Attendees Symposium Packet
A POSITIVE FUTURE:
HAZARDOUS HASTE MANAGEMENT
IN THE
PACIFIC NORTHWEST
OCTOBER 19-21, 198)
SEATTLE SHERATON HOTEL
Presented By
U,S, Environmental Protection Agency
and
The States of Alaska, Idaho, Oregon, and Washington
Cooperator: Institute for Environmental Studies
University of Washington
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SYMPOSIUM ATTENDEE PACKET
TABLE OF CONTENTS
SECTION TITLE
i. WELCOME
11. INTRODUCTION
A. AGENDA
B. SYMPOSIUM WHITE PAPER
C. DATA/CAPACITY, WASTE REDUCTION AND SITING EFFORTS:
State Program Highlights
D. HAZARDOUS WASTE MANAGEMENT IN THE NORTHWEST:
A Status Report (Executive Summary)
E. WASTE REDUCTION: An Issue Paper
F. SUMMARY OF EVALUATION FORMS, APRIL 28-29 1987
G. REGIONAL STEERING COMMITTEE BIOGRAPHIES
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* ~ \
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 SIXTH AVENUE
SEATTLE. WASHINGTON 98101
o S October 9, 1987
REPLY TO
Dear Attendee:
We are pleased that you are attending our Second Symposium on Hazardous
Waste Management sponsored by EPA, Region 10 and the states of Alaska, Idaho,
Oregon, and Washington. This symposium—A Positive Future: Hazardous Waste
Management in the Pacific Northwest—will be an important event.
At the first symposium this past April, we heard from national and
regional leaders about the current issues and trends in hazardous waste
management. Since then, we have been analyzing this information and looking
closely at the Pacific Northwest's situation. The second symposium is
designed to focus the attention of key leaders such as yourself on the Pacific
Northwest's data, waste reduction, and siting efforts. Regional and national
speakers from industry, government, and public interest groups will share
their views on the status of the region's hazardous waste management system
and future options to improve it.
There is specific time on the agenda for all attendees to comment on
these recommendations and present their views. We will use this input to help
us prepare a final report for the Governors and Legislatures of our four
states, and the Administrator of EPA, Lee M. Thomas, who is going to be the
keynote speaker on October 19.
We appreciate your efforts in helping make comprehensive hazardous waste
management for the^acific Northwest an achievable goal.
i Sincerely,
Rob|ie G. Russell Fred Hansen
Regional Administrator Director, Oregon DEQ
Co-Chairman Co-Chairman
Enclosure
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11
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INTRODUCTION
This symposium packet includes materials which will help frame the
conference hazardous waste management issues for attendees, and stimulate
thinking about possible future directions for the Pacific Northwest. EPA
Region 10 and the four states look forward to the observations and
recommendations which will came out of the symposium. We believe that the
following material will facilitate symposium discussion.
0 A Symposium White Paper, outlining issues and providing
initial recommendations for consideration during the October
21, "Future Directions," small group sessions;
0 A matrix briefly summarizing current waste reduction, and
siting efforts in the four states;
° The Executive Summary of a research paper on current
hazardous waste capacity and management in Region 10.
0 A waste reduction issues paper to help focus discussions
during this portion of the symposium.
Other materials are provided as well, and are referred to in the table of
contents. The ideas presented in these papers have not been endorsed by EPA or
the four states, at this time and represent the views of the authors.
The theme of the Symposium is, in part, "Where Do We Go From Here?" and
your comments will help form the recommendations delivered in the final report
to the governors and four legislatures. You will be asked to fill out an
evaluation/recommendation form prior to leaving. These comments will be
considered as recommendations are prepared for the report. As attendees, you
will receive a copy of the final report when it is issued.
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A.
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A Symposium
for
Government, Business, and Public Leaders
A POSITIVE FUTURE:
HAZARDOUS WASTE MANAGEMENT
in the
PACIFIC NORTHWEST
Seattle, Washington
October 19, 20, & 21, 1987
Seattle Sheraton Hotel
Co-sponsors:
U.S. Environmental Protection Agency, Region 10
and
The States of Alaska, Idaho, Oregon, and Washington
Cooperator:
Institute for Environmental Studies,
University of Washington
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A POSITIVE FUTURE:
Hazardous Waste Management in the Pacific
Northwest
BACKGROUND:
This past April, the states of Alaska, Idaho, Oregon and Washington, and U.S. EPA,
Region 10, hosted a symposium for key opinion and decision-makers to assess
current efforts to develop a comprehensive hazardous waste management system for
the Pacific Northwest. The response was compelling and the message clear - North-
west leaders are committed to development of appropriate alternatives, although
important issues must be addressed as we put them in place. Data-gathering efforts
are insufficient to provide adequate data to decision-makers on a region-wide basis.
Capacity assessment efforts and siting procedures are largely untested throughout the
region. Waste reduction efforts are under way in many large and small businesses,
but public policy could be better focused to provide incentives for reduction efforts.
It is necessary to continue the dialogue on these and other imortant issues as we
develop a comprehensive hazardous waste management system for the Pacific
Northwest.
PURPOSE:
This second symposium is designed to focus attention of key leaders on current
regional data, waste reduction and siting efforts, and to solicit input on appropriate
future actions. Leaders from industry, government, and public-interest groups will
share their views on the status of the region's hazardous waste-stream and manage-
ment options. A White Paper is being prepared to stimulate discussion on future
actions; attendees will be asked to consider and comment upon these and other
perspectives presented during the symposium. The Regional Administrator of
Region 10, EPA, and the four State Directors will then prepare a report for the four
Governors and State Legislatures and the Administrator of EPA outlining state and
regional actions that should be initiated by the public and private sectors.
WHO SHOULD ATTEND:
Key public/private sector, public and environmental interest organizations, attorneys-
at-law, and media leaders and decision-makers interested in helping to formulate
these recommendations for action.
TOPICS TO BE DISCUSSED AT THE OCTOBER 19-21 SYMPOSIUM
INCLUDE:
• The current data and capacity picture in the Pacific Northwest
• How national EPA initiatives will affect efforts in the Pacific Northwest.
• What processes work best on siting-related decisions and how risk is best
approached from the local citizens' perspective.
• Waste reduction successes to date in the Northwest and the main elements
of a waste reduction model tailored to meet the needs of the Pacific North-
west
What on-going regional coordination is needed as part of future efforts.
SYMPOSIUM STEERING COMMITTEE CO-DIRECTORS:
Robie G. Russell, Administrator, Fred Hansen, Director,
Region 10, U.S. Environmental Oregon Department
Protection Agency of Environmental Quality
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AGENDA Monday, October 19, 1987
Morning REGISTRATION: Grand Ballroom, 2nd floor,
7:30-8:45 Sheraton Hotel, 1400 Sixth Avenue
8:45 WELCOME
8.55 OPENING REMARKS: Taking The Next
Steps in the Northwest
9:10 KEYNOTE
9:45 BREAK
Bill Ross, Moderator, Ross
& Associates, WA
Robie G. Russell,
Administrator, Region 10,
U.S. EPA
Lee M. Thomas:
Administrator, U.S. EPA
10:00
10:25
11:25
12:00
Afternoon
1:30
3:00
UNDERSTANDING OUR WASTE STREAM AND
ASSESSING CAPACITY NEEDS: The Vital Role of Good Data
INTRODUCTION:
THE CURRENT NORTHWEST DATA
AND.CAPACrTY PICTURE
STATE CAPACITY CERTIFICATION:
The SARA Capacity Requirement
LUNCH
VIEWS FROM THE INSIDE: Northwest
Perspectives on How Generation, Analysis,
and Use of Hazardous Waste Data Helps the
Decision-Maker
BREAK
Richard Ford, Moderator,
Preston, Thorgrimson, WA
Lee Stokes, Boise State
University
Michael Taimi, Office of
Cross-Media Analysis,
OSWER, U.S. EPA
On your own
Tom Korpalski:
Hewlett-Packard, ID
Betty Tabbutt, Washington
Environmental Council
Patrick Wicks,
Environmental Resource
Management NW, WA
3:15
5:15
5:30-
7:00 pm
SITING DECISIONS: Current Issues in the Pacific Northwest.
INTRODUCTION
SITING AND THE COMMUNITY:
Technology, Risk Perception, and Effective
Community Dialogue
• Emerging Technologies
• Community Perception of Risk
• The Role of Community Involvement
WRAP-UP
RECEPTION: No-Host Bar, Cirrus Room
(35th floor, Sheraton Hotel)
Ken Brooks, Director, Div.
of Environment, Idaho Dept.
of Health and Welfare
Gaynor Dawson, ICF
Technologies, Inc., WA
Michael Elliot,
SE Negotiation Network,
Georgia Inst of Technology
Alice Shorett, Triangle
Associates, WA
Bill Ross
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Tuesday, October 20, 1987
REGISTRATION: Coffee and Pastries
Morning
7:30-8:30
8:30
WELCOME
Andrea Riniker, Director,
Washington State Dept. of
Ecology
8:45
10:20
10:35
11:20
12:00
Afternoon
1:30
SITING DECISIONS: Current Issues in the Pacific Northwest (cont.)
THE BUSINESS OF HAZARDOUS WASTE
MANAGEMENT: How the Market
Approaches What's Needed and Where
Moderator Frank Deaver, Tektronix, OR
BREAK
AN IN-DEPTH LOOK AT ISSUES -
SITING AND EQUITY:
A Systems Approach
RESPONDERS
What's Happening in NW on Siting -
Where We're Headed, Will We Get There?
LUNCHEON ADDRESS Grand Ballroom
MAKING YOUR LOCAL SYSTEM
WORK FOR THE HOUSEHOLD AND
SMALL BUSINESS GENERATOR:
The Anchorage Example
Gerald Smedes, Rabanco, WA
Paul Abernathy, Chem-Waste
Management/CSSI, CA
David L. Hodge, Envirosafe
Services, Inc. of Idaho
Roger Nelson, ECOS, WA
Alex Cross, Reidel Environ-
mental Technologies, OR
David Morell, Morell and
Assoc. CA
Pam Crocker-Davis, National
Audubon Society, WA
Jack Peterson, Idaho
Emergency Response
Commission
TEA
Jim Sweeney, Solid Waste
Services Dept, Anchorage, AK
2:00
3:30
3:45
4:30
WASTE REDUCTION: The Future is Now
WASTE REDUCTION IS HAPPENING IN
THE NORTHWEST:
It Makes Good Dollars and Sense
INTRODUCTION
Moderator Fred Hansen, Director
Oregon Dept. of Environmental Quality
BREAK
THE REMAINING BARRIERS:
Can Business and Government Get a
Handle on Them?
KEY ELEMENTS: a Waste Reduction Model
for the Pacific Northwest
Kirsten Oldenburg,
Congressional Office of
Technology Assessment
Kirk Thomson,
The Boeing Company, WA
John Harlan, Intel Corp, OR
George Kelly, One Hour
Fireweed Dry Cleaners
Anchorage, AK
Joan Cloonan, JR Simplot, ID
Fred Hansen
5:00
WRAP-UP
Bill Ross
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Tuesday Evening Session
7:30 LEGISLATIVE ROUNDTABLE: A Look At Legislators, State & Prov.
What's Happening and What's Feasible Dir., and Regional Admin.
Wednesday, October 21, 1987
Morning
8:00-8:30
8:30
8:50
10:30
10:45
12:00
12:15
Coffee and Pastries
WELCOME
FUTURE DIRECTIONS: Next Steps for the
Pacific Northwest
Small Group Sessions - Participant
Analyses of Conference Information and
White Paper
BREAK
Brief Report(s) on Small Group Discussion
Sessions
CLOSING REMARKS
ADJOURN
Dennis Kelso,
Commissioner, Alaska
Dept. of Environmental
Conservation
Robie G. Russell
REGISTRATION: The symposium fee of S85.00 includes one luncheon, coffee/pastry
breaks, conference materials, and the post-conference report. To register, please fill out the
form below and mail to IES, UW as shown. If you are unable to attend or send a substitute, a
refund of the registration fee, less $20.00 for handling, will be made if written request is
received by October 15, 1987.
HOTEL ACCOMMODATIONS: Please make your own; mention this symposium.
Sheraton Hotel, 1400 Sixth, Seattle (206/621-9000): Special corporate rate, $75 single or
double, (plus 12.9% tax), per night.
Crowne Plaza Hotel, Sixth & Seneca, Seattle (206/464-1980): Special government rate for
government employees with ID.
MORE INFORMATION: Polly Dyer, Cont. Environ. Educ. Dir., IES, UW (206/543-1812)
REGISTRATION FORM Hazardous Wast© Management October 19, 20, & 21, 1987
Registration Fee 585.00 $
Name
Agency/Company/Org anization ,
Position.
Address.
City
State
.Zip.
Daytime Phone (
Enclose check (U.S. funds only) made out to University of Washington or Purchase Order
(No ) or Requistion (No. )
Billing Address.
Return to: Hazardous Waste Management Symposium; Institute for Environmental Studies;
200 Engineering Annex, FM-12; University of Washington; Seattle, WA 98195
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B. COMPREHENSIVE HAZARDOUS HASTE
The Next Step
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COMPREHENSIVE HAZARDOUS HASTE MANAGEMENT: The Next Step
Prepared for:
A Positive Future:
Hazardous Haste Management
in the
Pacific Northwest
A Hazardous Haste Management Symposium
October 19-21 1987
Seattle Sheraton Hotel
Bill Ross
Ross and Associates
Seattle, Washington
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INTRODUCTION
The Environmental Protection Agency (EPA), Region 10, and the states of
Alaska, Idaho, Oregon, and Washington are sponsoring two symposia during 1987
to enable key opinion-and-decision-makers to reflect on the trends in
hazardous waste management in the Pacific Northwest. The symposia will
identify any information, research, or policy gaps existing at the local,
state, federal, or private level that may be inhibiting the development and
implementation of an acceptable comprehensive waste reduction and management
system for the region.
The first symposium, held in April 1987, outlined the basic elements of a
comprehensive waste management system, and described the current perspective
of government, industry, environmental, and citizen groups on the issues.
(See White Paper prepared for the first symposium.) The second symposium, to
be held in October 1987, will concentrate on what steps should be initiated in
the Pacific Northwest to facilitate the development of a comprehensive waste
management system here.
The actual decisions which will determine the success or failure of this
enterprise lie outside the scope of these symposia. Although many of the
pivotal people within the region have been and will be in attendance,
different forums than this should and will determine the many specific
decisions that will be made concerning hazardous waste management over the
next few years in the Pacific Northwest. What the symposia and the follow-up
actions resulting from them can do is to help build the framework of the
region's overall goals.
In particular, the symposia should assist in defining what the key
elements such as data management systems, waste reduction activities, and
siting procedures should be trying to accomplish. In this regard, the
environmental directors of the four states and the Regional Administrator
intend to prepare a summary report and recommendation after this symposium for
the four governors, four state legislatures, and the Administrator of FPA.
Progress can then be tracked in these areas as the significant individual
discussions—and struggles—occur in the next few years.
This White Paper presents a series of recommended options for symposium
participants to consider. Participants will have the opportunity during the
symposium to comment on these ideas and to present their own views as to what
is needed.
BACKGROUND
Significant activity is currently underway within Region 1.0 on hazardous
waste management issues.
A citizens' initiative is being circulated within the state of
Washington that would establish a state Superfund cleanup program,
even as a special session of the state legislature has been called
to consider thi s issue.
Two major hazardous waste incinerator proposals are pending within
Washington, and the Washington Department of Ecology is
implementing procedures to deal with these types of siting
decisions.
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0 Idaho is actively implementing its recently adopted state hazardous
waste plan, including beginning efforts to assume responsibility
for the Resource Conservation and Recovery Act (RCRA) program for
EPA. Idaho is also vigorously implementing the emergency response
and community right-to-know provisions of the Superfund Amendment
Reauthorization Act (SARA).
0 Oregon recently adopted its own state Superfund program and has
developed a state plan for promoting waste reduction activities.
0 Alaska is moving forward on assuming the responsibility to
implement RCRA for EPA and has prepared draft regulations that
would govern state siting decisions.
EPA, Region 10, is continuing to implement RCRA, the Toxic
Substance Control Act (TSCA), and the recently amended Superfund
program. Permitting, enforcement and cleanup activities are the
focus of intensive effort within EPA and the states.
Many small and large industries throughout the region are taking
steps to rectify past practices, cleanup old sites, develop and get
permits for new processes and facilities, and reduce waste
generation.
Even as this full range of activities is occurring, a many key leaders in
the field from government, industry, and public interest groups are
apprehensive. Some feel that more can and should be done in one particular
aspect, be it cleanup, enforcement, waste reduction, etc. Others believe that
one or more aspects—such as complex permitting requirements, emphasis on
enforcement, lack of treatment or disposal options, etc.--is a roadblock to
the pursuit of a comprehensive strategy.
For example, comments received from the evaluation questionnaires
completed at the last symposium suggest many industry and government personnel
believe that there is a lack of disposal capacity in the Region; and many
legislative and environmental/public interest representatives tended to
believe that waste reduction efforts were not adequately emphasized or
funded. (See Summary of Evaluation comments.) A sense of wariness seems to
grip many participants regarding the future, even as most agree on the basic
elements needed to build a comprehensive waste management system.
Such wariness by leaders in the field is understandable, since government
is obligated to operate under the rules at hand (primarily RCRA, Superfund,
and TSCA); industry believes that change will go no faster than capital,
technology and government flexibility can allow; and many of the public want
immediate corrective action and extensive waste reduction measures introduced
in a way that does not require new treatment or disposal sites. Hence, the
Pacific Northwest will be challenged to create over the next few years a
reliable and routine hazardous waste management system in which generators
correct prior improper disposal damage, are assisted in reducing waste
generation as much as possible, and have available and use environmentally
sound treatment and disposal options for the remaining residues.
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This routine comprehensive system should be capable of tracking in waste
generation and disposal activities. The system should place a strong emphasis
and priority on rewarding practices that prevent the creation of waste. Any
needed off-site treatment storage and disposal (TSD) facilities should be
appropriately located to minimize land use conflicts and reduce transportation
risks and on-site environmental problems. These facilities should be designed
and operated to meet responsible and conservative permit limits. Government
oversight of the system should monitor and enforce operations sufficiently to
inspire public confidence and protect the environment. The public should be
fully informed of, and involved in, the development and implementation of
these major elements.
THE KEY ELEMENTS IN A COMPREHENSIVE SYSTEM
In the effort to implement such a system, the impact of existing law is
crucial. The existing federal laws, primarily RCRA, Superfund, TSCA, and the
counterpart state laws must be made to work. The basic framework of waste
tracking, permitting, enforcement, and remedial action established by these
laws must be in place if public confidence is to be obtained during other
aspects of system development. This does not mean that these laws may not be
in need of correction or revision due to internal contradictions, excessive
complexity, or other problems. However, without the basic elements of a
regulatory program in place, further evolution toward a comprehensive system
will be extremely difficult, if not impossible. The difficulty industry and
government may have with RCRA, Superfund, and TSCA must be dealth with in a
manner that furthers these laws' fundamental aims.
At the same time, governmental implementation of these laws should be
done with an eye on overall system development. Appropriate flexibility in
the case-by-case application of these laws is called for to assure that each
individual decision contributes to the goal. Fostering long term solutions in
this period of dynamic change is as important as government's responsibility
to put waste generators and disposers under a regulatory framework, and to
rectify obviously egregious past practices.
Three specific elements of a comprehensive system are especially
important and particularly relevant to the Pacific Northwest: data management
systems, waste reduction activities, and siting procedures. There are several
reasons for this:
1. Intrinsic importance of these elements. Quality data
management is essential if decision makers and the public are to
have needed information in a timely manner. Decisions on capacity,
as well as the ability to track the waste stream for enforcement or
technical assistance purposes, depend on adequate data. The very
existence of hazardous waste is the root of the problem, so waste
reduction efforts are crucial. Success in waste reduction must be
documented in order for the more complex and controversial elements
of the system, such as siting of needed treatment and disposal
facilities, to have a chance of a fair hearing by the public.
Siting processes must be seen as dealing competently with questions
surrounding need, equity and public participation. The failure of
any given proposal to receive siting approval may not imply the
overall inability to site needed, responsible facilities. Reliance
upon siting processes that handle the controversial issues well,
however, is critical if decision makers ever are called upon to
make that judgment.
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2. A regional perspective is needed to develop these elements
effectively: These three elements can not be dealt with solely
state by state, due to the regional nature of the Pacific Northwest
waste stream. Waste importation and exportation among the four
Northwest states (and others) are daily facts of life. There is no
regional boundary that absolutely binds certain states into one
hazardous waste system, much less can any one state operate in a
vacuum from other states. Concerns over being a repository for
other states' wastes are commonly raised in policy debates', yet,
doubt exists as to whether economical waste treatment and disposal
services can be provided based on any one state's waste stream
alone. Regional analysis of a common data base, regional
cooperation on waste reduction efforts and regional coordination
(if not decision-making) on siting matters offers a logical and
efficient way to assist each state in making progress or reaching
conclusions on specific waste issues.
3. Federal initiatives on these elements will affect the
Northwest. Waste management issues in general and overall system
development in particular are inextricably linked to federal law.
The most pertinent federal initiative affecting system development
in the near term is the state capacity certification requirement in
the recently enacted Superfund Amendments and Reauthorization Act
(SARA). SARA legislates that a state shall not be eligible for
Superfund cleanup money after 1989 unless it can successfully
certify that it has adequate capacity for treatment, destruction or
secure disposition of all hazardous wastes reasonably expected to
be generated within the state for the next 20 years. (See Apendix
for full text.)
EPA is currently developing the process for states to show
compliance with this requirement. Not surprisingly, EPA, too, is
focusing on how the elements of data management, waste reduction,
capacity assessment and siting, and interstate coordination fit
together to "assure" adequate capacity for each state.
EPA is also preparing extensive revisions to the national data
collection devices, primarily the biennial report required from
all facilities which generate, store, transport, treat, or dispose
of hazardous waste. (States often require more frequent
reporting.) EPA is also launching a national Waste Minimization
Program, designed to develop the appropriate policy role for the
federal government in waste reduction and to provide technical
assistance to generators. It is important that the Pacific
Northwest's regional efforts be cognizant of and coordinate with
these national system development efforts.
ANALYSIS AND RECOMMENDATIONS
The remainder of this White Paper will analyze briefly the three elements
of data management systems, waste reduction activity, and siting procedures as
they presently exist in the Pacific Northwest, and provide draft
recommendations for their further development in light of the following
questions:
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1. What general improvements or modifications should be considered for
each element?
2. What regional effort, cooperation or coordination, if any, makes
sense for each element?
3. How do the pending national EPA initiatives affect each element,
and how can the Pacific Northwest best influence national policy?
4. What additional resources or funding would be necessary to
implement the recommendations?
I- Data Management Systems. The purpose of a data management system is to
provide the appropriate information to decision makers in a timely manner and
to enable interested parties to follow the evolution of an overall program's
development. For hazardous waste management, actions influenced by data
management include permitting priorities; compliance inspections; enforcement
actions; waste reduction progress documentation; technical assistance
priorities and research needs; and assessment of the need for treatment and
disposal capacity in a given area. The SARA state certification requirement
assigns to each states the specific responsibility of identifying a projected
20 year waste stream, and subsequent treatment and disposal strategy.
The states in Region 10 currently collect, process, and use data
differently. This is due to the different universe of hazardous waste
regulated by each state in the region, state priorities and needs, and
ultimately the financial resources devoted to data needs. In addition,
existing state and federal waste reporting forms primarily focus on an
individual company's waste generation and are not designed for assessing or
projecting regional capacity. A number of attempts are underway at EPA
Headquarters to address some of the inadequacies of the current data base.
However, implementation of these changes will not be immediate and may not be
designed to assess regional treatment and disposal capacity.
Industry has several different perspectives on the data issued. Large
industries can develop their own data base for making projections and planning
hazardous waste management programs. These data systems may incorporate the
results of internal recycling and waste reduction programs and make long term
capacity projections. The smaller businesses, although generating the least
amount of waste, are heavily affected by the regional off-site commercial
capacity issue, and often do not have any information on that issue. The
hazardous waste management firms operating TSD facilities develop and use
their own data in assessing regional capacity for marketing and siting
purposes. The current ability of government and industry to share their
respective data bases is haphazard at best.
Recommendations
1. Dr. Lee Stokes has analyzed the data management system in Region 10
in detail and has developed a series of twelve recommendations which are
endorsed here (see Dr. Stokes1 Executive Summary). Generally, there is a
need for data to be gathered by states by methods and at levels of detail
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that are compatible, so that a dynamic regional analysis of the waste
stream here can be conducted. An adequate understanding of the waste
stream would entail knowing accurately the origin of wastes, their type,
volume, and ultimate disposition both by location and method of treatment
or disposal.
2. Participation by Region 10 states in the national data revision
efforts is necessary to coordinate implementation of Dr. Stokes'
recommendations with the national data requirements. The national data
system will, for better or worse, be the driving force in data
collection. States will adopt it, duplicate it, expand it or abandon
it. Region 10 states have been active in these revision efforts to date
and should continue to do so. It is too early to tell whether or not any
additional data collecting effort by Region 10 states will be necessary
after the national revisions occur.
3. Industry/State/EPA regional coordination is needed to assure a
compatible and accurate management system. The four states and EPA,
Region 10, should develop a data task force now so that when the national
revisions occur, the Northwest can develop an implementation strategy
which results in a data system compatible among all four states. A
government/industry/public data task force should advise on the
information goals of the system, so that it produces the type of
information useful to each perspective without being unduly burdensome on
industry. The possibility of augmentation of the system to incorporate
industry generated data that is not required by regulations should be
explored.
4. The data analysis system ultimately developed for the region (and
used by each state for strictly intrastate purposes) should be capable of
elucidating the import/export dynamics for Region 10 generators and TSD
facilities. Such an understanding is critical if the region as a whole,
and each state individually, is to make logical decisions on treatment
and disposal needs for the region's (or state's) generators, and market
boundary decisions on the region's (or state's) existing or proposed TSD
facilities. These decisions at the very least will be needed to enable
the Region 10 states to meet the SARA capacity certification
requirements. (This will be discussed more fully under siting
recommendations.)
II. Waste Reduction Activities. Emphasis on waste reduction offers
challenging policy opportunities beyond hazardous waste issues alone. Most
national environmental legislation is designed to slow down the rate of
pollution from a particular source to a particular media, such as point source
discharges to surface waters, or new sources of air pollution. This "end-of
pipe" mentality, as it is known, was necessary in order to stop the "normal"
course of affairs that resulted in significant environmental degradation In
the 1950's and 1960's. However, waste reduction goes beyond the effort to
remove the pollution after the production process and prior to discharge, and
focuses on not creating the waste in the first place. Waste reduction
concentrates on keeping raw and process materials in the production process
and out of the waste stream.
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Because this is a new orientation towards pollution abatement, there is a
considerable debate about how waste reduction should be defined (see Waste
Reduction Issue Paper). For purposes here, we are referring to those
techniques which eliminate the creation of waste and will also include reuse
and recycling techniques that extend the productive life of certain materials
which otherwise would become waste.
How far waste reduction can go in eliminating the need for TSD capacity
is also hotly debated. It is clear that the economics of waste disposal is
crucial in shifting attention towards waste reduction activities as a cost
effective alternative. Some have argued that the complexity of the RCRA
permitting process for TSD facilities and the increasing cost of disposal from
land bans, etc. is designed to force action on waste reduction. Others
contend that RCRAs, by requiring generators to comply with various
administrative requirements which may not result in readily obvious benefits
to the environment, shifts scarce resources away from researching and
implementing waste reduction measures. The fact of the matter is that for a
variety of reasons, disposal costs are increasing and waste reduction efforts
are becoming more attractive and more frequently pursued.
Since waste reduction is a radical shift in viewing pollution control, it
is not surprising that most studies show that it is not only a lack of capital
or technology that prevents its wider use, but a lack of education on its
benefits as well. Some of the barriers to wider use of waste of reduction
techniques are:
A lack of understanding of the benefits of waste reduction;
0 A lack of information on available waste reduction options;
0 A lack of in-house technical expertise; and
0 A lack of capital to make industrial plant or process modifications.
0 The perceived conflict between some waste reduction techniques and
current hazardous waste laws and regulations under RCRA, Superfund,
and TSCA that could delay prompt implementation.
The challenge is to develop public sector policies and private sector
strategies which can eliminate these barriers and foster greater use of waste
reduction practices. It is possible, however, to emphasize waste reduction
now in the absence of a formal plan, since it can be done firm—by—firm and
need not wait for a critical mass of industry participation. Indeed,
significant waste reduction activities are occurring in the Pacific Northwest
on several fronts. What is lacking is a systematic way to foster and measure
the progress of these efforts in relation to the region's overall waste stream.
Recommendations
1. Each state should develop a viable waste reduction program. Waste
reduction programs appear to function best when divorced from the state's
enforcement responsibilities. Voluntary participation by industry, with
a free exchange of ideas about existing plant practices and innovative
techniques will achieve the greatest results in eliminating waste. This
will most likely occur the cloud of enforcement is far from the scene.
Such a program should consider including the following activities:
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Information clearinghouse, containing technical information,
case studies, knowledgeable people in the field, etc.
Technical assistance capability, providing on-site, hands-on
technical assistance to generators.
Demonstration grants, making funds available to research or
experiment on specific priority waste streams or practices.
Financial incentives for waste reduction, enabling
generators, through loans or tax incentives, to afford waste
reduction investments.
Awards program, giving recognition to generators
demonstrating success and leadership in waste reduct
ion
0 Data base capacity, enabling the tracking of the impact of
waste reduction on the waste stream.
2. The four states and EPA Region 10 should form a Regional Waste
Reduction Task Force, comprised of state and federal officials, industry
representatives and public citizens to determine which of the above
elements can be conducted more efficiently at a regional level or by a
regional body than by each state individually. A regional clearinghouse,
or newsletter, for example, may make more sense than four individual
ones. This decision will hinge in part on an analysis of the states'
waste streams, assessing them for similarities and differences.
Additionally, the task force should investigate the feasibility of
establishing a 'material exchange system' for the Pacific Northwest. A
material exchange is a clearinghouse in which potential users of selected
chemicals or metals are put in touch with generators whose waste contains
those chemicals or metals. Users may be able to pick up 'raw1 materials
more cheaply, while generators may avoid disposal costs by marketing a
now useful product.
3. EPA, Region 10, and each state issuing either RCRA or state siting
permits should establish a fast track review process for determining how
reuse, recycling and in-plant modifications that promote waste reduction
can be accommodated under RCRA, SARA, TSCA, and state law. Most waste
reduction efforts do not conflict with these laws, and do not even need
regulatory approval prior to implementation. However, generators do need
to be able to determine quickly if their proposal must go through the
traditional (and often lengthy) permit review. If RCRA, Superfund, or
TSCA indeed prevent truly good proposals from reasonably quick
Implementation, EPA should document such instances for consideration when
these laws are being reauthorized. (Of course, caution must be exercised
when assessing any waste reduction or off-site recycling or reuse
proposal to assure that risks to human health and the environment are
controlled. Some Superfund sites in the region are the result of
improperly conducted offsite "recycling" operations.)
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HI. SITING PROCEDURES. The issues surrounding the permitting and siting of
TSD facilities can be broken into two main categories, technical and
locational. Technical issues revolve around questions such as: is the
proposal facility in compliance with applicable law for past practices,
operational procedures, and discharge limits? Locational issues primarily
deal with the land use compatibility aspect of a proposal. In the context of
dealing with community or citizen interest in a siting proposal, both
technical and locational type issues invariably do arise. For this
discussion, the term "siting procedures" refers to how both technical and
locational aspects are addressed in the decision process of either the
relevant local or state permit authority, or within the review of the RCRA
permit.
Much of the siting activity in Region 10 states currently relates to the
permitting of existing facilities under RCRA. One RCRA permit has been issued
within the region. Approximately 150 RCRA permit applications are pending,
with around 20 of these receiving active consideration by regulatory
agencies. The primary, though no means exclusive, public concerns over siting
are associated with large off-site commercial TSD facilities. Washington
State has one commercial incinerator permit pending, and another project has
been proposed but no permit application has yet been submitted. Two new RCRA
deep well injection permits are pending for Alaska's North Slope oil fields.
The two existing commercial hazardous waste landfills in Idaho and Oregon have
RCRA permit applications being processed.
The symposia have presented a full range of issues and options associated
with various siting strategies. Three issues stand out, however, as- crucial
to the conduct of a successful siting process: need, equity, and,
citizen participation. (A "successful process" is one where proposals are
given a fair consideration under rules that would allow acceptable proposals
and reject unacceptable ones.)
1. Need. Although only Oregon has rules that require a formal finding
of need for any new hazardous waste treatment or disposal facility, the
question of whether or not a facility is "truly" needed is never far from
most people's minds in considering a proposed facility. Therefore, a
state's or region's data management system must have the ability to
address the question of whether or not an area's generators need access
to the proposed (or existing) facility. Although there is no apparent
enthusiasm for publicly-owned or operated facilities in Region 10, there
is an overall reluctance to let the market alone determine the number of
facilities. Many are concerned that the Pacific Northwest might treat or
dispose of significant quantities of wastes from areas all over the
country if large commercial facilities are permitted here. Both Oregon
and Idaho law make reference to regional waste streams as the sole market
source for new facilities. Hence, the question of need for a facility is
intimately linked to the determination of the size of the market which
the facility is designed or allowed to serve.
2. Equity. An essential characteristic of hazardous waste siting
endeavors is the potentially uneven distribution of costs and benefits
associated with any project. For example, the benefits from siting a new
hazardous waste facility accrue primarily to the operator and employees
of waste-generating industries, and to the 'general public' who
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10
presumably will gain from lessened illegal disposal and will have the
benefits from waste-producing industries without having a facility in
'their backyard'. The costs, especially non-monetary ones such as
perceived and real risks to health and other quality of life
considerations, on the other hand, are concentrated within a particular
community or neighboring communities that host the facility or its
transportation routes. Local opposition at siting attempts is not
surprising, given this fundamental geographical fact.
A broader equity issue exists among states. Is it fair for one state to
be the receptacle for other states' waste? For example, Washington
State's generators produce the vast quantity of wastes which go to the
Oregon and Idaho landfills. One strategy to obtain equity among states
is to require through federal law that each state take care of its own
capacity needs—or reach an agreement with another state to accommodate
its wastes. This is the essence behind the SARA capacity certification
provision discussed previously.
Siting policies must therefore consider issues of fairness or equity.
Techniques involving community negotiation and explicit compensation are
being developed to address this issue. Examples of compensation include
monetary compensation, guarantees of property values, provision of
ancillary community services, etc.
3. Citizen participation. All four states have different approaches to
the question of how the local community, private citizen, or public group
should participate in the siting decision-making process. (See
Data/Capacity, Waste Reduction and Siting Efforts Paper for narrative
description of existing state procedures.) Techniques such as
negotiation, mitigation, and compensation are being used more frequently
around the country in an attempt to obtain agreements with local
governments or residents that allow projects to receive approval. The
development of statewide siting criteria and the preemption of local
planning and zoning powers have also been tried to give decision a less
provincial aura.
No one procedure has been identified as being the best or superior way to
conduct a siting process. There are two reasons for this. Siting
processes are not supposed to result always in a 'yes' decision. Rather,
the procedures should weed out inadequate or unnecessary proposals and
allow acceptable ones to move forward. There is no foolproof way of
establishing rules that guarantee getting to the appropriate "yes" or
"no". Secondly, opposition forces are often successful in causing other
local groups to believe that the only way to show that the locals had any
say in the siting process is to block the entire project. (This is
especially true for projects which announce sites prior to conducting
discussions with the host community or residents.) The most successful
siting processes appear to have:
a. Rules that demonstrate that local interests have significant
say in how a project is to be sited and operated (if not a veto
prior to going to court);
b. A developer who is understands that local needs and fears are
real and deserve substantial responses; and
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c. Regulatory personnel who can inspire trust in the way they
relate to local people's concerns.
This combination has a chance of getting the community to 'maybe,' at
which time factors such as compensation and mitigation may be pivotal.
Recommendations
1. Analysis of the region's waste stream (see Dr. Stokes1 paper) shows
its dynamic nature, with wastes being imported and exported among all
states, except Alaska which only exports to the other three states. The
implications of this are threefold: (1) if market boundaries for disposal
facilities were constrained to stay within each state, the existing waste
stream flow would be severely disrupted; (2) siting decisions for
existing and new facilities, though performed under the host state's
procedures, will affect other states' generators, and (3) the SARA state
capacity certification requirement will undoubtedly motivate the states
to document in some manner their interdependence for disposal capacity.
Significant siting decisions will occur over the next few years in the
Pacific Northwest. Thus, coordination is called for among the states on
siting matters. A regional Hazardous Waste TSD Facility Siting Advisory
Board should be formed, comprised of local elected officials, corporate
leaders, and civic activists to:
Advise EPA and the states on the nature of the capacity
need/market size question, and what information is necessary
to address this question.
0 Assess the effectiveness of the states' siting processes as
major siting decisions occur by periodically reviewing the
TSD capacity of the region.
0 Recommend if other states outside of Region 10, or if
provinces of Canada should be invited to join this process
due to their TSD capacity needs or situation.
0 Recommend measures that could assist the states in the SARA
certification process.
Provide an early warning network if potential TSD gridlock is
approaching the region, and the absence of TSD capacity
becomes a critical concern.
2. Future circumstances could demonstrate the need for a formal regional
siting body. This would occur if it were believed necessary to:
a. Restrict the market boundaries for TSD facilities located here
on a regional basis;
b. Perform a regional assessment of capacity need and decide on a
regional basis the equity in locating any needed facilities;
c. Assure uniform siting procedures, including measures for
citizen participation; and/or
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12
d. Execute and implement a regional agreement necessary that
enables all member states to meet the SARA requirement.
Wholesale attempts by one state to exclude other states' wastes could be
a violation of the interstate commerce clause of the U.S. Constitution.
However, if states form a Compact as authorized by the U.S. Congress,
such exclusions are permissible. The Northwest Compact on Low Level
Radioactive Waste (of which Alaska, Idaho, Oregon, Washington, Montana,
Utah, Wyoming, and Hawaii are members) is one such example of a compact.
No compacts have been executed in the U.S. for hazardous waste disposal.
The compact process is not easy to structure, requiring adoption at the
state level and approval by Congress. Compacts have the advantage of
codifying regional cooperation on difficult issues, and do spell out
specifically the responsibilities of each member state, and the powers of
the resulting regional authority.
A regional decision-making body could be formed that did not attempt to
exclude wastes from non-member states, but performed the other tasks
described above. It would still be a major undertaking to organize and
authorize such a regional decision-making body. The Northwest Power
Planning Council is an example of a body that provides regional
decision-making for its member states.
In general, a formal compact or regional decision-making body should be
organized for hazardous waste management if leadership within the region
on hazardous waste issues, as well as the political leadership, believe
that the benefits of formal coordination justify it. Factors to consider
when assessing the benefits and obstacles are whether:
a. Individual state siting procedures prove incapable of
approving needed facilities, and TSD "gridlock" looms as
inevitable; or
b. The necessity to exclude legally non-member state's wastes
through a compact becomes a political prerequisite for siting
critically needed TSD facilities; or
c. EPA requires such formal bodies as the only form of
documentation of interstate cooperation that satisfies the
SARA requirement.
There is no evidence that the first condition is now true. Although many
of the states' siting procedures are untested, they show no evidence of
being incapable of siting appropriate facilities and rejecting
inappropriate ones. There is insufficient evidence on the second
condition. Only time will tell if such exclusions are indeed
justifiable. (If so, it may not require a compact, but might rely upon
operating agreements, limits on facility size, public ownership, etc., to
effectively accomplish the same objective.) With regard to the third
condition, EPA has shown no inclination to place reliance exclusively
upon compacts or formal regional bodies to document capacity cooperation
among states.
The Siting Advisory Group described in Recommendation #1 should provide
the additional scrutiny needed to assess the benefits from and obstacles
to the more formal regional body or compact.
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3. States should analyze the Impact of each other's legislative and
regulatory actions upon the development of an effective capacity strategy
for the region. Siting laws in one state which reduce its ability to be
part of a regional capacity solution can put pressure on other states to
do likewise. Interstate waste stream 'exclusionism1 is clearly against
the interests of the Pacific Northwest as a whole. Some ways to
accomplish this coordination are: a. testimony at legislative hearings
on pending legislation by knowledgeable legislators from other affected
states; b. written comment on agency regulatory proposals by state
director's from affected states; and c. informal networking by the
region's state and federal hazardous waste staff on a regular basis.
4. Region 10 states should be extremely active in EPA's process to
develop implementation procedures for the SARA certification
requirement. The progress Region 10 has made in developing a coordinated
approach to addressing state and regional waste issues, including
capacity, will be illustrative to EPA. Moreover, the forum that the SARA
process will provide to the states can maintain this momentum.
5. EPA and each state should develop a regional permitting strategy for
all pending TSD permits, and update it when necessary. Such a strategy
would attempt to insure that the most important permits for building a
comprehensive system receives priority attention within each state. This
could mean that a new transfer station permit might be a top priority in
Alaska, while an existing landfill permit renewal might be a top priority
in Idaho. To the extent that such a strategy contradicts national
priorities for permit issuance set by EPA Headquarters or the Congress,
EPA, Region 10, should seek accommodation.
6. Although this is not a strict siting recommendation, local and state
governments should investigate and implement ways to provide regular
waste pickup and transfer options for non-regulated hazardous waste
streams, such as from households and small businesses. These programs
can help maintain the integrity of local landfills and avoid pollution of
surface and groundwaters, as well as build public support for sound
environmental management in general.
CONCLUSION
This White Paper has been prepared for EPA, Region 10, and the states of
Alaska, Idaho, Oregon, and Washington in order to provoke thought about the
status of hazardous waste management in the Pacific Northwest, and to provide
options to improve the current situation. In particular, the data management
capability, the effort to promote waste reduction, and the attempt to conduct
siting processes in the Norhtwest have been examined. Specific
recommendations for changes are made, with emphasis on fostering on-going
long-term regional cooperation.
This nation is currently spending well over two billion dollars a year
trying to rectify the damage resulting from the way hazardous wastes were once
handled. The recommendations developed here and those which will undoubtedly
come out of the symposium will cost a modest amount of money to implement.
Whatever the amount, it will pale in the face of the Northwest's share of the
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14
two billion dollar yearly bill for past mistakes. As Shakesphere said, "The
past is prologue." If we are to learn from and not repeat this past, we must
change the way hazardous wastes are handled. To do so, less waste must be
generated and better TSD facilities must be available. In order to make the
difficult decisions as rationally as possible, good data is an absolute
necessity. The most important recommendation is that whatever is recommended
for the three elements, all symposium participants work to see that adequate
resources are available to implement the recommendations. If this occurs, we
will have a positive future for hazardous waste management and ultimately a
far less expensive one.
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APPENDIX
A. DEFINITIONS
The term hazardous waste management system is used to convey the
comprehensive scope implied by the sum of the terms: waste reduction, waste
minimization, waste recycling, waste treatment, and destruction, and waste
disposal. A comprehensive hazardous waste management system would use one or
more of these techniques to achieve adequate environmental protection by
either eliminating the waste in the first place, or by recycling, treating,
destroying, or disposing of the waste properly.
Hazardous waste is defined in this paper, as in the first paper,
according to the definition of the U.S. Congress Office of Technology
Assessment (OTA): "All nonproduct hazardous outputs from an industrial
operation into all environmental media, even though they may be within
permitted or licensed limits. This is much broader than the legal definition
of hazardous solid waste in the Resource Conservation and Recovery Act (RCRA),
its amendments, and subsequent regulation. Hazardous refers to harm to human
health or the environment and is broader than the term "toxic". For example,
wastes that are hazardous because of their corrosivity, flammabi1ity,
explosiveness, or infectiousness, are not normally considered toxic."
Other terms are defined as follows:
Hazardous waste reduction: "in-plant techniques that reduce,
avoid, or eliminate the generation of hazardous waste so as to
reduce risks to health and environment."
Hazardous waste minimization: waste reduction techniques that
minimize, but do not completely eliminate, generation of hazardous
waste at a particular plant or for a particular industrial process.
Hazardous waste recycling: techniques applied to hazardous waste
after it is generated to enable part or all of the contents of the
waste stream to be re-used in production activities. Re-refining
is an example of recycling.
Hazardous waste treatment: techniques applied to hazardous waste
after it is generated that change or destroy the characteristics of
the waste so as to render it non-hazardous (or less). Incineration
is a form of waste treatment which can destroy the hazardous
characteristics of a chemical compound.
Hazardous waste disposal: the controlled or contained release of
hazardous waste into any environmental media (such as air, land, or
water) with no further attempt to recycle or treat the waste
itself. Permit limits under state or federal law regulate the
volume and method of such controlled or contained releases.
Landfills are a type of hazardous waste disposal.
Listing under RCRA as 'hazardous waste1 puts such waste into the RCRA
permitting and enforcement system. Proper environmental management is still
needed for those wastes defined as hazardous by OTA, but not regulated by RCRA.
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B. SARA STATE CAPACITY CERTIFICATION REQUIREMENT
Section 104(k) of Superfund Amendments and Reauthorization Act (SARA) of
October 19, 1986:
"....Effective three years after the enactment of the Superfund
Amendments and Reauthorization Act of 1986, the President shall not
provide any remedial actions pursuant to this section unless the
state in which the release occurs first enters into a contract or
cooperative agreement with the President providing assurances
deemed adequate by the President that the state will assure the
availability of hazardous waste treatment or disposal facilities
which. ...
(A) have adequate capacity for the destruction, treatment, or
secure disposition of all hazardous wastes that are
reasonably expected to be generated within the state during
the two-year period following the date of such contract or
cooperative agreement and to Ibe disposed of, treated, or
destroyed,
(B) are within the state or outside the state in accordance
with an interstate agreement or regional agreement or
authority,
(C) are acceptable to the President, and
(D) are in compliance with the requirements of subtitle C of
the Solid Waste Disposal Act."
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C. DATA/CAPACITY, HASTE REDUCTION AND SUING EFFORTS:
STATE PROGRAM HIGHLIGHTS
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DATA/CAPACITY, HASTE REDUCTION AND SITING EFFORTS;
STATE PROGRAH HIGHLIGHTS IN
ALASKA, IDAHO, OREGON, AND HASHIHGTON
Prepared for:
'A Positive Future: Hazardous Wste Hanapent
in the Pacific Nortlwest"
October 19-21, 1987
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INTRODUCTION
The purpose of this paper is to provide a backdrop for
discussions at the October 19-21, 1987 Symposium, "A Positive
Future Hazardous Waste Management in the Pacific Northwest."
Providing a legislative and regulatory background may help
participants with discussions regarding current hazardous waste
management efforts in the region. It will also hopefully help
focus attention on areas for future action.
This paper highlights elements of the data/capacity, waste
reduction and siting legislation, regulations and processes in
Alaska, Idaho, Oregon and Washington.
It includes a narrative discussion of data/capacity, waste
reduction and siting efforts as well as two figures, one on siting
and one on waste reduction. Several points are worth noting:
(1) The two figures (Figures 1 and 2) describe state efforts
highlighting distinctive features of the state programs. For
instance, EPA regulations do not address siting process and states
have their own siting requirements.
(2) Although highlighting state-level activities (legisla-
tive, regulatory), the figures do not cover efforts underway at
the local level. For instance, the Alaska Health Project's Waste
Reduction Assistance Program, discussed in the narrative, is not
identified in Figure 1. The purpose of the figures is to provide
a comparison of state-level activities and to highlight the basic
legislative and regulatory structures in place.
(3) Neither the narrative nor the figures presume to be
comprehensive in their treatment of all data, waste reduction or
siting issues. Rather, they attempt to highlight information most
likely to be of use to the decision-makers wrestling with issues
addressed at the symposium.
(4) No figure was prepared for data capacity, in large part
because there is not an extensive statutory and regulatory frame-
work for this at the state level. This should not suggest the
data/capacity issue is less significant than siting and waste
reduction, however.
SUMMARY OF DATA/CAPACITY STATUS IN THE REGION
Of the four states in Region 10 Washington and Oregon are
authorized to conduct the RCRA hazardous waste program and cur-
rently regulate a greater universe of hazardous waste than that
required by EPA. Alaska and Idaho have hazardous waste regula-
tions in effect but have not yet received authorization for the
hazardous waste program from the EPA.
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Current federal regulations require generators and treatment,
storage, and disposal (TSD) facilities to submit biennial reports
covering facility activities for each even numbered year. This
report includes information on the types and volumes of waste
generated, treated, stored or disposed of during the year. In
authorized states this information is submitted to the state
agency and then reported to EPA. In non-authorized states, the
reports are submitted directly to the EPA. In addition, states
may collect and maintain additional generator and TSD data, either
in more detail or on a more frequent basis, than currently
required by EPA. Alaska is currently the only state not maintain-
ing a special data base for generators and TSDs. Washington and
Oregon have computerized this data, while Idaho has not. Only
Washington collects any kind of TSD capacity information such as
end of year storage capacity and only Washington has done any kind
of waste generation forecast models. Finally, with regard to
waste minimization all Region 10 states, except Alaska, have some
sort of a waste minimization strategy in place and both Oregon and
Washington are developing waste minimization regulations or
policies.
The EPA is currently in the process of addressing a number of
inadequacies and inconsistencies in its current hazardous waste
data management system. The new system being developed (titled
RCRIS) may be operational in FY 89 and all Region 10 states plan
to adopt the system if its current inadequacies are corrected and
funding levels to operate the system are sufficient. The system
as presently designed will be able to collect current data
information from a variety of sources including state data.
Whether it has the ability to adequately assess capacity has yet
to be determined.
SUMMARY OF WASTE REDUCTION ACTIVITIES IN THE REGION
Alaska
The Department of Environmental Conservation currently has no
formal program in existence to promote waste reduction in the
state. Initial planning efforts to establish a state waste
reduction program have begun. Lack of explicit statutory direc-
tion and funding are the principal reasons for not having a
program.
The Alaska Health Project (AHP) currently operates a Waste
Reduction Assistance Program (WRAP) which provides information and
technical assistance and conducts on-site audits for the small
business community. WRAP is a pilot project that was designed and
implemented under an EPA Region 10 grant. AHP recently received
additional federal assistance from Region 10 to continue the WRAP
program during the 1988 federal fiscal year. AHP also operates
the small business Hazardous Materials Management Project (HMMP)
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which provides education outreach and research on waste reduction
and hazardous materials. A manual is being developed under HMMP
to promote waste reduction in Alaskan small businesses. The Small
Business Development Center is assisting AHP in disseminating
various HMMP information materials to small businesses in Alaska.
HMMP is a three-year project funded by a private foundation. AHP
is a private non-profit organization located in Anchorage, Alaska.
Idaho
The Idaho Department of Health and Welfare currently has no
formal program in existence to promote waste reduction in the
state. Idaho recently adopted a state hazardous waste management
plan which was mandated by the State Hazardous Waste Facility
Siting Act of 1985. One of the goals included in the plan is to
encourage recycling, reuse, reduction, recovery and treatment of
hazardous wastes. The Governor has publicly committed to imple-
ment it vigorously, including its emphasis on waste reduction. A
total of 2 FTEs was appropriated in SFY 88 to begin implementing
the overall plan.
Oregon
The Oregon Department of Environmental Quality (ODEQ)
recently prepared a hazardous waste reduction plan to guide
implementation of its newly established waste reduction program.
Oregon's waste reduction program includes source reduction and
recycling. When fully implemented, the program will have the
following components: (1) information outreach; (2) education/
technical assistance; (3) research grants; and (4) financial
assistance. Although most elements of the program will be
administered by ODEQ, the technical on-site assistance component
of the program (waste reduction audits) will be conducted by a
nonregulatory agency or trade association. The ODEQ program is
currently funded by the state general fund at a level of 1.5 FTEs
for the next biennium. Additional staff persons (up to a total of
5 FTEs) are expected to be hired in the future. ODEQ recently
sponsored a conference on waste reduction in conjunction with the
Association of Oregon Industries and American Electronics
Association on August 18, 1987.
Washington
The Washington Department of Ecology (WDOE) currently
provides technical assistance on a limited basis to industry
concerning hazardous waste management and recycling. While
considerable planning efforts have been conducted concerning the
design and implementation of a state waste reduction program,
primarily as a result of Substitute Senate Bill (SHB 4245) which
established waste reduction as the top priority for managing
hazardous waste in Washington, a waste reduction program has not
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been established to date. Lack of resources are the principal
reason for not having a program.
SITING
Alaska
Alaska's statute was passed in 1981 and draft regulations
were proposed in March 1987. The statute requires the state to
evaluate and select potential sites for hazardous waste manage-
ment. The regulations require the applicant of any proposed
hazardous waste facility to notify the public of its intent, and
specifically to obtain a written agreement with the borough or
municipal government describing how the applicant will monitor
operations both on-site and off-site; respond to on-site accidents
and emergencies; assure safe transportation of wastes to the site;
and mitigate for decreases in property values and address condi-
tions that adversely affect agriculture or natural resources.
Also, Alaska's Department of Environmental Conservation (ADEC) may
appoint an advisory committee to assure that there is a forum for
citizen comments on the application. Such a committee must
prepare a report summarizing citizen concerns and how the appli-
cant will address the concerns. This report may substitute for
the agreement with the local government mentioned above.
If adopted, Alaska's regulations would establish setback
requirements so that no hazardous waste facility be located in a
critical habitat area, state game refuge, state game sanctuary,
state range area, national wildlife refuges, national monuments,
national parks, designated wild and scenic rivers, critical
groundwater management areas, sole source aquifers, or high risk
area from seismic, volcanic, steep inclines, floods, tsunamis,
The applicant is required to submit a risk assessment and
classify the assessment as to "safe" (10-6), "intrinsically
unsafe" (10-*), or "safe with provisions" (10-5). The applicant
is required to demonstrate financial responsibility (using Federal
regulations) and document any previous compliance history. There
are additional requirements for proposed hazardous waste incin-
erators including, for example, one year of ambient air quality
data and a projection of expected air quality after the facility
is built.
The regulations require the applicant to submit specific
geotechnical and hydrologic information and, for land facility and
underground injection well applicants, to make certain demon-
strations regarding the safety of geologic and hydrologic
conditions.
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Idaho
Idaho's statute was passed in February 1985, and requires a
hazardous waste management planning commission, consisting of 17
people representing diverse geographic areas of the state and
specified by statute as to representation, to develop a hazardous
waste siting management plan. The plan is required to provide for
geographic distribution of treatment, storage or disposal (TSD)
facilities and may instruct Idaho's Department of Health and
Welfare (IDHW), and Idaho's Department of Water Resources and
Transportation to conduct studies of waste inventory, waste
practices, needs, incentives for cooperation, and alternative
methods for treatment and disposal of hazardous waste.
A plan has been developed and was adopted by the Legislature
in March 1987. It directs IDHW to conduct educational programs
regarding the public's responsibility for generating hazardous
waste, to investigate procedures to establish household hazardous
waste collection, segregation, treatment, and disposal, and
directs local government to establish community information
committees in the city or county where a new facility is proposed.
In the area of alternative technologies, the plan directs the
Idaho Legislature to evaluate tax incentives, foster research and
development programs, and by directive to IDHW, limit land dis-
posal of wastes that are amenable to alternative technologies, and
make processing alternative technology permit applications a high
priority.
The plan suggests encouraging communication among states
surrounding Idaho regarding siting and suggests that the state
designate specific routes, favoring interstates and major highways
for the transportation of hazardous waste. The plan notes that
local government approval should be required regarding the
designation of non-state highways for hazardous waste transport.
The plan suggests that the Legislature either give fee
authority to local city and county governments or establish a
development fee as a permit condition to offset impacts of a
hazardous waste management facility. The plan reinforces the
concept of privately owned or operated facilities (as opposed to
publicly owned or operated) and suggests the IDHW encourage the
development of receiving, transfer, and storage facilities for
small quantity generators. The plan states that the licensing
procedure should be better coordinated with state and federal
permitting processes.
With regard to insurance, the plan suggests that the Idaho
Legislature implement mechanisms for affordable environmental
impairment insurance, such as tort law reform, state insurance
fund, or regulatory control of insurance rates. The plan recom-
mends that the state establish a state trust fund for post-closure
-5-
-------
cleanup of abandoned sites and for emergency cleanup purposes, and
that adequate funding be provided for state departments for
hazardous waste management.
The plan also sets forth siting criteria which are identified
as numerous hydrogeological and demographic characteristics, and
suggests the Legislature establish incineration siting criteria.
Finally, the plan also suggests the Legislature adopt legislation
to allow state control of PCB waste disposal consistent with the
federal Toxic Substances Control Act.
With regard to licensing new facilities, Idaho's statute
requires that a 10 member site review panel with representation
from the state and the public be established to receive public
input early in the permitting process and to approve, deny, or add
provisions to the siting license to mitigate public concerns.
The statute provides for state-preemption of local govern-
ment. The statute also provides for district court review of
property loss claims, if these claims are brought not later then
nine months after approval of the permit application.
Oregon
Oregon's statute was passed in June 1985 and regulations were
adopted in Spring 1986. The regulations specify a three step
permitting procedure which require the applicant (a) to request
and obtain authority to proceed, (b) submit and obtain a land-use
compatibility statement from local government and state, and
(c) to submit an application and obtain a permit.'
An interesting component to Oregon's process is the require-
ment of the applicant to provide information to allow the Oregon
Department of Environment Quality (ODEQ) to make a finding that
there is a "need" for the facility. "Need" is defined by the
regulations as (1) lack of adequate current treatment or disposal
capacity to handle hazardous waste or PCB generated by Oregon
companies, (2) the proposed facility's operation would result in a
higher level of protection of the public health and safety or
environment, or (3) the proposed facility's operation will sig-
nificantly lower treatment or disposal costs to Oregon companies,
excluding transportation costs within states that are parties to
the Northwest Interstate Compact on Low-Level Radioactive Waste
Management. In addition, to establish "need," the proposed
facility must significantly add to the range of hazardous waste or
PCB management technologies already employed at a permitted
treatment or disposal facility in states that are parties to the
Northwest Interstate Compact on Low-Level Radioactive Waste
Management. Notwithstanding the "need determination," ODEQ may
deny a permit, if ODEQ finds the capacity at other facilities
negates the need for a particular facility in Oregon.
-6-
-------
The regulations contain specific requirements regarding
appropriate facility size (to match projected need), and they
require best available technology. The regulations also contain
setback requirements, and requirements to use a Groundwater
Quality Protection Evaluation Matrix as a screen for locating
proposed facilities. The applicant must demonstrate financial
capability as specified in the regulations, and compliance history
as defined in the regulations. The regulations contain specific
land-use findings for local government to consider.
Community participation is highlighted in the regulations,
with the requirements that the Director of ODEQ appoint a com-
mittee of citizens composed at least partly by residents living
near to or along transportation routes to, the proposed facility
site, and part by nominees of local government. The committee is
charged with providing a forum for citizens' concerns and for
preparing a report summarizing the concerns and the manner in
which the company is addressing the concerns. The regulations
also recommend that local government and the applicant consider
negotiating an agreement appropriate for the potential impact.
Mitigation possibilities such as special monitoring both on and
off-site, for example, are mentioned in the regulations.
Washington
Washington's statute was passed in July 1985. It requires
the Washington Department of Ecology (Ecology) to develop a state
hazardous waste management plan to include waste generating
forecasts, capacity needs assessment, methods for promoting the
hazardous waste management priorities set forth by statute
(minimization of hazardous waste, for example), and citizen
involvement. Ecology expects the plan to be completed by June
1988.
The statute established state preemption authority for
disposal and incineration facilities, while also providing a key
role for local governments in hazardous waste management and in
citizen proponent negotiations (discussed below). Specifically,
local governments are required to develop local hazardous waste
management plans, and to designate local land use zones for
storage and treatment facilities. One million dollars in grants
are available to assist local governments in accomplishing these
objectives and the state is required to develop guidelines to
assist local governments in this endeavor.
The statute also requires Ecology to promulgate siting
standards. Ecology issued interim siting standards in January
1987, and expects final standards to be issued by the end of the
calendar year. The law lists fourteen factors that may be con-
sidered in establishing siting standards (such as geology, trans-
portation, etc.).
-7-
-------
The statute also contains provisions concerning citizen
proponent negotiation. The state has hired two professional
mediators/negotiators to aid in preparing a guidance report on
citizen proponent negotiation. The report will be designed to aid
users (e.g., citizens, developer, and local government) on how
citizen proponent negotiation may work. The report should be
available by fall. Ecology is authorized by statute to issue
regulations on negotiation processes and to spend money on it.
Ecology is also intended to serve as an information clearinghouse
on the subject.
-8-
-------
FIGURE I. WASTE REDUCTION
State
Alaska
Why Program
Established
No program cur-
rently exists.
Emphasis Placed
On Waste Reduction
No Indication
given.
Sourer
Reduction
No formal statutory
or regulatory plan.
Recycling/
Re-use
No formal program.
Economic
Incentives
No formal program.
Public Information
Programs
No formal program.
Idaho
To reduce the ex-
pense to both indus-
try and society.
The Idaho Hazardous
Waste Management
Plan which was re-
cently adopted by
the legislature has
as its mission to
provide for the
safe and effective
management of haz-
ardous wastes. The
committee which
formulated the plan
was organized
pursuant to
I.C. § 39-5805.
Listed as one
among many haz-
ardous waste man-
agement options
in State Siting
Act and Hazardous
Waste Management
Plan.
Recently adopted
legislation lists
source reduction as
one of several
facets of an over-
all waste manage-
ment plan.
Recent legislation
Hsts recycling
and reuse as impor-
tant parts of an
overall waste man-
agement plan.
Hazardous Waste
Management Plan
provides that the
legislature should
consider tax
credits and tax
free bonds for
construction of
alternative tech-
nology facilities.
The Idaho Hazardous
Waste Management
plan calls for pub-
lic hazardous waste
workshops, pam-
phlets, videos and
slides produced in
laymen's terms,
educational semi-
nars and TV and
radio features.
This public Informa-
tion is directed
toward the over.il]
plan, not specif-
ically at waste
reduction.
-------
FIGURE 1 (Cont.) WASTE REDUCTION
State Why Program
Established
Oregon In hazardous waste
statutes has
priority over other
hazardous waste
management
practices. Specific
reasons for waste
reduction (as listed
in Oregon Revised
Statutes 466 et
seq. , and DEQ's
Hazardous Waste
Reduction Program
Plan) include: more
efficient use of re-
sources, a decrease
in waste management
and regulatory com-
pliance costs, re-
duction of waste-
water treatment
costs and a reduc-
tion in the risks
to public health.
Emphasis Placed
On Waste Reduction
The statutes and
regulations do not
indicate the rela-
tive importance of
waste reduction
vis-a-vis other
management options,
but DEQ's report
indicates that
Oregon considers
waste reduction a
top priority.
Source
Reduction
Hazardous Waste
Management Regula-
tions mention
source reduction,
but do not give a
specific detailed
plan. The Hazard-
ous Waste Reduction
Program Plan pre-
pared by Oregon DEQ
has source reduc-
tion as a goal to
be achieved by in-
put substitution,
product reformula-
tion, product pro-
cess redesign and
improved operation
and maintenance.
Recycling/
Re-use
Mentioned as a
priority in Hazard-
ous Waste Manage-
ment Regs. , but
more fully des-
cribed in DEQ's
Hazardous Waste
Reduction Plan
Program.
Economic
Incentives
DEQ's report does
not specifically
provide for eco-
nomic incentives,
but does call for
financial assis-
tance.
Public Information
Programs
No formal program
within statutes or
regulations, but
DEQ's Hazardous
Waste Reduction
Program plan calls
for a quarterly
newsletter, produc-
tion and distribu-
tion of waste re-
duction informa-
tion, a waste
reduction reference
library, and a
toll-free hotline.
DEQ implementation
of the Information/
education component
of the program plan
officially began In
July, 1987.
Washington
No program currently
exists. Study was
mandated by RCW
70.105.150,
70.105.160, and
70.105.170. DOE
published a
comprehensive re-
port on July 1,
1986, but its pro-
visions have not yet
been adopted as
statutes or
regulat ions.
Number one priority
in legislative
declaration. See
RCW 70.105.150(1)
(a).
Waste Management
priorities
established by
statute. Hazardous
waste section of the
Dept. of Fcology
published a
comprehensive re-
port In July 1986
covering both
policy and technical
waste reduction
plans.
Mentioned as a
priority in statute,
but no specific
regulations have
been adopted. Haz-
ardous waste section
of the Dept. of
Ecology has pub-
1ished report which
lists recycling and
re-use as viable
waste management
options.
Not specifically
authorized by
statute, but DOE's
plan calls for
higher land
disposal fees so
that generators
will have more
economic
motivation to
change their waste
management
practices to a
more environ-
mentally sound/
preferred method.
No formal program as yet,
although the statute
authorizes a hazardous
waste, hotline and
provides that DOE must
implement a plan or pro-
gram to provide informa-
tion and education about
hazardous waste. DOE's
plan calls for a consult-
ative business outreach
program, an Information
waste exchange, technical
workshops, education and
information assistance,
an award program, and a
technical resource
center. DOE currently
provides technical
assistance on a limited
basis to Industry con-
cerning hazardous waste
management and recyclIng.
-------
FIGURE 1 (Cent.) WASTE REDUCTION
Educational/Tech-
nlcal Assistance
tancc
State
Research Grants/
Financial Assis-
Alaska
No formal program
currently exists
No formal program
in existence.
Idaho
No formal program
as yet, but the
Idaho Hazardous
Waste Management
Plan lists educa-
tional and techni-
cal assistance as
gools.
The Hazardous Waste
Management Plan in-
dicates that Idaho
Universities should
pursue alternative
waste management
technologies, but
makes no specific
provision for
research grants.
-------
FIGURE 1 (Cont.) WASTE REDUCTION
State
Educational/Tech-
nical Assistance
tance
Research Grants/
Financial Assis-
Oregon
Statute authorizes
program which Oregon
DEQ has included in
its Hazardous Waste
Reduction Program.
This program calls
for on-site hazard-
ous waste reduction
assistance, waste
reduction seminars
and a waste ex-
change.
DEQ's report pro-
vides for creation
of a Hazardous
Waste Reduction
Loan fund for loans
to small and medium
sized facilities
for industrial pro-
cess improvements
that reduce wastes
generated at the
source.
Wnshlngton
No formal program as
yet, although the
statute authorizes
DOE to provide
consultative
services and tech-
nical assistance.
DOE's comprehen s ive
plan calls for
technical workshops,
a consultative serv-
ice for businesses
and ;; technical re-
source center.
No formal program
in existence,
although, DOE's
report calls for
attractive fi-
nancing through
municipal bonds
(which are already
specifically autho-
rized under RCW
39.84 et seq.)
loans and grants.
These incentives
are part of a
broader incentive
program for overall
hazardous waste
management and
are not specifi-
cally directed
toward waste
reduction.
-------
FIGURE 2. STTING IN REGION TO STATES
State Statutory/Regula-
tory Schedules
and Authority
Alaska Draft regula-
tion issued
March 31, 1987,
have had full
public comment
and have been
issued pur-
suant to
authority of
Alaska Statute
(AS) 46.03, et
seq. They are
scheduled for
adoption on
December 15 ,
1987, and are
currently out
for public
comment.
Applicability of Determination of Regulatory
Siting Rules/ Need Preemption
Regulations
Including Owner/ Not formal part No formal
Operator of a of process now. preemption.
hazardous waste State has
management facility conducted a
which is: (1) a new waste stream
TSD facility, (2) a analysis.
Class I underground
injection well, (3)
required by EPA to
obtain a permit, (M
modified to include
additional hazardous
waste disposal or in-
cineration capacity.
Permitting
Procedures
Has a preap-
plication
procedure which
requires, among
other things:
1. published
notice of the
proposed project,
2. notification of
the local govern-
ment, and
3. a written
agreement with
the local govern-
ment.
The actual ap-
plication requires
written proof of
compliance with
the preapplication
procedures, aerial
maps of the pro-
posed site, and a
written summary of
citizens concerns
and responses
Community
Participation/
Negotiation
(1) Committee may
be appointed by the
Dept. of Environ-
mental Conserva-
tion. Composed of
residents living
near or along trans-
portation routes,
persons appointed
by local govern-
ment, and other
persons with
technical skill.
Committee prepares
written report
summarizing citizen
concerns and
measures operator
has taken, or will
take, to address
them. (2) Community
participation
required before a
person formally
submits an
application for a
hazardous waste
management facility
permit.
Idaho The legislature
adopted the Haz-
ardous Waste Fa-
cility Siting
Act, Idaho Code
(1C), 39-5801 in
1985. That act
largely in-
structs the de-
partment of
Health and Wel-
fare to promul-
gate a more com-
prehensive Haz-
ardous Waste
Management Plan.
The plan was
adopted in March,
1987.
Persons who con-
struct, expand,
enlarge or alter
commercial haz-
ardous waste dis-
posal, treatment or
storage facilities
or any on-site
land disposal fa-
cilities of cer-
tain categories
of waste must
first obtain a
siting license.
Owner or operator
must obtain such a
license.
No formal process.
No formal
preemption, but
local government
cannot
categorically bar
construction of a
hazardous waste
treatment and
disposal facility.
Hazardous Waste
Facilities Sitting
Act requires an
application
containing the name
and address of the
applicant, location
of the facility,
certain hydro-
geologic and
engineering data,
risks from trans-
portation, infor-
mation on the site's
impact on community
health. Other
procedures are
delineated
throughout the
matrix.
The statute requires
establishment of a
10 member site
review panel with
representation from
the state and public
in order to receive
public input early
in the process and
to approve, deny, or
add provisions to
the siting license
to mitigate public
concerns.
-------
FIGURE 2. (Cont.) SITING IN REGION 10 STATES
StateStatutory/Regula-
tory Schedules
and Authority
Applicability of
Siting Rules/
Regulations
Determination of
Need
Regulatory
Preemption
Permitting
Procedures
Community
Participation/
Negotiation
Oregon Siting provisions
contained in
Oregon Adminis-
tration Rules,
Chapter 340,
Division 120,
adopted March,
1986.
All hazardous waste
and PCB treatment
and disposal
facilities. Most
regulations apply to
the following: (1)
New off-site
treatment and
disposal facil-
ities for hazardous
waste and PCB. (2)
New hazardous waste
and PCB land
disposal facilities
located on-site.
Applicant must
provide implementa-
tion allowing DEQ
to make a determina-
tion there is a
"need" for a
facility. A
facility is
"needed" if: there
is a lack of
current treatment
/disposal capacity
to handle Oregon
generated wastes,
or it will result
in a higher level
of protection to
health and environ-
ment, or savings in
treatment/disposal
costs for Oregon
companies.
None specifically
provided for.
3-step permitting
process:
1. submit a re-
quest for and ob-
tain Authorization
to Proceed from
DEQ.
2. Submit a re-
quest for and ob-
tain a land use
compatibility
statement from
local government.
3. Submit an ap-
plication for and
obtain a treatment
or disposal permit
from DEQ.
to resolve con-
Committee of resi-
dents, partly ap-
pointed by local
government, liv-
ing near to or
along transporta-
tion routes par-
ticipates in
siting decision
considering such
issues as special
monitoring for
community health
risks, road im-
provements,
changes in pro-
perty values and
developing a plan
flicts and dis-
agreements be-
tween the com-
munity and the
operator.
Washington 1984-85 Revisions
to state law estab-
lished waste manage-
ment priorities,
capacity study,
siting standards,
local programs,
Citizen Proponent
Negotiations
(CPN), preemption
and private sector
role. Interim
siting standards
for disposal /incin-
eration facilities
are In place as
are guidelines for
local government
programs (zoning,
grants) . Final
siting standards
and CPN are under
development.
Interim siting
standards apply to
owners and operators
of landfills, incin-
erators, land
treatment facil-
ities, surface im-
poundments which
will be closed as
a landfill and
waste piles to be
closed as land-
fills (preempted
facilities) which
are required to ob-
tain interim or
final status per-
mits under
WAC 173-303-805/806.
No formal "need"
determination is
provided for,
although Department
is required to
develop a hazardous
waste management
plan including:
waste generation
forecasts, capacity
needs assessment,
and methods to
Implement the
statutory waste
management
priorities.
State prcfmptlon
authority to
approve, deny or
regulate disposal
and incineration
facilities,
although key roles
are provided for
local governments
in hazardous waste
management and
citizen proponent
negotiations.
Owners and opera-
tors applying for
a final facility
permit must com-
plete, sign and
submit that ap-
plication to DOE.
The information
required Includes
such information
as certain tech-
nical data, design
drawings and en-
gineering studies,
a general descrip-
tion of the facil-
ity, and a des-
cription of
security pro-
cedures.
Environmental
requirements must
al so be met.
Negotiation, media-
tion and other
conflict resolution
methods are encour-
aged when siting
disputes occur.
Ecology is now
designing a process
for (CPN). Public
hearings are
required when a
draft permit and
environmental
assessment is
issued.
-------
FIGURE 2. (Cont.1 SITING IN REGION 10 STATES
StateSizingPublic or
Restrictions/ Private
Waste Exclusion Ownership
Land Use Compat-
ability Showing
Mitigation of
Potential Risks
Host Community
Impac t/Property
Risk Assessment
Response to
Emergencies
Alaska
None.
Both public
and private
ownership
contemplated by
hazardous waste
facility siting
provisions.
Application must
include aerial
photographs, and
must demonstrate
that the hazardous
waste will not
escape the site
for 1000 years and
will not make con-
tact with the
nearest freshwater
acquifer for 1000
years. Several
geologic and seis-
mic reports must
also be submitted
showing contain-
ment qualities of
chosen site.
Certain locations
are excluded from
consideration
(special habitats,
ports, monuments
and wetlands).
Applicant must
obtain a written
agreement with
municipal or borough
government which
describes how the
facility will meet
specified operating
criteria necessary
for protection of
public health and
the environment.
In addition to
those require-
ments listed
elsewhere,
applicants are
required to
obtain an
agreement with
local govern-
ment describing
how owner/
operator will
mitigate for
changes in
property values
near facility.
Applicant for
permit of all
hazardous waste
management
facilities
(except storage)
must submit
a report identi-
fying risk
facility poses
to public on a
scale running
from safe
(10"6 risk) to
intrinsically
unsafe
(10~4 risk).
See also Fed.
Reg. Vol. 51,
No. 185, Wed.,
Sept. ?*f, 1986.
Contained in permit-
ting procedure.
Owner/Operator
describes how the
facility will re-
spond to on-site
emergencies and
assure safe
transportation.
Idaho None, but Haz-
ardous Waste
Management Plan
provide that the
Dept. of Health
and Welfare
should consider
placing restric-
tions on the types
of wastes accept-
ed for disposal
and treatment
based Inpart on
measures taken by
other states. Land
disposal ban re-
strictions In
place for sol-
vents, dioxins,
and California
list.
The Hazardous
Waste Manage-
ment Plan
encourages
Private owner-
ship, though
both public
and private
ownership were
apparently con-
templated.
No specific regula-
tions but statute
indicates that en-
gineering and
hydrology informa-
tion must be con-
tained in the
Siting License
Application.
Siting license ap-
plication must
give information
showing that harm
to scenic, his-
toric, cultural,
and recreational
values and risk
of accidents dur-
ing transport, will
not be substantial
or can be miti-
gated.
An owner of real
property who is
adversely affected
by a facility may
be compensated by
the facility
owner /operator
in an amount
equal to his
loss.
Application must No specific
address risks provisions.
from trans-
portation and
information on
site impact
on community
health. License
conditions
can be added
to address
these concerns.
-------
FIGURE 2. (Cont.) SITING IN REGION 10 STATES
State Sizing
Restrictions/
Waste Exclusion
Oregon Facility must have
capacity, in con-
junction with
other facilities,
to treat or
dispose of waste
generated over
the next 10 years
at a minimum in
Oregon, and, at a
maximum, for
wastes from the
8 NW compact
states. If
facility is larger
than what is need-
ed In Oregon,
owner /opera tor
must show addit-
ional size is
needed to make
the facility
economically
feasible.
Washington (1) Extremely
hazardous wastes
cannot be land-
filled (70 RCW
105.050)
(2) Land dis-
posal regula-
tions sre
being drafted.
Public or
Private
Ownership
Both public
and private
ownership
contemplated
by siting
provisions.
The most recent
siting provis-
ions establish
primary private
sector role in
providing waste
management
services.
Land Use Compat-
ability Showing
Applicant must
obtain local land
use approval.
Also, off-site
facilities must be
at least 3 miles
from larger popula-
tion areas (10,000
people or greater).
Facilities must be
one mile from
schools, churches,
commercial centers,
parks, scenic view
sites, resorts,
etc. Provision also
contains locational
restrictions based
on ecology,
geology, and
seismology
considerations.
Several require-
ments relating to
topographical and
geologic considera-
tions such as dis-
tance from aqui-
fers, fault lines,
unstable slopes,
coasts, surface
waters, and areas
where the soil has
subsided. Dis-
tance of public
Institutions,
parks, and other
high density popu-
lation areas is
also a factor in
siting decision.
Mitigation of
Potential Risks
Regulations recom-
mend local govern-
ment and the applic-
ant consider negotia-
tions to mitigate
impact.
No specific provi-
sions, but several
provisions in Draft
Location Standards
address minimizing
potential risks
associated with
hazardous waste
facilities.
Host Community
Impact/Property
DEQ recommends
that the local
government and the
applicant consider
negotiating an
agreement which
addresses the fa-
cility's potential
impact on property
values near the
site.
No specific provi-
sions in Interim
Siting Standards
or Draft Location
Standards. These
issues are an
integral part of
CPN which are
under develop-
ment.
Risk Assessment Response to
Emergencies
No specific Owner/Operator
provisions. required to
operate an emer-
gency response
team responsible
for responding to
spills within 50
miles of the
facility.
No specific pro- Owner/operator re-
visions, but risk quired to pay in-
assessment impli- creased cost for
citly included fire, hospital and
through the Draft other public fa-
Locational Stan- cilities. Roads
dards. leading to facil-
ity will be made
safer to trucks
carrying waste and
increased auto
traffic.
-------
D. HAZARDOUS HASTE MANAGEMENT IN THE NORTHHEST:
A STATUS REPORT
(EXECUTIVE SUMMARY)
-------
HAZARDOUS WASTE MANAGEMENT
IN THE NORTHNEST
A STATUS REPORT
PREPARED FOR THE
.S. ENVIRONMENTAL PROTECTION AGENCY
THE
STATES OF ALASKA, I
PREPARED BT
LEE N. SMS
CONSULTANT
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HAZARDOUS WASTE MANAGEMENT IN THE NORTHWEST
A STATUS REPORT
EXECUTIVE SUMMARY
AUGUST, 1987
Hazardous waste management data are collected and analyzed independently
and In somewhat disparate fashion by the Region 10 offices of the U.S.
Environmental Protection Agency and the pollution control agencies of the
northwest states. Accurate and comprehensive information regarding hazardous
waste generation and management will be needed soon if the industries and
governmental entities of the region are to establish a coordinated planning
program capable of identifying cost-effective means of compliance with new
statutory mandates. One important aspect of the emerging regulatory program
is the requirement that states demonstrate by 1989 that disposal capacity will
be available for all hazardous wastes expected to be generated in the next 20
years. Certification to that effect will be necessary if a state is to remain
eligible for remedial action funding through the provisions of the
Comprehensive Environmental Response, Compensation, and Liabi1ity Act.
An assessment of the status of hazardous waste and PCB waste control
programs in Region 10 was conducted in an attempt to characterize the
materials and current handling methods and to consolidate waste management
data from the four states (Alaska, Idaho, Oregon, Washington). The nature and
effectiveness of the data collection systems were also examined.
Hazardous Waste Generation
The most recent biennial reports (1985) and other documents were reviewed
so that sources and amounts of waste regulated pursuant to the Resource
Conservation and Recovery Act and companion state laws could be determined.
Eight hundred eighty-two major generators produced reportable quantities of
hazardous waste during 1985 (Alaska, 23; Idaho, 30; Oregon1, 206; Washington,
623). Fifty-seven percent of the generators were manufacturing plants and 297.
were trade, services or governmental organizations.
The Region 10 major generators reported 228,910 tons of hazardous waste,
exclusive of PCBs. Washington contributed 198,464 tons (86.7%); Oregon ,
26,813 tons (11.7%); Idaho, 2024 tons (0.9%); and Alaska, 1609 tons (0.7%).
Small quantity generators produced an additional 11,000-12,000 tons of waste,
and 30,000-60,000 tons of unregulated hazardous waste from households were
sent mostly to public solid waste landfills.
Manufacturing industries accounted for 86% of the waste, the largest
fraction (37.5%) coming from primary and secondary metals processors. Stone
and clay products industries produced 15.3% of the waste, transportation
equipment manufacturers 10.3%, and the electronics companies 4.5%. Only about
two percent of the waste came from cleanup of contaminated sites in 1985 (in
1984, the figure was nearly 20%).
Almost one-half of the wastes were those regulated only by the State of
Washington (104,349 tons, 46%), such as cement kiln dust, furnace black dross
and potlining from the aluminum industry, boiler fly-ash from the wood
products industry and fluxing salts from magnesium reduction. The dominant
RCRA-regulated wastes were metals (14%), corrosives (9%), electroplating
sludge (8%), steel emission dust (4%) and non-chlorinated solvents (4%).
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Disposition of Hazardous Waste
The Region 10 states ship waste to one another and to facilities in other
states for treatment and disposal. Waste is also imported to the region for
disposal. Nearly 10,000 tons of waste were exported from the region in 1985,
while 3694 tons were imported; thus, the region was a net exporter of
hazardous waste. Alaska exported 10% of its waste to other Region 10 states
and 40% to states outside the region. Idaho exported one-half of its waste to
Oregon and Washington and 38% to states outside the region, but also imported
twice as much waste for disposal as was exported. Oregon exported over
one-half of its waste (15,000 tons), but imported nearly 66,000 tons for
disposal, most of which came from Washington.
Region 10 wastes are often subjected to a series of reportable management
processes; the reports of each management practice result in double or triple
counting of some wastes, and therefore the generator and facility reports
cannot be easily reconciled. Imported wastes cannot be specifically tracked
either. Thus, the waste facility reports document the handling of
substantially more waste than is generated in a given year.
On-site storage (for over 90 days) accounted for 107,000 tons of waste in
the region in 1985 and 75,000 tons were stored off-site. The predominant
storage method (by weight) was waste piles. Nearly 10,000 tons of waste
received on-site treatment and 49,000 tons were treated off-site. On-site
disposal of 63,000 tons of waste was accomplished, while 77,000 tons were
disposed of at off-site facilities. Over 100,000 tons of Region 10 wastes
were landfilled and 45,000 tons were impounded as a treatment process or final
disposal; 1111 tons of waste were deep well injected in Alaska.
PCBs
Wastes containing polychlorinated biphenyls were considered separately
since they are regulated by the Toxic Substances Control Act rather than as
RCRA hazardous wastes. A limited special survey of electrical utilities and
other waste generators provided new insight regarding PCB waste generation in
Region 10. Concentrated PCB waste oils (greater than 500 ppm PCB) were
apparently generated in an amount falling within the range of 450-550 tons in
1985. Mineral oil wastes with PCB concentrations from 50-500 ppm may have
totaled 1200-1600 tons.
Disposal of waste transformer carcasses was estimated to amount to
2000-4000 tons. PCB-contaminted soil, debris and miscellaneous equipment
constituted 2000-3000 tons of waste. The generation of high concentration PCB
oil wastes in Region 10 is expected to increase slightly until 1988, remain
fairly constant until 1991, and then decline precipitously due to several
regulatory factors. The lesser-contaminated mineral oils, mostly present in
long-lived transformers, will remain in the waste stream in slowly declining
amounts for 15-30 years. PCBs are no longer being manufactured and have not
been distributed in commerce for some time; however, remedial action projects,
particularly in Alaska, will generate PCB wastes for 10 years or more.
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Projected Hazardous Naste Generation
Several elusive factors affecting the future generation of hazardous
waste in the region were crudely estimated as part of this assessment.
Economic growth, waste reduction practices, PCB equipment phaseouts and
implementation of remedial action (site cleanup) programs were projected to
produce a small net increase in waste generation over the 1985 level during
the next 20 years. The routinely generated wastes (non-cleanup) are expected
to decrease somewhat in the next 15 years due to waste reduction programs, but
ultimately increase from the 1985 base amount as a result of industrial
growth; however, the projection of other quite different scenarios could be
easily justified.
Hazardous Naste Management Technology
The Region 10 hazardous waste streams were generally analyzed in terms of
the applicability of alternative technology because of the impending limited
national ban on landfilling of wastes. One hundred twenty-six thousand tons
of Region 10 RCRA-regulated wastes (based on 1985 data) will be considered for
landfill ban by 1990 through the EPA regulatory process. Less than half of
that waste is being landfilled now (other than Washington-regulated waste).
Including contaminated soils, up to 60,000 tons of hazardous waste per
year might be amenable to incineration; however, two-thirds of that waste
would probably require fuel-assisted burning due to low potential heat
content. Wastes to be landfilled could increase or decrease depending on
economic factors arising from the treatment standards (most not yet
established) associated with the landfill ban statute. Increased recycling
and treatment of some categories of waste are probable. However, alternatives
to landfilling will not be readily available for some wastes, and the
stabilization and encapsulation processes which might be applied to those
wastes would substantially increase their volume prior to landfilling.
Waste Management Capacity
A review of waste management facility permit applications revealed a
potential regional on-site capacity for waste storage to be nearly 280,000
tons, far more space than actually occupied in 1985. On-site treatment
facilities would handle over 30,000 tons of waste per year, other than dilute
aqueous wastes which can be treated in very large volumes. Proposed on-site
incinerator capacity totals 4700 tons per year. Permit applications for
on-site disposal reflect facilities capable of handling three trillion tons of
wastewater per year by injection well (Alaska only), 57,000 tons by landfill
or land application, and 34,000 tons by impoundment.
Existing and proposed off-site storage facilities would provide space for
250,000 tons of waste, mostly in piles and impoundments. Various off-site
treatment facilities could handle up to 400,000 tons of aqueous inorganic
wastes, solvents, toxic anions and oily wastes. No commercial incinerators
exist in Region 10. One formal permit application has been filed for
construction of an incinerator which would burn up to 50,000 tons of waste per
year, and plans for a similar (competing ?) project have been informally
announced.
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Off-site landfill capacity as proposed for 10-year RCRA permits would be
about five million tons. The lifetime of the Idaho commercial landfill is
estimated by the company to be exactly 20 years (2007); such a rate of fill
would require the annual intake of waste in volumes 4-5 times as great as in
1985.
The Oregon commercial landfill would be full in 18 years (2005) at the
rate of fill experienced in 1985; in 12 years (1999) at the 1986 rate of fill;
and in 9 years (1996) at the rate of fill anticipated by the company.
However, note that the company owns much more land adjacent to the existing
facility which could be developed as landfill. The actual permit proposals
beyond the next 10 years cannot be anticipated.
Problems/Recommendations
Several problems were encountered when using the various hazardous waste
management data systems. Most of those problems relate to the unfami1iarity
of some generators with the reporting requirements and formats, the narrow
scope of required data, unsophisticated reporting systems in some states, poor
coordination of data collection processes in the region and the absence of a
suitable central data repository.
It is recommended that a regional or national hazardous waste data
management system be developed with the following features:
1. A single report form to be used by all states (or as the core of any
state-developed form) to collect data both from hazardous waste
generators and waste management facilities.
2. Surveys conducted at least annually and summary reports issued without
great lag time.
3. Clearly-stated reporting requirements, particularly With regard to
definitions of reportable wastes (for example, under what circumstances
are volumes of wastewaters reportable prior to treatment? Conversely.
when are treatment residuals reportable as newly generated wastes?)
4. An annual determination of the regulatory status of al 1 potential
generators.
5. Verification of all generator and facility-reported data by state
agencies and EPA (staff augmentation required).
6. Characterization of wastes in terms of physical form and all relevant
chemical components (within the limits of practical analysis) through
use of a more complex coding system.
7. Tracking of wastes throughout the country and reporting of treatment and
ultimate disposal of those wastes to the regulatory agency in the state
of origi n.
8. The capability to account for stored wastes at the beginning as well as
at the end of a reporting period.
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9. More detailed description of waste treatment processes through a more
complex coding system.
10. The capability to compare the volumes of various wastes on an annual
basis and to determine the degree to which each generic means of waste
reduction is employed by each category of industry.
11. The capability to determine the remaining permitted capacity of landfills
on an annual basis and the practical throughput capacity of treatment
facilities.
12. The entry of all core data into a commonly accessible automated system.
It is further recommended that the Region 10 states, individually or
collectively, conduct intensive studies of waste management capacity and waste
reduction potential as soon as practicable. The advice and assistance of the
waste generating industries and waste management businesses should be
solicited to assure success of the investigations.
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E. WASTE REDUCTION:
AN ISSUE PAPER
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HAZARDOUS HASTE REDUCTION:
AN ISSUE PAPER
Prepared for:
A Positive Future:
Hazardous Waste Management
in the
Pacific Northwest
A Hazardous Waste Management Symposium
October 19-21, 1987
Seattle Sheraton Hotel
David toll
Hazardous Reduction Specialist
Oregon Department of Environmental Quality
October 1981
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INTRODUCTION
Since the passage of the National Environmental Protection Act in 1970,
state and federal regulations have brought about significant progress in
the effort to control hazardous wastes in the Northwest and the nation.
However, comparatively little progress has been made toward reducing or
eliminating these wastes at the source. This fact was highlighted by
recent studies by U.S. Environmental Protection Agency (EPA) and the
Congressional Office of Technology Assessment (OTA) on hazardous waste
reduction which stated that of the $70 billion or more spent per year by
industry and government to manage and dispose of hazardous wastes, less
than one percent is spent on pollution prevention. Meanwhile, the total
quantities of hazardous waste generated continues to increase every year.
For both business and environmental reasons, waste reduction, as defined in
this paper, is generally accepted by industry, government and
environmentalists to be the most appropriate alternative to generation and
management of hazardous wastes. It is also the alternative that is
understood least. This paper focuses on waste reduction and the issues
that come with it, hoping that the ensuing discussion about a Pacific
Northwest hazardous waste management strategy will inform, educate, and
foster a commitment to waste reduction.
FUNDAMENTAL DIFFERENCES
Barriers to wide spread implementation of waste reduction practices are
described in another section of this paper, but clearly, part of the reason
for low implementation rate lies in the fact that hazardous waste reduction
is fundamentally different from traditional pollution control strategies.
Environmentally, an industrial process that reduces the generation of waste
is different from an "end-of-the-pipe" strategy that merely attempts to
remove, not eliminate, pollutants prior to discharge. An "end-of-the-pipe"
approach assumes that the pollution problem will be perpetual, while a
waste reduction approach tries to find a better production process that
doesn't create wastes in the first place. The "end-of-the-pipe" approach
does little to reduce the long-term environmental risk from pollution
whereas a waste reduction approach reduces environmental risk by
eliminating risks associated with waste handling, storage, transportation,
treatment and disposal. By looking at the industrial process as a whole
instead of just what leaves the smokestack, wastewater outfall or loading
dock, waste reduction promotes overall industrial efficiency.
In much the same way as an earlier idea - energy conservation - became an
integral part of energy supply planning in the Northwest, hazardous waste
reduction can be an integral part of the hazardous waste management
solution now. But like energy conservation, waste reduction will require
fundamentally different programs and procedures.
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DEFINING POLLUTION PREVENTION
There continues to be national discussion between industry, EPA, the U.S.
Congress, environmental groups, and the states about the definition of
pollution prevention and what specific industrial practices should be
promoted and/or developed by government.
As defined by the U.S. Congress and several states, hazardous waste
reduction means any in-plant practices that reduce the environmental
hazards associated with the waste without diluting or concentrating the
waste. This definition does not include any practice applied to waste
after it is generated and leaves the production process.
This definition applies to all non-product hazardous or toxic outputs put
into all environmental media (water, air and land) even though they may be
within permitted or licensed limits. This comprehensive definition is
necessary in order to avoid creating the myth of reduction by shifting
waste from one environmental medium to another unregulated or less
regulated medium, as has been done in the past, for example, by allowing
trichloroethylene (TCE) releases into the air as an unregulated waste.
The goal of waste reduction is to find ways to change the present
industrial processes and to design future industrial processes that will
reduce the environmental risk by reducing the quantity of hazardous and
toxic wastes generated at the source. To this end, the following practices
are included in the definition of waste reduction:
1. Input Substitution - replacing a hazardous substance used in a
production process with a non-hazardous or less hazardous
substance;
2. Product Reformulation - substituting for the end product an end-
product that requires less waste intensive manufacturing process;
3. Production Process Redesign - using production processes that are
fundamentally different than those currently used;
4. Production Process Modernization - replacing existing equipment
with new equipment based on the same process, but modified to
generate less waste;
5. Improved Operation and Maintenance - modifying existing equipment
and/or methods of using that equipment or modifying management
procedures to reduce waste generation; and
6. Reuse (in-process) - using a waste directly in the production
process.
These options all reduce the volume of waste generated without handling,
storage or transporting, thus keeping the environmental risks at an
absolute minimum.
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Waste Minimization;
Under the Resource Conservation and Recovery Act (RCRA), as amended in
1984, the Congress declared it to be the national policy of the United
States that, where feasible, the generation of hazardous wastes were to be
reduced or eliminated as expeditiously as possible. However, waste that
was generated will be treated, stored, or disposed of so as to minimize the
present and future threat to human health and the environment.
To this end, EPA requires that each hazardous waste generator sign a
certification statement, on the Uniform Hazardous Waste Manifest, that they
have a program in place to reduce the volume and toxicity of wastes
generated to the degree they determine to be economically feasible.
In addition, each generator who ships hazardous waste off-site, must
prepare a biennial report which among other things, describes the
generators efforts to reduce the volume and the toxicity of waste. These
generators must also describe the actual change in quantity and toxicity
during the reporting period.
Although there is no definition or guidance regarding these terms in RCRA,
EPA has adopted "waste minimization" as the term that encompasses what
would be allowed in a certifiable program for generators. EPA appears to
have settled on a definition of waste minimization that includes waste
reduction, as defined above, chemical reuse and both on-site and off-site
recycling. In addition, EPA, in an effort to set a program moving at the
national level, expects to develop non-regulatory technical assistance
programs to foster the development and wide-spread use of these options,
with the emphasis being put on waste reduction as the method of choice.
This recognizes for the first time by EPA, the primacy of preventive
practices over pollution control.
ADVANTAGES TO WASTE REDUCTION
Although waste reduction is the least developed and understood of the waste
minimization options, it has clear advantages over recycling and other
conventional pollution control practices.
Specifically, with regard to waste management costs, the current series of
land disposal restrictions under the 1984 RCRA amendments limits the number
of wastes that can be disposed of on land. These amendments also impose
more stringent standards on surface impoundments, which, according to EPA,
means that about half of those now in operation nationally will close.
(For example, Chem-Security's site at Arlington, Oregon is closing about a
dozen of its impoundments.) Therefore, prices for alternative waste
treatment are expected to rise dramatically as generators compete for
scarce treatment capacity.
As hazardous waste management companies seek new treatment and
or disposal sites, they encounter that familiar NIMBY syndrome ("Not in My
Backyard"). This makes siting new facilities extremely difficult, if not
impossible, and exacerbates the already limited disposal and treatment
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capacity problem. The net result of this is that some generators may be
faced with the situation where the only option available is waste reduction
to eliminate a waste stream from their industrial process.
For Pacific Northwest industry, waste reduction is an economically
attractive practice. By reducing the generation of hazardous wastes at the
source, generators can get more from their resources, decrease waste
management and regulatory compliance costs, reduce liabilities and create
additional revenues from the recovery of what once was considered waste.
Such savings will only help Northwest companies improve their
competitiveness and profitability.
Waste reduction also benefits state and local governments by reducing
wastewater treatment costs and disposal landfill requirements, thereby
increasing the potential capacity for industrial growth and diminishing the
need for major capital expenditures for landfills and treatment facilities.
Waste reduction develops positive relations between industry and the
public. In most cases, companies that establish hazardous waste reduction
practices have reaped an added benefit of being seen by the public as a
good corporate citizen.
Finally, whereas some waste minimization alternatives such as recycling may
require new permits or produce regulatory and liability problems for
generators, waste reduction does not. Waste reduction options, as defined
earlier, deal with changes to the production process which is not regulated
under RCRA. The regulated chemicals are treated as wastes only after they
exit the production process. Thus, a process change that reduces the
amount of wastes could actually reduce the overall regulatory burden.
Waste reduction stands alone as the only option for generators with this
benefit.
Put simply, waste reduction makes the most business and environmental
sense. For every dollar invested in waste reduction is a dollar invested
in industrial efficiency which keeps hazardous waste from being generated
and, therefore, will not require handling, shipping, storage, or disposal.
BARRIERS TO WASTE REDUCTION
In spite of these seemingly overwhelming economic, environmental, public
relations, and regulatory benefits inherent in hazardous waste reduction
practices, few Northwest generators are actively pursuing this alternative.
The reasons for this are varied and there is generally a lack of consensus,
nationally; about the importance or priority each should have. However,
the barriers are as follows: economic, technical, educational, corporate
and regulatory.
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Economic Barriers:
Although waste reduction practices often lead to cost savings, capital for
plant modifications is not always available. This problem is particularly
acute in small and medium sized companies. In addition, companies that
have already made modifications for other reasons are reluctant to
capitalize new changes until they can amortize the original investment.
Also, some waste reduction practices may not be cost effective in that
reducing some wastes small amounts may be achievable only at great expense.
Technical Barriers:
Ultimately, there are technical limits to waste reduction practices since
certain products cannot be manufactured without producing wastes. However,
the one major technical deficiency is the lack of experience with waste
reduction practices.
While U.S. and international examples of innovative waste reduction
applications are many, they don't even begin to scratch the surface of
potential technical options. A strong commitment to technical innovation
in the design and operation of industrial processes, specifically for
hazardous waste reduction purposes, could eliminate this deficiency. The
lack of such a commitment would be a barrier to waste reduction
implementa ti on.
Second, although many good waste reduction examples exist, few companies
are aware of them. Existing technical information has not been
consistently developed and distributed to potential users of the
technologies.
Educational Barriers;
Historically, environmental engineers have learned the skills of pollution
control "end-of-the-pipe" technologies, but have not learned much about the
industrial processes that generate the environmental pollutants.
Similarly, industrial engineers have been taught how to design new or
modify existing processes but not necessarily with the focus of reducing
the generation of hazardous wastes. And, engineering schools, in general,
have not seen fit to teach the practical side of waste reduction in the
production sector. In fact at some schools such endeavors are believed to
be insignificant to the theoretical aspects of engineering.
All of this adds up to a very large educational barrier to waste reduction
implementation in the long run.
Corporate Barriers;
There are several aspects of corporate operations that effectively act as
barriers to waste reduction.
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First, there seems to be a lack of interest in new methods. The
manufacturing process is the life-blood of a manufacturing company, fine-
tuned by trial-and-error over years of operation. To suggest that a
company should do something different, especially if the company is
profitable, is not of interest.
Second, in many industries there is a regular change of products and
processes to make those products. Although this can be a help in
implementing waste reduction technologies, it can also be a major barrier
since many processes use new chemicals producing new wastes which may not
be regulated. In this environment of regulatory uncertainty and with
limited capital resources, industry is reluctant to do more than is
specifically required of them.
Third, to be successful, waste reduction, much like energy conservation,
requires that everyone at all levels of the production process be involved
in looking for the possibilities. Also, hazardous waste management costs
should be charged to the unit that generated the waste. This requires a
level of corporate policy and commitment that can only be achieved at the
highest levels of the structure. Getting the attention and achieving this
commitment is not always easy.
Fourth and finally, waste reduction is perceived as a long-term ideal
rather than an immediate solution for industry to pursue. Even though
industry agrees that waste reduction should be done, it has been caught up
in the "end-of-the-pipe" approach for so long that treatment and disposal
are what they do because that's what they know best. However, it must be
said that industry has only been taking its cue from EPA which has
primarily promoted treatment and disposal.
None of these barriers are prohibitive , however, if the resources to
acquire the knowledge, develop the financial incentives, and make policy
decisions are made a priority.
Regulatory Barriers:
As mentioned earlier, there are no direct regulatory restrictions that
would make it difficult for a company to implement waste reduction
practices or techniques. However, RCRA appears to be a double edged sword.
There are inherent, indirect problems with the regulations.
In the OTA report on waste reduction, it is pointed out that federal
regulatory programs can be counterproductive to waste reduction, in that
they are driven by existing pollution control "end-of-the-pipe" technology
rather than by health and environmental considerations. Because these
regulations legally allow the disposal of hazardous wastes into the
environment, they do not foster waste reduction practices. This fact has
effectively kept attention and resources of the generator directed away
from waste reduction since it is very expensive to comply with the
regulations and develop waste reduction capabilities at the same time.
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Another regulatory barrier has surfaced for some companies that manufacture
products that are regulated by other agencies (FDA, OSHA. etc.). In some
cases the reduction of hazardous wastes can produce a product that is not
recognized under other regulations, thereby producing an unmarketable
product.
CONCLUSIONS
1. Waste reduction is a viable, cost-effective, and environmental
preferred method for preventing hazardous waste pollution in the
region.
2. Waste reduction, in many applications, is the lowest cost option for
dealing with hazardous wastes and should be encouraged by industry,
trade associations and government.
3. There are no substantial technical reasons for delaying the
implementation of a regional or state waste reduction program.
4. The primary barrier to wide-spread implementation of waste reduction
practices is educational in nature. A program to provide the
information and know-how available from existing examples is what is
needed, immediately.
5. On a regional basis, waste reduction, could be the lowest cost
component in the regional hazardous waste capacity equation and should
be developed as a resource similar to energy conservation's resource
role within the Northwest energy mix.
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F. SYMPOSIUM EVALUATION FOI
APRIL 28-28, 1987
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SUMMARY OF EVALUATION F(
HAZARDOUS HASTE MANAGEMENT APRIL 28/29, 198]
Prepared-for:
A Positive Future;
Hazardous Haste Management
in the
Pacific Northwest
A Hazardous Waste Management Symposium
October 19-21
. Seattle Sheraton Hotel
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SUMMARY OF EVALUATION FORMS
Background
Attendees at the April 28/29 Symposium -- "Challenges and Opportunities:
Managing Hazardous Wastes in the Pacific Northwest" — were given a
questionnaire asking them to assess the conference (its treatment of the
issues, usefulness, etc.) and provide recommendations regarding the follow-up
fall symposium. A copy of the questionnaire is attached to this summary.
The attached summary is provided for the information of the participants,
with these comments:
• The summary represents input from approximately 100 attendees,
approximately one-quarter of those in attendance,
• It is by no means intended to convey the results of a "scientific"
survey, but is merely to summarize the comments we received,
• (and), The comments received were not ranked in any priority
order. They simply repeat the most commonly-held conclusions or
observations.
The comments were helpful in the planning efforts of the Conference Steering
Committee. The summary follows.
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SUMMARY OF EVALUATION FORMS:
April 28/29 Hazardous Haste Capacity Symposium
General Observations from Conference:
1. Credible and useful framework with which to address the issues (waste
reduction, capacity, and how to go about the siting process). Generally
impressed with mix of attendees.
2. Widespread belief that current hazardous waste management capacity is
inadequate (particularly by industry and public sector employees — and
to a large extent by elected officials).
3. Waste reduction efforts must be pursued more vigorously. Many wanted
to know how much we can reduce hazardous wastes.
4. Generally expressed interest in "regional" solutions and efforts,
addressing such topics as the waste stream/capacity issue, policy level
and financial support of waste reduction, EPA technical and financial
assistance.
5. Interest in regional political process to lead to gubenatorial
endorsement for working on the issue(s).
Comments on Format and Organization of Follow-up Session:
1. Target certain issues and attempt to make some progress in dealing
with them in the Northwest.
2. Make it more interactive — via small group sessions on specific
topics. Use groups to float some ideas/recommendations.
3. More reports on success stories requested by elected officials.
4. Would like larger percentage of "public interest" representation —
including more elected officials.
Suggested Topics for Fall Conference:
1. Waste Reduction:
• More success stories — industries in this region
• Discussion of type approaches useful to foster reduction efforts
in the Northwest (regulatory, technical assistance/voluntary)
• How much can we realistically expect reduction to contribute?
• Federal solid waste definitions/regulations — do they result in
encouraging waste reduction?
• What about Small Quantity Generators (SQGs) and reduction?
Report on waste reduction and recycling.
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SUMMARY OF [VALUATION FORMS:
April 28/23 Hazardous Haste Capacity Symposia (Cont)
2. Regional/State Haste Stream Data and TSD Capacity:
• What do the numbers tell us?
• Need credible capacity effort as way to help get by the waste
reduction vs. siting gridlock.
• What is the relationship between regional political lines and the
nature of the hazardous waste TSD market?
3. Siting New Capaci ty:
• Regional siting efforts — does it make sense and how would we
begin to address in the Northwest?
• Trade-off: siting and permitting a facility vs. risk of
transportation.
• Other regions' experiences with siting — more on case studies
looking at particular types of issues (e.g., siting approach,
technologies, risk, public involvement).
• Public and private roles in siting (selection, ownership and
operation).
4. Siting and Public Involvement:
• Environmentalist panel: successful scenarios in siting.
Building involvement and trust.
• Use of mitigation and compensation in siting facilities.
• Innovative dispute resolution techniques.
5. Uncertainty and Ri sk:
• Risks and benefits of on-site vs. off-site commercial treatment.
• Health risks of incineration.
• Innovative technologies: do we allow higher level of risk?
• Risk of not having capacity
6. Treatment and Destruction Issues:
• Economics of hazardous waste incineration (facility size,
mobile vs. fixed, liability, public/private questions).
• Most promising technologies and ways to regionalize
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OF EVALUATION FORMS:
April 28/29 Hazardous Waste Capacity Symposium (Cont)
7. Interstate and Regional Efforts:
• What are the legal, economic and political barriers to Regional
hazardous waste management approaches?
• Exploration of regional approaches (e.g., waste exchange,
waste reduction efforts).
• What are the priority areas for regional hazardous waste
management efforts?
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APRIL 28-29, 1987 HAZARDOUS WASTE CAPACITY SYMPOSIUM
EVALUATION FORK
Your response to the following questions will help us assess the first
symposium and plan tne second symposium tnis fall.
1) Please identify the location of organization/ousiness you are
representing:
( )Alasna ( )Idano ( )0regon ( )Wasnington
( )other (please identify) .
2) Please identify the nature of oryanization you represent:
( ) Federal Elected official ( ) Media
( ) State Elected Official ( ) State Agency
( ; Local Electee Official ( j Local Agency
( ) Large Business ( ) Federal Agency
( ) Small Business \ ) Academic*
( ) Environmental Group ( ) Consulting Firm
( ) Private Bar ( j Otner
3) Why did you decide to attend tnis conference? Wnat conference topics
suojects are of relevance to you? Wnat expectations (if any) did you
nave?
4) What observations do you nave about tnis conference? Was it useful?
Were major topics/issues omitted that you think are important?(etc)
5) How would you characterize tne hazardous waste reduction treatment or
disposal options (waste reduction, off-site treatment, etc.) available
right now in tne Pacific Northwest? In your opinion, are they currently
adequate or inadequate? Why?
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6) What comments/suggestions do you nave that would help us plan for the
follow-up symposium trns fall?
What topics should De covered?
What areas of furtner investegation/researcn would you suggest we
pursue oetween no* and then?
What rule should regional cooperation play in addressing hazardous
waste/PCb management issues for the Northwest?
7) Do you plan to attend tne second symposium?
( )yes ( )no
Tnank you for taking time to answer these questions. Please leave this on
your chair wnen you leave.
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G. REGIONAL STEERING COMMITTEE BIOGRAPHIES
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JONATHAN ATER
ATTORNEY-AT-LAW
LINDSAY, HART, NEIL & WEIGLER
PORTLAND, OREGON
Jonathan Ater is the managing partner of the firm's energy and
environmental practice groups. He is also active as a general corporate
lawyer with experience in finance and large corporate transactions of all
kinds. He has extensive experience representing industrial clients in energy.
legislative, and general business matters since 1966.
Mr. Ater is a graduate of Yale College and Yale Law School where he was
on the Law Journal and elected to the Order of the Coif.
JAMES MICHAEL "MIKE" CALDWELL
COMMISSIONER
LAGRANDE, OREGON
James Michael "Mike" Caldwell has been the Union City Commissioner since
1980 and was re-elected in 1984. Prior to this appointment, he was a board
member of the LaGrande City Council.
Mr. Caldwell has served on various state of Oregon committees including
the Department of Environmental Quality Policy Advisory Committee and Rural
Lands Committee.
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JOAN M. CLOONAN
ASSISTANT GENERAL COUNSEL
J.R. SIMPLOT COMPANY .
BOISE, IDAHO
Joan M. Cloonan is currently Assistant General Counsel for the J.R.
Simplot Company. Ms. Cloonan is responsible for all energy, public utility,
and environmental matters.
Prior to this appointment, she was a trial attorney with the Pollution
Control Section, Division of Land and Natural Resources, of the U.S.
Department of Justice in Washington, D.C. and was an attorney with General
Electric Company.
Dr. Cloonan earned a Bachelors Degree Magna Cum Laude in Chemistry for Le
Moyne College of Syracuse and a Doctorate in Chemistry from Cornell
University. She holds a J.D., Magna Cum Laude, from Florida State University.
CHERYL F. COODLEY
ASSISTANT ATTORNEY GENERAL
DEPARTMENT OF JUSTICE
PORTLAND, OREGON
Cheryl F. Coodley is the Assistant Attorney General for the Oregon
Department of Justice. Her responsibilities include all environmental and
land use issues pertinent to the state of Oregon.
Prior to this position, Ms. Coodley was with Ball, Janik and Novack law
firm.
Prior to this, Ms. Coodley was the Chief Counsel and Staff Director,
Subcommittee on Investigations and Oversight for the U.S. House of
Representatives' Committee on Science and Technology.
Ms. Coodley earned a B.A. in Political Science from Bryn Mawr College; a
J.D. from the Boston University School of Law; a L.L.M. in Marine Law from the
University of Washington.
Ms. Coodley was appointed the Chair of the Advisory Task Force on
Hazardous Waste, Department of Environmental Quality for the state Oregon.
She is also a member of the National Board of Advisors, University of Oregon
Law School Journal of Environmental Law and Lititgation.
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RAM CROCKER-DAVIS
STATE REPRESENTATIVE
NATIONAL AUDUBON SOCIETY
LACEY, WASHINGTON
Pam Crocker-Davis has been a state representative of the National Audubon
Society of Washington State since 1981. She is also on the Puget Sound
Al1iance Counci1.
Prior to this appointment, Ms. Crocker-Davis was the founder and director
of the Western Washington Toxics Coalition.
Ms. Crocker-Davis earned a Bachelor's degree in History from the
University of Washington. She also attended the graduate School of Public
Affairs at the University of Washington, where her major focus was on
environmental policy and resource management.
Ms. Crocker-Davis is an active memeber of numerous boards and advisory
councils. In 1986 she received the State of Washington Award for
Environmental Excellence.
DENTON DARRINGTON
STATE SENATOR
STATE OF IDAHO
BOISE, IDAHO
Denton Darrington has been an Idaho State Senator for three terms.
Senator Darrington authored SB 1172 which recently passed the Idaho
Legislature. The statute established procedures by which PCBs may be
incinerated at concentrations of less than 50 parts per million.
He is the Chairman of the Health and Welfare Committee. He has taught
History for 21 years at Burley Junior High in Delco. He also has a small
dairy farm in Delco.
Senator Darrington received his B.S. in agricluture from Utah State. He
is active in the local Historical Society and Farm Bureau.
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FRANK DEAVER
CORPORATE ENVIRONMENTAL SERVICES MANAGER
TEKTRONIX, INC.
BEAVERTON, OREGON
Frank Deaver is the Corporate Environmental Services Manager for
Tektronix, Inc. Mr. Deaver is involved in environmental management activities
which includes sanitary and industrial waste treatment management, treatment
plant design, air/exhaust programs, hazardous waste management, and
environmental legislation analysis.
Mr. Deaver is active in many outside organizations including the
Association of Oregon Industries, America electronics Association, Machinery
and Allied Products Institute. He has served as a member of the Regional
Landfill Siting Committee and the Solid Waste Advisory Committee for the State
of Oregon.
BETTYE FAHRENKAMP
STATE SENATOR
STATE OF ALASKA
FAIRBANKS, ALASKA
Bettye Fahrenkamp was elected to the Alaska State Senate in 1978.
Currently, she is the Vice-Chair for the Citizens Advisory Commission on
Federal Areas; Member, Senate Labor and Commerce Committee; Member, Senate
Transportation Committee; Chair, Senate Special Committee on Oil and Gas
Committee; and Chair, Legislative Council. She is also a member of the
National Association of Women Legislators; National Conference of State
Legislators; and Chair-elect of the Western Legislative Conference.
Prior to this appointment, Senator Fahrenkamp was Chair for the Central
District Democratic Committee and Democratic National Committeewomen from
Alaska. She has worked as a Special Assistant to former U.S. Senator Mike
Gravel.
Senator Fahrenkamp earned a B.S. from Tennessee State University; a M.A.
from University of Alaska; and earned a Rate Separation Certificate from
Michigan State University.
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RICHARD D. FORD
MANAGING PARTNER
PRESTON, THORGRIMSON, ELLIS & HOLMAN
SEATTLE, WASHINGTON
Richard D. Ford joined Preston, Thorgrimson, Ellis & Holman in 1985.
Prior to this, he was the Executive Director of the Port of Seattle, the
region's largest owner/operator of major marine and air terminal facilities.
He also served as the General Counsel to the Port of Seattle, represented the
Washington State County Commissioners before the Legislature, and was in the
Office of the Secretary of the Treasury in Washington, D.C.
Mr. Ford is an Adjunct Professor at the University of Washington,
Graduate School of Public Affairs and the School of Business Administration.
Mr. Ford has served as Board Chair of a local savings and loan
association and is active in numerous professional organizations and civil
activities.
He earned a B.A. from Washington State University and J.D. from
Georgetown University.
FREDERICK J. HANSEN
DIRECTOR
DEPARTMENT OF ENVIRONMENTAL QUALITY
PORTLAND, OREGON
Frederick J. Hansen has been the Director of the Oregon Department of
Environmental Quality since 1984. As director, he oversees all the major
state environmental programs which includes clean air, clean water, hazardous
waste, and solid waste. He has a staff of approximately 300 employees.
Prior to this appointment, Mr. Hansen was the Chief Deputy State
Treasurer for the state of Oregon. His responsibilities included supervising
the state of Oregon's $5 billion in investments, $6.7 billion in outstanding
bonded debt and an annual cash flow of $7.5 billion.
Mr. Hansen earned a B.A. degree in mathematics and history from the
University of Oregon and a M.A. degree in history from McMaster University.
He also did one year Doctoral work in history at the John Hopkins University.
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TONY KNOWLES
MAYOR
CITY OF ANCHORAGE
ANCHORAGE, ALASKA
Tony Knowles was elected Mayor of Anchorage in November 1981 and
re-elected In October 1984.
Prior to Mayor Knowles' appointment, he served in the Borough Assembly
and Municipal Assembly following unification of the borough and city
governments. In 1972, he served on a citizen's committee to develop a
comprehensive plan for Anchorage's growth and development.
Under Mayor Knowles' leadership, the Municipality of Anchorage has
developed and implemented long-range plans for managing solid and hazardous
waste, with particular emphasis on household and small generators.
Mayor Knowles received a bachelor's degree in economics from Yale
University. He has served on a number of civic committees as well as sports
facilities committees.
JEAN C. MEDDAUGH
ASSOCIATE DIRECTOR
OREGON ENVIRONMENTAL COUNCIL
PORTLAND, OREGON
Jean C. Meddaugh is Associate Direcot for the Oregon Environmental
Council. The Oregon Environmental Council is a non-profit organization
interested in protecting and monitoring all environmental issues withing the
state of Oregon. The council oversees Department of Environmental Quality
programs as well as other state agencies.
Ms. Meddaugh is a member of numerous environmental and hazardous waste
committees in Oregon.
Ms. Meddaugh received a B.S. in Resource Development and Environmental
Management from the University of Oregon Department of Planning, Public
Policy, and Management, Summa Cum Laude.
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GILBERT S. OMENN
PROFESSOR OF MEDICINE AND ENVIRONMENTAL HEALTH
DEAN OF THE SCHOOL OF PUBLIC HEALTH AND COMMUNITY MEDICINE
UNIVERSITY OF WASHINGTON
SEATTLE, WASHINGTON
Gilbert S. Omenn is Professor of Medicine and of Environmental Health and
Deanof the School of Public Health and Community Medicine at the University of
Washington, Seattle. His research and public policy interests lie in areas of
genetic predisposition to environmental and occupational health hazards,
chemo-prevention of cancers, the improvement of science-based risk analysis,
and applications of genetic engineering.
Dr. Omenn received an A.B. from Princeton, M M.D. from Harvard, and a
Ph.D. in Genetics from the University of Washington. His internship and
residency in internal medicine were at the Massachustetts General Hospital.
He was research follow at the Woods Hole Oceanographic Institution, the
Brookhaven National Laboratory, the Weizmann Institute of Science in Israel,
and the National Institutes of Health in Bethesdam Maryland. He was also a
White House Fellow at the Atomic Energy Commission, as well as deputy to Frank
Press, President Carter's Science and Technology Adviser and Director of the
White House Office of Science and Technology Policy.
He has written numerous research papers and scientific reviews on
biomedical and genetic studies of brain functions; genetic predispositions to
drugs and other diseases; the diffusion and proper utilization of medical
technologies; and university/industry relationship, and other science policy
issues.
ROBIE G. RUSSELL
REGIONAL ADMINISTRATOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
SEATTLE, WASHINGTON
Robie G. Russell was appointed the Regional Administrator for Region 10
in August 1986. As Regional Administrator, he oversees the implementation of
all federal regulatory environmental programs in air, water, hazardous waste.,
and radiation. He has a staff of approximately 415 people including
operations offices in Alaska, Idaho, Oregon, and Washington.
Prior to this appointment, Mr. Russell was Senior Deputy Attorney General
for the state of Idaho. Mr. Russell was responsible for all matters
pertaining to Idaho cities, counties, special districts, election law,
planning and zoning, open meeting law, Indian law, state disaster planning,
and the offices of the Secretary of State. Other duties included litigation,
official legal opinions, legal guidelines and informal advice to clients and
public as well as the supervision of other attorneys, legal interns, and
clerical staff.
He earned a B.S. in Political Science, with emphasis in Public
Administration, English and History from the University of Idaho; a J.D. with
emphasis in Municipal Law and General Practice from the University of Idaho
College of Law. Mr. Russell has also done graduate work towards a Masters
degree in Public Administration.
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NEIL W. STANDAL
VICE PRESIDNET-GENERAL MANAGER
BOEING SERVICES DIVISION
THE BOEING COMPANY
SEATTLE, WASHINGTON
Neil W. Standal is a 29-year veteran of the Boeing Company and is the
Vice President-General Manager of the Boeing Services Division. He is
responsible for providing a corporate-wide focus on all common services
required to support company operations.
Mr. Standal is a graduate of Pacific Lutheran University, the University
of Washington AIMS program, and the Standford Executive Program.
WILLIAM E. SAUL
DEAN OF THE COLLEGE'OF ENGINEERING
PROFESSOR OF CIVIL ENGINEERING
UNIVERSITY OF IDAHO
MOSCOW, IDAHO
Dean William E. Saul has been with the University of Idaho since January
1984. His private sector expertise comes from his previous employment with
the Shell Oil Company, as well as extensive consulting work for engineering
firms. His educational expertise comes from teaching, researching, and
administration at the Michigan Technological University, University of
Wisconsin and the University of Stuttgart.
Dean Saul received a B.S. and a M.S. in Civil Engineering from Michigan
Technological University. He received his Ph.D. in Civil Engineering from
Northwestern University.
He is a member of the American Society of Civil Engineers, American
Concrete Institute, International Association of Bridge and Structural
Engineers, and the American Society for Engineering Education. He has
authored a book, Conference on Methods of Analysis, and numerous publications
and papers.
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JOLENE UNSOELD
STATE REPRESENTATIVE
STATE OF WASHINGTON
OLYMPIA, WASHINGTON
Jolene Unsoeld was elected in 1984 to the Washington State Legislature,
22nd District. Representative Unsoeld is currently the Vice-Chair of the
House Environmental Affairs Committee and is one of the major sponsors of HB
434 on State Superfund/RCRA. She is also a member of the Energy and
Utilities, and Higher Education, Selected Committee of Cleanup of Puget Sound
Committees. She played a major role in the adoption of the 1986 Water Sound
Financing Act. She was appointed in June 1985 to the Water Policy Committee
of the Western Legislative Conference of the Council of State Governments.
She was appointed in 1985 to be a board member of the Washington State
Institute for Public Policy. In 1986, she was appointed to the Northwest
Citizens Forum on Defense Waste.
Representative Unsoeld has been an independent citizen lobbyist,
consultant, and lecturer on legislative and political process, privacy, access
to public records, energy, and utility issues.
She is active both in political as well as professional and technical
committees.
LAWRENCE D. WEISS
EXECUTIVE DIRECTOR
ALASKA PROJECT
ANCHORAGE, ALASKA
Lawrence D. Weiss has been the Executive Director of the Alaska Health
Project since 1981. The Alaska Health Project is a non-profit organization
dealing in worker safety issues arising from exposure to hazardous materials
in the work place. The Health Project's activities include the Small Quantity
Generator Hazaroud Waste Minimization and Technical Assistance Pilot Project.
This pilot project conducts outreach and educational activities in support of
EPA's Small Business Initiatives to achieve small quantity generator
compliance with statutory and regulatory compliance.
Prior to this appointment, Dr. Weiss was an instructor in the Department
of Family, Community, and Energency Medicine, University of New Mexico School
of Medicine, as well as the Director of the Occupation Health Program and
Navajo Occupation Health Project at the University of New Mexico School of
Medicine.
Dr. Weiss earned his B.A. and M.A. in Sociology from the University of
California; his Ph.D. in Scoiology from the State University of New York; and
Postdoctoral Masters of Science in Occupational Health from the Harvard School
of Public Health.
Dr. Weiss is active on a number of advisory board, civic and professional
organizations. He has published numerous papers and books.
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