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EPA/530-SW-91-093K
PB92-131 358
MONTHLY HOTLINE REPORT
November 1 991
' .
,
V C ?
RCRA/SF/OUST and 1
Emergency Planning and Community Right-to-Khow
•> *-> \ •.-.•. f **
•C s^x% s
r-V%J
Hotline Questions and Answers
Resource Conservation and Recovery Act (RCRA) 1
Emergency Planning and Community Right-to-Know 3
New Publications
Resource Conservation and Recovery Act (RCRA) 4
Federal Registers
Final Rules 5
Notices 5
Call Analyses
Calls Answered 7
Caller Profile 10
Hotline Topics 12
RCRA/SF/OUST Hotline
National Toll Free No.: 800-424-9346
Emergency Planning and Community
Right-to-Know Hotline
National Toll Free No.: 800-535-0202
This report is prepared and submitted in support of Contract No. 68-WO-0039.
EPA Project Officer:
Barbara Roth. (202) 260-2858
U.S. Environmental Protection Agency
Washington, DC 20460
Printed D'
Recycled P
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HOTLINE QUESTIONS AND ANSWERS
RCRA
1. Multisource Leachate (F039) Waste
Code as it Applies to Contamination
From Spills
The hazardous waste code F039, known as
multisource leachate, is defined in 40 CFR §261.31
as leachate resulting from the disposal of more
than one hazardous waste listed in 40 CFR Pan
261, SubpartD, which is also a restricted waste
under the Land Disposal Restrictions program in
Part 268. Rainwater has percolated through soils
contaminated with spills of several different listed
hazardous wastes. Could the resulting
contaminated water now receive the F039 waste
code?
The January 31, 1991. Federal Register (56 FR
3865) states that in order to determine whether a
waste meets the criteria of F039, it is necessary to
first determine that the waste meets the definition
of leachate. This definition, found in 40 CFR
§260.10, is "any liquid, including any suspended
components in the liquid, that has percolated
through or drained from hazardous waste." The
preamble of the January 31,1991, notice also
clarifies that only liquids that have percolated
through land disposed wastes ("land disposal"
having the meaning of RCRA Section 3004(k)) are
considered to be leachate for the purposes of
making this determination. The definition of land
disposal in Section 3004(k) states that land
disposal "shall be deemed to include, but not
limited to any placement of such hazardous waste
in a landfill, surface impoundment, waste pile,
injection well, land treatment facility, salt dome
formation, salt bed formation, or underground mine
or cave" (emphasis added). Spillage and
drippage are also forms of land disposal, albeit
improper and illegal. Since spills and drips of
hazardous waste which have collected in the soil
are normally land disposed wastes, water that has
percolated through soils contaminated with more
than one listed hazardous waste for which Part
268 treatment standards are in effect is normally
F039.
2. Transfer Facility as Central Collection
Point
A company generates small quantities of
hazardous waste at several separate field
locations. The company does generate more th<:n
100 kilograms of hazardous waste per month .;;
each separate field location. May the compan.
use a transfer facility as a central collection p,
to consolidate waste from these field location*
Yes. A company may consolidate waste tr* •••-.
several locations or generation sites at a centra.
point provided that certain requirements are n v
First, each generation site must have an EPA
Identification No. and meet all applicable
requirements under 40 CFR Part 262. In
addition, each shipment of hazardous waste :•
be accompanied by a hazardous waste man it,-
and the transporter must also have an EPA
Identification No.
The transfer facility provision under §26
may be applied to a situation such as this one
under the following conditions. According •
§260.10, a transfer facility is defined as "an>
transportation-related facility including load
docks, parking areas, storage areas and other
similar areas where shipments of hazardous
-------
Hotline Questions and Answers
November 1991
are held during the normal course of
transportation." The transfer facility is the
place where transporters consolidate shipments
or transfer shipments to different vehicles in
order to redirect them; this activity usually
takes place over a short period of time. (45 FR
86966; December 31, 1980) Section 263.12
allows a transporter to store manifested
shipments of hazardous waste at a transfer
facility for up to 10 days without obtaining a
permit. During this time the hazardous waste
must be held in containers which meet
Department of Transportation (DOT)
packaging requirements. As long as the central
collection point meets the definition of a
transfer facility, the company may use it to
consolidate shipments of hazardous waste from
different generation locations. Note that if a
transporter mixes hazardous wastes of different
DOT shipping descriptions, §263.10(c)
requires compliance with 40 CFR Part 262,
Standards Applicable to Generators of
Hazardous Waste.
3. Removal of Toxicity Characteristic
Wastes from a Surface
Impoundment
A generator produced a solid waste and
disposed of his waste in an on-site surface
impoundment. After the September 25, 1990,
effective date of the toxicity characteristic (TC)
rule, the waste would meet the definition of a
newly-identified TC waste (40 CFR §26124).
If he chooses to remove the waste from his
surface impoundment and dispose of it off-site,
would his surface impoundment be a regulated
unit under Subtitle C ofRCRA?
No, not under the following circumstances.
The generator may remove the waste from the
surface impoundment prior to the effective
date of the TC rule and the unit will not be
regulated as a subtitle C unit. EPA has also
clarified that the Agency would not normally
consider the one-time removal of waste from a
unit on or after the TC effective date to bring
the unit into the hazardous waste management
system (e.g., as a storage unit). As stated in
the September 27,1990, Federal Register
clarification notice, "EPA does not consider
one-time removal of waste from a unit on or
after the TC effective date, in and of itself, to
make the unit a storage unit and thus subject to
Subtitle C. The Agency does not view one-
time removal of waste as part of a closure as
changing the status of the unit, as long as there
has not been ongoing management of the waste
in the impoundment." The preamble language
goes on to state that this removal is beneficial
to human health and the environment since it
would eliminate potential sources of
groundwater contamination. (55 FR 39410)
Should the generator choose to remove the
hazardous waste from the unit on a one-time
basis, he may use the impoundment as a non-
Subtitle C unit (provided no other hazardous
wastes are generated, managed, or disposed of
in the unit). On the other hand, if the generator
chcx>scs to leave the waste in place and does
not use the unit for hazardous waste
management after the effective date of the TC
rule i for example, if he intends for the surface
impoundment to be the final disposal site for
the waste), the unit would not be a regulated
Subtitle C surface impoundment.
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November 1991
Hotline Questions and Answers
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
4. Section 313: Employee Threshold
Determination
The owner of a facility covered under
Section 313 of the Emergency Planning and
Community Right-to-Know Act (EPCRA) does
not work for the facility but draws an income
from profit sharing. Would he be considered an
employee according to the definition under
Section 313 of EPCRA (40 CFR §372.3)?
If the owner of the facility does not work for
the facility and only draws a profit share, the
owner is not considered an employee, and the
reporting facility will not count the owner
towards the employee threshold.
5. Section 313: Reporting Releases
A facility has an on-site concrete basin used
as a collection pond for 80 percent of the
facility's waste and stormwater. No NPDES
permit was assigned to this concrete basin. The
wastewater is temporarily collected in the basin
and then sent to an off-site biological treatment
plant. How would the facility report releases of
the toxic chemicals contained in the wastewater
on the Form R (40 CFR §372)?
Since the facility's basin is not a water body
recognized by the state, the toxic chemicals
collected in the basin would be considered on-
site storage. Any leaching into the ground or
volatile air emissions, however, would be
reported as releases to land and air, respectively,
in Section 5 of the Form R. Also, if the chem icul
is sent off-site to the treatment facility during the
calendar year, it is reported as an off-site transfer
in Section 6 of the Form R.
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NEW PUBLICATIONS
HOW TO ORDER
NTIS Publications are available by calling (703) 487-4650, or writing NTIS, 5285 Port Royal Road, Springfield,
VA 22161. Be sure to include the NTIS Order Number listed under the document.
Hotline Publications are available through the RCRA/Superfund/OUST Hotline by calling a Document
Specialist at 1-800-424-9346. Be sure to include the EPA Order Number (if any) listed under the document.
RCRA
TITLE: "Regulatory Determination:
Landfills and Surface Impoundments
Receiving Pulp/Papermill Sludge"
AVAILABILITY: Hotline
EPA ORDER NO.: EPA/530-SW-91-077
EPA has determined not to promulgate
additional regulations for landfills and surface
impoundments receiving sludge from chlorine
and chlorine-derivative bleached pulp and
paper mills under Subtitle D.
TITLE: "Method 9096: Liquid Release Test
(LRT) Procedure"
AVAILABILITY: Hotline
EPA ORDER No.: EPA/530-SW-91-078
The (LRT) is a laboratory test designed to
determine whether or not liquids will be
released from sorbents when subjected to
overburden pressures in a landfill.
TITLE: "Background Document for LRT:
Single Lab Evaluation/1988 Collaborative
Study"
AVAILABILITY: Hotline
EPA ORDER NO.: EPA/530-SW-91-079
The background document for LRT
summarizes results from a single laboratory
evaluation and a multilaboratory collabrative
study on the LRT device developed for EPA
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FEDERAL REGISTERS
FINAL RULES
RCRA
"Approval of Alabama's Hazardous Waste
Program"
November 29,1991 (56 FR 60926)
EPA announces its intent to give final
authorization for Alabama's hazardous waste
program revisions effective January 28,1992,
unless EPA publishes a prior Federal Register
withdrawing this final rule. Comments must be
received by close of business December 30,
1991.
NOTICES
RCRA
"Response to Comments on RCRA
Program for Arkansas "
November 13,1991 (56 Ffi 57593)
EPA responded to the comments received
regarding RCRA program revision
authorization for Arkansas.
"Witco Corporation Receives an Exemption
to LDR Requirements"
November 13,1991 (56 FR 57644)
EPA gives notice that an exemption to the
land disposal restrictions under HSWA and
RCRA has been granted to Witco Corporation
for the Class I injection wells located at
Marshall, Texas.
Copies of RCRA Federal Registers are available
Specialist at 1-800-424-9346.
"Meeting on Mining Waste"
November 18,1991 (56 FR 58246)
EPA announces a meeting of the Policy
Dialogue Committee on Mining Waste to be
held December 9,1991, from 9 a.m. to 5 p.m.,
and December 10,1991, from 9 a.m. to 4 p.m.,
at the Sheraton City Center, 1143 New
Hampshire Avenue, NW, Washington, D.C.
"Allegan Metal Finishing Company's
Petition"
November 19,1991 (56 FR 58312)
EPA removes a final rule (55 FR 38058)
regarding the petition received from Allegan
Metal Finishing Company for exclusion of
wastes under 40 CFR §§260.20 and 260.22.
That rule denied a petition for the exclusion * •
hazardous waste under §3001(f) of RCRA.
"Data Transfers"
November 26,1991 (56 FR 59937)
EPA is transferring to its prime con tract IT
Booz, Allen & Hamilton, Inc., and Westat a:
their subcontractors, data that have been or A
be submitted to EPA under the authority of
RCRA.
SUPERFUND
"Administrative Settlement with Phoem»
November 4,1991 (56 FR 56412)
EPA gives notice of the proposed
administrative cost recovery settlement enu-
into by EPA and the City of Phoenix under
§l22
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Federal Registers
November 1991
NOTICES
"Mobay Chemical Corporation Requests
to Amend Registrations of Two of its
Products"
November 6,1991 (56 FR 56642)
Mobay Chemical Corporation has
requested to amend its registrations of trade
name products Baytex Technical and Baytex
Liquid Insectide. The notice deletes the use of
the active ingredient Fenthion from specific
applications.
"Proposed Settlement for Kassouf-
Kimerling Site"
November 12,1991 (56 FR 57523)
EPA gives notice of a proposed agreement
to settle claims for response costs at the
Kassouf-Kimerling Site in Tampa, Florida,
with the jje. minimis landowner parties.
Comments will be received for a period of
30 days.
"Correction of Priority List Document"
November 25,1991 (56 FR 59331)
EPA corrects document 91.25057
concerning the revised priority list of
hazardous substances that will be the subject of
toxicological profiles.
"Settlement with Ordnance Research,
Inc."
November 25,1991 (56 FR 59285)
EPA agrees to settle claims for response
costs at the Ordnance Research, Inc., Site in
Fort Walton Beach, Florida, with Ordnance
Research, Inc., and Mr. Fred Shintz.
Comments will be received for a period of 30
days.
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
"California Products Corporation Petition
Denied"
November 22,1991 (56 FR 58859)
EPA is denying a petition to delete
chromium (HI) oxide from the toxic chemical
list. The petition submitted by California
Products Corporation was denied because
chromium (HI) can, under certain conditions, be
oxidized to chromium (VI), which is a human
carginogen.
"Cancellation of Certain Pesticide
Registrations"
November 27,1991 (56 FR 60103)
EPA is issuing a notice of receipt of
requests by registrants to voluntarily cancel
certain pesticide registrations. Cancellations
will be effective February 25,1991, unless the
request is withdrawn.
GENERAL
"Meetings on the 1990 Emergency
Response Guidebook"
November 8,1991 (56 FR 57369)
The Department of Transportation's
Research and Special Programs Administration
will conduct a series of public meetings to
discuss revisions to the "1990 Emergency
Response Guidebook."
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600 -r
500 - •
400 • -
300 • -
200 - -
100
CALL ANALYSES
CALLS ANSWERED BY HOTLINE
November Daily Volume*
RCRA/SF/OUST
A
Emergency Planning and
Community Right-to-Know
8.877
Grand Total
8 12 13 14 15 18 19 20 21 22 25 26 27 29
Quarter-To-Date Volume*
September
RCRA/SF/OUST
Grand Total
Emergency Planning and
Community Right-to-Know
October
November
All calls answered by the Call Management System
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Call Analyses
November 1991
CALLS ANSWERED BY TYPE
November Daily Volume*
Questions
Grand ' :• n
1 4 5 6 7 8 12 13 14 15 18 19 20 21 22 25 26 27 29
Quarter-to-Date Volume*
o
September
October
Novemb«-
* All calls answered by the Call Management System. A single call m*\ rc\uli m multiple questions combined with docum
requests and referrals.
8
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November 1991
Call Analyses
CALLS ANSWERED BY PROGRAM AREA
November 1991*
* Based on 12,376 questions posed and excludes 1,505 referrals made from both Hotlines
-------
Call Analyses
November1991
CALLER PROFILE
RCRA/SF/OUST Hotline
Regulated Community
Citizens
State & Local Gov't/Native American
Federal Agencies
Educational Institutions
EPA
Other
Media
Interest Groups
Congress
Referrals
International
TOTAL
6,554
588
425
402
201
158
294
50
128
0
160
22
1
9,983
State/Local Gov't/
Native American
5%
Federal
Agencies
Citizens
7%
All
Others
10%
Regulated
Community
74%
10
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November 1991
Call Analyses
Emergency Planning and
Community Right-to-Know Hotline
Manufacturer
Food/Tobacco 54
Textiles 9
Apparel 1
Lumber & Wood 5
Furniture 4
Paper 17
Printing & Publishing 28
Chemicals 284
Petroleum & Coal 36
Rubber and Plastics 37
Leather 6
Stone, Clay & Glass 15
Primary Metals 47
Fabricated Metals 63
Machinery (Excluding Electrical) 17
Electrical&Electronic Equipment 55
Transportation Equipment 46
Instruments 5
Misc. Manufacturing 48
Not Able to Determine 45
Consultants/Engineers
Attorneys
Citizens
All Others
Trade Associations
Public Interest Groups
Universities/Academia
Insurance Companies
Hospitals
State Agencies/SERC
Fire Departments
EPA
Local Officials
LEPC
Farmers
Federal Agencies
Media/Press
Union/Labor
Distributors
Indians
Laboratories
Misc.
Referrals
Internationals
TOTAL
438
128
150
26
45
93
0
18
80
26
77
29
35
0
38
15
0
24
0
24
174
345
1
2,588
Citizens
7%
Attorneys
6%
Consultants/
Engineers
20%
All Others
31%
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Call Analyses
November 1991
HOTLINE TOPICS
RCRA
General/Misc.
Special Wastes
Ash
Bevill
Medical
Oil and Gas
Subtitle C Wastes
Hazardous Waste
Identification General
Toxicity Characteristic
Wood Preserving
Used Oil
Fluff
Mixed Waste
Delisting & Petitions
Hazardous Waste Recycling
Generators
Small Quantity Generators
Transporters
Treatment, Storage & Disposal
Facilities
General Facility Standards
Siting
Capacity
Treatment
Burning
Storage
Disposal
Land Disposal Restrictions
Permits & Interim Status
Corrective Action
Financial Assurance
Liability/Enforcement
Test Methods
Health Effects
Pollution Prevention/Waste Min.
State Programs
Hazardous Waste Data
Subtitle D Wastes
Household Hazardous Waste
Subtitle D Facilities
General Facility Standards
Siting
Combustion
Industrial Wastes
Composting
Source Reduction
Grants & Financing
Procurement
General
2
24
113
1
1,841*
175
36
151
0
48
42
163
433*
131
65
211
8
4
99
85
89
110
320*
124
179
0
97
109
0
77
51
0
90
589*
13
3
2
16
0
1
0
Building Insulation 0
Cement & Products with Fly Ash 0
Paper & Paper Products 0
Re-refined Lubricating Oil 0
Retread Tires 0
Solid Waste Recycling
General 162
Aluminum 4
Batteries 12
Glass 1
Paper 8
Plastics 10
Tires 10
Used Oil 158
Markets
General 0
Aluminum 0
Batteries 2
Compost 0
Glass 1
Paper 1
Plastics 2
Tires 3
Used Oil 3
TOTAL 5,879
SUPERFUND
General/Misc. 15
Access & Information Gathering 45
Administrative Record 3
Allocations from Fund 5
ARARs 20
CHRCLIS 70
Ciii/^n Suits 3
C'.ean-L'p Costs 10
Clean-Up Standards 24
Community Relations 6
(\ >n tract Lab Program (CLP) 9
Contractor Indemnification 5
Contracts 5
Definitions 22
Emergency Response 1
{Enforcement 10
Exposure Assess./Risk Assess. 17
Federal Facilities 12
Fund Balancing 5
Grants 62
12
* Hot topics for this reporting period
• Topics are calculated as the summation of all questions recehed b\ the Hotline. A single call may result in multiplr
questions.
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November 1991
Call Analyses
Hazardous Substances 47
Health/Toxics 11
HRS 45
Liability 77
Mandatory Schedules 0
Natural Resource Damages 2
NBARs 1
NCP 24
Notification ~ 61
NPL ^103*
Off Site Policy 4
On Site Policy 2
OSHA 4
PA/SI 13
PRPs 18
Public Participation 1
RCRA Interface 10
RD/RA 5
Remedial 35
Removal 11
Response 7
RI/FS 26
ROD 33
RQ 160*
SARA Interface 4
Settlements 6
SITE Program 25
State Participation 5
State Program 1
Taxes 7
Title III/Right-to-Know 28
TOTAL 1,125
OUST
General/Misc.
Applicability/Definitions
Regulated Substances
Standards for New Tank Systems
Tank Standards and Upgrading
Operating Requirements
Release Detection
Release Reporting & Investigation
Corrective Action for USTs
Out-of-Service/Closure
Financial Responsibility
State Programs
Liability/Enforcement
LUST Trust Fund
SUBTOTAL
50
42
19
8
6
10
33
32
14
30
209*
15
7
0
475
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
Title m General 283
§301-3 Emergency Planning
General 94
SERCs/LEPC 25
Notification 19
Mixtures 8
Extremely Hazardous Substances 56*
Delisting EHS 11
Exemptions 9
§304:
General 77
Notification Requirements 25
Reportable Quantities 32
RQs vs. TPQs 30
Transportation 3
Exemptions 23
§311/312:
General 196*
MSDS Reporting Requirements 33
Tier I/II Regulations 65
Thresholds 41
OSHA Expansion 23
Hazard Categories 17
Mixtures 16
Exemptions 30
§313:
Form R 172*
Thresholds 50
Phase I 41
Phase II 26
Phase IE 2
Pollution Prevention 33
NONs/NOTEs 126*
Petitions 38
Health Effects 21
Database 60
Exemptions 47
Training:
General 8
§305 Training Grants 0
§305 Emergency Systems Review 0
§ 126 (S ARA) Training Regulations 0
* Hot topics for this reporting period
• Topics are calculated as the summation of all questions received by the Hotline. A single call may result in mult >\
questions.
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Call Analyses
November 1991
General:
CEPP Interim Guide
Chemical Profile
NRT-1
Hazard Analysis
Risk Communication
Title m Workshops
Information Management
Prevention ARIP
Other
0
2
1
2
2
0
0
0
137
Trade Secrets
Enforcement
Liability
TOTAL
13
15
5
1,917
TOTAL HOTLINE QUESTIONS,
DOCUMENT REQUESTS AND
REFERRALS: 13,881
14
* Hot topics for this reporting period
• Topics are calculated as the summation of all questions received by the Hotline. A single call may result in mull
questions.
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LIST OF ADDRESSERS;
Ed Abrams, OS-332
Jennifer Anderson, EPA-Reg. 7
Kate Anderson, OS-520
Beth Behrens, EPA-NEIC
Kathy Bishop, OS-210
John Bosky, EPA-Kansas City
Brett Bowhan, DOE-Idaho
Susan Bromm, OS-500
Rick Brandes, OS-330
Karen Brown, A-149C
Nancy Browne, OS-520
Kathy Bruneske, OS-305
Karen Burgan, OS-110
Heather Burns, Hotline
Diane Buxbaum, EPA-Reg. 2
Sabrina Callihan, DOE
Carol Carbone, EPA-Reg. 1
Sonia Chambers, EPA-Reg. 5
Richard Clarizio, EPA-Reg. 5
Don R. Clay, OS-100
Jerry Clifford, EPA-Reg. 9
Bill Cosgrove, EPA-Reg. 4
Clinton Cox, EPA-Alabama
Mike Cullens, OS-240
Becky Cuthbertson, OS-332
Elaine Davies, OS-100
Jeffery Denit, OS-300
Lynn DePont, OS-305
Director, RED, LE-134S
Dave Eberly, OS-343
Chris Elias, CA Dept. of Health
Terry Escarda, CA Dept. of Health
Lisa Friedman, LE-132S
John Gilbert, EPA-Cinn.
Diane Glass, Kelly AFB, TX
Alan Goodman, EPA-Portland, OR
Kristan Goschen, EPA-Reg. 8
John Gorman, EPA-Reg. 2
Cheryl Graham, LE-132S
Hinton Howard, EPA-Reg. 5
Henry Hudson, EPA-Reg. 4
Susan Hutcherson, EPA-Reg. 10
Harriet L. Jones, EPA-Reg. 7
Kathy Jones, OS-210
Gary Jonesi, LE-134S
Walt Johnson, OS-240
Ron Josephson, OS-333
TonyJover,OS-120
Robert Kayser, OS-333
Mitch Kidwell, OS-332
Bob Kievit, EPA- Olympia, WA
Jerry Killiane, GAO
William Kline, OS-322W
Robert Knox, OS-130
Dan Kovacks, Hotline
Walter Kovalick, OS-110
Henry Longest, OS-100
JimLoomis, FLERC
Sylvia Lowrance, OS-300
Tom Lueders, EPA-Reg. 5
James Makris, OS-120
Andrea McLaughlin, OS-220W
Chet McLaughlin, EPA-Reg. 7
Dorothy McManus, OS-120
Tami McNamara, TS-779
Scott McPhilamy, EPA-Reg. 3
Margaret Mereas, EPA-Reg. 4
Charlotte Mooney, OS-332
Robert Morby, EPA-Reg. 7
Royal Nadeau, EPA-Reg. 2
Beverly Negri, EPA-Reg. 6
Susan O'Keefe,LE-134S
Chae Pak, EPA-Reg. 10
Myra Perez, EPA-Houston
Mark Phillips, EPA-Reg. 3
Steve Provant, EPA-Boise, ID
Jim Radle, Jr., EPA-Reg. 9
Carl Reeverts, WH-550E
OSW Division Directors
OSW Deputy Division Directors
OSW Branch Chiefs
Hazardous Waste Management Branch Chiefs, Regions I-X
Regional Counsel, Regions I-X
Regional Libraries, Regions I-X
John Riley, OS-210
Barbara Roth, OS-305
DaleRuhter,OS-341
Debbie Rutherford, OS-420WF
William Sanjour, OS-330
Sam Sasnett, TS-779
Tim Schoepke, TS-793
Jay Silberman, US Coast Guard
Stergios Spanos, NH DES
Elaine Stanley, OS-500
Kathie Stein, LE-134S
Beverly Thomas, OS-420WF
Christine Thomas, Hotline
Jim Thompson, OS-520
Linda Thompson, LE-134S
Robert Thompson, A-104
Steve Torok, EPA-Juneau, AK
Harriett Tregoning, PM-220
David Van Slyke, LE-134S
Barbara Wagner, EPA-Reg. 8
David Watson, PM-214F
Howard Wilson, PM-273
Denise Wright, OS -332
Tish Zimmerman, OS-220
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