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 ------- 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 ------- ------- * ~ \ 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 ------- 11 ------- 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. ------- A. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- B. COMPREHENSIVE HAZARDOUS HASTE The Next Step ------- 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 ------- 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. ------- 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. ------- 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. ------- 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: ------- 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 ------- 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. ------- 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: ------- 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.) ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- 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. ------- 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." ------- C. DATA/CAPACITY, HASTE REDUCTION AND SUING EFFORTS: STATE PROGRAM HIGHLIGHTS ------- 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 ------- 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. ------- 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- ------- 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- ------- 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- ------- Idaho Idaho's statute was passed in February 1985, and requires a hazardous waste management planning commission, consisting of 17 people representing diverse geographic areas of the state and specified by statute as to representation, to develop a hazardous waste siting management plan. The plan is required to provide for geographic distribution of treatment, storage or disposal (TSD) facilities and may instruct Idaho's Department of Health and Welfare (IDHW), and Idaho's Department of Water Resources and Transportation to conduct studies of waste inventory, waste practices, needs, incentives for cooperation, and alternative methods for treatment and disposal of hazardous waste. A plan has been developed and was adopted by the Legislature in March 1987. It directs IDHW to conduct educational programs regarding the public's responsibility for generating hazardous waste, to investigate procedures to establish household hazardous waste collection, segregation, treatment, and disposal, and directs local government to establish community information committees in the city or county where a new facility is proposed. In the area of alternative technologies, the plan directs the Idaho Legislature to evaluate tax incentives, foster research and development programs, and by directive to IDHW, limit land dis- posal of wastes that are amenable to alternative technologies, and make processing alternative technology permit applications a high priority. The plan suggests encouraging communication among states surrounding Idaho regarding siting and suggests that the state designate specific routes, favoring interstates and major highways for the transportation of hazardous waste. The plan notes that local government approval should be required regarding the designation of non-state highways for hazardous waste transport. The plan suggests that the Legislature either give fee authority to local city and county governments or establish a development fee as a permit condition to offset impacts of a hazardous waste management facility. The plan reinforces the concept of privately owned or operated facilities (as opposed to publicly owned or operated) and suggests the IDHW encourage the development of receiving, transfer, and storage facilities for small quantity generators. The plan states that the licensing procedure should be better coordinated with state and federal permitting processes. With regard to insurance, the plan suggests that the Idaho Legislature implement mechanisms for affordable environmental impairment insurance, such as tort law reform, state insurance fund, or regulatory control of insurance rates. The plan recom- mends that the state establish a state trust fund for post-closure -5- ------- cleanup of abandoned sites and for emergency cleanup purposes, and that adequate funding be provided for state departments for hazardous waste management. The plan also sets forth siting criteria which are identified as numerous hydrogeological and demographic characteristics, and suggests the Legislature establish incineration siting criteria. Finally, the plan also suggests the Legislature adopt legislation to allow state control of PCB waste disposal consistent with the federal Toxic Substances Control Act. With regard to licensing new facilities, Idaho's statute requires that a 10 member site review panel with representation from the state and the public be established to receive public input early in the permitting process and to approve, deny, or add provisions to the siting license to mitigate public concerns. The statute provides for state-preemption of local govern- ment. The statute also provides for district court review of property loss claims, if these claims are brought not later then nine months after approval of the permit application. Oregon Oregon's statute was passed in June 1985 and regulations were adopted in Spring 1986. The regulations specify a three step permitting procedure which require the applicant (a) to request and obtain authority to proceed, (b) submit and obtain a land-use compatibility statement from local government and state, and (c) to submit an application and obtain a permit.' An interesting component to Oregon's process is the require- ment of the applicant to provide information to allow the Oregon Department of Environment Quality (ODEQ) to make a finding that there is a "need" for the facility. "Need" is defined by the regulations as (1) lack of adequate current treatment or disposal capacity to handle hazardous waste or PCB generated by Oregon companies, (2) the proposed facility's operation would result in a higher level of protection of the public health and safety or environment, or (3) the proposed facility's operation will sig- nificantly lower treatment or disposal costs to Oregon companies, excluding transportation costs within states that are parties to the Northwest Interstate Compact on Low-Level Radioactive Waste Management. In addition, to establish "need," the proposed facility must significantly add to the range of hazardous waste or PCB management technologies already employed at a permitted treatment or disposal facility in states that are parties to the Northwest Interstate Compact on Low-Level Radioactive Waste Management. Notwithstanding the "need determination," ODEQ may deny a permit, if ODEQ finds the capacity at other facilities negates the need for a particular facility in Oregon. -6- ------- The regulations contain specific requirements regarding appropriate facility size (to match projected need), and they require best available technology. The regulations also contain setback requirements, and requirements to use a Groundwater Quality Protection Evaluation Matrix as a screen for locating proposed facilities. The applicant must demonstrate financial capability as specified in the regulations, and compliance history as defined in the regulations. The regulations contain specific land-use findings for local government to consider. Community participation is highlighted in the regulations, with the requirements that the Director of ODEQ appoint a com- mittee of citizens composed at least partly by residents living near to or along transportation routes to, the proposed facility site, and part by nominees of local government. The committee is charged with providing a forum for citizens' concerns and for preparing a report summarizing the concerns and the manner in which the company is addressing the concerns. The regulations also recommend that local government and the applicant consider negotiating an agreement appropriate for the potential impact. Mitigation possibilities such as special monitoring both on and off-site, for example, are mentioned in the regulations. Washington Washington's statute was passed in July 1985. It requires the Washington Department of Ecology (Ecology) to develop a state hazardous waste management plan to include waste generating forecasts, capacity needs assessment, methods for promoting the hazardous waste management priorities set forth by statute (minimization of hazardous waste, for example), and citizen involvement. Ecology expects the plan to be completed by June 1988. The statute established state preemption authority for disposal and incineration facilities, while also providing a key role for local governments in hazardous waste management and in citizen proponent negotiations (discussed below). Specifically, local governments are required to develop local hazardous waste management plans, and to designate local land use zones for storage and treatment facilities. One million dollars in grants are available to assist local governments in accomplishing these objectives and the state is required to develop guidelines to assist local governments in this endeavor. The statute also requires Ecology to promulgate siting standards. Ecology issued interim siting standards in January 1987, and expects final standards to be issued by the end of the calendar year. The law lists fourteen factors that may be con- sidered in establishing siting standards (such as geology, trans- portation, etc.). -7- ------- The statute also contains provisions concerning citizen proponent negotiation. The state has hired two professional mediators/negotiators to aid in preparing a guidance report on citizen proponent negotiation. The report will be designed to aid users (e.g., citizens, developer, and local government) on how citizen proponent negotiation may work. The report should be available by fall. Ecology is authorized by statute to issue regulations on negotiation processes and to spend money on it. Ecology is also intended to serve as an information clearinghouse on the subject. -8- ------- FIGURE I. WASTE REDUCTION State Alaska Why Program Established No program cur- rently exists. Emphasis Placed On Waste Reduction No Indication given. Sourer Reduction No formal statutory or regulatory plan. Recycling/ Re-use No formal program. Economic Incentives No formal program. Public Information Programs No formal program. Idaho To reduce the ex- pense to both indus- try and society. The Idaho Hazardous Waste Management Plan which was re- cently adopted by the legislature has as its mission to provide for the safe and effective management of haz- ardous wastes. The committee which formulated the plan was organized pursuant to I.C. § 39-5805. Listed as one among many haz- ardous waste man- agement options in State Siting Act and Hazardous Waste Management Plan. Recently adopted legislation lists source reduction as one of several facets of an over- all waste manage- ment plan. Recent legislation Hsts recycling and reuse as impor- tant parts of an overall waste man- agement plan. Hazardous Waste Management Plan provides that the legislature should consider tax credits and tax free bonds for construction of alternative tech- nology facilities. The Idaho Hazardous Waste Management plan calls for pub- lic hazardous waste workshops, pam- phlets, videos and slides produced in laymen's terms, educational semi- nars and TV and radio features. This public Informa- tion is directed toward the over.il] plan, not specif- ically at waste reduction. ------- FIGURE 1 (Cont.) WASTE REDUCTION State Why Program Established Oregon In hazardous waste statutes has priority over other hazardous waste management practices. Specific reasons for waste reduction (as listed in Oregon Revised Statutes 466 et seq. , and DEQ's Hazardous Waste Reduction Program Plan) include: more efficient use of re- sources, a decrease in waste management and regulatory com- pliance costs, re- duction of waste- water treatment costs and a reduc- tion in the risks to public health. Emphasis Placed On Waste Reduction The statutes and regulations do not indicate the rela- tive importance of waste reduction vis-a-vis other management options, but DEQ's report indicates that Oregon considers waste reduction a top priority. Source Reduction Hazardous Waste Management Regula- tions mention source reduction, but do not give a specific detailed plan. The Hazard- ous Waste Reduction Program Plan pre- pared by Oregon DEQ has source reduc- tion as a goal to be achieved by in- put substitution, product reformula- tion, product pro- cess redesign and improved operation and maintenance. Recycling/ Re-use Mentioned as a priority in Hazard- ous Waste Manage- ment Regs. , but more fully des- cribed in DEQ's Hazardous Waste Reduction Plan Program. Economic Incentives DEQ's report does not specifically provide for eco- nomic incentives, but does call for financial assis- tance. Public Information Programs No formal program within statutes or regulations, but DEQ's Hazardous Waste Reduction Program plan calls for a quarterly newsletter, produc- tion and distribu- tion of waste re- duction informa- tion, a waste reduction reference library, and a toll-free hotline. DEQ implementation of the Information/ education component of the program plan officially began In July, 1987. Washington No program currently exists. Study was mandated by RCW 70.105.150, 70.105.160, and 70.105.170. DOE published a comprehensive re- port on July 1, 1986, but its pro- visions have not yet been adopted as statutes or regulat ions. Number one priority in legislative declaration. See RCW 70.105.150(1) (a). Waste Management priorities established by statute. Hazardous waste section of the Dept. of Fcology published a comprehensive re- port In July 1986 covering both policy and technical waste reduction plans. Mentioned as a priority in statute, but no specific regulations have been adopted. Haz- ardous waste section of the Dept. of Ecology has pub- 1ished report which lists recycling and re-use as viable waste management options. Not specifically authorized by statute, but DOE's plan calls for higher land disposal fees so that generators will have more economic motivation to change their waste management practices to a more environ- mentally sound/ preferred method. No formal program as yet, although the statute authorizes a hazardous waste, hotline and provides that DOE must implement a plan or pro- gram to provide informa- tion and education about hazardous waste. DOE's plan calls for a consult- ative business outreach program, an Information waste exchange, technical workshops, education and information assistance, an award program, and a technical resource center. DOE currently provides technical assistance on a limited basis to Industry con- cerning hazardous waste management and recyclIng. ------- FIGURE 1 (Cent.) WASTE REDUCTION Educational/Tech- nlcal Assistance tancc State Research Grants/ Financial Assis- Alaska No formal program currently exists No formal program in existence. Idaho No formal program as yet, but the Idaho Hazardous Waste Management Plan lists educa- tional and techni- cal assistance as gools. The Hazardous Waste Management Plan in- dicates that Idaho Universities should pursue alternative waste management technologies, but makes no specific provision for research grants. ------- FIGURE 1 (Cont.) WASTE REDUCTION State Educational/Tech- nical Assistance tance Research Grants/ Financial Assis- Oregon Statute authorizes program which Oregon DEQ has included in its Hazardous Waste Reduction Program. This program calls for on-site hazard- ous waste reduction assistance, waste reduction seminars and a waste ex- change. DEQ's report pro- vides for creation of a Hazardous Waste Reduction Loan fund for loans to small and medium sized facilities for industrial pro- cess improvements that reduce wastes generated at the source. Wnshlngton No formal program as yet, although the statute authorizes DOE to provide consultative services and tech- nical assistance. DOE's comprehen s ive plan calls for technical workshops, a consultative serv- ice for businesses and ;; technical re- source center. No formal program in existence, although, DOE's report calls for attractive fi- nancing through municipal bonds (which are already specifically autho- rized under RCW 39.84 et seq.) loans and grants. These incentives are part of a broader incentive program for overall hazardous waste management and are not specifi- cally directed toward waste reduction. ------- FIGURE 2. STTING IN REGION TO STATES State Statutory/Regula- tory Schedules and Authority Alaska Draft regula- tion issued March 31, 1987, have had full public comment and have been issued pur- suant to authority of Alaska Statute (AS) 46.03, et seq. They are scheduled for adoption on December 15 , 1987, and are currently out for public comment. Applicability of Determination of Regulatory Siting Rules/ Need Preemption Regulations Including Owner/ Not formal part No formal Operator of a of process now. preemption. hazardous waste State has management facility conducted a which is: (1) a new waste stream TSD facility, (2) a analysis. Class I underground injection well, (3) required by EPA to obtain a permit, (M modified to include additional hazardous waste disposal or in- cineration capacity. Permitting Procedures Has a preap- plication procedure which requires, among other things: 1. published notice of the proposed project, 2. notification of the local govern- ment, and 3. a written agreement with the local govern- ment. The actual ap- plication requires written proof of compliance with the preapplication procedures, aerial maps of the pro- posed site, and a written summary of citizens concerns and responses Community Participation/ Negotiation (1) Committee may be appointed by the Dept. of Environ- mental Conserva- tion. Composed of residents living near or along trans- portation routes, persons appointed by local govern- ment, and other persons with technical skill. Committee prepares written report summarizing citizen concerns and measures operator has taken, or will take, to address them. (2) Community participation required before a person formally submits an application for a hazardous waste management facility permit. Idaho The legislature adopted the Haz- ardous Waste Fa- cility Siting Act, Idaho Code (1C), 39-5801 in 1985. That act largely in- structs the de- partment of Health and Wel- fare to promul- gate a more com- prehensive Haz- ardous Waste Management Plan. The plan was adopted in March, 1987. Persons who con- struct, expand, enlarge or alter commercial haz- ardous waste dis- posal, treatment or storage facilities or any on-site land disposal fa- cilities of cer- tain categories of waste must first obtain a siting license. Owner or operator must obtain such a license. No formal process. No formal preemption, but local government cannot categorically bar construction of a hazardous waste treatment and disposal facility. Hazardous Waste Facilities Sitting Act requires an application containing the name and address of the applicant, location of the facility, certain hydro- geologic and engineering data, risks from trans- portation, infor- mation on the site's impact on community health. Other procedures are delineated throughout the matrix. The statute requires establishment of a 10 member site review panel with representation from the state and public in order to receive public input early in the process and to approve, deny, or add provisions to the siting license to mitigate public concerns. ------- FIGURE 2. (Cont.) SITING IN REGION 10 STATES StateStatutory/Regula- tory Schedules and Authority Applicability of Siting Rules/ Regulations Determination of Need Regulatory Preemption Permitting Procedures Community Participation/ Negotiation Oregon Siting provisions contained in Oregon Adminis- tration Rules, Chapter 340, Division 120, adopted March, 1986. All hazardous waste and PCB treatment and disposal facilities. Most regulations apply to the following: (1) New off-site treatment and disposal facil- ities for hazardous waste and PCB. (2) New hazardous waste and PCB land disposal facilities located on-site. Applicant must provide implementa- tion allowing DEQ to make a determina- tion there is a "need" for a facility. A facility is "needed" if: there is a lack of current treatment /disposal capacity to handle Oregon generated wastes, or it will result in a higher level of protection to health and environ- ment, or savings in treatment/disposal costs for Oregon companies. None specifically provided for. 3-step permitting process: 1. submit a re- quest for and ob- tain Authorization to Proceed from DEQ. 2. Submit a re- quest for and ob- tain a land use compatibility statement from local government. 3. Submit an ap- plication for and obtain a treatment or disposal permit from DEQ. to resolve con- Committee of resi- dents, partly ap- pointed by local government, liv- ing near to or along transporta- tion routes par- ticipates in siting decision considering such issues as special monitoring for community health risks, road im- provements, changes in pro- perty values and developing a plan flicts and dis- agreements be- tween the com- munity and the operator. Washington 1984-85 Revisions to state law estab- lished waste manage- ment priorities, capacity study, siting standards, local programs, Citizen Proponent Negotiations (CPN), preemption and private sector role. Interim siting standards for disposal /incin- eration facilities are In place as are guidelines for local government programs (zoning, grants) . Final siting standards and CPN are under development. Interim siting standards apply to owners and operators of landfills, incin- erators, land treatment facil- ities, surface im- poundments which will be closed as a landfill and waste piles to be closed as land- fills (preempted facilities) which are required to ob- tain interim or final status per- mits under WAC 173-303-805/806. No formal "need" determination is provided for, although Department is required to develop a hazardous waste management plan including: waste generation forecasts, capacity needs assessment, and methods to Implement the statutory waste management priorities. State prcfmptlon authority to approve, deny or regulate disposal and incineration facilities, although key roles are provided for local governments in hazardous waste management and citizen proponent negotiations. Owners and opera- tors applying for a final facility permit must com- plete, sign and submit that ap- plication to DOE. The information required Includes such information as certain tech- nical data, design drawings and en- gineering studies, a general descrip- tion of the facil- ity, and a des- cription of security pro- cedures. Environmental requirements must al so be met. Negotiation, media- tion and other conflict resolution methods are encour- aged when siting disputes occur. Ecology is now designing a process for (CPN). Public hearings are required when a draft permit and environmental assessment is issued. ------- FIGURE 2. (Cont.1 SITING IN REGION 10 STATES StateSizingPublic or Restrictions/ Private Waste Exclusion Ownership Land Use Compat- ability Showing Mitigation of Potential Risks Host Community Impac t/Property Risk Assessment Response to Emergencies Alaska None. Both public and private ownership contemplated by hazardous waste facility siting provisions. Application must include aerial photographs, and must demonstrate that the hazardous waste will not escape the site for 1000 years and will not make con- tact with the nearest freshwater acquifer for 1000 years. Several geologic and seis- mic reports must also be submitted showing contain- ment qualities of chosen site. Certain locations are excluded from consideration (special habitats, ports, monuments and wetlands). Applicant must obtain a written agreement with municipal or borough government which describes how the facility will meet specified operating criteria necessary for protection of public health and the environment. In addition to those require- ments listed elsewhere, applicants are required to obtain an agreement with local govern- ment describing how owner/ operator will mitigate for changes in property values near facility. Applicant for permit of all hazardous waste management facilities (except storage) must submit a report identi- fying risk facility poses to public on a scale running from safe (10"6 risk) to intrinsically unsafe (10~4 risk). See also Fed. Reg. Vol. 51, No. 185, Wed., Sept. ?*f, 1986. Contained in permit- ting procedure. Owner/Operator describes how the facility will re- spond to on-site emergencies and assure safe transportation. Idaho None, but Haz- ardous Waste Management Plan provide that the Dept. of Health and Welfare should consider placing restric- tions on the types of wastes accept- ed for disposal and treatment based Inpart on measures taken by other states. Land disposal ban re- strictions In place for sol- vents, dioxins, and California list. The Hazardous Waste Manage- ment Plan encourages Private owner- ship, though both public and private ownership were apparently con- templated. No specific regula- tions but statute indicates that en- gineering and hydrology informa- tion must be con- tained in the Siting License Application. Siting license ap- plication must give information showing that harm to scenic, his- toric, cultural, and recreational values and risk of accidents dur- ing transport, will not be substantial or can be miti- gated. An owner of real property who is adversely affected by a facility may be compensated by the facility owner /operator in an amount equal to his loss. Application must No specific address risks provisions. from trans- portation and information on site impact on community health. License conditions can be added to address these concerns. ------- FIGURE 2. (Cont.) SITING IN REGION 10 STATES State Sizing Restrictions/ Waste Exclusion Oregon Facility must have capacity, in con- junction with other facilities, to treat or dispose of waste generated over the next 10 years at a minimum in Oregon, and, at a maximum, for wastes from the 8 NW compact states. If facility is larger than what is need- ed In Oregon, owner /opera tor must show addit- ional size is needed to make the facility economically feasible. Washington (1) Extremely hazardous wastes cannot be land- filled (70 RCW 105.050) (2) Land dis- posal regula- tions sre being drafted. Public or Private Ownership Both public and private ownership contemplated by siting provisions. The most recent siting provis- ions establish primary private sector role in providing waste management services. Land Use Compat- ability Showing Applicant must obtain local land use approval. Also, off-site facilities must be at least 3 miles from larger popula- tion areas (10,000 people or greater). Facilities must be one mile from schools, churches, commercial centers, parks, scenic view sites, resorts, etc. Provision also contains locational restrictions based on ecology, geology, and seismology considerations. Several require- ments relating to topographical and geologic considera- tions such as dis- tance from aqui- fers, fault lines, unstable slopes, coasts, surface waters, and areas where the soil has subsided. Dis- tance of public Institutions, parks, and other high density popu- lation areas is also a factor in siting decision. Mitigation of Potential Risks Regulations recom- mend local govern- ment and the applic- ant consider negotia- tions to mitigate impact. No specific provi- sions, but several provisions in Draft Location Standards address minimizing potential risks associated with hazardous waste facilities. Host Community Impact/Property DEQ recommends that the local government and the applicant consider negotiating an agreement which addresses the fa- cility's potential impact on property values near the site. No specific provi- sions in Interim Siting Standards or Draft Location Standards. These issues are an integral part of CPN which are under develop- ment. Risk Assessment Response to Emergencies No specific Owner/Operator provisions. required to operate an emer- gency response team responsible for responding to spills within 50 miles of the facility. No specific pro- Owner/operator re- visions, but risk quired to pay in- assessment impli- creased cost for citly included fire, hospital and through the Draft other public fa- Locational Stan- cilities. Roads dards. leading to facil- ity will be made safer to trucks carrying waste and increased auto traffic. ------- D. HAZARDOUS HASTE MANAGEMENT IN THE NORTHHEST: A STATUS REPORT (EXECUTIVE SUMMARY) ------- HAZARDOUS WASTE MANAGEMENT IN THE NORTHNEST A STATUS REPORT PREPARED FOR THE .S. ENVIRONMENTAL PROTECTION AGENCY THE STATES OF ALASKA, I PREPARED BT LEE N. SMS CONSULTANT ------- 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%). ------- 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. ------- 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. ------- 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 ------- 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- ------- 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- ------- 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- ------- 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- ------- 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- ------- 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- ------- 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- ------- F. SYMPOSIUM EVALUATION FOI APRIL 28-28, 1987 ------- 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 ------- 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. ------- 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. ------- -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 ------- -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? ------- 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? ------- 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. ------- G. REGIONAL STEERING COMMITTEE BIOGRAPHIES ------- 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. ------- 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. ------- 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. ------- 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. ------- 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. ------- 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. ------- 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. ------- 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. ------- 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. ------- |