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               UN|TED STATES ENVIRONMENTAL PROTECTION AGE
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                             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.

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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-

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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-

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          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-

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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-

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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-

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  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-

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     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-

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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-

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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-

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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
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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
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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 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
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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:?
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