..;

-**'~:**...

.- ,-t- " • .....-..

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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.horIza'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, weconsidered the following factors: total time required to complete each alternative, impact on other programfunctions (inspections, plan reviews, technical assistance, preparation oflegislative 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, wefeel most significant hazardous wastes in Oregon are being controlled. Fbr the limited resources available, webelieve thatmore 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. AsOregon'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 nowandJuly 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 ofpublic interest (see Appendix Ato 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, wehave 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. Somefundamental 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 wewould 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) wewould also try to deal with any knownPhase II deficiencies during the 1981 Legislative session.

# •

• Following legislative approval, wewould 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 throughJune 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 knowntoday, only one additional position (an environmental analyst) is proposed to be added to the resources identified in Section Bof the ProgramDescription.
The reasons webelieve 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 wealready 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 

# DepartmentofEnvironmentalQuality 522 S.W.5thAVENUE, BOX 1760, PORTLAND, OREGON97207 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 contactValerie 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 RunProgram 

# •

I would like to participate on a Taek Force to advise the DEQ and the Legislature about whoshould 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, SIGNMEUP
. 

### /1 

### /1 

### /1 /1 /1

NAME: I amwilling 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. Needto 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 IMPLEMENTINGAUTHORITY RCRA SECTION 3002: 

### STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE FEDERAL RULE (40 

### CFRPart 262) 

### NEEDED LEGISLATIVE.AUTHORITY
. Bl


### NEEDED ADMINISTRATIVEAUTHORITY 262.10 262.21 262.23 262.32 262.34 262.40

262.41 

### Needpenalties 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 

### CFRPart 263) NEEDED LEGISLATIVEAUTHORITY NEEDED ADMINISTRATIVEAUTHORITY , 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 L10CFRPart 265) NEEDED LEGISLATIVE AUTHORITY NEEDED ADMINISTRATIVEAUTHORITY 265.1 265.12 265.13 265.14 265.15
265.16 265.17

265.30

- .49
265.50

- .60 

# It f\J ZA100(1) None None None None None
None None

None
None



### Chart 1 Needto 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 LEGALAND IMPLEMENTING AUTHORITY RCRA SECTION 3004: INTERIM STATUS STANDARDS FOROWNERS AND OPERATORS OF HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITIES 

# •
D2
FEDERAL RULE (40CFR 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 ofmanifest 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 IAUTHORIZATIOIl PLAII F I
l;



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.r:. GI
...

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### a



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# J I 

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. V .",.r:.


## ... I:
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# .... > '" 

## ... .", .- GJ C 0


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### .... woo..


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## 'Sa, le9lsI January February /1arch April lature session If they are promul

### 6"' '-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.' STATEOF ORH;QN DEPAR'lMENTOFENVIRONMENTAL QUALITY' 

# • TO: FROM: Ernie Schmidt, Richard Reite INTEROFFICEMmO 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, .Althoughwe havenlt; needed. this authority to date, there have been a couple of near misses (i.e. CaronChemical and Energy Alternatives, Tualatin). In myopinion, lack of a civil penalty schedule is the major program deficiency, EPA concerns notwithstanding. Since a civil penalty schedule adopted nowwould likely not change due to any outside influence such as EPA rulemaking, efforts expended nowwould 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 ofNotice


# .• 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 VanKoilias Gayia Reese Ray Underwood Al Goodman, EPA-OOOv 

### " o
\..-- U 

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# •

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s31nlj ;0 31eo**3A!1;):>;}~,~~L----- "O!le!!J04~nv**  W!J;))UI I ;)se4d**aA!a~:>1j** > a\.

VICTORATIYEH COvFRNOR



## • 

# DepartmentofEnvironmental 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 InterimAuthorization 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 SolidWaste Division FSB:h ZHD66 (1) (0) Enclosure(s) P.S.: Because of this**~etter's** wide distribution, wehave also taken the opportunity to enclose a Public Notice of some civil penalty rules we propose to adopt more immediately. Your comments are invited.

# • Distribute Generator Rules o III 

### " ,T£,S-lst Meeting o lb n Disposal

- 1st Meeting <:> III o 

### '" L Pub!ic v>

# 1 '" 1f--Trans - A&W III 

# .. III Hearings 'tJ '0 Meeting



## - \.D 

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# - 

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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 ofEnvironmental 

# 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 SixthAvenue Seattle, WA 98101 Re: InterimAuthorizatipnHazardous 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: KenFeigner, Chief, Air/Hazardous Materials Dave Hanline, Program Development Sectionz 0 \1> \1> \.!> -< CO CO CO I'Tl '- :- '- "'" '- N 

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### S. E N V IRONMENTAL PROTEeTION AGEN C Y REGION X 1200 SIXTH AVENUE SEATTlE, WASHINGTON 98101**~~~**

## J?: MIS 530 

### NOV13 1981 

### WilliamH. Young, Director Oregon DepartmentofEnvironmental Quality P.O. Box 1760**port1an~,** 

### yOr1Pon 97207 Dear

## MC~: We have reviewed your proposed hazardous waste ru1emaking schedule, whichyoudiscussed in your letterofOctober 21, 1981. Since our
,targetdate for issuing final PhaseII regulations is now fall of 1983,

your schedule should allowyou to develop anapplication for final authorizationwell before the endofthe interimauthorization period. With the currentuncertainty overwhen final Phase II regulations will be announced, your proposed schedule'for rule revisionwill be anacceptable replacement to the oneincluded in your Phase I application
. Inconsideringyour schedule for developing rules, you should keep in mind the requirement of40CFR 123.122thatyou amendyour Phase I submission, within sixmonths of the effective date of the last PhaseII component, to include all Phase II components. Our recent discussions with your staffsuggest that rule changesmay not benecessary in order foryou to apply for PhaseII authori

### zatfon. If 

### it is determined that rule changesare needed, these changeswill have to be completedprior to the above date, estimated at this time to befall of 1984. You would ofcourse, have the option of applying for final authorization without the intermediate step ofPhase II interimauthorization. Under this scenarioyouwould have to haveall rule changes completed before the samedate, i.e., fall 1984.
John\R. Spencer**Reg;~nal** 

### Administrator cc: RichardReiter, Oregon Department ofEnvironmental Quality

iN ,,1, !III 

## L'::'J State of Oregon DEPARTMENT OF ENVIRONMENTAL QUALITY 

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## 1g1981 

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### PIRECTOR