530R87111
         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 I
                     WASHINGTON, D.C.  20460

                          JAN 28 1988
SUBJECT:  Final Monthly Report - RCRA-Superfund
          Industry Assistance Hotline  Report  for
          November 1987
                                                     OFFICE OF
                                            SOLID WASTE AND EMERGENCY RESPONSE
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 UNRESOLVED ISSUES - November  1987

 A .   RCRA

     1 .    Section 270.72 Changes in Interim Status

          A container  storage facility   has interim  status.   The  owner
          wishes to sell one-half of the container storage facility to  a
          person who   wishes to  set up   a solvent recovery  operation on
          the site.    The  solvent  recovery operator   wishes  to gain
          interim status  for storage by doing this.   The old  owner will
          have no  operational control  or interest   in  the  half of the
          facility that  is sold. ,  The   area will now be two  facilities
          under completely  separate ownership   and  operational control.
          Is this  allowed under  Section 270.72, changes during  interim
          status?

               Yes.  There is nothing in the regulations  to preclude an
               existing  facility  with   interim status  from selling off
               part of the facility and  transferring interim status for
               that part  of the  facility.   The new owner/operator will
               have to come into compliance  with Part   265,   and  among
               other  things  develop its  own closure plan, meet all of
               the financial responsibility  requirements  and submit  a
               new Part A for his part of the facility.   Any changes the
               new owner operator wishes to  make at  the interim status
               facility  will  have  to   satisfy Section  270.72,  which
               restricts both the types  of changes that  can  be made and
               the  dollar   amounts  of  such   changes   (i.e.  the 50%
               reconstruction limit).

          Source:    Fred Chanania  (202) 382-7706
          Research: Randy Eicher

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Exposure Informat icm	Kequi renen t a

Section 270.10(j) requires that exposure information accompany
Part B applications for landfills or surface impoundments.   Is
submission  of  exposure  information  a  condition for permit
issuance?  What should the exposure information include?

     No. Section  270.10(c) states  that an  application for a
     Part B  permit is  not considered incomplete if the owner
     or operator  fails  to  submit  the  exposure infor mation
     described  in  Section  270.10(j).    Failure  to  submit
     exposure information is a  separate violation  of Section
     3U19 of RCRA.

     At a minimum, the exposure information should address all
     potential pathways of human exposure to  hazardous wastes
     or constituents  resulting from releases during accidents
     and normal operations, including releases associated with
     transportation  to  or  from  the  unit.   These pathways
     include ground-water, surface water,  air emissions, food
     chain contamination,  and multi-media contamination.  The
     potential magnitude  and  nature  of  the  human exposure
     which  may  result  from  the  releases  should  also  be
     addressed.
Source:
Research:
Bob Kayser
Tish Zimmerman
(202)  382-4536
Financial Assurance
Corporation A owns 100% of the voting shares of corporation B.
Corporation  B   owns  over   50%  of  the  voting  shares  of
corporation C.  Can corporation A fulfill the  requirements as
a parent company of corporation C for the purpose of financial
assurance, via corporate  guarantee  as  required  in Sections
264.143, 264.145, 265.143 and 265.145?

     In  this  situation  corporation  A  is  a  "grandparent"
     corporation which indirectly owns over 50%  of the voting
     shares of  corporation C.  Corporation A does not fulfill
     the  definition of a parent corporation stated in Section
     264.141(d)  (see  April  7,  1982 Federal Register, 47 FR
     15037) as:  "A corporation which  directly owns  at least
     50% of  the voting  stock of the corporation which is the
     facility owner or operator; the latter  corporation which
     is deemed a "subsidiary" of the parent corporation."

     The  Agency  adopted  this  definition to ensure that the
     connection  between  the  two  firms  will  be  close and
     direct,  and the parent company is likely to have a strong
     interest  in   the   satisfactory   performance   of  its
     subsidiary.

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Financial Assurance  (Continued
     Since corporation  A is  not a parent corporation,  it nay
     not be used  to  demonstrate  financial  assurance  via a
     corporate guarantee for corporation C.

Source:   Carlos Lago     (202) 382-4780
Research: Craig Canpbell
Closure Plan Public Comment Period

As   specified   in   Section   265 . 11 2 ( d ) ( 4 ) ,    the   Regional
Administrator has  ninety  (90)  days  to   approve,  modify or
disapprove  the  closure  plan  for  an interim  status  facility
once  it   has  been   submitted  for   consideration  by  the
owner ' operator .  The section also provides  for  a  30 day public
comment period on the content of  the  plan,  which  is  to be
carried out  during the  90 day  term.    It  is  initiated via a
notice in the local newspaper.  It  is unclear as  to when this
public  comment  period  would  begin.  Is  it immediately upon
receipt  of  the  plan  without  an  initial  approval  by the
Regional  Administrator?    Or  would  it   begin  only after a
preliminary screening by the Region?

     Section  265 . 112 ( d ) ( 4 )  provides  for   a   30  day  public
     comment period  on the content  of a proposed closure plan
     for an interim status  facility and  does  not  state when
     this  period  is  to  be  initiated.    The Agency has not
     issued any specific guidance,   because  the   practice will
     vary  from  site  to  site  depending   on  the detail and
     complexity of the individual plan.   Owners  and operators
     may  request  public  hearings  in  addition  to  comment
     periods.  The Regional Administrator also  may schedule a
     hearing   at   his   own   discretion.       The   Regional
     Administrator may schedule the  hearing  with  or without
     the  benefit  of  the  response  from   the public comment
     period; regardless, the hearing  must  be   noticed 30 days
     prior  to  its  occurrence.    It is therefore conceivable
     that, within the framework  of  the   90  days  allowed, the
     time  required  ;o  fulfill  both regulatory requirements
     could be as long as bO days, or as short as  30  days (for
     current notice  of the  hearing and  the /omment  period).
     The Regional Administrator will review  the   plan  prior to
     offering  the   contents  for   public   review,  and  will
     approve, modify or disapprove  its contents within 90 days
     from the date of submission.

Source:    Chris Rhyne    (202) 382-4695
Research:  Andv O'Hare
                        -3-

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5.    Land Disposal Restrictions

     An F001 F002  waste subject  to the  November  7,   1986  F_R  land
     disposal restrictions meets the  criteria for   the  L\ National
     Variance specified  in Section 268.30.   In the  July  8, 1987  FR ,
     treatment standards  were set  for most;  HOCs.    FU01 and  EUU2
     wastes  are  also   HOCs.    Would the F001  F002  wastestrean  be
     subject to the new! y-pronulqcit ed HOC treatment   standards  even
     though it  has been  granted a two-year variance  for  FU01-E005
     so.vent wastes?

          The  solvent   would  only  be  subject  to   the  treatment
          standards  and  effective  date  in  the  November  7,  L986
          rule.  In 52 t_R  25762,  it  says  that   "where  treatment
          standards and  prohibition effective dates  are  pronulyated
          for California  list  waste  constituents   that  are  also
          cuv,-red 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 standard 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) 382-4805
     Research: Mark Janaskie


6 .    Underground Storage Tank

     In  the  April   17,  1987  Federa1 Register, Vol.  52, proposed
     regulations  for   underground   storage    tanks    (UST)   were
     published.   In the  proposed rule,  several release  detection
     methods for owners and operators of new L'STs  were  outlined  in
     Section  280.41.    One  of  these  proposed   methods,  Section
     280.41(e), tests or monitors for liquids  on the  ground-water.
     What proposed  techniques or  technique can be  used to  perform
     this method of  release detection for new USTs?

          Page 12733 of the  proposed  UST   regulations  (April  17,
          1987 F_R,  Vol. 52)  discusses three  general  techniques  that
          would be allowed under the specific conditions detailed
                             -4-

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    6 •    Lnderground Storage Tank (Continued)

              in the  regulations.  They are:  a physical inspection of
              a ground-water sample  using  sight  or  smell  to detect
              product;  lowering  a rod  with a thin film of paste on it
              that will .change color  when exposed  to any hydrocarbons
              on  top  of  the  water table; or a continuously operated
              automatic  sensing  device   capable   of  electronically
              detecting  the  physical  presence of hydrocarbons on the
              ground-water.    In  addition,  the  proposed regulations
              generally allow  any technique which can detect 1'8 of an
              inch or less of free product,  even if  it does  not fall
              into one  of the above categories.

         Source:    Ton  Young      (202)  475-7261
         Research: George Kleevic


B.  Superfund

    7 .    Section 103 Notification

         Section 103(a)  of SARA  requires that  any person who owns or
         operates a facility  where  there  has  been  a  release  of a
         hazardous substance in quantities equal to or greater than the
         reportable quantity, must notify the National  Response Center
         of such  a release.   Section  103(c) requires that any person
         who owned or operated any facility  at which  hazardous wastes
         have been  stored, treated,  or disposed  of shall, unless the
         facility  has    interim  status   or  a   permit,  notify  the
         Administrator  of the EPA of the existence of such facility.

         As  part  of  a   degradation  study,  various FIFRA registered
         pesticides listed  in Subpart  D of  40 CFR  Section 261, have
         been applied  to the  ground in quantities greater than the RQ
         for  those  substances.    Is  notification  of  this activity
         required?

              Section  103(e)  of  SARA  states  that  no  notification
              requirements  under  Section  103  shall  apply   to  the
              application  of  a  pesticide  product  registered  under
              FIFRA, or to the handling arid storage of such a pesticide
              product  by   an  agricultural   producer.    While  this
              exemption  applies  to  the  handling  and  storage  of a
              pesticide by an agricultural producer, it also applies to
              the application of pesticides  regardless of  whether the
              applicator  is  an agricultural producer or not.  However,
              because this exemption was intended to exclude from the
              notification requirements the application  of a pesticide
              product generally  in accordance with its purpose, (50 FR
              13464, April 4, 1985) the exemption applies to the


                                 -5-

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    7 .    Section 103 Xotif i c a_t ion (Continued)

              application  of  pesticides  for research purposes if the
              application is  done  in  che  normal  manner  and amount
              usually associated with that product.

         Source:   Carrie Wehling      (202)  475-8067
         Research:  Larry Buela


C.  CEPP

    8.    Section 311/312 Reporting Requirements

         A  manufacturing  operation  was  built  upon a waste disposal
         site.   The owner/operator of the  facility believes  there are
         hazardous   chemicals  buried  within   the facility boundaries.
         Would  the  owner/operator be required  to report these chemicals
         (hazardous waste)  under Section 311/312 of Title III?

              Sections 311  and 312  of Title  III of SARA requires that
              the presence of hazardous chemicals for  which facilities
              are required  to have  or prepare  a Material Safety Data
              Sheet (MSDS)  under the OSHA Hazard Communication Standard
              (29 CFR Section 1910.1200)  (HCS) be reported to state and
              local committees.   The HCS applies only to  "any chemical
              which is  known to  be present  in the workplace in such a
              manner  that  employees  may  be  exposed   under  normal
              conditions of use or in a foreseeable emergency."  29 CFR
              Section  1910.120U(b)(2).    Thus  unless  employees  are
              exposed  to  these  buried chemicals during a foreseeable
              emergency,  an owner/operator is  not obligated  to prepare
             or have  available an  MSDS on the chemicals and thus,  in
              turn,  is not   required  to   report  their  presence under
              sections 311  and 312 of Title III.

             Assuming the   facility's  employees are not exposed to the
             buried chemicals under  the  conditions  described above,
             they  may  still  be exempt from the HCS,  and thus sections
              311 and 312,  under the HCS's exemption for "any hazardous
             waste as such term is  defined by the Solid Waste Disposal
             Act  (as  amended     by  the Resource  Conservation  and
             Recovery Act   (RCRA)),  when subject to regulations issued
             under that  Act  by  the  Environmental Protection Agency."

             Even  if not subject  to  Title III because  exempt from the
             HCS,  the owner/operator may be required to notify the EPA
             of the chemical's  disposal  on the  facility under section
             103(c)   of   CERCLA,   provided the hazardous chemicals are
             also  CERCLA hazardous  substances.

                                 -6-

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Section 311/312 Reporting_Reguirenents  (Continued)

     An owner/operator  of a facility with  hazardous  chemicals
     buried within the facility boundaries  shuald consult  OSHA
     before determining  that it   is subject  to  or  exempt  from
     OSUA's HCS.

Source:   Kathy Brody    (202) 475-8353
Research:  Robert Costa
                        -7-

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1 1 .   ACTIVITIES - November
 A.   ^CRA Superfund Hotline

     1.    The  RCRA 'Superfund  and  CEPP  Hotlines  responded  to 12,538
          questions and requests for documents in November.           The
          breakdown is as follows:

                               RCRA   Superfund   UST    CEPP

     Information Calls         5247     1287      582    1341  -   8,457
     Call Document Requests     417      222      265     709  -   1,613
     Written Document Requests  386                       487  =     873
     Referrals                 1458                       137  =   1, 595
                              7,508    1,509      847   2,674  -  12,538

     2.    On November  4, Denise  Sines and Chris Bryant briefed OPPE  on
          Hotline  operations   as   related   to   tech   transfer  and
          clearinghouse issues.

     3.    On November  5, Denise  Sines and  Laurie Huber  met with Bill
          Foskett, OUST,  to preview  the "Reg-in-Box"  demonstration for
          Hot 1 me use .

     4.    On November  12,  Lucy  Sibold from OERR briefed the Hotline  on
          the current PA- SI guidance.

     5.    The  Superfund   '87   Conference   held   November   16-18  in
          Washington,    D.C.,   was   attended   by   many   Information
          Special ists .

     6.    On November 25, Greg  Ondich and  Mike Mastracci  from ORD and
          Jane Powers from OERR briefed the Hotline on the SITE program.


   B.   CEPP Hotline

     7.    On November 3,  10,  17, and 24, CEPP Hotline staff  attended the
          Preparedness Staff  meetings.

     8.    On November  6   and  20,  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.

     9.    On November  10,  Robert Costa of the CEPP Hotline  attended the
          Title  III   Workgroup  meeting  on  the  status  of  Title III
          activities .

     10.   On November  19,  Kim Jennings of the CEPP Hotline  attended the
          NRT meeting  on status  of Federal  emergency preparedness and
          training activities.

                                   -8-

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II.  ACTIVITIES - November 1987 (Continued)
B.  CEPP Hotline

   li.  On November  20, Dr.  Diane Beall of OTS and David Speights of
        the Preparedness Staff briefed the CEPP  Hotline staff  on the
        technical document  regarding bacitracin  and status of the 40
        chemicals being considered fur delisting.

   12.  On November 24, Brian  Littleton  of  the  CEPP  Hotline staff
        attended  the  Title  III  Workgroup  meeting on the status of
        Title III activities.
                                 -9-

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    III.  ANALYSES OF QUESTION'S - November  1987
                                                    Grand  Total   9,864
SUMMARY OF CALLS BY GEOGRAPHIC DISTRIBUTION  (EPA Regions):
      5.3°-,
                       25.3*,
     10.8
                        9.3-
     9.2
  INTERNATIONAL CALLS
Manufacturers
Generators
T transporters
TSDF1 s
EPA HQ
EPA Regions
Federal Agencies
5
14
1
7
1
••>
->
.1%
.9%
.4%
. 1%
.1";
.4%
.6%
                         State Agencies	
                         Local Agencies	
                         Used Oil Handlers_
                         U S T O ' O	
                         Consultants	
                         Attorneys
                         Laboratories
                                     RCRA
                                                     3.9%
                                                 11.0 %
                                                              10
                                                  3 . 0 ->
                                              _.
                                             1.8%
                                             0.8%
                                             4.7%
                                            '32.4%'
                                             7.9?
                                             1.8%
Univ. /Researchers
Trade Associations
Insurance Co
Environmental Groups
Press
Citizens
Other
2
0
0
0
o"
5
1
.5%
. 5%
.3%
.6%
".4%
.0%
.4%
General Information	351
3010 Notification	169
260.10 Definitions	113"
260.22 Petitions/Del isting	44
       Solid Waste Definition	112
       Hazardous Waste Definition  241
                                         264/265 TSDF
261
261
261
261
261
261
261
261
262
,10
, 22
i 2
,3
 C
 D
,4
, 5
,6
,7
       Characteristic
       Listed HW
HW
426
             411
       Exclusions	138
       Small Quantity Generators	112
       Recycling Standards	93_
       Container Residues	44
       Generator - General	138
       100-1000 kg mo	78~
       Manifest Info               111
                                   100
263
266
266
266

266
266
                     & Reporting
                     Shipments	
                                    49
                                    17"
                                    49"
                                    11"
    D
    E

    F
    G
    Recordkeeping
    Int ernatlonal
    Transporters	
    Use  Constituting  Disposal	
    HW  Burned  for  Energy  RecoveryoJ
    Used Oil Burned  for
     Energy Recovery	64
    Precious Metal Reclamation	1_3
    Spent  Lead-Acid  Battery
       Reclamation                15
A -
B -
C -
D -
E -
F -
G -
H -
I -
J -
K -
L -
M -
N -

O -
P -
Q -
R -
X -
268
                                          269
                                          270
                       Scope/Applicability	
                       General Facility Standards
                       Preparedness/Prevention	
                       Contingency Plans	
                                                                              10'
                                                                               3
Manifest/Recordkeeping/Reporting_lj
Ground Water Monitoring	  9.
Closure/Post Closure	
Financial Requirements	
Containers	
Tanks
                                           9J
                                           4!
                                           3.
Subtitle D
Used Oil - General
Household Hazardous Waste
D i o x i n s
Mixed Radioactive Waste
Asbestos /PCBs Radon
Infectious Waste
Liability /Enforcement
Corrective Action
Waste Minimization
Minimum Technology
113
86
28
33
59
85
26
62
82
22
25
                       Surface Impoundments	
                       Waste Piles	
                       Land Treatment	
                       Landf11 Is	
                       Liquids in Landfills	
                       Incinerators	
                       Thermal Treatment	
                       Chem, Phys, Biol Treatment
                       Underground Injection	
                       Miseellaneous	
                       - General	
                         Solvent & Dioxins	
                         California List Wastes	
                         Scheduled Thirds	
                          Air Emission Standards
                          A - General	
                          B - Permit Application	
                            - Changes to Permits	
                            - Special Permits
                            - Interim
                                           5'
                                           5.
                                          141
                                           2J
                                           "r
                                                D
                                                F
                                                G
                                                            Status/LOIS	
                                              - State Programs	
                                              - Administrative  Procedures
                                              Requirements	
                                          271
                                          124
                                          DOT
                                          OSHA Requirements/HW  Training
                                          Test Methods/HW  Technologies
                                          RCRA/Document
                                          SUBTOTAL
                                                                           2'
                                                                           6'
                                                                           3
                                                        Requests
                                                                        _ 121
                                                                          4T
                                                                        5 ~~ 6 6-
                                      - -10-

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I \DEKGROUND STORAGE TANKS
CERCLA
General
J80.10 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
Requirement s
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
Liabil itv
Enforcement
LUST Trust Fund
Other Provision
UST Document Requests
UST SUBTOTAL
Referrals - EPA - HQ
- Other Hotlines
- Regions
- State
- GPO, NTIS/PIC
ORD/Dockets
- Other
SUBTOTAL 1,
Written Request Responses:
Hotline Responses
Referred to EPA Program Offices
Referred to other Federal Agencies
Referred externally (states, organizat
Response Form Sent
Response Form Sent/FOIA
Form Letter Sent/Need more info
Requests filled - RCRA
- CERCLA
- UST
SUBTOTAL
162
53
31
14
21
19
10
19
11
31
12
29
10
19
8
43
37
11
16
5
11
10
265
847
230
275
140
154
531
128
458



General
SARA General
Access in Information Gathering
Allocations from Fund/
Fund Ba lancing . Grants
CERCLIS'103 Notification
Citizen Suits
Clean-Up Standards / ARARs/
How Clean Is Clean
Contractor Indemnification
Cont racts /Contract Lab Program
Exposure Assessment/
Public Health Evaluation
Definitions
Enforcement
Federal Facilities
Hazardous Substances/RQs
HRS
Liability/PRPs
Mandatory Schedules
Natural Resource Damages
NBARs
NCP
NPL
Off-Site Policy
On-Site Policy
PA/SI
Public Participation
Radon
RD/RA
Remedial
Removal
RI/FS
RODs/Clean-Up Costs
Sett lements
SITE Program
State Participation
Taxes
Title III/Riqht-To-Know
Other Provisions
CERCLA Document Requests
CERCLA SUBTOTAL 1

20
6
L02
3b
3
19
83
•>
64
6
_26
35
21
28
23
191
20
54

5
1
31
180
19
7
20
5

6
37
8

43
37
22
16
9
59
30
02°
,509

ion, etc) 125










235


386

TOTAL CALLS, DOCUMENT REQUESTS AND REFERRALS
                                           -11-

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        CEPP Hotline
Daily/Monthly Summary Report
     For November 1987
Total Calls 2050
Distribution of Calls by EPA Regions:
1 7.0 4 11.8 7
2 12.2 5 20.5 8
3 21.5 6 6.5 9
Callers:
Manufacturers 37.2
Distributors 1.8
Handlers 8.1
Attorneys 6.0
Consultants/Engineers 12.1
Laboratories 1 . 6
Trade Associations 2.2
Public Interest Groups 1.5
Universities/Acaderaia 2.2
Insurance Companies 0.1
Hospitals 1.0
Title III: General
Section 301-3 Emergency Planning:
SERC's
Notification Requirements
TPQ's
Sec. 305 Training Grants
Sec. 305 Emergency Review
Mixtures
Extremely Hazardous Substances
Release Notification: General
Notification Requirements 73
Reportable Quantities 36
RQ's vs. TPQ's 13
Written Responses
4.0 10 2.0
3.9 International:
8.0 Unknown:
State Agencies •
Fire Depts.
EPA
Local Officials
Farmers
Federal Agencies
Media/Press
Union/Labor
Citizens
Other
323
183
103
74
53
11
9
25
211
90
CERCLA vs. Sec. 304
Transportation
Exemptions
487
0.1
1.6
4.7
3.3
4.2
7.3
0.4
2.0
1.3
0.2
1.3
1.0
38
13
35
        -12-

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CEPP Hotline Daily/Monthly Summary Report - November 1987
(Continued)
SEC. 311/312: General
MSDS Reporting Regulations-
Tier I/II Regulatoins
Thresholds
Sec. 313: General
Thresholds
Public Meetings
Mass Balance Study

Trade Secrets
Enforcement
CEPP: Interim Guidance
Tech. Guidance
Chemical Profiles
NRT - 1
Teleconference
Title III Workshops
Other
Document Requests
# of Documents Requested
Referrals :
OTS (Section 313) 23
OSHA 25
Preparedness Staff 1
340
303 Haz. Categories 58
214 Mixtures 56
213 Exemptions 117
173
25
0
0

90
15
25
19
167
3
2
24
709
1544

RCRA/Superfund Hotline 60
Regional EPA 2
Other 24
                                      -13-

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IV.     PUBLICATIONS - November 1987
        RCRA
            The "Guidance on the Use of Stipulated Penalties in Hazardous
            Waste Consent Decrees,"  September 21,  1987,  a memorandum from
            Thomas L.  Adams, Assistant Administrator,  Office of
            Enforcement and Compliance Monitoring  to Regional
            Administrators, is available by calling the  Hotline.

            The following documents  are available  by calling the  Hotline:

            1.    Understanding the Sraall Quantity  Generator Regulations:
                 A Handbook for Snail Businesses:   Order No. EPA'' 530-SW-
                 86-019;

            2.    Solving  the Hazardous Waste Problem:   Order No.  EPA/530-
                 SW-86-037.

            OSWER Directive 9384.11, "Revised Procedures for Implementing
            Off-Site Response Actions," November 13, 1987,  is available
            by  calling the Hotline.

            Draft EPA Support Document:  Regulatory Standards and
            Solubilities  of Constituents of Concern, which is mentioned
            in  the November 17, 1987 FR and which  was submitted for
            public comment on July 29,  1986, contains the health-based
            standards to  which a waste stream is compared to determine
            whether a  waste should be delisted.   It is available  from the
            RCRA Docket.   The Order  No. is F-86-MADP-FFFFF.

            The document, dated February 4, 1987,  entitled Regulatory
            Standards, Solubilities, and Maximum Acceptable
            Concentrations for Constituents_o_f	Concern in Delisting
            Pet it ions  has not been noticed for public comment but is
            available  in  the RCRA docket.

            The following documents, with order  numbers, are available
            from XTIS:

            1.    Survey of Household Hazardous Waste and Related
                 Collection Programs, NTIS PB87-108-072AS.

            2.    Census of State and Territorial Subtitle D Non-HW
                 Programs, NTIS PB-87-108-080AS.


            "Protocol  for Evaluating Interim Status Closure and Post-
            Closure Plans," is available at NTIS.   The publication number
            is  PB-87-178-315 and the cost is S13.95.

            The memo entitled,  "Changes to State Laws Which Raise
            Consistency Issues," a memorandum from Marcia Williams,
            Director,  Office of Solid Waste to Regional  Hazardous Waste
            Division Directors, is available by  calling  the Hotline.
                                     -14-

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IV.   PUBLICATIONS

 RCRA (Continued)

     Copies of the proposed Infectious Waste Bill, introduced
     October 20,  1987,  (H.R.  3515)  is available by calling the
     Subcommittee on Transportation,  Tourism and Hazardous
     Materials at (202)  225-9304.
 CERCLA

     "Final Guidance on Use of Alternative Dispute Resolution
     Techniques in  Enforcement Actions," dated August 14, 1987,
     is available from the Public Information Center (PIC).

     "SITE  Strategy and Program Plan" is an OSWER Directive (No.
     9380.2-3), EPA 540/G-86-001, and is available from NTIS (PB-
     87-181-939)  and costs $13.95.

     The following documents are now available from NTIS:

     1.    "The Guidance on Remedial Investigations Under CERCLA"
          (EPA/540-G-85/002).   The NTIS number is PB 85-238-590.
          (Price  is S18.95. )

     2.    "The Guidance on Feasibility Studies Under CERCLA"
          (EPA/540-G-85/003).   The NTIS number is PB 85-238-616.
          (Price  is S18.95. )

     "Final Data  Quality Objectives for Remedial Response
     Activities," (OSWER Directive #9355.0-78) is available to
     public entities (States,  municipalities and citizens) through
     ORD.   It  is  2 volumes:

                         EPA/540-G-87-003   Vol. 1
                         EPA/540-G-87-004   Vol. 2
     The  information packages for the Superfund Preliminary
     Assessments  and Site Investigations are available by calling
     the  Hot 1 me .

     A copy of  "Hazardous Waste Research Locator," a list of
     technical  contacts and publications (CERCLA and RCRA), is
     available  from ORD.  The order number is EPA/600-9-87-007.
                              -15-

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 National  Toll  Free
           RCRA/Superfund Hotline
      #800-424-9346, Washington, D.C.
             Metro 202-382-3000
V.  FEDERAL  REGISTER  NOTICES  FOR  NOVEMBER  1987
 Forner Notices with Open  Connent_Per_ Lad
 September  23
 (proposal  to
 nodification
 1987: 52 FR 35838
amend HW permit
requirenents)
October 6, 1987; 52 FR  37335
(proposed  rule to amend  Federal
procurement guidelines)
October 14, 1987; 52 FR  38111
(extension of comment period
for delisting petition)
October 15, 1987; 52 FR 38312
(proposed procedures for claims
of secrecv under SARA Title III!
October 15, 1987; 52 FR 38345
(notice of availability of ATSDR
toxicological profiles)
October 19, 1987; 52 FR 38838
(proposed Federal procurement
guideline)
Proposal  to amend  regulations
governing modifications of hazardous
waste management permits.  New
procedure that applies to various
types of  changes at a facility.
Comments  accepted  until November 23,
1987.

Proposed  rule to amend the guidelines
for Federal procurement of paper
containing recovered materials  (40
CFR 250).  Comments accepted until
November  7, 1987.

Extension of the comment period on
the September 3, 1987 proposed rule
to delist waste from Syntex
Agribusiness, Inc., Springfield,
Missouri.  Comments  accepted until
November  4, 1987.

Proposed procedures for filing
claims of trade secrecy by facilities
reporting under Sections 303(d)(2)
and (d)(3), 311, 312, and 313 of SARA
Title III. The proposal includes EPA'b
policies on the review of the claims
for disclosure of  trade secret
information to health professionals.
Comments accepted  until December 14,
1987.

ATSDR and EPA announces the expected
availability of the 25 draft
toxicological profiles from the
priority  list of 100 hazardous
substances most commonly found at
NPL sites in accordance with CERCLA
Section 104(i) (3)  as amended by SARA
Section 110.  A 90-day comment period
is provided for each profile, starting
from the actual document release date.

Proposed guideline for Federal
procurement of certain engine
lubricating oils,  hydraulic fluids,
and gear oils containing rerefined
oils (40 CFR 252).  Comments will be
accepted until December 18, 1987.
                                     -16-

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                            RCRA/Superfund Hotline
     National  Toll Free #800-424-9346, Washington,
                                          D.C. Metro 202-382-3000
October 21, 1987; 52 FR 39243
(extension of comment period on
California list metals and
cvanide wastes)
                             Extension of the comment period on
                             the August 12, 1987 notice of data
                             availability on lowering the prohibi-
                             tion  levels for California list metal-
                             bearing and cyanide containing wastes
                             Comments accepted until November  12,
                             1987.
November 21, 1987; 52 FR 39386
(interim final rule - Section 123
SARA reimbursement to local
governrv  i s )
November 2, 1987; 52 FR 42038
(Science Advisory Board meeting)
November 2, 1987; 52 FR 41996
(Oklahoma st'-Te program
modifications)

November 3, 1987; 52 FR 42144
(Science Advisory Board meeting)
November 3, 1987; 52 FR 42144
(Science Advisory Board meeting)
November
(Sclence
9, 1987;
Advisory
52 FR 43109
Board meeting)
                             Interim final rule to provide
                             reimbursement to  local governments
                             for costs for emergency response to
                             hazardous substance releases as
                             authorized under  CERCLA as amended
                             by Section 123 of SARA.  Comments
                             accepted until December 21, 1987.
Federal Register Notices - November 1987
Notice of a Science Advisory Board,
Research Strategies Committee open
meeting was held on December 3, 1987
in Arlington, Virginia.  The Exposure
group will discuss research strategies
for exposure research.

Notice of a compliance schedule for
Oklahoma to obtain hazardous waste
program revisions  (40 CFR 271.21(g)).

Notice of a Science Advisory Board
meeting regarding the Risk Reduction
Group's strategy on environmental risk
reduction.  The meeting was held at
Headquarters on November 24, 1987.

Notice of a Science Advisory Board
meeting regarding the Sources,
Transport and Fate Subgroup's evalua-
tion of environmental contaminants
from both a media-specific and multi-
media basis.  The meeting was held in
Dallas on December 4, 1987.

Notice of a November 19-20 meeting of
Halogenated Organics Subcommittee of
the Environmental Health Committee of
the Science Advisory Board. Dis-
cussion centered on a review of the
health criteria documents for PCBs,
1-2-dichloropropane, and cis-and
trans-dichloroethylene.
                                   -17-

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   National Toll
         RCRA Superfund Hotline
Free *8UU-424-9346,  Washington, D.C
                Metro JU2-382-3000
November 9, 1987; 52
(DOJ consent decree)
    FR
November 9,  987; 52 FR 43133
( DOJ conSent dec ret- )
November 12, 1987; 52 FR 43393
(notice of model language for
DeMinimis Contributor
Statements)
November 16, 1987; 52 FR 43797
(Science Advisory Board meeting)
Notice of lodging of consent decree
pursuant to RCRA; Buckeye Products
Corporation, Adrian, MI, a TSDF.

Notice of lodging of consent decree
pursuant to RCRA; Hudson Refining Co
Inc., ,;rid Hudson Oil Co., Inc.
                     Publication of the Interim Model
                     CERCLA Section 122(g)(4) DeMinimis
                     Waste Contributor Consent Decree and
                     Administrative Order on Consent.
                     Provides model language for drafting
                     de minimis contributor settlements.
                     It is designed to be used in
                     conjunction with the Interim Guidance
                     on Settlements with DeMinimis Waste
                     Contributors under SARA Section
                     122(g), published at 52 FR 24333 (June
                     30, 1987).

                     Notice of a Science Advisory Board,
                     Research Strategies Committee -
                     Ecological Effects Subgroup meeting
                     held on December 15 and 16, 1987 in
                     Denton, Texas.
November 16, 1987; 52 FR 43763
(Department of the Interior)
                     Notice of availability of Type B
                     technical information documents for
                     performing natural resource damage
                     assessments.
November 17, 1987; 52 FR 43903
(North Carolina - Notice of
proceedings program withdraw)
November 18, 1987; 52 FR 44314
(final rule - TSDF liability
requirements)
                     Notice to commence proceedings to
                     determine whether to withdraw North
                     Carolina's hazardous waste program
                     approval.  The state must respond to
                     the order by December 17, 1987.  The
                     hearing was held on Januarv 12-13,
                     1988.

                     Final  rule to allow use of a corporate
                     guarantee as an additional financial
                     responsibility mechanism to comply
                     with liability coverage requirements
                     of 40  CFR 264 and 265.
                                   -18-

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   National Toll Free
    RCRA Superfund Hotline
$800-424-9346,  Washinqton, D.C.
Metro 202-382-3000
November 18, 1987; 52 FR 44220
(Science Advisory Board meeting)
                Notice of a Science Advisory Board,
                Drinking Water Subcommittee meeting t<
                be held on December 3-4, 1987 in
                Cincinnati, Ohio.  The purpose of the
                meeting will be to review the Health
                Effects Research Program on Drinking
                Water Distribution Systems.
November 18, 1987; 52 FR 44153
(correction notice and request
for comment)
                Notice of correction and extension
                of the comment period for the
                September 23,  1987 proposed rule on
                permit modifications for TSD
                facilities.   Comments accepted until
                December 18, 1987.
November 19, 1987; 52 FR 44481
(proposed CERCLA Settlement)
November 23, 1987; 52 FR 44921
(Title III; availability of
studv)
November 23, 1987; 52 FR 44938
( DO J consent decree)
NY  -fiber 24, 1987; 52 FR 45017
(Science Advisory Board meeting)
November 24, 1987; 52 FR 45017
(Science Advisory Board meeting
cancellat ion)
                Notice of a proposed settlement under
                Section 122(h) of CERCLA concerning
                the Union Chemical Co., Inc. hazardous
                waste site in South Hope, Maine.

                Notice of the availability of the
                toxic effects study on Bacitracin, ont
                of the 40 substances proposed for
                deletion from the "extremely hazardous
                substances" list of Section 302, Title
                III of SARA.   The Agency is also
                providing the approach used to
                determine if Bacitracin should be
                considered "extremely hazardous."

                Lodging of consent decree pursuant to
                CERCLA, in the Northern District of
                Ohio, for recovery of clean up costs
                for the Shenango Lake Project, from
                Horodyski Brothers and Co., et al.

                Notice of a December 10, 1987 meeting
                of the Unsaturated Zone Code
                Subcommittee of the Environmental
                Engineering Committee of the Science
                Advisory Board to review the Office oi
                Solid Waste's Unsaturated Zone Code
                FECTUZ.

                Notice on the cancellation of the
                December 15 and 16 meeting of the
                Ecological Effects Subgroup of the
                Research Strategies Committee of the
                Science Advisorv Board.
                                   -19-

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   National Toll Free
    RCRA/Superfund Hotline
28UO-424-9346, Washington,
D.C. Metro 2U2-382-3UOO
November 24, 1987; 52 FR 45018
(ATSDR; interim procedures for
requesting health assessments)
                \otice describing the interim
                procedures for individuals to request
                health assessments to be performed by
                ASTDR as authorized by Section
                104(L)(6>(B) of CERCLA as amended by
                SARA,  and Section 3UI9(c) of RCRA.
                                   -20-

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Martha Anderson, DORM
Jin Barrett, GRC
Frank Biros, WH-527
George Bonina, WH-563
Susan Bronn, WH-563
Karen Brown, PM-220
John Boskv, EPA- Kansas City
Diane Buxbaum, Region  2
Fred Chanania, LE-132S
Richard Clarizio, Region  5
Kathy Collier, RTP, N'C
Peter Cook, WH-527
Alan Corson, WH-565
Elizabeth Cotsworth, WH-563
Wayne Crane, PM-273F
Hans Crump, WH-548B
Gordon Davidson, WH-527
Elaine Davies, WH-562
Truett DeGeare, WH-563
Melinda Downing, DOE
Karen Ellenberger, WH-562A
Tim Fields, WH-548B
Lisa Friedman, LE-132S
George Garland, WH-563
John Gilbert,  EPA-Cin. OH
Lloyd Guerci,  WH-527
Lynn Hansen, WH-
Penny Hansen
Bill Hanson,
Betti Harris
Irene Hornet-
Barbara Hostage,
Hotline Staff
Warren Hull, A-104
Phil Jalbert, WH-548D
 WH-562
WH-548E
 EPA, Region
 WH-595
    WH-548B
Alvin K. Joe, Jr., GRC
Gary Jonesi, WH-562
Jin'jowett, WH-548B
Thad Juszc^-ak, WH-562A
Tom Kennedy, (ASTSWMO)
Robert Knox, WH-562
Jack Kooyom^jian, WH-548B
Mike Kosakowski, WH-527
Walter Kovalick, WH-548
Tapio Kuusinen, PM-223
Steve Leifer, LE-134S
Steve Levy, WH-565
Henry Longest, WH-548
Sylvia Lowrence, WH-562
Gene Lucero, WH-527
James Makris, WH-562A
Jack McGraw, WH-562A
Scott McPhilamy, Region 3
Royal Nadeau, Region 2
Mike Petruska, WH-562B
John Riley, WH-548B
Mike Riley, PM-214F
Clen Rastatter, WH-548
Dale Ruhter, WH-565
William Sanjour, WH-563
Pam Sbar, LE-134S
Mike Shannon, WH-563
Ken Shuster, WH-565
Elaine Stanley, WH-527
Jack Stanton, A-101
Anastasia Watson, WH-562B
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
                              -21-

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>IV.    PUBLICATIONS - November 1987

        RCRA
            The  "Guidance on the Use of Stipulated Penalties in Hazardous
            Waste Consent Decrees," September 21, 1987, a memorandum from
            Thomas L. Adams, Assistant Administrator, Office of
            Enforcement and Compliance Monitoring to Regional
            Administrators, is available by calling the Hotline.

            The  following documents are available by calling the Hotline:

            1.   Understanding the Small Quantity Generator Regulations:
                 A Handbook for Small Businesses:  Order No. EPA/530-SW-
                 86-019;

            2.   Solving the Hazardous Waste Problem:  Order No. EPA/530-
                 SW-86-037.

            OSWER Directive 9384.11, "Revised Procedures for Implementing
            Off-Site Response Actions," November 13, 1987, is available
            by calling the Hotline.

            Draft EPA Support Document:  Regulatory Standards and
            Solubilities of Constituents of Concern, which is mentioned
            in the November 17, 1987 FR and which was submitted for
            public comment on July 29, 1986, contains the health-based
            standards to which a waste stream is compared to determine
            whether a waste should be delisted.  It is available from the
            RCRA Docket.  The Order No. is F-86-MADP-FFFFF.

            The document, dated February 4, 1987, entitled Regulatory
            Standards, Solubilities, and Maximum Acceptable
            Concentrations for Constituents of Concern in Delisting
            Petit ions has not been noticed for public comment but is
            available in the RCRA docket.

            The  following documents, with order numbers, are available
            from XTIS:

            1.   Survey of Household Hazardous Waste and Related
                 Collection Programs, NTIS PB87-108-072AS.

            2.   Census of State and Territorial Subtitle D Non-HW
                 Programs, NTIS PB-87-108-080AS.
            "Protocol for Evaluating Interim Status Closure and Post-
            Closure Plans," is available at NTIS.  The publication number
            is PB-87-178-315 and the cost is $13.95.

            The memo entitled, "Changes to State Laws Which Raise
            Consistency Issues," a memorandum from Marcia Williams,
            Director, Office of Solid Waste to Regional Hazardous Waste
            Division Directors, is available by calling the Hotline.
                                     -14-

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