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; ..-
•

PHASE I AUTHORIZATION PLAN

In developing this authorization plan, several alternative schedules were

considered:

1. ]mmediate adoption of temporary rule changes to correct most

significant deficiencies (ORS 183.335) (5)~ conversion of

temporary rules to permanent rules within 180 days (ORS

183.335) (6); Legislative changes to correct statutory

deficiencies~ and a final set of administrative rule changes

prior to applying for Phase II and/or final aut.hor Iza'tLonr - -

2. ]mmediately entering into normal administrative rule change

process to correct all Phase I administrative deficiencies;

Legislative changes to correct statutory deficiencies; final

set of administrative rule changes prior to applying for Phase

• 3.

II and/or final authorization•

No immediate administrative rule changes; Legislative changes

to correct statutory deficiencies; administrative changes to

correct rule deficiencies prior to applying for Phase II and/or

final authorization.

In deciding which alternative to pursue, we considered the following

factors: total time required to complete each alternative, impact on other

program functions (inspections, plan reviews, technical assistance,

preparation of legislative package, etc.), public health and/or

environmental significance of known administrative deficiencies, impact

on rule making public participation program.

In selecting alternative_three, we concluded the following:

(p, I
•

•

1. In our jUdgment, none of the administrative deficiencies are

so significant as to require immediate rule change. Based on

almost ten years of experience in trying to manage hazardous

waste in Oregon, four years of overseeing a licensed disposal

site and the recent registering of generators and transporters,

we feel most significant hazardous wastes in Oregon are being

controlled. Fbr the limited resources available, we believe

that more benefit would come from continued technical assistance

. to. the regulated community or additional field work to verify

compliance with our existing programs than from spending time

modifying our existing program to impact people already partially

covered. While implementing our program, we can seek voluntary

compliance with the federal program, note probable compliance/noncompliance with the federal program, and develop a data base

to facilitate implementing our fully equivalent program.

2. Adoption of temporary rules while legally possible is a very

cumbersome and time consuming process. While possible to

accomplish at any regularly scheduled EQC meeting (third Friday

of each month), or at a specially convened EQC meeting, it does

require readoption as a permanent rule within 180 days. Two

staff reports need to be prepared (temporary rule and permanent

rule) and a shortened pUblic participation program occurs.

•

' ...-

3. As Oregon's legislature meets only every other year, this

upcomming session (January 1981) becomes very important in terms

of statutory changes for compliance with Phase I (and maybe Phase

II) regulations. Adopting temporary and permanent rules within
•

•

the next 180 days would coincide with preparing for and dealing

with the 1981 legislature. Since this session is critical, we

would prefer to fully concentrate our limited time on securing

the needed statutory changes between now and July 1, 1981.

4. Since hazardous waste is a fairly recent regulatory program,

public participation in rule making has been an essential

element. Further', since hazardous waste issues can be very

emotional, we have been particularly sensitive to allow adequate

~ime'for the public to be invo1~ed in the rule making process.

For our most recent hazardous waste rules (licensing of treatment

sites) eight months elapsed from the initial draft through final

rule adoption. Because this next set of statutory and

administrative rule changes is so important to maintaining the

state's initative in the hazardous waste program, a very

deliberate program, including the appointment of several task

forces, has been scheduled. The first step towards that process

was taken on August 1, 1980, with a 'solicitation of public

interest (see Appendix A to this part).

In summary, it is our judgment that immediate rule changes are not

essential to demonstrate that we cover a "substantially equivalent"

universe of generators, transporters and management facilities. The next

key to Oregon's maintaining its initative in the hazardous waste field

is to secure from the 1981 Legislature necessary statutory changes to allow

us to develop a fully equivalent and consistent program. Considering past

legislative action in this regard, we have every reason to believe the

legislature will continue their support of our efforts. Attention should

fo,3
•

•

not be drawn away from this essential effort, however, to make temporary

fixes to existing rules. Following legislative change, we anticipate

needing a year and a half to fully involve the public in amending the

administrative rules. Some fundamental decisions on format (i.e.,

codifying EPA rules as Oregon rules, simply adopting EPA's rules by

reference, maintaining those existing Oregon rules that are more

restrictive, adopting EPA's approach to recyclable waste, etc.) lie ahead

of Oregon and it would be unfortunate, considering the support we've

enjoyed to date, to shortchange the public parti~ipa~ion process. To

the degree that we draw adverse attention to the handling of hazardous

waste rule making procedures, we may also affect the current support for

the overall hazardous waste program. We believe one reason for the

program's general public support to date has been the deliberate pace we

have established to bring the program into being. Considering it took

EPA almost four years to promulgate only part of their program, allowing

Oregon sufficient time to correct minor deficiencies in a logical sequence

does not seem unreasonable.

Depicted in Chart 1 are the identified statutory (DRS) and administrative

(OAR) rule changes needed. Depicted in Chart 2 is a schedule that. suggests

that we would first concentrate our efforts on correcting statutory

deficiencies during the 1981 Legislative session (January - June 1981).

Hi?torically, DEQ's legislation has been considered and adopted late in

the legislative session. Furthermore, to the degree they're promulgated

in time (i.e. October - November 1980) we would also try to deal with

any known Phase II deficiencies during the 1981 Legislative session.
•

•

Following legislative approval, we would use the period from July 1981

to December 1982 to fully involve the pUblic in amending rule deficiencies

for Phase I. Again to the degree we could address Phase II administrative

issues at the same time we would propose to do that.

In developing its budget for state fiscal years 1981-82 (July 1, 1981

through June 30, 1983), DEQ assumed that the necessary statutory and

administrative changes were, or will be, made to allow final authorization

. . . .

to be attained. Based on program implementation requirements as they are

known today, only one additional position (an environmental analyst) is

proposed to be added to the resources identified in Section B of the

Program Description.

The reasons we believe that level of commitment is reasonable are:

1. We expect few, if any, additional disposal sites to be licensed

because of the statutory requirement for State ownership of the land.

Further, the existing hazardous waste disposal site has an expected

life of 40 years even at a doubling of the current use.

2. We expect few, if any, additional off-site treatment facilities to

be on line in the next few years due to the capacity in the existing

licensed facilities. Further, we are aware of only a few on-site

treatment facilities.

3. It is very difficult to predict at this time how many generators will

store waste for longer than 90 days, thereby requiring a license.
•

4.

As for off-site facilities, we hope to have some 10-15 licensed by

1983 to handle small quantities of hazardous waste from households

and small business.

The major 'effort to identify non-notifiers (i.e., generators,

transporters, or management facilities) should be completed within

the next year thereby allowing resources to be reassigned to license

drafting, compliance monitoring, complaint investigation, enforcement,

and emergency spill response.

•

5. A number of existing industrial treatment facilities, surface

impoundments, land treatment facilities and incinerators are already

licensed (permitted) by other DEQ programs thereby simplifying the

permit reissuance process (considering the, knowledge we already have

of these facilities.

The additional position to be added is schepuled to be funded by license

fees and will cost approximately $31,000 per year.

ZAD73 (1)
Appendix A

Phase I ~Interim Authorization t

Department of Environmental Quality

522 S.W. 5th AVENUE, BOX 1760, PORTLAND, OREGON 97207 PHONE (503) 229- 5913

August 21, 1980

TO: Hazardous Waste Advisors

RE: Public Participation Opportunities in the Solid waste Management Program

Dear Sirs/MInes:

We have appreciated your past 'assistance in the development and review of

waste Rules. We are presently updating the Solid Waste Division's Public

Process, and would like to update our mailing list as well.

Hazardous

Participation

Please indicate on the enclosed lists which tasks you would like to be ·involved in

(you needn't confine yourself to Hazardous Waste), and where we should direct our

mailings. Please return as·soon as possible, preferably within the next two weeks,

as .many of the activities will begin shortly thereafter (including prioritization of

an~ Objectives, the Legislative Task Force, the Education Task Force, the Data

se Task Force, and the Task Force to advise the DEQ and the Legislature regarding

responsibility for the Hazardous Waste Program).

If you h~ve any questions, or would like to know more about any of the activities,

please contact Valerie Lee, our Public Affairs Officer, at 229-6044 (call toll-free

1-800-452-7813) .

I look forward to working with you to carry Oregon's waste management efforts forward

over the coming year.

Sincerely,

Ernest

~~A. SChmidt, Administrator

Solid Waste Division

PLEASE RETURN ENCLOSED SIGN-UP SHEETS OR CALL US BY SEPTEMBER 4

I.
e

HAZARDOUS WASTE

Who will run the 1.

Program in Oregon?

Pesticide 2.

Container Disposal

Licensing 3.

Facilities

Public Hearings on 4.

State Authorization

to Run Program

•

I would like to participate on a Taek Force to advise the DEQ and the Legislature about who should

run the Hazardous Waste Program in Oregon, the State or .the Federal Government.· '

If the State dec~des to continue to run the Program, and makes the necessary changes in State Law so

that Oregon qualifies to do so, I would like to advise the DEQ and the EQC in the development of the

rules necessary to administer the program.

I would like to review proposed rules governing disposal of pesticide containers.

I would like to receive notice of application for licensing hazardous waste treatment, storage,

collection and disposal facilities.

I would like to receive notice of EPA's hearings regarding Oregon's application ~or authorization

(interim and/or final) to run the Hazardous Waste Program. The outcome will determine whether

State regUlations or Federal regulations will govern the program.

••

YES, SIGN ME UP .

/1

/1

/1

/1

/1

NAME: I am willing to attend meetings L.I

(in Portland)

1\DDRESS:

6" I would like to review drafts by L.I

TELEPIIONEI mall

1\FFILI1\TIONI

j

-n

SF52(2)

.I!a~ . '

" ", \1tc..... • -3- '

LJ
• • •

PHASE I AUTHORIZATION PLAN

NEEDED LEGAL AND IMPLEMENTING AUTHORITY

RCRA SECTION 3001: IDENTIFICATION AND LISTING OF HAZARDOUS WASTE

A1

FEDERAL RULE

(40 CFR Part 261) NEEDED LEGISLATIVE AUTHORITY , NEEDED ADMINISTRATIVE AUTHORITY ,

261.5

261.10

261.11

261. 20

261. 24

261. 31

261. 32

261. 33

,~

ZA100 (1)

None

None

None

None

None

None

None

None

Chart 1

Nee~ to reduce small quantity exemption

for wastes listed in 261.33.

May ,want to adopt criteria statement.

May want to adopt criteria statement.

Need to adopt hazardous waste numbers.

Need to adopt leach test rule.

Present coverage incomplete - need to

adopt list.

Present coverage incomplete - need to

adopt list.

Present coverage incomplete - need to

adopt list.
PHASE I

•

AUTHORIZATION PLAN

• •

NEEDED LEGAL AND IMPLEMENTING AUTHORITY

RCRA SECTION 3002: STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE

FEDERAL RULE

(40 CFR Part 262) NEEDED LEGISLATIVE.AUTHORITY .

Bl

NEEDED ADMINISTRATIVE AUTHORITY

262.10

262.21

262.23

262.32

262.34

262.40

262.41

Need penalties of $25,OOO/day as specified

in RCRA Section 3008.

None

None

None

Need statutes to license generator storage

and treatment facilities.

None

None

Need to address international shipments.

Need :to add certification to manifest.

Need rules for rail and water shipment.

Need: to modify container labeling

requirements.

Need to reduce unlicensed storage time

to 90 days.

Need·to require generator to keep waste

analysis records and to extend retention

time ~in the event of unresolved

enforcement action.

Need to modify generator report to

include DOT hazard class and hazardous

waste number.

262.42 None

262.43 None

262.50 None

,~ Chart 1

ZA100(1)

Need· 35 and 45 day action deadline.

Need additional reporting requirement.

Need rules for international shipments.
\-

PHASE I AUTHORIZATION PLAN

• •

NEEDED LEGAL AND IMPLEMENTING AUTHORITY

RCRA SECTION 3003: STANDARDS APPLICABLE TO TRANSPORTERS OF HAZARDOUS WASTE

Cl

FEDERAL RULE

(40 CFR Part 263) NEEDED LEGISLATIVE AUTHORITY NEEDED ADMINISTRATIVE AUTHORITY ,

263.10

263.20

263.22

263.30

263.31

6"

:::::.

ZAIOO(l)

Need to remove exemption for pUblic vehicles and

those under 8000 lbs.

None

None

None

None

Chart 1

May need specific applicability rule.

Need to reduce small quantity exemptionfor wastes listed in 261.33. Need rules

for rail and water shipments and for

international shipments.

Need rules for rail and water shipments

and for international shipments. Need

rules' to extend manifest retention time

in tne event of unresolved enforcement

action.

Need. rule for emergency transportation.

Need rule for water shipments.

Need. specific action rules.
i.

PHASE I AUTHORIZATION PLAN

• •

NEEDED LEGAL AND IMPLEMENTING AUTHORITY

RCRA SECTION 3004: INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE TREATMENT,

STORAGE, AND DISPOSAL FACILITIES

Dl

FEDERAL RULE

L10CFR Part 265) NEEDED LEGISLATIVE AUTHORITY NEEDED ADMINISTRATIVE AUTHORITY

265.1

265.12

265.13

265.14

265.15

265.16

265.17

265.30 - .49

265.50 - .60

Itf\J

ZA100 (1)

None

None

None

None

None

None

None

None

None

Chart 1

Need to remove generator exemption.

May need rules for foreign shipments.

May need rules for general waste

analysis. Presently in site license.

May need rules for security. presently

in site license and facility plans.

May need rules for inspections.

Presently in site license and management

plan.

May need rules for personnel training.

Pres~ntly in site management plan.

May need rules for special waste

handling. Presently in site license,

facility and management plans, and

disposal request approvals.

May'need rules for preparedness and

prevention. presently in site license

and facility and management plan.

May need rules for contingency planning

and emergency procedures. Presently in

site .license and management plan.
'. •

PHASE-I AUTHORIZATION PLAN

NEEDED LEGAL AND IMPLEMENTING AUTHORITY

RCRA SECTION 3004: INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE TREATMENT,

STORAGE, AND DISPOSAL FACILITIES

•

D2

FEDERAL RULE

(40 CFR Part 265)

265.70 - .77

265.90 - .109

265.110 - .139

265.140 - .169

265.190 - .219

265.220 - .249

265.250 - .269

\~ZA100 (1)

NEEDED LEGISLATIVE AUTHORITY

None

None

None

Need statutes to require collection and treatment

sites to provide for closure costs.

None

None

None

Chart 1

NEEDED ADMINISTRATIVE AUTHORITY

Need to reduce small quantity exemption

for wastes listed in 261.33. Also may

need rules for rail and water shipments,

handling of manifest discrepancies, and

recordkeeping and reporting procedures

that are presently in site license and

management plan.

May need rules for groundwater

monitoring. Presently in site license

and management plan.

May need rules for closure and

postclosure requirements. Presently in

site license and facility plans.

May oeed rules for tank requirements.

presently in site facility and

management plans.

May need rules for surface impoundment

requirements. presently in site

faciiity and management plans.

May need rules for waste pile

management. presently in site facility

and management plans and disposal

requ~st approvals
'- •

PHASE I AUTHORIZATION PLAN

NEEDED LEGAL AND IMPLEMENTING AUTHORITY

RCRA SECTION 3004: INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE TREATMENT,

STORAGE, AND DISPOSAL FACILITIES

•

D3

FEDERAL RULE

(40 CFR Part 265) NEEDED LEGISLATIVE AUTHORITY NEEDED ADMINISTRATIVE AUTHORITY

265.270 - .299

265.300 - .3~9

265.340 - .369

265.370 - .399

265.400 - .429

,~

""'

ZA100(1)

None

None

None

None

None

Chart 1

May need rules for land treatment.

presently in site facility and

management plans.

May need rules for landfills. presently

in site license, facility and management

plans, and disposal request approvals.

May need rules for incinerators.

presently may be put in site license and

facility and management plans.

May need rules for thermal treatment.

presently may be put in site license and

facility and management plans.

May need rules for chemical, physical

and biological treatment. Presently in

site facility and management plans and

disposal request approvals.
PHASE I

-

AUTHORIZATION PLAN

NEEDED LEGAL AND IMPLEMENTING AUTHORITY

OTHER RCRA PROGRAM REQUIREMENTS

• e

El

FEDERAL RULE

(40 CFR Part 123) NEEDED LEGISLATIVE AUTHORITY NEEDED ADMINISTRATIVE AUTHORITY

123.8

123.9

123.10

\~

ZAIOO (1)

Need statute giving power of entry similar to

ORS 459.285.

Need statutes raising civil and criminal penalties

to $lO,OOO/day.

Need to modify confidentiality statutes to permit

sharing of information with EPA.

Chart 1

•
~i'~""" '. • •

PHASE I AUTHORIZATIOIl PLAII F I

l;

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.r:. GI ... ... :l

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7!'p r II Hay June ~uly August September October Ilovember Dec. I:

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'- 0 ... a:: ... VI

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LEGAL AND IHPLEHENT !tIG AUTHOR ITV

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Dec.

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V .",.r:. ... I: ...

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.... woo.. Note: Because of a biennial legislature, ........0 I any Phase II deficiencies requlrIng additional statutory authority can only be enacted during tile 'Sa, le9lsI January February /1arch April lature session If they are promul6"' '-lay gated prior to Aprl' 1981. Any ,

"" promulgations after that ~ate wl'I

- co have to be presented to the '983 6" A 711'~.. legislature.

Chart 2
.'

STATE OF ORH;QN

DEPAR'lMENT OF ENVIRONMENTAL QUALITY'

• TO:

FROM:

Ernie Schmidt,

Richard Reite

INTEROFFICE MmO

August 31, 1981

SUBJECT: Hazardous Waste Management Schedule of Civil Penalties

With the passage of SB146, plans to upgrade our rules are being formulated.

The plan submitted with our Phase I Interim Authorization application

outlined a rulemaking process that would be completed December 1982. A

major goal of mine has been to avoid multiple rulemaking steps.

With one exception that is still my goal. The exception relates to a·civil

penalty schedule for violation of hazardous waste statutes, rules, EQC

orders or. license condd.td.ons , . Although we haven l t; needed. this authority to

date, there have been a couple of near misses (i.e. Caron Chemical and

Energy Alternatives, Tualatin). In my opinion, lack of a civil penalty

schedule is the major program deficiency, EPA concerns notwithstanding.

Since a civil penalty schedule adopted now would likely not change due to

any outside influence such as EPA rulemaking, efforts expended now would

not be duplicated at a later date.

October 9, 1981 -- Request for Authorization to hold public hearing

If you agree that early rulemaking is appropriate, I would propose the

following schedule:

•

September 11, 1981

September 18, 1981

October 20, 1981

November 1, 1981

EQC agenda item proposed

EQC staff report due

Submission of Notice to Secretary of State

Publication of Notice

.•

December 1-4, 1981 -- Public Hearing(s)

December 11, 1981 -- EQC Staff Report Due

January 8, 1981 -- EQC Hearing for adoption

Since civil penalty authorities are administered by Regional Operations, I

further suggest that Fred Bromfeld and Van Kollias coordinate preparation

of reports, Department of Justice reviews and scheduling of hearings.

Gayla Reese should be responsible for public notices activities.

with your concurrence, Fred and Van should proceed immediately.

RPR:h

ZH800 {I)

cc: Fred Bromfeld

Van Koilias

Gayia Reese

Ray Underwood

Al Goodman, EPA-OOO
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VICTOR ATIYEH COvFRNOR

•

Department of Environmental Quality

522 SOUTHWEST 5TH AVE. PORTLhND, OREGON

MAILING ADDRESS: P.O. BOX 1760. PORTLAND, OREGON 97207

October 19, 1981

•

Dear Messrs./Mesdames:

In an open letter dated August 3, 1981, we announced that the Department of

Environmental Quality had been. granted Interim Authorization by the U.S. Envi~onmental Protection Agency to manage hazardous waste in Oregon.· A

significant result of this action was that ·DEQ rules for generators,

transporters, treaters, storers, and"disposers remain enforceable in lieu

of the federal rules.

However, as part of the Interim Authorization requirements, DEQ agreed to

amend its hazardous waste rules to be fully equivalent to and consistent

with the federal program; i.e., to become eligible for full Authorization.

This is to be done through a public rulemaking process which is expected to

take 36 months.

The purpose of this letter is to initiate that process. Enclosed.please

find a proposed rulemaking schedule and an inquiry concerning your desire

to participate.

We need your input in the formulation of these rules. As they are rather

complex, it is proposed to draft them in stages. We foresee at least eight

rule packages: Generators, Permit Issuance, Transportation - Air and

Water, Transportation - Hotor Vehicle and Rail (t9 be drafted by Public Uti~ity Commissioner), Treatment and Storage Sites, Hazardous Waste

Classification, Disposal Sites, and, at the end, the total set of rules.

You may comment on a single or as many packages as you desire.

Simply indicate your preference on the enclosed form and mail as indicated

thereon.

The first package, Generators, is scheduled for distribution about December 1st.

An indication of your interest by that date would be greatly appreciated.

Richard P. Reiter, Supervisor

Hazardous Waste Section

Solid Waste Division

FSB:h

ZHD66 (1) (0)

Enclosure (s)

P.S.: Because of this ~etter's wide distribution, we have also taken the

opportunity to enclose a Public Notice of some civil penalty rules we

propose to adopt more immediately. Your comments are invited.
•

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TO: Fred Bromfeld

Hazardous Waste Section

DEQ

Box 1760

portland, OR 97207

(503) 229-6210

DATE:

FROM: NAME

---------------------------------- ADDRESS

PHONE NO.

(Please enclose a business card if possible)

REPRESENTING -----~---,---,.------:---~-:-:----:------

I wish to receive the following rules packages for comment:

L--/ Generators

:.

L--/ Permit Issuance

L--/ Transport9tion Air and Water

L--/ Treatment and Storage Sites

L--/ Hazardous Waste Classification

L--/ Disposal sites

L--/ Transporters - Motor Vehicle and Rail (To

be drafted by Public Utility Commissioner)

I will probably comment by:

L/ Phone

L/ Letter

/ / Attending the public meetings (At DEQ Portland office except

for Transportation - Motor Vehicle and Rail which will be held

at PUC Salem office) .

I have the following additional comments to make:

ZEI00 (10/19/81)
Department of Environmental Quality

522 SOUTHWEST 5TH AVE. PORTLAND, OREGON

MAILING ADDRESS: P.O. BOX 1760, PORTLAND, OREGON 97207

•

•

October 21, 1981

John Spencer, Regional Administrator

EPA Region 10

1200 Sixth Avenue

Seattle, WA 98101

Re: Interim AuthorizatipnHazardous Waste Program

Dear Mr. Spencer:

Enclosed, please find a revised schedule for amending our rules prior to

applying for final Authorization. You will note a greater delineation

of tasks than is presented on page 6.16 of our Interim Authorization

application and an ordering of those tasks in the sequence in which we

believe the federal rules will be finalized. The delay in our schedule

reflects the presumed delay in the corresponding federal rules schedule.

Also, as a result of this delay, it is quite possible that we may apply

for Phase 2 Interim Authorization rather than wait for final Authorization.

We will know more when the final Phase 2 Guidance Document becomes

available.

Sincerely,

William H. Young

Director

FSB:k

ZKD244 (2)

Enclosure

cc: Ken Feigner, Chief, Air/Hazardous Materials

Dave Hanline, Program Development Section
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u. S. E N V I RON MEN TAL PRO TEe T ION AGE N C Y

REGION X

1200 SIXTH AVENUE

SEATTlE, WASHINGTON 98101

~~~ J?: MIS 530

NOV 13 1981

William H. Young, Director

Oregon Department of Environmental Quality

P.O. Box 1760

port1an~, yOr1Pon 97207

Dear MC~:

We have reviewed your proposed hazardous waste ru1emaking schedule,

which you discussed in your letter of October 21, 1981. Since our , target date for issuing final Phase II regulations is now fall of 1983,

your schedule should allow you to develop an application for final

authorization well before the end of the interim authorization period.

With the current uncertainty over when final Phase II regulations will

be announced, your proposed schedule' for rule revision will be an acceptable

replacement to the one included in your Phase I application .

In considering your schedule for developing rules, you should keep in

mind the requirement of 40 CFR 123.122 that you amend your Phase I

submission, within six months of the effective date of the last Phase II

component, to include all Phase II components. Our recent discussions

with your staff suggest that rule changes may not be necessary in order

for you to apply for Phase II authori zatfon. If it is determined that

rule changes are needed, these changes will have to be completed prior

to the above date, estimated at this time to be fall of 1984.

You would of course, have the option of applying for final authorization

without the intermediate step of Phase II interim authorization. Under

this scenario you would have to have all rule changes completed before

the same date, i.e., fall 1984.

John\R. Spencer

Reg;~nal Administrator

cc: Richard Reiter, Oregon Department of Environmental Quality

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State of Oregon

DEPARTMENT OF ENVIRONMENTAL QUALITY

[ffi ~@~O W [ID

NOV 1g 1981

oraca Of IHE PIRECTOR