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 of hazardous waste in Idaho. This 

legislation provided the authority for promulgation of hazardous waste rules and standards by the 

Idaho Board of Health 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 of Idaho'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 of State regulations became 

effective on January 1, 1985. Annual rule updates and corrections have been promulgated 

subsequently (see Appendix II). 

HWMA instructs the Board of Health 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 of equivalency 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 of July 1,1987, and interim 

authorization for the HSWA Corrective Action provisions promulgated as of July 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 of this 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 of this document consists 

of appendices 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 of duplicative 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 of all delegable hazardous waste regulations in RCRA Cluster V. An EPA 

Headquarters memorandum dated January 26, 1996 recommended States defer adoption 

of the 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 of a 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 of Idaho's 

hazardous waste program. Minor reorganizations did not impact these responsibilities. 

C. Staff Job Descriptions [40 CFR §§ 271.6 (b)(l)] 

There are no new staff positions which require job descriptions for the purposes of this 

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%) 

of the 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 staff positions. 

E. Training 

Continual staff training is a key element of the 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 of the RCRA staff during the time-frame 

applicable to this revision package. 

In addition to technical training, where appropriate, RCRA program staff are trained in 

accordance with the State ofIdaho Worker Health and Safety Program, which includes 

training in the use of personal protective equipment and the requirements of 29 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%) of the 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 of Idaho'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 of the 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 of Attorney General for all programs. The RCRA program is allocated 

approximately 1.5 FTE attorneys. 

3 
Idaho 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 of hazardous waste or used oil handlers in Idaho is 

delineated in Appendix VIII. These numbers are based on receipt of hazardous 

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 of handlers, 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 of Idaho'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 of hazardous 

waste managed within the State ofIdaho for the calendar year 1995. This 

information was obtained.fromthelSs 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. 

If these 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 of the 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 of Agreement. 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 of Idaho'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 of the 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 of data from the Hazardous Waste Data Management System 

(HWDMS) to RCRIS, (2) information sharing procedures, (3) 

implementor of record policies, (4) dispute resolution procedures, and 

(5) general RCRIS management issues. The MOU was amended in 1995 

with the addition of Attachment 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 of an amendment during the 1996 legislative session, Section 

39-4411 ofHWMA now requires all hazardous waste generators and 

disposal facilities to report quantities of hazardous 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 of hazardous 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 of both 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 staff participated 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 CLUSTERS ADOPTION 

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 

• Optional Rule Page 2 
• • • 

I 1
 I RULE CODE I : FR REFERENCE I PROM.DATE RULE NAME 

' : ' ; 

Universal Waste Rule (Hazardous Waste Management System; Modification of the 

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) 

~C~AV 4/15lQe (T)

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 

;\~

Mlchsel Lenaghen :J

.~~ 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 

Bureau Chief ..4. 

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 

AQ Engineer WO Analyst

George Fink - Mike Cook 

AQ Engineer WQ Analyst 

- Ray McDougal f-- Rick Huddleston 

AQ Engineer : WQ Engineer 

f-- Bill Rogers f-- • James Macinnis (NIRO)

AQ Engmeer We) Cllgineer

- 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.-.. 

I .. _-'"

- .­ .ti 

--

_ 

_. _ ~'~~U;' -' 

-­

-­

£511, £& 1 f .........,.... 

•. o , _ ",na _ .....

- --­

.... 

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

--­

......, _"a' 

H" ." ,u", 

_ '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 mana~. 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 

Two H\\ 'I" opcalllli pennit. for 

un'l' al I...El were 'uaed 11I" ycar. 

0. of the penn'la ia for spec ifIC: "' ''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 ha ndhllll 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 101M pllbhc 

,n ea.ly 1996. W" e..pect 10 rec"ive 

Ib,,,,, more pe rmil app licalions in early 

111\16. 

"lure than 70 unlll Ihal lreal and 

Ilor" hU-Iroolls "'·U l'" al the l"'El 

operale under int""m Stal"S p,ovisions 

.... hich al1o... lions Ihal " ·ere In operanon plior 10 reg ulalion 10 co nl;nue 10 

operale pro,',d"d lhe y meet specific 

,equi remenll. Evenluall y lhese uni" 

w,lI be eueer fully 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~ '"

I w 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 0.01 0/. 

'"

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', """Ii. IW1. 

T1>tj'«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 cha nged whcn an 

alkaline ,u[),;lanee" addc'<.l10 change the pH. 

How hazardous waste is managed 

LJndfill 

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 IOnSot'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 Idaho. % ....of 

the wa>1e destined for recycling wenl out"",f- s'tate. 

There are no commercial incinuat..... in Idaho. so 

waste mUSl be taken oul ofthe stalC for incineralion. An 

e\perimcntal iocincrator at INEL incinerated some wa.-n: 

in 1995, a.ceounting for lhe 30

;;' ofwa ' ICincinernted in 

SIale,• 

,- ... 

landfIll 1,11>0 

-..­

-­~, '" 

Hazardous waste imported 

into Idaho 

(0.2%) (79.1%) m Y/.) Envirosafe 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 

ICfritOOcs. Canada and Mexico. 

In 1995, ESII received 115,938 tons of ", ..'Ie. an 

incrca..of lO.7';;'from lhe 103,548IOn, theyreceived 

during 1994 

M06tofthis wa.SIC (95%) carne from out-of-state. 

Total n,,~ nS.81b 2.4n Only 5%oflhe wa'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 Ofw"le were treated \(I reduce 

loxicily prior to di,posal. 99"/. of this Irealment was 

done at lhe facility where the wa",c was genernted. 

1,757 IOnSof waste were reuSl'd or clt'd

10ESll in l 994, 

Three majortypesofwasle are received by ESll : 

• RC RA We_ICwhich is defined by federal and 

state lawas hazardous. 

• TSCA Wa.,le i. defined by TSC"A and regul 

ated by the EPA in Idaho 

• State ""-aslCwhich is defined and regulated as 

hazardous by other states. bui not by Idaho, 

When brought to Idaho. il i. handled as a 

hazardouswa.'<Ie • 
I)/r'"' " 

\l~az a d o u waste regulations 

Used Oil Regulation5 

Idaho ha<; had regulalion s 

pertaining to used oil for over a 

year. Federal regulations foon<! in 

40 eFR part 279 have been 

adopled by reference by !be slale 

of Idaho. •Adopted by reference " 

mean. lhal !be ....ie adopted the 

federal rule. ju.1as they are in 

the federal books. Idaho i. 

required 10 do this 10 keep our 

program as strict as, bol no more 

. tricter than. the fede ral program. 

lk u.sedoil regulaliom • 

apply 10regulaled generalors, 

Iran.porters, and borners of used 

oiL DEQ bas brochures availahl e 

on these regulalions. If yoo'd like 

copi es 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 

streamlinesregulatiOllS governing 

management and collectionof 

certain rommonly generated wastes 

knownas ' univeJSlll wastes." 

Univa-sal include ""'".ardons 

wa>;!e batl"ries sudl as nickelcadmium batteries, some hazardous 

Wa>;!e pesticides. and mercurycontaining thermostats. 

By reducing certain regulatory require menIs, this rule will 

encourage e nvironmentally-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'.-dI>l'""If' 10",. 

""',..... J9-111 1. no. ,..".I...-l i,-" l»\:I, Joi", ..../I IN ;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,tcLiu-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 J9S-	 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 of the 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 staff members 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 staff and 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 of up 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 staff member 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 staff member 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 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 by calling 

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. If it does indicate a change, it is 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 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 staff who 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 staff members 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 of the report and the facility's EPA identification number. If the 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 of facilities 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 of handlers in RCRIS. Four different sorts 

are 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. If the 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. If the 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. 

• 

If a member of the 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, ifthe 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 of the 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 of primarily 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 

of hazardous waste by bringing violators into compliance from the point of generation to final 

treatment, reuse, or disposal. The tools used to implement this policy consist of direct monetary 

or equivalent economic 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 of processes and their associated waste streams 

in addition to the review of product data to determine characteristic properties of the waste. 

Often samplesofwaste streams are collected for analysis to verify the accuracy ofthe generator's 

waste characterization. Inspections also include the evaluation of quantities of wastes generated, 

accumulated, or stored on-site to determine regulatory status. 

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 of potential threat to human 

health and the environment, proximity to population, water sources or other environmentally 

sensitive media, travel distance to the site, and availability of resources as determined by DEQ 

management. 
Hazardous Waste 

Compliance/Enforcement Strategy 

Page 

September, 

2 of 10 

1996 o

"The Resource Conservation and Recovery Act Inspection Manual"(1993) is used for initial 

training of Hazardous 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 staff or outside contractor services may be required to complete the sampling activity 

to obtain representative samples. Compliance staff work 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 of operation, 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, staff are assigned specific areas and prepare 

individual sections of the Narrative Inspection Report. Inspections of this magnitude may also 

require extensive, post-inspection in-house review of information 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 

specific procedures during the inspection. Review of plans, which may require the use of outside 

contractor services, will be undertaken as necessary under the coordination of the appropriate 

compliance staffmember. Where the regulated unit has a permit, the annual inspection will also 

include verification of compliance 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 of entry, 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 of hazardous 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 of each federal fiscal 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 staff with DEQ's inspection/enforcement role. 

HW Science Officers gain access to facilities or sites upon a presentation of credentials signed 

by the Idaho Department ofHealth and Welfare Director (Director): 

ill. ENFORCKMENT 

A. Enforcement Process Overview 

The identification, processing, and final resolution of an 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 

Page 

September, 

4 of 10 

1996 o

2. Facility Notification 

In accordance with EPA's Enforcement Response Policy of 1996 (ERP) guidelines, a facility 

is notified of non-compliance by the following: the HW Science Officer drafts a Warning 

Letter (WL) or Notice of Violation (NOV) for all administratively-issued actions. 

After review by the EB Manager and assigned Deputy Attorney General (Attorney), WLs 

are submitted to the EB Chief for 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 of violations of HWMA and the Hazardous. 

Waste Rules is summarized in EPA's 1996 ERP. This document is herein adopted as part 

of this 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 of hazardous 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 of exposure 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 of recalcitrance; 

3)	 Violations should be of a nature to permit prompt return to compliance; 

2. Notification 

Violatorsare informed of an enforcement action by Certified Mail delivery of a WL or NOV. 

In the case of a Judicial Referral (JR), the violator is notified by phone by the assigned 

Attorney upon his receipt of the JR. 

The WL recites applicable State rules and HWMA provision violated and may include 

copies of the 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 -:10 

:",­

resolution of the enforcement action. The NOV stipulates a request for a compliance 

conference must be made within fifteen (15) days after receipt of the NOV. Although the 

actual compliance conference is usually held after the fifteen (15) day contact period, the 

lack ofcontact 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 

Page 6 

September, 1996 

of 10 o

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 of a JR by the Enforcement Manager, through the 

Chief, and subsequent action by the AG's Office. If negotiations 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 complianceC 

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 of time 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 of documentation 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. 

If the documentation is not acceptable, a revision is requested and a short turnaround time0 

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 of the 

missed deadline. Ifthe schedule is then met within five (5) working days, no formal action 

will be taken. If the 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. Ifthe 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 of a 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 of the 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 Chief discusses 

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 of a complaint is subject to approval of the 

• 

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 

Page 

September, 

8 of 10 

1996 o

Subsequent to the receipt of a 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. If there are
 

significant disagreements, the legal staff can raise their concerns to the appropriate levels
 

administratively; but the ultimate decision rests with the DEQ Administrator.
 

Thedecision whether cases are suitable for district court action is determined by tbe AG's Office.O

The EB Chief, in consultation with the AA and DEQ Administrator, determines if a case should 

be filed. If the AG's Office agrees, the assigned Attorney prepares a complaint after review of 

the JR. 

E. Public Notification 

When the facility is notified of a 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 of violations, 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 of remedies 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. If the 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 of an 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 of threat to human health or the environment, compliance history of the 

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 

Page 

September, 1996 

10 of 10 o

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 of EPA 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 of Environmental 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 of authorized 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 of DEQ and the Director of the EPA Region 10 Hazardous 

Waste Division. Minor revisions may be approved by the Chief of the 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 of Understanding (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 of EPA oversight is to strengthen the State enforcement program and ensure national 

RCRA goals are achieved. EPA's oversight is to be accomplished through evaluation of the 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 completion ofan oversight inspection,the EPA inspector is responsible for conducting a closing 

interview with the State inspector. The purpose of this 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 of RCRA 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 of facilities 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 of the 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 of HWMA and the Hazardous Waste Rules within the 

State's jurisdiction. 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 of HWMA 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 

of EPA 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. 

If the State and EPA do not agree on an acceptable enforcement action, the Administrator ofDEQ and the 

Director of the 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 of the 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 

of RCRA 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 of State-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 of mutual 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 of regulations, technical judgement 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 of a 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 

of any 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. 

Wallace N. Cory, tAdzd~1J~ Administra 

Idaho Division ofEnvironm n Quality 

Mike Bussell, Director Date 

EPA Region 10, Office of Waste and Chemical Management 
Idaho Division of Environmental 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 of authorized 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 of the Ef'A'Region 10 Hazardous 

Waste Division. Minor revisions may be approved by the Chief of the DEQ Enforcement Bureau and the 

Chief ofthe 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 ofUnderstanding (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 of EPA 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 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 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 of this 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 of facilities 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. Every effort 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's jurisdiction. 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 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. ' ' 

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 

' ' of EPA 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. 

If the 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. 

" \ .. : I. ~" '..'
 · , J~Jv.::- .\., -'
 VI ,. Reporting {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 ~PA and agreed to by. DEQ, an? will include all inspection and enforcement activity completed the 

,~_preVlous month. The State IS responsible for the accuracy of State-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, technical judgement 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 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 of a 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, 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. . 

,tJa;d~)? , q/lqf;c, 

Wallace N. Cory, Administra Date 

Idaho Division ofEnvironm n Quality 

.sau: 1~/2..lqtp

Mike Bussell, Director Date 

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

- -1- ·· .. _.e.: - -.---_ --- ----: .a_ ------ -.-_ -_ :---- _.. __ .. --- _ --_ .. ; ----_ ..-_.----_ -:- --_.----.. ---.- -- -- -1-"-_.. --- ---- .. -----_ .. ---

BLOUNT INC CCI OPER I PERMI11 0011 I : : I : 5 - CL310 09/30/97 

100 00906 6481 : STE CONTACT: HHJI : : I : I ISO UNIVERSE: 5 I : : I : I : HCAPS: HI EPR: HI I : : : : I : 

:-~~. ~~~~;; -1- _.; :.~~2;· ~~;2~;~~ _.! ; :.~~ii·o~;;;;~~ ·-1-'·;···:'~~2~O·; ;;30;~~· ., ; :'~~500' o;;;o;~;··I"·;· ·':'~026· 06;;O;~;' -1-······ . : Is· CA026 06/29/96 : S • CA026 09/28/96 : 5 • CA026 12/31/96 : 5 • CA470 03/30/97 : I : : : S • CA190 09/30/96 I : S • CA026 03/31/97 : ................-_ : - :. -_ .•.......••..••...•...:........•..•.........•..·1-· ....••.•........._..•.. :........•...•.........•.. I •••••, •••••••••••••••••• -1'..••.•-.•......'" .
 

DART INDUSTRIES INC I PoSTCLoSUREl 0021 5 • PC633 04/30/96 1 a S • PC633 07/25/96 I 5 - PC623 12/30/96 : S • PC633 01/28/97 I 5 • PC633 04/30/97 1 S • PC633 07/31/97
 

100 00046 7332 : STE CONTACT: JEMI il 5 • PC623 05/31/96 I I : 5 • PC623 03/01/97 IS· PC623 06/30/97 :
 

ISO UNIVERSE: 0: I 5 • PC633 06/30/96 : : 1 S • PC621 03/31/97 I :
 ~CAPS: La EPR: HI I I· I I : : :
 ............... - _ _ --1- -_ -1- _ --- ·· .. ·1--· ---.- _ -- _ :-----_ --- -- _.. -- - :.. -.- _ _.. _- _ "1--"··-"--- _.. _ _.. -·"7 -_ .. : __ _.._-_ -- .---..- - ..
 

ENVIROSAFE SERVICES OFI PCPERMIT 001: il S • PC026 04/24/96 : 5 • PC026 09/30/96 : 5 • PC026 12/31/96 I 5 • CL026 03/31/97 : S CL026 06/30/97 : S CL026 09/30/97 

100 00077 3952 : STE CUNIACT: MHJ: I I : : S • PC026 06/30/97 1 S • PC026 09/30/97 

;50 UNIVERSE: 0 S I : I I : I : S • PC026 09/30/97 

HCAPS: ME EPR: HI: I 1 I I I I I 1 __ -- _ .. --_ --- I -- - --- -oo oo -_ 1 .. - - _. _. --- - •• - 1 --- -. - .. --- .----1 -- .. "".OO" 1 __ - ---_.- - .. --. _ .. __ ._ .. ­ ! CA EVENTS !il S • CA626 04/12/96 I 5 • CA626 09/01/96 Is· CA560 12/30/96 I 5 • CA570 02/28/97 I 

1 I 1 5 • CA026 09/30/96 : S • CA026 12/31/96 S· CA999 03/31/97 1 I : . I : S • CA570 09/30/96 I 1 I 

: I : 5 • CA636 09/30/96 I : I ........................................... : _.. _ f _. --- ---- ..-_ ..-----._ .. : _oo- ------ _._ -1--"""""""" - oo_ ..--.-...... ....---..--- -- - -1----- --- -- _ _ -, --_.. - --_._..---------


ENVIROSAFE SERVICES OFI PERKII1 0011 a S HOllO 04/12/96 : 5 H0160 09/30/96 I 5 M0200 12/31/96 S M0205 02/01/97 : S • OP026 06/30/97 : 5 • OP026 09/30/97 

100 07311 4654 I STE CONTACT: JJH I iii 5 OP623 04/15/96 IS' OP026 09/30/96 IS· 0?026 12/31/96 S OP026 03/31/97 I I TSO UNIVERSE: 0 5 : I a S OP623 04/16/96 : I : 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 

I 1 

I 

I 

il 

il 

il 

S OP251 

5 OP026 

5 OP633 

05/31/96

05/31/96

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 CONTACT
 
08/05/96 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 

:-_ .. _ --_.. -.. _.. --·1·· -- __ .. --- -.--------: -.. -------------_.- -----.. :.-._--------_--_ .. _.. __ -:.. ------------ ----- 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 : : ...... _.. __ ·-.. --.. ---1·-------_.oo·- - :---- ----- ---- -.. - _--)----- -.. ---_._ .. ----- : ···1· ·1··········· : ... 

PACIFICORP : PCPERHITl 0031 a S PC621 04/02196 IS' MP1S0 07/15/96 I S - PC623 10/01/96 IS' MP20S 01/31/97 : : 

IDD 00060 2631 : STE CONTACT: JEMI iil S - PC0260S/06/96 IS- MP488 07/15/96 IS' PC633 11/29/96 I : 1 

ISD UNIVERSE: 0 : . : S - PC026 06/14/96.1 S • MP489 08/15/96 IS' MP424 12/16/96 : 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······..···············..··1 ..·········..· ..···· ······ 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 : : : --.- -.--- --- --: --..- -.-.- : ,- ,--.- ! : -..-- : -..--.- -: ---- ----····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
 

o o o
 
• • • 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 .. -_.. -_.. - --_ -- -1-·-_ _ --_ "l"·"---_ ---- _.----""-1-"-""---- --- .. ------- --- J ..------ _ .. --- _ .. -- --1----"-" --------- ---- -- -1----.- -- .. -- -_ .. _ ----1-" _ -----.. _ _-------... SAFETY-KLEEN CORP 1.181 PER/IIT1 0011 il S OP621 04/01/96 IS· OP026 09/28/96 : S • OP026 12/31/96 : S • OP026 03/31/97 : S OP621 04/01/97 : S • OP026 09/30/97 

100 98177 0498 : STE CONTACT: BAHI iI S • OP631 04/19/96 : : ! : 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, MHJI 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 .. ----. -.. --.. --. --.. --. -1--........ ·.. · .... ·..... ---: ---- ....--.. --...-----.- .. ---1 ..... -...-.-- --......-.. --- .. ·---l-" -_ ......-....... ----....... ----.. :..._- .-- --...-.. --- .. -. -.- --"'1"-" .... --.. -.....----- .. _-- .. --·1-"----.----.. -"'- .. -...... --.--
 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-.. -------.. -- ----- ~--.- -.. - ------.. -- -- 1"- .. -.-- ------.. - -.--- --- ----- -.. -----.. ­ : 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 CONTACT
 
08/05/96 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··-----.-. -...-.---.. --. -:----....-.----.. -.. ---.-.:.---------····------··---1-·--·--...-....-----. ··--1· ----....·------···-·----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
 

o o o
 

J I 
• • • 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••• __ •......-•.•...•..•.. ,•••.....-••.....--. --••. ' ,.....••.•••.....•-••..... 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 I 5 • OP150 11/30/96 IS· 01'488 01/30197 I 5 • OP171 D6/30/97 : S • OP205 07130197

: 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