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

                          -5-

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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
                                   -13-

-------
 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

-------
                                   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-

-------
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-

-------
                        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.
                                  -17-

-------
                            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.
                                -18-

-------
                         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-

-------
                         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-

-------
                        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-

-------
                         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-

-------
                         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-

-------
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-

-------
 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
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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
                                             -26-

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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-
                                             -27-

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