## PROGRAM DESCRIPTION
BACKGROUND 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 significantly reduced 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). HWMA instructs 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 ofJuly 1,1990. On March 30,1995, Idaho was granted final authorization for HSWA and non-HSWA provisions promulgatedas ofJuly 1, 

### 1993.-Appendix III contains a table illustrating Idaho's RCRA program authorization status. :) 

### II. 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 Waste Rules and Standards were amended (Appendix 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

. 

# •
1

### Idaho Revised Authorization 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. RCRA 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. An 

### EPA Headquarters memorandum dated January 26, 1996 recommended States defer adoption ofthe Organic Air Emission Standards for Tanks, Surface Impoundments, and Containers (59 FR 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 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 the purposes ofthis revised application. Several title changes have been enacted; however, the duties associated with these positions remain unchanged. The organizational chart in Appendix VI includes these changes. 

### D. State Agency Staffing and Funding Idaho's RCRA program currently consists of 12.95 FTE that are utilized to implement the program. The federal government provides approximately forty-nine percent (49%) ofthe funding for these positions. Federal RCRA funding is allocated for 

### 2 

# C}

C.""-**C-~~**

### 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 VII 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%) ofRCRA program 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 RCRA program 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 Staff Support 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 currentindirect rate offifty-eight percent (58%) assessed on 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 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 VIII. 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 

# 0 regulated community must include factoring in the complexity ofthe INEL. The Permitting Six Quarter Plan better illustrates projects underway at the INEL (Appendix 

### XV). Appendix VIII also contains information regarding quantities ofhazardous waste managed within the State ofIdaho for the calendar year 1995. This information was obtained.fromthel Ss S Hazardous Waste Annual Report which is also included in Appendix VIII. 

### 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 since submission ofthe last revision package. The RCRIS MOU has been amended, and an attachment is included under Appendix IX. 

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



### 4 

# c

### Idaho Revised Authorization Application 

# • September, 1996 Page 5 

### 4.



# • 5.

6.

7. 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, Compliance/Enforcement 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 inspector's 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. 

### Hazardous Waste Transportation Authorities There are no changes to this part ofthe program. 

### Enforcement Program Summary The 1987 EPA Enforcement 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 EPA Enforcement Response Policy. The HWMA Civil Penalty 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. 

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

# •
5

### Idaho Revised Authorization Application September, 1996 Page 6 

# o
8. Waste Stream Delisting Idaho received its first petition to delist a hazardous waste from EnviroSafe Services ofIdaho, 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. ESII's 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 ofIdaho'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 Idaho's DEQ has performed all data entry and QAlQC 

### work for both the 1993 and 1995 BRS cycles. Idaho's DEQ intends to continue these activities. 

# o

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 MOU details (1) the conversion ofdata from the Hazardous Waste Data 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 amended in 1995 with the addition ofAttachment 2 as provided in Appendix IX. The MOU was updated to reflect our information sharing agreement and Idaho's new responsibility to assign RCRA ill 

### Numbers. RCRIS SOPs have been updated since the last revision package was submitted. The updated SOPs can also be found in Appendix IX.



### 6 

# c

### 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 ReviewIDecision-Making 

# • Permitting activities are projected in a Six Quarter Plan. 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 Quarter Plan [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 Quarter Plan includes all facilities under-going the permit process and permit status information. 

### I. Implementation of HSWA Amendments 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 in the RCRA Work Plan and are negotiated annually. Impacts are described below:



### 7

# c Idaho Revised Authorization Application September, 1996 Page 8 

### 1. 

### 59 FR 47982 Land Disposal Restrictions Phase II

- 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 of the Hazardous Waste Recycling Regulatory Program RULE CODES: 142 A-E



### J. 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 of petitions the Department receives. Additionally, the regulated community has already requested and received several training sessions from DEQ staff. Radioactive Mixed Waste 

# o

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.



### 8 

# c

# • • •

RCRA PROGRAM AUTHORIZATION STATUS

Cluster Covers Federal Program Changes Between Rules Adopted Final Program Revision Application Date Federal Register Approval Published Base Program Non-HSWA Requirements prior to Cluster I 1/1/76 & 6/30/84 YES 6/89 3/26/9055 FR 11015
Non-HSWA I 7/1/84 & 6/30/85 YES 6/89 3/26/9055 FR 11015 Non-HSWA II 7/1/85 & 6/30/86 YES 6/89 3/26/9055 FR 11015 Non-HSWA III 7/1/86 & 6/30/87 YES 6/89 3/26/9055 FR 11015 Non-HSWA IV 7/1 /87 & 6/30/88 YES 11/91 4/6/92 66 FR 11580 Non-HSWA V 7/1/88 & 6/30/89 YES 11/91 4/6/92 66 FR 11580 Non-HSWA VI 7/1/89 & 6/30/90 YES 11/91 4/6/9266 FR 11580 HSWAI 11/8/84 & 6/30/87 YES 11/91 4/6/9266 FR'11580 HSWA II 7/1/87 & 6/30/90 YES 11/91 4/6/9266 FR 11580 RCRA I 7/1/90 & 6/30/91 YES 12/94 4/12/95.60 FR 18549 RCRA II 7/1/91 & 6/30/92 YES 12/94 4/12/9560 FR 18549 RCRA III 7/1/92 &·6/30/93 YES 12/94 4/12/9560 FR 18549 RCRAIV 7/1/93 & 6/30/94 YES 8/96 RCRAV 7/1/94 & 6/30/95 YES 8/96

Idaho Revised Authorization Application August 1996

# • '. •

REFERENCE GUIDE TO CLUSTERSADOPTION 

# I I RULE CODE 

# I FR REFERENCE PROM,DATE ' ' ' RULE NAME ' :

, , , CLLJSTER 

# I STATE EFFECTIVE
, DATE 125 58 FR 38816 07/20/93 

### - Requirements for Preparation, Adoption, & Submittal of Implementation Plans RCRA IV 4/26/95 4/26/95 4/26/95 4/26/95
4/26/95
4/26/95
4/26/95 4/26/95
4/26/95

4/26/95
4/15/96 (f)

4/15/96 (f) 126 58 FR 46040 08/31/93 Testing & Monitoring Activities RCRAIV 127" 58 FR 59598 11/09/93 Burning of Hazardous Waste in Boilers & Industrial Furnaces RCRA IV 128 59 FR 458 01/04/94 Hazardous Waste Management System; Identification & Listing of Hazardous Waste; Wastes from Wood Surface Protection Hazardous Waste Management System; Identification & Listing of Hazardous Waste; Treatability Studies Sample Exclusion Hazardous Waste Identification & Listing of Hazardous Waste; Recycled Used Oil Management Standards Recordkeeping Instructions RCRA IV
RCRAIV
RCRAIV
RCRAIV 129" 59 FR 8362 02/18/94

130 59 FR 10550 03/04/94

131 59 FR 13891 03/24/94 132 59 FR 28484 06/02/94 Hazardous Waste Management Syste: Identification & Listing of Hazardous Wastes; Wastes from Wood Surface Protection; Correction RCRA IV
RCRA IV

RCRA IV
RCRAV
RCRAV 133" 59 FR 29958 06/10/94 Standards Applicable to Owners & Operators of Hazardous Waste Treatment, Storage,'& Disposal Facilities, Underground Storage Tanks, & Underground Injection Control Systems; Financial Assurance; Letter of Credit 134 59 FR 31551 06/20/94 Hazardous Waste Management System; Correction of**Lis~ing** of P015--Beryllium Powder Hazardous Waste Management System; Testing & Monitoring Activities, Land Disposal.Restrictions Correction Identification & Listing of Hazardous Waste; Amendments to Definition of Solid Waste 126.1 59 FR 47980 09/19/94

135 59 FR 38536 

## • 07/28/94



### Idaho Revised Application August 1996 • Optional Rule Page I

# • • •
I RULE CODE 

# I FRREFERENCE 

# I PROM.DATE 

# I RULE NAME 

# I CLUSTER 

# I STATE EFFECTIVE DATE 136 59 FR 43496 08/24/94 Standards for the Management of Specific Hazardous Wastes; Amendment to RCRAV 4/15/96 (T) Subpart C-Recyclable Materials Used in a Manner Constituting Disposal; Final Rule 137 59 FR 47982 09/19/94 Land Disposal Restrictions Phase II-Universal Treatment Standards, &Treatment RCRAV 4/15/96 (T) Standards for Organic Toxicity Characteristic Wastes & Newly Listed Waste 137.1 60 FR 242 01/03/95 Technical Amendment to the Universal Treatment Standards &Treatment RCRAV 4/15/96 (T) Standards for Organic Toxicity Characteristic Wastes & Newly Listed Waste 59 FR e28ge**12/Qe~4 ~azaFElsYs**  VVastsTr:eatmsRt, Stsra!ijs, & Oisf}ssal Fasilitiss &**~azaFElsYs** \Masts RCRAV**4/15/~e** (T)**GSRsrat~rs;** OF!ijaRis Air emissisRs**Stam~arc;Js** fer TaRks, Syrfass Imf}sYR9msRts, & CSRtaiRsrs 139 60 FR 3089 01/13/95 Hazardous Waste Management System; Testing & Monitoring Activities RCRAV 4/15/96 (T) 140 60 FR 7824 02/09/95 Hazardous Waste Management System; Carbamate Production Identification & RCRAV 4/15/96 (T) Listing of Hazardous Waste; & CERCLA Hazardous Substance Designation & Reportable Quantities 140.1 60 FR 19165 04/17/95 Hazardous Waste Management System; Carbamate Production Identification & RCRAV 4/15/96 (T) Listing of Hazardous Waste; & CERCLA Hazardous Substance Designation & Reportable Quantities; Correction 140.2 60 FR 25619 05/12/95 Hazardous Waste Management System; Carbamate Production Identification & RCRAV 4/15/96 (T) Listing of Hazardous Waste; &CERCLA Hazardous Substance Designation & Reportable Quantities; Correction 141 60 FR 17001 04/04/95 Hazardous Waste Management System; Testing & Monitoring Activities RCRAV 4/15/96 (T) 142A' 60 FR 25492 05/11/95 Universal Waste Rule (Hazardous Waste Management System; Modification of the RCRAV 4/15/96 (T) Hazardous Waste Recycling Regulatory Program); Final Rule 1428' 60 FR 25492 05/11/95 Universal Waste Rule (Hazardous Waste Management System; Modification of the RCRAV 4/15/96 (T) Hazardous Waste Recycling Regulatory Program); Final Rule 142C' 60 FR 25492 05/11/95 Universal Waste Rule (Hazardous Waste Management System; Modification of the RCRAV 4/15/96 (T) Hazardous Waste Recycling Regulatory Program); Final Rule 1420' 60 FR 25492 05/11/95 Universal Waste Rule (Hazardous Waste Management System; Modification of the RCRAV 4/15/96 (T) Hazardous Waste Recycling Regulatory Program); Final Rule 

### Idaho Revised Application August 1996 Page 2 • Optional Rule

# • • • I 1 

# I RULE CODE 

# I : FR REFERENCE 

# I PROM.DATE RULE NAME

' : ' ; Universal Waste Rule (Hazardous Waste Management System; Modification ofthe Hazardous Waste Recycling Regulatory Program); Final Rule 142E· 60 FR 25492 051111/95

eO**~~ ~e8~8** **05/1Ql~5 l=Ia~a~gol,ls**  Waste**T~eatment, Sto~€le,**  & Disposal**~aGilities** &**l=Iaza~gol,ls** VVaste

60 FR 33912 06/29/95**Gene~ato~s; O~aniG** **Ai~** Emission**Stanga~gs ro~**  Tanks, Sl,IRaGe Imp0l,lngments, &**Containe~** Solid Waste, Hazardous Waste, Oil Discharge & Superfund Programs; Removal of Legally Obsolete Rules 144 CLUSTER 

# I STATE EFFECTIVE DATE RCRAV 4/15/96 (T)
4/15lQe (T)**~C~AV**

RCRAV 4/15/96 (T)



### Idaho Revised Application August 1996 • Optional Rule Page 3

# • • • • )..**.J~** .,.-'.., . .....', -\.- .: 

# Permits and Enforcement Organization Chart

Orville D. Green Asst. Administrator

Robert Wllkosz 1SB Chie! Brian Monson GPO Clue!**:~,** Dave Pisarski EB Chiet Martin Bauer CPB 

## cuet Phyllis Heitman Admin. Secretary

Jonuo,y I. 1PgS

# • • • Permits and Enforcement

j**;\~** :J Mlchsel Lenaghen

.**~~ RIoH;t!pll011~I/Gell**  0111,;8 .,.,**~::fl l.~** 

### i.:_~; ••..:.. .

### .::..~'._~· ..

### :~·,._·.**_;.L~_~:..:.~~Il**

"" . 

### .**,~,** 

# Secretarial Staff "

Tech Services Bureau Secrela"al Stett

.. I

Valerie Engleman WVICJ f'rocfls:;iICfJ Spoc

.

Linda Smllh WOld Processing Spec. Conslructn Print Bureau 'I: Secteteuel Stett**r~**

.

## ~.l
;, 'j';'

## ~ I ; :" :.:iDfdil-illid:

## -,.:'I.Q'~;u' 

# ·ll

.. •.... L."l •.l

Belly Miller IVOI,I f'lOcesslflg Spec.

Nols Knackert Word Processing Spec.



### - Phyllis Hsllman Admin, Sectetery

Sherry Davis lV'I/,1 f'r",.'tlssIfIU Spec.',

Terl Gregory Senu» Se<:I<llary '- Operating Prmt Bureau Sectetsrie! Sla/(

Rene Johnson WI/lei PIO<:eSSIIIU Spec.

<.

Jessica Jones WOld Ptocessmq Spec, '­

# • • ••



# • • Permits and Enforcement

. Construction Permits Bureau

Martin Bauer ..4.



## Bureau Chief 

# I I Dick Rogers Water Permit Mgr.

'0 ".'" \v, !]i/: .••• ,**~:.** ,I I. "',:':.':"'!'f"**~I** .i -0; I} l:.

... l!**\~** j;

.... :..**l~-'** ,

f-- 

## Jose Fabile
- Nancy Bowser 

## WO Analyst AQ Engineer



## - Mike Cook George Fink AQ Engineer WQ 

## Analyst

f-- 

## Rick Huddleston

- Ray McDougal AQ Engineer : WQ Engineer

f-- f-- • 

## James Macinnis (NIRO) 

## Bill Rogers We) 

### Cllgineer AQ 

### Engmeer



## - Dan Salgado f-- 

## Paul Wakagawa AQ Engineer WQ Engineer ."



## - Mike Simon '-- Jerry Yoder AQ Engineer WQ Engineer

AprH n. 1996---------- 

# Permits and 'Enforcement Operating Permits Bureau

Brian Monson Bureau Chief 

# I

I

... , 11'1._' I 

### I 

### Rensay Owen LOR Section 10 Falls**~"'l"** , T1 l.-.'. ;"""'1-,:.\ ..**".~'.'** 'Hf:';"'1 ;"·'· '1·.·.· .. ,·1

.... Ill". ;'",\ 

### Randy Steger HW Permits Manager
,-;,,',11.­**·.~** .. ql .•**,.·.··,,~~,·** '''''''' " "" , .. :'**~.** , : 

# I

.•• ·;,ii 

### I Sue Richards

AQ Manager

# • • Permits and Enforcement Technical Services Bureau

·1, 

## Robert Wilkosz Bureau Chief



## Val Bohdan Senior AQ Engineer 

# I John Brueck HW Program Oev. Mgr.

f-- 

## Paula Jo Miller L 

## HW Science Officer

r-- 

## Pam smolczSnski HW Program pecialist

- 

## Tim Teater Permit Support Super.

I- 

## Gary Reinbold AQ Analyst

'-- 

## Tony Wilson Prog. Oev. Spec. 

# I AVijit Ray Env. Sciences Manager



# .

- 

## Tom Anderson AQ Engineer

f- 

## Joe Baldwin Env. Hydrogeologist

- 

## Carole Thomas AQ Engineer

"- 

## Mary Walsh Meterologist

< r-- 

## Jerry West WQ Science Officer

- 

## Wade Woolery ARAR Engineer

Novamba, 16, 1995 •

# • • ••

I' 

# Permits and 'Enforcement Enforcement Bureau

Dave Pisarski

Bureau Chief "'7.<'''' :1.":""''''-''''''''''''''' "I""

### :'.:,,~, ' ,'.1'.",

# I:" , . . n.,,,, 'J'"". ,.. ,," 

## 1 

# !

,-,.,-'1-'-'"'''' 

## J 

## I Mike Gregory

. HW/W Enforcement Mgr.

11:

...... :"

..·.:,1::' ..

...**~,** .. ".'.". ,.···.·.. 1·' '" ,..**JI·'~·'\·"";~·~'·'''·'·''''.''·U'''.''',H,,·.·~~,** ... 1\t ....¥;

.. ";,"

I- 

## Matt Alvarado HW Science Officer



## - Matt Garringer HW Science Officer

I- 

## Patricia Harris HW Science Officer



## - Robert Higdem HW Science Officer

­



## - Chris Lavelle WQ Science Officer



## - Eileen Loerch HW Science Officer 

## '-- Natalie McLeod 

# I I Tim Trumbull

. Air Enforcement Mgr.

.' ,,' •**~.** .;.. ' '. • , ", " • .' " ' ••.• I • ;, ••.., .......**~'.,** •.• "'"

I- 

## JR Fuentes AQ Compliance Analyst



## - Ron Hill AQ Engineer



## - Sally Tarowsky AQ Compliance Analyst



## .-... Connie Wold AQ Compliance Analyst



## - Tom Harman (NIRO) AQ Field Supervisor <



## - Tom Krinke AQ Science Officer

- 

## Rick Elkins (SEIRO) HW Science Officer AQ Science Officer

Seplemb,,' 25. 1995

# •

•

• 1995 Basic Criminal Environ. Investigations 1995 Conf. Hazardous Wastes & Materials 40 CFRParts 264-265 Subpart Training 40-Hour OSHA Training a-Hour OSHA Refresher Advanced Authorization Conference Basic Criminal Environmental Investigations Bioremediation Symposium Calif. EPA Air Resource Bd - Incinerators Calif. EPA Air Resource Bd - Hot Mix Asphalt Chemical Safety Audits Chemistry of Hazardous Materials Conflict Resolution: Preventing ViolencelWorkplace Conflict Management Skills for Women Connection: Groundwater in Idaho CPR Effective Business Writing English 201 Critical Reading & Writing Environ. & Safety Solutions for Mining Industry Environmental Enforcement EPA Advanced RCRA Training EPA Toxic Chemical Release Reporting Erosion Control Workshop Explosive Ordnance Disposal Support Fugitive Dust Emissions Integrated Data for Enforcement Analysis International Incineration Conference

<- 

### RCRA STAFF ATTENDED TRAINING 

### 1995-1996

International Symp. on Environ. Tech - Plasma Introduction to Soils Introduction to Ground Water Investigations Investigation Management LOR Satellite Training Liner Technology National Technical Workgroup Exec. Bd Mtg National Enforcement Training National Meeting for Corrective Action Organic TSD Emissions Polaroid School of Law Env. Seminar Preliminary Assessment & Site InvestigationRadiation Worker & Safety RCRA Land Disposal Restrictions RCRA Policy Conference RCRIS/BRS Data Management Meeting Remediation by Natural Attenuation Respirator Fit-Testing and Training Rethinking Environmental Regulation Risk Assessment Guidance for Superfund Sexual Harassment Education Supervision & Human Relations Using the Internet Vadose Lane Hydrology Waste Testing & Quality Assurance Waste Management 95 Conference



### IDAHO REVISED AUTHORIZATION APPLICATION AUGUST, 1996','-. 

# • IDAHO 

## ·HANDLER ACTIVITY COUNT REPORT· July 22, 1996

Fully Regulated Generators 52 Small Quantity Generators

. . . . . . . . . . . . . . . . . . . . . . . . . .. 191 Conditionally Exempt SQGs 757
HW Transporters 73 . Subject to CEI Universe (Calculated Universes) 10 Land Disposers Combustion/Incinerators BIFs Treatment/Storage 

### 8 1 (1 

### facility - 4 units) 

# o 5 

# • UO and HWF HANDLER ACTIVITY·· Used Oil Fuel Handlers (Notifiers) 40**~arketers** 

### Transporters Burners 7 12 6 Hazardous Waste Fuel Handlers (Notifiers) 7 Burner/Blenders Marketers 7 3 

# • * Source: Resource Conservation and Recovery Information System (RCRIS). Idaho State Database.

. 

## ** Handler Activity: This information is generated from the Notification of Regulated Waste Activity fonn (8700-12) and is a strict 'notifier count' which may.not reflect actual numbers.

- --- .... _-- -.--- .,.. -**._~.** ----------:-"-------

--- -----------:----

..

### _------_.-. ... -- :..... " . .' 

# • IDAHO ANNUAL QUANTITIES OF HAZARDOUS WASTES October 1994 - September 1995



# • ACTIVITY ANNUAL TONS Generated In-State 1,219,964 Transported Into State 32,596 Transported Out of State 2,472 In-State Treatment and Disposal On-Site 1,217,972" In-State Treatment and Disposal Off-Site RCRA 33,415 TSCA 69,716 State HW 12,806



### * Source: Biennial Reporting System (BRS) for January 01,1995 through December 31,1995.



### The quantities displayed above for "General In-State" represents wastes generated by Large Quantity Generators and Small Quantity Generators. Conditionally Exempt Generators are not addressed in these data. Idaho generators report to the Sate pursuant to Idaho Code § 39-4411 which requires an annual report submittal to the DEQ. 

# • Idaho Revised Authorization Application August 1996

# o

Helping generators comply: DEQ's compliance assistance program Sorm Lane of Norm's Auto Body Shop had a problem. He wasn'l sure if he was complying with all of the hazardous wasH, regulations that applied to hi, business. After reading an 

### anide in the paper about a business like his that was cited be<:ause of improper dispos.al of sump "'aste, he wondered if he should be handling his sump WI<le differently. He didn't want to face the hassle of an inspection, yet be didn't want to 110 something that would contaminate the local aquifer or the river where he and his kids like 10 swim and fish. But he was concerned that a call to DEQ would draw trouble his way. So when Norm was contacted by Hazardous Waste**lns~tor** Eileen l oerch, oITering to come Oul to his place for a hassle-free mspecnon. he was at once skeptical and mlereslcd. "] wanted to make sure I wasn't inviting trouble," explains Norm. He didn't get trouble, Instead. he got a courtesy visit to his business by one of the state's hazardous wa-te inspe<;tors, lie learned aboul non-toxic sol"ents he could use in his parts

.....asher, The inspector went m'er new protocols for managing sump waste and gave No"" a fact sheet outlining the pl'OCCSS. "Td do il again" said Norm, "and I'd recommend it to other people," Norm i, a composite of over 50 people and busine,....s that have taken advantage of DEQ', RCRA Compliance Assistance pilol program which helps generalors comply with hazardous waste regulation,. Through this program. bu,i_ aesses have an opportunity to ha,'e a hazardous waste inspeclion conducted with no risk of enfor<:ement action or penalties, The inspections conducted during the pilot project focus on small to medium size businesses which generate small quantities of hazardous waslc, Prior 10 the inspe<;lion, the inspe<:tor will discuss "ground rules," They include a commit. ment from DEQ 10 forgo enfor<:ement aclion, provided certain criteria are met. There are a few caveats, howe"er. If the inspector observes knowing or willful violalions or significant conlamination from releases of hazardous waste or malerials, is denied aCCess to any portion of the facility, or is verbally abused, the compliance inspection will immediately be terminaled, and Ihe inspector will leave the business, TM inspe<;­ tion will also be terminated if a condition which presents an immediate thl'<'at 10 life, bealtb. or Ihe environment exists, If the inspection is terminated under these cir<:umSlances, the business loses enforcement immunily, "I really enjoy conducting Ihese inspeclions." say, RCRA Halardoos Wastcs Sciences Officer Eileen Locrch. "I point out any areas of concern and answer que<lion, about hazardous waste management. If I don't knov.-' the answer, do some research back al Ihe office or find out who does know the answer and refer the busi. neSS 10 the appropriate person or agency, Also. since Ihese inspections take less time and require less follow.up than an enforcement inspeClion, I Can perform more inspections." Loerch continued. "Wilhout the specter of enforcement standing between us, we can have open. clear discussions and exchange idea-, Bmh the inspector and the business' representative Come a"iay from the visit with a dearer understanding of Ihe other person's point of view. and we both learn from the experience" 

## I**Df"(l** £-+<0• .-I 

# - /to/f.S Ilnown C

... ..__**~'** 

# .... .s.-. .. ' . 

# -'

. 

# - b<:r_,

..._ .. 

# ..... ., , 

# -

...... , 1;\0- EI'll.-..

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.. _-'" 

# - 

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## ~'~~U;' 

# _. -'



# -­ -­ £511, £& 1 f


# ........

# .,

# .... •. ",no , _



# - a _ ..... 

# --­

....

, p .......... 

# --­ ...... , _"a'

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### _ 'f

... 

# .......

# _­

.... ,t It("/t.f

.. ,.." 

### n-n. __
S '

..0...."**,j <1.**  I.'H ,_**,"--'f"~** 

## ""--' 

# Managing hazardous waste data The. <bta rn Ih" <C'f'I'" "ere comp,led from quanerly report' 'ubm,n"d by larlle and "rtall qUJnllly bazardOtls ",a"e ,,,,,,,ralon In I<bOO The"" .epon, delail lype' and amoun1> of haLardoo. "a. Ie ",n"raIW. 

## 1M,,, "asle

.......nag..u. and lbe amounl. of " ••le rema,ning on-<I1e. prm ,dlnll a ··.nal'

....OIM of huardou. "Ule mana,ernenl ,n Idaho \\,,, al"" obl.un ,nformallOQ 

### on

...asl" from 1M Federal B"",­ mal Rcpon Th' rq>OfI

.. =lu,red from Jar q
... 1,ly JIC1K"ral"'" and ITellmCnl. "'"'" oJ d .po..al f., h""" 

## ,n ee l cd 

# It... for mfonnalKJU on llazaflk " "tnllOll, manag,,­ menl and lrn.trneT11. and wasle mmulU· ?alion ""Uul"". [)au fium !hI' "'I"'fl i. entered inlO • nal,onal har.ardo", waste databIlse 10 pro.,dc a nahonal**~snapslxM"** of hlLzanlou. "asle man**a~.** The**199~** feder;ll H'cnn

.. L Report forms and Insttul:11OllS "'eTC m:mdy """" 10 all lQ(1S and TSo. DEQ """" doUb called RCRIS 10 lfaCk hanfdo._ ...­ 

### facilm.... penrutWI&. 

### ""foo,""'''''11 iIIOd corm:tr.'C ao;Uon. lbo' IS aho a _ tiona! d .. N IC: IIKd '" lhc L Ea.-iroammtal f"100a:l

... , "lJ'"l'O'1 10 IndI. 'Ii-..aI and 

### Sw"**R~R."** act"Ill'" 

### I


# Permit update T

wo H\\ 'I" opcalllli pennit. for un'l' al I...El were 'uaed 11I" ycar. 0. of the penn 'la ia for specifIC: "' ''IC mana,,,menl a"li\1 ' iu bei n.S eonducled al 1M Rad 'o.lIcll ", \\al l" MUlag"menl C"ompl" , 

### 1bc Olbcr '" for 

### a etlc"""al ...·1I1e handhllll and neulrahza lloo fae ,lny. 

### Sc'C11 addUlonal petalil Iwheauons. repreocnllnll III wardoll' " 'asle manal"mcnt unllS. arc """",,n.lly being res ,n.'ed and I'roc" . ocd , T

... 

### -o drafl pemm, .. ,ll 

### Ix preW"nlw 1 01 M pllbhc



### ,n ea.ly 1996

. W" 

### e..pect 10 rec"ive Ib,,,,, more permil applicalions in early 111\16. "lure than 70 unlll Ihal lreal and Ilor" hU-Iroolls "'·U l'" al the l"'El operale under int"" m Sta l"S p,ovisions

.... hich al1o... lion s Ihal " ·ere In operanon plior 10 reg ulalion 1 0 co nl;nue 1 0 operale pro ,',d"d lhe y 

### meet specific ,equi remenll. Evenlu all y lhese uni" w,lI be eueer f ully pcrmined or cloocd "lor" lhan 30 ,,, qu,,. led changes for unin ope rallnll under ",'enm slalus were reviewed by DEQ in**lI'i~,** 

# Legislative action changes reporting 

# requirements I_cad offi f< ",

.. )Qf.halardous" <Ie

.... _ fi "only one LcglSlat'llII**~;ed",** the 1_ kgis1al= and 

### lI&J>Cd l') (.. """" Batthas chan..,.l !be 1q'O<>f1' for hazardom" a<;tc**~on** from qualle,h 10



# ....... ""'" The Ie" Lallon. proroscd by the JOlnllq' IIu,,, Task torcc on the [", 'ronmrntal ,>It11T1<'01 Sc Iml,al"e. 'rctroael"eloJa 

### uuy I, 

# "'" Other \han lhe**~"enn** of filing. llle reportlllg requ,mnenu rerTl3l1l the sa""'. Generators ...,Il sec lhe same famIliar <C'f'Iln f",m••JU I 

### lessoften Ge""talo" '" 

### ,11 m.:el\ 

### e reporting fonm In Ihe rrulll ",lh a mn'nderlener in**(kl~r** 1'191> The report '" ,II be duc to DI () on January31. 19Q7, I

# Hazardous Waste Imported into Idaho in 1995

•**R~,"k** 

### Sule 

# _eRA PCB 1995 % . f 

### 1994 

# w .... w ... W;aste 

# ,

# .... Ictal 

# ,

# .... OR 

### 2 

# '" 3,7112 9367 

### 14.000 12.0S°;i, ltl,l75 Il 

# a 0 9,412 

### 2,723 

### 12.135 1O,47"1io 

### M WA 

# • 3,324 5,622 2.651 11,597 

### 1O.0'!. 

### 211,1123 

# " s 0 0 6.673 

### 6.673 

### 5.76°,. M 

### CA 

# " 4.412 \,493 08 

### 5,973 

### 5.15% 11.034 ID 

### 7 

### 2.507 

# '" 2,278 5.f,OS 

### 4.113% 

### 2,831 

## vr 

# " 335 4,974 0 

### 5300 

### 4511% 

### 3.755 

### KS 

# , \00 1.7411 L69Q 

# 3'

.... 3.06% 1.357 

# "" \0 

# , 

# '" 1.776 2.475 

### 2.13°,­ 259 S\A 

### 11 0 

# ",., I. ,," 

# z.eo 2.12°". 2.833 AI( 

### 12 ,1115 

### '5' 

## .c 1.385**l.l~** 1.8119 

# rx 1J 

# '" \,065 

### 12' 1,.3311 

### 1.15% 327 OK 14 7 0 

### 1.043 1.050 091% M 

### SD \5 

# " 

# , 953 %\ 

### 0.113% 

### J.273 W 

## re 20 7)2 14 

### 7" 0"% 

## ·no PA 17 0 0 

# "" "" 0"''' 

### 2.253 

## co is 0 JjJ 

### 273 

### 626**O~o4** 3.145 

## I \11 

# " 0 0 

### 590 590 051% 

### \5

FT. 

### 20 0 0 

# '" "7 043% 

# '" '" 21 0 

### 233 231 -l<i) 

## 0"'" 

# '" 'I' 22 0 

### \5, 

### 21S3 '37 0) 

# '" Rl 

### 2J 0 0 

# '" 

# "" o33°,. 4.561 

# " " " ) 200 

## )"**O.3~** 

### IT 25 0 

### 203 128 ))\**02~** 

# '" 11\ 

# ze 207 92 1J JI)**O.2~** 

# "" Iw 27 0 0 

### 286 

### 286 025% 

# ....

ABU 

# " 263 0 0 

### 263 0.23% 451l 

### AZ 29 0 0 239 239 

### 0.21% 324 

## wy .10 

### 5' 92 

### \5 

# '''' 014 

## 'N SIT 

### 31 0 

## es 95 

# '''' 0.14°'" 11.850 1 '" 

### Jl 

### 7 

# , III 

# '" 0,1)"4 

### 2J 

# I ,,\ )) 0 0 

### \'3 14' 0,12% M

OC'

.. 

### 34 

# " a 0 

## ei 0.05"'" '08 

# '" 

# " 0 -l<i 0 -l<i 0,04" '" 1.414 W\ 

# '" 0 

# " 0 

# "**O,04~** 

# '" W, 31 0 0 

### 20 20 0,02"" 

# '" \lX" 

# " 

# " 10 0 

### 17 0.010/. 

# '" DE 

### 30 0 

# , 0 

### 7 0.010/. M**~M** 

# '" ) 0 0 ) 0,0': 0 

### 22 

## TR" 

# " \ 0 

### 2 

# ,**O,(~** 

# '" AL' 

# .c M 

# '" 

# '" M M 

### 1.'i4 GAO 

# " M 

# '" '" M M 

### 219 AR' 

# " M 

# '" '" M 

# '" 17 MDO 

# " M 

# '" '" M 

# '" m GUo 

# " M 

# '" '" M 

# '" 79 

### Total 

## - 12.XH(I 3.'.415 (19,716 115.9311 100% 

### I03,54X

# Trends in Idaho waste generation During**99** Idaho generalo", reported that Ihey generated 1.219,964 Ions of hazardous waste, Th

.. was a deerea"" of 130.039 tons. or 10" /0, from 1994 This reduction was due in pan 10 less waslewater being generated. 0,'''' the**yea~** lrl'nds in waste generation ltavc been difficult 10 establish. Differences in generation amounts all: mainly altribulable to impro\'ed dala collection methods, belle. reporting of wastewater thai is hazardous "'3>1", and reduction in the types of wastewater considered hazardous waste . • 

# Hazardous waste generated in Idaho in 1995 '92 '93 '94 '95

Solvent waste is generated by various industry and bUSiness aclivi· tics such as pans degreasing and dry deaning, 2.164 Ions. (23.2° 4 ) was generated during 1995. Wa'le is both haz.ardous and radioactive. It is generated and stored at INfL. During 1995 1.685 tons ( 18,1%) were generaced .

• The remaining Itil tons (1.7%) of tbe nonwastewater 100al is a variecy of waste Iypes. including discarded chemicals. wood trealing wasle•• and other listed '89 '90 '9 1

Remediacion waste is from deanups of conlaminaled sile.. II Can be

generated at various sites where contamination has occul'TCd such as Superfund 

## sues. Typically,

remediation wa,Ce i, contaminated soil. There

were 150 Ions (1.6%) generaled in 1995. Wastewater made up 99"/0. or 1.2 10.650 tom. of the ha,,ardous waste generated in Idaho during 1995. Water that is u'led in indu,trial processes becomeS hazardous when il is**mi~ed** wich hazardous wa,Ce. or eoncain, eharaeceriscie or Ii,ced hazardous wasCes. The remaining 1% of the haz.ardous waste (9.314 1(Ins) are made up of:

• TreatmenC, Storage and Di.posal waste is generated from collection systems at permitted TSD facility hazar-dOllS wa.te landfill•. Of the 1% of non·waslewaler waste generated in Idaho in 1991, 2,766 Ions (29.7%) was TSD wa.te.

• Characteristic waste is hazardous becallse il may be ignit_ able, cotTOsive. reactive or**lo~ie.** 2.388 ton. (25.6 %) of chis waste was generated in 1995. 1,0"

. ,....**'~8**

•

•**MI~ed**

•

### w.. 

# i

# r
.... .:.

I**~"'**

wasles, • •

Wh'_

.... .. M <,h

....**,I;~_-4I** .. /9911 of "ltgl. _"

.. "" a' INH '-""ltil>u,'"a**~,Jrol** <>/

### _,It'" ldal>a' , """I i. IW1. T1>t j'«ili,,·..JJtJa II=>M,,"-'

........ '" a

__ltu2aM"" M"'-'U'wat",

....kitlgtllt

... "tta

_ _ 

### 11=>""""-, "",-,I; aJI<1 

## ""'-'U>m"'''

_

## <""., "" M".tt. T1>t

.." ytdI' ,I>ty Jj<rol'l,i."'",lot I'mdw,**~iJtg**
,,.,.,., ratalby**V7~,6~3** 

# -

### Reuse /ReC}'de A hazardous waste wlvenl Ihal IS run Ihroog,h a s1ill to rem,,,,c contaminants lIIld reused i, an example of a wa,IC manaSed by reuse and m:ycling. Some generators maintain Ihm 

### own still, 10 

### treat sol,,;:nl, in thi, manner, others ha,·e a recycling company pIck Ihem up to recycle them olf.site Hazardous WaMe

....ialer i, Iypically managed by treatment
. as is some TSD waste,



### Incineration Hazardous wastes thai are incineTJted are burrn.'<.l al "'I)' high lemperalures. Some solvent wa,les. n'111CdiaILon wa,te,. and characteris1ic wa,ICs 

### arc incinerated 

### I Treatment Ha>ardou' wa,le that i' treated is chemically changed 10 remove Ihc chamcteri,i,e thai made il hazardou,

. A waSlewalcr Ihal is hazardous because il is acidic, for c'ample. may be changed whcn an alkaline ,u[),;lanee" addc'<.l10 change the pH. 

# How hazardous waste is managed LJn dfill

Hazardous wa'te that i' landfilled is /i"l chemleally 'tabilized. ihen "'hdifie'<.l, It is then placed m a I"'nnined ha7.ardou, wa'lc landfill, Remediation wa,le. such a, contaminaled 'oil. i. typically managed by landfilhng. as IS ",me TSD wa'lc and characteristic waSlc•.



# How Idaho's hazardous waste was managed in 1995 Ofthe 1.219,%4 IOnS ot'bazaroous wa'ie gCOC1"' ated in Idaho in 1995 , 728.288 

### too, WCTe managed in Idaho, T1>e remaining amounts 

### ",ere u,ually kept in I"'nnined siorage units. awailing treatment and di.posal. Aboot 4% of that waste was 

### recycled in I daho

. %

.... of the wa>1e destined for recycling wenl out"",f- s'tate. There are no commercial incinuat
..... in I daho. so waste mUSl be taken oul ofthe stalC for incineralion. An e\perimcntal iocincrator at I NEL incinerated 

### some wa.-n: in 1995, a.ceounting for lhe 30 ;;' ofwa ' IC incinernted in SIale, • 

# ,- 

# ... landfIll 1,11>0 

# -..­ 

# -­**~,** 

# '" Hazardous wasteimported into Idaho (0.2%) (79.1%) m Y/ .) E nvirosafe Scnico:sofldaho, Inc , operates Idaho 's ltealmc"' 

### m
.... n 4,717 

# '" only commercial haz.ardoo., """le landfill. Wa.'lle i.m:eived reu,", Of recycle m,"nerallon 

# ."" ('/'I.s" 4 ) J.7S7 (0.2%) (<ill %) 

# " (<ill %) ('/'I ,'Ill" 4) 

# " (4,

2%) 

# '" (263'4) 

## st ( ! (x1'4) (0020/ .) 

# '''"' ('IS, 8%) (97J1%) 

## o (0'

1 .) from mosI Slales in the United States, SC'ICralAmcrican ICfrit OOcs

. Canada and M exico. In 1995, ESIIreceived 1 15,938 tons of",

.. 'Ie. an incrca.. oflO.7';;'from lhe 103,54 8IOn,theyreceived during 1994 M

06tofthis wa.SIC (95 %) carne from out-of-state

. Total**n,,~** nS. 81b 2

. 4n Only5%oflhewa'le, 5.605 ton
..came from Idaho genera­ ('/'1,70/ .) IOJ,\,.) lors ,That'san iocrca", of2,77410ll'0verthe amount senl 

# -..-

............

Hazardous waSle is la nd fill«l in Ida ho at a commercial pennined hazardous waste landfill owned and 0l"'raled by En" irosa fc Service' ofIdaho, In<:. The landfill is located near ( ;rand" iew'. 80"

... of Idaho's landfilled wa,te was managed 

### in-state, with 20% going to out
...f·'lale I"'nnined hazardous wa,te landfills

. 724.884 Ions O fw"le were treated \(I reduce loxicily prior to di,posal. 99" /

. ofthis Irealment was 

### done at lhe facility where the wa",c was genernted. 1,757 IOnS ofwaste were reuSl'd or**clt'd** 10ESll in l 994, Three majortypesofwasle arereceived by ESll :

• RC RA W 

### e_ICwhich is defined by federal and state lawashazardous. • TSCA Wa.,le i. defined by TSC"A and regul ated by the EPA in Idaho • State ""-as lCwhich is defined and regulated as hazardous by other states. bui not by Idaho, Whenbrought to Idaho. il i.handled as a hazardouswa.'<Ie •

### I)/r'"' "

# \l~**az a d o u**  waste regulations

Used Oil R egulation5 I daho h a<; had regulalion s pertaining to used oil f or over a year. Federal regulations foon<! in 40 eFR part 27 9 have been adopled by reference by !be slale of I daho

. •Adoptedby reference " mean. lhal !be

....ie adopted the federal rule. j u.1 as they are in the federal books. Idaho i. required 10do this 10 keep our program as strict as, bol no more

. tricter than. the federal program. lk u.sedoil regulaliom • apply 10regulaled generalors, Iran.porters, and borners ofused oiL DEQ bas brochures availahle on these regulalions. If yoo 'd like copies or woold like 10 talk with 

### someone aboul these regulations, conlaCt DEQ.


### Universal Treatment Standards TIle uniVffSalllUlmenl

. tandard.... or lITS, .treamline the existing set of land dispos.al restriction IlUlmenl .tandards

. TIley apply uniformly to the trearmentof over 200 contaminanlS, regardless of !be waste in which it is foun d. TIle lITS rule also finalil.e. land di.pos.al re. triction .tandard. for 42 newly_listed identified wastes. 

### Universal 

### Waste Rule Tbe univernal wasle rule streamlines regulatiOllS governing management and collectionof certain rommonly generated wastes known as ' uni veJSlll wastes ." Univa-sal include ""'".ardons wa>;!e batl"ries sudl as nickel

### cadmium batteries, 

### some hazardous Wa>;!e pesticides. and mercurycontaining thermostats

. By reducing certain regulatory requiremenIs, this rule will encourage environmentally-sound collection programs and req'cling. Individuals may pelilion DEQ to include Olher w

..,1e .tream. as universal wasles, providing !bey meet !be crileria e sta blished 

### under the rule.

l'1li,- ""•...J**ospJa~** "" ,lot**,~~** ""''' proKrIlot i,- "'lfI'.-d I>l' 

## ""If' 10",. ""',

..... J9- 111 1. 

### no. ,..".I...- l i,-" l»\:I, Joi ",

..../IIN ;rochMkd;",1N "'porl, 

### I.fiw-'

.....**;. .,.....**  uf ,lot"'I"'" i,- 

### Q"'iklbJ_rn- DEQ. 

## £iJc

. ropy",'" W ,j j

# -- IDAHO DEPARiMENT 

# C·

OF HEALTH AND WELFARE DIVISION OF ENVIRONMENTAL QUALITY 

### ,.

1410 Nortn HUlOn, Boise. 10 83706-1255. (208) 334-0502 Philip E. Batt. Gavernor 

### July 25, 1995

Judy Fey U.S. EPA Region 10 1200 Sixth Avenue Seattle,**Washi~gton** 

### 98101 Dear Ms. Fey:
RE: Attachment #2 to 01/10/91 RCRIS MOU for Idaho 

# • Enclosed is the above-mentioned attachment in which DEQ and EPA, Region 10 agree to share all data, and agree that DEQ has assumed the function of assigning RCRA ID Numbers. Thank you for your assistance in this matter
.. Sincerely,



# .**'n!ltt~~** 

# 1l,tcLi

# u-dNatalie McLeod Hazardous Waste Science Officer Technical Services Bureau Permits and Enforcement

NM: IS\memos\rc:rismou.ac.c. 

### Enclosure

cc: COF**,~~** 

# •."

.......,. 

# .' ATTACHMENT #2 TOOl/10/91 RCRlS MOU FOR IDAHO**.~~- .:~""** 

## ... - ..-. ."

. '..



### Section 

## n. TERMS OF AGREEMENT, Paragraph 

# B: Information Sharing, last sentence: "All data may be transferred as Region 10 and DEQ collectively agree." EPA Region 10 and DEQ hereby "collectively" agree to share all data. All data is defmed as "core" and "non-core" data. It is understood that the non-core data will be transferred to the Region 10 Merged and Implementer Databases only. Non-core data will not be transferred to the National Oversight Database.

Section II. TERMS OF AGREEMENT, Paragraph C. Implementor of Record Policies/Assi!ffiIl1ents, 1. 

### lOR Policies, (a)., last sentence: "When access to the Facility Index System (FINDS) is established, DEQ will assume the function of assigning IDs." EPA Region 10 and DEQ hereby agree that DEQ will assume the function of assigning RCRA ID numbers through the RCRA ID Module of RCRlS which was implemented in 

### Version 6.0.0, February 1995. 

# • SIGNATURES

U.S. Environmental Idaho Department of Protection Agency Health and Welfare Division of Environmental Quality

# -,~Jo.,_**C)~** 

# __ Judy Fey RCRlS Project Officer RCRlS Project Officer Date 

## G / 7 

## J

# 9S- Date 

## 7/21

# /q~ I I 

# r I 

# •. tRCRIS STANDARD OPERATING PROCEDURES 

# • July 1, 1996 I. Introduction 

### The Resource Conservation and Recovery Information System (RCRIS) is the automated data -system used by the Idaho Division of Environmental Quality (DEQ) to track hazardous waste permitting, enforcement and corrective action activities. The system also maintains general information about all of the hazardous waste handlers in the state. RCRIS is physically located on the EPA mainframe in North Carolina. DEQ has access to its . own account set up by EPA on the mainframe into which all of the RCRIS data is entered. DEQ's data is electronically merged with EPA Region lO's data once a month, and that data is further merged with the National Oversight Database. The staff involved in the operations and maintenance of RCRIS are listed below:

• SAIDBA - The System Administrator/Database Administrator is in charge ofthe overall management ofRCRIS. This person must perform the duties ofthe System Administrator and the Database Administrator as described in the RCRIS Memorandum of Understanding, the RCRIS User Guide and this document. 

# • • Hazardous Waste Permit Officers - These staff members are responsible for providing permitting and corrective action information to be entered into RCRIS, and for performing QA/QC after that information is entered.

• Hazardous Waste Science Officers - These staff members are responsible for providing compliance and enforcement information to be entered into RCRIS, and for performing QA/QC after that information is entered.



### • Data Entry Operators'; These staffmembers ate responsible for entering information into RCRIS.

• RCRA Hazardous Waste Program Development Manager - This person supervises the SAIDBA and is responsible for overseeing the overall management of RCRIS.

• 

### RCRA Permits Manager - This person makes suggestions to improve the operation of the permitting and corrective action aspects of RCRIS and coordinates with the SAIDBA to implement those suggestions.

• Environmental Enforcement Manager - This person makes suggestions to improve the operation of compliance aspects of RCRIS and coordinates with the SAIDBA to implement those suggestions.
1 

# •:. -,
The following are Standard Operating Procedures for the operation and maintenance ofDEQ's RCRIS 

# •

•

• database. Included are procedures for data processing, data entry, QA/QC, data retrieval, data maintenance, system maintenance, security and information sharing. .

II. Data Processing Information to be entered into RCRIS originates in two different places: DEQ staffand the regulated community. Forms from DEQ staff include permitting forms, corrective action forms, and compliance forms. Forms from the regulated community include Notification forms, Part-A forms, Non-notifier Data Entry Forms, Notification Change Worksheets and annual reports. A. Forms originating from DEQ Staff Four forms are completed by DEQ staff for data entry into RCRIS. One form is used for permitting information, one is used for corrective action information, one is used for both permitting and corrective action information, and one is used for enforcement information. Each form is described below:

• RCRIS Event Update Form These forms are used to enter information regarding permitting and corrective action events. They are completed by the Hazardous Waste Permit Officers. Each facility in the permitting or corrective action universe has its own individualized form.

• RCRIS Unit Update Form These forms are used to enter information regarding unit groups at facilities in the permitting universe. They are completed by the Hazardous Waste Permit Officers.

• Instrument/Area/Constituent Form These forms are used to enter information regarding the legal instrument in which corrective action is performed, the physical area corrective action is taking place or the chemical constituents of the contamination. found

.. They are completed by the. Hazardous Waste Permit Officers.

• Evaluation - Violation - Enforcement Form These forms are used to enter information regarding hazardous waste inspections, detected violations and resulting enforcement actions. They are completed by the Hazardous Waste Science Officers. Forms are completed by staff as necessary and submitted to the SA/DBA. The SA/DBA reviews the forms for completeness and sends them to data entry staff in batches ofup to 25. The forms are entered by data entry staff and returned to the SA/DBA. The SA/DBA orders the appropriate reports and returns the forms and reports to the staff member who originally submitted them. The staffmember will QA/QC the forms against the reports to assure proper entry. If there are .any errors, the staff member will indicate the error and return the forms to the SA/DBA. The process will continue until all the forms are entered correctly. Once
2

# • SA/DBA orders the appropriate reports and returns the forms and reports to the staff member who originally submitted them. The staffmember will QA/QC the forms against the reports to assure proper entry. Ifthere are any errors, the staff member will indicate the error and return the forms to the SA/DBA. The process will continue until all the forms are entered correctly. Once the forms are entered correctly, they can be kept by the staff 

### member for further use, or returned to the SA/DBA for filing in the Facility History (FH) file. The reports used for QA/QC are listed below:

• 

### Idaho Pennitting Report This report is used to QA/QC information from the RCRIS Unit Update Form and information about permitting events on the RCRIS Event Update Form.

• 

### Abbreviated Corrective Action Report This report is used to QA/QC information about corrective action instruments and areas on the Instrument/Area/Constituent Form, and corrective action events on the RCRIS Event Update 

### Form,

• 

### Constituents Report This report is used to QA/QC information about corrective action constituents on the Instrument/Area/Constituent Form. ' 

# • • Evaluation. Violation and Enforcement Report This Report is used to QA/QC all information on the Evaluation - Violation ­ Enforcement Fonn. B. Forms originating from the regulated community Six forms are either completed by the regulated community and submitted to DEQ, or are completed by DEQ.staff.with. information.from the.regulated community. These forms are entered into the Handler Module of RCRIS, but are all processed in a slightly different manner. Each form and the way it is processed is described below:

• Notification of Regulated Waste Activity Form These forms are used by the regulated community to apply for an EPA Identification Number. They may be initial submissions or amendments. Notification forms are received, processed, and identification numbers are assigned "by DEQ. Following are procedures for processing notification forms. Notification forms are received by the SA/DBA, who verifies the forms bycalling the.facility contact. The SA/DBA then sends the fomis in batches of up to 25 to data entry where the number is assigned. The SA/DBA will tell data entry staff if a form is an emergency. If it is an emergency, data entry staff will notify the 

# • 3

### SNDBA of the number and the SNDBA will notify the facility contact. The 

# • forms are then entered into RCRIS and returned to the SNDBA. The SNDBA sends an acknowledgement letter to the facility contact. The SNDBA will QA/QC the forms by using the notification views function of RCRIS. If errors are found, the forms are rebatched and returned to data entry. Once the forms are entered correctly, the SNDBA files the forms in the Facility History (FH) file.

• Part A Permit Application These forms are used by the regulated community to apply for interim status or to accompany a Part B Permit Application or permit modification. They may be initial submissions or amendments. They are, received by the Hazardous Waste Permit Officers and reviewed for technical accuracy. They are then sent to the SNDBA where they are further reviewed for completeness. The SNDBA sends the forms to data entry in batches. The forms are entered by data entry staff and returned to the SNDBA. The SNDBA will QA/QC the forms using the part A views function of RCRIS. If errors are found the forms are rebatched and returned to data entry. Once the forms are entered correctly, the SNDBA files the forms in the Facility History (FH) file. 

# • • 

### Non-Notifier Data Entry Form These forms are used to enter information regarding a handler that has not applied for an EPA Identification Number and to assign that handler an EPA Identification Number. These forms are completed by the Hazardous Waste Science Officers using information gathered from the facility during an inspection. The forms are then processed and an EPA Identification Number is assigned to the facility. Following are procedures for processing Non-Notifier forms. The Hazardous Waste Science Officer sends the forms to the SNDBA where they are reviewed for completeness. The SNDBA sends the forms to data entry in batches of up to 25 where the EPA identification numbers are assigned. Data entry will notify the SNDBA'of the number, who will notify the Hazardous Waste Science Officer. The forms are entered into RCRIS and returned to the SNDBA. The SNDBA will QA/QC the forms using the notification views function of RCRIS. If errors are found the forms are rebatched and returned to data entry. Once the forms are entered correctly, the SNDBA files the forms in the Facility History (FH) file,

• 'State ID Number Data Entry Form These forms are used to enter information regarding a handler that is not required to obtain an EPA Identification Number. These state numbers are used for tracking purposes in RCRIS to accurately count the number of Compliance Assurance/Technical Assistance (CA/TA) inspections that the Hazardous Waste Science Officers perform. 

# • 4

-**~.** --'-**----.-~------** ...**--~.** -**--~-:--r_.:,"_.** _- ' ..... :-,.. -, .,'

. , ....... : .... . . • • ';".-.1 .... ••



### The Hazardous Waste Science Officer sends the forms to the SA/DBA where they 

# • are reviewed for completeness. The SA/DBA assigns the next sequential State ID Number, indicates it on the forms, and sends the forms to data entry in batches of up to 25. The forms are entered into RCRIS and returned to the SA/DBA. The SA/DBA will 

### QAlQC the forms using the notification views function of RCRIS. If errors are found, the forms are rebatched and returned to data entry. Once the forms are entered correctly, the SA/DBA files the forms in the Facility History (FH) file.



### • Idaho Hazardous Waste Generator Annual Reports This report is submitted by the regulated community' on an annual basis. The information in this report is entered into the Generator/TSD-Information System. When this report indicates a change in generator status it is used as a RCRIS data entry form. The SA/DBA receives the report and determines if it indicates a change in generator status. Ifit does indicate a change, it is sent in batches ofup to 25 to data entry. The changes are entered into RCRIS and the forms are. returned to the SA/DBA. The SA/DBA will 

### QAlQC the forms using the notification views function ofRCRIS. Iferrors are found, the forms are rebatched and returned to data entry. Once the forms are entered correctly, the SA/DBA files the forms in the RCRA Administration (QG) file. 

# • • Notification Change Worksheet These forms are used to make changes to notification data. They are completed by the SA/DBA using information received from the regulated community. The forms are sent in batches of.up to 25 to data entry. The changes are entered into RCRIS and the forms are returned to the SA/DBA. The SA/DBA will 

### QAlQC the forms using the notification views function of RCRIS. If errors are found the forms are rebatched and returned to data entry. Once the forms are entered correctly, the SA/DBA files the forms in the Facility History (FH) file.



### III. Training The SA/DBA is responsible for training all DEQ staffwho use RCRIS. New employees who use RCRIS will be trained by the SA/DBA in individual sessions. Whenever changes are made to. RCRIS or new capabilities are implemented, the SA/DBA will train the affected staff in group sessions. The SA/DBA will attend the annual national RCRA Information Management Training and any other RCRIS training courses as they become available. 

# • 5

### IV. Data Retrieval 

# • When any DEQ staffmembers require information from RCRIS they will make a request by Email to the SA/DBA. If the request is for a report for a specific facility, the request should include the name ofthe report and the facility's EPA identification number. Ifthe request is for specific information not found on any particular report, the request should be as specific as possible. The request should include a date for which the information is needed. When a request for information from RCRIS comes from the public the request should be routed to the SA/DBA in accordance with DEQ's Public Information Request Policy.



# v. Reporting The SA/DBA is responsible for generating and distributing certain reports from RCRIS on a regular basis. These reports include the Six Quarter Plan, Idaho Handler Activity Count Report, and four different sorts of the RCRIS Handlers List. 

# • • Six Quarter Plan This report identifies permitting and corrective action events taking place during six consecutive quarters at each RCRA permitted facility. It enables the RCRA Permit Manager and the Hazardous Waste Permit Officers to get a brief summary of the scheduled and actual events/activities associated with each facility and is used in conjunction with the RCRA Workplan.



### • The Idaho Handlers Activity Count Report This report lists the number offacilities in each Universe. It 

### is generated in WordPerfect using information obtained from RCRIS. This report is to be distributed to each DEQ Regional Office, the Hazardous Waste Science Officers, the RCRA Hazardous Waste Program Development Manager, the Operating Permits Bureau Chief, and the Idaho Handler Activity Count Report File (IH).

• 

### The RCRIS Handlers Lists These lists identify the EPA Identification Number, facility name, location address, generator status, and hazardous waste activities ofhandlers in 

### RCRIS. Four different sortsare generated from the RCRIS database. Three sorts include all handlers (notifiers, nonnotifiers, and state CA/TA identification numbers). They are sorted by EPA Identification Number (numerically), facility name (alphabetically), and by location address (city, street). The fourth sort includes notifiers only sorted by location address. The Notifiers RCRIS Handlers List is the only list released to the public upon request. A copy of this list is to be distributed to the Permits and Enforcement Public Information Request Custodian. All four lists are distributed to each DEQ Regional Office, the Hazardous Waste Science Officers and the RCRA Hazardous Waste Program Development Manager. 

# • 6• I "

....... ;:

__ .... • " •• ;..' • •.•. ..- ':::":'l; ... ;t";-·-·

..**:~/** -:"" .•..::,"" '•.. :>:



## ...

VI. 

### Lookup Table Maintenance 

# • The SA/DBA is responsible for entering and deleting implementor defmed codes into the RCRIS lookup tables. Suggestions for adding or deleting codes originate from the hazardous waste compliance and permitting staff. These suggestions are forwarded to the appropriate supervisor (Environmental Enforcement Manager, or RCRA Permits Manager) for approval. Ifthe addition or deletion is approved the staff member forwards the request to the SAIDBA who then makes the change.



### VII. Form and Report Maintenance The SA/DBA is responsible for keeping the RCRIS data entry forms and reports updated. When a new RCRIS version is released, the SAIDBA will review any new features. The SAIDBA will discuss the new features with the Environmental Enforcement Manager or the RCRA Permits Manager as appropriate. Ifthe decision is made to implement the new features the SAIDBA will make the necessary changes to the data entry forms or begin using the new report. The SAIDBA will conduct a group training session with the affected staff 

### members. 

# • Ifa member ofthe hazardous waste staff

### identifies the need for a new report, that suggestion will be forwarded to the appropriate supervisor for approval. If the request is approved, the supervisor will discuss the report with the SAIDBA to determine the best format to organize the new report. Once a report format is decided upon, the SAIDBA will submit an official request to EPA Region 10. Region 10 will prioritize the work request and, if

### the request is possible, will complete the request accordingly. The SAIDBA will test the report and work out any problems with region 10. Once the report is fmalized the SAIDBA will put the report into production and conduct a group training session with the affected staff 

### members. When any RCRIS user identifies a need for an enhancement to RCRIS, the suggestion will be forwarded to the appropriate supervisor. Once the request is approved, the request is forwarded to the SA/DBA. The SAIDBA then processes the request through the RCRIS Change Management Process as described by EPA.



### VIII. Security The SA/DBA is responsible for maintaining RCRIS security. As employee turnover occurs the SA/DBA will add and delete names into RCRIS security. Mainframe security (RACF) is maintained by EPA Region'X. RCRIS has three levels of access. The lowest level is "read only." This will allow the user to view the data and order reports. Read only access is given to the Environmental Enforcement

. Manager, the RCRA Permits Manager and the RCRA Hazardous Waste Program Development Manager.

. 

# • 7,

• I,

...



### "Read/write" access allows the user access to all ofthe read only functions plus data entry access. 

# • Read/write access is given to all data entry operators that work on RCRIS . "DBA" access gives the user complete access to RCRIS. DBA access is given to the SA/DBA and the EPA Region 10 DBA. The RCRIS MOU defines instances in which the regional DBA will access RCRIS.

IX. 

### Data Sharing The SA/DBA is responsible for assuring that data, is shared,between DEQ and EPA Region' 10 as defmed in the RCRIS MOU. The SA/DBA will submit an extract to update the region's database on the third working day of each month. The regional DBA will submit an extract to update DEQ's database on the fourth working day of each month

.



# •

'



# • 8

;..____________ ._**._~ ~._._**  ..•_. __ __ •

__**~.,** __ - .----.-- • .._. .h

............**_____'_.~-** __ ...**_~'._~** •••

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

# •

THERE HAVE BEEN NO NEW CHECKLISTS ADDED 

# •

•

# • RCRA Inspection Forms and Checklists

Hazardous Waste Inspection Checklist Hazardous Waste Inspection Waste Stream Identification' Hazardous Waste Inspection Generator Checklist Hazardous Waste Inspection Preparedness and Prevention Checklist Hazardous Waste Inspection Personnel Training Checklist Hazardous Waste Inspection Contingency Plan Checklist Hazardous Waste Inspection Container Checklist Hazardous Waste Inspection Tank Checklist Hazardous Waste Inspection Satellite Accumulation Checklist Hazardous Waste Inspection Conditionally Exempt Small Quantity Generator (CESQG) Checklist

• Hazardous Waste Inspection Small Quantity Generator Checklist (100-1000 kg.month) Hazardous Waste Inspection Transporter Checklist Hazardous Waste Inspection General Interim Status Facility Requirements Checklist Hazardous Waste Inspection List ofAttachments Hazardous Waste Inspection Comments Hazardous Waste Inspection Summary ofFindings
Waste Reduction Checklist
Waste Prevention Checklist 

### # 1 Incinerators Checklist RCRA Land Disposal Restrictions Inspection 

# • Region 10 Waste Minimization Checklist
Pre- Inspection Checklist

# • Operation and Maintenance Inspection Guide (RCRA Ground-Water Monitoring Systems), March 1988 Facility-Specific Inspection Checklist For: Pressure Treated Timber Company, October 1988 Protocol for Evaluating Interim Status Closure/Post-Closure Plans, August 1986 Region VIII Multi-Media Inspection Checklist for Heap Leach Gold Mining, December 1994 Contingency Plan Checklist, December 1988 RCRA Checklist for Recycling Wastes to be Burned for Energy Recovery, June 1987 National Multi-Media Screening Inspection Checklist Used as a Guideline, May 1993 California List Waste HSWA Requirements, April 1988
Waste Reduction Checklist, January 1994 

# •

•
Idaho Revised Authorization Application September 1996

### Idaho 

# • Division of Environmental Quality (DEQ) Hazardous Waste Compliance/Enforcement Strategy


### I. OVERVIEW A. Idaho's Hazardous Waste Authority Idaho's authority to regulate hazardous waste is vested in the Hazardous Waste Management Act of 1983 (HWMA), Idaho Code 

### § 39-4401 et seq, and the Rules and Standards for Hazardous Waste (Hazardous Waste Rules), IDAPA 16.01.05.000 et seq. Idaho is authorized to administer the hazardous waste program in lieu of the U.S. Environmental Protection Agency (EPA) pursuant to the Resource Conservation and Recovery Act of 1976 (RCRA), as amended, by the Hazardous and Solid Waste Amendments of 1984 (HSWA). 

### B. Idaho's Regulated Community Idaho's regulated community is diverse in activity and includes Department ofDefense facilities and a major Department ofEnergy facility within the permitted facilities regulated. In 

### addition, the regulated community consists ofprimarily light industrial and service-type companies who generate and/or handle hazardous waste. 

# • C. 

### Compliance and Enforcement Philosophy The State's hazardous waste program protects human health and the environment from the threat ofhazardous waste by bringing violators into compliance from the point ofgeneration to final treatment, reuse, or disposal. The tools used to implement this policy consist ofdirect monetary or equivalenteconomic sanction penalties, informational media to bring forth public pressure to ensure handler compliance, and legal avenues to enforce compliance. 

### ll. 

### INSPECTIONS A. Inspection Procedures Inspections are conducted to ascertain compliance with state and federal hazardous waste requirements. All inspections include evaluation ofprocesses and their associated waste streams in addition to the review of product data to determine characteristic properties of the waste. Often samples ofwaste streams are collected for analysis to verify the accuracy ofthe generator's waste characterization. Inspections also include the evaluation ofquantities ofwastes generated, accumulated, or stored on-site to determine regulatory status. Compliance inspections are conducted pursuant to a complaint or as part of the regularly scheduled inspections that are negotiated annually through the State Grant Work Plan. Complaints are received from the EPA Idaho Operations Office (100), 

### DEQ Regional Offices, direct telephone contact from the general public, other federal, state, or local agencies, and 

# • regulated facilities. The degree ofresponse to a complaint depends upon such factors as whether the complainant was an eye-witness, the type offacility, immanency ofpotential threat to human health and the environment, proximity to population, water sources or other environmentally sensitive media, travel distance to the site, and availability ofresources as determined by DEQ management.Hazardous Waste Compliance/Enforcement Strategy September, 1996 

# o Page 2 of 10 "The Resource Conservation and Recovery Act Inspection Manual"(1993) is used for initial training ofHazardous Waste Science Officers (HW Science Officers) and as a refresher guide for all compliance staff HW Science Officers prepare for an inspection by reviewing DEQ's facility files. State developed inspection checklists are utilized for inspections where applicable. HW Science Officers follow current EPA inspection guidelines for scrutinizing facility records, waste analysis plans, employee training, emergency preparedness and contingency planning, manifest usage, sampling data, and waste minimization plans. Inspection guidelines/checklists are 'continually updated by both DEQ and EPA. Improvements to inspection guidelines/checklists are integrated as upgrades occur. EPA Publication SW-846 and the 1988 Hazardous Materials Bureau Standard Operating Procedures as amended, are used as guidance for sampling activities. Compliance staff are trained and provided with specialized equipment to handle most sampling activities for tanks, containers, contaminated soils, and small in-ground pits or impoundments. For very large surface impoundments or very large soil areas, special sampling plans, specific equipment, and additional 

### staffor outside contractor services may be required to complete the sampling activity to obtain representative samples. Compliance staffwork closely with the State Laboratory in preparation of samples and formulating methods to address testing not normally performed by the Lab. 

### The most comprehensive inspections presently performed. by compliance staff are at 

# landO Disposal Facilities (e.g., ESTI-B) and Federal Facilities (e.g., INEL). Presently, State resources are on-site six percent of the operating time at the ESTI-B Facility. Although HW Science Officers witness many daily activities at the hazardous waste landfill, an annual inspection is performed by the State to scrutinize all aspects ofoperation, including but not limited to: waste identification, analysis and recordkeeping, contingency and emergency planning, personnel training and protection, spill containment, equipment integrity, operational procedures, groundwater data assessment and/or sampling, manifest checking, and waste disposal recordkeeping. During a comprehensive inspection, staffare assigned specific areas and prepare individual sections ofthe Narrative Inspection Report. Inspections ofthis magnitude may also require extensive, post-inspection in-house review ofinformation obtained during the inspection. Waste analysis, training, contingency and emergency planning, and other operational records are usually reviewed prior to the site inspection so the HW Science Officer can focus on facility specificprocedures during the inspection. Review ofplans, which may require the use ofoutside contractor services, will be undertaken as necessary under the coordination ofthe appropriate compliance staffmember. Where the regulated unit has a permit, the annual inspection will also include verification ofcompliance with all permit-specific requirements. HW Science Officers denied entry will leave the facility and call or return to the office to discuss the issue of facility access denial with the DEQ Enforcement Bureau RCRA Manager (EB Manager), DEQ Enforcement Bureau Chief (EB Chief) and/or the Attorney General's Office

# C (AG's Office). A decision to initiate formal entry procedures, authorized by Idaho Code § 39­ 4412(5), is based on criteria which prompted the inspection and the owner/operator's previous compliance history. Facilities, which have received RCRNHWMA permits, are subject to I

### Hazardous Waste c omPlianCelEnfOrcement Strategy September, 1996 • Page 3 of 10 permit suspension and revocation (termination) for denial ofentry, in accordance with IDAPA 16.01.05.012 (40 CFR §§ 270.30 and 270.43). 

### B. Inspection Prioritization Inspection priorities are determined by EPA's RCRA Implementation Plan (RIP), current EPA policy directives and DEQ established initiatives/priorities. Situations in which DEQ must initiate an immediate response to a release or possible release ofhazardous waste, which may impact human health or the environment, are given an immediate priority as determined by the EB Manager and EB Chief Non-emergency inspection activities are negotiated at the beginning of each federal fiscal year. This negotiation includes identifying and scheduling TSDF inspections and the total number of (un-named) generator inspections. One month prior to the beginning ofeach federalfiscal year quarter all scheduled generator inspections will be identified by DEQ and submitted to EPA-IOO. C. 

### StafTExperience and Credentials 

# • There are six (6) HW Science Officers and the EB Manager devoted exclusively to field inspection activities. The HW Science Officers are responsible for all inspection activities and preparationofenforcement actions, and may be called upon to serve as expert witnesses in either civil or criminal court actions. Prior experience of compliance staff include, on the average, severalyears ofRCRA, Superfund/CERCLA, water quality, or general environmental sampling and inspection experience. As 

### part of initial training, new inspectors are paired with senior compliance officers to maintain consistency with interpretation and application of tbe RCRAIHWMA regulations. The senior inspector/mentor approach has been most efficient.to familiarize new staffwith DEQ's inspection/enforcement role. HW Science Officers gain access to facilities or sites upon a presentation ofcredentials signed by the Idaho Department ofHealth and Welfare Director (Director): ill. 

### ENFORCKMENT A. Enforcement Process Overview The identification, processing, and final resolution ofan enforcement action follows a step-bystep chain of events that is repeated for every instance of non-compliance. These events are listed in chronological order. 

### 1. 

### Post Inspection Records/lnformation Review After a field inspection, the HW Science Officer assures the inspection checklists are complete, prepares the Narrative Inspection Report, develops and catalogues photographs, submits samples for analysis, requests additional information/documentation from the 

# • facility as necessary, and reviews the additional documentation upon receipt, and determines violations.

### Hazardous Waste CompliancelEnforcement Strategy September, 1996 

# o Page 4 of 10 

### 2. Facility Notification In 

### accordance with EPA's Enforcement Response Policy of 1996 (ERP) guidelines, a facility is notified ofnon-compliance by the following: the HW Science Officer drafts a Warning Letter (WL) or Notice ofViolation (NOV) for all administratively-issued actions. After review by the EB Manager and assigned Deputy Attorney General (Attorney), WLs are submitted to the EB Chieffor approval, signature, and issuance. NOVs are reviewed by the EB Manager and assigned Attorney prior to submittal to the EB Chief. After approval, the EB Chief routes the NOV to the Permits and Enforcement Division Assistant Administrator (AA) who forwards the document to the DEQ Administrator. The NOV is then issued via certified 

### mail-to the facility. 

### B. Violations 1. 

### Classifications The strategy for recognition and enforcement ofviolations ofHWMA and the Hazardous. Waste Rules is summarized in EPA's 1996 ERP. This document is herein adopted as part ofthis CompliancelEnforcement Strategy. . 

# 0

ERP violations are classified into two main categories and priorities to delineate the appropriate enforcement response.



### a. Class I Violations 1)	 Failure to assure that hazardous wastes are delivered to permitted facilities; 2) Failure to detect, prevent, or provide emergency or corrective action for releases ofhazardous waste. 

### b. Class IT Violations 1)	 Any violation which is not considered Class I. 

### Violators, having committed a Class I or Class II violation, are segregated into two categories based upon the nature of the violation(s) and/or the history of previous compliance.



### c. Significant Non"-Compilers (SNCs) 1) Has caused actual or substantial likelihood ofexposure to hazardous waste or hazardous constituents; 

### 2) Is a chronic or recalcitrant violator, 

### i.e., Class I or Class II repeatedO violations;**---~----1**

### Hazardous Waste 

# • CompliancelEnforcement Strategy September, 1996 Page 5 of 10 3)	 Has failed to perform activities and/or failed to meet timeliness stipulated in a Permit, Consent Order, or Decree; or 4)	 Has substantially deviated from statutory or regulatory requirements. d. Secondary Violators (SVs) 1)	 Violators which do not meet the criteria listed above for SNCs; 2)	 Typically are first time violators; no history ofrecalcitrance; 3)	 Violations should be ofa nature to permit prompt return to compliance; 2. Notification Violatorsare informed ofan enforcement action by Certified Mail delivery ofa WL or NOV. In the case of a Judicial Referral (JR), the violator is notified by phone by the assigned Attorney upon his receipt ofthe JR. The WL recites applicable State rules and HWMA provision violated and may include copies ofthe specific statute(s) and rules(s). 

# • The NOV recites applicable State rules and HWMA provisions violated; may include copies ofthe specific statute(s) or rules(s); may stipulate monetary penalties pursuant to the HWMA Civil Penalty Policy; and stipulates the violator may request a compliance conference to discuss the alleged violation(s), proposed penalty amount, and other information to seek a
-:1 0 :",­ 

### resolution of the enforcement action. The NOV stipulates a request for a compliance conference must be made within fifteen (15) days after receipt ofthe NOV. Although the actual compliance conference is usually held after the fifteen (15) day contact period, the lackofcontact by the violator withinthis time period may induce further enforcement action. In most cases, a courtesy telephone call is made to the violator by the EB Manager if the fifteen (15) day limitation is approaching and no contact has been made by the violator. C. Administrative Enforcement 

### 1. Compliance Conference Compliance conferences are used to bring together DEQ's compliance representatives (HW Science Officer(s), EB Manager, EB Chief and Deputy Attorney General) and the alleged violator to discuss issues contained in the NOV. A pre-conference discussion is held between the HW Science Officer(s), the EB Manager, and/or the EB Chief to recount the violations, the proposed penalty, and past history ofthe violator. Also discussed are any other factors which the EB Manager needs to know, as he/she represents DEQ in the compliance conference

. 

# •

### Hazardous Waste Compliance/Enforcement Strategy September, 1996 

# o Page 6 of 10 The lead role in conference negotiations is held by the EB Manager. The EB Manager explains that the purpose of the conference is to provide an opportunity for the alleged violator to explain the circumstances surrounding the alleged violation(s) and to agree to a negotiated Consent Order (CO), which precludes further enforcement action and compels compliance. Written enforcement decisions and agreements will not be made during the compliance conference since only the DEQ Administrator is authorized to sign COs. File notes are drafted by the HW Science Officer to document negotiations and additional information provided during the compliance conference. All enforcement activities are tracked by the HW Science Officer and documented in RCRIS. The compliance conference can be expanded, in difficult proceedings, to include more than one meeting, and may extend over a lengthy time period. In any case, if an. agreement cannot be reached within sixty (60) days after receipt of the NOV, DEQ may seek civil action in district court after preparation ofa JR by the Enforcement Manager, through the Chief, and subsequent action by the AG's Office. Ifnegotiations proceed satisfactorily, DEQ may elect to extend the sixty (60) day period. 

### 2. Consent Order The CO, which stipulates actions to be undertaken by the violator, schedules for compliance

# C and/or deliverables, arid the agreed upon penalty or other acceptable compensation; shall be signed by the violator and the DEQ Administrator at the end offormal negotiations. The goal in setting compliance schedules in COs is to assure the facility achieves compliance by demonstrating progress. The State takes into consideration the amount oftime necessary to achieve physical compliance when setting schedules. Time limits are discussed with the facility representatives during the compliance conference and an agreed upon schedule is set. Past EPA and State COs are used as guidance in setting timetables. A very short timeframe, such as five (5) days, is set for submittal ofdocumentation that facility representatives claim is available at the facility. A longer timeframe, such as ninety (90) days, is given for submittal of plans and procedures that must be developed by the facility. A longer time period is usually set for cleanup actions that may need to be taken if such delayed action would not pose an imminent threat to human health, public safety, or the environment.
An 

### extension to a CO compliance schedule may be granted for justifiable reasons. In the extension request, the owner/operator must document why the extension is necessary and that negligencehas not caused the delay. In addition, the State will perform a completeness review on all documents, plans, and/or procedures. Ifthe documentation is not acceptable, a revision is requested and a short turnaround time

# 0 is required.

### Hazardous Waste 

# • Compliance/Enforcement Strategy September, 1996 Page 7 of 10 Compliance schedules that are not met may be addressed by DEQ in several ways. The first response is for a DEQ representative to call the owner/operator and inform him/her ofthe missed deadline. 

### If the schedule is then met within five (5) working days, no formal action will be taken. Ifthe schedule is not met within this additional allowance period, a WL is sent to the owner/operator explaining the deadline was missed and must be met within five (5) working days. 

### If the owner/operator does not respond to this WL, legal action may ensue. Legal actions that may be taken are issuance ofNOV that will site the CO violation and assess a penalty, or initiation ofa civil suit. 

### D. Non-Administrative Enforcement 1. 

### Judicial Referral A higher degree of enforcement is brought about by a non-administrative civil or criminal procedure. To begin this process, the EB Manager prepares a Judicial Referral Package 

### (JR). The 

### JR is a case history compilation that includes all factual data and a step-by-step account of activities, places, and people involved in the site inspection leading to the violation determination. Depending on the circumstances ofthe case, the AG's Office can, by request 

# • ofthe EB Chief initiate a direct investigation under prevailing criminal procedures, whereby the AG's Office conducts in-field investigations to document all evidence in preparation of criminal proceedings.

..,.....,- .....
.... 

### 2. Litigation DEQ may institute civil action as its first response under the following circumstances: 1) significant threat to human health or the environment; 2) violator is a chronic offender; 3) legal obstacles prevent a non-litigation process; or 4) precedent-setting enforcement action. DEQ is authorized to initiate litigation sixty (60) days after an NOV has been issued and resolution has not been reached through a CO. 

### If DEQ determines that, due to the seriousness ofthe violations or an NOV arid CO will not bring about compliance, DEQ may begin court action without first initiating an administrative action. The EB Manager, in concert with the EB Chief, makes the decision to pursue litigation. The EB Chiefdiscusses litigation with the AA and the DEQ Administrator, who discusses it with the Director. In most cases, the DEQ Administrator has full authority to initiate the litigation process with consultation and review by the Director. Filing ofa complaint is subject to approval ofthe 

# • AG's Office. The decision whether or not to pursue litigation is based on the seriousness of the violation(s) and the ability to reach a settlement through administrative procedures

.Hazardous Waste Compliance/Enforcement Strategy September, 1996 

# o Page 8 of 10 Subsequent to the receipt ofa complaint, the defendant has twenty (20) days to reply. Once an answer to the complaint is received, legal discovery begins. Legal action must be brought within two (2) years after DEQ first had knowledge or ought reasonably to have had knowledge ofthe violation. Other agencies which might have an interest in the case, for instance EPA's Regional Counselor the U.S. Department ofJustice, may be contacted during the litigation process. 

### 3. Legal Resources DEQ's legal assistance is provided by the AG's Office Division ofNatural Resources. There are 6.33 Attorneys and one paralegal assigned to DEQ with approximately 1.5 FTE Attorneys dedicated to hazardous waste enforcement. The AG's office provides a full range of legal services to the Enforcement Bureau including enforcement review and participation in civil and criminal litigation. The AG's office also performs a standard review of NOVs and may participate in compliance conferences. However, they do not have the authority to veto an . Enforcement Bureau request to issue an NOV or to prepare an enforcement action. Ifthere are

significant disagreements, the legal staff can raise their concerns to the appropriate levels administratively; but the ultimate decision rests with the DEQ Administrator. 

# O Thedecision whether cases are suitable for district court action is determined by tbe AG's Office. The EB Chief, in consultation with the AA and DEQ Administrator, determines if a case should be filed. Ifthe AG's Office agrees, the assigned Attorney prepares a complaint after review of the JR. 

### E. Public Notification When the facility is notified ofa violation and when the corresponding Consent Order is signed, the Compliance Officer completes a DEQ press release form and submits it to DEQ's Public Affairs Unit. 

### F. Assurance of Compliance DEQ strives to ensure that facility owner/operators come into compliance after enforcement actions have been taken. This assurance is achieved in several ways, depending on the type of enforcement action taken, the severity ofthe violations, and the category ofthe facility. If the enforcement action is a WL requiring submittal of documentation detailing the owner/operator's remedy ofviolations, DEQ reviews the submitted information and, if adequate to assure compliance, sends the owner/operator a written response confirming resolution or return to compliance status. If compliance has not been achieved, further information iSO requested until DEQ is satisfied that all violations have been remedied. Timeframes for completion ofremedies will be stipulated in any follow-up request when the initial response is insufficient to confirm compliance. Enforcement action using WLs will not normally bring forth

### Hazardous Waste Compliance/Enforcement Strategy September, 1996 Page 9 of 10 a follow-up inspection, unless there is reason to suspect environmental damage has occurred or false information has been provided to DEQ. If the enforcement action is an NOV which results in a CO, DEQ will review submitted documentation as required by CO compliance schedules. DEQ may also prescribe assurances offuture compliance in the CO. Ifthe CO requires a cleanup action, a DEQ representative may conduct an on-site inspection during cleanup activities and/or after CO requirements have been met. 

### G. Permit Enforcement


# • A State permit is a license for a facility to operate under specific conditions, as requested by the permit applicant and approved by DEQ. The operational HWMA/RCRA permit contains items which are immediately enforceable if violated and if deemed severe enough by DEQ, may bring forth permit suspension or revocation. If an application is deemed incomplete, a notice of deficiency (NOD) will be issued. Pursuant to IDAPA 16.01.05.012, action may be brought against permit applicants who fail to correct incomplete or inadequate permit applications. In addition, ifa complete application is not submitted in a timely manner, enforcement proceedings may be initiated by the Hazardous Waste Permit Manager in conjunction with the EB Manager and appropriate legal staff. Within ninety (90) days after request ofan application, the facility is inspected by a HW Science Officer and the assigned Permit Officer. Interim status facilities, which have not yet submitted or received a request for their Part B Application, will continue to be inspected by HW Science Officers with the completed results forwarded to the assigned Permit Officer. All permit and enforcement actions are reviewed and discussed with the EB Manager, the DEQ Operating Permits Bureau (OPB) Hazardous Waste Permit Manager, the EB Chief, and the OPB Chiefto ensure permit and enforcement activities are properly coordinated. 

### H. Enforcement Prioritization Complaints from the general public are primarily investigated by Regional Office staff who determine whether the potential for a violation exists. If so, the Regional Office refers the complaint to the EB Manager for enforcement. The EB Manager prioritizes the complaints based on immediacy ofthreat to human health or the environment, compliance history ofthe facility, notification status of the facility, complaint motives, quantity of waste, regional coverage, and multi-media concerns. IV. 

### INFORMATION MANAGEMENT Inspection information is gathered from inspector field logs, photographs, inspection checklists, 

# • photocopies, and sampling data. Appropriate information derived from an inspection is recorded on the Resource Conservation and Recovery Information System (RCRIS) Data Entry Form, and submitted to the RCRIS Project Officer in the Operating Permits Bureau for review and direct data entry into RCRIS. From the initial date of inspection, all subsequent dates of compliance/enforcement decisions or actions are entered into RCRIS. Information including the .'1

### Hazardous Waste Compliance/Enforcement Strategy September, 1996 

# o Page 10 

### of 10 

### Narrative Inspection Reports, narratives, and photos are kept in a secured facility file. File information is kept at least three (3) years, after which it may be archived. 

### V. STATEIEPA COORDINATION In those instances where inspections reveal violations ofEPA regulations for which the State has no equivalent, the HW Science Officer notes this violation in the Narrative Inspection Report. If the chosen enforcement action is a WL, the EPA violation will be included in the WL and the facility will 

### be asked to comply. EPA 100 determines if enforcement action is warranted and refers the action to EPA Region 10.



# o

o

### Idaho Division ofEnvironmental Quality and U.S. Environmental Protection Agency, Region 10 

# • HAZARDOUS WASTE COMPLIANCE ASSURANCE AGREEMENT


## I. Introduction
The purpose of this Hazardous Waste Compliance Assurance Agreement (Agreement) is to define the relationship between the State of Idaho (State), Division of Environmental Quality (DEQ) and the U.S. Environmental Protection Agency, Region 10 (EPA) regarding enforcement ofthe hazardous waste program (as defined by the federal Resource Conservation and Recovery Act of 1976 (RCRA), as amended by the Hazardous and Solid Waste Amendments of 1984 (HSWA)), and to clarify mutual expectations for conducting compliance activities relating to hazardous waste management in the State of Idaho. This Agreement embodies and reflects the principles outlined in the "Revised Policy Framework for StatelEPA

### E~orcement Agreements." 

### It is understood the State will have responsibility for enforcement ofthe hazardous waste program pursuant to the authority provided by the Hazardous Waste Management Act (HWMA), Idaho Code 

### § 39-4401 et seq. and the Rules and Standards for Hazardous Waste (Hazardous Waste Rules), IDAPA 16.01.05.000 et seq. EPA will assume an oversight role to ensure full execution ofauthorized requirements. EPA retains authority for non-delegated HSWA requirements. However, EPA will normally defer to the State enforcement actions that are consistent with federal requirements and which result in achieving compliance with applicable

- statutes and regulations.

# ~odifications to this agreement may be proposed by either party. Any major modification or revision must be in writing and signed by the Administrator ofDEQ and the Director ofthe EPA Region 10 Hazardous Waste Division. Minor revisions may be approved by the Chiefofthe DEQ Enforcement Bureau and the Chiefofthe EPA Waste Management Branch, Seattle. This Agreement will become effective upon signature by the State and EPA. 

### II. Compliance and Enforcement Performance Oversight of the State enforcement program by EPA will be accomplished through written reporting requirements, compliance and enforcement overviews, file reviews, and mid-year and annual reviews of applicable State program components. The program performance expectations are contained in the following, which are also utilized in conducting program reviews: 1. Idaho's 1996 Revised Authorization Application and Memorandum ofAgreement (MOA); 2. National Criteria for a Quality Hazardous Waste Management Program (June, 1988); 3. EPA's 1996 Enforcement Response Policy; 4. Idaho CompliancelEnforcement Strategy (1996); 

### 5. HWMA Civil Penalty Policy (June, 1987); 6. RCRA Civil Penalty Policy (May, 1984); 7. RCRA/State Oversight Inspection Guide (October 1990); 

# • 8. RCRA Program Evaluation Guides (OSWER, July, 1988); 9. U.S. EPA Annual RCRA Implementation Plan 

### (RIP) 10. State/El'A Agreement and State Grant Workplan; 11. Federal Facilities Compliance Strategy (November, 1988); 12. Federal Facilities Compliance Act of 1992;

### Hazardous Waste Compliance Assurance Agreement September 13, 1996 

# • Page 2 13. RCRIS Memorandum ofUnderstanding (MOU) (1991) and Amendments; 14. Final Addendum on Multi-Media Enforcement to the Policy Framework on StatelFederal Enforcement Agreements (May, 1992); 15. Interim Revised Supplemental Environmental Projects Policy (May, 1995); 16. Criminal Enforcement Addendum to the Policy Framework for StatelEPA Enforcement Agreements (February, 1993); and 17. Idaho Site Treatment Plan (November 30, 1995). 

### In. Inspections 

### A. Oversight: The purpose ofEPA oversight is to strengthen the State enforcement program and ensure national RCRA goals are achieved. EPA's oversight is to be accomplished through evaluation ofthe State's compliance inspection and enforcement activities in accordance with documents referenced above. 

# • It 

### is agreed that designated EPA and State personnel shall actively participate in selected joint inspectionprocesses. The State inspector will take the lead in all oversight inspections, except when mutually agreed in advance by the State and EPA, then EPA will assume the lead. Prior to conducting an oversightinspection, the EPA representative will briefthe appropriate State compliance inspector on the purpose and extent of the oversight inspection. The lead State inspector and the EPA representative will then review files, compliance reports, and follow-up documents to determine if data needs are sufficient to satisfy program requirements for inspection purposes. During the inspection, the lead inspector shall be the person responsible for obtaining information determined to be necessary. The EPA inspector may participate as necessary to clarify issues, evaluate violative practices, document findings, insure compliance with federal requirements, and otherwise complete the inspection. Any information obtained will be made available to both agencies. Upon completionofan oversight inspection,the EPA inspector is responsible for conducting a closing interview with the State inspector. The purpose ofthis interview is to evaluate the State inspector's performance and enhance his/her ability to conduct an inspection. The State inspection report will be provided to EPA in accordance with the Enforcement Response Policy and the National Criteria for a Quality Hazardous Waste Management Program. EPA will provide the State with a copy of EPA'soversightreview ofthe State inspection report within forty-five (45) calendar days ofreceiving the report. 

### B. Other: EPA may conduct independent inspections ofRCRA handlers with prior notification to the State. Everyattempt will be made to discuss independent inspections with the State to clarify the scope and to explain the rationale and need for the inspection. Reasonable Notice • IV. 

### EPA inspections offacilities within the State will normally be conducted jointly with the State and after appropriate prior notice is provided to the State. EPA will provide the State with a schedule of oversight inspections by the end ofthe first quarter ofthe federal fiscal year. The schedule will include independent

### •

•

• Hazardous Waste Compliance Assurance Agreement September 13, 1996 Page 3 inspections, consistent with the DEQ inspection schedule, and in accordance with the procedures outlined in the MOA. Everyeffort will be made to accommodate unscheduled inspections and/or unforeseen situations that may not allow for advance notice. V. Timely and Appropriate Enforcement Action It 

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

### is further understood the State's authority, policy, and procedures for enforcement are not identical to EPA's. The State agrees to take timely and appropriate enforcement actions consistent with the EPA EnforcementResponse Policy and the HWMA Civil Penalty Policy. Regarding' formal enforcement actions (those requiring an EPA administrative order), EPA and DEQ view the federal timeliness criteria as target time frames only. The State shall have the enforcement lead for any violation of State program requirements. The State will also give consideration to information submitted by the public regarding potential violations ofHWMA or the Hazardous Waste Rules. The State agreesthat EPA may take independent enforcement action ifthe State has not acted in a timely and appropriate manner. Prior to EPA initiating any specific overfile enforcement action, the State and EPA agree to consult with each other to verify compliance and enforcement circumstances. The quarterly compliance meetings will act as a forum for the State and EPA to negotiate appropriate State enforcement action in lieu ofEPA overfile. All quarterly compliance meetings will have written agendas developed with input from both the State and EPA ten (10) working days in advance ofthe scheduled meeting date. The results ofthese meetings will be documented in writing and available to the State and EPA twenty (20) working days following the meeting. Ifthe State and EPA do not agree on an acceptable enforcement action, the Administrator ofDEQ and the Director ofthe EPA Region 10 Hazardous Waste Division will attempt to reconcile outstanding differences prior to proceeding. In no case will EPA issue an order or commence civil action in the State without providing DEQ notice pursuant to RCRA § 3008. Normally, prior to issuing any enforcement action, EPA will provide the State with a copy ofthe order referring to the action and allow fourteen (14) days for State comments. EPA retains its right to issue orders and bring actions under §§ 3008(a), 3008(c), 3008(h), 3013, and 7003 ofRCRA and any other applicable federal statute. VI. Reporting The State agrees to classify and report violators, including high priority violators, in accordance with EPA's Enforcement Response Policy (December, 1987). All State inspection and enforcement activity will be reported by the State in the Resource Conservation and Recovery Information System (RCRIS) database using direct RCRlS data entry. RCRlS data will be submitted via the merge process on the schedule provided by EPA and agreed to by DEQ, and will include all inspection and enforcement activity completed the previousmonth. The State is responsible for the accuracy ofState-owned RCRIS data and data entry. Other program reporting responsibilities for the State and EPA are addressed in the MOA, the StatelEPA Agreement, the RCRA Workplan, and the RCRIS MOD.

### •

•

• Hazardous Waste Compliance Assurance Agreement September 13, 1996 Page 4 

### VII. Notification The State and EPA agree to share compliance information relevant to a pending or issued enforcement action on a facility ofmutual interest or concern, as described in other agreements and as discussed at quarterly meetings (e.g., lab data, consultant reports, compliance follow-ups, manifest discrepancy reports, etc.). This information will be shared in a timely and responsible manner. The State and EPA will seek to resolve differences in interpretation ofregulations, technicaljudgement or program goals, and priorities as they arise. All resolutions/decisions shall be documented in writing and followed by both the State and EPA. Any enforcement-related public notice, news release, or other public announcement from EPA, which relates to a matter for which the State has primary enforcement responsibility, shall be provided to and discussed with the State prior to release by EPA. In such cases, the State will be provided with an opportunity to be present at all press conferences or public meetings where EPA press releases are to be discussed. Ifpossible, seventy-two (72) hours notice, but not less than twenty-four (24) hours, will be given to the State prior to issuance of a press release or the holding ofa press conference by EPA, relating to a matter for which the State has primary enforcement responsibility. 

### VIII. Effect Nothing in this Agreement shall be construed to constitute a valid defense by regulated parties in violation ofany state or federal environmental statute, regulation, or permit. 

### IX. Expiration, Termination, and Revision This Agreement shall be executed by the DEQ Administrator and the Regional Administrator, effective the date signed by the Regional Administrator, and shall replace the Compliance Assurance Agreement dated December 22, 1994. This Agreement shall continue in effect until terminated in writing by the State or EPA upon sixty (60) days prior notice to the respective party. This Agreement will be reviewed on an annual basis and may be updated as necessary.

# tAdzd~1J~ Wallace N. Cory, Administra Idaho Division ofEnvironm n Quality

Mike Bussell, Director Date EPA Region 10, Office ofWaste and Chemical Management

### Idaho Division ofEnvironmental Quality and 

### U.S. Environmental Protection Agency, Region 10 

### HAZARDOUS WASTE, '. COMPLIANCE ASSURANCE AGREEMENT

I. Introduction 

### The purpose of this Hazardous Waste Compliance, Assurance Agreement (Agreement) is to define the relationship between the State of Idaho (State), Division of Environmental Quality (DEQ) and the U.S. EnvironmentalProtection Agency, Region 10 (EPA) regarding enforcement ofthe hazardous waste program , (as defined by the federal Resource Conservation and Recovery Act of 1976 (RCRA), as amended by the Hazardous and' Solid Waste Amendments of 1984 (HSWA»; and to clarify mutual expectations for conducting compliance activities relating to hazardous waste management in the State of Idaho. This Agreement embodies and reflects the principles outlined in the "Revised Policy Framework for StatelEPA Enforcement Agreements." It 

### is understood the State will have responsibility for enforcement ofthe hazardous waste program pursuant to the authorityprovided by the Hazardous Waste Management Act (HWMA), Idaho Code§ 39-4401 et seq. and the Rules and Standards for Hazardous Waste (Hazardous Waste Rules), IDAPA 16.01.05.000 et seq. EPA will assume an oversight role to ensure full execution ofauthorized requirements. EPA retains authority for non-delegatedHSWA requirements: However, EPA will normally defer to the State enforcement actions that are consistent with federal requirements and which result in achieving compliance with applicable statutes and regulations. ' Aodifications to this agreement may be proposed by either party. Any major modification or revision must in writing and signed by the Administrator ofDEQ and the Director ofthe Ef'A'Region 10 Hazardous Waste Division. Minor revisions may be approved by the Chiefofthe DEQ Enforcement Bureau and the Chiefofthe EPA Waste Management Branch, Seattle. This Agreement will become effective upon signature by the State and EPA.
II. Compliance and Enforcement Performance 

### Oversight .of the State enforcement program by EPA will be accomplished through written reporting requirements, compliance and enforcement overviews, file reviews, and mid-year and annual reviews of applicableState program components. ,The program performance expectations are contained in the following, which are also utilized in conducting program reviews: 1. Idaho's 1996 Revised Authorization Application and Memorandum ofAgreement (MOA); 2. National Criteria for a Quality Hazardous Waste Management Program (June, .1988); 3. EPA's 1996 Enforcement Response Policy; 4.' Idaho Compliance/Enforcement Strategy (1996); 5. HWMA Civil Penalty Policy (June, 1987); 6. RCRA Civil Penalty Policy (May, 1984); 7. RCRNState Oversight Inspection Guide (October 1990); 

# • 8. RCRA Program Evaluation Guides (OSWER, July, 1988); 9. .U.S. EPA Annual 

### RCRA Implementation Plail (RIP) 

### 10.**S~teIEPA** 

### Agreement and State Grant Workplan; 11. Federal Facilities Compliance Strategy (November, 1988); 12.· Federal Facilities Compliance Act of 1992;

# c Hazardous Waste Compliance Assurance Agreement September 13, 1996 Page 2 13. RCRIS Memorandum of Understanding (MOU) (1991) and Amendments; 14. Final Addendum on Multi-Media Eriforcement to the Policy Framework on State/Federal Enforcement Agreements (May, 1992); 15. Interim Revised Supplemental Environmental Projects Policy (May, 1995); 16. Criminal Enforcement Addendum to. the Policy Framework for StatelEPA Enforcement Agreements (February, 1993); and 17. Idaho SiteTreatment Plan (November 30, 1995). 

### III. Inspections A. Oversight: The purpose ofEPA oversight is to strengthen the State enforcement program and ensure national RCRA goals are achieved. EPA's oversight is to be accomplished through evaluation ofthe State's compliance inspection and enforcement activities in accordance with documents referenced above. It 

### is agreed that designated EPA 

### and State personnel shall actively participate in selected joint inspection processes. The State inspector will take the lead in all oversight inspections, except when mutually agreed in advance by the State and EPA, then EPA will assume the lead. Prior to conducting an oversight inspection, the EPA representative will brief the appropriate State compliance inspector on the purpose and extent of the oversight inspection. The lead State inspector and the EPA representative will then review files, compliance reports, and follow-up documents to determine if 

# 0 data needs 

### are sufficient to satisfy program requirements for inspection purposes. During the inspection, the lead inspector shall be the person responsible for obtaining information determined to be necessary. The EPA inspector may participate as necessary to clarify issues, evaluate violative practices, document findings, insure compliance with federal requirements, and otherwise complete the inspection. Any information obtained will be made available to both agencies. Upon completion ofan oversight inspection, the EPA inspector is responsible for conducting a closing interview with the State inspector. The purpose ofthis interview is to evaluate the State inspector's performance and enhance his/her ability to conduct an inspection. The State inspection report will be provided to EPA in accordance with the Enforcement Response Policy and the National Criteria for a Quality Hazardous Waste Management Program. EPA will provide the State with a copy of EPA's oversight review ofthe State inspection report within forty-five (45) calendar days ofreceiving the report. 

### B. Other:
EPA may conduct independent inspections of RCRA handlers with prior notification to the State. Every attempt will be 

### made to discuss independent inspections with the State to clarify the scope and to explain the rationale and need for the inspection. 

### IV. 

### Reasonable Notice EPA inspections offacilities within the State will normally be conductedjointly with the State and after appropriate prior notice is provided to the State. EPA will provide the State with a schedule ofoversight inspections by the end ofthe first quarter ofthe federal fiscal year. The schedule will include independent

### Hazardous Waste Compliance Assurance Agreement September 13,1996 Page 3

• 'inspections, consistent with the DEQ inspection schedule, and in accordance with the procedures outlined 

### in the MOA. Every effort will be made to accommodate unscheduled inspections and/or unforeseen situations that may not allow for advance notice. 

# v. Timely and Appropriate EnforcementAction It 

### is understood the State will address all violations ofHWMA and the Hazardous Waste Rules within the State'sjurisdiction. It is further understood the State's authority, policy, and procedures for enforcement are not identical to EPA's. The State agrees to take timely and appropriate enforcement actions consistent with the EPA Enforcement Response Policy and the HWMA Civil Penalty Policy. Regarding formal enforcement actions (those requiring an EPA administrative order), EPA and DEQ view the federal timeliness criteria as target time frames only. The State shall have the enforcement lead for any violation ofState program requirements. The State will also give consideration to information submitted,by the public regarding potential violations ofHWMA or the Hazardous Waste Rules. ' '

c 

### The State agrees that EPA may take independent enforcement action ifthe State has not acted in a timely and appropriate manner. Prior to EPA initiating any specific overfile enforcement action, the State and EPA agree to consult with each other to verify compliance and enforcement circumstances. The quarterly compliance meetings will act as a forum for the State and EPA to negotiate appropriate State enforcement action in lieu ' ' ofEPA overfile. All quarterly compliance meetings will have written agendas developed with input from • both the State and EPA ten (10) working days in advance ofthe scheduled meeting date. The results ofthese meetings will be documented in writing and available to the State and EPA twenty (20) working days following the meeting. Ifthe State and EPA do not agree on an acceptable enforcement action, the Administrator ofDEQ and the Director ofthe EPA Region 10 Hazardous Waste Division will attempt to reconcile outstanding differences prior to proceeding. 

### In no case will EPA issue an order or commence civil action in the State without providing DEQ notice pursuantto RCRA § 3008. Normally, prior to issuing any enforcement action, EPA will provide the State with a copy ofthe order referring to the action and allow fourteen (14) days for State comments. EPA retains its right to issue orders and bring actions under §§ 3008(a), 3008(c), 3008(h), 3013, and 7003 ofRCRA and any other applicable federal statute. " \ .. : I.**~"** '..'



### · , J**~Jv.::-** .\., -' 

### VI 

### ,. R

### eporting**{f\~'\'** ".9:,}'\:' ' ,

# ,~'\The State agrees

# ~classit .:

# ~port~o;a!RfJ" including

# ~~~~~~~:~:;~~~rdance with 

### EPA's }\}.\ Enforcement

### Respo~se I>ohcy

### (OO'emeer,~ All State inspection and enforcement activity will be**1~\V** 

### reported by the State in the Resource Conservation and Recovery Information System (RCRIS) database using direct RCRIS data entry. RCRIS data will be submitted via the merge process on the schedule provided

## .~~ by

## ~P A and agreed to by. DEQ, an? will include all inspection and enforcement activity completed the**,~_preVlous** 

### month. The State IS 

### responsible for the accuracy ofState-owned RCRIS data and data entry. Other

### ~).i:i.-' program reporting responsibilities for the State and EPA are addressed in the MOA, the StatelEPA Agreement, the RCRA Workplan, and the RCRIS MOD.

# c Hazardous Waste Compliance Assurance Agreement September 13, 1996 Page 4 

## vn. Notification

# '~ The State and EPA agree to share compliance information relevant to a pending or issued enforcement action on**\~** facility ofmutual interest or concern, as described 

### in other agreements and as discussed at quarterly meetings (e.g., lab data, consultant reports, compliance follow-ups, manifest discrepancy reports, etc.). This information will be shared in a timely and-responsible manner. The State and EPA will seek to resolve differences in interpretation ofregulations, technicaljudgement or program goals, and priorities as they arise. All resolutions/decisions shall be documented 

### in writing and followed by both the Stateand EPA. Any enforcement-related public notice, news release, or otherpublic announcement from EPA, which relates to a matter for which the State has primary enforcement responsibility, shall be provided to and discussed with the State prior to release' by EPA. In such cases, the State will be provided with an opportunity to be present at all press conferences or public meetings whereEPA press releases are to be discussed. 

### Ifpossible, seventy-two (72) hours notice, but not less than twenty-four (24) hours, will be given to the State prior to issuance of a press release or the holding ofa press conference by EPA, relating to a matter for which the State has primary enforcement responsibility. 

### VIII. Effect Nothing 

### in this Agreement shall be construed to constitute a valid defense by regulated parties in violation 

# 0 ofany state or federal environmental statute, regulation, orpermit, 

### IX. Expiration, Termination, and Revision This Agreement shall be executed by the DEQ Administrator and the Regional Administrator, effective the date signed by the Regional Administrator, and shall replace the Compliance Assurance Agreement dated December 22, 1994. This Agreement shall continue in effect until terminated in writing by the State or EPA upon sixty (60) days prior notice to the respective party. This Agreement will be reviewed on an annual basis and may be updated as necessary. .

# ,tJa;d~)? 

# , q/lqf;c, Wallace N. Cory, Administra Date Idaho Division ofEnvironm n Quality

## 1~/2..lqtp 

# .sau:

Mike Bussell, Director Date 

# (j EPA Region '10, Office ofWaste and Chemical Management

# • • •

08/0S/96 PAGE IDAHO SIX aUARTER PLAN BEGINNING APRIL 1996 FROM THE RCRIS STATE IMPLEMENTER DATABASE EVENT TYPE = ALL CA AND PERMIT EVENTS / RESPONSIBLE AGEHCY = ALL 1ST aTR 2ND aIR 3RO aTR 4TH aTR 5TH aTR 6TH aTR APR·JUN JUL·SEP oCT·OEC JAN-MAR APR·JUN JUL·SEP FACILITY PERMIT 96 96 96 97 97 97

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# I

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### I

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### I HCAPS: ME EPR: ME I I a 5 OP026 04/30/96 I: I I : I iii S HOIOO 05/16/96 I: : I
: I il S MOllO OS/29/96 : I : I 1 I il 5 OP026 05/31/96 :: :: I 1 il S OP251 05/31/96 :: :: I I il 5 OP633 06/12/96 : I I I

NOTE: ACTUAL EVENTS PRECEDED BY -a­

(EY 10 EVENT RESPONS I BLE AGENCY/SECTION KEY TO TSO UNIVERSES E/P = FEDERAL PERMITS SEClION CONTACT o • LAND DISPOSAL FACILITY :/C : FEDERAL COMPLIANCE SECTION CONTACT S = STORAGEITREATMENT FACILITY E/O = FEDERAL OPERA liONS OFFI CE CONTACT C • COMBUST 1ON :11 FEOERAL CONTACT, SECT ION UNKNOWN E/S = STATE CONIACT. ENTERED BY EPA J Jol NT FEDERAL/STArE CONTACT S = STAlE CONTACT08/05/96 PAGE IDAHO SIX OUARTER PLAN BEGINNING APRIL 1996 fROM THE RCRIS STATE IMPLEMENTER DATA8ASE eVENT TYPE = All CA AND PERMIT EVENTS / RESPONSIBLE AGENCY = ALL 1ST OTR 2ND OTR 3RD OTR 4TH OTR 5TH OTR 6TH OTR APR-JUN JUL-SEP OCT-OEC JAN'MAR APR-JUN JUL-SEP FACILI TY PERMIT 96 96 96 97 97 97

... ,;"""" -:- -- : : - : _..-- : -_..__a. _.- -- -_ -_..; --- - -_ -1-"""""""""""" -_ -. !'4ORRISON KNUDSEN CORP: PCPERMITI 002: iil S PC621 05/14/96 : S PC622 07/31/96 : S - MP230 11/01/96 IS' MP240 01/01/97 

### ! S • PC632 04/01/97 : S - PC622 08/01/97 IDD 98097 6831 : STE CONTACT: REBI S • PC631 06/15/96 : S • PC632 09/15/96 : S • MP231 11/15/96 : S • PU22 02101/97 I : ISO UNIVERSE: 0: : I' : : : I' HCAPS: ME EPR: ME : I I I I : I :-_ .. _ --_ .. -..
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__ .. --- -.--------: -.. -------------_.- ----- .. :.-._----- ---_--_ ..
_ .. __ -: .. ------------ ----- J ------ .. - .. --- --------- f--- _.._- ..- -0.- _._ .. --­ : CA EVENTS : a S CA643 04/03/96 : S CA026 07/31/96 : S - CA626 11/30/96 : S • CA636 02/01/97 IS' CA62605/31/97 : S CA63609/01/97' .: : iil S CA633 05/06/96 : S • CA633 08/01/96 : : : : : : iil S CA026 05/07/96 I : : : : : : a S CA626 05/1 0/96 I 

### I : : : I : iil S CA636 06/05/96 : I : : : : : iil S • CA643 06/17/96 : : I : :
......

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### I : HCAPS: ME EPR: ME I : S - PC026 06/30/96 IS' MP160 09/30/96 : S • MP200 12/30/96 : I I :..· ········ ..·····,·········· ..··············1·························1······
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### 1···· · ········ ···· : . : CA EVENTS I iil S - CA026 06/10/96 : iil S - CA633 07/09/96 : S • CA633 10/31/96 : S - CA623 02115/97 I S - CA633 05/31/97 : S • CA623 07/30/97 : : S • CA633 06/15/96 IS' CA623 07/25/96 : I : IS' CA633 09/30/97 : : : iil S • CAns 07/31/96 : : : :

. .: : I iil S - CA750 07/31/96 I : : : 

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..--.- -: ---- ---- ····1····--- '-'-'- --.- - . ?RE.SSURE IREATED TlMBEI POSTCLOSUREI 001: 

### I S PC47607/31/96 1 : : S PC621 04/30/97 I loD 04711 1018 : STE CONTACT: BLE: I S PC621 07/31/96 : I : S PC621 OS/28/97 : TSo UNIVERSE: 0: : I S PC631 08/31/96 : : : S PC631 06/30/97 : HCAPS: ME EPR: HI : : : S PC026 09/28/96 : : : S PC631 06/30/97 : I·· ····· ········:··· .. ··· .. ··········· ··· .. 1··········
.. · , , \ , .. : CA EVENTS I iil S CA160 04/19/96 : a S CA623 07/23/96 : S CA626 10/31/96 : S CAS70 02/28/97 I I : : iil S CA200 05/03/96 : S CA470 07/31/96 : S CASSO 12131/96 : S CA623 02128/97 : : : : iil S CA410 OS/24/96 I S CA026 09/30/96 : S CA636 12131/96 : S CA633 03/31/97 : : : : iil S CA460 OS/24/96 I S CA633 09/30/96 I SCAnS 12/31/96 : S CA999 03/31/97 : : : : iil S CA4S0 06/21/96 : I I : : I I iil S CASOO 06/21/96 I I I I :

NOTE: ACTUAL EVENTS PRECEDED BY 'il'

(EY TO EVENT RESPONSIBLE AGENCT/SECTION KEY TO TSD UNIVERSES E/P = fEDERAL PERMITS SECTION CONTACT o • LAND OISPOSAL FACILITY E/C = fEDERAL COMPLIANCE SECTION CONTACT S = STORAGE/TREATMENT FACILI TY E/O • FEOERAL OPERATIONS OFFICE CONTACT C • COMBUSTION En fEDERAL COHTACT, SECTION UNKNOIIH E/S • STATE CONTACT. ENTERED BY EPA J = JOINT FEDERAL/STATE CONTACT S • STATE CONTAg 

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08/05/96 PAGE !DAHO SIX QUARTER PLAN BEGINNING APRIL 1996 FRON THE RCRIS STATE IMPLEMENTER DATABASE ::VENT TYPE. ALL CA ANO PERMIT EVENTS / RESPONSIBLE AGENCY. All 1ST QTR 2ND QTR 3RD QTR 4TH QTR 5TH QTR 6TH QTR APR'JUN JUl·SEP OCT'DEC JAN-MAR APR· JUN JUl·SEP FAC IllTY PERMIJ 96 96 96 97 97 97

- a. -_ .. • - - - - - -:- - - -1-··· -. -- 0_· -- - - -. -.- -l·· - --_.

_ .. - -. -- ---- -- ----I- _.- .. -- _ -. _.-- _ - --1-·· .-- ..--. -- _.--- -.._ .. - --:.- - _.- ---_ .. -_. -oo •• - --1-" - ----- --_.. ---- --- --_.. ­ SAFETY·KLEEN CORP 1-181 CA EVENTS : il S CA626 04/01/96 

### ! a S CA626 07/12196 I S CA626 10/21/96 I S CA626 01/15/97 I S CA626 04/15/97 : S CA626 09/01/97 (DO 00071 2026: : il S CA636 05/13/96 I S CA63608/20/96 I S CA636 11/22/96 I S CA170 02/15/97 : S CA636 05/31/97 : S CA026.09/30/97 TSO UNIVERSE: 0 S I I il S • CA026 06/28/96 IS· CA026 09/28/96 I S CA026 12/31/96 I S CA636 02/28/97 : S • CA026 06/30/97 Is· CA636 09/30/97**,~CAPS:** ME EPR: HI I : : : S CA075 12131/96 : S CA026 03/31/97 I I 

### I I : I S CAI60 12131/96 I I : I I I : S CA225 12131/96 : : I

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### ! : S • OP624 04/01/97 

### I TSD UNI VERSE: S I IS, OP632 04/30/96 : I I : S • OP026 06/30/97 I NCAPS: lO EPR: LO : I il S - OP026 06/28/96 I : I : S • OP631 06/30/97 : I : I I : : S • OP634 06/30/97 :

............... -_ _ _.-- :.. ---- -_ - --- -I**~--** .. - .. - -.. ---- -_ .. - : - - - - -.. - -: .. - - -.. - - --- f - ..- --- ..-_ -- - "1- -.. -- .- - -- ----- 1-- ----· - · -- ---- .. USAF MOUNTAIN HOME BASi PERMITI 0011 S • OP026 06/29/96 IS· OP026 09/28/96 IS· OP026 12131/96 IS' OP026 03/31/97 IS' OP026 06/30/97 : S • OP026 09/30/97 103 57212 4557 : STE CONTACT, MHJ

### I Ii: I 

# I TSO UHIVERSE: 0 S I I I I : I**~CAPS:** liE EPR: HI: : : I I : : :.. - - -- --.--: - -- - -- I· · -. - ----- .. -:.--- .. ---- - -.. -.. --.. - t--- -- ----.- --- · -----1
.. -- ··- --- -- .. - - ·1 ------ -- -- --- I CA EVENTS : iI S • CA056 04/01/96 : S • CA070 09/30/96 I : : : : I : I : 1 1

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.. -...... --.-- USDOE IDAHO HAT'l ENGI: AMI/IF-01 508! I : S • OP026 12131/96 IS' OP026 03/31/97 IS' OP020 04/30/97 : S • OP100 09/30/97 104 89000 8952 : STE CONTACT: BLE: I : : : S • OP403 06/30/97 I TSD UNIVERSE: 0 C : : : : : I : HeAPS: HI EPR: HI I : : I I I : : _ : '."'.'" ···-1·· : ,. _. ·1-····· ··1-········· - , ···1········ , . : AHI/IF-02 509: : : S - OP026 12131/96 : S • OP026 03/31/97 IS- OP020 04/30/97 : S • OP100 09/30/97 : STE CONTACT: BlE: : \ I : S • OP403 06/30/97 : : --. - - -- ---1
.. ----· -_ ---- -- -- : ---- --- ---- -- : -- - -- .. ----- - :- ---.-- .. ----- - --.. -.. -1 ··-------- .. --- .. -- ·1" -- ---- -.. - ---.. ­ : Cl-BLUCIC·II 5021 il S • CL360 04/15/96 : a S • CL370 07/01/96 : S • Cl370 11/01/96 : S • CL380 01/01/97 I : : SlE COHTACT: REBI il S • CL370 06/07/96 I I : I : 1-··
.. ---.. --- -.. -.. :.. - ---.. -- .. -- --. --- .. 1 -·---- .. - -. - --.-- -1-
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.. -.-- ------ .. - -.--- --- ----- -.. ----- .. ­ : CL·BLOCK·IV 5071 il S - Cl310 06/24/96 : I : I : : STE CONTACT: RE81 I I I I :
NOTE, ACTUAL EVEHTS PRECEDED BY 'il'

KEY 10 EVENT RESPONSIBLE AGEHCY/SECTION KEY TO TSO UNIVERSES E/P FEDERAL PERMITS SECTION CONTACT o • LAND DISPOSAL FACILITY E/C FEDERAL COMPLIANCE SECTIOH CONTACT S • STORAGEITREATMEHT FACILITY s/o = FEDERAL OPERAIIONS OFFICE CONTACT C • COMBUSTION E/7 = fEDERAL CONTACT. SECT lOll UNKNOIIN E/S STATE CONTACT, ENTERED BY EPA J JOINT FEDERAL/STAlE CONTACT S = STATE CONTACT08/05/96 PAGE 4 10AHO SIX OUARTER PLAN BEGINNING APRIL 1996 FROM THE RCRIS STATE IIlPLEIlENTER DATABASE EVENT TYPE = ALL CA AND PERHIT EVEHTS / RESPONSIBLE AGENCY = ALL 1ST OTR 2ND OTR 3RO OTR 4TH OTR 5TH OTR 6TH OTR APR-JUN JUL-SEP OCT-DEC JAN·HAR APR·JUN JUL-SEP FACILITY PERMIT 96 96 96 97 97 97 I- ------.. -----.--1------ .-._-- --.. ---- ---.-J- ••••--------------••----J.•------••-.-. -.-- ----··-1-- -----.. --------.--. ·-··1-----··------····

---- .... :.. -.. ------.... ----... -.­ : CL·BLOCJ(-V 5101 'I S • CL310 07/31/96 I 1 

### I 1 I STE CONTACT: REBI , S • CL310 08/31/96 : : I : I .. _._ __ 1 _ - _.._. __..__ 1
.. - :1._-

_ .. _ .. _ _ .. I •• _ .. _ .. _ .. __ 1 .. __ .. .. __ _ ••• 1 • 

### ! CL-BLOCK-VI 5111 

### I 

### ! I 

### ! 5 - CL310 06/01/97 

### I . : STE CONTACT: REBI I I ' : S • CL310 06/30/97 : : ... -----.-.----- -1··-----.-. -

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.... ·------···-·----1--··· .. -.-- ---..... ------ I CL-BLOCKIII 0211 as - Cl311 OS/22/96 : iil S • CL330 07/02/96 'I 5 - CL340 11/01/96 I 5 - CL360 01115/97 J : 5 - CL370 08115/97 : STE CONTACT: RE81 a S - CL311 OS/23/96 : a S - CL330 07/03/96 , I I : 

### ! : as· CL320 06/03/96 : S - CL421 09/15/96 : : 1 : .-" --- ....... -----... :---- .. -.. -....... ---.- .... .-. .. ----1---- .... ----.--.......... _-·· ...... -1-·.- ......-_ .. -------_.... --- .. :......---- -------........ ------1---------------·· --------l·· ------- .. -...... ------._ .. -­ : CL-CPp·FDP 022: as· CL370 04/01/96 : 1 : : I : STE CONTACT: HHJ; a 5 - CL380 05/13/96 1 I : I : :---_ _ ----- .. : ---- .. --_ --------1- ------

__ . ----- -_ f -.- ----- -- .-- -------- -:1--------.---.-.------.- ·-1---- ----.. -.. ---- -------- -1------ .----.-- ---.-. --. --. : RDDOOI 503: I 5 - ROllO 09/30/96 : S • RD100 12/31/96 I . : : : STE CONTACT: BLE: I : I I

. I 1-··· -.-.-- .. ---- ... ·1-·- -....-... -. ----. -.. -------: .-- -....------ --....-. --- -.. f ..--------- ·--------------1---· -.- --oO ....... -- ... ------ -- 1.. _--.- .---- ......... --.-----oO ..:... -----.---------- ... -----­ : VOL04&D7 0191 as· OP026 04/01/96 I 5 HOllO 07/01/96 : S CL370 10/31/96 : S - M0160 01/02/97 S HOZOO 04/01/97 : S .140424 08115/97 : STE CONTACT: JEH! a 5 H0240 04/04/96 : 5 H0150 09/01/96 : S H0488 12/01/96 : S - H0150 02/15/97 S H048904/30/97 I 5 H0200 08/30/97 : I a 5 HOllO 04/05/96 ; S HOl00 09/30/96 : 5 HOllO 12/02/96 : S 110488 03/30/97 5 H0205 05/01/97 I S H0205 09/30/97 : : a 5 HOllO 04/15/96 : 5 OPOZ6 09/30/96 : S CL380 12/31/96 : S.· OP026 03/31/97 5 H0160 05/15/97 I S OP026 09/30/97 : : S OP315 OS/23/96 : \ S OP026 12/31/96 I S OP026 06/30/97 : : : S HOl00 06/01/96 : :: : : : Q) 5 140230 06/03/96 : :: : : : Q) 5 HOZ31 06/28/96 I I I I : -------. -- .._-: .- .. - -- .-_ ..-.-- --- f - -- --**.--~.** ----- - ---- ..- -: --- ..- ..-- ------ ---.--- t---- ..- -- .-- --- ..- ,- .. -.--- - ----.- 1-------.. ·- -- ---- .. I VOL05 0051 a S OP6Z7 05/10/96 I a S OP637 07/01/96 I S H0240 12/01/96 I S - OP627 02/01/97 I 5 - OP026 06/30/97 : S - OP627 08/01/97 : STE CONTACT: KLHI iil 5 OP62705/10/96 I S OP63707/01/96: S - OP026 12/31/96 I S OP63703/15/97 liS OP637 09/15/97 : : a S OP026 05120/96 : S OP026 09/30/96 I : 5 - OP026 03/31/97 : , S • OP026 09/30/97 : : a 5 140230 06/24/96 ; ; : I : : : a 5 H0231 06/24/96 I I I : :

- .. - .. - - ­ :oO ..-- -- ..- - ..----: ..- - - .. -oO t- - ----- - -- -..- .. r- -- - --- ..- ..- ..---·1 --- oO ..--------- ..- -- t -.. --- .. -._ - · .. · .. 1- .. -.. - --- "·oO ..---- -- ..-. : VOL08 011; a S - OP026 06/28/96 : S • OP026 09/30/96 1 S - OP026 12/31/96 : S - OP026 03/31/97 IS· OP026 06/30/97 1 S - OP026 09/30/97 I STE CONTACT: BAHI : I : : :
HOTE: ACTUAL EVENTS PRECEDED BY 'a'

KEY TO EVEHT RESPONSIBLE AGEHCY/SECTION KEY TO TSD UNIVERSES E/P = FEDERAL PERHITS SECTION CONTACT o • LAND DISPOSAL FACILITY E/C FEDERAL COMPLIANCE SECTION CONTACT S • STORAGEITREATHENT FACILITY e/o = FEDERAL OPERATIONS OFFICE CONTACT C = COMBUSTION en FEDERAL CONTACT. SECTION UNKNOIIN E/S STATE CONTACT. ENTERED BY EPA J JOINT FEDERAL/STAlE CONTACT 5 • STATE CONTACT 

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OB/05/96 PAGE 10AHO SIX OUARTER PLAN BEGINNING APRIL 1996 FROM THE RCRIS STATE IMPLEMENTER OATABASE EVENT TYPE' ALL CA ANO PERMIT EVENTS / RESPONSIBLE AGENCY' ALL 1ST OTR 2ND OTR 3RD OTR 4TH OTR 5TH OTR 6TH OTR APR·JUN JUL·SEP OCT-DEC JAN-MAR APR-JUN JUL·SEP FACllI TY PERMIT 96 96 96 97 97 97 : ·'-1-" -1- -1-" - : - -."- - : :
.. I VOL09 0121 a 5 OP100 04/1B/96 : S • OPll0 07/15/96 ': 5 OPllD 10115/96 IS· OP070 03/31197: 5 • OP11D 05115/97 I : STE CONTACT' BLEI as- OPll0 04/1B/96 : 5 • OPl00 07/31/96 , 5 • OP160 12131/96 : I : .': I as· OP406 04123/96 'I S • OP100 09130/96 I I' : I

, I as· OP110 06104/96 , I , : :

, ••••••••••••••••• , ••••••••• - ••••••••••••••• , •••••• "-' •• - ••••••• , •••• r••• , ••••••••••••••••••••• 1•••

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## I V0111&12 014: S • OP110 05/01196 

## Is· OP150 08/01/96 

### ! S • OP489 10/03196 IS· OP171 01102197 

### ! 

## I I STE CONTACT: JEMI 5 • 0I'11D 05/01196 IS' OP48809/01/96 : S • OP160 11/04/96 IS· OP200 01116/97 : I I : : : I S - OP205 02117/97 : I ':- -_ -1- -1-··""""""""""""""" -- : - '"': ':" -- -1-" -- -_ -1- --- _ _.­ r VOl16 5051 as· OPll0 OS/28/96 : S • 0P150 07101/96 : 5 • OP160 10/01/96 I : : : STE CONTACT: REB: : S • 01'488 08115/96.1 5 • op171 11/15/96 I : : I : : S - OP4B9 09/15/96 : . S • OP200 12101/96 I : : : : : IS· OP205 12115/96 I I I I"·'·"· .- : - _ :- -. - --.. -.. : - --.'.' -: .. - 

### -I-- ,..--, ,.,.", ..-.: -.- . I V0117 504\ as· OP40604/23/96 : S • OPll0 08/30/96 5 • OP150 11/30/96 IS· 01'488 01/30197 I 5 • OP171 D6/30/97 : S • OP205 07130197 

# I
: STE CONTACT: BAM: as· OP100 06/10/96 : : S • OP160 03130197 : S • 01'200 06/30197 : S • 01'026 09130197 1-"""""""""""""""":""" --_ -1- -0-""""""''''' "1- ----- _ --. ----_ -.. -.. ,..
_ .. -_ .. _ -_ ..
_

.. ---_ .. ------: ---- _ .. _ _ _ .. -- - -I _
.. -- -_ ­ : V0119 5121 a S • 01'020 06129196 IS' 01'403 08/01/96 IS- OP100 11/30/96 : S • OP110 02{15/97 : S • OP100 04/30/97 I 5 • 01'150 07l3DI97 I STE CONTACT: BAM I I I I : I

NOTE: ACTUAL EVENTS PRECEDED BY';;)'

KEY TO EVENT RESPONS I BLE AGENCY/SECTI ON KEY TO TSO UNI VERSES E/P • FEDERAL PERMITS SECTION CONTACT D • LAND DISPOSAL FACILITY E/C • FEDERAL COMPLIANCE SECT 10M CONTACT S • STORAGE/TREATMENT FACILITY E/O • FEDERAL OPERATIONS OFFICE CONTACT C • COMBUSTI ON En • FEDERAL CONTACT. SECTION UNKNOIIN E/S • STATE CONTACT. ENTERED BY EPA J • JOINT FEDERAL/STATE CONTACT S • STATE CONTACT