530R88101

                              >f!RONMENTAL PROTECTION AGENCY
                              HINGTON, D.C. 20460
                   , R£G|0M
                                                             OFFICE OF
                                                    SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT:
FROM:
          Final Monthly Report - RCRA/Superf und Industry
          Assistance Hotline and CEPP Hotline Report for
          January 1988               ,.

          Thea McManus
          Office of Solid Wajste (WH-562)
TO:
          Hubert Watters /'office of Emergency
            and Remedial Response (WH-548B)

          See List of Addressees
     This report
68-01-7371.
                  is prepared  and submitted for EPA Contract No.
I.  SIGNIFICANT QUESTIONS AND RESOLVED ISSUES - January 1988

  A.   RCRA Program

     1 .   Definition of Used Oil

     Number 2 fuel oil is used to clean  air filters  and then is
     burned for  energy recovery.   Is  "used oil" subject to the
     regulations of 40 CFR 266, Subpart E?  If the substance used
     for  cleaning  the  air  filters  was gasoline, and then was
     burned for energy recovery,   would  it  be  considered "used
     oil"?
          Currently,   there  is  no  more  specific definition of
          "used oil"  than that found in RCRA Section  1004 and in
          40  CFR  266.40(b).     When  the  "used  oil" technical
          standards are proposed,  a  more specific  definition of
          "used oil"   will be   included in  that proposal.  EPA's
          current position is   oil  that  has  been  refined from
          crude  oil,  used  as  a  lubricating hydraulic or heat
          transfer fluid,  and  has  become  contaminated through
          use,  is a "used oil."  Petroleum distillates which have
          been  used only as cleaning agents,  or only  for their
          solvent  properties,  would  not  be regulated as "used
          oil"  when burned for  energy  recovery  or  recycled in
          some  other   manner.   It is important to note that "used
          oil"  does not need to  be  a  solid  waste  per Section
          261.2 in  order to  be regulated under RCRA Subtitle C,
          because the authority to  regulate "used  oil" is found
          in Section  3014 of RCRA.
Source:    Dave Tompton
Research: Becky Cuthbertson
                              (202)  382-2550

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2.  "Lab Packs" at Generator Sites

Is  a   permit  required   for  a   service  company  (under
contractual  agreement  to  manage  a  generator's hazardous
waste) to  come onto a generator's site and re-package small
containers of hazardous  waste  into  large  containers with
absorbents?

     A generator  may accumulate  wastes pursuant to Section
     262.34,  and  nothing  in  Section  262.34  precludes a
     generator  from   treating  waste  when  it  is  in  an
     accumulation  tank  or  container   provided  that  the
     performance standards  under Subparts  I and  J of Part
     265 are  met  (51  FR  10168),  and  provided  that the
     treatment  is  not  thermal  treatment  or incineration
     which  are  subject  to  Part  265  Subpart  P   and  O
     respectively.    Further,  the  addition  of  absorbent
     material to waste in a  container  or  the  addition of
     waste to a container holding absorbent material also is
     exempt  from  permitting  in  accordance  with  Section
     265.1(c)(13) .    Because  a  service company may act on
     behalf of the generator, a permit would not be required
     for  a  service  company  to re-containerize the wastes
     and/or add absorbent material  prior  to  shipping off-
     site.   The Agency's  current policy  on treatment at a
     generator  facility  is  that  treatment  often renders
     waste less hazardous or at least easier to transport or
     more amenable for recovery.    For  these  reasons, EPA
     considers  that  such  treatment  is not only allowable
     under §262.34, but treatment  is consistent  with sound
     waste  management  (memo,  dated  12/15/87, from Marcia
     Williams to Robert Greaves).

Source:   Mike Petruska  (202) 475-8551
Research: Bob Adamson
3.   Disposal of Mixed Radioactive and Hazardous Waste

A generator of  a  mixed  radioactive  and  hazardous waste,
which  is  a  listed  hazardous  waste  with  a  pH below 2,
disposes of  it  on-site  in  a  land  disposal  unit.   The
disposal  began  in  early  1986  and ended in the summer of
1987.  The owner never submitted a Part  A or  Part B permit
application.    The  State  in which the facility is located
became  authorized  for  RCRA  in  late  1985,  but  is  not
authorized to enforce HSWA provisions, and is not authorized
to  regulate mixed waste.  However, the State has its own
                          -2-

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3.    Disposal of Mixed Radioactive and Hazardous Waste
     (Cont'd)

regulations regarding  mixed waste.   If  the owner wants to
close the land disposal unit,  will he be  required to submit
a  Part   B  permit   application  and  conduct  groundwater
monitoring?

     According to the Federal  Register of  July 3,  1986 (51
     FR  24504),  mixed  radioactive  and hazardous waste is
     subject to  RCRA  regulation.    In  a  state  which is
     authorized  to  implement  Subtitle  C,  the mixed waste
     will  not  be  subject  to  the  Subtitle  C authorized
     program until  the state  becomes authorized to regulate
     mixed waste; however, state  regulations enforced under
     state law would apply to  the mixed waste.  In addition,
     if the facility contained  a  RCRA-regulated  unit, and
     was applying for its permit, EPA could use RCRA Section
     3004(u)   authority   for    releases    of   hazardous
     constituents  from  solid  waste  management units (the
     mixed radioactive and hazardous waste would  be a solid
     waste, per Section 261.2(b).

     Once the State receives authorization to regulate mixed
     radioactive  and  hazardous  waste,  the  disposal unit
     would become  subject to  the State's authorized program
     regulations,  and  would   become  subject  to  the HSWA
     provisions (which  would  be  enforced by  EPA until the
     State   gained   authorization   to    implement   HSWA
     authorities).

     If  the  disposal  unit  was closed and was an inactive
     facility prior to the  date chosen  by the  State to be
     the  interim  status  "in existence" date, the disposal
     unit  might  not  be   subject  to   State  Subtitle  C
     regulation unless the waste was subsequently managed in
     a  manner that would  constitute treatment,  storage,  or
     disposal.    However,  if  State law does not otherwise
     prohibit it, the State could elect  not to grandfather
     any inactive  mixed waste units.  A State could do this
     because a State RCRA  program can  be broader  in scope
     than the  Federal program.   Thus, a State could choose
     to regulate inactive units in some manner.

     If the disposal unit  was still  an active  facility on
     the date  the State  selects as  its interim status "in
     existence" date, which can be no later than the date on
     which the State's authorization to regulate mixed waste
     became effective, the facility would need to submit a
                          -3-

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3.   Disposal of  Mixed Radioactive  and Hazardous Waste
     (Cont'd)

     Part  A  permit   application   within   the  timefrarae
     specified  in  the  State's  regulations  or statute to
     qualify for interim status.

     Depending  on  the  regulatory  dates  selected  by the
     State, closure  of the  disposal unit could occur while
     the facility was under  interim status.   State  law on
     closure,   post-closure    permits,   and   groundwater
     monitoring will control.

Source:   Betty Shackleford   (202) 382-2221
Research: Beckv Cuthbertson
4.  Federal Authority Over Authorized States

Does  the  Regional  Administrator  always  retain oversight
authority for  State permit  issuance or  may a State become
completely autonomous  if  it  has  final  approval  for all
phases of its RCRA program?

     Section 3006(c)(4) of HSWA provides that in the case of
     an authorized  State  program,  until  such  program is
     amended to reflect the amendments made by the Hazardous
     and Solid Waste Amendments  of  1984  and  such program
     amendments receive  interim or final authorization, the
     Administrator shall have the  authority in  such States
     to issue  or deny  permits or those portions of permits
     affected   by   the   requirements   and   prohibitions
     established by the Hazardous and Solid Waste Amendments
     of  1984.    The  Administrator  shall  coordinate with
     States the procedures for issuing such permits.

     Even if  a State  has final authorization of all phases
     for its RCRA program, however, the Administrator always
     retains  a   statutory  oversight  authority  for  such
     programs.    Section  3006(e)  of  RCRA  authorizes the
     Administrator to withdraw approval of any State program
     where, after public hearing, it is  determined that the
     State is not administering and enforcing its program in
     accordance  with  the  requirements  of  Section  3006.
     After  notifying   the  State,  the  Administrator  may
     withdraw  authorization   for  the   State  program  if
     corrective  action  measures  are  not  taken  within a
     reasonable time, not to  exceed 90  days.   Further, 40
     CFR Section 271.8(a) provides that any State seeking to
     administer a program shall submit a Memorandum of
                          -4-

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4.  Federal Authority Over Authorized States (Cont'd)

     Agreement (MOA)  executed by the State Director and the
     Regional Administrator.   Such  Memorandum of Agreement
     shall  not  contain  provisions  which  restrict  EPA's
     statutory oversight responsibility.   The Administrator
     may also  comment on permits and draft permits pursuant
     to 40 CFR Section 271.19 and Section 271.8  and Section
     3008(a)(3) permits the Administrator to revoke permits.
     Finally, Section 7003 permits the Administrator to take
     action   in   cases   of   imminent   and   substantial
     endangerment notwithstanding  other  provisions  of the
     Act,  including State authorization.

Source:   Marty Madison  (202) 382-2229
Research:  Bob Adamson
5 .    UST Applicability

A  company  owns  property  on  which a gasoline underground
storage tank (UST) is located.   A trucking  firm that often
provides service  to this  company is the owner and operator
of  the tank.   Under the  proposed regulations  in the April
17,  1987  Federal  Register  (52 FR 12662), is the property
owner responsible for complying  with any  of the provisions
for the underground storage tanks?

     The regulations  proposed for underground storage tanks
     generally apply to the owners and operators of USTs (40
     CFR 280.10).   Owner is defined as "any person who owns
     an UST system used  for storage,  use or  dispensing of
     regulated  substances"  (for  tanks  in use on or after
     November 8,  1984);  for  tanks  no  longer  in  use on
     November 8,  1984, owner  is defined as "any person who
     owned such  UST immediately  before the discontinuation
     of  its  use"  (40  CFR  280.12).   An operator is "any
     person in control of, or having responsibility for, the
     daily operation of the UST system" (40 CFR 280.12).  If
     the trucking firm described above is the sole owner and
     operator  (as  defined  in  280.12)  of the underground
     storage tank and the  property  owner  has  no property
     interest  in  or  operation  responsibilities connected
     with the UST, then the proposed regulations would apply
     only  to  the  trucking  firm  and  not to the property
     owner.  However, the proposed regulations  continue the
     "interim  prohibition,"  Section  280.11, which forbids
     the installation by "any person" of a bare steel UST
     not otherwise subject to the UST technical requirements
     (e.g.  tanks for which regulation is deferred).  Persons
     who are not owners or operators of an UST may
                          -5-

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   5.   UST Applicability (Cont'd)

        nevertheless  be  subject  to  the  interim prohibition
        under the proposed rules  as a  person who  installs or
        arranges for installation of an UST.

   Source:    Karen Reed     (202)  382-7925
   Research:  Ross Elliott
B.  CERCLA

   6.   Reportable Quantity Determination

   Hydrogen  chloride  gas  is  introduced  into  water to form
   hydrochloric acid.  Saturation  for this  reaction occurs at
   38  percent  (%).    Therefore,  any  hydrogen chloride present
   after the saturation point  is  reached,  does  not  go into
   solution and  will remain  in  the  gaseous state.  Can the RQ
   assigned to hydrochloric acid, a listed hazardous  substance,
   be  used for hydrogen chloride  gas?

        The RQ  for  anhydrous  hydrogen chloride is 5000 pounds
        and applies  to all forms  of hydrogen chloride.

        When determining a RQ for a  form of  hydrogen chloride
        that occurs   in a  solution, the  Clean Water Act (CWA)
        "mixture  rule"  will  be  used  if  the  percentage of
        hydrogen chloride in solution is known.

        For example:  To determine the RQ of a product solution
        of water and 35 percent (%) hydrochloric acid,  the CWA
        "mixture rule"  is applied as follows; divide the RQ of
        hydrochloric  acid,  5000  pounds,  by  the  percentage
        (expressed as  a decimal)  of the  hydrochloric acid in
        solution, 0.35.  The  product of  this equation  is the
        RQ, in pounds, for the previously described solution.

                  5000/0.35 = 14,286 pounds

        If the hazardous substance occurs as a constituent of a
        hazardous waste, the  same  rule  can  be  applied when
        determining   the  RQ  for  the hazardous waste.  If the
        percentage of the hazardous  substance in  the waste is
        not known, however, the RQ for the listed or  unlisted
        hazardous substance  constituent is  to be used.  When
        more than one  hazardous   substance  is  in  product or
        waste solution, always use the lowest applicable RQ for
        the solution.

   Source:    Ivette  Vega    (202) 475-7369
   Research:  George  Kleevic
                             -6-

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   7 .  CERCLA Notification

   CERCLA Section 103(d)(l) authorizes the EPA to promulgate
   rules and regulations  specifying,  with  respect  to the
   location,  title,  or  condition  of  a facility, and the
   identity, characteristics, quantity, origin, or condition
   of any  hazardous substances  contained or deposited in a
   facility, the records  which  shall  be  retained  by any
   person required  to notify  the EPA  under CERCLA Section
   103(c).   Section  103(d)(2)  specifies  the restrictions
   regarding  the  disposition  of the records identified in
   Section  103(d)(l)  and  penalties  for  violating  those
   restrictions.

   Has EPA  promulgated any  regulations under its authority
   in Section 103(d)(1)?

   Are  the  restrictions   and   penalties   under  Section
   103
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8.    Emergency Release Notification (Cont'd)

          Section 304(b)   notice is not required,  the facility
          owner  or  operator  must  still   provide  follow-up
          emergency   notification   under    Section   304(c).
          Section 304(c)  states that,  "As soon  as practicable
          after   a   release   which  requires  notice  under
          subsection (a),  such owner or operator shall  provide
          a written follow-up emergency notice... setting forth
          and   updating    the   information    required  under
          subsection    (b),     and    including    additional
          information...".      Notification    of   the   above-
          described release  is required under subsection (a),
          thus written follow-up emergency notice  is required.
          While the initial notification of  releases of CERCLA
          hazardous   substances   that   are   not  extremely
          hazardous  substances  and  do  not  have reportable
          quantities,   must  follow  different  the  format  of
          CERCLA  Section  103  notifications  until April  30,
          1988,  because   Section  304(c) requires  that  the
          follow-up emergency notice set forth the information
          required  under  Section  304(b).     Notification  of
          these releases   will also  be reported in the manner
          prescribed by Section 304(b).

     Source:    Kirsten Engel   (202) 382-7706
     Research:  Kim Jennings
     9.    Coverage  Under  Toxic  Chemical   Release  Reporting
          Requirements

     To  file  the toxic  chemical  release report for §313,  how
     would a compound that  falls into two reporting categories
     be  reported (i.e.  PbCr03)?

          A  compound  that  has  constituents   in  two   toxic
          categories would   have  to   be   included  under both
          categories when  submitting a toxic chemical  release
          reporting  form.   In the  example indicated,  the  total
          weight of  PbCr03  must  be included in  determining  the
          threshold  for both lead   and its compounds  and in
          determining  the   threshold for   chromium and  its
          compounds.  In reporting the releases  of lead,  only
          the  stoichemetric  weight   of   the lead released in
          PbCrOS  would  be  included.     Likewise,   only  the
          chromium  in   PbCr03  that   is   released   would be
          included in the §313 reporting  form.

     Source:    Sam Sasnett  (202)  382-3821
     Research:  Brian Littleton

                            -8-

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II.  ACTIVITIES - January 1988

 A.  RCRA/Superfund Hotline

   1.   The RCRA/Superfund Hotline and CEPP Hotline responded to
        13,566 questions and requests for documents in January.
        The breakdown is as follows:

                             RCRA   Superfund   UST    CEPP

Information Calls            5682     1248      723    1669  =   9,322
Call Document Requests        690      174      350     788  =   2,002
Written Document Requests     281                       292  =     573
Referrals                    1477                       192  =   1,669
                            8,130    1,422     1,073   2,941  -  13,566


   2.   On January  6, Gwenn  Gebhard, OUST briefed the RCRA/Superfund
        Hotline on the December 23,  1987 Supplemental Notice.

   3.   On January 14, Linda Cooper briefed the RCRA/Superfund Hotline
        on Federal Facilities.

   4.   On January 20, Dan Chadwick and Bob Hall,  OSW briefed the
        RCRA/Superfund Hotline on the Oil and Gas  Report to Congress.

   5.   On January  27, Denise Sines met with Phil Jalbert to discuss
        the Superfund Report to Congress.

   6.   On January 28,  Tom  Young,   OUST  briefed  the RCRA/Superfund
        Hotline on the Leak Detection Study.

   7.   The  RCRA/Superfund  Hotline  reviewed  the  "Hazardous  Waste
        Guidebook" for Karen Brown,  Small Business Ombudsman.

   8.   The Hotline continued to support Mike Petruska and  Emily Roth
        on the OSW project.

B.  CEPP Hotline

   9.   January  5,  12,  and  25,  members  of  the Title III Hotline
        attended the Preparedness Staff meetings.

  10.   On January 5, Robert Costa of the Title III Hotline attended a
        Workgroup meeting on the status of Title III activities.

  11.   On January  7, Sam  Sasnett of  the Office of Toxic Substances
        briefed the Title III Hotline on the development  of the final
        rule on toxic chemical release reporting (§313).
                                 -9-

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B.  CEPP Hotline (Cont'd)

 12.   On  Jannuary   1,   Robert  Costa  of  the  Title  III  Hotline
       participated in  a  meeting  with EPA  Public Affairs regarding
       the Ashland Oil spill in Pittsburgh, PA.

 13.   January  11-15,  Brian  Littleton  of  the  Title  III Hotline
       attended the §305 Inspection Training held in Bethesda.

 14.   On January 15,  Renee  Rico and  Dennis Leaf  of the  Office of
       Toxic  Substances  briefed  the  Title III Hotline on the §313
       petition process and the status of pending petitions.

 15.   On January 15 and 29, Robert  Costa of  the Title  III Hotline
       attended  the  Preparedness  staff  conference  call  with the
       FEMA/EPA Regional  Coordinators  on  the  status  of  Title III
       activities.

 16.   On January  19, Kim Jennings of the Title III Hotline attended
       the Title  III  workgroup  meeting on  the status  of Title III
       activities.

 17.   On January  20, Tony  Jover of  the Preparedness Staff briefed
       the Title III Hotline on the Title III  information management
       activities that were underway or planned.

 18.   January 20-21,  John Ferris of the Title III Hotline attended a
       training session estimating releases  of   toxic  chemicals for
       §313 given by Rutgers University in New Jersey.

 19.   On January  27, Robert  Costa of  the Title  III Hotline along
       with other members  of the Title III Outreach  Subcommittee met
       with representatives  of public  interest groups  on Title III
       public  outreach activities.
                               -10-

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III.  ANALYSES OF QUESTIONS - January 1988          Grand Total  10.625




SUMMARY OF CALLS BY GEOGRAPHIC DISTRIBUTION (EPA Regions):




1      5.1%      3	24.6%	 5     17.0%     7     3.6%     9     11.0%
2 10.0% 4 12.0% 6 9
INTERNATIONAL CALLS 0.3%
Manufacturers 5.0% State Agencies
Generators 14.0% Local Agencies
.0% 8 4.0% 10 3.2%
4.7% Univ. /Researchers 2.0%
1.6% Trade Associations 0.4%



Transporters 1.1% Used Oil Handlers 1.0% Insurance Co 0.2%
TSDF's 7.0% UST 0/0
EPA HQ 1.6% Consultants
EPA Regions 3.0% Attorneys
Federal Agencies 3.6% Laboratories
RCRA
General Information 443
3010 Notification 91
260.10 Definitions 84
260.22 Petitions/Delisting 32
261.2 Solid Waste Definition 158
261.3 Hazardous Waste Definition 291
261 C Characteristic HW 485
261 D Listed HW 433
261.4 Exclusions 150
261.5 Small Quantity Generators 132
261.6 Recycling Standards 88
261.7 Container Residues 44
262 Generator - General 177
inn innn to/mo SQ

Manifest Info 93
Accumulation 133
Recordkeeping & Reporting 126
International Shipments 23
263 Transporters 51
266 C Use Constituting Disposal 11
266 D HW Burned for Energy Recovery 62
266 E Used Oil Burned for
Energy Recovery 85
266 F Precious Metal Reclamation 22
266 G Spent Lead-Acid Battery
Reclamation 16
Subtitle D 162
Used Oil - General 101
Household Hazardous Waste 27
Dioxins 23
Mixed Radioactive Waste 23
Asbestos/PCBs/Radon 117
Infectious Waste 35
Liability/Enforcement 85
Corrective Action 77
Waste Minimization 98
Minimum Technology 24
5.0% Environmental Groups 0.5%
32.7% Press 0.4%
8.3% Citizens 4.2%
2.0% Other 1.5%
264/265 TSDF
A - Scope/Applicability
B - General Facility Standards
C - Preparedness/Prevention
D - Contingency Plans
E - Manif est/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 - General
Solvent & Dioxins
California List Wastes
Scheduled Thirds
269 - Air Emission Standards
270 - 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 Training
Test Methods/HW Technologies
RCRA Document Requests
SUBTOTAL 6,




12:
3?
K
1?
2(
9:
12:
s:
4(
20(
5(
(
K
3(
2<
5(
1


2!
8'
8"
6-
2:
i:
4'
21
2(
K
3'
6(

2-
2:
9:
69(
37:
                                      -11-

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UNDERGROUND STORAGE TANKS
     CERCLA
General
280.10 Applicability
280.11 Interim Prohibition
280.12 Definitions - General
UST
Reeulated Substance
280 B New UST Systems - General
280.20 Performance Standards
280.21 Upgrading
280.22 Notification
280 C General Operating
Requirements
280 D Release Detection
280 E Release Reporting and
Investigation
280 F Corrective Action -
Petroleum
280 G Corrective Action -
Hazardous Substances
280 H Out-of-Service/Closure
280 I Financial Responsibility
281 State UST Programs
Liability
Enforcement
LUST Trust Fund
Other Provision
UST Document Requests
UST SUBTOTAL 1.
243
77
41
27
42
35
8
16
11
32
8
38
30
20
8
35
29
15
7
1
8
9
350
073
Referrals
s -
EPA - HQ
- Other Hotlines
- Regions
State
GPO/NTIS/PIC
ORD/Dockets
Other

237
302
105
187
544
102
1,477
SUBTOTAL
Written Request Responses:
                                             General
                                             SARA General
                                             Access & Information Gathering_
                                             Allocations from Fund/
                                               Fund Balancing/Grants	
                                             CERCLIS/103 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 Substances/RQs	
                                             HRS
                                             Liability/PRPs	
                                             Mandatory Schedules	
                                             Natural Resource Damages
                                             NBARs	'_
                                             NCP	
                                             NPL
                                                    Participation
 Off-Site Policy
 On-Site Policy_^
 PA/SI	
 Public
Radon	
 RD/RA	
 Remedial^
 Removal	
 RI/FS	
 RODs/Clean-Up Costs	
 Settlements	
 SITE Program	
 State Participation	
 Taxes	
 Title III/Right-To-Know_
 Other Provisions
 CERCLA
 CERCLA
Document
SUBTOTAL
                                                             Requests_
Hotline Responses
Referred to EPA Program Offices
Referred to other Federal Agencies
Referred externally (states, organization, etc)
Response Form Sent
21

45

Response Form Sent/FOIA
Form Letter Sent/Need more info
Requests filled - RCRA
      215
                - CERCLA
                - UST
SUBTOTAL
      281
TOTAL CALLS, DOCUMENT REQUESTS AND REFERRALS   10,625
                                      -12-

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Total Calls
2649
        CEPP Hotline
Daily/Monthly Summary Report
     For  January 1988

            Written  Responses
292
Distribution of Calls by EPA Regions:
1 7% 4 10% 7
2 12% 5 23% 8
3 21% 6 7% 9
Callers :
Manufacturers 44%
Distributors 2%
Handlers 8%
Attorneys 5%
Consultants/Engineers 11%
Laboratories 1%
Trade Associations 1%
Public Interest Groups 2%
Uni versities/Academia 2%
Insurance Companies 1%
Hospitals 1%
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 45
Reportable Quantities 45
RQ/s vs. TPQ's 8
3% 10 2%
2% International:
7% Unknown:
State Agencies
Fire Depts.
EPA
Local Officials
Farmers
Federal Agencies
Media/Press
Union/Labor
Citizens
Other
281
150
77
77
71
23
4
29
212
78
CERCLA vs. Sec. 304
Transportation
Exemptions
080
2%
4%
2%
5%
5%
.40
1%
2%
.20
2%
2%
38
19
9
                                    -13-

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                CEPP Hotline Daily/Monthly Summary Report (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
Referrals ;



OTS (Section 313)



OSHA
                      27
Preparedness Staff
                                 384
                                 181
                                 548
                                 241
                               389
                                42
                                 0
                                46
                                25
                                69
                                18
                               109
                                40
Document Requests        	788



# of Documents Requested 	1978
        Haz. Categories   115




        Mixtures	83




        Exemptions   	154
RCRA/Superfund Hotline	56



Regional EPA           	7_



Other                      59
                                   -14-

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                        RCRA/Superfund Hotline
National Toll Free #800-424-9346,  Washington,  D.C.  Metro #202-382-3112


IV.     PUBLICATIONS - January 1988

   RCRA

   The following documents have been sent to the National Technical
   Information Service (NTIS).  NTIS is located in  Springfield,  VA.
   Their phone number is (703) 487-4860.

        "Report to Congress on Management of Wastes from the
        Exploration, Development and Production of  Crude Oil,  Natural
        Gas and Geothermal Energy," (Vols. 1-4):

        (Vol. 1 - PB88-146220, $32.95
        (Vol. 2 - PB88-146238, $19.95
        (Vol. 3 - PB88-146246, $32.95
        (Vol. 4 - PB88-146253, $14.15
        (Complete set: PB88-146212, $86.00;  Microfiche,  complete set
        $6.95)

   "Hazardous Waste Generator Survey" is available  by calling  the HELP
   LINE (1-800-635-8850)  or Jim Craig at (202)  382-3410.

   "The Impact of Lead Industry Economics and Hazardous  Waste
   Regulations on Lead Acid Battery Recycling  Revision and Update,"
   September 1987, is available by contacting  Louisa Worthington at
   Putnam,  Hayes  and Bartlett, 124 Mt. Auburn St., Cambridge, MA
   02138,  (617) 492-6900.  The cost is $25.00

   "Appendices to the Report to Congress on  the Discharge of Hazardous
   Waste to POTWs" are available by calling  Tom O'Farrell's office at
   (202) 382-7137.

   The "RCRA Statute" is available by calling  the RCRA/Superfund
   Hotline.

   "List of Federal Register Notices/Rules of  Activities to Implement
   RCRA" is available by calling Martha Girard at (202)  523-5227.

   "Revised Enforcement Response Policy," OWPE Directive Number
   9900-.0-1A,  is available by calling the RCRA/Superfund Hotline.


   CERCLA

   The "SCAP FY88 Information Letter" is available  by calling  the
   RCRA/Superfund Hotline.

   The "Environmental Laws" (GPO/052-070-06259-2) is available by
   calling  the  Government Printing Office at (202)  783-3238.  The cost
   of  the document is $19.00.
                              -15-

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                        RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3112
V.  FEDERAL REGISTER NOTICES - January 1988

Former Notices with Open Comment Period
December 8, 1988; 52 FR 46538
(DOJ proposed consent decree)
December 8, 1988; 52 FR 46539
(DOJ proposed consent decree)
December 23, 1987; 52 FR 48637
(supplemental notice to
proposed rules -USTs; request
for comments)
January Federal Register Notices

January 4, 1988; 53 FR 31
(proposed exclusion)
Notice of lodging of a proposed
consent decree pursuant to CERCLA,
with the U.S. District Court for
the Eastern District of
Pennsylvania, requiring Air
Products and Chemicals, Inc., et.
al., to clean up and monitor the
McAdoo Associates Site in
Schuykill County, PA.  DOJ
accepted comments for 30 days
after this notice.

Notice of lodging of a proposed
consent decree pursuant to RCRA,
with the U.S. District Court for
the Central District of
California, requiring Quemetco,
Inc. and RSR Corporation to comply
with RCRA groundwater monitoring,
financial responsibility, closure
and battery storage requirements,
pay a $60,000 civil penalty, and
take corrective action to address
releases of hazardous wastes.  DOJ
accepted comments for 30 days
after this notice.

Notice of a request for comments
on six issues not raised
previously in the April 17, 1987
proposed rule for USTs.  Comments
were accepted until January 22,
1988.
The notice proposes to exclude
from the lists of hazardous
wastes (§261.31 and §261.32),
solid wastes generated at the EPA
Mobile incinerator system in
McDowell, Missouri from burning
2,4,5-T and Silvex pesticide
products.  Comments will be
accepted until Feb. 3, 1988.
                              -16-

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                        RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3112
January Federal Register Notices (Continued)
January
(notice
report )
        4, 1988; 52 FR 81
        of availability of
January 5, 1988; 53 FR 126
(Illinois-approval of
revisions to State program)
January 5, 1988; 53 FR 127
(Florida State program
revisions; extension of
comment period)

January 5, 1988; 53 FR 128
(Indiana-final determination
of State program revisions)
January 6, 1988; 53 FR 244
(North Carolina State program
withdrawal proceedings
correction)
January 8, 1988; 53 FR 519
(amendments to definition
of solid waste)
Notice of availability of Report
to Congress on crude oil, natural
gas, and geothermal energy,
exploration, development and
production waste.  Announcement of
public hearings.

Approval of revisions  of the
Illinois Hazardous Waste Program.
Final authorization for the
program revisions become effective
March 5, 1988.  Comments will be
accepted until February 4, 1988.

Notice extending the comment
period on Florida's hazardous
waste program.  Comments will be
accepted until February 1, 1988.

Final agency determination to
grant authorization for Indianna
hazardous waste program
modifications.  Authorization for
the program revisions, as
discussed in the September 29,
1987 FR became effective
January 19, 1988.

Notice correcting the date and
location of the North Carolina
State hazardous waste program
withdrawal proceeding hearing.
The hearing will be held on
February 23-25, 1988, at the
Velvet Cloak Inn, 1505
Hillsborough St., Raleigh, NC
27605.

Notice which provides the Agency's
interpretation of the decision of
the District of Columbia Circuit
Court of Appeals on the Agency's
authority to regulate certain
hazardous secondary materials
(American Mining Congress vs.
EPA); and proposed amendments to
present regulations required by
the courts decision.  Comments on
the proposal will be received
until Feb. 22, 1988.
                             -17-

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                        RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3112
January Federal Register Notices (Continued)
January 12, 1988; 53 FR 754
(Agency information collection
activities under OMB review)

January 13, 1988; 53 FR 850
(proposed rule for reporting
hazardous substance activity
when transferring Federal real
property)
January 14, 1988; 53 FR 911
(proposed rule, re-opening of
comment period)
January 14, 1988; 53 FR 959
(lodging of consent decree
under CERCLA)
January 19, 1988; 53 FR 1358
(Tennessee schedule of
compliance for modification
hazardous waste program)
January 21, 1988;  53 FR 1641
(standards for remedial actions
at inactive uranium processing
sites)
Survey of municipal waste
combustors.
The rule proposes to require a
notice to be included in each
contract transferring Federal real
property.  The proposed rule
fulfills the statutory
requirements under §120(h) of
CERCLA as amended by SARA.
Comments on the proposal must be
received by Feb. 12, 1988.

The notice re-opens the comment
period on a proposed rule under
TSCA §4 that requires testing on
73 chemicals which are App. VIII
hazardous constituents of Part 261
of 40 CFR.  The comment period is
re-opened until Feb. 16, 1988.

The proposed consent decree
provides that Aquair will pay the
U.S. $5000 in a post judgment
settlement for illegal disposal of
hazardous substances at the Bluff
Road Site in Columbia, South
Carolina.

Notice which details a schedule of
compliance for modification of
Tennessee's hazardous waste
program.  Six provisions are
proposed to be included, for which
the State plans to submit an
application to EPA by Dec. 31,
1988.

Proposed rule extended hearing
record comment period from
Jan. 8, 1988 to Jan. 29, 1988.
                              -18-

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                        RCRA/Superfund Hotline
National Toll Free #800-424-9346,  Washington,  D.C. Metro #202-382-3112
January Federal Register Notices (Continued)
January 22, 1988; 53 FR 1834
(notice of information
collection activities under
OMB review)
January 22, 1988;  53 FR 1836
(notice of availability of
review)
The notice requests review by each
Governor of summaries of State
mining waste regulations to be
used in the formulation of
regulations under Subtitle D of
RCRA.

The notice announces the
availability of a new financial
assistance program: The RCRA
Integrated Training and Technical
Assistance (RITTA) iniative.  The
funds will provide support at the
State level for personnel training
and technical assistance.
                                 -19-

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Martha Anderson, DORM
Jim Barrett, GRC
Frank Biros, WH-527
George Bonina, WH-563
Susan Bromm, WH-563
Karen Brown, PM-220
John Bosky, EPA- Kansas City
Diane Buxbaum, Region 2
Fred Chanania, LE-132S
Richard Clarizio, Region 5
Kathy Collier, RTF, NC
Peter Cook, WH-527
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-562
Penny Hansen,  WH-562
Bill Hanson, WH-548E
Betti Harris,  EPA, Region 7
Cheryl Hawkins, WH-548
Irene Horner,  WH-595
Barbara Hostage, WH-548B
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
Tom Kennedy, ( ASTSWMO )
Robert Knox, WH-562
Jack Kooyomjian, 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
Carl Reeverts, WH-550E
John Riley, WH-548B
Mike Riley, PM-214F
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
Jeffery Denit, 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
                              -20-

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