UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 April 24, 1987 OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE 530R87102 MEMORANDUM SUBJECT: Final Monthly Report - RCRA/Superfund Industry Assistance Hotline Report for February 1987 r**^ , FROM: Thea McManus, Officepf Solid Waste f\>y" Jt Hubert Watters,i'0ff ice of Emergency and Remedial Response (WH-548) TO: See list of addressees This report is prepared and submitted for EPA contract No. 68-01-7371. I. ACTIVITIES \ A. The Hotline received 6,398 calls during February. Hotline staff responded to 7,970 questions and requests for documents during February. B. On February 11, Paul Cassidy of OSW briefed the Hotline on the proposed rule on containerized liquids in landfills (51 _FR 46824). Major topics discussed included the liquids release test (LRT), absorbent biodegradability, and the paint filter test. C. On February 12, Hotline staff members met with Chuck Carpenter and Alicia Corley of OWPE and Pat Murray and George Bonina of OSW to discuss the Hazardous Waste Data Management System (HWDMS). The Hotline frequently receives inquiries on the permitting and compliance status of facilities as well as the number and names of generators and facilities. Being more informed on what types of information is available in HWDMS is most helpful in responding to these requests. D. On February 25, John Cross of OWPE briefed the Hotline on CERCLA enforcement. He highlighted and discussed the major enforcement related implementation activities under the Superfund Amendments and Reauthorization Act (SARA). E. Hotline staff started attending the Superfund Amendments and Reauthorization Act (SARA) workgroups as observers to keep up-to- date with EPA's implementation activities under SARA. Attending these workgroups will make the Hotline more cognizant of the development processes, major issues, and decision milestones involved in the development of regulations and guidance. ------- F. Hotline management net with Thea McManus, Joan Warren and Mary Jean DePont of OSW to discuss the various reports generated by the new Hotline phone system. Wbrk is ongoing to identify the phone reports which EPA will receive regularly on the Hotline operations. G. During February, OSW and Hotline staff have met frequently to discuss the February 2, 1987 AMS joint RCRA Docket and RCRA/Superfund Hotline Automated Information System Study. AMS staff briefed OSW and Hotline staff on the study. Hotline staff met with OSW staff to discuss their comments on the study. The Hotline has reviewed the report thoroughly and has prepared comments. II. SIGNIFICANT QUESTIONS AND RESOLVED ISSUES A. RCRA 1. Small Quantity Generator Determination A recycler regenerates listed spent solvent (F005) that he receives from off-site. The recycler burns the still bottoms and a portion of the reclaimed solvent on-site in an industrial furnace. He sells the remaining reclaimed solvent to two companies: one that will burn it as fuel and one that will use the solvent for its solvent properties. How does the recycler count the still bottoms and reclaimed solvent for the purpose of small quantity generator monthly quantity determinations? The recycler must include the still bottoms-in his quantity determinations because they are hazardous waste generated on- site and burned for energy recovery. As a hazardous waste fuel, they are subject to 40 CFR Part 266 Subpart D. According to §261.5(c), a generator must count wastes subject to Part 266 subpart D in his monthly quantity determination. The reclaimed solvent fuels that are burned on-site and marketed off-site are subject to Part 266 Subpart D and the counting requirements. The only waste quantity that the recycler does not include in his quantity determinations is the reclaimed solvent that will be used for its solvent properties. 40 CFR 261.3(c)(2)(i) exempts reclaimed materials that will be used beneficially from regulation as wastes as long as they are not burned for energy recovery or used in a manner constituting disposal. Because the reclaimed solvent will be used as a solvent and not a fuel or product applied to the land, it would not be included in the monthly quantity determinations. Source: Mike Petruska (202) 475-8551 Specialist: Jennifer Brock (202) 382-3112 -2- ------- 2. F006 F006 is specifically electroplating wastewater treatment sludge. If a corrosive electroplating wastewater is drunnied up and shipped off-site without treatment it is classified as D002. This waste goes to an acid waste treatment facility where it is mixed with other various types of acid wastes. Is the sludge from this treatment process going to be classified as F006? Yes, since some of the waste is electroplating wastewater, the sludge is partly derived from the wastewater and will meet the definition of F006. Source: Steve Hirsch (202) 382-7706 Specialist: Randy Eicher (202) 382-3112 3. Liquids in Landfills In the "Statutory Interpretative Guidance on the Prohibition of Liquid Hazardous Waste in Landfill", May 6, 1985, the discussion of chemical stablization indicates that the stablized material must achieve a strength of at least 50 p.s.i. and pass the paint filter test for free liquids. Does the Agency require that the waste has fully achieved the 50 p.si. level or above before disposal or that the waste just pass the paint filter test? Section 3004(c)(l) prohibits the disposal in a landfill of bulk liquids to which absorbents have been added. The Agency has not issued regulations prescribing a method to determine whether absorbents have been added, but the guidance does recommend the owner/operator provide a one-time demonstration that 50 p.s.i. can be achieved. The waste need only pass the paint filter test once the initial one time demonstration that the process will achieve at least 50 p.s.i. has been completed. Source: Paul Cassidy (202) 382-4682 Specialist: Randy Eicher (202) 382-3112 4. Land Disposal Restrictions The Nbventoer 7, 1986 Federal Register (51 FR 40572), land disposal restrictions final rule, states that the storage of hazardous waste which is restricted from land disposal is prohibited unless conditions are met under §268.50. A generator has interim status to store waste on-site. The generator wants to store his waste for up to one year to accumulate the waste as necessary to facilitate proper recovery, treatment and disposal in accordance with §268.50(b) (51 FR 40572). When does the one year begin? -3- ------- Storage of restricted wastes by permitted or interim status facilities is allowed solely for the purpose of accumulating sufficient quantities to facilitate proper treatment, recovery or disposal. The one-year period acts as a bench-mark to determine which party (EPA or the storage facility) bears the burden of proof to demonstrate that storage is for the allowable reasons. For storage of one year or less, the burden is on EPA to demonstrate non-compliance. For storage more than one-year, the burden is on the facility owner or operator to demonstrate that such storage time is necessary. The owner/operator does not have to notify the agency of storage for more than one year. The burden of proof only applies in the event of an EPA inspection or for enforcement purposes. For a generator with interim status or a permit to store hazardous wastes, the one year begins on the date the waste is first placed in the tank or container. If the generator accumulated the waste prior to the effective date of the land disposal restrictions final rule (51 PR 40572), the waste is not subject to the rule. Therefore, tEe generator can store his waste indefinitely since he has interim status to store a hazardous waste. The November 7, 1986 land disposal restrictions final rule (51 FR 40572) allows generators to gain interim status if compliance with the land disposal restrictions requires storage for more than 90 days. Source: Mitch Kidwell (202) 382-4805 Research: Carla Rellergert (202) 382-3112 5. Appealing a Petition Denial A generator submitted a petition under §260.22 to amend Part 261 to exclude a hazardous waste produced at a particular facility, but the Agency's final decision was to deny the petition. What options does the generator have for appealing the Agency's decision to deny the petition? A generator who has had his petition denied by the Agency may appeal to the U.S. Court of Appeals for the District of Columbia Circuit, pursuant to §7006(a)(l) of RCRA. The generator may also wish to petition the Agency for reconsideration of the decision. Denial of a delisting petition is a final Agency action, however, and a petition for reconsideration does not extend the time to file suit in court. Source: Steven Hirsch (202) 382-7706 Research: Joe Nixon (202) 382-3112 ------- B. CERCLA 1. Worker Protection Standards Section 126(e) of the Superfund Amendments and Reauthorization Act (SARA) requires the Occupational Safety and Health Administration (OSHA) to issue interim final regulations concerning worker protection standards for employees engaged in hazardous waste operations, within 60 days after the enactment date of SARA. OSHA responded with the issuance of an interim final rule in the Federal Register on December 19, 1986 (51 FR 45654). The interim final regulations amend the OSHA employee protection standards found in Subpart H of 29 CFR Part 1910. The interim final rule became effective immediately and regulates employee safety and health at hazardous waste operations and during emergency response to hazardous substance incidents. The interim final regulations shall apply until final regulations become effective. However, OSHA does not have jurisdiction over state and local government employees. This role was left up to the individual states. Twenty-five states have their own OSHA approved occupational safety and health plans. These states must develop a comparable standard applicable to both private and public (state and local government employees) sectors within six months of the publication date of the interim final rule or show OSHA why there is no need for action, e.g., because an existing state standard covering this area is already "at least as effective" as the new Federal standard (51 FR 45662, December 19, 1986). What protection standards will apply to employees of state and local governments in the remaining 25 states which do not have an OSHA approved state plan? Employees of state and local governments in the remaining 25 states which do not have an OSHA approved state plan are not subject to the interim final worker protection standards. Section 126(f) of SARA addresses the coverage of these state and local employees in states without an approved OSHA plan. Within 90 days after OSHA promulgates the final regulations on worker protection standards, EPA shall promulgate identical standards. These EPA standards will apply to employees of state and local governments in states without an approved OSHA plan. The final OSHA regulations (which will be duplicated by EPA) include worker protection provisions relating to site analysis; training; medical surveillance; protective equipment; engineering controls; maximum exposure limits; informational program; handling; new technology program; decontamination procedures; and emergency response. OSHA must promulgate these final standards within one year after the enactment date of SARA per SARA section 126(a). The final regulations will be effective within one year after the promulgation date (section 126(c) of SARA). Source: Joe Freedman (202) 382-7700 Elva Slagle (202) 382-2997 Research: Caroline Danek (202) 382-3112 -5- ------- 2. Contractor Indemnification Does the contractor indemnification provision which was added to CERCLA by the Superfund Amendments and Reauthorization Act of 1986 (SARA §119(c)) extend to subcontractors or EPA contractors who are transporting hazardous substances from a CERCLA site? Yes it may. Section 119(c) of CERCLA, as amended, authorizes EPA to indemnify response action contractors for third party liabilities arising from a release of hazardous substances due to the contractors' negligence. Both EPA response contractors and their subcontractors are eligible for indemnification. EPA is developing guidelines regarding the nature and extent of the indemni fication. Source: Tom Gillis (202) 382-4524 Research: Deborah McKie (202) 382-3112 -6- ------- III. ANALYSES OF QUESTIONS Manufacturers 5.0% Generators 24 . 4& Transporters 2.0% TSDF's 9.0% EPA HQ's 3.0% EPA Regions 2.4% Federal Agencies 2.0% Local Agencies 2.0% Breakdown of calls by EPA Regions: 1 5.4% 3 22.5% 2 12.4% 4 11.0% Internat ional 0.4% RCRA General Information 477 3010 Notification 99 260.10 Definitions 89 260.22 Petitions/Delisting 34 261.2 Solid Waste Definition 177 261.3 Hazardous Waste Definition 281 261-C Characteristic HW 368 261-D Listed HW 352 261.4 Exclusions 112 261.5 Small Quantity Generators 125 261.6 Recycling Standards 102 266-C Use Constituting Disposal 8 266-D HW Burned for Energy Recovery 83 266-E Used Oil Burned for Energy Recovery 115 266-F Precious Metal Reclamation 15 266-G Spent Lead-Acid Battery Reclamation 29 261.7 Container Residues 42 262 Generator (Gen'l) 88 100-1000 kg/too, generator 92 Manifest Info 88 Pre-transport 18 Accumulation 101 Recordkeeping & Reporting 34 International Shipments 19 263 Transporter 58 264/265 TSDF A-Scope/Applicability 80 B-General Facility Stdrds. 20 State Agencies 4.4% Consultants 32.0% Press 0.4% Trade Associations 0.6% Citizens 4.0% UST 0/0 3.6% Used Oil Handlers 2.2% Others 3.4% 5 12.0% 7 6.0% 6 9.2% 8 4.0% C-Preparedness/Prevent ion D-Contingency Plans E-Mani f es t/Recordkeep ing/ Reporting F-Ground-Water 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-Chem. , Phy s . , Bio . Treatment R-Underground Injection X-Miscellaneous Part 268-Land Disposal Restrictions Part 269-Air Emissions 270 B - Permit Application D - Changes to Permit F - Special Permits G - Interim Status 271 State Programs 124 Administrative Procedures Liabi 1 i ty /Enforcement Corrective Action HSWA General Waste Minimization Dioxins Subtitle D Referrals Document Requests SUBTOTAL (RCRA) 9 13.5% 10 4.0% 21 15 10 642 87 103 22 144 42 2 4 53 53 7 7 6 4 208 15 66 14 8 36 57 10 24 71 20 31 21 66 215 1238 6341 -7- ------- CERCIA AND UST CERCLA. (as amended by SARA) General/Overview 112 Access & Information Gathering 8 Allocations from Fund/ Fund Balancing CEPP/"Right to Know" 197 CERCLA Reauthorization 14 CERCLIS/§103(c) Notification 43 Citizen Suits Federal Facilities NPL 0 Clean-Up Standards (ARARs) 44 Contractor Indemnification 4 Exposure Assessment/Public Health Evaluation 22 16 32 Hazardous Substances/RQ 146 Liability/Enforcement Mandatory Schedules NCP 8 29 88 Natural Resource Damages 4 Off-Site Policy On-Site Policy 14 17 Pollution Liability Insurance 1_ RD&D/Training 13_ RI/FS - RODs 19_ Radon 10 Remedial Removal Taxes Settlements Document Requests_ SUBTOTAL (CERCIA) UST Program Definitions: UST regulated substance other Notification Interim Prohibition Tank Standards: leak detection_ inventory other Corrective Action_ Liability Other Provisions Document Requests SUBTOTAL (UST) 32 17 33 15 245 1192 30 17 39 41 45 11 24 11 14 43 155 437 -8- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346 Washington, D.C. Metro #202-382-3000 IV. PUBLICATIONS RCRA "Procedural Guidance for Review of Exposure Information" September 26, 1986 is available by calling the Hotline. "Strategy for Implementation of the EPA Mandatory Quality Assurance Program", March 11, 1980, is available by calling the Quality Assurance Office at ORD (202) 382-5763. The publication number is EPA QAMS 001/80. The "RCRA Ground-Water Monitoring Technical Enforcement Guidance Document" (TEGD) September 1986, OSWER Directive Number 9950.1 is now available through the National Technical Information Service (NTIS) as well as the Government Printing Office (GPO). The NTIS publication number is PB-87-107751 and the cost is §30.95. The phone number for NTIS is (703) 487-4650. The GPO Publication number is 005-00-00260-6 and the cost is §16.95. The phone number for GPO is (202) 783-3238. Interim Final copies of the "Draft Minimum Technology Guidance on Double Liner Systems for Landfills and Surface Impoundments — Design Construction and Operation" (EPA/530-SW-85-014) and the similar document for single liners (EPA/530-SW-85-013) are available by calling Ken Skahn at (202) 382-4684. There will be an official notice of availability and request for comments in the Federal Register around April 1, 1987. "Hazardous Waste: EPA Has Made Limited Progress in Determining Wastes to be Regulated", December 23, 1986, is available from the GAO Report ^ Distribution Center by calling (202) 275-6241 or 275-6242. The publication number is GAO/RECD-87-27. "Waste Oil Interim Enforcement Guidance" dated November 1986 is available by calling Charles Perry at (202) 475-7030. "Permit Applicants Guidance Manual for Unsaturated Zone Monitoring at Land Treatment Units" (EPA/530-SW-86-040) is available by calling ORD at (513) 569-7562. "Use of Water Balance Method" (SW-168) is available for copying at the RCRA Docket. There is a copying cost of 20 cents per page beyond 50 pages. To make an appointment for copying, call the RCRA Docket at (202) 475-9327. "Designing and Installing Underground Storage Tanks under the New Federal Law", January, 1987, is available by calling the Hotline. -9- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346 Washington, D.C. Metro #202-382-3000 CERCLA "Site Descriptions for NPL Update Number 6" is available through the Public Information Center at (800) 828-4445 or (202) 646-6410. "The Integrated Superfund Comprehensive Accomplishments Plan (SCAP)", is available by making a written request to: J. Winston Porter, Assistant Administrator Office of Solid Waste and Emergency Response WH-562A U.S. Environmental Protection Agency 401 M Street, S.W. Washington, D.C. 20460 "Unfinished Business", February, 1987, a document prepared by OPPE dealing with issues of Superfund, is at the printers. In order to be placed on a mailing list for this document, call Pat Neal at (202) 382-4012. -10- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346 Washington, D.C. Metro #203-382-3000 V. FEDERAL REGISTER NOTICES FOR FEBRUARY 1987 Former Notices with Open Comment Period After February 1987 January 22, 1987; 52 FR 2492 (proposed amendment to the National Priorities List) January 26, 1987; 52 FR 2695 (tentative denial of petitions to suspend the lead limit of used oil fuels) January 27, 1987; 52 FR 2836 (proposed chemical inventory forms and inventory reporting requirements) Proposed sixth update to the National Priorities List (NPL). This update contains 64 sites. The NPL is Appendix B to the National Oil and Hazardous Substances Contingency Plan (NCP). These sites are being proposed because they meet the eligibility requirements of the NPL. This notice provides the public with an opportunity to comment on placing these sites on the NPL. Comments must be submitted on or before March 20, 1987. Notice of tentative determination to deny petitions that requested the suspension of the lead limit (lOOppm) which was placed on used oil fuel that is to be burned in any boiler or furnace (November 29, 1985; 50 FR 4964; effective May 29, 1986). Comments on this tentative denial will be accepeted until March 27, 1987. Request for comments on the proposed uniform emergency and hazardous chemical inventory forms and proposed regulations to implement the MSDS and inventory reporting requirements. Sections 311 and 312 of SARA require EPA to publish these uniform formats for use by facilities that are required to prepare material safety data sheets (MSDS) and inventory forms. The information is to be submitted to local and state officials and made available to the public. Written comments should be submitted on or before March 30, 1987. February Federal Register Notices February 4, 1987; 52 FR 3479 (notice outlining Title III petition policy) Notice outlining EPA's policy on the petition provisions of section 313(e) of the Superfund Amendments and Reauthorization Act of 1986, which allows for petitions from the public requesting changes to the List of Toxic Chemicals Subject to Provisions of Section 314 of the Emergency Planning and Community Right to Know Act of 1986. -11- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346 Washington, D.C. Metro #203-382-3000 February 4, (notice of meeting) 1987; 52 FR 3946 a TSDR public Febuary 5, 1987; 52 FR 3651 (Arizona program modification compliance schedule) February 5, 1987; 52 FR 3652 (Guam program modification compliance shedule) February 5, 1987; 52 FR 3698 (Leaking Underground Storage Tanks Trust Fund) February 5, 1987; 52 FR 3699 (limitations on Superfund response claims) February 5, 1987; 52 FR 3748 (proposed rule and notice of public hearing on air emissions from hazardous waste treatment, storage, and disposal facilities) February 10, 1987; 52 PR 4186 (extension of comment period on Ground-Water Protection Strategy document) Announcement of public meeting to address the ATSDR National Hazardous Substance Exposure Registry, which is required by section 104(i) of CERCLA, as amended by section 110 of SARA. The meeting is scheduled for March 23-24, 1987. Notice of Arizona's compliance schedule to adopt Federal program modifications in accordance with Section 271.21(g). Notice of Guam's compliance schedule to adopt Federal program modifications in accordance with section 271.21(g). Announces the availabily of the Leaking Underground Storage Tanks Trust Fund to pay for the cost of certain Federal and State response and enforcement activities for releases from underground storage tanks containing petroleum, as required by section 9003(h) of RCRA, as amended by section 522 of SARA. Advises the public of limitations on Superfund response claims made by private parties seeking reimbursement from the Hazardous Substances Superfund as, contained in the National Oil and Hazardous Substances Contingency Plan (NCP). Proposed standards to limit emissions of volatile organics from hazardous waste treatment, storage and disposal facilities, as required by Section 3004(h) of RCRA. Comments will be accepted until April 6, 1987. A public hearing is scheduled for March 23, 1987. Announces the extension of the public comment period on the draft "Guidelines for Ground-Water Protection Strategy" announced as available in 51 FR 43664. The deadline for submitting written public comments has been extended to March 2, 1987. -12- ------- National Toll Free #800-424-9346 Washington, D.C. Metro #203-382-3000 February 11, 1987; 52 FR 4384 (open meeting on major and minor modifications of RCRA permits) February 12, 1987; 52 FR 4698 (open meeting of the Science Advisory Board) February 17, 1987; 52 FR 4824 (corrections to DOT hazardous substance final rule) February 23, 1987; 52 FR 5472 (availability of delisting petition data) February 23, 1987; 52 FR 5499 (meeting of the Advisory Committee negotiating the Hazardous Waste Injection Restrictions) February 25, 1985; 52 FR 5578 (availability of information on uncontrolled hazardous waste sites) Notice of an open meeting of the Advisory Committee negotiating regulations governing major and minor modifications of Resource Conservation and Recovery Act (RCRA) permits. The meeting is scheduled for February 23, 1987. Notice of an open meeting of the Science Advisory Board Environmental Engineering Gonmittee to discuss the Underground Storage Tanks Failure Model, the Waste Minimization Research Plan, the Mining Waste Screening Phase Risk Assessment Methodology, the Toxicity Characteristic Leaching Procedure and the Air Emissions Characteristics Test. The meeting is scheduled for March 5-6, 1987. Corrects the regulatory text of the DOT final rule amending the Hazardous Materials Regulations, promulgated November 21, 1986 (51 FR 42174), which incorporated CERdA hazardous substances into the Hazardous Materials Regulations. Notice of availability of waste sampling and ground-water monitoring data, submitted by U.S. Nameplate Company in response to the proposed denial of their delisting petition (51 FR 26428). Comments will be accepted until March 25, 1987. Notice of open meeting of the Advisory Committee negotiating the Hazardous Waste Injection Restrictions. The meeting is scheduled for March 9-10, 1987. Announcement of the availability of information generated from the investigation of uncontrolled hazardous or potentially hazardous waste sites. This information may include the identity, quantity, physical state, concentration, and containment of toxic substances at a site, and their potential effect on groundwater, surface water, drinking water, food chain, soils, and air in the vicinity of the site. -13- ------- -16- Frank Biros, WH-527 George Bonina, WH-563 Susan Bronm, WH-563 Karen 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-i32S 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 Carolyn Barley WH-563 Colleen Carruthers WH-548 Jim Jowett, WH-548B Thad Juszczak, WH-562A Robert Knox, WH-562 Jack Kooyoomjian, 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 Deborah Hartman (WH-527 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 Devorah Zeitlin WH-562) Bruce Weddle, WH-563 Steve Wilhelm, Region VII Marcia Williams, WH-562 Eric Males WH-565 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 ------- |