aft \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 ...... 530R86112 c. U '^c OFFICE Of SOLID WASTE AND EMERGENCY RESPONSE MEMORANDUM SUBJECT: Monthly Report - RCRA/Superfund Industry Assistance Hotline Report for April 1986. OFUJL FROM: Joan Warren, Office of Solid Waste (WH-562L Nancy warkinson, Office of Emergency and Remedial Response WH-548B) TO: See list of addressees This report is prepared and submitted for EPA contract No. 68-01-6885 I. ACTIVITIES A. The Hotline responded to 9,066 questions and requests for documents in April. B. On April 21, 1986, Hotline staff met with Mary Decker (OUST) and Carrie Wehling (OGC) to discuss UST issues both resolved and unresolved. C. The Hotline noticed a surge in calls concerning the UST program as the May 8, 1986 notification deadline approached. D. On April 29, Cotmander Rock and Steve Hanowich of the National Response Center visited the Hotline to gain a greater understanding of Hotline operations. Reciprocal visits will occur soon. II. REGIONAL ACTIVITIES; SUPERFUND INFORMATION SERVICES A. Region II (New York 800-732-1223 or in New Jersey, 800-346-5009). o Josh Bloom responded to 42 calls in April. o A news release advertising the Region II Superfund Hotline has been finalized. The release will be mailed to all daily and weekly newspapers in New York and New Jersey. ------- - 2 - o The breakdown of calls by subject is as follows: Radon sites - 7 Specific sites - 14 CEPP - 12 CERCIA - 7 RCRA - 2 o The breakdown of callers is as follows: Public - 25 Industry - 3 Consultants - 1 Local Government - 10 Environmental Organizations - 1 Press - 2 o Josh Bloom has recently left his position on the Region II Superfund Hotline. His replacement is Richard Wice. B. Region IX (800-231-3075) o Nancy Alvarado-Blauer responded to 166 calls in April. f o The increaded call load is due to the mass mailing of announcement advertising the toll-free service, recent fact sheets and significant site activities. o About 15% of all calls were referrals to other offices (i.e., RCRA, TSCA, Library). o Nancy provided RCRA community relations support to Patricia Post, Community Relations Coordinator. o The breakdown of calls by subject is as follows: Specific sites - 77 CEPP - 6 CERCLA - 44 RCRA - 27 Other - 12 o The breakdown of callers is as follows: Public - 73 Industry - 12 Consultants - 30 Federal Government - 5 State Government - 15 Local Government - 17 Environmental Organizations - 4 Other - 10 ------- - 3 - III. SIGNIFICANT QUESTIONS AND RESOLVED ISSUES A. RCRA 1. Corrective Action Orders Under §3008(h) The owner/operator of a surface impoundment has managed hazardous wastes in the impoundment without interim status or a RCRA permit. A release of hazardous wastes from the impoundment has contaminated surrounding soil and groundwater. Upon discovery of this improper management and resultant contamination, the EPA intends to issue a corrective action order under Section 3008(h) of RCRA. Given that the owner/operator never an interim status, can the corrective action order be issued? Section 3008(h) authorizes the EPA Administrator to issue corrective action orders to address releases of hazardous wastes into the environment from facilities authorized to operate under Section 3005(e). This authority extends to include those facilities that should have had interim status, but failed to notify EPA under Section 3010 of RCRA or failed to submit a Part A application. Accordingly, the corrective j action order can and should be issued to ensure prompt and ! thorough clean-up of the site. (Please see the December 16, 1985 memorandum from J. Winston Porter, Assistant Administrator, Office of Solid Waste and Emergency Response, entitled "Interpretation of Section 3008{h) of the Solid Waste Disposal Act"). Source: Virginia Steiner (202) 475-9329 Research: Jim Ginley 2. Small Quantity Generator Accumulation On March 24, 1985, EPA promulgated regulations allowing a generator to operate two distinct on-site accumulation areas for wastes generated at different monthly rates (51 FR 1014). A generator has two accumulation areas on-site. In one area, the generator stores waste identified as small guantity generator (SQG) waste. According to §262.34(d), an SQG that generates between 100 and 1000 kg. in a calendar month may store this waste on-site for up to 180 days without a permit or interim status provided that the quantity of waste accumulated never exceeds 6000 kg. The SQG waste can be stored for 270 days if it is transported 200 miles or more. In another area at the same site, the generator stores large quantity generator (LOG) waste which was produced during the months the generator exceeded the 1000 kg/month limit. A LQG may store this waste on-site for up to 90 days without a permit or interim status. Must the generator count waste stored in his LQG accumulation area when determining if the 6000 kg. accumulation limit is exceeded in (S262.34(d)(l))? ------- - 4 - Section 262.34(d) states that a generator who generates greater than 100 kg. but less than 1000 kg. of hazardous waste in a calendar month may accumulate hazardous waste on-site for 180 days or less without a permit or interim status provided that, among other requirements, the quantity of waste accumulated on- site never exceeds 6000 kg. This provision applies only to waste streams produced during calendar months when less than 1000 kg is generated. If more than 1000 kg is generated, it is fully regulated as large quantity generator waste. The 6000 kg cap for the SQG waste stream applies to all waste accumulated on-site. "On-site" means all contiguous property (§260.10). The definition does not refer to "units" or "accumulation areas". Therefore, the generator must count all waste, including both SQG and LOG that is on-site, in order to determine compliance with §262.34(d)(1). Source: Bob Axelrad (202) 382-5218 Maureen Smith (202) 382-7703 Research: Ingrid Rosencrantz 3. Appeal/Recourse Process for Permit Denial An owner/operator (o/o) of an interim status facility is seeking a finalf RCRA permit. If the o/o submits a complete permit application, but > the state or region denies the permit, what procedural recourse or appeal process may the o/o follow? It appears that Part 124 Subparts A and E both state procedures to follow for appealing a permit denial. If the o/o of an interim status facility submits all necessary information, then a final decision to grant or deny the permit can be made. An o/o wanting to appeal a permit denial would follow the procedure in §124.19 of Part 124 Subpart A, which addresses recourse for permit denial. This Subpart contains procedures for informal hearings. Briefly, the o/o has a 30-day period in which he may request a review by serving a notice to the Regional Administrator. On the other hand, Part 124 Subpart E outlines a more formal appeal process for permit or interim status terminations. Thus, if the o/o of an interim status facility fails to submit adequate infor- mation for a final permit application, then its interim status could be terminated, and the Agency would follow the appeal procedures in Subpart E. Generally, the formal or "evidentiary" hearing of Subpart E is applicable to RCRA facilities only where there has been a termination of a permit based upon a RCRA violation or the termination of interim status based upon a failure to submit information necessary to make a final permit decision. Source: Carrie Wehling (202) 475-8067 Research: Margaret Kneller ------- - 5 - 4. UST Regulated Substances The Underground Storage Tank (UST) program applies to underground tanks holding regulated substances. Regulated substances include petroleum and "any substance defined in Section 101(14) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (but not including any substance regulated as a hazardous waste under Subtitle C of the Resource, Conservation, and Recovery Act, as amended)" per 40 CFR 280.1 (50 FR 28755). A substance which exhibits a "hazardous waste characteristic" and which is not a petroleum fraction is stored in an underground tank. The substance is excluded from RCRA regulation under 40 CFR 261.2(e)(ii) because it will be reused as a substitute for a conmercial chemical product. Must the owner notify EPA of this underground tank under §280.3? No, the owner of this tank is not reguired to notify EPA because in this case the underground tank does not contain a regulated substance. The characteristic material in this tank does not meet the definition of a RCRA solid waste under §261.2(e)(ii) since it is reused as a substitute for a commercial chemical product. If a material is not a solid waste under RCRA, it cannot meet the definition of a hazardous waste under §261.3. Since this characteristic material is not a RCRA hazardous waste and is not specifically listed on the CERCLA hazardous substance list in 40 CFR 302.4, it is not a CERCLA hazardous substance. Hence it is not a regulated substance under the UST program and a tank containing this substance and no other regulated substance is not subject to notification under §280.3. Source: Carrie Wehling (202) 475-8067 Research: Jennifer Brock 5. Delisting A petroleum refinery obtained interim status in 1980 for a surface impoundment used to treat and store K051. The facility manages no other hazardous waste. In 1981, the EPA granted a delisting for the K051 waste because the owner/operator proved that the refining process waste did not contain lead and hexavalent chromium, the constituents for which K.051 was listed. Does the K051 delisting effectively mean that the facility never managed a listed hazardous waste? How would the delisting affect the facility's interim status? A person may submit a petition to EPA, pursuant to 40 CFR §§260.20 and 260.22, to have a waste at a particular facility delisted. Prior to September 21, 1985, EPA granted only "informal" or temporary exclusions. "Informal" exclusions were suggestions to the Regions that enforcement discretion be used when a tentative decision to grant a temporary exclusion had been made. Temporary exclusions removed a waste at a particular facility from regulation, pursuant to 260.22(m) (then in effect, see 50 FR 28727-28, July 15, 1985). EPA follows the procedures set forth in 40 CFR §260.20 to grant final exclusions, which are regulatory amendments. ------- - 6 - Wastes which were informally excluded were technically still hazardous wastes. An impoundment holding informally excluded K051 waste was subject to the Loss of Interim Status provisions on November 8, 1985. For temporarily excluded wastes, the facility's status depends on the scope of the temporary delisting granted. If only the waste generated after the date of the temporary exclusion was delisted, waste placed in the impoundment prior to that date would still be hazardous (K051) waste. The impoundment would have had interim status and should have met Part 265 standards. The Loss of Interim Status provision applied to the impoundment on November 8, 1985. If the temporary exclusion covered the waste already in the impoundment as well as K051 waste generated after the exclusion date, then the facility would still have interim status, but none of the Part 265 interim standards would apply to that surface impoundment. The facility would technically have been subject to the Loss of Interim Status provision, but not required to certify compliance with financial responsibility or ground water monitoring requirements, since none of these Part 265 requirements were "applicable," or to submit a Part B permit application on November 8, 1985, (50 FR 38947, September 25, 1985). If EPA revokes the temporary exclusion, or it ceases to be in effect by operation of law, e.g., if the Agency does not make a final decision on the petition by November 8, 1986, (RCRA §3001(f)(2)(B)), the facility will become subject to the Part 265 interim status requirements. The facility must then certify compliance with financial responsibility and ground water monitoring requirements and submit a Part B permit application within 12 months or lose interim status (RCRA S3005(e)(3». Source: Steve Hirsch (202) 382-7703 Research: Jennifer Brock 6. Land Disposal Ban A petrochemical company generates a solid waste that contains traces of naturally occurring benzene and toluene [The waste is quenching oil]. Would the presence of these hazardous constituents prohibit the generator from land-disposing this waste? Section 3004(e) of the Solid Waste Disposal Act, as amended by Section 201 of the Hazardous and Solid Waste Amendments of 1984, prohibits land disposal of certain RCRA hazardous wastes. On January 14, 1986, (51 FR 1602), EPA proposed that the spent solvents, F001 through F005, be among those wastes banned from land disposal (§268.30(b), 51 FR 1763). Both spent toluene and spent benzene (added to F005 on February 25, 1986, 51 FR 6537) are listed in the F005 group, but only when they meet the listing as spent solvents. ------- - 7 - The --quenching oil does contain the hazardous constituents of concern, namely benzene and toluene, but does not meet the listing of F005. The oil does not contain spent benzene or toluene used for solvent purposes. Accordingly, the oil would not be banned from land disposal by the proposed §280.30. The spent quenching oil, however, would be subject to other bans on the disposal of bulk and noncontainerized hazardous (if it exhibited a characteristic) and non-hazardous liquid wastes in landfills (§264.314(a), 50 FR 28748, and §264.314(e), 50 FR 28749; §265.314(b), and (f), 50 FR 28750). In the future, the quenching oil may also be listed as RCRA hazardous waste F030, depending on the outcome of the rule proposed on November 29, 1985 (50 FR 49170). Within six months of that listing, EPA would have to make a decision on whether used oil should be banned from land disposal per §3004(g)(4). Source: Alan Corson (202) 382-4770 Research: Jim Ginley 7. Corrective Action for UIC Wells The owner of a hazardous waste underground injection well is applying to his State for a UIC permit after November 8, 1985. Section 3004(u), as amended by the Hazardous and Solid Waste Amendments of 1984, stipulates that a RCRA permit issued after November 8, 1984 must require corrective action for all releases of hazardous waste or constituents from any solid waste management unit at a treatment, storage, or disposal facility. Must corrective action be addressed in the UIC permit? Section 270.60(b), regarding permit-by-rule regulations for UIC wells was amended in the final codification rule (50 FR 28752) to require compliance with corrective action regulations under §264.101. The proposed codification rule of March 28, 1986 restates that a UIC permit issued after November 8, 1984 is not a RCRA permit-by-rule until corrective action requirements have been met for all solid waste management units at the facility (51 FR 10714). A memorandum dated April 9, 1986, from Michael Cook (Office of Drinking Water) to the Regions further clarifies this point by stating that a UIC permit is a RCRA permit-by-rule when corrective action has been addressed for the entire facility. Corrective action for the well only will be addressed in the UIC permit. If there are other RCRA units at the facility, corrective action for those units will be addressed in a RCRA permit, when it is issued. If there are no other RCRA units requiring a RCRA permit, then corrective action for any other solid waste management units will be addressed in the UIC permit. Source: Dave Fagan (202) 382-4740 Research: Kim Gotwals ------- - 8 - CERCIA 1. Endangerment and Exposure Assessments What is the difference between an endangerment assessment and an exposure assessment under CERCLA? An endangerment assessment must be conducted for all CERCLA enforcement sites. At a minimum, it should establish the potential health and environmental threats of the site in the absence of response action. One component of the endangerment assessment is the exposure assessment which evaluates the extent and duration of human exposure to site contaminants. The Endangerment Assessment Handbook describes the endangerment assessment process in detail and explains its relationship to other types of assessment. Endangerment assessments may also be done to support a RCRA §7003 enforcement action. Source: Kathy Plourd (202) 382-5646 Lee Tyner (202) 382-7703 Research: Jennifer Brock 2. CERCLA Section 108(b) f Section 108(b) of CERCLA states that: "Beginning not earlier than 5 years after the date of enactment, the President shall promulgate requirements (for facilities in addition to those under Subtitle C of the Solid Waste Disposal Act and other Federal law) that classes of facilities establish and maintain evidence of financial responsibility consistent with the degree and duration of risk associated with the production, transportation, treatment, storage, or disposal of hazardous substances." Has the EPA proposed any regulations to implement these financial requirements? No, the EPA has not proposed any regulations in order to implement financial assurance requirements under §108(b)(l) of CERCIA. EPA did, however, ask for cements on identifying the classes of facilities for which financial requirements would be developed (48 FR 21598). Source: Sylvia Lowrance (202) 475-8253 Carole Ansheles (202) 382-4761 Research: Ingrid Rosencrantz ------- - 9 - 3. CERCIA "Hazardous Substances What mechanism exists for adding hazardous substances to the CERCIA list? Currently , the hazardous substance list is found in 40 CFR 302.4. As provided in Section 101(14) of CERCIA, the list of hazardous substances contains substances regulated under RCRA, CWA, CAA, and TSCA. Whenever the Agency designates new substances under any one of those statutes, the substances automatically become CERCIA hazardous substances by operation of Section 101(14). EPA has authority under §102 (a) of CERCIA to designate additional hazardous substances "which, when released into the environment, may present substantial danger to the public health or welfare or the environment..." On May 25, 1983 the Agency published an advance notice of proposed rulemaking on procedures to designate additional substances under Section 102 (48 FR 23602). However, the Agency has not gone final on these procedures. Thus, there are currently no procedures in place for the addition of new substances to the list under CERCIA. Additions to the list must occur through designation under other statutes. The Agency is currently in the process of developing the designation procedure and will, in particular, be studying the designation under Section 102 of the acutely toxic chemicals identified by EPA's Chemical Emergency Preparedness Program (CEPP). The CEPP focuses on chemicals that meet EPA's criteria as being acutely toxic (i.e., that can cause death or injury in the event of an accidental air release) . The list of approxi- mately 400 acutely toxic chemicals, the criteria and EPA's interim guidance on developing contingency plans for releases is available in one document entitled "Chemical Emergency Preparedness Program Interim Guidance," November 1985. The document is available from the CEPP hotline at (800) 535-0202 or (202) 479-2449. Source: Jack Kcoyomjian (202) 382-4130 Carrie Wehling (202) 475-8067 Research: Denise Wright ------- - 10 - IV. ANALYSES OF QUESTIONS The Hotline responded to 9,066 questions and requests for documents in April, the questions asked, the percentage of callers was: Of Generators Transporters TSDF's EPA HQ's EPA Regions Federal Agencies Local Agencies Breakdown of calls by 15% 3 2 11% 4 16% 1% 6% 1% 3% 3% 2% EPA Regions: 25% 15% International 0 State Agencies Consultants Press 4% 22% 4% Trade Associations <1% Citizens <1% UST 0/0 Used Oil Handlers Others 5 17% 7 68% 8 27% 4% 4% 4% 4% 9 7% 10 2% RCRA General Information 3010 Notification 260.10 Definitions 260.22 Petit ions/Delisting 261.2 Solid Waste Definition 261.3 Hazardous Waste (HW) Defn. 261-C Characteristic HW 261-D Listed HW 261.4 Exclusions 261.5 Small Quantity Generator 261.6 Recycling Standards 266-C Use Constituting Disposal 266-D HW Burned for Energy Recovery 266-E Used Oil Burned for Energy Recovery 266-F Precious Metal Reclamation 266-G Spent Lead-Acid Battery Reclamation 261.7 Container Residues 262 Generator (Gen'l) Manifest Info Pre- transport Accumulation Recordkeepinq & Reporting International Shipments 263 Transporter 270 B - Permit Application D - Changes to Permits F - Special Permits G - Interim Status 271 state Programs 124 Administrative Procedures Liability/Enforcement Referrals 222 90 82 40 127 204 207 197 92 143 91 19 72 124 40 40 39 54 76 20 82 17 20 39 30 6 16 35 64 7 22 184 264/265 TSDF g A-Scope/Applicability f B-General Facility Standards C-Preparedness/Prevention D-Contingency Plans E-Manifest/Recordkeeping/Reporting F-Groundwater Monitoring G-Closure/Post-Closure H-Financial Requirements I-Containers J-Tanks K-Surface Impoundments L-Waste Piles M-Land Treatment N-Landfills 0-Incinerators P-Thermal Treatment Q-Chemical, Physical, Biological Treat. R-Underground Injection XA-Mi scellaneous/Exper imental CERCLA General/Overv iew Hazardous Substances/RQ NCP Taxes/PCLTF Removal Remedial NPL On-site policy Off-site Policy CERCLIS/Not i f icat ion Liability/Enforcement CERCLA Reauthorization 80 42 4 9 4 87 64 50 22 82 30 9 20 41 14 6 4 3 3 88 115 20 15 17 39 103 14 23 25 46 45 Document Requests 1512 ------- - 11 - RCRA AMENDMENTS General 26 Effective Dates 32 Small Quantity Generators_ Liquids in Landfills Ban_ 224 Land Disposal Restrictions_ Storage of Banned Waste Minimum Technology Standards_ Groundwater Comraission_ Corrective Action Interim Status Corrective Action Orders Loss of Interim Status_ Permits Exposure Assessments_ RD&D Permits Waste Minimization 31 71 32 26 Retrofitting Surface Impoundments 16 Groundwater Monitoring 9 28 26 47 15 11 11 30 Listings/Characteristic Revision 51 Delisting 27 Used Oil Listing 777 Recycling Std._ 63 Hazardous Waste Exports_ Mining waste, Utility Waste & Cement Kiln Dust Uranium Mill Tailings_ State Implementation__ Subtitle D Procurement Guidelines Inventory of Injection Wells_ Inventory of Federal Facilities_ Inspect ions Federal Enforcement^ Citizen Suits H.W. Underground Tanks UST Definitions Notification Interim Prohibition Tank Standards Total 10 Dioxins from Resource Recovery 10 Domestic Sewage 3 42 381 938 86 97 1502 ------- - 12 - V. Publications RCFtA Memorandum entitled "Implementation of Waste-as-Fuel Rules at DOD Facilities" dated March 19, 1986 from Marcia Williams, Director, Office of Solid Waste is available by calling Bob Holloway at (202) 382-7936. "Funding Needs for Subtitle D Activities," a preliminary report to Congress, April 1985, is available by calling Mike Flynn at (202) 382-4489. "Permit Writers' Guidance Manual for Hazardous Waste Land Storage and Disposal Facilities - Phase I: Criteria for Location Applicability and Existing Applicable Regulations" is now available through the National Technical Information Service (NTIS). The publication number is PB-86- 125580. "Interim Guidance Concerning Corrective Action for Prior and Continuing Releases - Underground Injection Control Program Guidance #45; a memorandum from the Office of Water dated April 9, 1986 is available by contacting Harriet Hubbard at (202) 382-5330. The Science Advisory Board Report on EPA's "Ground-Water Monitoring Technical Enforcement Guidance Document" is available to the public by calling Sheryl Bently at (202) 382-2552. If the caller is frcm the EPA, copies may be obtained by from Mary Ratiff at (202) 382-4126. The yearly updates to the "Survey or Selected Firms in the Conmercial Hazardous Waste Industry, 1980," SW-894.2, 894.3 and 894.4, are available through the RCRA Docket. The Hotline will take requests. List of UST definitions and exemptions (April 1985) is available from Office of Underground Storage Tanks. The Hotline will take requests. "Hazardous Waste Implementation Strategy" (DRAFT) a letter from Marcia Williams, Director, Office of Solid Waste, is available by calling her office at (202) 382-4627. CERCLA "Draft Addendum to January 17, 1986 Guidance CERCLA Funding of State Oversight to Potentially Responsible Parties," is available by calling Tony Di ecidue at (202) 382-4841. "Reporting and Exchange of Information on State Enforcement Actions at NPL Sites" is available by calling Tony Diecidue at (202) 382-4841. ------- - 13 - The "Superfund Public Health Evaluation Manual" (DRAFT) December 5, 1985 and the "Superfund Exposure Assessment Manual" (DRAFT) January 14, 1986 are now available by calling the Public Information Center (PIC) at (202) 829-3535 or (800) 828-4445. The Bill reauthorizing CERCLA for 60 days (until May 31, 1986) is "House Joint Resolution (HJR) 573" and copies are available by calling the House Documents Rocm at (202) 225-3456. ------- - 14 - VI. FEDERAL REGISTER NOTICES FOR APRIL Former Notices with Open Garment Period as of May 1, 1986 February 4, 1986: 51 FR 4458 (proposed state sewage sludge management programs) March 5, 1986A: 51 FR 7593 ("Land Disposal Petitioners Guidance Manual") March 28, 1986: 51 FR 10706 (proposed codification rule) April Federal Register Notices April 9, 1986: 51 FR 12148 (denial of forty-six delisting petitions) April 21, 1986: 51 FR 13497 (correction to UST notification rule) April 21, 1986: 51 FR 14526 (EPA's semiannual regulatory agenda) April 22, 1986: 51 FR 15018 (tentative final authorization for California) April 29, 1986: 51 FR 15887 (notice of final delistings) Proposed rule to require states to develop sewage sludge management programs that assure compliance with Federal Criteria for the use and disposal of sewage sludge. The proposed rule provides procedures for obtaining EPA approval of State sewage sludge management programs. Comments are due by May 5, 1986. Notice of availability of document entitiled "Lane Disposal Petitioners Guidance Manual," to be used for petitioning the Agnecy for the removal of lane disposal restrictions (proposed January 14, 1986) Comments on the document are due by May 5, 1986. Proposed codification of HSWA provisions concerni double liners, leachate collection systems, corrective action beyond facility property bounda underground injection wells, and the agplicabilit of post-closure permitting standards, Contents ar due by May 27, 1986. Notice of denial of forty-six delisting petitions Basis for denial is insufficient information on hazardous or non-hazardous nature of waste. Effective date is April 9, 1986. Correction of dates for notification by depositoi of UST owners regarding UST notification requirements, published in the November 8, 1985 Federal Register (50 FR 46602). Publication of EPA's semiannual regulatory agend This agenda provides the status of regulations u development, revision, and review at the Agency. Notice of tentative determination for final authorization of California's hazardous waste management program. Comments are due by June 4, 1986. Notice of final exclusions granted for waste generated at three facilities. Effective date is April 29, 1986. ------- - 15 - April 29, 1986: 51 FR 15916 (proposal to deny del1sting peitions and revoke temporary exclusions) April 30, 1986: 51 FR 16061 (proposal to grant delistings) Notice of proposal to deny sixteen delisting petitions and revoke two temporary exclusions. Basis for denial and revocation is insufficient information in petitions on hazardous or non- hazardous nature of waste. Ccrnnents are due by June 12, 1986. Notice of proposal to grant exclusions for wastes generated at five facilities. Canments are due by May 30, 1986. ------- -14- Martha Anderson, DOFM Frank Biros, WH-527 George Bonina, WH-563 Susan Brown, WH-563 Kaien Brown, PM-220 John Bosky, EPA - Kansas City, KS Diane Buxbaum, Region II Richard Clarizio, Region V Eileen Claussen, WH-562 Pat Cohn, WH-527 Kathy Collier, Research Triangle Park, N.C. Peter Cook, WH-527 Alan Corson, WH-565 Elizabeth Cotsworth, WH-563 Hans Crump, WH-548B Truett DeGeare, WH-563 Steve Dorrler, EPA - Edison, NJ Melinda Downing, DOE Barbara Elkus, WH-527 Tim Fields, WH-548B Elaine Fitzback, WH-527 Lisa Friedman, LE-132S George Garland, WH-562 John Gilbert, EPA - Cincinnati, OH lantha Gilmore, WH-562 Peter Guerrero, WH-563 Penny Hansen, WH-562 Bill Hanson, WH-548E Betti Harris, EPA-Region VII William Hedeman, WH-556 Lee Herwig, A-104 Hotline Staff Warren Hull, A-104 Phil Jalbert, WH-548D Alvin K. Joe, Jr., Geo/Resource Gary Jonesi, WH-562B Sylvia Lawrance, WH-527 Jim Jowett, WH-548B Thad Juszczak, WH-562A Robert Knox, WH-562 Jack Kooyocmjian, WH-548B Mike Kosakowski, WH-527 Jerry Kotas, WH-527 Walter Kovalick, WH548 Tapio Kuusinen, PM-223 Robert Landers, EMSL/LV Carol Lawson, A-107 Steve Leifer, LE-135 Steve Levy, WH-563 Henry Longest, WH-548 Gene Lucero, WH-527 James Makris, WH-548A Jack McGraw, WH-562A Scott McPhilamy, Reg. Ill Tony Montrone, WH-527 Sue Moreland (ASTSWMO) Sam Napolitano, PM-220 Christina Parker, WH-562 Karen Reed, PM-273 John Riley, WH-548B Clem Rastatter, WH-548 Dale Ruhter, WH-565 William Sanjour, WH-563 Susan Sawtelle, WH-562 Pam Sbar, LE-134S Mike Shannon, WH-563 Ken Shuster, WH-565 Elaine Stanley, WH-548 Jack Stanton, WH-527 Hillary Sommer, N.C. Bruce Weddle, WH-563 Steve Wilhelm, Region VII Marcia Williams, WH-562 Hazardous Waste Division Directors, Regions I-X Hazardous Waste Management Branch Chiefs, Regions I-X Regional Counsel, Regions I-X Regional Libraries, Regions I-X ------- CONTINUATION OF HOTLINE REPORT ADDRESSEES Sue Moreland Executive Director Association of State & Territorial Solid Waste Managment Officials Suite 343 444 N. Capital Street, N.W. Washington, D.C. 20001 r Joyce Baker The EPA Library, Region III 6th & Walnut Sts. Philadephia, Pa. 19106 Steve Dorrler U.S. EPA Environmental Response Branch Woodbridge Avenue Raritan Depot, Bldg. 10 Edison, NJ 08837 John Gilbert U.S. EPA Environmental Response Branch 26 West St. Clair Street Cincinnati, OH 45268 Diane McCreary Library U.S. EPA - Region III 6th & Walnuts Streets Philadelphia, PA 19106 Alvin Joe Geo/Resource Consultants, Inc 1620 Montgomery Street San Francisco, CA 94111 John Bosky U.S. E.P.A. Region VII 25 Funston Road Kansas City, KS 66115 Doug Skie Chief, RCRA/Superfund Program U.S. EPA - Region 8 Federal Building, Room 292 301 South Park Drawer 10096 Helena, Montana 59601 Betti Harris State Programs Section U.S. EPA - Region VII 324 East Eleventh Street Kansas City, Missouri 64106 NOTE: Barbara Hostage should also get a copy MAIL CODE: WH-548 & Hotline gets 7 copies (Next page) ------- Carl Eklund, Division of Solid & Hazardous Waste DEQE Winter Street Boston, MA 02108 Robert Landers EMSL - LV P.O. Box 15027 Las Vegas, NE 89114 St|ve Wilhelm Chief, Records Compliance U.S. EPA - Region VII 324 East llth Street Kansas City, Missouri 64106 U.S. EPA Library, Region IX 213 Freemont St. San Francisco, CA 94105 Attn: Marcia Saylor Chris Jansen Pacific Resources, Inc. P.O. Box 2279 Honolulu, HI 96842 Drew McCoy McCoy and Associates Hazardous Waste Consultants 13131 West Cedar Drive Lakewood, Colorado 80228 Martha A. Anderson Director, The University of Arizona Department of Risk Management 1143 North Cherry Avenue Tucson, Arizona 85719 Lucy Mlenar U.S. EPA - Region V 230 South Dearborn Street Chicago, IL 60604 Diane Buxbaum, U.S. EPA-Region II 2AWM-SW 26 Federal Plaza New York, NY 10278 Ken McGill (3HW11) U.S. EPA, Region III Waste Enforcement Branch PA/RCRA Enforcement Section 841 Chestnut Street Philadelphia, PA 19107 Bruce Smith (3HW10) Chief, Waste Enforcement Branch U.S. EPA, Region III 841 Chestnut Street Philadelphia, PA 19107 ------- Kathy Collier Air Information Center U.S. EPA Mail Drop 35 Research Triangle Park, NC 27711 Mr. Scott McPhilamy EPA Region III Wheeling Field Office 303 Methodist Bldg. ll£h & Chapline Streets Wheeling, WV 26003 Richard Clarizio U.S. - EPA V 230 South Dearborne (5HS-13JCK) Chicago, IL 60604 Hillary Scraner Nuclear Production Dept. Duke Power Co. P.O. Box 33189 Charlotte, NC 28242 Melinda Downing Dept of Energy 1000 Independence Ave., S.W. 3G092 Washington, D.C. 20585 Travis Wagner Soil & Material Engineering, Inc. 1903 Harrison Avenue Box 609 Gary, North Carolina 27511 Headguarters SAC/BEP Offutt AFB, Nebraska 68113 ------- Regional Libraries U.S. EPA - Region I J. F. K. Federal Building Boston, Ma 02203 ATTN: Librarian U.S. EPA - Region II 26 Federal Plaza New York, NY 10278 ATTN: Librarian U.S. EPA - Region III 841 Chestnut Street Philadelphia, PA 19107 ATTN: Librarian U.S. EPA - Region IV 345 Courtland Street, N.E. Atlanta, GA 30365 ATTN: Librarian U.S. EPA - Region V 230 South Dearborn Street Chicago, IL 60604 ATTN: Librarian U.S. EPA - Region VI 1201 Elm Street Dallas, TX 75270 ATTN: Librarian U.S. EPA - Region VII 72 Minnesota Avenue Kansas City, KS 66101 ATTN: Librarian U.S. EPA - Region VIII 1860 Lincoln Street Denver, CO 80295 ATTN: Librarian U.S. EPA - Region IX 215 Fremont Street San Francisco, CA 94105 ATTN: Librarian U.S. EPA - Region X 1200 Sixth Avenue Seattle, WA 98101 ATTN: Librarian ------- Hotline Disk 3/22/85 Regional Counsels, Regs. I - X Patrick A. Parenteau Office of Regional Counsel U.S. EPA - Region I J. F. K. Federal Building Boston, Ma 02203 Douglas R. Blazey Office of Regional Counsel U.S. EPA - Region II 26 Federal Plaza New York, NY 10278 Bruce M. Diamond Office of Regional Counsel U.S. EPA - Region III 841 Chestnut Street Philadelphia, PA 19107 James H. Sargent Office of Regional Counsel U.S. EPA - Region IV 345 Courtland Street, N.E. Atlanta, GA 30365 Robert B. Schaefer Office of Regional Counsel U.S. EPA - Region V 230 South Dearborn Street Chicago, IL 60604 Paul A. Seals Office of Regional Counsel U.S. EPA - Region VI 1201 Elm Street Dallas, TX 75270 David R. Tripp Office of Regional Counsel U.S. EPA - Region VII 726 Minnesota Avenue Kansas City, KS 66101 Tom Speicher Office of Regional Counsel U.S. EPA - Region VIII 1860 Lincoln Street Denver, CO 80295 Karl R. Morthole Office of Regional Counsel U.S. EPA - Region IX 215 Fremont Street San Francisco, CA 94105 James R. Moore Office of Regional Counsel U.S. EPA - Region X 1200 Sixth Avenue Seattle, WA 98101 ------- Linda Murphy U.S. EPA - Region I Chief, Waste Management Branch John Kennedy Bldg. Boston, MA 02203 Rich Walka U.S. EPA - Region II Chief, Solid Waste Branch 26rFederal Plaza Nefr York, NY 10007 Robert Allen U.S. EPA - Region III Chief, Hazardous Materials Branch 6th & Walnut Streets Philadelphia, PA 19106 James H. Scarbrough U.S. EPA - Region IV Chief, Residuals Management Branch 345 Courtland Street NE Atlanta, GA 30365 David Stringham U.S. EPA - Region V Chief, Waste Management Branch 230 S. Dearborn Street Chicago, IL 60604 Randy Brown Chief, Hazardous Materials Branch U.S. EPA - Region VI 1201 Elm Street Inter First Two Bldg. Dallas, Texas 75270 Mike Sanderson U.S. EPA - Region VII Chief, Hazardous Materials Branch 726 Minnesota Avenue Kansas City, KS 66101 Louis W. Johnson U.S. EPA - Region VIII Chief, Waste Management Branch 1860 Lincoln Street Denver, CO 80295 Philip Bobel U.S. EPA - Region IX 215 Fremont Street San Francisco, CA 94105 Kenneth D. Feigner U.S. EPA - Region X Chief, Waste Management Branch 1200 Sixth Avenue Seattle, WA 98101 ------- Merrill S. Hohman U.S. EPA - Region I Director, Air & Hazardous Materials Division John F. Kennedy Bldg. Boston, MA 02203 Conrad Simon U.S. EPA -Region II Director, Water Division 26 Federal Plaza Stephen R. Wassersug U.S. EPA - Region III Director, Air, Toxics & Hazardous Materials Division 6th and Walnut Streets Philadelphia, PA 19106 Tom Devine U.S. EPA - Region IV Director, Air and Hazardous Materials Division 345 Courtland Street NE Atlanta, GA 30365 Bill Constantelos U.S. EPA - Region V Waste Management Division 16th Floor 230 S. Dearborn Street Chicago, IL 60604 Allyn M. Davis U.S. EPA - Region VI Air & Hazardous Materials Division 1201 Elm Street First International Bldg. Dallas, TX 75270 David Wagoner U.S. EPA - Region VII Air & Hazardous Materials Division 726 Minnesota Avenue Kansas City, KS 66101 Robert L. Duprey U.S. EPA - Region VIII Air & Hazardous Materials Division 1860 Lincoln Street Denver, CO 80295 Harry Seraydarian U.S. EPA - Region IX Toxics & Waste Management Division 215 Fremont Street San Francisco, CA 94105 ------- Charles Findley U.S. - EPA - Region X Air & Hazardous Materials Division 1200 6th Avenue Seattle, WA 98101 Kathleen Hodley National Center for Appropriate Technology P.O. Box 3838 Butjte, I^TT 59702 ------- |