UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             WASHINGTON, D.C. 20460       ,  .
                                MAR 301988     530R88102
                                                              OFFICE OF
                                                      SOLID WASTE AND EMERGENCY RESPOIMS
MEMORANDUM
SUBJECT:  Final Monthly Report - RCRA/Superfund Industry
          Assistance Hotline and CEPP Hotline Report for
          February 1988

FROM:     Thea McManus,       V     "x
          Office of Solid Waste (WH-562)            ,

          Hubert Watters, Office of Emergency and
            Remedial Response (WH-548B)

TO:       See List of Addressees


   This report is prepared and submitted for EPA Contract No.
68-01-7371.

I.  SIGNIFICANT QUESTIONS AND RESOLVED ISSUES - February 1988

 .A.  RCRA Program

   1.   Used Oil Marketer

        Corporation  A  owns  both  Corporation  B and Corporation C.
        Corporation B generates an  off-specification used  oil.  The
        State in  which Corporation B generates the used oil does not
        allow burning of the oil.  Therefore, Corporation B ships the
        used oil to a sister corporation, Corporation C.  Corporation
        C burns the used-oil for energy recovery.  Is Corporation B a
        marketer as specified in 40 CFR 266.43(a)?

             A  marketer  as  defined  in  Section  266.43(a)  is "any
             person who  markets  used  oil  fuel...marketers  include
             generators  who  market  used  oil  fuel  directly  to a
             burner...."  Even though  no funds  are exchanged during
             the transaction, Corporation B is marketing the used oil
             fuel to Corporation C.   There  are no  exclusions which
             state  that  used  oil  given to a sister corporation is
             excluded from regulation, or that marketing  requires an
             exchange of funds.  Thus, Corporation B must comply with
             the  regulations  which  pertain  to  marketers (Section
             266.43).  Corporation C is also a burner.

        Source:   Sarah Carney (202) 382-7932
        Research: Craig Campbell

-------
2.    Corrective Action and Permits

     If  a  release  of  hazardous waste or  hazardous  constituents
     from a solid waste management unit (SWMU)  is  identified  after
     the  issuance  of  a  permit,  can  EPA reopen the permit  and
     modify  it  to   include   additional   investigation and/or
     corrective measures?  Does the "permit  as  a shield" provision
     in 40 CFR 270.4(a)  protect  the  facility from   such action
     until the permit comes up for reissue?

          Permits issued  prior to  November 8, 1984,  the date of
          enactment of the Hazardous  and Solid Waste Amendments,
          cannot  be  reopened  to  establish   a   Section  3004(u)
          corrective action  program  until  reissuance.   Permits
          issued after November 8, 1984, address releases from  all
          solid waste management units  (SWMUs) at the facility.
          During  the  permitting  process   EPA conducts  a  RCRA
          Facility Assessment (RFA) to determine whether there  has
          been  a   release  from  any  SWMU  located   within  the
          facility's boundaries.  The RFA also determines whether
          any  further  investigations  or corrective  measures  are
          necessary.    EPA  will   then develop    a   custom-made
          corrective  action  program  which will be  incorporated
          into the  permit.   Most permits   currently  being issued
          contain a  reopener clause for newly  identified releases
          after permit issuance.   Absent such  a  reopener clause,
          if  the   Director  receives  information about a  new
          release, then  the authority  under Section  270.41(a)(2)
          could  be  employed.    Section 270.41(a)(2)  states that
          when the Director has received new information that "was
          not available at the time of permit issuance (other than
          revised   regulations    [see   Section    270.41(a)(3)],
          guidance, or  test methods) and would have justified  the
          application of different permit conditions  at  the time
          of  issuance"    the  permit  may  be  modified during  its
          term.

          The "permit as a shield" provision in Section 270.4 does
          not  provide  a  shield  when  new information  such as
          mentioned above is obtained after  permit  issuance.  The
          "permit as a shield" provision applies to standards that
          are  established  in   the   permit   which    cannot   be
          arbitrarily changed  by the  Director during the term of
          the permit.  Section 270.41(a)(3)  allows a permit  to be
          modified  during  its  term  due to amended  standards or
          regulations at the request of the  permittee (see  52 FR
          45793).  Section 270.41(a)(3)  also allows the Director
                              -2-

-------
2.   Corrective Action and Permits (Cont'd)

     to "modify  the permit  when the standards and regulations on
     which the permit was  based have  been changed  by statute or
     amended standards  or regulations"  such as the land disposal
     restrictions in 40 CFR Part 268.

     Source:    Matt Hale     (202) 382-4740
                Dave Pagan    (202) 382-4497
     Research:  Deborah McKie
3.   Clean Closure of Interim Status Surface Impoundment and Waste
     Pile

     A waste  pile and  surface impoundment,  both interim status,
     were clean closed in 1985  per  Section  265.228  and Section
     265.258.  Closure was certified as per Section 265.115.  Will
     the waste pile and  surface impoundment  site require ground-
     water monitoring?

          According to the December 1, 1987, Codification Rule (52
          FR 45788), owners/operators of  surface impoundments and
          waste piles  that received waste after July 26, 1982, or
          certified closure  after  January  26,  1983,  must have
          post-closure  permits  unless  they demonstrate that the
          "clean  closure"  met   Part   264   standards  (Section
          270.l(c)).

          Sections 270.1(c)(5)  and (6) outline the procedures for
          determining if the closure met Part 264 standards (i.e.,
          equivalency  determination).    If equivalency is shown,
          then the surface impoundment and waste pile will  not be
          required  to  have  a  post-closure  permit.  If, on the
          other hand, the Agency decides equivalency  was not met,
          a  post  closure  permit  will  be  required.   The post
          closure permit would have to address applicable Part 264
          Ground-water  monitoring,  unsaturated  zone  monitoring
          corrective action and post-closure care requirements.

          These requirements  also  apply  to  landfills  and land
          treatment units.

     Source:   Sharon Frey    (202) 475-6725
     Research: Cheryl McNabb


4.    Identification Numbers

     Corporation A  owns a  large site.   Corporation  B, a wholly
     owned subsidiary of Corporation  A, is  a permitted treatment
     facility on the site.  Corporation B has an identification

                              -3-

-------
4.   Identification Numbers (Cont'd)

     number associated  with this  site activity.   Corporation C,
     another wholly owned subsidiary  of  Corporation  A,  is also
     located on  this site and will be generating hazardous waste.
     Should Corporation C use  the identification  number which is
     associated with  the site,  although a different Corporation,
     or is Corporation C required to obtain its own identification
     number?

          Section  262.12  requires  a  generator  to  have an EPA
          identification   number    before   treating,   storing,
          disposing    of,    transporting,    or   offering   for
          transportation,  hazardous  waste.    The  definition of
          generator, in Section 260.10 is keyed to both person and
          site:  "any person by site whose act or process produces
          hazardous  waste...".    The  definition  of  person  in
          Section 260.10 is  "an  individual,   trust,  firm, joint
          stock company,  Federal agency, corporation (including a
          government   corporation),   partnership,   association,
          State,  municipality,  commission, political subdivision
          of a State, or any interstate body."   The definition of
          individual generation  site in  40 CFR Section 260.10 is
          "the  contiguous  site  at  or  on  which  one  or  more
          hazardous   wastes   are   generated."    An  individual
          generation site, such as  a  large  manufacturing plant,
          may have  one or  more sources of hazardous waste but is
          considered a single or  individual  generation  site, if
          the site or property is contiguous.

          In this  situation Corporation  B and  Corporation C are
          two distinct entities (i.e.,  persons).   They must each
          apply f°r  a separate  EPA identification  number.  Even
          though   identification   numbers   are   usually  site-
          specific,  where   different  people  conduct  different
          regulated activities on a site, a person conducting each
          regulated  activity  must  obtain  an EPA identification
          number.  This does not preclude  an EPA  Regional office
          or State from issuing the same number to two persons.

     Source:   Diane Regas    (202) 382-7706
     Research: Craig Campbell


5.    Land Disposal Restrictions

     The November  7, 1986 Federal Register (51 FR 40572) codified
     the land disposal restrictions for solvent  and dioxin wastes
     identified  in  40  CFR  261.31.    At that time all of these
     solvent and dioxin wastes were restricted from surface land
                              -4-

-------
5.    Land Disposal Restrictions (Cont'd)

     disposal  unless they met the appropriate treatment  standards
     set forth in Section 268.41.   There was  a national  variance
     from  the  effective  date    (November  8,  1986)   for these
     requirements  which  was  given  to   generators   of  100-1000
     kilograms  of  hazardous  waste  per  month  (small  quantity
     generators).  This variance was granted  because EPA  believed
     there was not enough capacity to handle this waste  (see 51  FR
     40615).   Small quantity generators (SQGs)  would  be  subject  to
     the  treatment  standards  on  November  8,  1988 (see 40 CFR
     Section  268.30(a)  &  (b)).    The August  27,   1987,  Federal
     Register   (52  FR   32446)  proposed  to codify the solvent and
     dioxin land  disposal restrictions  for Underground Injection
     Control   (UIC)  Class  I  wells which are regulated under the
     Safe Drinking Water Act (SDWA)  and by a  RCRA permit   by rule
     (see 40   CFR 268.30(a)   &(b)).   The  August 27, 1987,  proposal
     does not  contain a SQG national variance.    Does the  variance
     granted to  SQG solvent  and dioxin   waste also   apply to the
     same wastes injected into Class I wells after August  8, 1988?

          No.     The  November  7,  1986,  SQG  national  variance
          granting  an   extension  to  the  effective  date to the
          solvent and dioxin restrictions  applies only   to wastes
          which will  be placed in land units other than UIC Class
          I wells.  The August 27, 1987,  proposal  did not address
          a national variance for SQG waste specifically.   It does
          however propose to grant  an extension  of  the effective
          date for solvent wastes which are solvent-water  mixtures
          or solvent-containing  sludges   containing   less  than 1
          percent (1%)   total F001-F005  solvent constituents (see
          40 CFR 148.10(a)).  Therefore,  small   quantity generator
          solvent  wastes   must  meet the  applicable   treatment
          standards prior to injection into a Class I well unless
          they contain   less than  one percent (1%) total  solvents
          after generation.   This will result in a three (3) month
          "lag time" when SQGs may place  their untreated  (greater
          than one  percent)  solvent  wastes  in  all  land units
          except UIC Class I wells.

          EPA  did  not  propose  a special SQG variance granting  an
          extension to  the effective date of  the DIG restrictions
          because  it  is  believed  there  are currently  few SQGs
          disposing of  their wastes by injection who  will  not also
          be eligible for the one percent (1%)  total  solvent
          variance.  It is believed there is adequate treatment
          capacity for   all  SQGs and other generators who  generate
          solvent wastes above one percent (1%).

     Source:    John Atcheson  (202)  382-5508
     Research:  Deborah  McKie

                              -5-

-------
6.    Blending of Hazardous Waste Fuel Burned in Cement Kilns

     A notice in the September 15,   1987,  Federal   Register (52 FR
     34779)  clarifies the "big city cement kiln" restriction under
     40 CFR  Section  266.31(c).    The  restriction  prohibits the
     burning  of  hazardous  waste   fuels   in cement kilns located
     within  the boundaries of a  city  with  a  population greater
     than  500,000  unless  the  kilns comply with the regulations
     applicable to hazardous waste  incinerators.   The regul  ions
     applicable to  hazardous waste incinerators include Suh^jrt O
     of  Parts  264  and  265,  permitting  under   Part  270,   and
     notification under RCRA Section 3010.

     Subpart O  applies to  units that burn wastes for the purpose
     of destruction rather than energy recovery,  so that blending
     or mixing  of hazardous  waste prior  to incineration would be
     considered treatment rather than a recycling   activity (i.e.,
     producing a fuel).

     Therefore,  if  a  marketer blends  hazardous waste fuels in
     tanks prior  to  sending  it  to  a  "big  city  cement kiln"
     (subject to  incinerator regulations) to be burned for energy
     recovery, is  the  blending considered  to  be  treatment of
     hazardous waste, or could it be a recycling operation?

          A  tank  in which  a marketer blends hazardous waste fuel
          is subject to 40 CFR Parts 264 and  265, and permitting,
          regardless  of  the  type  of unit in which the fuel is
          subsequently burned.  According  to preamble  language in
          the April  13, 1987, Federal Register (52 FR 11819), EPA
          believes that fuel blending  tanks  are   subject  to the
          same  standards  as  other  hazardous waste fuel storage
          devices (52 FR 11820). In  addition, nothing explicitly
          excludes  a  marketer's  hazardous  waste  fuel blending
          tanks  from  regulation.      Therefore,    it   makes  no
          difference whether a marketer sends hazardous waste fuel
          to a boiler or  industrial furnace  subject to  Part 266
          Subpart  D,  or  to  a unit  subject to the incinerator
          standards.  The marketers at least  have to  comply with
          the  permit  and  facility  standards  for storage units
          under Parts 270, 264 and  265.

     Source:    Bob Holloway   (202) 382-7917
     Research: Ross Elliott
                              -6-

-------
B. CEPP

   7.    Toxic Chemical Release Reporting;   Exemptions

        Are castings,  which contain nickel,  exempt  from reporting on
        the Toxic Chemical Release Reporting Form under Section 313?

             The final  rule for Section 313 (53 FR 4528)  contains an
             exemption for toxic chemicals  present in  articles.   An
             article is  defined as  "a manufactured item:   (i) which
             is  formed  to  a   specific   shape   or  design  during
             manufacturing;   (ii)   which   has  end  use  functions
             dependent in whole or in part  upon its  shape or design
             during end use; and (iii)  which does not release a toxic
             chemical  under normal conditions of processing or use of
             that item at the facility"  (emphasis added).   An item
             will not   qualify as an article if there is a release of
             a toxic chemical from  the normal  use or  processing of
             that item.   If under normal  conditions of processing or
             use, the  metal casting is ground  or cut  in a  way that
             would release  nickel, a listed toxic chemical,  it would
             not  qualify  for  the  article  exemption.   Therefore,
             releases   would  have  to  be  reported if the amount of
             nickel processed  or  used  in  this  way,  exceeded the
             appropriate  reporting  threshold.    In  addition,  the
             exemption for toxic chemicals  in articles  applies only
             to the processing or  use of  the article.   The person
             producing the article would be required  to report toxic
             chemicals manufactured,  processed, or otherwise used to
             produce the article.

        Source:    Sam Sasnett   (202)  382-3821
        Research:  Kim Jennings


   8.    Emergency and   Hazardous  Chemical  Inventory;   Confidential
        Location Information

        When submitting  a Tier  II form under Section 312, a covered
        facility  can   claim   the   required   location  information
        confidential.       How   is   this  confidential  information
        protected?  Are there any  penalties  under  Title  III  if a
        State or  local official, who receives this information, fail
        to protect its confidentiality?

             While the location information on the  Tier II  form can
             be claimed  confidential under Title III, Title III does
             not provide  a confidentiality  protection procedure for
             this  information.       Since  claims of confidentiality
             regarding the location of chemicals in facilities are


                                 -7-

-------
8.    Emergency and  Hazardous  Chemical  Inventory;    Confidential
     Location Information (Cont'd)

          not covered  by Title  III trade secrecy protection,  the
          duty to protect this  information as  confidential rests
          with State and local officials.   As the Agency stated in
          its October 15, 1987 rule, "The  confidential location in
          information should  not be  sent to EPA, but only to  the
          requesting  entity.    This  information  will  be kept
          confidential by  that entity  under Section 312(d)(2)(F)
          which refers to  Section  324 of  Title  III.   Section
          324(a)  states  that upon  request by a facility owner or
          operator subject to the requirements of Section 312,  the
          State emergency  response commission and the appropriate
          local emergency planning  committee  must  withhold from
          disclosure  the   location  of   any  specific  chemical
          required by Section 312(d)(2) to be contained in  a Tier
          II  inventory form."  52 FR 38312, 38317.
          Interested persons  should contact their State and local
          government's attorneys office for  information regarding
          procedures   for    protecting   confidential   location
          information.

          Since  protection  of  Tier   II  confidential  location
          information is  not covered  under Title  III, the State
          itself  does not provide  penalties  for  the  failure to
          protect  such  information.   Penalties may, however, be
          provided under State and local law.

     Source:     Kathy Brody   (202)  475-8353
     Research:   Robert Costa
                              -8-

-------
II.   ACTIVITIES - February 1988

   1.   The RCRA/Superfund  Hotline  and  CEPP  Hotline  responded to
        17,603 questions and requests for documents in February.  The
        breakdown is as follows:

                            RCRA    Superfund   UST    CEPP

Information Calls          6,674      1,575     875   2,634  = 11,758
Call Document Requests     1,246        317     391   1,858  =  3,812
Written Document Requests    174                         82  =    256
Referrals                  l»_59p      	  	     187  -  1/777
                           9,684      1,892   1,266   4,761  = 17,603


A.  RCRA/Superfund Hotline Activities

   2.   On February 1 and 25, Denise  Sines, Hotline  Project Director
        met  with  Hubert  Watters,  OERR to discuss related Superfund
        issues.

   3.   On February 3, Denise Sines, Hotline Project Director met with
        Bill  Foskett,  OUST  to  discuss the 7-Point Justification in
        support of the Reg-in-a-Box program.

   4.   On February 4, Don  Shosky, Region  VIII, On-Scene Coordinator
        briefed  the  RCRA/Superfund  Hotline  on  OSC  activities and
        authorities.

   5.   On February 12, Denise Sines, Hotline Project Director and
        Laurie Huber of the RCRA/Superfund Hotline met with Jay Evans,
        ICF, to discuss the development of Summary Document  UST Final
        Rule in support of the ODST program.

   6.   On   February   17,   Stephanie   Bergman,  OUST  briefed  the
        RCRA/Superfund Hotline  to  discuss  "Financial Responsibility
        for Hazardous Substance USTs".

   7.   On  February  17,  the  RCRA/Superfund Hotline viewed the "For
        Your Family's Sake" videotape.

   8.   On February 23, Laurie Huber of the RCRA/Superfund Hotline met
        with Dem  Cowles of  the D.S.  Conference of Mayors to discuss
        the development of quick  reference  for  local  officials for
        managing USTs in support of the OUST program.

   9.   On February  26, Jim  Craig and  Mike Burns of OSW briefed the
        Hotline  on   Biennial   Reporting   and   Waste  Minimization
        Reporting.


                                 -9-

-------
B.   Emergency Planning and Community Right-to-Know Hotline Activities


   10.  On  February  2-3,  the  Title  III Hotline staff attended the
        meeting with Regional PS/OTS/Outreach personnel to discuss the
        status of Title III activities.

   11.  On February  9, Minda  Sarimento and Robert Costa of the Title
        III Hotline, attended the TRI Committee meeting on  the status
        of Section 313 activities.

   12.  On February  16, Robert Costaof  the Title III Hotline attended
        the Title  III Workgroup  meeting on  the status  of Title III
        activities.

   13.  On February 17, Cathy Bishop of  the Preparedness Staff briefed
        the Title III Hotline  on EPA's   Draft Indian  Policy on Title
        III.

   14.  On  February  23,  Brian  Littleton  of  the Title III Hotline
        attended the TRI Committee  meeting on  the status  of Section
        313 activities.

   15.  On  February  23,  the  Title  III  Hotline staff attended the
        Preparedness Staff meeting.

   16.  On February 25, John Ferris  of the Title  III Hotline attended
        the  National  Response  Team  (NRT)  Meeting on the status of
        Federal Emergency Preparedness and training activities.

   17.  On February 26, Minda Sarimento  and Robert Costa  of the Title
        III  Hotline  attended  the  Preparedness Staff Conference Call
        with the FEMA/EPA Regional  Preparedness  Coordinators  on the
        status of Title III activities.
                                -10-

-------
                                                      Grand Total: 12,842
 III.  ANALYSES OF QUESTIONS

 SUMMARY OF CALLS BY GEOGRAPHIC DISTRIBUTION  (EPA Regions):

 1     5.6	 3	24.0	 5     17.1	 7     3.4

                                 6
                                                               10.8
9.6
  INTERNATIONAL CALLS
12.6
9.2
8
4.1
10
3.1
                      0.2
Manufacturers
Generators
Transporters
TSDF's
EPA HQ
EPA Reqions
Federal Agencies
5.3
16.5
1.2
7.4
1.1
2.3
2.6
State Agencies
Local Agencies
Used Oil Handlers
UST O/O
Consultants
Attorneys
Laboratories
4.5
1.6
0.8
4.3
31.1
8.0
1.5
                                     RCRA
Univ . /Researchers
Trade Associations
Insurance Co
Environmental Groups
Press
Citizens
Other
2.2
0.4
0.4
0.4
0.6
5.7
1.2
General Information	
3010 Notification	
260.10 Definitions	
260.22 Petitions/Delisting	
261.2  Solid Waste Definition
261.3
261 C
261 D
261.4
261.5
261.6
261.7
262
                              525  264/265 TSDF
                              108
                               40
                              253
 Hazardous Waste Definition   385
 Characteristic HW	570
 Listed HW	517
 Exclusions	170
 Small  Quantity Generators	110
 Recycling Standards	119
 Container Residues	62
 Generator - General	196
 100-1000 kg/mo	77_
 Manifest Info	97
 Accumulation                 157
263
266 C
266 D
266 E

266 F
266 G
 Recordkeeping &  Reporting	171
 International Shipments	25
 Transporters	58
 Use Constituting Disposal	11
 HW Burned for Energy Recovery 99
 Used Oil  Burned for
   Energy  Recovery_            108
 Precious Metal  Reclamation	20
 Spent  Lead-Acid Battery
    Reclamation                 24
Subtitle D
                              127
Used Oil - General	
Household Hazardous Waste_
Dioxins
                               54
                               36
Mixed Radioactive Waste
Asbestos/PCBs/Radon	
Infectious Waste
                               29
                              133
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
- Scope /Applicability
- General Facility Standards
- Preparedness/Prevention
- Contingency Plans
- Manif est/Recordkeeping/Reporting
- Ground Water Monitoring
- Closure/Post Closure
- Financial Requirements
- Containers
- Tanks
- Surface Impoundments
- Waste Piles
- Land Treatment
- Landfills
Liquids in Landfills
- Incinerators
- Thermal Treatment
127
39
13
14
24
95
105
118
40
153
101
6
9
34
25
60
3
                   Q -
                   R -
                   X -
                   268
                                         269
                                         270
     Chem,  Phys,  Biol Treatment
     Underground Injection	
     Miscellaneous	
     - General	
       Solvent & Dioxins
                         California List Wastes_
                         Scheduled Thirds
                   271
                   124
       Air Emission Standards
       A - General
       B
       D
       F
       G - Interim Status/LOIS
       State Programs	
                             Permit Application
                             Changes to Permits
                             Special Permits	
     - Administrative Procedures
Liab i1ity/Enforcement_
Corrective Action	
Waste Minimization	
Minimum Technology	
                               27  DOT Requirements
                              100
                               78
                               61
                               13
                   OSHA Requirements/HW Training
                   Test Methods/HW Technologies	
                   RCRA Document Requests	
                   SUBTOTAL
                             32
                            142
                                                       117
                                     110
                             55
                             "12
                             J75
                             41
                                                                        22
                             21
                                                        39
                            101
                                                        15
                                      36
                                     108
                                   1,246
                                   7,920
                                       -11-

-------
UNDERGROUND STORAGE TANKS
CERCLA
General
280.10 Applicability
280.11 Interim Prohibition
280.12 Definitions - General
UST
Requlated 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,
Referrals - EPA - HQ
- Other Hotlines
- Regions
- State
- GPO/NTIS/PIC
ORD/Dockets
- Other
SUBTOTAL 1,
Written Request Responses:
Referred to EPA Program Offices
Referred to other Federal Agencies
280
89
38
28
40
23
15
19
13
32
18
63
19
24
9
50
48
23
13
12
12
7
391
266
206
292
153
209
582
148
590
174


Referred externally (states, organization,
Response Form Sent
Response Form Sent/FOIA
Form Letter Sent/Need more info
Requests filled - RCRA
- CERCLA
- UST
SUBTOTAL






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
154
61
4
24
113
7
61
7
Contracts/Contract Lab Program 	 52
Exposure Assessment/
Public Health Evaluation 40
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
Settlements
SITE Program
State Participation
Taxes
Title III /Right -To-Know
Other Provisions
CERCLA Document Requests
CERCLA SUBTOTAL 1
16
5
etc)
25
3

125


174
22
29
31
212
37
94
2
3
4
53
17(
22
9
18
12
4
5
36
22
42
40
28
20
18
19
78
16
317
,892

TOTAL CALLS, DOCUMENT REQUESTS AND REFERRALS 12,842
                                          -12-

-------
       Emergency Planning Community Right-to-Know Information Hotline
                        Daily/Monthly Summary Report
                             For February 1988
Total Calls
             4761
                           Written Responses_
                                              82
Distribution of Calls by EPA Regions:
1
2
3~
 77
 / '0
14%
17%
4
5"
6"
14%
25%
 7%
Callers;

Manufacturers
Distributors
Handlers
Attorneys
Consultants/Engineers
Laboratories
Trade Associations
Public Interest Groups_
Universities/Academia
Insurance Companies
Hospitals
7
8"
9"
                       52%
                        2%
                        1%
                        5%
                       11%
                        IT
                        1%
                        2T
                     0.30%
                        1%
4%
3%
6%
10     2%	
International;   0.13%
Unknown:           2%
                                                    4%
                        State Agencies 	
                        Fire Depts.    	1%
                        EPA                   2%"
                        Local Officials	5%
                        Farmers            0.75T
                        Federal Agencies	
                        Media/Press    	
                        Union/Labor        0.20%
                        Citizens              TT
                        Other              0.63%
                                                    1%
                                                                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
Reportable Quantities
RQ's vs. TPQ's
SEC. 311/312: General
MSDS Reporting Regulations
Tier I/II Regulatoins
Thresholds
310
113
136
72
76
15
2
22
230
63
51
38
25
493
244
1087
465










CERCLA vs. Sec. 304
Transportation
Exemptions

Haz. Categories
Mixtures
Exemptions
41
8
7

217
202
226
                                     -13-

-------
Sec. 313;  General "            703
Thresholds                 	60
Public Meetings            	0_
Mass Balance Study
Trade Secrets              	54
Enforcement                	20
CEPP:  Interim Guidance        427
       Tech. Guidance
Chemical Profiles          	9
N'RT - 1                    	86
Teleconference             	Q_
Title III Workshops
Other                      	51.
Document Requests             1858
# of Documents Requested      3741
Referrals;
OTS (Section 313)__	5      RCRA/Superfund  Hotline	56
OSHA                            48      Regional  EPA            	8_
Preparedness Staff	Q__    Other                   	70_
                                     -14-

-------
                         RCRA/Superfund Hotline
 National Toll Free #800-424-9346,  Washington,  D.C.  Metro #202-382-3112
IV.   PUBLICATIONS - February 1988

   RCRA

        "Notification of  Hazardous Waste Activity,"  EPA #8700-12  OOP is
        available by referring callers to the Regions.

        "RTC:   Wastes from Extraction and Benefication  of Metallic Ores,
        Phosphate Rock,  Asbestos, Overburden from Uranium Mining and Oil
        Shale," is available through the National  Technical  Information
        Service (NTIS).   NTIS's telephone number is (703) 487-4860.

        "Final  RCRA  Civil  Penalty  Policy,"  dated  May  8,   1984, is
        available via the RCRA/Superfund Hotline.

        "Chemical Activities Status Report/Toxic Integration  Information
        Series," is  available from NTIS.  The order  number is
        PB842-139-58.  The cost is $38.95.

        "The  Hazardous   Waste   Incineration   Permitting   Study,"  is
        available from NTIS.  The order number is PB87-202-420.

        "The Solid  and  Hazardous  Waste Report for FY'87," is  available
        via the RCRA/Superfund Hotline.
   CERCLA
        The "Record of Decision  (ROD)  Update  Newsletter,"  is available
        from the Public Information Center (PIC),  382-2080.

        "Superfund Progress Report," may be obtained by routing requests
        to Karen Ellenberger (WH-562A)  in the  Assistant Administrator's
        Office.

        The "1987  Record of Decision (ROD) Annual Report,"  is available
        from NTIS.

        "The Superfund Advisory"  may be obtained by routing   requests to
        Karen  Ellenberger  (WH-562A)  in  the Assistant Administrator's
        Office.

        Requests for the  "Potentially   Responsible  Party  (PRP)  Search
        Manual,"  should  be  sent  to   Dorothy Biggs,  EPA/NEIC Library,
        Bldg.  #53, Box 25227,  DFC, Denver, CO  80225.

        "Data  Quality  Objectives  for  Remedial   Response   Activities"
        (Vols.     I  and  II)   are  available  from NTIS. The accession
        numbers  are Vol. I:   PB88-131-370 and Vol  II:  PB88-131-388.

                                   -15-

-------
                         RCRA/Superfund Hotline
 National Toll Free #800-424-9346, Washington,  D.C. Metro #202-382-3112
V.  FEDERAL REGISTER NOTICES - February 1988
   Former Notices with Open Comment Period
   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 8,  1988; 53 FR 518
   (amendments to definition
   of solid waste)
   January 13,  1988;  53 FR 850
   (proposed rule for reporting
   hazardous substance activity
   when transferring  Federal
   real property)
Approval of revisions of the
Illinois Hazardous Waste Program.
Final    authorization   for   the
program revisions become effective
March  5,  1988.    Comments  were
accepted until February 4, 1988.

Notice extending the comment
period on Florida's Hazardous
Waste Program.  Comments were
accepted until February 1, 1988.

Notice which provides the Agency's
interpretation of the decision of
the District  of  Columbia Circuit
Court  of  Appeals on the Agency's
            to   regulate  certain
             secondary   materials
            Mining   Congress  vs.
            proposed amendments to
present  regulations  required  by
the  Courts  decision.    Comments
have been extended from
February 22,  1988 until
May 23, 1988.

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 Section 120(h)
of  CERCLA  as  amended  by  SARA.
Comments  on   the  proposal  were
accepted until February 12, 1988.
                                      authority
                                      hazardous
                                      (American
                                      EPA);   and
                                   -16-

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

 January 14, 1988; 53 FR 911
 (proposed rule,  re-opening
 of comment period)
 February 5,  1988;  53 FR 3446
 (petition to extend certain
 land disposal restrictions)
 February 8,  1988;  53 FR 3644
 (lodging of  consent decree
 to under CERCLA)
 February 9,  1988;  53 FR 3818
 (proposal of financial
 assurance requirements for
 hazardous substance tanks)
 February 9,  1988;  53 FR 3796
 (lodging of  consent decree
 under RCRA)
 February 10,  1988;  53 FR 3894
 (hearing date and location)
 February 10,  1988;  53 FR 3948
 (lodging of consent decree
 under CERCLA)
The notice re-opens the comment
period on a proposed rule under
TSCA  Section   4   that  requires
testing on  73 chemicals which are
Appendix       VIII      hazardous
constituents  of  Part  261  of 40
CFR.   The comment  period was re-
opened until February 16, 1988.

Notice which petitions for a
case-by-case extension of the
effective   date   of   the   land
disposal  restrictions  on certain
corrosive waters.

The proposed consent decree
requires the  Manville Sales Corp.
implement and fund remedial action
at   the   defendants   production
facility in Waukegan, IL.

In the ANPRM comments and
information are sought regarding
approaches to financial assurance
requirements     for     hazardous
substance underground tanks.

The proposed consent decree
requires the Paxton Landfill Corp.
and Stryker  International Inc. to
perform an  environmental study of
the  Paxton   II  section  of  the
landfill located in Chicago, IL.

Notice providing date and location
of  proceedings  to  determine  if
North  Carolina's  hazardous waste
program    approval     will    be
withdrawn.

The proposed consent decree
requires the defendants pay $2
million  to  the  State  of  Rhode
Island and the U.S. EPA.
                                 -17-

-------
                         RCRA/Superfund Hotline
National Toll Free #800-424-9346,  Washington,  D.C.  Metro #202-382-3112
   February Federal Register Notices (Cont'd)
   February 11,  1988;  53 FIR 4070
   (request for  public comment)
   February 11,  1988;  53 FR 4085
   (lodging of consent decree
   under CERCLA)
   February 12,  1988;  53 FR 4280
   (initial list of Federal
   facilities to be included in
   the docket)

   February 18,  1988;  53 FR 4850
   (correction to final rule)
   February 18,  1988;  53 FR 4850
   (notice of State schedule for
   compliance)
   February 22,  1988;  53 FR 5195
   (notice of proposed rulemaking;
   extension of  comment period)
   February 23,  1988;  53 FR 5298
   (request for  public comment)
This notice requests comments on
the proposed  DeMinimis settlement
in    accordance    with   Section
122(1)(1).  The  276  parties will
pay   an   estimated  $11  million
concerning   Cannon's  Engineering
Corp.   four   (4)  sites  in  New
England.

The proposed consent decree will
settle litigation between U.S.
and  Shell  Oil  Company  over the
clean  up  of  the  Rocky Mountain
Arsenal near Denver, CO.

Notice provides initial list of
Federal facilities included in the
docket as required by SARA
Section 120(c) .

The rule provides correction to
Table I of Appendix IX of Part 261
changing   the   location   of   a
Reynolds Aluminum Company site for
Portageville, ME to Sheffield, AL.

The notice provides Indiana's
compliance schedule for adopting
program  modifications for Section
3006(f) of HSWA.

Notice extends the comment period
on the proposed redefinition of
solid waste from February 22, 1988
to March 23, 1988.

The notice solicits comments on
the  "Interim  Guidance  on Notice
Letters,     Negotiations,     and
Information  Exchange."   Comments
must be submitted to the Agency on
or before April 25, 1988.
                                   -18-

-------
                        RCRA/Superfund Hotline
National Toll Free #800-424-9346,  Washington,  D.C.  Metro #202-382-3112
 February Federal Register Notices (Cont'd)
 February 24,  1988;  53 FR 5298
 (final rule)
 February 25,  1988;  53 FR 5573
 (correction to and clarifica-
 tion of final rule)
 February 29,  1988;  53 FR 6059
 (correction of proposed rule)
The final rule promulgates a
regulation   which   extends   the
applicability of  the consolidated
rules  of  practice  governing the
administrative assessment of civil
penalties  and  the revocation and
suspension    of     permits    to
enforcement actions taken pursuant
to Section 9006 of SWDA.  The rule
is effective March 25, 1988.

The rule corrects and clarifies a
denied delisting petition.  It
specifically  addresses  omissions
associated  with  the  Monroe Auto
Equipment    Company's   delisting
petition.

The notice provides a correction
to the proposed  amendment  to the
definition of solid waste.
                                 -19-

-------
Martha Anderson, DORM
Oevereaux Barnes, WH-5628
Jim Barrett, GRC
Frank Biros, WH-527
George Bonina, WH-563
Susan 8ro««, WH-563
Karen Brown, PM-22Q
John Bosky, EPA- Kansas City
Diane Buxbaua, Region 2
Fred Chanaoia, IE-132S
Richard Clarizio, Region 5
Kathy Col 1 ier, RIP, NC
Peter Cook, WH-527
Elizabeth Cotsworth, WH-563
Wayne Crane, PM-273F
Hans Cruap, WH-5488
Gordon Davidson, WH-527
Elaine Davies, WH-562
Truett OeGeare, WH-563
Jeffery Oenit, WH-562
Melinda Downing, DOE
Karen Ellenberger, WH-562A
Ti« Fields, WH-5488
Lisa Friedaan, LE-132S
George Garland, WH-563
John Gilbert, EPA-Cin. OH
Lloyd Guerci, WH-527
Matt Hale,  WH-563
Lynn Hansen, WH-562
Penny Hansen, WH-562
Bill Hanson, WH-548E
Betti Harris, EPA, Region 7
Cheryl Hawkins, WH-548
Irene Homer, WH-595
Barbara Hostage, WH-5488
Hotline Staff
Phil Jalbert, WH-548D
Alvin K. Joe, Jr.,  GRC
Gary Jonesi,  WH-562
Ji» Jowett,  WH-548B
Thad Juszczak, WH-562A
Toni Kennedy, (ASTSWMO)
Robert Knox,  WH-562
Jack Kooyonjian, WH-548B
Mike Kosakowski, WH-527
Walter Kovalick, WH-548
Tapio Kuus^nen,  PM-223
Steve Leifer, LE-134S
Steve Levy,  WH-565
Henry Longest, WH-548
Sylvia Lowraoce, MH-562
Gene Lucero,  WH-527
Jaaes Makris, WH-562A
Joseph Hartone,  A-104
Jack McGraw,  WH-562A
Scott McPhilaay, Region  3
Royal Nadeau, Region 2
Mike Petruska, WH-562B
Carl Reeverts, WH-550E
John Riley,  WH-5488
Mike Riley,  PM-214F
Suzanne Rudzinski,  WH-563
Dale Ruhter,  WH-565
Will \am Sanjour, WH-563
Pa« 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 Willhela,  Region 7
Dan Yuraan,  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 -

-------