrator; by

.registered mail, a certification that the hazardous waste management unit or facility has been 

# • closed.in accordance with the specifications in the approved closure plan. This certification must be signed by the owner or operator and by an independent registered professional engineer. Such
Idaho Hazardous Waste Program Summary

-- March 2000 27

# 0 information will be the basis for the Administrator releasing the owner or operator from any applicable financial assurance requirements. E. Post-Closure Specific post-closure requirements for closed interim status facilities begin at IDAPA 16.01.05.009 [40 CFR § 265.1,17]. Post-closure for HWMA regulated facilities generally leads to the permitting requirements ofIDAPA 16.01.05.008 [40 CFRPart 164]. 11. TSD FACILITY CLOSURE

- APPROVEDIPART B PERMITTED A. 

### Applicability All owners and operators ofhazardous waste management facilities are subject to closure and, possibly, post-closure requirements. Therefore, the permittee is required to submit a plan for closure as part ofthe permit application. The closure plan is subject to review, comment, and revision in conjunction with the permit application, drafting, and approval process. B. Plan Reyiew and Comment While closure plans must be 

### submitted with the permit application post-closure mayor may not be addressed in the permit application process. For hazardous waste disposal units, and most waste piles and surface impoundments, a plan for post-closure must be included in the permit application. Surface impoundments and waste piles not otherwise required to prepare contingent post-closure plans must submit a post-closure plan to the Administrator within 90 days ofthe date it is determined that the unit must be closed as a landfill. 

### Note: As with HWMA permits, 

# () HWMA closure andpost-closure plans are subject to financial assurance requirements. However, these requirements do not apply to federal facilities. C. Public Notification Amendment ofclosure and post-closure plans is subject to the permit modificationprocedures previously described in this document, and as found at IDAPA 16.01.05.012 [40 CFR Part 270]. D. Follow Through An 

### approved closure plan must be precisely adhered to. The conditions ofthe plan are subject to HWMA enforcement authorities. Unless specified differently within the approved plan, completion ofclosure activities is subject to the time and procedural requirements ofIDAPA**16.01.05~008** 

### [40 CFRPart 264, Subpart G].
. - Within 60 daysofcompletionofclosure, theowner must submit to the 

### Administrator, by

registered mail, a certification that the hazardous waste management unit or facility has been closed in accordance with the specifications in the approved closure plan. This certification must be signed by the owner or operator, and by an independent registered professional engineer. Such information will be. the basis for the Administrator releasing the owner or operatorfrom any applicable financial assurance requirements. 

# ()

Idaho Hazardous Waste Program Summary

-- March 2000 28

# • E. HWMA Corrective Action In cases where hazardous wastes have been systematically disposed, .or released to the environment, IDAPA 16.01.05.009 [40 CFR Part 265] (interim status) regulations may be applicable. 

### Ifso, these areas ofdisposal or release are considered to be waste management units. In many (most) cases ofthis type, the regulated entity 

### will attempt to extractthemselves·from the permitting requirements by performing corrective measures (also subject to regulatory requirements) to remove the hazardous waste from the identified disposal facility. Determining the applicability ofHWMA to these types 

### offacilities is important for regional representatives. Regardless ofwhether or not such a determination is accurately made, permitting, closure, and post-closure requirements will continue to apply to such an entity until the provisions ofthe HWMA are specifically met.


# • Althoughthe HWMA was not intended to function as a corrective action authority, recent ·rules and guidance developed by EPA's Office of Solid Waste (OSW) are designed to facilitate corrective action under interim status closure or alternate permitting authorities under HWMAIRCRA (See 

### Management of Remediation Waste Under RCRA and 

### Management of Remediation Waste Under RCRA

- RoadMap, Appendix 6). Due to the process through which rules are or are not adopted in the state ofIdaho, close coordination ofHWMA corrective action between the SO and RO is required. For additional perspective as to HWMA Program expectations pertaining to corrective action, see the 

### July 1999 

### Interim EPA Region 10 Policy for Corrective Action Cleanup Under a State Non-RCRA Authority in States Authorizedfor CorrectiveAction (Appendix 7). Included in the Corrective Action component ofHWMA permittingis post-closure permitting. In situations where corrective actions do not achieve "Cleanclosure" ofregulated units, IDAPA 16.01.05.009 [40 CFR Part**265~** 

### Subpart G] requires full subpart B permitting ofthe uriit(s) as post-closure units. These types ofpermits currently exist in the following DEQ regions: Boise, Twin Falls, and Idaho Falls. Responsibility for permitoversight and continued corrective action associated with post closure units in Idaho has been passed to the respective regions. The resource commitment associated with oversight ofthese permits is relatively small. However, the applicable requirements are specific to HWMA and differ substantively from Idaho's other permitting and/or corrective action programs. Regions are encouraged to work closely with the SO to maintain consistent oversight ofthese permitted facilities. 

# •
Idaho Hazardous Waste Program Summary

-- March 2000 29

# •

Appendix 1 Memorandum of Agreement between the United States Environmental Protection Agency,

Region 10, and the Idaho Division of Environmental Quality. 

# •

•- - ',.-.i'/---r.**I'dk~c-i('** 

### --.. 

## .'

.

## ~~ c·"

### F1EC~rVE.D

r,.:.:



# •

' ... :.:::;



### -

•

.

<_.

### •



## ... NOV 0 6 1998 ON.Of 

### ENVIRoNMENTALQUALm' 

### MEMORANDUM 

# orAGREEMENT BETWEEN AIR

## a HmFlDOUSWAS'TF 

### THE STATE OF IDAHO AND 

### . THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10
I. GENERAL TIllsMemorandum ofAgreement (hereinafter "Agreement") establishes policies, responsibilities, and procedures pursuant to 40 CF:R 271.8 for the' State ofIdaho Hazardous Waste program (hereinafter "StateProgram") authorized under §3006 ofthe Resource Conservation and Recovery Act of 1976 (42 USC 6901 

### etseq. as amended (public Laws 94-580, 95-609,96-463,96-510,96-482,97-272;98-45, and 98-616) (hereinafter "RCRA"), and the United States Environmental Protection Agency Regional Office for Region 10 ·(hereinafter "EPA"). This Agreement further sets forth the manner in which the State and EPA will coordinate the State's administration and enforcement ofthe State Program and pending State aUthOrizatiOn and EPA's administration ofthe non-delegated provisions ofthe Hazardous and Solid Waste Amendments of 1984 (HSWA). Forpurposes ofthis Agreement, references to "RCRA!' include HSWA.

. .' . . . .' . .' . '. 

### This Agreement is entered into by the Administrator, Division ofEnvironmental Quality, of the
. Idaho Department 'of Health and Welfare 

### (hereinafter "DEQ Administrator" or "the State") .and the Regional Administrator, EPA Region 10 (hereinafter "Regio.nalAdministrator".or "EP**~'~).** 

### For administrative purposes, the Idaho Division ofEnvironmental Quality will serve as lead agency to simplify coordination and communication between the State' and EPA. Nothing in this Agreementshall be

### construed to restrict in 

### any way EPA's authority to fulfill its oversight and enforcement responsibilities under RCRA. Nothing in this Agreement shall be construed to contravene any provision of40 CFR Part 271. The parties will review this Agreement jointly at least once a year (and other times as appropriate) during preparation ofthe annual State Grant Work Plan, in connection with grant funding under §3011-ofRCRA>--'--

- -- . - ----- This Agreement may be

### modified upon theinitiative ofeither party in order to ensure consistency 

### with State Program modifications made or-for any other purpose mutually agreed upon. Any revisions or modifications to this Agreement must be .in writing and must be signed by the State and the Regional Administrator. This Agreement 

### will remain in effect.until such time as State Program authorization is withdrawn by

# or is voluntarily transferred.to EPA according to the criteria and procedures established in 40**C.F~** 

### 271.22 and 40**~FR 271.2~**  

### .or until replaced by a revised Agreement signed by the DEQ Administrator and the Regional Administrator.
. _ - _ Memorandum ofAgreement Page 1 of 13 . '?P\lic::prf nO/17/0f.

# .**~.** 

# .' "".:**C~** To ensure effective program review, the State agrees to allow EPA access to 

### all files and other ­ 

### r-' "'\ information requested 

## as deemed necessary by EPA for reviewing State Program administration and

. ,,:' 

### enforcement subject to any applicable restrictions ofthe Idaho Public Records Act, Idaho Code 

### § 9-337 

### et.seq. EPA agrees that all requests for information will be coordinated in advance. " Review ofState files may be

### sch~duled 'at quarterly intervals. Program review meetings between the State and EPA will be scheduled at least fifteen (15) days in advance unless agreed to differently. A tentative agenda for the meeting will be prepared by EPA. 

### B. " Identification ofPriority Activities The State and EPA agree to develop, on an annual basis as 

### apart ofthe State Grant Work Plan, criteria for priority activities, including activities regarding handlers ofhazardous waste. These criteria will be.based on. guidance issued by EPA in the annual" 

### Agency Operating Year Guidance/RCR.-\ Implementation Plan and other guidance documents 

## as may be appropriate, 'and will serve to identify those activities.which should receive the.highest priority during-the 

### grant period. : Examples ofactivities which will be considered high prioritywill include, but not be limited to, facilities 'to be inspected, facilities to 

## be permitted, and enforcement against facilities with.known or suspected ground-water contamination.
. . '"
. IV. "". INFORMATION SHARING

.....**~".'I\** 

### A• 

### General

...-/ 

### As the national hazardous waste-program 

### matures, the respective'roles and responsibilities in this" 

## StateIEPA partnership will become more clear.' During the annual 

### review ofthis Agreement the State and

.EPA will carefully examine the following information sharing provisions for needed revisions. B. 

### 1. EPA will keep the State' informed ofthe content and meaning offederal statutes, regulations, . guidelines, standards
.. 

### policy decisions, directives,.and any other factors that may affect the State

Program. EPA will also provide general technical guidarice to the State. EPA will share with the State any national reports developed by EPA from the data submitted through State reporting



### .requirements.
. - .. _. -_. _.-- -_._- --...' 2. The State and EPA have agreed to a joint permitting process (see. Section V.D of this Agreement). 'Under this process the State and EPA have established policies and procedures by . which each will pursue their respective and/orjointresponsibilities underHSWA .

. The State and EPA agree to the sharing ofinformation as specified under Section V.D ofthis

## Agreem~nt and the aru:ual.State Grant Work

## P~an.**Spe~ifically i~cluded.**  shall be the

## pr(»~::~.:~eU I I 

### for shanng and coordinating the exchange ofinformation on the followmg:'
. 

### I. Memorandum ofAgreement Page 3 of 13 R pv;**c;:p~** nQIl 7/0':'

# ,. c. Information indicating the status. of the State's permitting, closure, post-closure, and

. , ground-water monitoring: d. Various reports designed to accurately describe thestatus ofthe State's authorized program including biennial reports swnmarizing the quantities and types of hazardous waste generated, transported, treated, stored and disposed·

### in the state. The State may modify and will transmit to applicable handlers EPA Biennial Report forms to ensure the format
. reflects current state statutory and/or regulatory authority; 

### and

e. State decisions to grant variances, waivers, .and delisting requests made by hazardous waste handlers. 

### 3. The State agrees to provide EPA with a copy of any decisions 

### regardingrequestsmade by hazardous waste handlers to change their classifications (e.g., requests to be deleted 

## as generators but to

# retain facility status) and facility requests to make on-site changes prior to permit issuance (e.g., requests to handle additional wastes not identified on the facility's.original notification and RCRA Part A 

### Permit Application.) 'Generally, these issues are addressed during the EPA/State quarterly sites meetings. 

# :. 4. The State. agrees to provide EPA when requested, copies of reports resulting from any compliance inspections and subsequent enforcement actions such as actions against CERCLA waste receiving facilities and federal facilities
.. .: 5. The State 

## '-011 make available any pertinent information requested by EPA within a mutually 

# ._.... agreed'upon timeframe
.. Information provided to EPA will be SUbjectto the terms ofthe Idaho Public Records Act, Idaho Code 

### § 9-337 

### et. seq. ,At the discretion of the Director, "made available" maymean temporary access in lieu ofactual delivery to.**EP~.** '

. . . 6. The State agrees to provide EPA with a copy ofeach State decision regardingvariances, waivers, and delisting petitions at the time such requests are granted. The State agrees to provide EPA. with a copy ofeach proposed variance, waiver, or delisting submittal at the time it is received. Ifgranting ofa variance, waiver, or delisting would impair

### theState's equivalency; i.e., impose standards less stringent than RCRA, the EPA will confer with the State to 

### resolve these issues. The State agrees not to issue a waiver, variance, or delisting which would render 'the State Program less stringent than that ofEPA.
. 

## D. Site-Visits _. EPA is responsible for maintaining reliable national data on hazardous waste management. This data is used to report to the President and Congress on the achievements ofthe hazardous.waste program and to support EPA's regulatory development efforts. Ifadditional information is required, EPA will seek to gain this information from the State. The State ofIdaho agrees to supply the Regional Administrator with this informaicri 

### if**:::~.:!;!y** available and as resources allow. Ifthe State is .unable to provide 

### t1::: enformation or if

### it- is necessary to supplement the State**info~ation,** EPAmay conduct a special survey
Memorandum 'ofAgreement Page 5 of 13 Revised 09/1 7/96

## , \: '., . 

# ····..c B. 

### EP A Overview of

### State Permits 

## .'\ While EPA may comment on any permit application or draft permit, EPA's overview. will focus primarily on those facilities identified by the.State and EPA in Idaho's RCRlS generatec . Quarter Plan, annual State Grant Work Plan and the State's' Program Description
. . EPA may comment

### in writing on 'any draft permit or proposed permit modification, whether or not EPA commented on the permit application, within forty-five (45) days ofits receipt. EPAshouldbe notified by the State and be allowed at least as long to comment as the public at large; this time 

### period should be 

### tied to the State's public participation process. Where EPA indicates in a comment that issuance, modification, reissuance, termination or denial ofthe permit would be inconsistent with the approved State Program, EPA shall include in the comment: .

. . 

### a. a statement ofthe reasons for the comment"(including the section ofthe State or federal law or regulations that supports the'comment), and' b.the actions that should be taken by the State 

### in order to address the comment (including . the conditions which the permit would include ifit were issued by EPA). . The State Director and EPA Regional Administrator agree to meet or confer, within thepermit review period, whenever necessary to resolve a disagreement between their staffs on the terms of any State-issuedpermit. EPA shall send a copy ofits'written comments to the permit applicant. EPA**sh(--~** 

### \ withdraw such comments when satisfied that the State has met**~r** 

### refuted its concerns and shall**al~~/**



### .. ..**~.** 

### provide the permit applicant with copy ofsuch withdrawal. 

# --' Under §3008(a)(3) of

### RCRA, EPA may terminate a State-issued permit in accordance withthe procedures of 40 

### CFR Part 124, Subpart E, or bring an enforcement action 

### in accordance with the procedures of40 

### CFR Part 22 in the case ofa violation ofa State Program requirement. In 

### exercising these authorities, EPA will observe the conditions established in 40 

### .CFR271.19(e). The State agrees to provide EPA with the following information in the timeline as specified for sites identified in the Annual State Grant Work Plan. Copies offacility permit 

### -. "applications, revisions.. additions, and permit modification requests. Copies ofNODs, final draft permits, proposed permit modifications, publicnotices, fact sheets. Copies offinal permit or permit modifications. Within fifteen (15) working days ofreceipt.

Within fifteen (15) working days ofcompletion and at least seven (7) working days prior to public notice or a mutually agreed time frame. Within ten (10) working days of 

# (; completion. Memorandum ofAgreement Page? of 13

..... --.:_-.... flO/17/Q(i

I

### • . The State agrees that any compliance schedule

# contain~d in any permit issued will require (' ') compliance with apnlicable standards within a specified time period. The State may issue 2 

### variance to '-.:_.,/ a perminee under Idaho Code §39-4409(7) and IDAPA §16.01.05.356. The State agrees to consider all comments EPA makes on permit applications and draft permits. The State will satisfy or refute EPA's concerns on a particular permit application, proposed permit modification, or draft permit in writing before issuing the permit or making the modification. 

### D. Joint Permitting Process Pursuant to RCRA §3006(g)(l), EPA has the authority to issue or deny permits or those portions ofpermits to facilities in Idaho for the requirements and prohibitions in or stemming from HSWA until" the State'sprogram is amended to reflectthose requirements and pr-ohibitions and authorization is received for the portion or portions 

### of the State Program.
.

. EPA' and IDHW herebyestablish thisjointpermitting process for the issuance ofRCM permits in Idaho. This joint 

### permitting processisestablished in accordance with §3006(c)(3) of RCRA. A. determination on which sites may require joint permitting will be' made by the State and EPA. Accordingly, revisions to the State Grant.Workplan will be negotiated at least annually
.. The State and EPA agree to use state personnel to act on behalf of EPA in exercising the dministrativ.e lead for all facility-requested permit modifications resulting from 

## anewly promulgated
. • SWA regulation, adopted as a matter ofState law, but not yet authorized by EPA. The State shall be**:~.** 

### responsible for notifying EPA in situations in which the State is unable to act as the administrative 

### lead -./" agency. For such permit modifications the State shall be responsible for the preparation of all related documents. EPA shall provide written confirmation/agreement on proposals and interpretations resulting from unauthorized HSWA requirements. All correspondence and permit modifications resulting from an unauthorizedHSWA requirement will bejointly signed by EPA and the State. The resulting additional workload to the .State will be identified and negotiated in the annualState Grant Work Plan and Six Quarter Plan. Upon authorization of the State for provisions of HSWA, the specifics of the. joint permitting process as set in the annual State .Grant Work Plan shall be amended to reflect that authorization. 

### E.COMPLIANCE WITH 40 CFR 270.3

. . 

### Authorization .of the State does not relieve EPA ofits responsibility for .cornpliance 

### with other . Federal "laws that may apply toihe issuanceofpermits (see 40 CFR 270.3). EPA and Idaho agree to

coordinate to the greatest degree possible any permit actions to which -the following laws may apply: The Wild and Scenic Rivers Act, 16 V.S.c. 1273, 

### et seq.; The National Historic Preservation Act 0(1966, 16 U.S.c. 470,et seq.; 

### The Endangered Species Actof 1966 U.S.C. 1531, et seq. 

### (including the consultation provision ofsection 7); The Coastal Zone Management Act, 16 U.S.C. 1451" 

### et seq.; and The Fish and Wildlife Coordination Act, 16U.S.c. 661, et seq. 

### The State agrees to consult with EPA when appropriate 

# . eO determine the potential applicability ofthese laws to 

### ReRA pennit actions.



### Memorandum ofAgreement Page 9 of 13 Revised 09/17/96

### . inspection report provided in compliance with tirn"e frames outlined in the 1996 Enforcement Response

# 0

-.:) Policy, no EPA inspection will be made, unless the Regional Administrator deems the State actions

., inadequate. In 

### case of an imminent hazard to human health and/or the environment, the Regional Administrator may shorten or waive the notice period.
.

. TSD facility 'inspections will be negotiated annually in accordance With the State Grant Work. Plan and theCompliance Assurance Agreement. The frequency ofEPA oversight and training inspections will 

### be specified in the annual State Grant Work Plan. EPA will negotiate on an annual basis the number ofinspections 

### 'in which EPA will accompany the State.
. . The EPA may take enforcement action azainst 

### any persondetermined to be in violation ofRCRA

. 

# .­ in accordance with §3008(a)(2) or upon request by the State. EPA will take enforcement action upon determining that the State has not taken timely and appropriate enforcement action or upon request by the State. Prior to issuing a compliance order under §3008(a) EPA will give notice to the State. EPA also retains 

### its right to issue orders and bring actions under §§3008(h), 3013 and 7003 ofReRA and any other applicable Federal statute. After notice. to the State, EPA may take action under §3008 ofRCRA against a holder ofa State-issued permit on the grounds that the permittee is not complying with a condition of that permit. In addition, EPA may take action under RCRA §3008 against a holder of a State-issued permit on the grounds 

### that the permittee is not complying with a condition that the Regional Administrator, in commenting on that permit application or draft permit, stated was necessary to implement approved State Program requirements, whether or not that condition was included in the final permit,
. 

# c B. State

......



### .- The State agrees to carry out a timely and effective program for monitoring compliance of generators, transporters, and TSD facilities, including federal facilities with applicable program requirements (see 40 CFR 271.15). As part ofthis program; the State will conduct inspections to assess compliance with 'generator and transporter standards (including manifest requirements), facility staridards, permit requirements, compliance schedules, and all otherprogram requirements. Compliance monitoring activities and priorities will be specified in the Compliance Assurance Agreement and the annual State Grant Work Plan and shall be consistent with all applicable Federal requirements and with the State's Program Description. The State will inspect on at least a biennial basis, every interim status or permitted

### non-fede~ai· TSD facility to enforce compliance with the Idaho Hazardous Waste Management Act, State orjointlyissuedpermits, and**~!_ St~~.te_!~gula1~~n~~_** **TSDJ~cUity. iQ~pecti9JlLwillbe_negotiated**  

### annually in accordance with the State Grant Work Plan and the Compliance Assurance Agreement. Inspections which reveal violationsofEPA regulations whichthe State has not yet adopted will be referred to EPA for further action, the exception being for State-issued warning letters which request compliance ofthe noted EPA regulations. More frequent inspections may be performed at TSD facilities (i.e., land disposal, corrective

. action) as negotiated in the annual State Grant Work Plan process. Individuals in the State Program may be designated as EPA representatives under §3007

# 0[0 RCRA so that**t~:::** 

### can inspect EPA permitted facilities for**''':'J~ations** 

### of the tenus and conditions 

### .0i Federal permits. Memorandum ofAgreement Page 11 of 

## 13 Revised 09/17/96.......... 

### -.

r: .• 

## c." Confidentiality olBusiness Information '"'-<")' 

### The State agrees to determine whether a record constitutes a trade secret pursuant to Idaho Code §9-340(2)within 

### three (3) days, or, upon"notice"to the requestor not longer than ten (10) days from receipt" ofa request for such record. 

### Records which have not been Claimed as trade secrets by a business at the 

### firstopportunity at or near the time ofsubmission or collection and have not been the subject ofreasonable effort to maintain secrecy, and are not trade secrets within the meaning ofIdaho Code § 9-340(2) 

### will be' released upon request without further notice to'

### the business.
. D.

. 

### Oversight 1, 

### The State agrees to 

### keep a log of

### denials ofrequests for information 

### (or "a 

### file containing copies" ofdenial letters sent to requestorsjwhich will be made. available to EPA during the State review. ( " "" " 

### 2. The State agrees to keep EPA fully informed ofany proposed modifications to its basic statutory "orregulatory authority, its 

### forms, procedures, or priorities, as applied to §3006(f). 3. .	 'Theeffective

### d~te ofthis.MOA is the date ofsignature by the Regional Administrator.

### ~TATEOFIDAHO . u.S.

### ENVIRONMENTAL PROTECTION AGENCY ."; .•EPT. OF 

### HEALTH & WELFARE . REGION 

### 10


### BY:

# ~.:n~ DEQADMmISTRATOR
.

# ~A,#('Z"lqqC. 

# /O#.&e DATE: 

# c?£r2(1L$

"REGIONAL ADMINISTRATOR 

# '.

Memorandum ofAgreement Page 13 of 13 Revised 

### 09/17/96

# C) ,

.Mernorandum ofAgreement Between The 

### State ofIdaho and . The U.S. EnvironmentalProtection Agency Region 10 

### CONCURRENCES POLICY FILE Initials:

### .'J~ 

# &1·tf -0t

# W

# \,~ Yes X 

### No
Name: Hunt**~;-Z~-\g** 

### . Eckman " Queitzsch Bussell Ifpolicy file please bee to RMSPU Manager Date:

... 

# ·Cf(21 11'Y**'l1~1-JCfb** 

### . (.
... 1.'1. \b'" RCRISEVENf Yes 

### No Xl 

# o

# •

Appendix 2 Hazardous Waste Inspection and Enforcement References 

# •

•ApPENDIX 

### 2 - HAZARDOUS WASTE INSPECTION/ENFORCEMENT REFERENCES (1) EPAlldaho Memorandum of Agreement, III.A. 

# • (2) EPA/Idaho Memorandum of Agreement, IV.C.2. (3) EPA/Idaho Memorandum of Agreement, IV.C.4. (4) EPA/Idaho Memorandum of Agreement, VII.A. (5) EPAlldaho Memorandum of Agreement, VII.B. (6) Idaho Code 39-108 (7) Idaho Code 39- 108 (3) (8) Idaho Code 39- 108 (3I(a) (9) Idaho Code 39- 108 (3I(vi) (10) Idaho Code 39-4404 [11] Idaho Code 39-4412 (1) (12) Idaho Code 39-4412 (2) [13] Idaho Code 39-4412 (3) [14] Idaho Code 39-4413 (A1(1 lIa) (15) Idaho Code 39-4413 (All 1 lib) [16] Idaho Code 39-4413 (AI(1)(e) [17] Idaho Code 39-4413 (c) [18] Idaho Code 39-4414 (1) [19] Idaho Code 39-4415 [20] EPA/Idaho Compliance Assurance Agreement, I. [21] EPA/Idaho Compliance Assurance Agreement, tlI.A. (22) EPA/Idaho Compliance Assurance Agreement, V. [23] EPA/Idaho Compliance Assurance Agreement, VI. [24] HWMA Civil Penalty Policy, I. [25] HWMA Civil Penalty Policy, IV. [26]HWMA Civil Penalty Policy, V. HWMA Civil Penalty Policy, VI. HWMA Civil Penalty Policy, VII.A.2. • ] HWMA Civil Penalty Policy, VII.A.3. (30) HWMA Civil Penalty Policy, VII.A.4. [31] HWMA Civil Penalty Policy,**VII.B~** [32] EPAlldaho Compliance & Enforcement Strategy, II.A. [33] EPAlldaho Compliance & Enforcement Strategy, II.B. [34] EPA/Idaho Compliance & Enforcement Strategy, II.C. [35] EPA/Idaho Compliance & Enforcement Strategy, II.C.3. (36) EPA/Idaho Compliance & Enforcement Strategy, III.A. [37] EPA/Idaho Compliance & Enforcement Strategy, III.A.1. [38] EPAlI,daho Compliance & Enforcement Strategy, III.A.2. [39] EPA/Idaho Compliance & Enforcement Strategy, III.A.S. (40) EPA/Idaho Compliance & Enforcement Strategy, III.B.1. [41] EPA/Idaho Compliance & Enforcement Strategy, III.B.2. (42) EPAlldaho Compliance & Enforcement Strategy, III.C.1. [43] EPA/Idaho Compliance & Enforcement Strategy, 111.0.2. (44) EPA/Idaho Compliance & Enforcement Strategy, III.G. [45] EPAlldaho Compliance & Enforcement Strategy, IV.**J4§]liaza!!!~us W~~!e**  Science**OJfic~!_** Class CodeQ754,2, IPC [47] OSHA 1910.134 Respirator Protection Requirements [48] 40 CFR 311. 1 (49) OEQ Health and Safety Plan [50] EPAlldaho RCRA Work Plan [51) RCRA, The Law, 3007 (a)(1 & 2) [52) RCRA, The Law, 3007 (e) [53] RCRA, The Law, 3009 [54) RCRA, The Law, 4007

, .] RCRA, The Law', 9004 (b)(1 ) ] RCRA, The Law, 9004 (e) . 7] EPAlldaho Enforcement Response Policy, I. [58] EPA/Idaho Enforcement Response Policy, ILA. [59) EPA/Idaho Enforcement Response Policy, II.B. [60] EPA/Idaho Enforcement Response Policy, II.B.1. [61] EPA/Idaho Enforcement Response Policy, II.B.2. [62] EPA/Idaho Enforcement Response Policy, II.B.3. [63] EPA/Idaho Enforcement Response Policy, II.C. [64] EPA/Idaho Enforcement Response Policy, II.C.1. [65] EPA/Idaho Enforcement Response Policy, II.C.2. [66] EPA/Idaho Enforcement Response Policy, II.C.3. (67) EPA/Idaho Enforcement Response Policy, IV, [68] Enforcement Procedures Manual, Section 2 [69] Enforcement Procedures Manual, Section 3 [70] Enforcement Procedures Manual, Section 4 [71] Enforcement Procedures Manual, Section 5 [72] EPAlldaho Hazardous Waste Management Plan, II.C. [73] EPAlldaho Hazardous Waste Management Plan, .11.0. [74] 10APA 16.01.05.850.01

# •

Appendix 3 Notice of Violation and Consent Order Routing Processes 

# •

•

# • NOTICE OF VIOLATION ROUTING PROCESS Regional Office Determination of Need for NOV·
Regional Office Prepares.a Complete Enforcement Referral Package for the State Program Office

State Program Office Arranges Conference Call Among the Enforcement Team 

# •

• Technical Services Drafts the NOV

Technical Services Group Revises the

. NOV Regional Office Review State Program Office Review

Regional Office Review and Approval Attorney General Review and

Approval State Program Office Review and Approval

State Program Office Routes NOV for Administrator Signature and Mails the Signed NOVCONSENT ORDER ROUTING PROCESS Compliance Conference

Technical Services Group· Drafts Consent Order
Regional Office Review State Program Office Review
Technical Services

Group 2nd Draft

Attorney General Revi.ew ...... ........ State Program Office Team Member Conducts Conference Call if Conflicting Comments Warrant

_ ­

State Program OfficefTechnical Services Group/Attorney General/Regional Office Final Draft

State Program Office Routes for Signature

State Program Office

Mails Signed Copy

State Program Office Notifies Team Members Upon Receipt of CO Signed by

Facility, and Date the CO is effective

• If the responsible party makes changes to the draft Consent Order, the routing process fro

# (~) this point will be repeated.

# •

Appendix 4 DEQ Enforcement Tracking Log 

# •

• Icurrem tn,ougn week Of 1;t/1U/llll

10118199 1119199 12110199
AshgroV8 Cemem 814199 8118199 8123199 913199 RTC Inkom 9121199 9123199 10119199 1111199 6127199 Arnold Machine NIA 4m98 10123/98 10130188 Idaho Fells 1115198 '48.600 8ellord Medlce' 12117198 2116199 1111199 1126199 1126199 8elle,d 2/17199 3/5199 814199 Poceteno 1/29199 11111199 Reg. Ag.' 1129199 'Re9. Ag. Incorrect Certified Assey 9127199 1018199 RTC Coeurd'Alene 11118199 9/16197 Reglonel Office 'elerrel 8119199 DanceFarm, 10130198 11130198 12116198 12118198 12123198 12/28198 1122/99 9119199 11116199 Blackfoot 7113/98 Double l Menl 3124197 411197 413197 4m97 419197 619197 8121197 913)97 12131197 119198 1124198 AmericanFells 2nddll 2nd dII '26,170 919/96 12/2197 12/6197 1126196 E&GContrecto, 10122/99 1116199 11110199 12/8199 Pocetello 8111199 ESIISile B 3124194 GrandView Evergreen Resources tl117197 Sade Springs 1018196 Green Velley Fertilizer 10130198 11116198 1214198 12/14198 12115198 12/18198 1128199 316199 718199 NIA Rigby 914198 GTS T,ansmlssion 2120198 3131198 On nold**Re~Mp** NOV leke BlOomProperty) 2nd per AG ached tor Revoked Rethdrum 2122199 request 7/fj8 WLin 4130197 & 7122198 Develop. mentCurrent through week of 12110/99 ,.-

Mark Hansen CH Ilo M ORCorp) Poe.tella Hogoyo Antiquo & 7/29/98 H/A Restoration Nampa 5/8/96 IHEEl'98 projcompo 5/25/99 8/9·11199 8/27/99 1st 8/27/99 10/21/99 Idaho Foils date: 4115-17/98 record 3/5/99 roviow 8/8·12/98 & 7/13-16/98 inspections INEElCNew Issues· NI 8/22/97 7/25/97 8/21/97 8/25/97 'axed hnd del 10114­ hod del 717198 5/6/99 Pold 9611deho Falls unsgnd 8/26/97 16/97 717198 2ndclfl 5/6/99 var. recordreview5 8/2t/97 2ndclfl'_ 10/5/98 '385,094 11118-22196 sgnd 12117· 9/30/98 3rd dfl polly 8/25/97 18/97 mailed 'ued 8/8/99 10/1/98 114/99 '114,908 2110­ 3rd dfl meII SEP 11/98 1/4/99 1/6/99 'oaoCt '0.0 3118­ 2111/99 2111/99 19/98 fede_ fed 0.0 2111199 2/16/99 5/4·5/98 10/27· 28/98 1/26­ 27/99 INEEUNRF 5/20/99 7/27/99 VCO 7/16/98 INEEl 4/3/92 NON/CO Lake Shore Tie & lumber 3/4/99 5/27/99 7/30/99 Hormer Future Forestry) 9116/99 9/22/99 Havdan 3/4/99 Lynn Industrial 11/19/99 11/24/99 GardenCity 09/23/99 Naval Warfare Center 11/26/99 Bayview 6/B/99 Po1latch 6/10/99 6/30/99 B/12/99 Lewiston 9/17/99 10/19·21/99 Roundy's Pole fence Co 11/4/99 11/4/99 1120/99 9/14/99 Eogia 10/21/9B,""urrem tnrougn WeeK 01**'1II.1IUI:JI~**

O.kot. MIning Corp. Yellowplne 8/4-6, 17- 18/99 TechnlChem. Inc 8/28199 8/30/99 801

•• 4/21/99 Stibnlte Mining. Inc. ln199 3/12/99

Transmission City 3/13/96 11/24/96 4/2/96 12/4/96 TO NOV 3/27/96 4/4/96 6/18/98 8/12196 1/9/97 STIP PNLTY 8/27196 Pocatello 3/13196 RTNO OF .,0,200 UNCLMO IF NEEDED 4130/98 SNTTO Demendltr 8 R8RTS ••nt 7/8198 CSElRO) 10.1e_ FOR HNO 

# .It. by DEL 7/17198 n:vd 4/30198 7/13198 FIIIIureto comply Itr eent 10122198 usAntlmonv • Preach.,. 12/12196 CoveMine Sunbeom 8/19-20196**lreLOa~1UOO** RTC • Rotum to Complionc.

3Current through week 01 12/10/99

cc: Steve AllreO' listrator Doug Conde . 

# o o
Tim Callanan, AGs Kate Kelly,State Waste' Brian Monson, State Waste Mike Gregory: State Waste Eileen Loerch, TS Matt Garringer, TS Roben Higdem, TS Dave Luft, TS Natalie McLeod, TS Matt Alvarado, Boise RD Ron Lane. Boise RD John.5utherland. Coeur d'Alene RD Catherine Reno, Idaho Falls RD Donnie Edwards, Lewiston RO Boyd Robens, Pocatello RO Bill Allred, Twin Falls RD

4

# •

Appendix 5 Permit Processing Timelines and Table 1 - Permitting Flow Chart 

# •

•

# . .. 

# •

•

1

2 

### TIME-LINES FOR PROCESSING RCRA HAZARDOUS WASTE STORAGE AND TREATMENT PERMITS STAFF DAYS ELAPSED TIME MONTHS A.. PRE-APPLICATION MEETING1 

### 7 7 1. Evaluate Facility Including Site Visit if appropriate 2. Determine Idaho

- Hazardous Waste Facility Siting Act -applicability 3. Discuss Critical Segments of Application, Application Process and Time-frames for Final Permit Determination 4. Call-in the Application B. RECEIVE & REVIEW PERMITS2 

### 83 8 1. Acknowledge Receipt 2. Conduct Initial Completeness Review 3. Issue NOD or Conduct Comprehensive Technical Review -4. Issue 1st NOD 5. Receive & Review Revised Application 6. Issue 2nd NOD

­ 7. Receive & Review Revised Application 8. Conduct Final Facility Inspection _C. 

### PREPARE DRAFT PERMIT 42 3 1. Draft Permit 2. Draft Corrective Action Module 3. Transmit Draft to Owner/Operator & EPA-Region 10 for -30-day Review 4. Incorporate % 

### &/or EPA Comments into Draft Permit D. PUBLIC REVIEW 15 3 1. Prepare & Distribute Public Notice 2. Prepare for & Conduct Public Hearing (if necessary) 3. Respond to Comments D. ISSUE FINAL PERMIT 22 3 1. Finalize Permit Incorporating Response to Comments 2. Distribute Final Permit TOTAL 162
. 

### 24 EXISTING FACILITIES: If the OPB does not have-to "CALL-IN" the Part B**pe~it** 

### application, six (6) months can be taken off the schedule. NEW FACILITIES: Are subject to the Idaho Hazardous Waste FacilitySiting Act, 7-12 months would have to be added to the schedule. The time-line estimates for REVIEWING PERMITS are based on the issuance of two (2) Notices of Deficiencies {NODs}. If additional NODs are necessary the time-frames increase approximately 3 months per additional 

# • NOD
.

# •• PERM!T PROCESS STEPS PRE-APPLICATION MEETING 

### There are no set time-frames for conducting these meetings, however enough information must be obtained to determine: 1. What sections of the Rules, Regulation and Standards for Hazardous Waste are applicable, e.g. IDAPA and 40 CFR equivalents
. 2. Whether or not this facility constitutes a "new facility" subject to the Idaho Hazardous Waste Facility Siting Act. 3. Whether or not the facility will require other DEQ permits to operate, i.e., Air Permit To Construct, Operating Air, Wastewater· Land Application Permit, etc. Based on the information gathered above and on when the hazardous waste facility application would be submitted to the DEQ, a schedule for the final administrative disposition of the application would be developed with the facility owner/operator. RECEIVE 

### & REVIEW PERMITS 

### The DEQ provides to the facility owner/operator a written receipt acknowledging the date the application was received and how that date fits into the schedule for the ·final administrative disposition of the application developed in conjunction with the Pre-Application Meeting. Conduct Initial Completeness Review Each application submitted for a "new facility" should be initially reviewr-"\ for completeness within 30 days of its receipt. Each application submitc\ / for an "existing facility" should. be initially' reviewed for comptet.ene.ss within. 60 days of its receipt.'
. Conduct Comprehensive Technical Review Once the initial completeness
.. review has been' conducted there are no recommended time-frames for conducting the subsequent comprehensive technical review(s)
. Similarly, there are no set time-frames for how long an 0/0 

### should.be afforded to respond to a Notice of Deficiency (NOD). However it· is common practice for the DEQto work with the % 

### in establishing how long they will need to respond to the specific deficiencies. Again it must be understood that the time-line estimates for REVIEWING PERMITS are based on the issuance of two (2) NODs. If additional NODs are necessary the timeframes increase approximately 3 months per additional NOD. Receive 

### & Review Revised Application 

### & Conduct Final Facility Inspection After the % 

### submits a completely revised**appli~.cation** 

### _**~hj,ch.** 

### J;;atisfies all' applicable regulations,

- a:--final facility·' inspection is usually warranted to ensure that the operations described in the application do in fact coincide with the physical operations at the facility. PREPARE DRAFT PERMIT 

### A Draft Permit is prepared containing Modules which address any/all applicable regulations, e.g., storage in containers, treatment in tanks, etc. All permits issued .after the HSWA amendments of 1984 must contain corrective) Action Provisions, i.e., a separate Module dealing with the issue. .Once t( DEQ has a draft permit, it is .transmitted to the Owner/Operator & 

### EPA-Regio
.." 10 for 30-day Review.
.

# • The critical elements in determining the HWMA!RCRA time-frames for permitting would be:
. 1. Is this a "new facility" subject to the Idaho Hazardous Waste Facility Siting Act? 2. Does II

### treatment " include thermal/incineration technologies?



# •

•

### • TIMELINES FOR PROCESSING RCRA FACILITY PERMITS I. HAZARDOUS WASTE STORAGE & TREATMENT PERMITS STAFF DAYS ELAPSED TIME MONTHS A. RECEIVE & REVIEW PERMITS' 83 8 .B. PREPARE DRAFT PERMIT 42 3 C. PUBLIC REVIEW 15 3 D. ISSUE FINAL PERMIT 

## ...n J TOTAL 162 17 II. HAZARDOUS WASTE INCINERATION PERMIT STAFF DAYS ELAPSED TIME MONTHS A. RECEIVE & DISTRIBUTE PERMIT2 5 1 B. REVIEW PERMIT 208 12 C. PREPARE DRAFT PERMIT 62 5 D. PUBLtC REVIEW 34 3 E. ISSUE FINAL PERMIT 

### -JlZ J TOTAL 371**2!'-~** 

# l_) III.

. HAZARDOUS WASTE LAND DISPOSAL PERMIT STAFF DAYS ELAPSED TIME MONTHS A. RECEIVE & DISTRIBUTE PERMIT2 5 1 B. REVIEW PERMIT 232 12 C.PREPARE DRAFT PERMIT 49 5 D. PUBLIC REVIEW 34 3 E. ISSUE FINAL PERMIT 

### -JlZ J TOTAL 382 29 EXISTING FACILITIES: If the OPB has to**·CA~L-IN·** the Part B permit application, six (6) months must be added to the schedule.

. __ NEW FACILITIES: Are subject to the Idaho Hazardous Waste Facility Siting Act. To date, only one (1) Siting License has ever been issued, the administration ·01 which took seven (7) months.

'The timeline estimates for REVIEWING PERMITS are based on the issuance of two (21 Notices of Deficiencies (NODsl.

2This step is incll!ded for Incineration and land Disposal Permits due to the need for Multi-Media coordination.FLOW CHART FOR RCAA PERIUTTING PROCEOURES
TSD Application eUbmitted to Director 

# I I

APPl i cat i on reviewedl 

# I for completene.. 

### I 

## I 

# • I

Notify applicant in writing ot application'. completeness (within 30 days ot .Ubmittal tor new facilities , within 60 day. tor interia .tatu. facilities) IncolD lete complete Notice of Deficiency (NOD) (Regional Administrator " lists information needed to make application complete) Information not submitted appropriate In the case ot a IDajor, new facility, prepare' lDail to spplicant a project**Decision"Schedul~** Information**sUbmittedl------~** Notity applicant that application is complete ("Bffective date ot application")

Technical "Review of APplication (indeUnite periOd "ot tilte to determine technical" soundne•• , enforceability. protectiven.e., and comprehensiveness) Incom lete Notice ot Deticiency (NOD) (llore than one NOD may be submitted to applicant) 

# e.-
Intormation not submitted Permit denied with appropriate enforcelDent action Informati eUbmitted Co lete

Notity applicant that technical review ot application i. complete

Prepare a dratt permit

Decision etfective ilDlDediah1y if Decision eftective at a later date than wae epecified Revi_ or in notice of tinal eVidentiary hearinq requested no co_ent. to chall98 it w.re, received 

# • Deny Permit Issue notice of Withdrawal ot intent to deny "notice to deny· PUblic notice of denial

45 day public 

## L...---------l**co_e~t** period PUblic hearing, if" requested

Decision effective

at 30 days atter Unal decision decision

Review denied: decision etfective JUdicial review Final permit deciaion

# '.

Appendix 6 Management of Remediation Waste Under RCRA Road Map

'

# •

•

# ••

•••••• MANAGEMENT OF REMEDIATION WASTE UNDER ReRA ROADMAP
.



# • GUIDANCE SUBJECT CITATION TOPICS AREA

# ;!III.,!gl;.III!I~1.1'1111_II[il,i!';i\_IIII:illl1IIII!lltll"111~11f.l1r~!1111 EPA Letter from Michael Information on the Scope and Shapiro to Norman Applicability ofthe Area of Nosenchuck, March 25, 1996**Con~tionPolicy** EPA Memorandum from Use ofthe Area ofContamination Concept Michael Shapiro, StepbenD. During RCRA Cleanups Luftig, andJeny Cliffordto RCRA Branch Chiefsand CERCLA Regional Managers, March 13, 1996 EPA Letter from David EPA Interpretation of"Active Bussard to ScottDuBoff, April Management" m the Closing ofWaste 6, 1994 ManagementFacilities EPA Memorandum and Use ofthe Corrective ActionManagement Documentfrom Sylvia Unit Concept Lowrance andBruceDiamond to Waste ManagementDivision Directors. RCRABranch
orContamination Policy Chiefs. and RCRA Regional Area Counsel, August31. 1992 (AOC) EPA.Letter from Sylvia Applicability ofRCRA Requirements to Lowrance to Douglas Green, Common Excavation Activities June 

### 11. 1992 EPA Memorandumfrom LandDisposal Restrictions (LOR) Caroline Wehling to Steven Applicability for Investigative Derived Goliaa, April 16. 1991 Wastes EPA Letter fromDonClay to Applicability ofLDR Guides Richard Stoll, January 7, 1991 EPA Memorandum from Replacement ofContaminated Soil and Sylvia Lowrance to David Debris TreatedUnder a Treatability Ullrich, October9. 1990 Variance

_._-_.-. . EPA Letter from Lisa Applicability ofLDR and Permitting Friedmanto Richard Stoll, September 5. 1990 S5 FR 8758-8764 (March 8. FinalNational ContingencyPlan (NCP)

# - 1990) Preamble Discussing the Area of Contamination (AOC) 

### Page 1 of 7

### MANAGEMENT OFREMEDIATIONWASTE UNDERRCRA 

# c> ROAD MAP GUIDANCE SUBJECT AREA CITATION TOPICS Superfund LDR Guide #S : Determining When Land DisposalRestrictions (LDRs) Are Applicable to CERCLA Response Actions ProposedNational Oil and Hazardous Area ofContamination Polley Superfund Directive: 9347.3- OSFS; Superfund LOR Guide #5 (July, 1989) (AOC) • Continued 53 FR 51443-51447 (December 21, 1988) Substances Pollution ContingencyPlan (NCP)

- Preamble Discussing the Area of Contamination (AOC) EPA Memorandum from Michael Shapiro, Stephen D. Luftig, and Jerry Clifford to RCRABranch Chiefs and .CERCLA Regional Managers, March 13, 1996 Use ofthe Area ofContamination Concept During RCRA CleanupsWhich Covers Some ofthe Differences BetweenAOCs and CAMUs {located with "AOC" materials] Agency Flexibility in the CAMU Rule
Appropriate Mechanism'forApproval of CAMU at U.S.S. LeadFacility Impact ofCAMU Regulations on the Management of"As-Generated" Hazardous Wastes EPA Letter fromMichael Shapiro to M.L. Mullins, October 18, 1995 . EPA Memorandum from Devereaux Barnes to Norm Niedergang, February 17, 1995' Correenve Action ManagementUnits (CAMUs) & Corrective Ac:tion EPA Letter from Sylvia Lowrance to Doug MacMillan, May4, 1993 TemporaryUnits ('IUs) .58 FR 8658-8685 (February 16, 1993) CAMUs & TUs, Final Rule
EPA Authority ofCAMUs During a State Cleanup Using CERCLA-like Authority and Similar State Documents

-"'.­ - .­ ..­ - --­ - ----.,.-.­ -­ --_ .._-_.- S8 FR 8679 (February 16, 1993)

.'-­ - -­ .. ­ 

### , .

.•

, . II**~~'** •• 1 ";_ •• " 

### Page 2 of 7

# ••• MANAGEMENT OF REMEDIATION WASTE UNDER RCRA ROAD MAP GUIDANCE SUBJECT AREA CITATION TOPICS
Land Disposal Rule Phase N; Preamble Discussion on LDR Applicability to Contaminated Soil
Determination ofWhen Contamination is Caused by Listed HazardousWaste

Site-Specific LDRTreatment Variances

-- Treatability Studies Exemption . -

. 63 FR 28619 (May 26, 1998)

61 FR 18804-18805 (April 29, 1996) Management ofHazardous Contaminated Media (HWIR-Media); Proposed Preamble Discussion on Application of
. LDRs Final NCP [located with "AOC" materials] Proposed NCP - Preamble Discussion on Determination ofWhen a Waste is a Listed Waste under RCRA 55 FR 8758-8760 (March 8, 1990) 53 FR 51444 (December 21, 1988)
63 FR 28606-28608 (May 26, 1998) LDR Phase N Soil Treatment and Standards

- Preamble Discussion on Variance from Soil Treatment Standards 62 FR 64504-64509 (December S, 1997) Clarification ofStandards for Hazardous Waste - LDRTreatment Variances, Final Rule Use ofSite-Specific Land Disposal
. Restriction Treatability Variances Under 40 CFR 268.44(h) During Cleanups

HWIR-Media Proposal-Preamble Discussion on Media TreatmentVariances EPAMemorandum from Michael Shapiro and Steve Luftig to RCRA/CERCLA Regional SeniorPolicy Managers, January 8, 1997 61 FR 18828 (April 29, 1996)
53 FR31199-31200 (AUgust 17, 1988) Preamble Discussion on Non-RulemalOng Procedures for Site-Specific LDR Treatment Variances S9FR 8362-8366 (February 18,1994) Hazardous Waste Treatability Studies Sample ExclusionRule EPALetter from Sylvia Lowrance to"]osephPaulick, September 9, 1992 - ... Clarification ofRCRARegulations Concerning Notification for Treatability Studies Hazardous Waste Treatability Studies Sample Exemptions - Final Rule S3 FR 27290-27302 (July 19, 1988)


### Page 3 of 7

### MANAGEMENT OF REMEDIATION WASTE UNDER ReRA 

### ROAD MAP GUIDANCE SUBJECT AREA CITATION TOPICS Exemption for Ninety Day Accumulation 51 FR 10168 (March 24, 1986) Exemption for Ninety Day Accumulation

Permit Waivers EPA Memorandum from J. Winston Porter to Regional Administrators, November 16, 1987 RCRA PermitRequirements for State Superfund Actions

EPA OECA Memorandum from Steven A. Herman to Addressees, October 20, 1997 Transmittal of Guidance on the Use of Section 7003 ofRCRA (Actual Guidance located in Corrective Action Toolbook) EPA Letter from Sylvia Lowrance to Elizabeth Powell, June 15, 1989 Response to Questions on a Variety of RCRA Issues Related to Remediation of Contamination at a Facility Exemption from 40 CFRPart 264 Requirements for People Engaged in the Immediate EPA Letter from J. Winston Porterto Fred Hansen, September29, 1986 Responses to questions related to accidental spills oflisted or characteristic hazardous wastes Phase ofa Spill Response 4S FR 76626-76630 (November 19, 1980) Preamble Discussion on the Hazardous Waste Spill Response Exemption Changes During Interim Status to Comply with Corrective Action Requirements 54 FR 9599 (March7,1989) Changes to Interim Status Facilities, Final Rule » Changes During Interim Status Related to Corrective Action
EPA Letter from Sylvia Lowrance to Mark Hansen, November 3,1992 Interpreting the EmergencyPermit Regulations Emergency Permits 40 CFR270.61, originally promulgated as 40 CFR 122.27 4S FR 33326-33327 (May 19, 1980) 'Hazardous Waste and ConsolidatedPermit Regulations Preamble Discussion on EmergencyPennits

, ,

,. TemporaryAuthorizations at Permitted Facilities 

## -**~3 f.R3.791~-_37921**  . (September 28, 1988) PennitModifications for Hazardous Waste ManagementFacilities, FinalRule

- PreambleDiscussion on Temporary Authorizations ./ . '-.:>,.-i



# 0·· "

," 

# -' Page 4 of 7

I I

# 11 

# • MANAGEMENT OF REMEDIATION WASTE UNDERRCRA

. ROAD MAP



# • GUIDANCE SUBJECT CITATION TOPlCS AREA

# ~~11!.!I

# ••**ltliEII11.1:iIIII11§;~lE!lll.1111.!.II;'.111;**

Contained-In Policy

.- _.---- _._-- _. _._--­ 63FR65877-65879 (November 30, 1998) EPA Letter from Elizabeth Cotsworth ·to WilliamR. Weissman, August 21, 1998

63FR28621-28622 (May 26, 1998) 61 FR 18795-18803 (April 29, 1996) EPA Letterfrom Michael

.Shapiro to T.L. Nebrich, Jr., February27, 1996 EPA Letterfrom Michael
.. Shapiro to PeterWright, September 15, 1995 EPA Memorandumfrom Devereaux Barnes to NOIID Niedergang, .February 17, 1995 EPA Letterto T.L. Nebrich, Jr., March 22, 1994 EPA Letterfrom Michael Shapiro to William Warren, October 15, 1992 

### 57 FR37225-37226**_(~~.18,.1992)** -.-

EPA Letterfrom Sylvia Lowrance to John Ely, March 26, 1991 HWIRMedia

# -Final Rule- Preamble Discussion on "Howhas EPA Tried To Solve These Problems in the Past?" USWAG's, EEl's, andAGA's Concerns Regarding the Effects the LDRTreatment Standards Published onMay 26, 1998 May Have on Cleanup ofManufactured Gas Plant Sites LDRPhase IVFiDalRule

- The Contained-In PolicyPreamble Discussion HWlRMedia

- Proposed Preamble Discussion on the Contained-InPolicy Clarification ofSeveral RCRAIssues Including the Contained-In Policy Response to a Letter Seeking Clarification ofthe Contained-InPolicy
The Contained-In Policy as it Applies to Environmental Media ContamiDated with P and U ListedWastes The Contained-In Policyas it Applies to Contaminated Soils Clarification ofIssues Relating to the Regulatory Status ofSoils Contaminated from the Releases ofCommercial Chemical Products Identification and Listing ofHazardous Waste.CERCLA-Hazardous-Designation

- Preamble Discussion on Codification of Contained-In Policy for Debris Summarization ofEPA's CurrentPosition on the Contained-In Policy 

# • Page 5

### of 7

### MANAGEMENT OFREMEDIATION WASTE UNDER RCRA ROAD MAP GUIDANCE SUBJECT AREA CITATION
EPA Letterfrom Jonathan Cannon to Thomas Joding, June 19, 1989

Contained-In Policy

- EPA Memotmdum from Sylviatowrance to Jeff ZeliksoD, 

### Jauuary 24, 1989 Continued EPA Memorandum from Sylvia Lowrance to Timothy Fields, Jr., January 3, 1989 .EPA Memorandum from Marcia Williams to Patrick Tobin. November 13, 1986 EPA Memorandum From Elizabeth A. Cotswcrthto RCRA Regional SeniorPolicy Advisoa, October 19, 1998

Soil Treatment Standards' 63 FR28602-28622, (May 26, 1998)
63 FR287S1-28752 (May 26, 1998) EPA Letterfrom Michael Shapiro to JancO Bergman, June 14, 1995

RCRA Section 3020(b) Exemption for Reinjection of Contaminated Groundwater
. EPA Memorandum from Don 'R. Clay to Waste Management Division Directors and Regional CODDSel, DecemberTT.**198~** LDRTreatment Standards for Contaminated Soils 63 FR28602-28622(May 26, 1998) TOPICS
EPA Interpretation ofthe Contained-In Policy
Status ofContaminated Groundwater and LimitatioDS onDisposal and Reuse
Status ofPersonnel Protective Equipment as a RCRA Waste
RCRA Regulatory Status ofContaminated Groundwater
Phase IV Land DisposalRestrictions Rule

- Clarification ofEffective Dates

LDR Phase IV Final Rule

- Preamble DiscusSion on !.DRTreatmentStandards for Soil

. Altemative LDRTreatment Standards for Contaminated Soil Interpretation ofLandDisposal RestrictioDSPhase II Final Rule as it Pertains to Underlying Hazardous Constituents in the Soil that Exhibit ToxicityCharaeteristics ApplicabilitY ofLandDisposal Restrictions to RCRA & CERCLA GroundwaterTreatmentReinjection

- Saperftmd ManagementReview:

... '-
- - .• _·.0 Recommendation-No.26 LDR Phase IV SoilTreatmentStandard Regulations [located with "SoilTreatment Standards
.. materials]



### Page 6 of 7

### MANAGEMENT OF REMEDIATION WASTE UNDER ReRA 

# '. ROAD MAP GUIDANCE SUBJECT CITATION AREA 63FR28606-28608 (May 26, 1998) Site-Specific, Risk-Based LDR Treatment Variance for Contaminated Soils TOPICS
LDRPhase IVFinal Rule 

# -Preamble on Site-Specific, Risk-Based LDR Treatment Variance for Contaminated Soils [located with "Regulations and Policies that Apply to Contaminated Environmental Media" materials]

# ilill.I~:llli:.llmlllll.IIIIII:~lllill~!lIllmlf:'ll~I'ill!1111111!llllll.llllllflltllltIII1

LDRTreatment Standards for Contaminated Debris 

# • EPA Letter from Michael Shapiro to Kenneth Kastner, June 3, 1994 57 FR37194, (August 18, 1992) 57 FR 37221-37243, (August 18, 1992) 57 FR 37277-37280, (August 18, 1992) Clarification ofthe RCRA Regulations Applicable to Hazardous Debris
LDRs for Newly ListedWastes and Hazardous Debris

# - Final Rule Summary LDRs for Newly Listed Wastes and Hazardous Debris

# -Preamble Discussion LDRs for NewlyListed Wastes and Hazardous Debris

## - Treatment Standards for Hazardous Debris



# '. Page 7 of 7.

## Appendix 7 Interim EPA Region 10 Policy for Corrective Action Cleanup Under

a State Non-RCRA Authority in States Authorized for Corrective Action 

# •

•,

# . 

# •**uNrrEDSTATESE~RONMENTALPROTEcnoNAGENCY** REGION 10 1200SbcJh AY8I1Ue Seattle.WA98101
July 1999 Interim EPA Region 10 Policy for Corrective Action Cleanup Under a state Non-RCRA Authority in states Authorized for Corrective Action

I GUIDING PRINCIPLES



# * States may choose to use a non-RCRA authority or program to accomplish environmental cleanup at facilities subject to RCRA corrective action in a manner consistent with the authorized RCRA program. 

# * The authorized state RCRA program is responsible to insure that cleanups completed under a state non-RCRA authority are consistent with RCRA. 

# * EPA has an oversight obligation for the authorized RCRA program. 

# * There is a need for state/EPA coordination when a state non-ReRA authority Is 

# • used:

. 1) to Insure that state progress toward final corrective action Is acknowledged in the national data base; and 2) to minimize the need for additional RCRA corrective action measures once a facility has undergone cleanup through a state non-RCRA mechanism. POLICY STATEMENTS Use of a non-RCRA state cleanup program/authority does not substitute for compliance with base (preventative) RCRA 

### requlrements. When a state program/authority is used for cleanup the facility is not exempted from the base requirements of RCRA, including properwaste management. monitoring, financial assurance, and closure requirements which apply to treatment, storage, and disposal of hazardous waste. There is an expectation that the authorized state hazardous waste rules will be appropriately applied and enforced .. The authorized state RCRA program ultimately Insures consistency between the authorized state RCRA program and the corrective action done under a state non-RCRA authority_

. EPA also has an obligation to insure that cleanups at RCRA facilities subject to corrective action are consistent with RCRA requirements and guidance. EPA Region 10 encourages joint traininglforums on RCRA guidance. Questions regarding the applicability or interpretation of RCRA guidance should be discussed with EPA Resion 10 during regular progress meetings as soon as possible to prevent the facility from ultimately being revisited under RCRA. 

# •. Prior to terminating interim status through permit denial, authorized state RCRA 

# o programs are accountable to insure all corrective actions are complete as measured by RCRA rules, policy and guidance, and documented as part of the administrative record supporting permit denial. In cases where termination of interim status through final denial of

# apermit is conducted as a means to address compliance issues (such as failure to submit a complete Part B permit application - see 270.10(e)(5}), states should ensure an enforceable mechanism is in place to complete corrective action when such work is not completed at the time of permit denial. Such actions warrant consultation with EPA Region 10 to insure either federal 3008(h) jurisdiction is preserved, a 3008(h) consent instrument 

## is in place, or a formal regional decision to not exercise 3008(h) authority is made.

. . Permits requiring corrective action must not be terminated prior to all corrective action obligations being completed, and public notice and comment on corrective action completion has been conducted and documented as part of the permit administrative record. States must craft permit language that requires permittees to maintain a valid Part B permit for the duration of corrective action even after regulated units have been clean closed and active waste management ceased. For facilities subject to modification or revocation and reissuance of permits under 270.41, care must be taken not to terminate permit authority for corrective action. EPA Region 10 does not Intend to provide "comfortn that facilities cleaned up under the state non-RCRA program/authority will be protected from further Federal RCRA action. However, if the authorized state RCRA program insures that cleanups are consistent with RCRA requirements and guidance, this should not be a concern. Before the completion of a cleanup under a . state program/authority, the authorized RCRA program should determine whether additional Corrective Action is necessary at this facility. VVhere additional corrective action under RCRA is not required, this decision should be reflected through a permit determination by the authorized RCRA program or by an appropriate public process for a . facility that is not seeking a permit, including providing timely information to EPA Region 10.

EPA will be using the national R(:RA data base to monitor progress at all RCRA facilities subject to corrective action, with particular focus on high priority facilities. Cleanup actions under a state non-RCRA authority consistent with RCRA corrective action requirements should be reported in the national database. A data crosswalk may be used to standardize program 

# c. events. Regular state/EPA Region 10 communication regarding progress at RCRA corrective Action facilities, especially high priority facilities, Is necessary 

### to. Insure that

. progress Is reported, and to minimize the need for further RCRA corrective action at a facility which has undergone remediation under a state authority/program. EPA Region 10 will expect to meet with the State RCRA program on a regular basis (minimum twice year1y) to discuss progress at high priority facilities, projections for meeting Environmental Indicators, and issues relating to consistency with RCRA guidance. These meetings may be in conjunction with mid-year and end-of-year §3011 state grant meetings.

# •

•

•Information aboutRCRA facilities subject to corrective action must be available to the public. Public participation on a site-by-slte basis should continue to be consistent with RCRAguidance

. EPA Region 10 and the State will work together on revising or amending the Program Description and the Memorandum of Agreement to clearly articulate the strategy of using an authority other than RCRA for corrective actions. This revision, necessary to keep the regulated community and the general public fully informed, will not be considered part of the authorized program and a federal register notice will explain that the revision will be construed as a broader-in-scope by EPA. 

### EPA strongly encourages states to seek authorization for the Post-closure rule. Absent authorization for this rule, States may address corrective action at unitslfacilities subject to post-closure permit requirements through a non-RCRA authority. However, the authorized state must retain RCRA jurisdiction at the facility, and when corrective action work under the non-RCRA authority is complete the authorized program must administrativel1)reevaluate whether the goals of corrective action have been achieved, or whether a PC permit is required. This**~ecision** must be reflected in a permit denial or PC permit, which includes a public comment period. EPA PLANS FOR OVERSIGHT EPA has an oversight responsibility for the entire authorized State RCRA program. As part of our oversight of the authorized corrective action program, EPA Region 10's primary oversight goals are to insure that environmental cleanups are progressing toward meeting Environmental Indicators and final cleanup, and that final cleanups are 'consistent with RCRA regulations and guidance. Currently EPA Region 10 will be focusing corrective action oversight resources on high-priority corrective action facilities (those on the GPRA baseline). EPA Region 10 will provide oversight ofthe authorized state RCRA program, not the non-RCRA state authority or program. It is the responsibility of the authorized state program to insure that RCRA is being consistently carried out and that corrective action at RCRA facilities is consistent with the authorized program. EPA Region 10 expects to accomplish our oversight responsibility in several ways. First, we will be closely monitoring the national RCRA database to evaluate progress at facilities subject to corrective action, especially high priority facilities. We will be using this data to provide information to Congress and the public. Secondly, we will rely on on-going EPA/State communication including meetings and conference calls to give us an understanding of the status and progress of corrective action and to insure that environmental indicators at high priority facilities are met and documented properly. If regular meetings/conference calls do not provide for site-specific information, we will utilize site-by-site reviews as resources allow. If, over time, it is clear that the State is meeting the expectations set forth in this'letter, and if communication on site progress is effective, we would expect that site specific reviews and general oversight of corrective action would be reduced.

.I
I / !

# ~. / /



### Appendix 8 Complaint Response Policy and Flowchart 

# •

I ------ . 

# •
\ \

# •

•

• IDEQ Response Procedures and Guidance for Potential HWMAIRCRA Cases THE INTENT OF THIS DOCUMENT IS TO DEFINE A PROCESS WHEREBY REGIONAL OFFICE AND STATE OFFICE CAN WORK TOGETHER TO RESOLVE ISSUES THAT MAY INVOLVE HAZARDOUS WASTE. THE GOAL IS TO ENSURE TIMELY RESPONSE AND COORDINATED FOLLOW UP TO THESE ISSUES. THE PROCESS FOCUSES ON A JOINTLY DEVELOPED STRATEGY TO RESOLVE ISSUES, ESTABLISH TIMELINES AND ENSURE ACCOUNTABILITY. 

### 1. Incident Notifications Received by the State Office Incident notifications received by the State Office (SO) will be forwarded to the appropriate IDEO/Regional Office (RO) Regional Manager (RM) by the

. Enforcement Coordinator (EC). The RO has the discretion to determine the need to include SO Technical Services (TS) staff in further handling of the incident. The incident notification will be transmitted by registered E-Mail. If the E-Mail system is not working at the time, a telephone call to the RM shall be substituted. All relevant documentation pertaining to the incident will be either faxed or mailed to the appropriate RM within 

### 3.days of the notification. Based on the information in the incident documentation, the EC has the . discretion to make an initial determination of the potential for a HWMAIRCRA

component in the case. Copies of each incident notification sent to the ROs will be maintained by the EC ina file. The EC may request information from the RM concerning cases referred to the RO. 2. Incident**Noti~cations** 

### Received by RO's When an incident notification is received by a RO, the initial investigation of the incident may be conducted by RO personnel. Based on that initial investigation or historical knowledge of the site, RO personnel will attempt to determine if a HWMAIRCRA component exists. ROs may also contact the SO for assistance to determine RCRAlHWMA applicability. If HWMAIRCRA is determined or suspected to be a component ofthe case, the RM (or designated RO staff) will prioritizelhec6mplaifinflspectioii 

## and investigate with properly trained RO or TS. HWMAIRCRA personnel within an acceptable timeframe. The RO must ensure that this inspection has been logged into the Monthly Report. If enforcement is required, the RM or designated RO staff should forward the case to the EC and participate in the enforcement process as per the HW Program Protocol.

### IDEO Response Procedures and Guidance for Potential HWMAIRCRA Cases Page 2 3. Assignment of a Referred Incident Case from an RO When the EC has received an enforcement referral, the EC will process this referral with participation from the RO as per the HW Program Protocol. 4. Information Exchanges Between ROs and the SO A. All documents pertaining to HWMAIRCRA regulated facilities generated by the SO, shall include a cc to the RM of the appropriate RO. Similarly, any documents and letters pertaining to HWMAIRCRA regulated facilities in the region, generated by the RO, shall include a cc to the EC. B. All HWMAIRCRA enforcement documents resulting from an incident referral, shall be sent in draft form by the SO to the RO for review and comment within the timeframes contained in the HW Program Protocol. 

# •

•

### ReRA - Remediation- Hazardous Waste Issue Flowchart 

# • Complaint Received

RO Follow-up Regional Office Investigation



# • RO Performs HWMAI RCRA Inspection

Enforcement

Case turned over to State Waste & Remediation Program Office 

# •

# • IDAHO HANDLER ACTIVITY COUNT REPORTAugust 14, 2000 Large Quantity Generators 42 Small Quantity Generators 124 Conditional Exempt SQGs 919 HW Transporters 94 Subject to CEl Universe (Calculated Universe) , 10 Land Disposers 8 Incinerators 

### 1 BIFs 

# o Treatment/Storage 

### 5 UO and HWF HANIoLER ACTIVITY 

# • Used Oil Fuel Handlers (Notifiers) 49 Marketers 6 Transporters 15 Burners 

### 7 Hazardous Waste Fuel Handlers (Notifiers) 5 BurnerlBlenders 5 Marketers 2



# I • Source: Resource Conservation and Recovery Information System (RCRIS), Idaho State Notifiers Database (generated from the Notification ofRegulated Waste Activity Forms [8700-12] submitted to DEQ). 

# • File: IH (RCRA Admin)

# • • •

ltll/.:!B/OB PAGE IDAHO SIX QUARTER PLAN BEGINNING JULY 1999 FROM THE RCRIS REGIONAL IMPLEMENTER DATABASE· EVENT TYPE ALL CA AND PERMIT EVENTS / RESPONSIBLE AGENCY ALL 1ST QTR 2ND QTR 3RD QTR 4TH QTR 5TH QTR 6TH QTR JUL-SEP OCT-DEC JAN-MAR APR-JUN JUL-SEP OCT-DEC FACILITY PERMIT 99 99 00 DO DO 00

..................................... _ _ .. _ .. __ 1

__ _ _ _ __ 1 _ _ .. .. 1 _ •• __ _ __ _ .. __ __ _ _ _ _ _ __ __ _ .. ASTARIS IDAHO LLC • CLOSURE 1 501' • a En • CL360 03/14/00 • • • 100 07092 951B • STE CONTACT: I •••• TSO UNIVERSE: 0 S I. "'" NCAPS: HI EPR: HI I • • • • • • I _ .1_ ", __ __ .. _ _I
_ _ _ .. __ __ __ _ __ .. __ _ __ .. _ • __ .. __ .. 1 __ .. __ __ _ 1_ _ _ .; .. _ _ .. __ I CA EVENTS • I • • En· CAOSO 09/30/00 • J I I I I J •

__ .. _ _ .:._ _ _ -- -_ _ .. _1_ __ _ _.__ " __ _ _ __
_ _ __ __ _ - • • _1 __ __ • __ __

__ 1_
_ BLllJNT INC CCI OPER I PERMITI 001' I I iii S : OP622 02/29/00 • • • 100 00906 6481 I STE CONTACT: MHJI • I • I TSO UNIVERSE: I •• •• NCAPS: HI EPR: HI I • • I I • I I.

__ •• __ .. .. _ .. _ __ _. __ _. _ _ _ .. __ I ..
_ _ •• 1.
.. __ __ 1_ ..

_ •• • __ .. __ • _ • __ .. _ .. _1
_ .. _. ._**~_** I CA EVENTS I iil S • CA623 09/22/99 • as· CA026 12/22/99 • iii S • CA633 03/01/00 I as· CA623 OS/24/00 "S' CA633 08/15/00 • S • CA633 12/31/00 I • iii S • CA026 09/30/99 • • • I S - CA623 09/15/00 •

...-. -- •• - ....... - .. - ...... - .1.

_ ••• ...__ .... 1 •• .. _ ... _ .. ..._1_
.... _ .. _ .. __ .. _ .. _ ........ ...... _1 .. _ .... _
... __ .... ._ •• ... _ .. __ .... _ .... _. • ... 1 .. _. • • __ .. _ .. _..;.

_ .1_
.. _._. ..... .. __ .... _ .. _. __ BOISE LOCOMOTIVE COMPA' PCPERMITI 002' iii S • PC623 OB/02/99 • • as· PC622 01/18/00 • iii S • MP240 04/14/00 • iii S • Pe014 07120/00 • S • PC026 12/31/00 100 98097 6831 • STE CONTACT: BSG' iii S • PC633 OB/20/99 I • a S - MP230 03/29/00 I iii S • PC026 05/1B/00 • S • PC026 09/30/00 • TSD UNIVERSE: D' I • I iii S - PC623 06/12/00 • NCAPS: ME EPR: ME • • as· PC631 06/23/00 • • as· PC407 06/28/00 • 

# I.

.. S • PC633 06/30/00 • 1-
.. __ _ .1 .. _ ._ __ 1
__ _ _ __ • _ 1 ._ .. .. 1 _ __ __ I ",__ _ _ _ _ __ .. _ • _ _._ I CA EVENTS • S • CA500 09/15/99 • S • CA626 12/31/99 • I as· CA026 06/28/00 I • • • S • CA636 09/30/99 • • - • as· CA407 06/2B/00 I •

- ,-."

--- - --.- 1 _. I _ .. _ __ I _1 _ _ 1 • e 1
__ • _. 1 __ _ __ • __ __ .. _ DART INDUSTRIES INC • POSTCLOSUREI 002' as· PC633 07/08/99 • iil S PC623 12/10/99 • as· PC622 02/01/00 I iii S • PC621 04/25/00 • S • PC633 07130/00 • S • PC026 12/31/00 100 ·00046 7332 • STE CONTACT: DER' iil S • PC026 08/22/99 • iil S • PC026 12/22/99 • as· PC026 02/10/00 • as· PC623 05/05/00 • S - PC489 08/15/00 S· PC623 12131/00 TSD UNIVERSE: D' I I as· PC633 12/22/99 • • iil S • PC631 05/05/00 • S • PC026 09/30/00 NCAPS: LO EPR: HI • I I I iil S • PC488 05131/00 S - PC205 09/30/00
• • I • is· PC026 06/15/00 I • • • a S - PCI60 06/15/00 I • 'a S • PC251 06/15/00 •
NOTE: ACTUAL EVENTS PRECEOED BY 'i'

• KEY TO EVENT RESPONSIBLE AGENCY/SECTION • KEY TO TSD UNIVERSES 

### • • E/P FEDERAL PERMITS SECTION CONTACT I 0 = LAND OISPOSAL FACILI TY • E/C FEDERAL COMPLIANCE SECTION CONTACT S = STORAGE/TREATMENT FACILITY '. E/O a FEOERAL OPERATIONS OFFICE CONTACT C = COMBUSTION • E/7 FEDERAL CONTACT. SECTION UNICNOlIN • E/S STATE CONTACT. ENTERED BY EPA
• J JOINT FEDERAL/STATE CONTACT • S = STATE CONTACT

# o 

# o

08/28/00 PAGE 2 IDAHO SIX llUARTER PLAH 8EGINNING JULY 1999 FRCJI THE RCRIS REGIONAL IMPLEMENTER DATABASE EVENT TYPE = ALL CA AND PERMIT EVENTS / RESPOHSIBLE AGENCY = ALL 1ST gTR 2NO gTR 3RD OTR 4TH OTR 5TH OTR 6TH OTR JUL-SEP OCT-DEC JAN-MAR APR-JUN JUL-SEP OCT-DEC FACILITY PERMIT 99 99 DO 00 00 00

.. - - -_ .. I .. __ .1

__ __ .. __ .. I .. 1 .. .. __ __ __ 1--

_ _ _ .. .I _

__ _ __ __ .. _ __ .. __ .. _ _ __ ENVIROSAFE SVCS OF IDA' PCPERMIT 001' as, PC637 09/07/99 • as'

- PC407 11/10/99 • as- PC633 01/04/00 • as· PC631 06/07/00 I S PC623 07/31/00 • S - PC621 11/30/00 100 00077 3952 • STE CONTACT: SSG' • as- PC621 11/12/99 • • as- PC407 06120/00 • S - PC621 08/07/00 • T50 UNIVERSE: 0 • • iil S - PC623 12/20/99 • • • S • PC633 09/30/00 • NCAPS: ME EPR: HI • • • • • •

....................._ __ 1 __ __ _I
__ _ _ .. _ .1 __ .. I - - __ _ __ __ .. too..**~_** .. _ 1 __ __ __ .. ENVIROSAFE SVCS OF IDA' PRMT1-0RGNAL 001' as- MOllO 07/15/99 I as- OP621 11/12/99 • as- OP633 01/07/00 • a S - M048904/D6/00 • as· OP4070'7/12/00 I S - OP623 10/31100 100 07311 4654 • STE CONTACT: SSG' as:· OP629 07/23/99 .• iil S - OP026 11/19199 • iil S - OP65801/07100 • iil S - OP658 04/06/00 • S· OP623 07131/00 I S - OP621 11/30/00 TSD UNIVERSE: D S • • a S - OP406 D7128/99 • iil S - OP627 11123199 I as- OPD26 02/16/00 • a S - M0160 04/12/00 • S - OP621 08/07/00 • S - OP026 12/31/00 NCAPS: ME EPR: ME • iil S - OP63908/04/99 I as· OP637 11/23/99 • as - OP623 02/25/DO • as - OP631 06/07/DO • S - OP02609/3D/00 I S OP614 12/31/00 • a S - OP658 D8/04/99 • as- M0488 12/03/99 • as· OP407 D2/29/00 • a S - M0240 06/12/00 'S- OP633 D9/3D/DO S - OP633 12/31/DO • as- M0240 08125199 • a ,S - OP614 12/15/99 I as- oP633 03/03/00 • a S - OP026 D6120/DO • • as- OP623 08127199 • a S - OP623 12/27/99 • as· OP407 03/14/00 • iil S - OP407 06/20/00 • • as- OP6Z3 09/02/99 • • a S - OP622 03128/00 • • iil S - OP026 09/16199 • • as· OP628 03/31/00 • • as· OP406 09/23/99 • I • as· OP627 09/23/99 • • • as· OP633 09127199 • • • • as'

- OP633 09127/99 • • • • • 1_ _
__ 1. .. _ .. .. _ _1 .. _ _ .. __ .. _ .. - __ _ - _ - - - - I .. - _ - - .. _ .. _
__ _ 1-
_ _ _ .. _ .. • PRMT2-RENEIIL 002' • • as- M0407 02123/00 • S • OP150 04/30/DO • I I STE CONTACT: SSG' • • S - OPl10 03/31/00 • I •

__ _"_ .. - - - - - _ .. ":
_ _ I.
__ .. I _ .. 1_ - - .. __ _ _ __ 1 __ .. _ __ _ .. _ - _1_
_ _-- .. 1-
__ _ __ _1_
_ __ .. _ PACIFICORP • PCPMT-ORGNL 003' as· PCD2608/09/99 I iil S - PC026 11/16/99 • as- PC622 01/27/DO • as· PC621 05/02100 • S PC633 08/31/00 I S PC026 lU31/0D 100 DD060 2631 • STE CONTACT: DER' • • as- Pc633 01128/00 • as· PC631 05/12/00 • S • PC026 09/30/00 • S - PC6Z3 12/31/00 TSD UNIVERSE: D' • • '·a S - PC026 03/15/00 • as· PC026 06/21/00 • • NCAPS: HI EPR: ME • • • • • as· PC6Z3 06121/00 • • 1 __ _ _ .. _ _I _ - .. _ __ .. I - .. _ _1 __ .. __ _ _ -I - .. - _ .. __ -- ':'1-
__ _ 1-_ _ _ __ • .. _ _ • PCPMT-RENEIIL 004' as- PC100 08/05/99 • iil S • Pell0 10129/99 • • a S - PC150 05/30/00 • S - PC488 08/15/00 • • STE CONTACT: DER' • • • • S - OP489 09/30/00 • I • • • • • S - pc160 09/30/00 • J

__ _ .. __ I _ .. 1 - - _ .. - - 1 _. _ _ - __ _ _ -1- - -- _ .. - __ _ .. 1 __ __ .. 1

_ __ _ __ ._ • CA EVENTS • as- CA026 08/09/99 '01 S - CA026 12/31/99 • a S - CA633 01/28/00 • a S - CA026 05/02/00 • S • CAOZ6 09/30/00 • S • CA026 12/31/00

• I a S CA633 08/11/99 • a S - CA623 12131/99 • as- CA026 01/31100 • a S - CA623 06/21/00 • S - CA633 09/30/00 • S - CA6Z3 12131/00
NOTE: ACTUAL EVENTS PRECEDED SY 'a'

KEY TO EVENT RESPOlISI8LE AGENCY/SECTION KEY TO T50 UNI VERSES E/P = FEDERAL PERMITS SECTION COHTACT o = LAND DISPOSAL FACILITY E/C = FEDERAL CCMPL lANCE seen011 CONTACT S = STORAGE/TREATMENT FACILITY E/O = FEDERAL OPERATIONS OFFICE COHTACT C a CCJlBUST I ON En = FEDERAL CONTACT. SECTION UNlCNaIN E/S = STATE CONTACT. ENTERED 8Y EPA • J = JOI NT FEDERAL/STATE CONTACT • S = STATE CONTACT

.

# • • •

PAGE 3 IDAHO SIX QUARTER PLAN BEGINNING JULY 1999 FROM THE RCRIS REGIONAL IMPLEMENTER OATABASE EVENT TYPE = ALL CA AND PERMIT EVENTS / RESPONSIBLE AGENCY = ALL .08128/00

1ST QTR 2ND QTR 3RD QTR 4TH QTR 5TH QTR 6TH QTR JUL-SEP OCT-OEC JAN-MAR APR-JUN JUL-SEP OCT-DEC FACILITY PERMIT 99 99 DO 00 00 00

..... __ .. _ __ 1_

__ .. _ .. _ _ __ _ I _ _ __ __ -_ __ __ .. 1
__ -_ .. _ .. __ I
__ _ .. _ -_ -- .. --- -- .. PRESSURE TREATED T1MBE' POSTCLOSUREl DOli Gl 5 - PC623 07/27/99 • Gl 5 - PC621 12/29/99 • Gl 5 PC631 01/06/00 • • Gl 5 PC623 07/28/00 • IDD 04711 1018 • STE CONTACT: BLE' Cil 5 - PC633 08/18/99 • • as· PC623 01/20/00 ' , 5 • PC633 OS/04/00 • TSO UNIVERSE: D' • • • a 5 - pc633 01128/00 ' • NCAPS: ME EPR: HI • • • , , • •

_____ __ __ I __ _ .. _ .1
__ _ _ _ toO _ .. _ _•• 1 __
__ _ _ __ _ .. __ __ _ .. 1_ _ .. _ .. -_ - •• _ .. SAFETY-KLEEN SYSTEMS I' PERMIT1 001' iii 5 - OP621 09/10/99 'a 5 • Mo230 11124/99 • as· OP407 01/25/00 • iii S • OP631 06/07/00 • 5 - OP621 OS/07/00 • 5 • 01'026 12/29/00 IDO 981n 0498 • STE CONTACT: BSG' iii 5 - OP026 09/17/99 • Cil 5 - 01'026 12/31/99 • iii 5 • M0231 02/23/00 • iii 5 • OP026 06/28/00 5 - 01'026 09/29/00 • TSO UNIVERSE: S' , iii 5 - OP631 09/30/99 • • iii 5 • M0240 02/24/00 • a 5 - 01'621 06/30/00 NCAPS: LO EPR: LO " as- 01'614 02/28/00 '

, , iii 5 • OP622 02/28/00 • • iii 5 - OP026 03/13/00 ' • , , , iii 5 • 01'621 03/15/00 •

_ _ 1-
_ I _
__ -- __ .. ·1 _ ..

__ .. __ .. _ ••**_~** .-- .- - --- .-- - - - - .. - - -. - - .. - - -- --. -- - --. - .-- .. - - - -- .. - - •• ,:,,,.-,,, - ••• - - •• -. -- - - - - -. US AFB MOUNTAIN HOME • PERMlTl 0011 Cil 5 • 01'026 09/30/99 • iii 5 • 01'610 11/04/99 • iii 5 - OP622 03/14/00 'iii 5 • OP026 06/28/00 • 5 • OP026 09/29/00 • 5 • 01'026 12/29/00 103 5n12 4557 ' STE CONTACT: BAM' • iii 5 • OP026 12/30/99 'iii 5 - 01'026 03/17/00' I , TSO UNIVERSE: S' , • ., • NCAPS: HI EPR: HI • , • • • • • •• ...**_~** ..._ ..... - -- - ... -_ .. - - - .1 ..... - - - - -- - - - __ .. - --1- - - _ .. - _._ - - _ .. - - _ ... - -- .1_ .. - _.
__ ......... - __ ••••• _ - __ • - I - - ••• --. - ••• --- - - - - ...- - - - - I ........ - - - --. - ..... - - -- - - - .-- .--- - - -- •••• - - -- .. -- -".7 - - - 1- ..... - .. - .... - - ........ - __ - .. _-- -- US DOE INEEL LAB • AMWTF-Ol 508' 5 • OP4B9 09/30/99 • iii 5 - OP150 10/28/99 'iii S - OPI70 01118/00 • iil 5 • 01'180 04/07/00 'a 5 • OP200 07/18/00 • ID4 89000 8952 • STE CONTACT: BLE' , iii 5 • OPl60 11/10/99 'iii 5 • OPl70 01/19/00 • as- 01'190 04/26/00 ' • TSD UNIVERSE: 0 C S' •• iii 5 • OPl70 01/20/00 • , • NCAPS: HI EPR: HI • • , • , • , I ••

__ • _ _ __ _ ••• _ _ _ _ _ _ __ _ _ _ __ ••••••

__ .. __ .. __ •

__ •• __ _. _ __ • __ _ • _ •• __ __ • CL-BLOCK-IV 507' iii 5 • CL380 07/08/99 , • iii 5 • CL370 01128/00 ' . • • STE CONTACT: DER' • '.a 5 • CL380 03/07/00 • • , •• - -- .. ---.- - ...-- .... - ...... - ._ .. _ - - - ... .... -.

_ •• I ....... ..._ ...__ .... _ .... _ ••• _._ ......... _ .... _ .. _ •

__ ._ .. __ ..... toO. ..... ....:.. __ .. _ ... .... ...
_ ........... ... ............ ._ •••• _ .. __ ... .. _ • CL·BLOCK-V 510' • as· CL380 11/02/99 • • • • STE CONTACT: DER' , , , , , .- • • .• -- - -- -- _ - - __ _ .. _ .. - -- - -- - .. __ 1- _ .. 1_ _ __ _ _ .. _ -
_ .. _ .. _ __ .. j.

__ I _ _ .. _ .. __ 'CL-BLOCK·VI 511' • Cil 5 - CL340 10/04/99 • iii S - Cl370 01/10/00 ' • , STE CONTACT: DER' • iii 5 - CL421 10/04/99 • Cil 5 - CL380 01/31100 • , , I .. _ _ _ _ .. _ __ • .. _

__ .. __ _. _ _ .. __ __ .. _ __ _ _'" _ .. _ .. __ .. •

__- _ .. _ _ _ _ _ _ _ .. __ __ _ _ __ .. __ .. _ • VOL04 019' iii 5 • M0489 07/27/99 • Cil 5 • M0200 12/02/99 • as· M02DS 01102/00 • iii S - 01'622 04/03/00 • 5 - OP026 09/29/00 ' 5 • 01'026 12129/00 , STE CONTACT: BAM' iii 5 • OP026 09/09/99 'a 5 • OP026 12/21199 • iii 5 • OP026 03/01100 • as- OP026 06/28/00 • ' ,
NOTE: ACTUAL EVENTS PRECEDED BY 'iii'

KEY TO EVENT RESPONSIBLE AGENCy/SECTION , KEY TO TSD UNIVERSES E/P .. FEOERAL PERMITS SECTION CONTACT o = LAND OISPOSAL FACILITY E/C .. FEDERAL COMPLIANCE SECTION CONTACT 5 = STORAGE/TREATMENT FACILITY E/O .. FEDERAL OPERATIONS OFFICE CONTACT C .. COMBUSTION En = FEDERAL COHTACT. SECTION UNKNOWN E/S = STATE CONTACT. ENTERED BY EPA
• J = JOINT FEDERAL/STATE CONTACT , 5 .. STATE CONTACT

## r 

# o 0 

# o

08/28/00 PAGE 4 10AHO SIX QUARTER PLAN BEGINNING JULY**1~** FROM- THE RCRIS REGIONAL IMPLEMENTER OATABASE EVENT TYPE =ALL CA ANO PERMIT EVENTS / RESPONSIBLE AGENCY =ALL 1ST OTR 2NO OTR 3RD OTR 4TH OTR 5TH OTR 6TH OTR JUL-SEP OCT-OEC JAN-MAR APR-JUN JUL-SEP OCT-DEC FACILITY PERMIT 99 99 00 00 00 00 1_ "'
__ .. .. t __**_~** 1 __ __ • __ _ .. _ __ I _ .. __ .. .. _ __ __ _ _ __ _ ... • VOL05 005' a S ,- OP627 07/08/99 • as- oP230 12/06/99 • as- 01'230 01/06/00 • as- OP622 04/03/00 • S -01'026 09/30/00 • • STE CONTACT: BLE' as· OP230 08/08/99 • as- OP628 12/16/99 • as· OP627 01/28/00 • 1iI S - 01'230 04/05/00 • • • as" 01'637 08/20/99 • as' - 01'638 12/16/99 • as- 01'240 02/04/00 • as- 01'628 04/05/00 • • • as- OP240 09/16/99 • as· OP026 12/30/99 • as· OP240 02/24/00 • as· OP638 05/15/00 • • • as· OP026 09/27/99 • as· 01'231 12/31/99 • as· OP637 02/25/00 • as· 01'026 06/05/00 I • I • • S • 01'026 03/31/00 • as· op240 06/22/00 • • I 1
__ __ .. _ 1_
_ __ __ - __ __ 11 .. _ _ .. _ _ .. __ • .. • VOL08 011I as- M0230 09/30/99 • as- '10231 11/12/99 I as· 01'02603/17/00 • as· OP622 04/03/00 • S • CL02609/30/00 • S - OP270 10/11/00 • STE CONTACT: BAMI as· M0230 09/30/99 I as· M0240 11/12/99 • • as- OP315 05/01/00 S· CL370 09/30/00 S· OP026 10/30/00 • • as· 01'026 09/30/99 • as- M0231 12/15/99 I • as- M0230 05/02/00 S - CL380 09/30/00 S· CL026 11/01/00 • I • as- M0240 12/15/99 • I as· 01'026 05/02/00 S· OP026 09/30/00 • • • as· 01'026 12/15/99 • • as- M0231 OS/24/00 • I I I as- M0240 OS/24/00 I I I • • I as· CL026 06/28/00 • • 1

__ .. _ _ 1_
__ __ 1. _ .. _ - __ I

__ .. __ _ 1
__ _ .. __ _ _ _ 1
__ _ .. __ .. __ • _ _ . I VOL09 0121 • as- OP100 10/01/99 • S - OP150 03/15/00 • as· OP622 04/03/00 I as· 01'160 07/03/00 I I STE CONTACT: BLE' "S- OPllD 12/01/99 I • • as- OP488 07120100 I 1 ..

__ •• __ _ I •• _ _ •• _. __ • • •• 1
__ •••,_. _. __ ••

__ J - _ - - - - - .. - - .. - _ - - _. - - _. - - _ .. - __ _ _ _ .. - _ I - _ •• - - __ • _ .. - _ .. __ 1_. __ .. • _. _. __ __ I VOL11(19) 014' as· 01'11008/02/99 I as- 01'639 11/09/99 I as- OP48901/14/00 I as- OP622 04/03/00 , S - OP026 09/30/00 "S· OP026 12/31/00 • STE CONTACT: BAMI as· 01'629 09/30/99 • as- OP150 11/15/99 • as· OP171 01/27/00 I as· 01'230 04/07/00 • • I • I iii S • OP488 11/15/99 I as· OP200 01/27/00 I as- 01'240 04/14/00 I • • I I iii S • 01'160 12/01/99 I as· OP205 01/27/00 I as· OP026 06/28/00 I • 1 .. _. __ • __ _ __ 1 __ - __ - - _ - - _ - - __ .. _1_ - _ •• - .. - - •••

_ -. - __ I --. - _ -_ - - _ •• __ 1 __ - ••,-- -- _ - •• - _ _1 .. - - -
__ _. __ I. __ • _ _ _ __ _ • V01l2 512 1 as- 01'110 08/02/99 .1 as· OP150 11/15/99 • as· OP171 01/27/00 'a s • 01'622 04/03/00 • S - OP02609/30/00 "S- OP026 12/31/00 • STE CONTACT: BLEI I as- 01'488 11/17/99 I.a S • OP200 01/27/00 • S • OP026 06/30/00 •

, I as· OP16O 12/01/99 'a S • OP205 01/27/00 I •

, • • I as· 01'489 01/27/00 • I 1._.
__ _ _ _ .. 1.

__ ••• _. __ •• _ • J .. _._ •• __ __ __ ._1
.. -- -.:. - •• -_ - J_ •• -**._~** ••• _ - - - -

_ •••• _ 1 .. _. _ _ _ .. __ • • . , V01l5 506' ' I I as· OP100 02/22/00 • • s - OPl10 08/30/00 I • STE CONTACT: BAM' • I I I • I	 __ _ •• _ I __ _ .. _ __ •• I .. __ .. _ .. - - - __ .. - _ .. -.1-

- - - •• - .. _. - - - •• -- - .-- - .1_ ••• _ _ •• - I -. _ _ _ •••• __ 1 __ _ __ _ _ .. _ .. I VOL16 50S' as· OP026 09/30/99 'a s • 01'026 12/21/99 • as- OP026 03/20/00 • as- OP622 04/03/00 "S' OP026 09/30/00 • S • OP627 12/29/00 I STE CONTACT: BAM' , I I as- OP026 06/28/00 • • S - OP026 12/30/00
NOTE: ACTUAL EVENTS PRECEDED BY 'a'

, KEY TO EVENT RESPONSIBLE AGENCY/SECTION KEY TO T50 UNIVERSES I	 E/P = FEDERAL PERMITS SECTION CONTACT o = LAND OISPOSAL FACILITY

E/C = FEDERAL COMPLIANCE SECTION CONTACT S = STORAGE/TREATMENT FACILITY E/O = FEDERAL OPERATIONS OFFICE CONTACT C = COMBUSTION EI? = FEOERAL CONTACT. SECTION UNKNOW1l , E/S = STATE CONTACT. ENTEREO BY EPA I	 J = JOINT FEDERAL/STATE CONTACT • S = STATE CONTACT

# • • •

08128/80 IDAHO SIX QUARTER PLAN BEGINNING JULY 1999 FROM THE RCRIS REGIONAL IMPLEMENTER DATABASE EVENT TYPE = ALL CA AND PERMIT EVENTS / RESPONSI.BLE AGENCY = ALL PAGE

FACILITY PERMIT 1ST OTR JUL-SEP

99 2ND OTR OCT-OEC

99 3Ro OTR JAN-MAR

00 4TH OTR APR-JUN

00 5TH OTR JUL-SEP

00 6TH OTR OCT-OEC

00
I
_ _ 1
__ __ 1_
__ _ _ .. __ .. _"''' _ 1_
_ I _ .. __ .. _ J _._ __ I -_ .. • VOL 17 504' I STE CONTACT: BAM I I I 1 _ .. _ _ I
__ __ ._ I _1
__ _ _ • iii S I I 1_ - OPl00 02/01/00 • iii S I I

__ __ _1 .. - OP622 04/03/0D I S I J._ .. _ - OPl10 08/30/00

_ 'S- OP150 10/30/00 I S - OP488 12/IS/DO 'S- OPI60 12/30/00 J
_ _ ... I VOL 18 514 1 I STE CONTACT: BAM' I I

................. __ __ _ __ _ _ • iii S • Ii S I

__ - OPl10 12/06/99

- OP150 12/14/99
• _ .. __ _ I I I

_ • Ii S
• iii S
•

_ - OP488 05/12/00 • • OPI60 OS/29/00 • I

__ • --1- S S

_ - OP170 07/20/00 •

- OP489 07/21/00 • •

__ __ I S·
- OP171 10/31/00 S - OP200 10/31/00 S .- OP205 12/01/00

__ • • I I VIISDOEID

STE CONTACT: 5151 VSH' S
- OP003 10/01/99 I I I Ii S
- OP015 05/16/00 I S
- OP002 08/30/00 'S· CL310 12/31/00

NOTE: ACTUAL EVENTS PRECEOED BY 'iii'

I I. KEY TO EVENT RESPONS I BLE AGENCY/SECTION I KEY TO TSD UNIVERSES
I E/P = FEDERAL PERMITS SECTION CONTACT • E/C = FEDERAL COMPLIANCE SECTION CONTACT I E/D = FEDERAL OPERATIONS OFFICE CONTACT I En = FEOERAL CONTACT. SECTION UNKNOliN • E/S = STATE CONTACT. ENTERED BY EPA I J = JOINT FEDERAL/STATE CONTACT • S = STATE CONTACT • I I D I S • C = LAND DISPOSAL FACILITY = STORAGElTREATMENT FACILITY = COMBUST!ON

## HAZARDOUS WASTE MANAGEMENT IN IDAHO 

# 2000

n\ll report ...'
.... , .... lime peliod fr<tm JOllWll')' 1 Ihrough o..cm.ber 31, 2000. It <ko<I,bn 1ht types and ..,..,.",t> of hazardOUI 

## w-_ Jef><f>'ed io I daho. how th

.. w.... w.. 

### Jn01'Ia8<d, and my woslo**mno ;n** **n~** oo- , i10. The report .100 di"'

..... 1M l)pn andlIo:I'IOon" oftw.douo ....- i...,.,.,ed into I daho
. Thill infonnalfOll i.**~l<d** by ,h. Idah o 0.
.... "".", ofEn,- ;ronmen' " Quali!}' (DEQ) from th< Idah o H_ WUk**Of** Ann
.... R<p<>oU .ubnMed by Lor i< ond S_II QuotrI"y Ilu .atdwl. WOOl' Gonerar<>rs**(L~).** as reqUIred by l d>llo Code S«:lKln 39-4411(4) 

# of,,,,, I daM H..._ W..,. M""'ll<m<nl
.......**IH WMA**  """ lTom repotUwbonIlt<d by«>rmIOI'<ialllaiordous wast<di<p>UI f",ih' ;.., as requi red by Idaho Coo. Section 39-4411(S ), Th" rtpool

..<lJstribukdl<> 1ht GovemoJ, UgJ . I......" and !he publio< of Idaho 10 p«...., on ........ <>Wn"

.... of Idaho huMdoo,

....... maDll8<fD<'l'
.....;vlti

.. , Addlti<>nal ;n_ i"" regording DEQ moy be foofld at hllp"""""'2.Sl
.... ;d.

..... <kqI. Th< ldoho DEQ <",",ibutcs to ,to< nOlioool <>vervI

.... of**'-~** ....... ......08..,....,' 

## ,(0... 'h""'gh**~al** Blain," R eporting and 'M R rc
. CONe,
...

## ,i"" and R

«O\'or)' Inf"n"
. ';"" Sysl<m (RCRAlnf<». The (<dora! BI<fI!l,a1 R<port desmbos naroonal hanrdou. wask Kb"';tiC'las rq>o<1<d by LQGs andTreatmen" S,ongo,ondDi$pooal(TSD) be,l" j
....

### orr 0Ih«

### year_ RCRAtnfo assign. huardo
.. ",'"'' r""lily i<lrn"fl

.... "" nurrben ond lra< k. hai",<loU> 

## w"', p<nmn,ng, ""fotoem<nl, and <OffU1i"" O<1i<>ol at h...an:lous



## ......, grn<ra'''''' fxlln,,,,, B " nn
.. 1 R<p<>rt,nll andRCRAlnfo

.. _ by 'he u.s. En,;"""""",'ol

## _to"" Agm<y(EPA) '0 ITa<k and r<p<>rt n.. "",a1 hOlal'dous ...0Sl' ""i'iti
.. '0 ,.... 1'Jnid<rn
. U .S.Congress, and,t>< publ",. Thi. ,nf"""",ion may .1", be0«n0<d 'hroo¢l

# ,h. In'
....... at ei,her ofthe fol!<>wing "l<s:hup;iI
.." ....·
.• oa·02'
...'n' irgi" Jdc' i"i.hlml, '" hnp:/Iwww·<pO·llo,"IOranl>'.

Tho Uni
........ W
.... R. Ie
..... ,rr«ti", "" May I I, 1995.Tho putpoK of ,t>< R.I, i

. to ,ncowo!/, ",,)\Oling and prop<r dispoal <>f """'" common 

## h"""""'" and

....

# ,h. "8,,1010<}' butd<n on ,he 001k<t<Jrs '" lI on <>f**""i,~1**

.. ...., r-"o"I...ly ..-.lll
....,....... The ori.ginal rul. d<fin<d !>aDrdoulI NIt""
... hozardoo.

..._ lh<>-nJ:Jolal>, and
.....ordOll p"'i,id
... i ,her

...a11<d '" oolkol<d in a p"'i,idt ooll«tion P"'S'om '
.. un"

...... ",,,,,,

. Eff «tl"" }onllOl} 6, 2000, sp<n l hannlou.



### .......lan¥ -.eadded '0 tlw: Ii
.. of"",.....,.)
......... Tho Un,wnar W R. I, allow. tho hondl
.... <>f**"ni .~1** 

....... 10 m<eI 'nnll""l standords for ooll«tion,

# "otag., lronsportOlion, andRpOI1inJ, xcordinllto 4(l CFR Pan 273.**H~,** linaI ....i
........ "*<1, r<oy<li"llo trt:OlfnrnI, ordi"""" fx,I", comply
..'i'h full hanrdo lI<JM<Ml 1«l.'r<m<1ll>, AhliOllllh**on,,~1** 

## ""'vn "'"

......ir«! to be r<porl<d "" 

# , h. I daho Haz.vdou
. W
.... G<n<raI", R<pon. DEQ
.....O.fOlI'S 10 ""Ionlorily ,ncl""" oninnal
...... ,nfonnal'on ,n tho" reports to ...iSl II'8<kinll of'h<>< lI<ri,·i,in. I HE R EPORT Tb<r-o -.e 10,602'OIlS ofhazan!Oll
......... g""""«1

## ,n Idaho d
. " ng 2000, '" f<l'OI'«I by ldollo LQOlISQGs- W
....... ..... a<<:oon,<<I rot <IIi I 'on. '"4.3% of til< 10taIreponed hozaod«l.

......, 11<'",'01«1. Non-......' ... ·OI<f
.....ordou. wa>l< """",n,«I f or 9S.1'\'
. oftho .-J or**10,1** I lon'- lbes<
......... roll in til< follo...i"-8 ""pion; R"'ErOAT ION WASff.S _ l,527 10"" MOSI rom<d iat'on "1OSl
.... lI<J1
.....«I f.-om ,he <lnn.p ofoon'am,no,«I ",
.. (S.porforid and "'''''' s;, .. p<riorminll O or,,<I,ve lKlion, ondior """,vinll and .pgro,linll .ndotll"O"nd
..orall' lanb WASff.S • 2,7QS Ion•

Thi.
....... is both hOl..-.ious and**rad~,** •.fot Ih< l"'"2000, IHmi.«I
....... ..... 11
....,..,«1arid ..orod 01 lNEEL TuA"'ENT, STORAGE. AM> D1S1'OSAL (TSD) W

ASff.S. loS 12I oru Th.. 

## ""'.ardoo
........ isg<n<r>t<d f.-om rniduaIs ond <oll«lioon JY'SrnlI at perminod TSD fx,Ii"
.. :wid hOlard"",
......, landfills. SoLVE'" W-.sru;. I,l6 1 Ion. Spcn1ool, B<Jl<f.,«I hy , ori"". ;nd""'Y on<!

...s;.... O<I;'ih $lt oh
.. paru de'V'""n• • 

## paI""n
.. '''011$ 

## mon.r""""'n. 1"'00.-0 lind dJy d.aninl!- Ov.JlA<"IuISIIC W-.sru; •**84~** I ono Thi.
... _ i. hazard<>u. \>«""
.. 'I <onllin
. """ or tnOf'< <hara<l"i"i< or illl\,'ab,l,t)', '_"i'y, fOX,,,,t)', or 'o""t)' OrI1EJtW-.sru;·IUlon
. Th IOOloid<o disoanlod ,,,,,,",,,,01<!I<rrO<:aI
.. • niwnol arid ""

...11
......... lio«d_1h< .....,.. 1ofMt.dous

.. 105k 5",""o'ed i1Il<laho. as iTpOItcd by Idaho LQGIIISQG
.. inereas<d from 7.!S$ lOllS in 1999 to 10.602 """ in 2000
. Non-
........ Okr hanrdous

.._ ..

## n ,.."," ,1><ftOOtd from 7,$Oll'or>O in 1999 to 10,141 'or>O in 2000
. TI ". i. OIl incr= of opptO, imatoly 26%. Thi. i""",ase WI be onribuled main!)' 

## '0 """" c1nl>np octiv'ly in 2000 

# ()

F"", of'h
... .. lwafdouo
...... c01cgonn liSl ed <Ill therr<lll' pas. showed iocreases from 1999 """",nlS
. 1h<
...·0 thOl oho"'ed rodU<li""

. from l'i'J'J """""'''w= Sol"..,,,
..... ChorO<1eri.bc 11'_
. A. bw, <:<lII,ino" to r<f ,.. ,I><i, proc..... '0 k<ep hazat<looJ smn.,ion down IIIld coo,in." to ..p1ou "",,·haunlou. ol
..**m.~,",** ....h
..
, ..ycling. di
..ill. /i""
. and ",bn
...... m,n,,,,,,,"",,,, and poll.'"", pr<V<III"'" opI_ puHi<; heal,h andthe <nvironmcn1 ofI dalH> "'i ll_fi,



# """'" " J!i'"

'1/95 rsse '997 1991l HI1/9 2000 

# () '9115 ' 996 1991 1998 ' 999 2000

H.y.o!!poys W AST! IIlO!'9RTED "'TD I D!l!fO

... 2000 The ""Iy <oIlm<ro
.. 1w,""",u landfill <>p<ra!,ng in Idaho i. Envir.,..f. Servi.e> ofldaho. Inc (ESIl)
. The H it Sit. ISlocated ,n Ow}'i>« C""nl)i
..... Orand Vi I doho. In 2000. E5 1tf'«<'I"ed 163•., 7 IOfU of "'
...... d"t<1l5< of 4% from ,h" 160,074,,,,,. """; ved dunng l'i'J'J. M_ of ,1>< (IH.7J-O'on. or%
.7%)r
.....o<I

.. ESll c 

## from_,
....... Idahosmn
...... ...,,5.427 ,ons OJ'V.) '0 ESIt in 2000, The II.,. from " 'hi<;h

# ,he"""
....... ,,·os 50'" '" ESIt New York, "'hieh ..." 32,ll7 ' OMf or dispooal in 20m. 1,""i,;"""lIy, ,... .......i,·0<1
.. ESlt h
.. been 'cpor1o<1 in ,hlttOJ cUl<g<>ries;
RCRA 11'
..,._ Thi
....... i.defined by the fed<r.il R""u,
.. C""""'01ion I!o: Rerovery A<1 (RCRA) and HWMA
..hanrdo
.... II i
. t<gulatcd by ldolto and,It< federal so,cmmem
PCB W
.... _ Thi. "
..... i. def,ned
.. . 'o,i. IIlib>lanc
. by ,he fcdcnd To,i. Subol""", C""trol A<1 (T'SCAl ThIS
...... i. cu
......lly ""Iy t<gulatcd by lhe f<dor.1 !<,.-.rnmen' in I dalH>, 5,
... W
.... _ Thio ,... ... i. regul
..0<1
..mtn;f<Sl<d
..... bazardo

... ",

.... by"'
..... ......ond mo" be disposed In 0permined RCRA ha7at<looJ. ",
.... d;>p<>saI facilily ,,-hen>lIippedto lolaho
. Thi. <a1<gory oJ", ,ocludeo nor>-ha.rMdous
....... di.posed at ESU,

# ( IL'ZARDOUS WASTE**1~IPORn:IlI:'lTO** 

## 111,\110 IN 

# 2000 (TONS) IKRA

# .. ShU


# ..**%~** 

## H' l_ ToT,u. Sn
.. l_ T"'

....**R<.~"** ..........n 

# ........... ............**rn** 

# , 

# ,

# .. ., 120 Sy )%J171 

# .. n .H71 

# , 29,9191 

# ..**~,1191** • 

# .­ 19.9&93 

# .. " lUll 

# , 

# ,.,n.,**1l .~)H**  

### :6.lon 16 001 

# - , N.,., u**2O~~'** 

# .. 12'" 1U' 

# , • lS ,ln
.• 

# .. 1I.19HI CO 

# ".,s.-• 

# "N ,-"n IUSU 

# '" '4,MI' 

### uu 

# • 

# , " I.t>lH ).6761 

# " 6.:ISl HJ2 S8.)IH '2H 

# • .,ooH lOB 1,)10:


# .. 1126 '.4271 2.7'70 

## '0 USg, 3.0 

# .. 2610 3,311.4 CO •.21' S 

# • " I,H I6 l.SUO 

# -"


# .. '" 1.4S19 

# - •% 2.468 • 

# .. %" %" 

# " SV 

### u 

# " 

# ,,, 1.,,""0 

# ,", on" 

# 'M' 1----
......_ 1.2.11 , 

# "' 

# .. 1.261 • 

### m JtH 

## ,n Z,6oIll 

# .. " D' m 1,01' 2**~"** 

# " m. 

# '" .31 • 

### so UH IJUI 

# " 191 2 

# '" 

# .. D. 

# .. " l.nU 

# 'N 

# '" 

# .. .. '''' M>; 1.(>&6.7 

# "' 1S61 

# 'N' 

# " 61 .7 

# - 1..11 S**--: ;--.**  

# " 

# "

•• .J 

# .. .. M' 

# ­ 138 1 

# ." " 

# '" 121 

# " IH 

## 00. H.' r-, NJA 

# '" '" NiA · · 

# '" "' W, W, W, N'A**2.~J**

- NiA · · 

### W, W, W, N,. 'A N.'A 

# .. N '" 

## I'J' 

# " NA" 

# "' ,,, 

# "' "' "'" So..." i"A 

# N' 

# "

. '"**~,** 

# "',,,

# .. SA 

# " SA l SA 

# 'I.' " 

# " !'I _A SA" SA

# '~ 

# I "" 

# " s," 

# :: " 

# 1 '" 00 SA'· SA

. ,2J.;( 

# " " '" 101.$0')1 ",101 1!>l.IS66**,~** 169.971 I**'rn~** 

# "

• I ncludes non-state entities: AD (Alberta, Canadl)
. 

## •• Included in 1999 t otal, but no waste was recei
...

### ed in 2000
.In 2000, 1 0 ,602 l<H>S ofl>azardou
. ",.""
...... ,q>o<ttd
..**~td** in Idaho. Of!h

.. omoun', 10,218 tool
. were rnonagtd

..in8 .,...of lI

.. rntll>odo hlltd btl_

.Tho r=wo.,nin8 ",ut
. w.. kepi in penninc:d 

### li ons< ""it
. . ....i'in8 furthtt ltntmtnl and d,--, .Tho chan below ,,,,,lOOn WUI. managed from I"""i""

. 

### J'ars' gmcroIi""
_**MANAGE~ENT** rctxi, MAN"'GED M"' NM; ED MEmO!) TO]>;" IN·STATE OUT·Of·STATE

Lond f,1I 

# fu_'
Reu••/RCC)"lc l.616**,~** l.521 J,S42 5,J24 

# ,. ,. 

# - 1,4&7



# - '" " I"",

..... """ 

# , 0 

# ,**~'"**



## )

I 'ON 1>.W9d e-MIt 

### '...os**O,~** e&I'IIOd 

### 'sn ;U'o'll )f Y'19 Q'ilU'ilfiOn lIJ IAUS Mlnln ' OLU OWl'"loa:

Ull!B**~H** Iltl 

### .cm"llltlU"N!4IaJOlu'"lR4'Q 0IfllPlJO OIOlS