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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                                       11

           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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                                       16

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)
                                 -2-

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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
                                 -3-

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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.
                                 -4-

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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-

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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-

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     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-

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     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-

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                                                               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.

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                                                            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.

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                                                            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.

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                                                            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.

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                                                      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.

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                                                      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.









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                                                     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.










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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.








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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.

-------
     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.

-------
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

-------
        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.
                                  -1-

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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.
                                   -2-

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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


                                  -3-

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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.
                                  -A-

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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.
                                  -5-

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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.
                                  -6-

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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.
                                  -7-

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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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                                  -2-

                      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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                                  -3-


                             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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