1.	Facility Name/Site Identifier	PacifiCorp - Medford Facility	

2.	Legal name (as registered with the Oregon Corporations Division) 

3.	Mailing address

a.	825 NE Multnomah, Suite 1500

b.	Portland, OR 97232

4.	Facility location address

a.	925 South Grape Street

b.	Medford, OR 97501

c.	Jackson County

5.	Contact information

a.	Tom Hosler-Environmental Cord. 		503-813-6639	Portland Office
b.	Andy Gentry - Operations Manager   	541-776-5481	Medford Facility	
c.	Dave Coe - Facility Manager 		541-776-5460	Medford Facility

6.	Business activity information

a.	primary NAICS Code or SIC Code  =  SIC 4911

b.	facility description = Electrical Utility

7.	
Please provide information about your current regulatory status.   

Regulatory Status Category 	
Permit Number	
Permitting or Compliance Issues	
RCRA:  Is your facility	
A Large Quantity Generator?	Y    N   DK			
A Small Quantity Generator?	Y    N   DK			
A Conditionally Exempt Generator?	Y    N   DK		In compliance, permit not required	
A TSD Facility?	Y    N   DK			
AIR:  Is your facility	
Not required to have a permit?	Y    N   DK			
Permitted under an ACDP?	Y    N   DK			
Permitted under a Title V permit?	Y    N   DK			
WATER:  Is your facility	
Not required to have a permit?	Y    N   DK 			
Permitted under a WPCF permit?	Y    N   DK 			
Required to pretreat?	Y    N   DK 		City requires to pretreat waste water from equipment & vehicle wash operations	
Permitted under an NPDES permit?	Y    N   DK 			
Permitted under a Tier I storm water permit?	Y    N   DK 			
Permitted under a Tier II storm water permit?	Y    N   DK 			
Regulated under the Underground Injection Control Program?	Y    N   DK 			
Permitted under a POTW discharge permit?	Y    N   DK 	95-M1-1006	Permit requires to pretreat waste water before discharging to sanitary sewer system	
OTHER:  Is your facility	
Required to have a Solid Waste Permit?	Y    N   DK 			
A TRI reporter?	Y    N   DK 			
A State Fire Marshal Hazardous Substance reporter?	Y    N   DK		Must list hazardous substances on site above threshold limits	
A potentially responsible party under Superfund?	Y    N   DK 			
Regulated under the Safe Drinking Water Act?	Y    N   DK 			
Subject to Underground Storage Tank Regulations?	Y    N   DK 		Facility has 2 underground storage tanks	
Regulated under TSCA?	Y    N   DK 		PCB Management	
Required to have a SPCC Plan?	Y    N   DK 		Facility stores over 1320 gallons of oil on site	
Regulated under FIFRA?	Y    N   DK 		To ensure herbicides/fungicides are being properly managed.	
Other?____________________	Y    N   DK 			

8.	Please provide the following information about the implementation status of your Environmental Management System (EMS) (check the appropriate boxes or provide dates):  

	 Not yet developed    

	 Basic EMS    

	 ISO Comparable EMS     

	 ISO Certified EMS    

	Third Party Certified

EMS Element	In Development	Functioning Since (date)	
Environmental Policy Statement		12-20-1999	
Identification of Environmental Aspects and Impacts		September 1999	
Setting Objectives and Targets		August 1999	
Structure and Responsibility	X		
Training		September 1999	
External Communications	X	December 1999	
Monitoring and Measurement	X		
EMS Audits	X	December 1999	
Management Review	X	March 2000	
Certification	X		

9.   Please provide the following information on your facility’s significant environmental impacts.   If your facility’s significant environmental impacts do not lend themselves to numerical values, please provide a written summary.  Include additional pages if necessary.  

1996-1998		    1999			1995
a.  Significant Environmental Aspects	
b.  Performance Measure/
Normalization Factor	
c.  Current Levels	
d.  Past Performance	
e.  Regulatory Limit
 (if any)	
f.  Future Target/
Objective	
Equipment Repair
Use of paints/solvents	a.  1833 gal/yr.    Annual rate
b.  7.05 gal/day       unit rate	a. <50 gal/yr       annual rate
b.   .2 gal/day          unit rate	a.   4,000 gal/yr         rate
b. 15.38 gal/day       year	20,000 gallons before VOC regulations in effect	Eliminate use of all enamel based paint	

Hazardous Waste Generation – 
Carbon Filter Drums	a. 0 lbs/year        annual rate
b. 0 lbs./day            unit rate	a.0 lbs/year      annual rate
b.  0 lbs./day            unit rate	a.   lbs.yr                  rate
b.  2,795 lbs.  year	220 lbs. – if generated in one month	Eliminated use of chlorinated solvents in 1995.	

Reduce treated poles being sent to landfill – Recycle treated poles	a.* 8.4 tons/yr   annual rate
b.   642 lbs.day      unit rate	a. 135 tons/yr    annual rate
b. 1038 lbs.day       unit rate	a. tons/yr                  rate
b.   0 lbs.                year	Not Applicable	Continue to Recycle – Goal is to determine % increase in recycling effort once baseline is determined.	

					
Reduce wood reels being sent to landfill – Recycle reels	a. * 23 tons/yr   annual rate
b.  175 lbs.day      unit rate	a. 17 tons/yr    annual rate
b. 130 lbs.day       unit rate	a. tons/yr                  rate
b.   0 lbs.                year	Not Applicable	Continue to Recycle – Decrease percentage of waste going to landfill once baseline is determined.	

Begin to Measure Other Recycled Products	a.                         annual rate
b.                             unit rate	a.                         annual rate
b.                             unit rate	a.                               rate
b.                             year		By starting a baseline, and measure what is being recycled, goals could be set to increase recycling efforts by a certain percent. 	
						
Reduce the number of spills	a.  6 reported spills per year

	a. 5 reported spills per year	a.5 reported spills per yr.	Not Applicable	Reduce the number of spills. Continue to 	
						
	* 1997-1998 average					

10.	If not demonstrated in the table above, how has performance improved over the past three years?
•	Product substitution has eliminated the use of hazardous paint and solvents in the equipment maintenance operations.
•	Complete elimination of hazardous waste carbon drums.
•	Decreased the disposal of treated poles to a landfill by increasing the recycling by approximately 90%.

How will the environmental performance be significantly better than would otherwise be required by law?
•	A framework will be put in place that is committed to exceed environmental performance levels.
•	We have implemented a comprehensive recycling program that includes non-regulated materials.
•	Employees are committed to continually look for better ways to perform the task at hand more efficiently with less impact to the environment.

Please provide your Stakeholder Involvement Plan for reporting to and for involving stakeholders and citizens and identifying whom your key stakeholders might be in discussing the EMS and environmental performance of your facility.  Include current activities and demonstrate that you have initiated implementation of the Stakeholder Involvement Plan.  

•	
•	A Stakeholder Plan is currently under development. However, the following will be key basic elements of the plan: 

Reorganizing the former Customer Advisory Council.  This will give concerned and interested customers the opportunity to be involved with the environmental planning and performance of the facility.  Also, this group can help identify other potential interested parties.  

Organizing an open house at the Medford facility. This will give PacifiCorp the opportunity to provide information to the public about the facilities operations and it will also give the public an opportunity to share their ideas and express any concerns they may have about the facility. 

DEQ mailed notices to its interested parties regarding the Green Permit program.   A public hearing was held to inform the public of the Green Permit program and solicited comments.  The facility has determined that the next step is to invite the public to open house to include a tour of the facility.   

11.	Please describe desired incentives or waivers for consideration in your GEMS permit along with justification.  

Single Point of Contact
•	PacifiCorp requests a single point of contact from the Department of Environmental Quality.  The single point of contact will consult with compliance staff from all DEQ programs, as well be the lead contact for issues dealing with EPA. 

Consolidate Spills Reporting 
•	PacifiCorp requests annual reporting of certain spills of mineral oil dielectric from electrical equipment, which are less then 100 gallons.  Mineral oil dielectric is defined as containing less than federally reportable quantities of PCB's.   This incentive request will only include the spills that are covered under our EMS.  We request this change be implemented in two phases, as described below:

Phase 1 would start at the time our EMS is fully implemented.  For one year after implementation of our EMS PacifiCorp will demonstrate our ability to go beyond compliance for addressing spills incidents.  We will demonstrate this by reporting all spills, submitting a response report describing how the spill was cleaned up and how it can be prevented in the future, and taking confirmation samples if requested by the Department.  We will create a matrix form with this information that will be submitted to DEQ.  After one year of EMS implementation, PacifiCorp will submit an annual report to DEQ for review and approval.  At that time, if DEQ deems that PacifiCorp’s performance has gone beyond compliance, we request consolidated reporting of spills in lieu of individual reporting.

Phase 2 begins in the second year of EMS implementation. After DEQ approval PacifiCorp will report spills of mineral oil dielectric from electrical equipment, which are less then 100 gallons on annual basis. Submittal of the annual spill report will coincide with submittal of the annual EMS report and will describe the procedures in the EMS that were followed to address each spill and provide some possibilities on how to avoid similar spills in the future. 

•	The following types of spills will continue to be reported on an individual basis: Spills over 100 gallons, spills of oil containing federally reportable quantities of PCB, spills that enter navigable waterways, spill to stormwater systems and spill to extremely sensitive habitats. 

Oversight Fees
•	In conjunction with implementation of phase 2 describe above, PacifiCorp requests the waiver to oversight fees associated with individual spill reporting.  Phase 2, allows for reporting spills annually and not on an individual basis, therefore, cost associated with individual spill reporting will no longer be applicable. 

Scheduled Technical Assistance Inspections
•	We request that DEQ use enforcement discretion regarding facility inspections.  We would like DEQ to focus on corrective action processes described in our EMS and provide PacifiCorp an opportunity to correct the deficiencies in a timely manner and prevent such occurrences in the future.  We also request that environmental audits be scheduled in advance. 

12.	Statement of Certification:

I have reviewed this application and all supporting documentation in their entirety and to the best of my knowledge, information, and belief formed after reasonable inquiry, the statements and information contained herein are true, accurate, and complete.

	
Name of designated responsible official:	Tom Hosler

Title of responsible official:	Environmental Coordinator

                                                                                                                                                        
Signature of responsible official					        Date