•* r. UN|TED STATES ENVIRONMENTAL PROTECTION AGE V*"1^^ WASHINGTON, D.C. 20460 *«,, DEC 8,987 530R87109 "JFFiCf. Or- SOLI'O WASTE a.NO EME,MGl_."i_-Y RESPONSE SUBJECT: Final Monthly Report - RCRA/Superfund Industry Assistance Hotline Report for September 1987 /w^- FROM: Thea McManus Office of Solid Waste (WH-562) Hubert Matters, 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 - September 1987 A. RCRA PROGRAM 1. Subtitle D Programs on Indian Lands Under Subtitle D of the Resource Conservation and Recovery Act, States developed programs according to Federal guidelines for regulation of non-hazardous solid waste. In 40 CFR Parts 240 to 257, EPA established guidelines for solid waste management. What solid waste disposal criteria apply to sanitary landfills on Indian lands? Will those criteria change when the new regulations for municipal landfills are published? Because State authority generally does not extend to Indian lands, State Subtitle D standards do not apply to sanitary landfills on Indian lands. However, the Federal solid waste disposal criteria apply to sanitary landfills on tribal lands directly. Therefore, Indian lands must follow the guidelines established in 40 CFR Part 257 for solid waste management. ------- 1. Subtitle D Programs on Indian Lands (Continued) EPA plans to publish proposed regulations for municipal landfills in the Federal Register in the near future. In developing the proposed ruleraaking, EPA is examining options for exempting Indian tribes from certain requirements. Source: Allen Maples (202) 382-4683 Research: Jennifer Planert 2. Certification of Closure The owner/operator of a hazardous waste management unit is conducting closure and hires a contractor to certify the closure. 40 CFR 264/265.115 state that certification of closure must be made by an independent, registered, professional engineer. Can the engineer who is employed by the contractor performing the closure, certify the closure of the facility? Yes, the "RCRA Guidance Manual for Subpart G Closure and Post-Closure Care Standards and Subpart H Cost Estimating Requirements" clarifies that an "independent" engineer cannot be directly employed by the owner or operator of the unit. Also, the May 2, 1986 Federal Register (51 FR 16433) states that, "... the certification should be made by a person who is least subject to conscious or subconscious pressures to certify to the adequacy of a closure that in fact is not in accordance with the approved closure plan." Source: Sharon Frey (202) 475-6725 Research: Chris Bryant 3. Waste Identification A company generates aerosol paint and solvent cans from painting and cleaning operations. The cans are empty as per common industry practices used to empty such devices to less than 3% by weight of the total capacity of the container (40 CFR 261.7(b)(1(i) & (iii)). The cans may still contain propellant, making the cans reactive if put in contact with a strong initiating force (i.e., intense pressure or heat). Since for all practicable purposes the cans are free of contents that might have been hazardous wastes, would this be regulation of the aerosol cans themselves? RIL #43 specifically excluded the regulation of the cans, and solely addressed only the potentially hazardous contents. Therefore, would aerosol cans free of hazardous waste, but still potentially reactive because of contained propellant be regulated as hazardous waste? -2- ------- 3. Waste Identification (Continued) Irrespective of the lack of contained waste, the aerosol cans would be a RCRA hazardous waste because they demonstrate the hazardous characteristic of reactivity (40 CFR 261.23(a)(6)). Source: Mike Petruska (202) 475-6676 Research: Andy O'Hare 4. Treatment of Infectious Waste There is growing national concern over proper infectious waste management. What are some of the treatment methods currently used for infectious wastes? Although RCRA section 1004 includes wastes with infectious characteristics in the definition of hazardous waste, there are presently no Federal regulations for management of infectious waste under RCRA Subtitle C. Instead, regulation of infectious waste has been left up to the States' discretion. EPA has, however, issued a guidance manual entitled EPA Guidance for Infectious Waste Management (May 1986), available through NTIS (publication number PB-86-199130) which describes numerous methods for effective treatment of infectious waste. Many treatment methods employ some form of heat or chemical sterilization. Steam sterilization uses steam at a temperature high enough to kill infectious agents in combination with pressurization in a vessel such as a steam sterilizer, autoclave, or retort. Steam sterilization is an effective treatment method for low-density wastes such as plastics. A method that can be used for most types of infectious waste is incineration. Incineration converts combustible wastes into a noncombustible ash while combustion gases are vented to the atmosphere. A third type of heat-related treatment is thermal inactivation. For liquid wastes, thermal inactivation heats the waste at a set temperature for a designated period of time. Solids may be chemically inactivated by heating them in an oven, typically at 320 degrees to 380 degrees Fahrenheit for two to four hours. Chemical treatment methods include gas/vapor sterilization and chemical disinfection. In gas/vapor sterilization, the infectious waste is fumigated with a gaseous or vaporized chemical such as ethylene oxide or formaldehyde. Chemical disinfection (the name is self-explanatory) is effective for liquid wastes but may also be used for solid wastes. -3- ------- A technology that may be used in the future is sterilization by irradiation. Ionizing radiation has already been used to sterilize other materials such as food and medical supplies. Source: Jacqui Sales (202)475-8933 Research: Jennifer B. Planert 5. Land Disposal Restrictions - Haloqenated Organic Carbons An F001/F002 waste subject to the November 7, 1986 Federal Register land disposal restrictions meets the criteria for the 1% national variance specified in Section 268.30. In the July 8, 1987 Federal Register, treatment standards were set for most HOCs. F001 and F002 wastes are also HOCs. Would the F001/F002 wastestream be subject to the newly-promulgated HOC treatment standards even though it has been granted a two-year variance F005 solvent wastes? The solvent would only be subject to the treatment standards and effective date in the November 7, 1986 rule. In 52 FR 25762, it says that "where treatment standards and prohibition effective dates are promulgated for California list waste constituents that are also covered under the November 7, 1986 rule, the treatment standards and effective dates from the prior rule apply." The general rule is that where a constituent is subject to more than one treatment standard, the treatment standard (and effective date) for the more specific constituent applies. Example: the F001-F005 treatment standard/effective date presides because, as a subset of the HOCs, it is more specific. Also, for a waste where two or more treatment standards apply because of different constituents (e.g., F001 and Lead), both would apply with respective effective dates. In the case above mixed with lead, the F001/F002 treatment standards and effective date would apply for the solvent constituents (rather than the HOC standard) and would get a variance until 11/8/88. However, the lead would be subject to the requirements effective 7/8/87. Source: Mitch Kidwell (202) 382-4770 Research: Mark Janaskie -4- ------- 6. SW-846 Test Method 3060 Why was Method 3060, for alkaline digestion to hexavalent chromium, dropped from the third edition of EPA's "Test Method for Evaluating Solid Waste?" Is there a replacement method? The SW-846 Test Method #3060 is used to determine the total concentration of hexavalent chromium in solid waste. It uses a basic digestion of the waste sample to solubilize both water-insoluble and water-soluble hexavalent chromium compounds. Method 3060 was dropped from the third edition of the SW-846 Manual because it yielded inconsistent results from sample to sample within the same matrix and from matrix to matrix. The method also provides the analyst with no way of distinguishing when it would or would not work. An evaluation study of Method 3060 indicates that not only is it possible to oxidize Cr*3 to Cr*6, but that Cr*6 can be reduced to Cr""3 during digestion. In fact, there is more likelihood that Cr*6 is reduced than Cr*3 oxidized. Also during the digestion, precipitates are formed which can present problems. It may be appropriate to continue using Method 3060, provided the user can demonstrate that it works by doing spike recoveries. At this time EPA does not have a current or expected replacement method for Method 3060. Source: Denise Zabinski (202) 382-7458 Research: Joe Nixon 7. Land Disposal Restrictions - California List A manufacturer produces an aqueous waste stream containing 250 mg/1 nickel, 1600 mg/1 free cyanides, and 650 mg/1 chromium (VI) at a rate of approximately 5000 gallons/month. The waste stream is characteristically hazardous due to the presence of free cyanides and chromium (VI) (D003 and D007, per 40 CFR Section 261.23- 24). The manufacturer has the waste shipped via tank truck to a commercial wastewater treatment facility that treats the wastewater in tanks. The wastewater treatment facility has a contract with a metals recovery firm to accept the sludges after treatment for reclamation. a) In addition to normal manifesting requirements, what must the manufacturer do in order to comply with the land disposal restrictions for his off-site waste shipments? -5- ------- 7. Land Disposal Restrictions - California List (Continued) b) If the manufacturer has a wastewater treatment facility constructed and, as a result, will be discharging the liquid portion of his waste under a NPDES permit and shipping his non-liquid sludges to a metals recovery facility, how will the off-site shipment of the sludge be regulated? a) The manufacturer's aqueous waste stream is restricted from land disposal according to Sections 3004(d)(2)(A), (b)(iii), and (B)(vi) of RCRA, which prohibit the land disposal of liquid hazardous wastes containing greater than 1000 mg/1 free cyanides, 500 mg/1 chromium (VI), and 134 mg/1 nickel. Consequently, the off-site shipment of his aqueous waste stream must be accompanied by a notification to the treatment facility of the applicable prohibitions in Section 3004(d) of RCRA, per 40 CFR 268.7(a)(l). The notice must include the following information: (i) EPA Hazardous Waste Number; (ii) The corresponding treatment standards and all applicable prohibitions set forth in Section 268.32 or RCRA Section 3004(c); (iii) The manifest number associated with the shipment of waste; and (iv) Waste analysis data, where available. b) If the manufacturer's wastewater treatment sludge is hazardous only because of characteristics, as identified in 40 CFR 261 Subpart C, and the sludge is sent to a facility which reclaims metals from the sludge, the sludge is no longer subject to the land disposal restrictions of 40 CFR Part 268. 40 CFR 260.10 defines a sludge as "any solid, semi-solid, or liquid waste generated from a municipal, commercial or industrial wastewater treatment plant, water supply treatment plan, or air pollution control facility exclusive of the treated effluent from a wastewater treatment plant." According to 40 CFR 261.2, a sludge which exhibits a characteristic of a hazardous waste is not a solid waste (and therefore not a hazardous waste, per 40 CFR 261.3) if it is to be sent for reclamation. Pursuant to 40 CFR 268.l(a), the land disposal restrictions of 40 CFR Part 268 apply specifically to hazardous wastes. Consequently, if the waste is not a hazardous waste under RCRA, the regulations of 40 CFR 268 do not apply. Source: Matt Straus (202) 475-8551 Mitch Kidwell (202) 382-4805 Research: Kris Andersen -6- ------- 8. Land Disposal Restrictions - Corrosive Waste A manufacturer generates an acidic aqueous hazardous waste stream (D002, per 40 CFR 26.122(a)) with a pH of 1.8 in his production process. The waste is piped from the production area to an acid neutralization tank, where the pH is raised to an average of 3.0. After treatment, the waste stream is shipped off-site to a commercial wastewater treatment plant where it is neutralized further and then discharged under a NPDES permit. Must the manufacturer comply with the requirement of 40 CFR 268.7(a)(2) to certify that the restricted waste may be land disposed without further treatment when he ships the waste off-site? No. If the waste stream was hazardous solely for the characteristic of corrosivity (40 CFR 261.22(a)) and after treatment it does not exhibit any characteristic of a hazardous waste, as described in Subpart C of Part 261, the waste is no longer a hazardous waste (40 CFR 261.3(d)(1)). According to the applicability provisions set forth in 40 CFR 268.l(a), "This part identifies hazardous wastes that are restricted from land disposal and defines those limited circumstances under which an otherwise prohibited waste may continue to be land disposed." Consequently, if the waste cannot be identified as a hazardous waste under RCRA, then the regulations of Part 268 do not apply, including the certification requirement of 40 CFR 268.7(a)(2). Source: Mitch Kidwell (202) 382-4805 Research: Kris Andersen B. Superfund 9. Re-Opener Clause in Covenants Not to Sue EPA published a policy memorandum in the July 27, 1987 Federal Register (52 FR 28038) concerning covenants not to sue. The Superfund Amendments and Reauthorization Act (SARA) of 1986 provides for covenants not to sue under Section 122(£). According to this provision, EPA may issue covenants not to sue for CERCLA liability, including future liability, in settlement of some CERCLA cases. One goal behind this provision is to encourage timely settlements between responsible parties and EPA. SARA Section 122(f)(3) requires that EPA certify that a remedial action is complete in order for a covenant not -7- ------- Re-Opener Clause in Covenants Not to Sue (Continued) to sue for future liability to be effective. If EPA issues a covenant not to sue for future liability to a settling party, but the remedy at the site subsequently fails or additional problems arise at the site, does the covenant not to sue remain in effect? The covenant not to sue would not remain in effect in these cases according to the policy set forth in the July 27, 1987 Federal Register. SARA Section 122(£)(6)(A) explicitly requires the EPA to include a "re-opener" clause in the covenant in the event that problems arise from conditions at the site that were unknown at the time EPA certified complete remedial action. In addition, Section 122(f)(6)(C) allows EPA to include a condition in covenants not to sue, allowing for future enforcement actions under Section 106 or Section 107 to ensure protection of public health and the environment. In its July 27, 1987 policy, EPA interprets Section 122(f)(6)(C) as authorizing a "re-opener" in the covenant to address liability in the case of remedy failure, i.e., the remedy fails to protect public health and the environment. (See 52 FR 28041 and 28042.) EPA may forego the reopener clause for future liability in three situations. Under Section 122(f)(6)(B), EPA may waive the unknown conditions re-opener if extraordinary circumstances exist and the settlement agreement provides reasonable assurance that public health and the environment will still be protected. In addition, Section 122(£)(2) provides for special covenants not to sue for future liability if: (1) EPA requires off-site disposal after rejecting a proposed on-site remedy that is consistent with the NCP, or (2) the chosen remedy includes complete destruction, elimination or permanent immobilization of the hazardous substances so that they present no foreseeable future risk to health and the environment. Source: Jon Fleuchas (202) 382-3077 Research: Jennifer Planert 10. Hazard Ranking System How are "facility," "site," "unit," and "release," defined under CERCLA? Which of the above mentioned areas is characterized when applying the Hazard Ranking -8- ------- 10. Hazard Ranking System (Continued) System (HRS) to determine whether that area is eligible to be placed on the National Priorities List (NPL)? The term "facility" is defined in CERCLA Section 101(9) and in the National Contingency Plan (NCP) at 40 CFR 300.6 as "any building, structure, installation, equipment, pipe or pipeline (including any pipe into a sewer or publicly owned treatment works), well, pit, pond, lagoon, impoundment, ditch, landfill, storage container, motor vehicle, rolling stock, or aircraft, or any site or area where a hazardous substance has been deposited, stored, disposed of, or placed, or otherwise come to be located; but does not include any consumer product in consumer use or any vessel" (emphasis added). Release is defined in CERCLA Section 101(22) and codified at 40 CFR 300.6 as including "any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injection, escaping, leaching, dumping, or disposing into the environment." There are no statutory or regulatory definitions of either "site" or "unit" under CERCLA. The term "site" is a generic term that is often used when referring to the area or location at which there has been a release, and which is undergoing some type of a Superfund response action. Generally a "site and a "facility" refer to the same area. Although "unit" is not specifically defined under CERCLA, the use of this term commonly carries a meaning equivalent to the RCRA term "hazardous waste management unit" (HWMU) which is defined in 40 CFR 260.10 as "a contiguous area of land on or in which hazardous waste is placed, or the largest area in which there is significant likelihood of mixing hazardous waste constituents in the same area. Examples of HWMUs included a surface impoundment, a waste pile, a land treatment area, a landfill cell, an incinerator, a tank and its associated piping and underlying containment system and a container storage area. A container alone does not constitute a unit; the unit includes containers and the land or pad upon which they are placed." Section 105(a)(8)(A) of CERCLA requires that EPA develop a system for "determining priorities among releases or threatened releases" and that system "shall be based on relative risk of danger to public health or welfare or the environment... taking into account... the population at risk, the sensitive ecosystems... and other appropriate factors" (emphasis added). Appendix A to 40 CFR -9- ------- 10. Hazard Ranking System (Continued) Part 300 contains EPA's User's Manual for the Hazard Ranking System (HRS). The introduction describes an HRS that is to be used in "evaluating the relative potential of uncontrolled hazardous substance facilities to cause health or safety problems, or ecological or environmental damage." BaSed on these statutory and regulatory discussions one may infer that "facility" and "release" are very broad definitions and are used almost interchangeably when applying the HRS and when conducting any subsequent response action. When EPA investigates an area and is gathering all relevant information to determine the relative risk for danger that is present, it is the "release," which can be synonymous with "facility," which is characterized and addressed for the purposes of applying the HRS. There is no discussion in Section 105 of a "site" or a "unit for the purposes of determining a potential NPL identification. Boundaries are not definitively drawn at the time of the HRS scoring or NPL promulgation, but are further defined at a later time, usually during the Remedial Investigation/Feasibility Study (RI/FS) phase. Section 104(d)(4) of CERCLA allows EPA to treat two or more non-contiguous facilities as one for the purposes of response actions if the facilities are "reasonably related on the basis of geography, or on the basis of threat, or potential threat to the public health or welfare or the environment." Since listing is for the purpose of prioritizing potential response actions, Section 104(d)(4) extends to the listing of sites as well. The September 8, 1983 Federal Register (48 FR 40663) states that in most circumstances sites will be scored and listed on the NPL individually, because this approach more accurately represents the hazards and potential hazards present at the site. The criteria that EPA evaluates when determining whether to list two or more sites together include: (1) whether they were part of the same operation, (2) whether the contamination from the sites are threatening the same ground or surface water resource, and (3) the distance between the non-contiguous sites and whether the target population is essentially the same (40 FR 40663). Listing similar sites separately does not preclude EPA from approaching the remedial activities of non-contiguous sites as one, or from addressing individual units at one NPL site with different actions where it is more appropriate or beneficial. Source: Suzanne Wells (202) 475-8103 Research: Deborah McKie -10- ------- II. ACTIVITIES - September 1987 A. The RCRA/Superfund and CEPP Hotlines responded to 14,100 questions and requests for documents in September. The breakdown is as follows: RCRA Superfund UST CEPP Information Calls 5913 1435 659 1979 = Call Document Requests 907 95 395 719 = Written Document Requests 207 456 Referrals 1208 127 = 8,235 1,530 1,054 3,281 = B. On September 1, Kim Jennings of the CEPP Hotline attended the Title III Workgroup meeting on the Status of Title III activities. C. On September 2, Joe Nixon and Laurie Huber of the RCRA/Superfund Hotline briefed the Hotline staff on an underground storage tank and piping field trip. D. On September 1, 8, 15,-22, and 29; the CEPP Hotline attended the weekly Preparedness staff meetings. E. On September 11 and 25, Robert Costa of the CEPP Hotline attended the Preparedness Staff Conference Call with the FEMA/EPA Regional Preparedness Coordinators on Status of Regional Title III activities. F. On September 14 and 15, Laurie Huber of the RCRA/Superfund Hotline briefed the UST staff on Hotline functions and activities. G. On September 14 and 15, the CEPP Hotline staff attended the RRT Co-Chairs meeting. H. On September 15, Robert Costa of the CEPP Hotline attended the Title III Workgroup meeting on the status of Title III activities. I. On September 22, Jennifer Planert of the RCRA/Superfund Hotline attended a Federal Facilities Workshop meeting. J. On September 29, Kim Jennings of the CEPP Hotline attended the Title III Workgroup meeting on the status of Title III activities. -11- ------- 11,. AJNALYbtb ut ULhbLLONb - September 1987 SUMMARY OF CALLS BY GEOGRAPHIC DISTRIBUTION (EPA 1 52 3 26. 32 5 2 11. % 4 12.02 6 INTERNATIONAL CALLS: 0.1% Manufacturers 7.02 State Agencies Generators 15. OZ Local Agencies Transporters 1.12 Used Oil Handlers TSDF's 7.6Z UST 0/0 EPA BO 3.02 Consultants EPA Regions 3.02 Attorneys Federal Agencies 2.02 Laboratories RCRA General Information 542 301U Notification 79 260.10 Definitions 84 260.22 Petitions/Delisting 47 261.2 Solid Waste Definition 135 261.3 Hazardous Waste Definition 232 261 C Characteristic HW 423 261 D Listed HW 520 261.4 Exclusions 157 261.5 Small Quantity Generators 133 261.6 Recycling Standards 108 261.7 Container Residues 35 266 C Use Constituting Disposal 9 266 D HW Burned for Energy Recovery 74 266 E Used Oil Burned for Energy Recovery 104 266 F Precious Metal Reclamation 18 266 G Spent Lead-Acid Battery Reclamation 15 9 £ *) /-«_...__.*.-_ _ /•*-»_ _ _ — 1 1 CO zo^ (jen era tor — ueneral 1OJ 100-1000 kg/mo 80 Manifest Info 85 Accumulation 81 Recordkeeping 4 Asportlng 25 International Shipments 10 263 Transporter 4$ Subtitle D 132 Used Oil - General " 65 Household Hazardous Waste 25 Dioxina 34 Mixed Radioactive Waste 41 Minimum Technology 41 Infectious Waste 28 Liability/Enforcement 110 Corrective Action 76 Waste Minimization 27 Asbestos/PCBs/Radon 68 REGIONS): 202 7 3.12 9 7.32 8 6.02 10 4.62 Universities/Researchers 1.22 Trade Associations 1.02 Insurance Co 5.32 Environmental Groups 29.42 Press 6.82 Citizens 2.42 Other 264/265 TSDP A - Scope /Applicability B - General Facility Standard* C - Preparedness /Prevent ion u - contingency Plans E - Manifest/Recordkeeping/Reporting_ F - Ground Water Monitoring G - Closure/Post Closure H - Financial Requirements I - Containers J - Tanks K - Surface Impoundments L - Waste Piles M - Land Treatment N - Landfills Liquids in Landfills 0 - Incinerators P - Thermal Treatment Q - Chem, Phys, Biol Treatment R - Underground Injection X - Miscellaneous 268 - Solvents & Dioxlns California List Wastes Scheduled Thirds General 269 - Air Emission Standards A - General B - Permit Application D - Changes to Permits F - Special Permits' G - Interim Status/LOIS 271 - State Programs 124 - Administrative Procedures DOT Requirements OSHA Requirements /HW Technologies Test Met hods /HW Technologies RCRA Document Requests SUBTOTAL * 7.52 2.02 120 42 8 14 53 147 115 34 42 194 68 8 3 46 39 66 7 2 9 14 155 140 15 97 18 63 40 27 28 47 122 6 86 45 138 907 6820 1.92 1.02 0.22 0.82 0.72 3.42 2.32 -12- ------- L^D-KGSDL-ND STORAGE TANKS 'Gen e ra 1 280.10 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 DOC REQ. SUBTOTAL Referrals - EPA - HQ - Regions - State - GPO/NTIS/PIC/ ORD /Dockets - Other - SUBTOTAL Requests responded to by Hotline Referred to EPA Prograa Offices Referred to other Federal Agencies Referred externally ( states » organizat Response Fora Sent Response Form Sent/FOIA Form Letter Sent /Need more info Requests filled - RCRA - CEBCLA - UST SUBTOTAL 168 54 40 20 47 32 9 20 11 37 8 37 20 25 8 58 27 14 6 5 6 7 395 * 1054 267 117 133 390 301 * 1208 :ion, etc) C E RC LA General SARA General Access & Information Gathering Allocations from Fund/ Fund Balancing/Grants CERCLIS/5103 Notification Citizen Suits Clean-Up Standards/ARARs/ How Clean Is Clean Contractor Indemnification Contracts/Contract Lab Program Exposure Assessment/ Public Health Evaluation Definitions Enforcement Federal Facilities Hazardous Subs tan ces/RQs HRS Liability /PRPs Mandatory Schedules Natural Resource Damages NBARs NCP NPL Off-Site Policy On- Site Policy PA/SI Radon RD/RA Remedial Remova 1 RI/FS HDDs /C lean-Up Costs Settlements SITE Program State Participation Taxes Title IH/Rlght-To-Know Other Provisions CERCLA DOC REQ. CEBCLA SUBTOTAL 126 8 12 1 - - - 31 10 19 * 207 lUb 58 13 13 67 4 85 13 48 34 18 34 12 243 26 69 2 5 9 41 128 22 6 8 2 3 40 16 27 41 45 23 9 9 136 11 95 * 1530 Written Responses: Total 92 -13- ------- CEPP Hotline Daily/Monthly Summary Report For SEPTEMBER 1987 Total Calls: 3281 Distribution of Calls by EPA Regions; 1_ 6.6Z 3 15.9Z 2 9 11.22 8.1Z 4_ 10 International 0.2Z Caller*; Manufacturers Distributors Handlers Attorneys Consultants/Engineers Laboratories Trade Associations Public Interest Groups Universities/Acadenia Insurance Companies Hospitals 15.2Z 1.6Z 49. 1.3Z 7.9Z 6.0Z 9.2Z 1.8Z 1.81 l.OZ 1.4Z 0.1Z 0.4Z Written Requests; 456 25.4Z 7.5Z Unknown 1.9Z State Agencies Fire Oepts. EPA Local Officials Farmers Federal Agencies Media/Press On ion /Labor Citizens Other 3.5Z 2.2Z 4.9Z 2.1Z 2.1Z 4.0Z 0.8Z 1.3Z 0.8Z 0.1Z l.SZ 1.1Z Title III: General 556 S301-3 Emergency Planning: 223 SERC's Notification Requirements TPQ's Sec. 305 Training Grants Sec. 305 Emergency Bevxcv Mixtures Extremely flaz. Substance* 201 63 18 37 248 65 Release Notification; General 80 Notification Requirements __ Reportable Quantities _ R Q's vs. TPQ's 24 13 CEKLA vs. Sec. 304 46_ Transportation 18 Exemptions 32 -14- ------- -'-'""' "•"—iifcillifllttl CEPP Hotline Daily/Monthly Summary Report (Continued) Ic_5__3_l_iy_31_2_: General SD3 Reporting Regulations Ie- I/IC Regulatoins hresholds .ec»_3_l.3..:'H General 'hresholds ublic Maetings ass Balance Study rads Secrets inforcement !EPP: Interim Guidance Tech» Guidance Inemical Profiles ;RT - i itle III Workshops ther Jo_c_u_me_n_t_ f of Docunents R-equVated fef er __ )TS (Section 313) _____ 2_8 )SHA « . . r 4fe, _98.2 _815_ _209. 22, HazA Categories 3_09_ Mixtures 117 Exemptions 158 0 55 719" 1473 'reparedness S'tarff 0^ RCRA/Superfund Hotline_ nil EPA •'' ": Other 41 _JL 12 -15- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000 IV. PUBLICATIONS - September 1987 RCRA "Summary of Appropriate Analytical Methods for Appendix IX; Parts I and II," is available from the National Technical Information Service (NTIS). The number is PB87-230-371. The cost is $48.95 for paper copy and $6.50 for microfiche. NTIS's telephone number is (703) 487-4860. "Siting Guidelines for Disposal of Mixed Waste," EPA/530-SW- 029, is available by calling the Hotline. "Guidance on Conceptual Design Approval for Commercial Low- Level Radioactive and Hazardous Waste Disposal FAcilities," EPA/530-SW-87-027, is available by calling the Hotline. "Implementation Strategy to Accompany the Proposed Rule for Burning of Hazardous Waste Fuels," OSW #9494.00-1, is available for viewing at the RCRA Docket. "Guidance for POTW's Directly Receiving Hazardous Waste," dated July 21, 1987, is available by calling Paul Connor at (202) 475-7718 or at regional offices. "Proceedings of the First Annual EPA Symposium on Solid Waste Testing and Quality Assurance," July 13-17, 1987, is available by calling Dan Hansen at the American Public Works Association. "Final Guidance on the Use of Alternative Dispute Resolution Techniques in Enforcement Actions," August 14, 1987, is available from the Public Information Center (PIC). The following documents are available from the Office of Groundwater Protection, (202) 382-7077: "State and Territory Groundwater Classification Systems". "Survey of State Groundwater Quality Protection Legislation," 1985. "EPA Activities Related to Source of Groundwater Contamination". "Groundwater Data Management with STORET". -16- ------- IV. PUBLICATIONS (Continued) CERCLA "Superfund Risk Assessment Information Directory," is available from the Public Information Center (PIC). "RI/FS Improvement Analysis Manual," July 1987 is available for viewing at the Superfund Docket and at the Regional offices. "PRP Search Manual," is available at the National Technical Information Service (NTIS). The number is PB 87-2324-76. NTIS's telephone number is (703) 487-4860. "The memo entitled "Entry and Continued Access under SARA," dated June 5, 1986, is available by calling John Fleuchas at (202) 382-3109. "Community Relations in Superfund: A Handbook," OSWER Directive #9230.0-3A (March 1986) is available by writing to OERR. The memo entitled "Superfund Project Execution," dated August 1987, is available at the Public Information Center (PIC). "Compendium of Superfund Field Operations Methods," OSWER Directive #9355.0-14 (EPA/540-P-87/001A) is available from ORD in Cincinnati. Their telephone number is (513) 569-7562. -17- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000 V. FEDERAL REGISTER NOTICES - September 1987 Former Notices with Open Comment Period July 6, 1987; 52 FR 25255 (proposed rule-administra- tive enforcement actions in the UST program) 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) 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 10, 1987; 52 FR 29620 (OSHA hazardous waste operations and emergency response) 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, 1986. 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. The documents address addenda to the health assessments for trichloro- ethylene and dichloromethane 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 September 21, 1987. accepted until Notice of extended public comment period concerning the Interim Guidelines on Nonbinding Preliminary Allocations of Responsibility (NEAR) to September 3, 1987. Notice of Science Advisory Board meeting concerning revisions of the Hazard Ranking System (HRS). The meeting will be held September 14 and 15, 1987 in Washington, D.C. Notice of proposed rulemaking by OSHA on hazardous waste operations and emergency response. Comments will be received on or before October 5, 1987. -18- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000 August 11, 1987; 52 FR 29708 (extension of comment period) August 12, 1987; 52 FR 29992 (notice of data, request for comment) August 14, 1987; 52 FR 30570 (proposed rule changes to interim status and permitted facilities and post-closure permits) 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, 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. August 24, 1987; 52 FR 31948 (proposed rule regarding statistical methods for ground-water data analysis) August 27, 1987; 52 FR 32446 (land disposal restrictions for underground injection wells) August 27, 1987; 52 FR 32496 (notice of ARAR guidance) 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. 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, 1987, 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. -19- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000 September 2, 1987; 52 FR 33284 (comment period extension on De Minimis settlement interim guidance) September 9, 1987; 52 FR 33960 (comment period extension on RCRA admin- istrative enforcement orders under Section 3008(h)) September 29, 1987; 52 FR 36461 (comment period on covenants not to sue) Notice of extending the comment period on the "Interim Guidance on Settlements with De Minimis Waste Contributors" under Section 122(g) of SARA. The interim guidance was published on June 30, 1987 (52 FR 24333). Comments will be accepted until September 30, 1987. Notice extending the comment period on August 6, 1987, proposed rule on the issuance of and Administrative Hearings on RCRA Section 3008(h) corrective action orders. Comments will be accepted until September 22, 1987. Notice extending the comment period on the interim guidance governing the issuance of covenants not to sue under Section 122(f) of SARA. The interim guidance was published on the July 27, 1987 (52 FR 28038). Comments will be accepted until October 30, 1987. September Federal Register Notices September 2, 1987; 52 FR 33284 (extension of comment period) September 3, 1987; 52 FR 33439 (proposed delistings) September 3, 1987; 52 FR 33446 (notice of intent to delete sites) Extension of public comment period on the Interim Guidance on Settlements with De Minimis Waste Contributors. Comments will be accepted until September 30, 1987. Proposed rule to delist waste streams from Syntex Agribusiness, St. Louis, MO. Comments will be accepted until October 5, 1987. Notice of intent to delete three sites from the National Priorities List and request for comments. The sites are the Middletown Road Dump, Annapolis, MD, Harris (Farley Street), Houston, TX, and Mountain View Mobile Home Estates, Globe, AZ. Comments will be accepted for 30 days from September 3, 1987. -20- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000 September 3, 1987; 52 FR 33480 (proposed consent decrees) Notice of proposed decrees lodged in the Southern District of Texas for the "Motco Site", and in the District of Massachusetts, for the Hocomonco Pond Site. Comments will be accepted for 30 days from September 3, 1987. September 8, 1987; 52 FR 33812 (removal of regula- tions ) September 9, 1987; 52 FR 33960 (extension of comment period) September 9, 1987; 52 FR 33936 (correction to final rule) September 10, 1987; 52 FR 34328 (notice of consent decree) September 15, 1987; 52 FR 34779 (notice of extension of compliance date) September 18, 1987; 52 FR 35279 (request for comments) September 21, 1987; 52 FR 35452 (Final State Program Authorization-Proposed) Final rule withdrawing two procedural rules concerning the Arbitration Procedures and Natural Resource Claims for the Hazardous Substance Superfund. Extension of public comment period on the August 6, 1987 proposal concerning administrative enforcement orders under Section 3008(h) to September 22, 1987 (40 CFR Parts 22 and 24). Correction to the final Section 270.14, Development of Corrective Action Programs After Permitting Hazardous Waste Land Disposal Facilities. Settlement Agreement Pursuant to CERCLA Harvey and Knotts hazardous waste site in New Castle County, Delaware, United States vs. General Motors Corporation. Comments will be accepted by the Assistant Attorney General. Extension of date for submission of Part A Permit Applications for Certain Cement Kilns Burning Hazardous Waste. Request for comments on expanding the sample exclusion in 40 CFR Section 261.4(d) to include samples sent for treatability studies. Comments will be accepted until October 19, 1987. Proposal for Wisconsin's Final Authorization of state hazardous waste management program-applications for revisions. Comments will be accepted until October 21, 1987. -21- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000 September 22, 1987; 52 FR 35577 (notice of proposed administrative settlement CERCLA) September 22, 1987; 52 FR 35604 (notice of availa- bility of a joint guidance document) September 22, 1987; 52 FR 35556 (notice of compliance schedule to adopt State Program Modification) September 23, 1987; 52 FR 35767 (notice of grant issuance) September 23, 1987; 52 FR 35838 (proposal to amend HW permit modification regulations) September 23, 1987; 52 FR 35894 (final rule for SQG exception reporting) Notice of proposed administrative settlement concerning the Union Chemical Co., Inc. hazardous waste site in South Hope, Maine, in accordance with Section 122(1)(1). Comments will be accepted for 30 days from September 22, 1987. Notice of availability of a joint guidance document between EPA and the Nuclear Regulatory Commission concerning the Conceptual Design Approach for Commercial Mixed Low- Level Radioactive Waste Disposal Facilities, from the RCRA/Superfund Hotline. Final authorization of Washington's State Hazardous Waste Management Program; Final Rule effective November 23, 1987 unless a Federal Register notice is published withdrawing this action. Comments will be accepted until October 22, 1987. $1.2 million grant issued to the National Governors Association to implement Section 104(K) of SARA (the State Capacity Assurance Project). Proposal to amend regulations governing modifications of hazardous waste management permits. New procedure that applies to various types of changes at a facility. Comments will be accepted until November 23, 1987. Finalization of the modified exception reporting requirement for small quantity generators of hazardous waste. -22- ------- RCRA/Superfund Hotline National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3000 September 28, 1987; 52 FR 36311 (lodging of consent decree) September 29, 1987; 52 FR 36444 (notice of proposed rulemaking) September 29, 1987; 52 FR 36461 (extension of comment period) September 30, 1987; 52 FR 36616 (notice of Science Advisory Board meeting) September 30, 1987; 52 FR 36643 (notice of proposed consent decree) Notice of consent decree lodged in the District of Connecticut for cost recovery of response costs incurred under CERCLA Section 107 and RCRA Section 3008. The case was United States vs. City of Derby, Connecticut. Comments will be accepted for 30 days from September 28, 1987. Notice proposing final reauthorization for Indiana's hazardous waste management program. The final authorization would not include authorization to implement HSWA. Comments will be accepted until October 29, 1987. The action will become final unless withdrawn in a subsequent FR notice. Notice extending the public comment period for the interim guidance on covenants not to sue under CERCLA Section 122(f). Comments will be accepted until October 30, 1987. Notice of Science Advisory Board's Radon Advisory Committee meetings, October 13-16, 1987 in Washington, D.C. Notice of proposed consent decree lodged in the District of Rhode Island regarding the Picillo Farm Superfund site in Coventry, Rhode Island, under CERCLA Section 122(f)(2) and RCRA Section 7003(d). Comments will be accepted until October 30, 1987. September 30, 1987; 52 FR 36644 (notice of proposed consent decree) Notice of proposed consent decree lodged in the District of New Jersey regarding the Renora Superfund Site in Edison, New Jersey, under CERCLA Section 107. Comments will be accepted until October 30, 1987. -23- ------- Martha Anderson, DORM Jim Barrett, GRC Frank Biros, WH-527 George Bonina, WH-563 Susan Broram, 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 Karen Ellenberger, WH-562A Tim Fields, WH-548B Lisa Friedman, LE-132S Goerge Garland, WH-563 John Gilbert, EPA-Cin. OH Peter Guerrero, WH-563 Matt Hale, WH-563 Penny Hansen, WH-562 Bill Hanson, WH-548E Betti Harris, EPA, Region 7 Lee Herwig, A-104 Irene Homer, WH-595 Barbara Hostage, SE-384E Hotline Staff Warren Hull, A-104 Phil Jalbert, WH-548D Alvin K. Joe, Jr., GRC Gary Jonesi, WH-562 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 Napolitano, 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 Willhelm, Region 7 Marcia Williams, WH-562 Dan Yurman, WH-562A 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- ------- Patrick A. Parenteau Regional Counsel Region I, US EPA #2203 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 ill, US EPA 841 chestnut St. Philadelphia, PA 19107 James Neet Regional Counsel (6C) Region VI, US EPA 1201 Elm St., inter. First TV 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 rv 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., I 1417 Chicago, IL 60604 (312) 353-2022 Ms. Dolores Eddy U.S. EPA, Reg. VIII Library 999 18th St. #500 Denver, CO 80202-2405 (303) 293-1444 Ms. Dottie Biggs U.S. NEIC Library - Bldg. 53 BOX 25227 Denver Federal Ctr. Denver/ CO 80225 (303) 236-3219 Ms. Diana McCreary U.S. EPA, Reg. Ill Library 3MA2 Curtis Bldg., 6th & Walnut Sts. 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 -25- ------- 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 V First international Bldg. Dallas, IX 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 vin 1860 Lincoln St. Denver, CO 80203 Bruce smith Chief, Haz. Waste Enforcement Br. O.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- ------- Janice Hicks (T-i-3) Office of Ccnununity 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 wirter 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 VII 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 Complianc 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 APB Nebraska, 6811:? -27- ------- |