VICTORATIYEH COVI!'RNOR



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# ---- DepartmentofEnvironmental Qua/tty
522 SOUTHWEST5TH AVE. PORTLAND. OREGON MAILING ADDRESS: P.O. BOX 1760. ?ORTLAND. OREGON 97207

June

### 24, 1980
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• Donald P. Dubois, Regional Administrator EPA

- Region 10 1200 SixthAvenue Seattle, WA 98101
Re: BW 1.21 InterimAuthorization

STATEMENT OF INTDlT .In response to your letter ofMay 14, 1980, and SubpartF of 40 CFR Part 123 (Consolidated Permit Regulations) promulgatedMay 19, 1980, I hereby declare Oregon's intent to apply for Phase 1 InterimAuthorization, phase 2 InterimAuthorization, and Final Authorization to implement a state hazardous waste management program in lieu of a federal program. Should. you determine that the programs described in our phase 1 and Phase 2 applications are not "substantially equivalent" to the promulgated federal program, wewould expect to use the information in those documents to develop a "cooperative agreement- during the annual State-EPA Agreement (SEA) process. In either case (Phase I InterimAuthorization or cooperative agreement), for federal fiscal year 1981 wewould expect to need all of the estimated project grant monies ($395,000) for administration of a state-federal hazardous waste program. (Under a cooperative agreementwe would expect to administer all of our existing state program and any of the federal programyou would be capable'of delegating). Since we are currently working on our SEA application, I would appreciate knowing as soon as possible ifyou can assure us of these monies. BRIEF DESCRIPTION OF EXISTING STATE PROGRAM For the types of hazardous waste generated in Oregon, particularly, and the PacificNorthwest generally, we believe wecurrently have a program capable ofmeeting your "SUbstantially equivalent" Phase I Interim Authorization requirements. We currently have state statutory and administrative authority to:



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• Donald P. Dubois, Regional Administrator page 2 June 19, 1980


### 1. Register and inspect generators. 2. Register and inspect**transporters~** 3. License (permit) off-site storage (collection) sites, off-site treatment sites, and disposal sites. 4. Inspect on and off-site storage (collection) sites, on and off-site treatment sites, and disposal sites. 5. Take enforcement action against generators, transporters, and operators ofmanagement facilities. 6. Require use of a manifest for intra-state shipments of hazardous waste. 

### 7. Require reports from generators and operators of**manage~ent** facilities. 8 • Require liability insurance of all operators ofmanagement facilities. 9. Require closure and postclosure financial requirements for operators of disposal sites. Any identified statutory deficiencies will be scheduled for correction during the next legislative session scheduled to convene in January, .1981. Any identified administrative deficiencies can generally be corrected**~ithin** 180 days, if necessary, while still providing an opportunity for pUblic participation. Ifpossible, however, wewould like to consolidate all required administrative changes into a single hearing following the 1981 legislative session (therefore, sometime after July 1, 1981.) Enclosed for your use are copies of Oregon Revised statutes, Chapter 459 and 767 and Oregon Administrative Rules, Chapter 340-62 and 63, and Chapter 860-36. We have already begun a detailed part-by-part analysis of federal rules promulgated February 26 and May 19,1980, and expect to begin submitting draft copies for your preliminary review in the next two to three weeks (Part 262 and 263 nearly complete: Part 261 and 264 scheduled next).**OR~~IZAT!ONAL** STRUCTURES See Charts 1 and 2 attached for organizational structures for the Department ofEnvironmental Quality and public Utility Commissioner as it relates to the state's hazardous waste program. PHASE 1 INTERIM AUTHORIZATION APPLICATION SCHEDULE July 2, 1980 August 1, 1980 September 16, 1980 Letter of Intent Draft Interim Authorization Application Complete Interim Authorization Application The above dates represent final completion dates for the activities described. Following receipt of your interim authorization "guidance document," weexpect to work on all sections of the application simultaneously and submit drafts of completed portions to your State



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• Donald P. Dubois, Regional**A~~inistrator** Page 3 June 19, 1980 Delegation Coordinator as we develop them.**~~en** you have designated a state delegation coordinator, please let us know immediately.) Our prime contact person and person responsible for meeting the above schedule is: Richard Reiter, Supervisor Hazardous Waste Section area code 503**229-6~34.** If there are any questions regarding the above matters, please feel free to contact this office or Richar4 Reiter. Sincerely,

# tJ~**;.{~~** WilliamH. youn{J 

# I Director RR:bn PBD157 Enclosures cc: KenFeigner, ChiefAir and Hazardous Materials Ranch John Vlastelicia

- Oregon Operations Office LErnie..s..chmidt/Rich Reiter.

Ray Underwood, Dept. ofJustice Harold Sawyer, Administrator, Water QualityDivision .E. JackWeathersbee, Administrator, Air Quality Division Fred Bolton, Administrator, Regional Operations paul Henry, Public Utility Commissioner DonGodard, Dept. of Energy PatAmedeo, Governor's Office

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# • DEPAR'n°iENT OF**~·VIRONL~I':;'.L** QUALITY

Governor I Victor Atiyeh I

Environ.'nental**Quali~** Commission

. . Joe B• Richards, Chairman ". " "

DEQ William H. Young, Director 

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Manage- Laboratory Regional Solid \<Jaste Air Water ment;: Division Opera- Division Quality Quality Services tions , Division Division Ernest. A. 

# I Division Division Schmidt,Adr.linistrator

Hazardous Waste Section Richard po, Reiter \ Supervisor 

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-' Chart 1

# • PUBLICUTILITY COMMISSIONER

Governor Victor 

### Atiyah

Public 

### Utility**Cqr.missione~**


## .. John J. 

### Lobdell

rative ::>ervices Consumer Assistance and**~eatherization** 

### Programs 

# IProceed;ngs 

### Motor ?rogram Don 

### Haakenson Assistant Cczmi

### s si

### oner j 

### Rail-Air-Marine 

# I**Progr~r:t**

## ~tility ;,rogram



# • Investigations OJ

### visi

### on Paul-Henry, 

### Division Administrator



# LS Chart 2