UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
530R87108
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
SUBJECT: Final Monthly Report - RCRA/Superf und Industry
Assistance Hotline Report for August 1987
FROM: Thea McManus
Office of Solid aste(WH-562)
Hubert Watters Office of Emergency
and Remedial Response (WH-548B)
TO: See list of addressees
This report is prepared and submitted for EPA contract
No. 68-01-7371.
I. SIGNIFICANT QUESTIONS AND RESOLVED ISSUES
A. RCRA Program
1. Changes at Interim Status Tank Facilities
According to 40 CFR 270.72, an owner/operator who
wishes to make changes in an interim status facility
must submit a revised Part A permit application and a
justification for the change to the Regional
Administrator (or State Director). The revised Part A
application is required for management of new hazardous
waste at the facility, increases in design capacity,
changes in the facility's process for treatment, storage
or disposal, and changes in ownership or operational
control at th« facility.
interim status tank storage facility plans to
its tanks to meet the new secondary containment
stani§4« of Section 265.193 (see 51 PR 25422). Does
a p g r ftif 1 a g a tank to meet secondary containment
requirements constitute a "change during interim status"
under Section 270.72?
RECEIVED
NDV121987
ENVIRONMENTAL PROTECTION AGENCY
LIBRARY, REGION V
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Yes. Upgrading a tank to meet the hazardous waste
tank secondary containment requirements does
constitute a change subject to Section 270.72.
According to Section 270.72(c), an owner/operator
who 'wishes to make a change at an interim status
facility must submit the revised Part A application
and the justification for the change prior to
making the change.
In general, Section 270.72(e) does not allow a
change under interim status where costs exceed
fifty percent (50%) of the capital cost of
construction of a comparable new facility.
Nevertheless, Section 270.72(e) contains an
exception to this prohibition for tanks that must
be retrofitted to comply with Section 265.193 (see
51 FR 25486). Therefore, the cost of retrofitting
a tank to comply with Section 265.193 would be
allowed to exceed fifty percent (50%) of the cost
of constructing a new tank facility. Retrofitting
to meet the secondary containment standards of Part
265 Subpart J is still considered to be a change
requiring submittal of a revised Part A application
and justification.
Source: Carrie Wehling (202) 382-7706
Research: Jennifer B. Planert
2. Tank Integrity Assessments
40 CFR 264.191 of the hazardous waste tank
regulations was promulgated in the July 14, 1986 Federal
Register. It requires owner/operators of existing tank
systems without secondary containment to conduct an
integrity assessment by January 12, 1988, to determine
that the tank system is not leaking or unfit for use.
Is an integrity assessment necessary for a hazardous
waste tank system where the tank has secondary
containment but the above-ground piping does not? Does
the interpretation change if the tank is above-ground,
in-gr«mnd or underground?
Vo. An integrity assessment is not required for
hazardous waste tanks that have secondary
containment even when the above-ground piping does
not. 40 CFR 264.191 states that existing tank
systems that do not have secondary containment and
meet 40 CFR 264.193 requirements must perform an
integrity assessment. A "tank system" includes
both the tank and its ancillary equipment (e.g.,
attached piping).
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Since the tank has secondary containment (provided
it is in compliance with Section 264.193) and 40
CFR 264.193(f) excludes above-ground piping
(exclusive of flanges, joints, valves and other
connections) that is visually inspected for leaks
on a daily basis from secondary containment
requirements, the "tank system" has secondary
containment meeting the requirements of Section
264.193. Therefore, it is not subject to the
initial integrity assessment requirement. The
above-ground, in-ground or underground
classification of the tank would not influence the
requirement.
Source: Chet Oszman (202) 382-4499
Research: Kate Anderson
3. 100-1000 kg/mo Generators
40 CFR Part 262 states that a 100-1000 kg/mo
generator has 180 days to store hazardous waste without
a permit or interim status. If the waste is shipped
more than 200 miles, the generator is allowed to store
waste on-site for up to 270 days. Is it permissible for
a 100-1000 kg/mo generator to ship waste to a TSD
facility more than 200 miles away, even though the
generator could send the shipment to a facility less
than 200 miles away?
40 CFR Part 262 contains no regulations addressing
when a generator is permitted to ship waste in
excess of 200 miles, and thus receive an extra 90
days storage time. 40 CFR 262.40 states that a
generator can store hazardous waste for 270 days,
"if he must transport his waste or offer his waste
for transportation over a distance of 200 miles or
more." The preamble notes that "the Agency has
decided not to establish specific criteria for
determining if a generator may accumulate waste on-
site for 180 or 270 days. EPA believes that such
criteria would not serve any useful purpose... ."
"In addition, the Agency was concerned that
establishing criteria for demonstrating that the
closest facility was greater than 200 miles from
the generation site would be unnecessarily
confusing and could have the perverse effect of
causing waste to go to less desirable management
practices (e.g., where a disposal facility is
located within 200 miles while a recycling facility
is located over 200 miles from the generator, the
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generator could be forced to utilize the less
desirable disposal facility)." Id. Therefore, it
would be permissible for a generator to send
hazardous waste to a facility greater than 200
miles, away even though there is a TSD facility
closer than 200 miles away.
Source: Mike Petruska (202) 382-7936
Research: Mark Janaskie
4. DOT Manifest Requirements
When filling out a hazardous waste manifest, must
the generator include the EPA hazardous waste
identification number and hazardous substance reportable
quantity under the Department of Transportation (DOT)
shipping description?
In the November 21, 1986 Federal Register (51 FR
42175), DOT's Research and Special Programs
Administration (RSPA) issued final hazardous
materials regulations which incorporated CERCLA
hazardous substances as DOT hazardous materials.
In a later Federal Register dated February 17, 1987
(52 FR 4824), the RSPA published corrections to the
November 21, 1986 regulations. Together, these
regulations amended 49 CFR Parts 171 and 172 by
placing additional information requirements on
shippers of hazardous waste (i.e., generators).
Section 172.02 of the new DOT regulations requires
the shipper (hazardous waste generator) to identify
EPA waste streams by the EPA identification number
and for wastes which exhibit an EPA characteristic
of ignitability, corrosivity, reactivity or EP
toxicity, by the letters "EPA" and the word
"ignitability" or "corrosivity" or "reactivity" or
"EP toxicity", as appropriate. Section 172.203 and
Section 172.324 of these regulations require the
notation "RQ" on the shipping papers in association
with the proper shipping description when a package
(i.e., container) contains a reportable quantity or
•ore of hazardous waste. However, the new DOT
regulations do not require the "numerical
reportable quantity" to be on the manifest (see
Ibrember 21, 1986 Federal Register (51 FR 42175)).
Source: Paul Muahovic (202) 475-7736
Research: Joe Nixon
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5. Exporting Hazardous Waste
Are -lead-acid batteries sent to Canada for
recycling subject to RCRA Section 3017 requirements?
No. Lead-acid batteries sent to Canada for
recycling are not subject to the export
requirements of 40 CFR 262.53, which codifies
Section 3017. The regulations parallel the
statute, which requires that any person exporting
hazardous waste shall: provide notification to the
Administrator; obtain consent from the receiving
country; attach a copy of that consent to the
manifest; and ensure that the shipment and terms of
the written consent are in agreement. The
Cooperative Agreement between the governments of
Canada and the United States parallels the same
points outlined above. As explained at 51 FJ?
28669, the definition of "exporter" excludes wastes
not subject to regulation through the manifest
system. Because 40 CFR 261.6(a)(2) and (3) exclude
lead-acid batteries that are being reclaimed or
regenerated from all substantive regulation until
the batteries are "cracked" or broken open, a
person exporting uncracked lead-acid batteries for
reclamation or regeneration is not an exporter
subject to Section 3017.
Source: Paul Mushovic (202) • 475-7736
Research: Laurie Huber
6. Corrective Action for Closed Underground Storage Tanks
While excavating and closing his gasoline
underground storage tank, an owner/operator discovers
that the tank has corroded and gasoline has leaked into
the surrounding soil. Will the owner/operator be
subject to corrective action for the release once the
proposed regulations for the underground storage tanks
(USTs) becoae effective? [Note: The tank will no
longer be In the ground on that date.]
The proposed regulations for underground storage
tanks (USTs), which appeared in the April 17, 1987
Federal Register (52 FR 12662), do not directly
address the applicability of the corrective action
regulations to tanks which are no longer
underground on the effective date of the
regulations. However, the issue will be clarified
in the final regulation. The proposed UST closure
regulations do require a retroactive site
assessment and notification of the implementing
agency for tanks that have been improperly closed
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prior to the effective date of the regulations
(proposed in Section 280.80(d)). Improper closure
may lead to corrective action per proposed Section
280."80(e) if a release is discovered. Currently, a
proper closure includes emptying the UST and either
removing it from the ground or filling it with an
inert solid material. If an UST has been properly
closed, however, the proposed closure regulations
do not require site assessment and corrective
action for that tank.
However, the release from the removed tank could
still be subject to corrective action under State
law. In addition, EPA could use authority granted
under RCRA Section 9003(h)(4) to require corrective
action at the site. Section 9003(h)(4) authorizes
the Administrator to require the owner/operator of
an underground storage tank to take corrective
action for a release of petroleum. Under Section
9003(h)(4), EPA and States with cooperative
agreements can issue clean-up orders to
owner/operators who will take corrective action
properly and promptly. If necessary to protect
human health and the environment, EPA or a State
may use LUST Trust Fund monies to take corrective
action at the site. Prior to the effective date of
the regulations under Section 9003(c), funding
priorities would fall to sites for which a solvent
owner/operator cannot be found to undertake
corrective action properly.
Source: Dick Valentinetti (202) 382-4758
Carrie Wehling (202) 382-7706
Research: Jennifer B. Planert
7. Manufacturing Process Units
A manufacturing process unit that holds methylene
chloride is located within a building that is slated for
demolition. If the owner/operator (o/o) of the unit
clos«f^the building and ceases to operate the unit, how
long i««s the o/o have before the methylene chloride
must b« shipped off-site?
First, the owner/opera tor of the unit should
determine if the methylene chloride would be
regulated as a hazardous waste. If the methylene
chloride is a spent material it would be regulated
as a solid waste if disposed of, used in a manner
constituting disposal, burned for energy recovery,
reclaimed, or accumulated speculatively (Section
261.2(c)(l), (2), (3), and (4)). If the spent
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methylene chloride solution contained, before use,
ten percent (10%) or more methylene chloride, it
would meet either the F001 or F002 listings in
Secti-on 261.31 and subsequently would also be
regulated as a hazardous waste, assuming the
methylene chloride regulated was utilized for its
solvent properties. If the methylene chloride is a
commercial chemical product and not a spent
material, it would be regulated as a solid waste if
used in a manner constituting disposal, disposed
of, or burned for energy recovery (Section
261.2(c)(l) and (2)). If the product is reclaimed
or accumulated specu1 atively it would not be
regulated as a solid waste (Section 261.2(c)(3) and
(4)). If the solvent is disposed of, used in a
manner constituting disposal, or burned for energy
recovery it is a solid waste and, due to the fact
that it would meet the U080 listing in Section
261.33(f) it would also be regulated as a hazardous
waste.
Assuming that the methylene chloride would be
regulated as a hazardous waste, 40 CFR Section
261.4(c) states that waste generated in a
manufacturing process unit is not subject to
regulation until the waste exits the unit or unless
the waste remains in the unit for more than 90 days
after the unit ceases to be operated. The October
30, 1980 Federal Register (46 FR 72024) explains
that this allowance only applies when the generator
is in compliance with Section 262.34. That is,
generators of more than 1000 kg of hazardous waste
per month have 90 days to store the waste without
having to obtain a permit or interim status. As
stated above, for manufacturing process units this
"90-day clock" begins when the waste exists the
unit or when the waste remains in the unit for more
than 90 days after the unit ceases operation.
However, the preamble in 45 FIR 72024 states that in
situations where the unit does cease to be operated
for Its primary purpose, the "clock" starts when
the operation stops. Thus, the preamble implies
th«t for the owner/operator of the above unit the
accumulation period begins the day that the
MBofacturing process unit is shut down.
It was not the Agency's intent to regulate wastes
in these units unless the waste exits the unit or
remains in the unit for more than 90 days after the
unit is no longer in operation. Therefore,
although there is preamble language to the
contrary, the accumulation period for the
owner/operator of the above unit would begin either
when the waste exits the unit, or if the waste
remains in the unit for more than 90 days, the
clock would then start on day 91.
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Furthermore the October 30, 1980 Federal Register
goes on to explain that if hazardous wastes do
remai-n in the- unit for more than 90 days after
cessation of operation, "...EPA believes that these
wastes should be fully regulated and that the units
should be regulated as storage facilities. Thus,
at that point, the owner/operator of the unit would
have to have interim status..." (45 FR 72024).
Source: Mike Petruska (202) 475-6676
Matt Straus (202) 475-8551
Research: Chris Bryant
8. Definition of Solid Waste and Reclamation
A distributor of a U-listed commercial chemical
product finds that the product is no longer saleable
(for example, it is past is shelf life). If the
distributor ships it back to the manufacturer for
reclamation, the material is not a solid waste under 40
CFR 261.2 because listed commercial chemical products
are not solid wastes when reclaimed. However, in many
cases the manufacturer will not know whether the
material can be reclaimed until a sample is analyzed.
Could the distributor ship the entire lot back to the
manufacturer, while not knowing whether the material was
a solid waste?
Yes. The distributor can ship the entire lot back
to the manufacturer, while not knowing whether the
material was a solid waste. There are no
provisions in the RCRA regulations restricting
shipments of commercial chemical products.
Technically, it remains a commercial chemical
product until such time as they are discarded or
intended to be discarded (Section 261.2 and Section
261.33). This decision is made by the
manufacturer. The U-listed commercial chemical
product would still be shipped pursuant to
applicable DOT and U.S. Postal Service regulations.
It would not need to be manifested as a hazardous
waate.
Source: Paul Mushovic (202) 475-7736
Research: Becky Cuthbertson
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I. SIGNIFICANT QUESTIONS AND UNRESOLVED ISSUES
B. CEPP
9. Landfills' and Title III
Are landfills covered under Title III of SARA since
they are covered by RCRA?
Yes, landfills are subject to certain Title III
requirements. Subtitle A of Title III is intended
to identify facilities which present a potential
hazard for a chemical emergency and to provide a
process for local emergency planning committees to
engage with such facilities in determining the
significance of the release hazard and developing
response plans to facilitate timely and appropriate
response in the event of a chemical spill. Because
landfills meet the definition of "facility" and may
in some instances present such a hazard, EPA
interprets them to be subject to reporting and
notification requirements under Section 302 in
Subtitle A.
While EPA agrees that conditions at some facilities
(including landfills) may not pose significant
chemical hazards even though extremely hazardous
substances are present in excess of the threshold
planning quantity, in other such facilities
conditions will exist which do present a
significant hazard. Such assessment must be made
on a site-specific basis. EPA believes that
leaving such decisions to the local planning
committees is consistent with the purpose of
Subtitle A. Communities must know which facilities
may present potential for chemical emergencies so
they can determine the nature of the risk to the
public and to emergency responders.
It is recognized that Resource Conservation and
Recovery Act (RCRA) regulations already address
• •ay of the goals of Subtitle A of Title III.
•ovever, it is important that the facility
Contingency plan and local coordination required
by RCRA be coordinated with any new State and local
planning structure or community planning process
established under Title III. Full compliance with
the RCRA requirements should minimize additional
planning activities with local communities under
Title III. Therefore, these requirements are not
duplicative. It should be noted that landfills may
not be exempt under certain sections of Title III.
Placement of a container holding an extremely
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hazardous substance into a landfill which has a
federal permit for this chemical is exempt from the
Section 304 emergency release notification. Also,
under Subtitle B, Sections 311/312, landfills fall
under the exemption for any hazardous waste defined
as such by the Solid Waste Disposal Act. In
addition, landfills do not fall into the SIC codes
covered by the Section 313 Toxic Chemical Release
reporting requirements.
Source: David Speights (202) 382-4492
Research: Brian Littleton
10. Calculation of Extremely Hazardous Substances in
Landfills
How are the quantities of the extremely hazardous
substances (e.h.s.) to be calculated in determining if
landfills are subject to the Section 302 requirements?
EPA realizes the practical problems presented for
landfills in complying with the Title III
requirements. Owners of these facilities must
determine, based on reasonably available
information whether any e.h.s.'s are in excess of
the threshold planning quantities (tpq). However,
in making such a determination, owners and
operators of landfills should apply the one percent
(1%) exclusion (see 40 CFR 355.30(a) and (e)(l)).
EPA believes that the one percent (1%) exclusion is
applicable to the contents of the entire landfill
based on the assumption that such containers will
degrade in the landfill environment. Therefore, if
the total weight of an extremely hazardous
substance is greater than one percent (1%) of the
total weight of the landfill waste and equals or
exceeds the threshold planning quantity for that
substance, the landfill is subject to Section 302
notification requirements. If no extremely
k|tc ardoas substance exceeds this level, the
liadfill is not subject to emergency planning
requirements under Title III unless designated by
the Governor or State Emergency Response Commission
under Section 302(b)(2). Following any resulting
notification to the State Commission and
designation of a facility emergency coordinator
(Section 303(d)(l)) the local committee may.
depending on their site specific assessment of the
hazards posed by the particular facility, request
participation of the facility in the Title III
planning process. Even though many landfills may
not be required to provide planning notification
based on the one percent (1%) exclusion cited
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above, the landfill owner/operator and the local
emergency planning committee should work
cooperatively to ensure that potential chemical
emergencies are addressed.
Source: " David Speights (202) 382-4492
Research: Brian Littleton
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II. ACTIVITIES
A. The Hotline responded to 13,110 questions and requests for
documents in August.
B. On August" 4, Kim Jennings of the CEPP Hotline attended the
Title III Workgroup meeting on the status of the Title III
activities.
C. On August 4, 11, 18, and 25, CEPP Hotline staff attended the
weekly Preparedness Staff meetings.
D. On August 12, Dave Topping (OSW) briefed the RCRA/Superfund
Hotline on the F006 and F019 hazardous waste listings.
E. On August 13, John Goodrich-Mahoney briefed the
RCRA/Superfund Hotline on the status of the Toxicity
Characteristic Leaching Procedure (TCLP).
F. On August 18, Matthew Glaudemans of the CEPP Hotline
attended the Title III Workgroup meeting on the status of
Title III activities.
G. On August 19, Denise Wright of the RCRA/Superfund Hotline
briefed DOT representatives on hazardous substances
reportable quantity regulations.
H. On August 20-21, Robert Costa of the CEPP Hotline attended
the Title III Workshop held in Chicago. The Workshop
presented views of state and local officials and the
regulated community on the methods to deal with Title III
implementation.
I. On August 26, Dave Phillips and Doug Bice briefed the
RCRA/Superfund Hotline on EPA's Title III program.
J. On August 27, Matthew Glaudemans of the CEPP Hotline
attended the National Response Team monthly meeting. An
army chemical emergency exercise, the NCP, and the sudden
widespread death of dolphins were discussed.
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III. ANALYSES OF QUESTIONS (August 1987)
SUMMARY OF CALLS BY GEOGRAPHIC DISTRIBUTION (EPA Regions):
1 5.0% 3 24.0% 5 18.4% 7 0.7%
2 11. OZ 4
12.2%
9.3%
8
4.4%
10
INTERNATIONAL CALLS
0.3%
Manufacturers
Generators
Transporters
TSDF's
EPA HQ
EPA Regions
Federal Agencies
5.2%
17.0%
2.0%
7.4%
1.5%
3.0%
2.9%
State Agencies
Local Agencies
Used Oil Handlers
UST 0/0
Consultants
Attorneys
Laboratories
4.6%
1.7%
1.1%
2.4%
31.4%
7.6%
1.8%
11.6%
3.1%
RCRA
Univ. /Researchers
Trade Associations
Insurance Co
Environmental Groups
Press
Citizens
Other
1.73
0.92
0.42
0.5%
0.6%
4.6%
1.6%
General Information 462
3010 Notification 109
260.10 Definitions
260.22 Petitions/Delisting
261.2 Solid Waste Definition 169
83
92
261
261
261
261,
261,
261,
261,
262
3
C
D
4
5
6
7
Hazardous Waste Definition 295
Characteristic HW 453
Listed HW 356
Exclusions 139
Small Quantity Generators 125
Recycling Standards 186
Container Residues 34
Generator - General 143
100-1000 kg/mo 74_
Manifest Info 112
Accumulation 43
263
266 C
266 D
266 E
Recordkeeping & Reporting 43
International Shipments 28
Transporters 66
266
266
F
G
Use Constituting Disposal 9
HW Burned for Energy Recovery 59
Used Oil Burned for
Energy Recovery_ 74
Precious Metal Reclamation 23
Spent Lead-Acid Battery
Reclamation 24
Subtitle D fr.
Used Oil - General
Household Hazardous Waste_
Dioxins
Mixed Radioactive Waste
Asbestos/PCBs/Radon
Infectious Waste
114
82
28
24
18
32
37
Liability/Enforcement_
Corrective Action
Waste Minimization
Minimum Technology
95
55
86
35
1
264/265 TSDF
A - Scope/Applicability
B - General Facility Standards
C - Preparedness/Prevention :
D - Contingency Plans '_
E - Manifest/Recordkeeping/Reporting^
F - Ground Water Monitoring_
- Closure/Post Closure
Financial Requirements_
Containers
Tanks
G
H
I
J
K
L
M
N
0
P
Q - Chem, Phys, Biol Treatment,
R - Underground Injection
X - Miscellaneous
268 - General
Surface Impoundments,
Waste Piles "
Land Treatment
Landfills
Liquids in Landfills,
Incinerators
- Thermal Treatment
Solvent & Dioxins
California List Wastes,
Scheduled Thirds
269
270
- Air Emission Standards
-A - General
B
D
F
G - Interim Status/LOIS
State Programs
Permit Application,
Changes to Permits,
Special Permits
Administrative Procedures,
Requirements
271
124
DOT
OSHA Requirements/HW Training,
Test Methods/HW Technologies,"
RCRA Document Requests
SUBTOTAL
1<
20
23
1
41
1<
IK
595
893
7093
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III. ANALYSES OF QUESTIONS (August 1987)
UNDERGROUND STORAGE TANKS
General
280.10 Applicability
280.11 Interim Prohibition
280.12 Definitions - General
UST
Regulated Substance
280 B New UST Systems - General
280.20 Performance Standards
280.21 Upgrading
280.22 Notification
280 C General Operating
Requirements
280 D Release Detection
280 E Release Reporting and
Investigation
280 F Corrective Action -
Petroleum
280 G Corrective Action -
Hazardous Substances
280 H Out-of-Service/Closure
280 I Financial Responsibility
281 State UST Programs
Liability
Enforcement
LUST Trust Fund
Other Provision
UST Document Requests
UST SUBTOTAL 1
159
55
37
24
33
31
5
26
5
30
22
43
15
22
8
48
23
20
12
2
11
6
553
190
Referrals - EPA - HQ
289
- Other Hotlines_
- Regions
State
135
GPO/NTIS/PIC
ORD/Dockets,
Other "
426
345
SUBTOTAL
1195
Written Request Responses:
CERCLA
General 19
SARA General 3
Access & Information Gathering
Allocations from Fund/
Fund Balancing/Grants 1'
CERCLIS/103 Notification
Citizen Suits
8
Clean-Up Standards/ARARsA
How Clean Is Clean
Contractor Indemnification
Contracts/Contract Lab Program_
Exposure Assessment/
Public Health Evaluation
Definitions
Enforcement
Federal Facilities
Hazardous Substances/RQs
HRS
Llability/PRPs
Mandatory Schedules
Natural Resource Damages
NBARs "
NCP
NPL
Off-Site Policy
On-Site Policy
PA/SI
Public Participation
Radon
RD/RA
RODs/Clean-Up Costs_
Settlements
SITE Program
State Participation
Taxes
Title III/Right-To-Know_
Other Provisions
CERCLA Document Requests
CERCLA SUBTOTAL
(starting 9/1/87)
Hotline Responses
Referred to EPA Program Offices
Referred to other Federal Agencies
Referred externally (states, organization, etc)_
Response Form Sent_
21
42
18
207
Response Form Sent/FOIA
Form Letter Sent/Need
Requests filled - RCRA
- UST
SUBTOTAL
more info
A
CLA
starting 9/1/87)
startina 9/1/87)
startina 9/1/87)
startina 9/1/87)
291
TOTAL CALLS, DOCUMENT REQUESTS AND REFERRALS (starting 9/1/87)
-14-
31
13
Remedial
Removal
RI/FS
33
13
38
30
31
19
15
88
19
149
1562
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CEPP Hotline
Daily/Monthly Summary Report
For August 1987
Total Calls
1779
Distribution
1
2
3
6.4%
12.4%
20.1%
of Calls by EPA Regions:
4
5
6
12.2%
23.0%
8.2%
7
8
9
2.9%
2.1%
7.8%
Written Responses
Callers;
Manufacturers
Distributors
Handlers
Attorneys
Consultants/Engineers
Laboratories
Trade Associations
Public Interest Groups
Universities/Academia
Insurance Companies
Hospitals
Title III: General
37.9%
2.1%
8.2%
4.5%
8.6%
1.9%
2.6%
2.3%
1.9%
0.2%
0.9%
Section 301-3 Emergency Planning;
SERC's
Notification Requirements
TPQ's
Sec. 305 Training Grants
Sec. 305 Emergency Review
Mixtures
Extremely Hazardous Substances
Release Notification: General
Notification Requirements
Reportable Quantities
RQ's vs. TPQ's
36
18
285
190
101
113
63
17
31
156
67
10
1.6%
State Agencies
Fire Depts.
EPA
Local Officials
Farmers
CERCLA vs. Sec. 304
Transportation
Exemptions
740
International: 0.1%
Unknown: 2.5%
3.8%
2.5%
4.3%
6.2%
3.0%
Federal Agencies 2.OX
Media/Press 0.8%
Union/Labor 0.1%
Citizens 2.3%
Other 2.8%
20
10
17
-15-
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CEPP Hotline Daily/Monthly Summary Report (Continued)
SEc. 311/312; General 305
MSDS Reporting Regulations 186 Haz. Categories 76_
Tier I/II Regulations 78 Mixtures 34_
Thresholds 203 Exemptions 44
Sec. 313; General
Thresholds
Public Meetings
Mass Balance Study
Trade Secrets
Enforcement
CEPP: Interim Guidance
Tech. Guidance
Chemical Profiles
NRT - 1
Teleconference
Title III Workshops
Other
Document Requests
# of Documents Requested
Referrals:
OTS (Section 313).
OSHA
25
21
Preparedness Staff
107
12
19
13
125
29
74
26
454
898
RCRA/Superfund Hotline.
Regional EPA
Other
31
28
-16-
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RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000
IV. PUBLICATIONS
RCRA
"Risk Assessment, Management, Communication: A Guide to Selected
Sources" is available from U.S. EPA's Public Information Center (PIC).
The EPA Information Systems Inventory (ISI) is available from NTIS
on disc (PB87-131-017) and paper copy (PB87-131-009).
"Guidance for Coordinating ATSDR Health Assessment Activities"
(OSWER Directive #9285.4-02) dated March 11, 1987 is available by
writing: U.S. EPA, OERR-OPM (WH-548D), 401 M Street, S.W.,
Washington, D.C. 20460.
"Regulatory Status of Facilities Previously Granted Temporary
Exclusions," July 31, 1987, a memorandum from Marcia Williams,
Director, Office of Solid Waste to Regional Division Directors,
is available by calling the Hotline.
"Scope of the CERCLA Petroleum Exclusion Under Section 101(14)
and 104(a)(2)," July 31, 1987, a memorandum from Francis S. Blake,
General Counsel, U.S. EPA to J. Winston Porter, Assistant
Administrator for Solid Waste and Emergency Response, U.S. EPA,
is available by calling the Hotline.
"Permit Guidance Manual on Unsaturated Zone Monitoring for Hazardous
Waste Land Treatment Units" (EPA/530-SW-86-040), October 1986, is
available from NTIS (accession number PB87-215-463). The document
costs $18.95 for hard copy and $6.50 for microfiche.
The following documents are available from the Office of Ground-Water
Protection (WH-550G) by calling 382-7077:
1. "EPA Activities Related to Sources of Ground-Water Protection,"
and
2. "Survey of State Ground-Water Quality Protection Legislation,"
1985.
CERCLA
FY 1987 RO^Anaaal Report (PB87-199-550) is available from NTIS.
FY 87 Sup«jrttt»< Comprehensive Accomplishments Plan (SCAP) is
available fro« Terry Ouverson at (202) 475-9367.
"RI/FS Improvements," July 23, 1987, a memorandum from
Henry Longest, Director, Office of Emergency and Remedial Response
to U.S. EPA Regional Division Directors, is available by
contacting Lisa Feldt.
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RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000
V. FEDERAL REGISTER NOTICES FOR AUGUST 1987
Former Notices with' Open Comment Period
June 3, 1987; 52 FR 20914
(proposed rule on permitting
mobile hazardous waste treat-
ment units and delisting
hazardous waste)
June 4, 1987; 52 FR 21152
(proposed rule on toxic
chemical release reporting;
community right-to-know)
June 11, 1987; 52 FR 22380
(technical resource documents
on construction quality
assurance and absorption
procedures)
June 29, 1987; 52 FJR 24181
(comment period extension on
TCLP applicability)
June 30, 1987; 52 PR 24333
("Interim Guidance on
Settlements with PgMinimua
Waste Contributors11!
Proposed rule on permitting procedures
and other regulations to facilitate
the use of mobile treatment units in
the treatment of hazardous waste. Also
proposed are alternative delisting
procedures under which delisting can
occur as part of the permitting process.
Comments will be accepted until August
3, 1987.
Proposed rule which publishes the
uniform toxic chemical release
reporting form as required by Section
313 of Title III of SARA. Comments
will be accepted until August 3, 1987.
Notice of availability of Construction
Quality Assurance for Hazardous Waate
Land Disposal Facilities and a draft
technical resource document on Batch-
type Absorption Procedures for Esti-
mating Soil Attenuation of Chemicals.
Comments will be accepted on the draft
technical resource document until
August 15, 1987.
Notice extending the comment period for
the May 18, 1987 supplemental notice
to the proposed Toxicity Characteristic
Leaching Procedure (52 F_R 18583). The
supplemental notice requested comments
on the applicability of the TCLP to
wastes likely to be managed in surface
impoundments. Comments will be accepted
until August 16, 1987.
Notice and request for comments
regarding EPA's "Interim Guidance on
Settlements with DeMinimus Waste
Contributors" under Section 122(g) of
SARA. Comments will be accepted
until August 31, 1987.
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RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000
July 6, 1987; 52 FR 25255
(proposed rule-administrative
enforcement actions in the UST
program)
July 20, 1987; 52 FR 27199
(state program revisions)
July 20, 1987; 52 FR 27226
(proposed deletion of substance
from Title III Section 313 List
of Toxic Substances)
July 20, 1987; 52 FR 27257
(notice of draft updated
assessments for trichloro-
ethylene and dichloromethane)
July 22, 1987; 52 FR 27579
(notice of availability
of guidance manual)
July 28, 1987; 52 FR 28167
(extension of comment period)
August Federal i««iater Notices
August 3, 1987; 52 PX 28696
(final rule denying petitions)
Proposed rule to extend the applicability
of the consolidated rules of practice
(40 CFR 22) which govern administrative
enforcement actions taken pursuant to
Section 9006, SDWA, as amended. Comments
will be accepted until September 4, 1987.
Final rule revising the final
authorization of Minnesota's
hazardous waste management program.
Comments will be accepted until
August 19, 1987.
Proposed rule deleting butyl benzyl
phthalate from the list of toxic
chemicals under Section 313 of Title
III of SARA. Comments will be accepted
until October 19, 1987.
Notice of availability of three
documents for external review. TB«
documents address addenda to the health
assessments for trichloroethylene and
dicloromethane and new methods regarding
dichloromethane. Comments will be
accepted until September 9, 1987.
Notice of availability of Alternate
Concentration Limit Guidance; Policy
and Information Requirements. Comments
will be accepted until September 21,
1987.
Extension of public comment period on
the May 29, 1987 proposed rule
addressing liners and leak detection
at land disposal units until August 27,
1987.
Final rule denying petitions submitted
by Arvin Automotive, Bayliner Marine
Corporation and Digital Equipment
Corporation to exclude their wastes
from the hazardous waste lists.
-19-
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RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000
August 3, 1987; 52 FR_ 28697
(final rule listing- K062)
August 4, 1987; 52 FR. 28866
(extension of NBARS comment
period)
August 5, 1987; 52 FR 29060
(notice of Science Advisory
Board meeting on HRS)
August 6, 1987; 52 FR 29222
(proposed rule on conduct
of administrative hearings)
August 7, 1987 52 FR 29395
(extension of comment period)
August 10, 1987; 52 FR 29522
(state schedule of compliance)
August 10, 1987* 52 FR 29565
(transfer of d«t* to EPA
contractor) "
August 10, 1987; 52 FIR 29566
(indoor air quality Report
to Congress)
Final rule promulgating the listing of
Hazardous Waste K062. The scope of the
listing applies to pickle liquor from
steel finishing operations at facilities
within the iron and steel industry
(SIC Codes 331 and 332).
Notice of extended public comment period
concerning the Interim Guidelines on
Non-binding Preliminary Allocations of
Responsibility (NBAR) to September 3,
1987.
Notice of Science Advisory Board meeting
concerning revisions of the Hazard Rankinj
System (HRS). The meeting will be held
September 14 and 15, 1987 in Washington,
D.C.
Proposed rule establishing procedures
governing the conduct of administrative
hearings requested pursuant to.Section
3008(b) of RCRA by recipients of
corrective action orders under
Section 3008(h). Comments will be
accepted through September 8, 1987.
Notice extending the comment period of
the May 29, 1987 proposed rule requiring
manufacturers and processors of 73
chemicals to perform testing in support
of the RCRA program. Comments will be
accepted if submitted on or before
August 27, 1987.
Colorado's schedule of compliance
for modification of its hazardous
waste management program.
Notice of transfer of data to
contractors for the development of
RCRA hazardous waste management
regulations.
Notice of Report to Congress on Indoor
Air Quality Implementation Plan as
required by SARA Section 403(d).
-20-
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RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000
August 10, 1987; 52 FR 29571
(DOJ consent decree)"
August 10, 1987; 52 FR 29620
(OSHA hazardous waste
operations and emergency
response)
August 11, 1987; 52 F_R 29708
(extension of comment period)
August 12, 1987; 52 FR 29992
(notice of data, request
for comment)
August 12, 1987; 52 FR 29990
(technical correctionT
August 12, 1987; 52 FR 29846
(final exclusion rulej
August 12, 1987; 52 FR 29849
(final exclusion rulej
August 13, 1987; 52 FR 30192
(notice of tentative
determination)
August 14, 1987; 52 FR 30570
(proposed rule changes to
interim status and permitted
facilities and post-closure
permits)
Loading notice of consent decree
pursuant to RCRA; Water Research Inc.,
a fuel blending facility.
Notice of proposed rulemaking by OSHA
on hazardous waste operations and
emergency response. Comments must be
received on or before October 5, 1987.
Response to petition on mobile
treatment units. Comment period on
regulatory exclusion portion of the
rule extended to September 3, 1987.
Notice of data availability and request
for comments, Land Disposal Restrictions
on waste containing prohibition levels
of California List metals and cyanide.
Comments will be accepted on or before
October 13, 1987.
Technical corrections to proposed rule
requiring testing of materials under
TSCA in support of RCRA rulemaking.
Final exclusion from hazardous waste
listing for wastes generated by
General Electric (Shreveport, Louisiana)
and the Keymark Corporation (Fonda, New
York).
Final exclusion from hazardous waste
listing for wastes generated by Boomer
Industries Incorporated (Landrum,
South Carolina).
Notice of tentative determination on
application regarding final authoriza-
tion of Maine's hazardous waste
management program. Written comments
will be accepted, and, if requested,
a public hearing will be held.
Proposed rule regarding changes to
interim status and permitted facilities,
and procedures for post-closure
permitting. Comments will be accepted
on or before October 13, 1987.
-21-
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RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000
August 17, 1987; 52 JFJZ 30681
(notice of state program
modifications)
August 17, 1987; 52 FR 30682
(notice of state program
modifications)
August 18, 1987; 52 FR 30964
(notice of proposed consent
decree)
August 24, 1987; 52 FR 31948
(proposed rule regarding
statistical methods for
ground-water data analysis)
August 25, 1987; 52 FR 32058
(notice of availability of
funds from ATSDR)
August 27, 1987; 52 FR 32446
(land disposal restrictions
for underground injection
wells)
August 27, 1987; 52 FR 32496
(notice of ARAR guidance)
Notice of South Carolina's compliance
schedule to adopt program modifications.
Notice of Tennessee's compliance
schedule to apply for program
modifications.
Notice of proposed consent decree
lodged in U.S. District Court for
the District of New Hampshire on
August 10, 1987 under CERCLA Sections
106 and 107 and RCRA Section 7003;
"U.S. et. al. vs. Ottati and Goss.
et. al."Comments will be received
30 days from August 18, 1987.
Proposed rule for changing the
statistical analysis method used
in determining statistically
significant changes in levels of
hazardous constituents measured
in ground-water samples. Comments
will be accepted on or before
October 23, 1987.
ATSDR availability of funds for 1987
to continue project with State of
Missouri, Department of Health.
Assistance will be maintaining central
listing of persons exposed to TCDD
(dioxin).
Proposed rule implementing underground
injection restrictions of certain
hazardous waste, and land disposal
restrictions technical requirement for
Class I hazardous waste injection wells,
Comments will be accepted on or before
October 26, 198.7, and a public
hearing will be held September 21, 1987
in Washington, D.C.
Notice of interim guidance on
compliance with applicable
or relevant and appropriate
requirements. Comments will be
accepted until October 13, 1987.
-22-
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RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000
August 31, 1987; 52- PR 32850
(notice of proposed consent
decree)
August 31, 1987; 52 FR. 32851
(notice of proposed consent
decree)
Notice of a proposed consent decree
lodged in the Northern District of
New York for recovery of costs
expended to clean up Pollution
Abatement Services (Oswego, New York)
under CERCLA. Comments will be
accepted for 30 days from August
31, 1987.
Notice of proposed consent decree
lodged in the District of New
Hampshire under CERCLA and RCRA,
resolving the liability of General
Electric, Solvents Recovery Service
of New England, Lilly Industrial
Coatings and the State of New
Hampshire in the matter of U.S.
et. al. vs. Ottati and Goss, et. al.
Comments will be accepted for 30 days
from August 31, 1987.
-23-
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Martha Anderson, DORM
Frank Biros, WH-527
George Bonina, WH-563
Susan Bromm, WH-563
Karen Brown, PM-220
John Bosky, EPA-Kansas City, KS
Diane Buxbaum, Region 2
Richard Clarizio, Region 5
Sylvia Lowrence, WH-562
Kathy Collier, RTF, NC
Peter Cook, WH-527
Alan Corson, WH-565
Elizabeth Cotsworth, WH-563
Wayne Crane, PM-273F
Hans Crump, WH-548B
Elaine Davies, WH-562
Truett DeGeare, WH-563
Melinda Downing, DOE
Tim Fields, WH-548B
Lisa Friedman, LE-132S
Goerge Garland, WH-563
John Gilbert, EPA-Cin. OH
Peter Guerrero, WH-563
Penny Hansen, WH-562
Bill Hanson, WH-548E
Betti Harris, EPA, Region 7
Lee Herwig, A-104
Irene Homer, WH-595
Hotline Staff
Warren Hull, A-104
Phil Jalbert, WH-548D
Alvin K. Joe, Jr., Geo/Resource
Gary Jonesi, WH-562B
Jim Jowett, WH-548B
Thad Juszczak, WH-562A
Robert Knox, WH-562
Jack Kooyomjian, WH-548B
Mike Kosakowski, WH-527
Jerry Kotas, WH-527
Walter Kovalick, WH-548
Tapio Kuusinen, PM-223
Steve Leifer, LE-134S
Steve Levy, WH-565
Henry Longest, WH-548
Gene Lucero, WH-527
James Makris, WH-562A
Jack McGraw, WH-562A
Scott McPhilamy, Region 3
Toni Kennedy, (ASTSWMO)
Royal Nadeau, Region 2
Sam Mapolitano, PM-220
Christina Parker, WH-562
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, A-101
Bruce Weddle, WH-563
Steve Wilhelm, Region 7
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
-24-
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Peciior.al Counsels
Patrick A. Parenteau
Regional counsel
Region I, US EPA 12203
John F. Kennedy Federal Bldg.
Boston, MA 02203
James H. Sargent
Regional Counsel
Region IV, US EPA
345 Courtland St. NE
Atlanta, GA 30365
David R. Tripp
Regional Counsel
Region VII, US EPA
1200 6th Avenue
Seattle, WA 98101
Douglas R. Blazey
Regional Counsel
Region II, US EPA
26 Federal Plaza, Rm. 1009
New York, NY 10278
Robert B. Schaefer
Regional Counsel
Region V, US EPA
230 South Dearborn St.
Chicago/ IL 60604
Tom Speicher
Regional Counsel
Region VII, EPA
999 18th St., One Denver PI.
Denver, CO 80202
Bruce M. Diamond
Regional Counsel
Region III, US EPA
841 Chestnut St.
Philadelphia, PA 19107
James Neet
Regional Counsel (6C)
Region VI, US EPA
1201 Elm St., Inter. First
Dallas, ix 75270
Karl R. Morthole
Regional Counsel
Region ix, us EPA
215 Fremont St.
San Francisco, CA 94105
Regional Libraries
Ms. peg Nelson
U.S. EPA, Region I Library
Room 2100-B, JFK Federal Bldg.
Boston, MA 02203
(617) 565-3300
Ms. Gayle Alston
U.S. EPA, Region IV Library
345 Courtland St., N.E.
Atlanta, GA 30308
(404) 347-4216
Ms. Connie McKenzie
U.S. EPA, Region VII Library
324 East llth Street
Kansas City, MO 64106
(913) 236-2828
Ms. Julienne Sears
U.S. EPA, Region x Library
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-1289
Mr. Dennis P. Carey
U.S. EPA, Reg. II Library
26 Federal Plaza
New York, NY 10278
(212) 264-2881
Ms. Lou Tilley
U.S. EPA, Region v Library
230 S. Dearborn St., * 1417
Chicago, IL 60604
(312) 353-2022
Ms. Dolores Eddy
U.S. EPA, Reg. VIII Library
999 18th St. 1500
Denver, CO 80202-2405
(303) 293-1444
Ms. Diana McCreary
U.S. EPA, Reg. Ill Library 3M
Curtis Bldg., 6th & Walnut st
Philadelphia, PA 19106
(215) 597-0580
Ms. Leticia Lane
U.S. EPA, Region VI Library
1201 Elm Street
First Internat'l Bldg.
Dallas, TX 75270
Ms. Marsha saylor
U.S. EPA, Region IX Library
215 Fremont Street
San Francisco, CA 94105
(415) 974-8076
Ms. Dottie Biggs
U.S. NEIC Library - Bldg.
Box 25227
Denver Federal Ctr.
Denver, CO 80225
(303) 236-3219
53
-25-
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Merrill S. Hbhman, Director
Waste Management Division
U.S. EPA, Region I
John F. Kennedy Bldg.
Boston, MA 02203
Patrick Tobin, Director-
Waste Management Division
U.S. EPA, Region IV
345 Courtland St., N.E.
Atlanta, GA 30365
David A. Wagoner, Director
Waste Management Division
U.S. EPA, Region VII
324 E. llth Street
Kansas City, MO 64106
Charles Findlay
Hazardous Waste Division
U.S. EPA, Region X
1200 6th Ave.
Seattle, WA 98101
Conrad Simon, Director
Air & Waste Mgmt. Divison
U.S. EPA, Region II
26 Federal plaza
New York, NY 10278
Bill Constantellos, Dir.
Waste Management Div.
U.S. EPA, Region V
111 W. Jackson St., 16th Fl,
Chicago, IL 60604
Robert L. Duprey, Dir.
Waste Mgmt. Division
EPA, Region VIII
1860 Lincoln St.
Denver, CO 80295
Stephen Wassersug, Director
Hazardous Waste Mgmt. Div.
EPA, Region III
6th and walnut streets
Philadelphia, PA 19106
Allyn M. Davis, Director
Hazardous Waste Mgmt. Div.
1201 Elm Street, EPA, Region
First International Bldg.
Dallas, TX 75270
Jeffrey Zelikson, Director
Toxics & Wastes Mgmt. Div.
EPA, Region IX
215 Fremont Street
San Francisco, CA 94105
Branch Chiefs
Linda Murphy, Chief
EPA, Region 1
State Waste Program Br.
John F. Kennedy Bldg.
Boston, MA 02203
James Scarborough, Chief
Residuals Mgmt. Branch
EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30308
Mike Sanderson, Chief
RCRA Branch
EPA, Region VII
726 Minnesota Ave.
Kansas City, MO 64106
Kenneth D. Feigner, Chief
Waste Mgmt. Branch
EPA, Region X
1200 6th Avenue
Seattle, WA 98101
Richard Salkie (2AWM-SW-Rm. 905)
EPA, Region II
Hazardous Waste Programs Branch
26 Federal Plaza
New York, NY 10278
David Stringham, Chief
Solid Waste Branch (5HS13)
EPA, Region V
230 S. Dearborn St., 13th Fl.
Chicago, IL 60604
Lou Johnson, Chief
Hazardous Waste Branch
EPA, Region VIII
1860 Lincoln St.
Denver, CO 80203
Bruce smith
Chief, Haz. Haste Enforcement Br.
U.S. EPA, Region III
841 Chestnut Street
Philadelphia, PA' 19107
Robert Allen, Chief
EPA, Region III
Waste Mgmt. Branch (3WH30,
841 Chestnut St.
Philadelphia, PA 19107
Randy Brown, Chief
EPA, Region VI
Hazardous Waste program Br
First International Bldg.
1201 Elm St.
Dallas, TX 75720
Philip Bobel, Chief
RCRA Programs Branch (T-2)
EPA, Region IX
215 Fremont St.
San Francisco, CA 94105
David Doyle
Chief, Records Compliance
U.S. EPA, Region VII
324 East llth St.
Kansas City, MO 64106
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Janice Hicks (T-l-3)
Office of Community Relations
215 Fremont street
San Francisco, CA 94105
Alvin Joe
Geo/Resource Consultants, Inc.
851 Harrison Street
San Francisco, CA 94107
Carl Eklund
Division of Solid & Haz. Waste
DEQE
Winter Street
Boston, MA 02108
Bruce Smith (3HW10)
Chief, Haz. Waste Enforcement Br,
U.S. EPA, Region III
841 Chestnut Street
Philadelphia, PA 19107
Richard Clarizio
U.S. EPA, Region V
230 South Dearborn St.
(5HS-13JCK)
Chicago, IL 60604
Myra Perez
U.S. EPA, Region VI
6608 Mornwood Drive
Houston, TX 77074
John Gilbert
U.S. EPA
Envir. Response Branch
26 West St. Clair St.
Cincinnati, OH 45268
John Bosky
U.S. EPA, Region vil
25 Funston Rd.
Kansas City, KS 66115
Lucy Mlenar
U.S. EPA, Region ix
215 Fremont Street
San Francisco, CA 94105
Melinda Downing
Dept. of Energy
1000 Independence Ave., SW
3 G092
Washington, D.C. 20585
John Creech
Air Informaton ctr.
U.S. EPA, Mail Drop 35
Research Triangle Park, NC
27711
Chet Mclaughlin
State Programs Branch
U.S.EPA, Region VII
324 East llth St.
Kansas City, MO 64106
David Doyle
Chief, Records Ccmpliar
U.S. EPA, Region VII
324 East llth St.
Kansas City, MO 64106
Diane Buxbaum
U.S. EPA, Region II
Woodbridge Ave.
Edison, NJ 08837
Stephen Wilson
HQ APLC/DEVQ
WPAFB, Ohio 45433
Headquarters SAC/BEP
Offutt AFB
Nebraska, 68113-
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