\
                         ES ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON, D.C. 20460

                  IP         MAT 2 0 1988     530R88103

      ENVIRONMENTAL HKUitCllON AGENCY!
           LIBRARY, REGION V                                        OFFICE OF
MEMORANDUM                                          SOLID WASTE AND EMERGENCY RESPONSE

SUBJECT:  Final Monthly Report - RCRA/Superfund  Industry
          Assistance Hotline and CEPP Hotline Report  for
          March 1988
FROM:     Thea McManus
          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 _ISSDES_ -  March  1988

   A.    RCRA Program

   1.   Definition of Tank/Definition of Wastewater Treatment  Unit

          A facility  includes a wastewater treatment unit that  meets
          the  definition  in   Section   260.10   and    the  Section
          264.Kg)(6)  exclusion.    Piped directly to  the wastewater
          treatment unit is a tank on wheels that is used to  collect
          an EP  toxic wastewater treatment sludge.  When the  wheeled
          tank is full it is disconnected  from the  piping  and  towed
          to  the  generator's  90-day  accumulation  area   where the
          sludge is emptied into  the generator's accumulation  tanks
          and/or containers.   The wheeled tank is then moved  back to
          the wastewater treatment unit  and reconnected.   Does this
          wheeled tank  meet the definition of a  tank or a container?
          If it is a tank, would it also be covered by  the wastewater
          treatment unit exemption?

               The wheeled  tank would  meet the  definition  of a tank
               under Section 260.10 because  it is  stationary during
               operation.  Devices that are typically used as  part of
               the storage/treatment  system  and that  are directly
               connected by piping to the wastewater treatment system
               are  regarded  as  being  stationary  units.    If the
               wheeled  tank  is  used  to  accumulate   a wastewater
               treatment sludge as  part  of  a   wastewater  treatment
               facility,  it  would  fall  within the definition of a
               wastewater treatment unit per Section 260.10  and  would
               be included in the Section 264.Kg)  (6)  exemption.

        Source:   Carrie Wehling (202) 382-7706
                  William Kline  (202) 382-7924
        Research: Randall Eicher

-------
2 •    Applicability qj[ _Subt it lei

     A  facility  currently  considering  altering  its wastewater
     treatment system,  uses a  water  detergent  mixture  to clean
     engines in  an auto  body shop.   The resultant wastewater is
     collected in  a sump  in the  vicinity of  the cleaning area.
     The wastewater,  when collected,   contains up  to ten percent
     (10%)  used oil removed from the surface of the engines.   The
     contents of  the sump are discharged to an on-site wastewater
     treatment facility which is  subject to  a National Pollution
     Discharge  Elimination  System  (NPDES)  permit under Section
     307(b) of the CWA.  The wastewater contained  in the  sump is
     always contaminated  with a certain fraction of used oil.   It
     is conceivable, depending on  volumes of  used oil contained,
     that  the  wastewater  could  fail  the  levels  for toluene,
     benzene, phenol, etc., as specified in  the proposed Toxicity
     Characteristic  Leaching  Procedure  (TCLP).   The wastewater
     would  therefore be hazardous  waste  (once  the  procedure is
     codified).    Assuming  this  sump  meets the definition of a
     tank,  would it fall under the jurisdiction of  Subtitle I  for
     used  oil  tanks  (currently  deferred  in  the  proposed  DST
     regulations), or since it could be hazardous wastewater based
     on  the  TCLP,  would  the  sump  holding  it be a wastewater
     treatment unit as  defined in 40 CFR Section 260.10?

         The regulatory status of the sump would be  dependent on
         its contents.   Because  the sump contains oil, it falls
         within the jurisdiction of the Subtitle I program.   The
         requirements  for OSTs under Subtitle I will be finalized
         later this year.  The  rule  may  contain  exemptions or
         deferrals  for  these  types  of  sumps.  The Subtitle I
         regulations may also exclude  any  tank  regulated under
         Subtitle C.   Thus, if at some future date, the waste is
         deemed hazardous  based on  the TCLP,  the sump (meeting
         the definition  of tank)  would no  longer be subject to
         the Subtitle  I regulations.   However,  even if  the tank
         were regulated  solely under the Subtitle C program,  the
         sump  would  meet  the   regulatory   exemption   for  a
         wastewater treatment  unit in 40 CFR Section 260.10.   It
         may, therefore,  not be subject to either the  Subtitle I
         or  Subtitle   C  tank  standards.   In that case release
         detection,   secondary   containment   and   other tank
         specifications   could   be   either  written  into  the
         individual NPDES  permit   or   specified   by   a  CWA
         rulemaking.

     Source:    Carrie Wenling (202) 382-7706
     Research: Andy O'Hare
                              -2-

-------
B. Superfund

   3.    Administrative Record

        What is the difference between the Information Repository and
        the  Administrative  Record  for   sites   on   the  National
        Priorities List  (NPD?  Where would you find each?  What are
        the statutory citations?

             The Information  Repository  implements  Section  117 of
             CERCLA  and  includes  any  information  that  should be
             available to the  public  concerning  a  remedial action
             plan.  This information must be available for inspection
             and copying at or near the facility at  issue and should
             include:

             o    The proposed/final action plan;
             o    Waivers to clean-up standards;
             o    Summaries of public comments;
             o    Explanation  of  significant  changes  in the final
                  plan;
             o    Explanation of any  differences  between  the final
                  remedial plan  and any actual  remedial,  enforcement
                  or settlement actions undertaken, and
             o    Transcripts of public meetings.

             According to Section 113  of CERCLA,  the administrative
             record  contains  the  basis  for  selecting  a response
             action.  The information in the  record must  consist of
             all  items  developed  and  received pursuant to current
             procedures for selecting a response action (e.g., PA/SI,
             HRS, RI/FS)  including procedures  for the participation
             of   interested   parties   and  the   public.      The
             administrative record  must also include all information
             required  to  be  in  an  Information  Repository  under
             Section 117 of CERCLA.  Files containing the record must
             also be available to the public at  or  near the facility
             at issue  or any  other location the President wishes to
             place a duplicate of the Administrative Record.

        Source:   Jon Fleuchaus  (202) 382-3109
        Research: Joe Nixon


   4.    Preliminary Assessments at Federal Facilities

        EPA published  the initial  list of  Federal facilities under
        CERCLA  Section  120(c)  (the  Federal Agency Hazardous Waste
        Compliance Docket) in the February 12, 1988, Federal Register
        (53 FR 4279).  The Federal facilities docket is to be updated
        every six  (6) months  and every  facility listed  in it must
        conduct  a  Preliminary  Assessment  (PA).  How long will the
        Federal facilities listed have to conduct their PA?

                                 -3-

-------
4.    Preliminary Assessments at Federal Facilities (Cont'd)

          Facilities  on  the  initial  list of Federal facilities
          under Section 120(c) are  required under  Section 120(d)
          to conduct  a PA  within 18  months of  the enactment of
          SARA (April 17, 1988).   CERCLA  Section 120(c)  requires
          EPA to  update the  Federal facilities  docket every six
          (6) months.  EPA has interpreted  the statutory deadline
          for conducting  the PA within 18 months at  facilities on
          the initial list to extend to future lists.   This means
          that  upon  being  listed  and  published in the Federal
          Regis^ter, the Federal facilities will have  eighteen (18)
          months to conduct a PA.

     Source:   Linda Cooper (202) 475-7025
     Research: Marc Jones
5.    State Cost Share Requirements

     Section 104(c)(3)  of CERCLA  required States to share in the
     cost of  fund-financed  remedial  actions  executed  at sites
     identified on  the National  Priorities List  (NPL).   How was
     this requirement  altered  by  the  Superfund  Amendments and
     Reauthorization Act of 1986 (SARA)?

          Before  the  enactment  of  SARA,  the  percentage  of a
          State's cost share was  dependent upon  the ownership of
          the  NPL  site  at  the  time of the hazardous substance
          disposal.   A share  of  ten  percent  (10%)  of  remedial
          action costs  was required at privately owned sites.  At
          publicly owned sites the State was  required to   fund at
          least 50  percent of all response costs.  The 50 percent
          share  was  inclusive  of  costs  incurred   during  all
          removals,   remedial  planning,  remedial action, and the
          phase of  the remedial  action necessary  to ensure that
          the chosen remedy was operational and functional.

          Following  the  enactment  of SARA, Section 104(c)(3) of
          CERCLA  as  amended  requires  States  to  cost   share a
          minimum  of  50  percent  of  all  response costs at any
          facility  operated,  either   directly   or   through  a
          contractual  relationship  or  otherwise  by a State (or
          political   subdivision  thereof)  at  the  time   of  any
          disposal of hazardous substances at the facility.  Thus,
          SARA alters the criterion for the 50 percent  cost share
          from ownership to operation.  The ten percent (10%) cost
          share requirement still applies  to remedial  actions at
          all sites, whether privately or State-owned.

     Source:    Betty Winter (202) 382-2448
     Research:  Chris Bryant
                              -4-

-------
6.    Contact Laboratory Program

     A  potentially  responsible  party  (PRP),  is  performing  a
     remedial investigation and feasibility  study (RI/FS).   Must
     this party  use an EPA contract laboratory for any analytical
     work?

          Under Section 104(a)(l)(B) of CERCLA as amended by SARA,
          a PRP may perform an RI/FS if that party is qualified to
          conduct such investigations.  A qualified person must be
          contracted  to  assist  in  overseeing and reviewing the
          RI/FS.   The PRP must also agree  to reimburse  the Fund
          for any costs incurred under, or in connection with, the
          oversight contract,  or arrangement.

          Generally, under such arrangements, the PRP will not use
          a CLP laboratory if  the PRP is funding the investiga-
          tions.  However, the PRP will be required to demonstrate
          that the laboratory  chosen is capable of doing  the work
          in question, and is  acceptable to the Agency.

     Source:   Ross Natoli (202) 382-2063
     Research: Laurence Buela
7.    Hazardous Substances and Reportable Quantities

     If  a  release  of  drilling  fluids  from  the production of
     petroleum (temporarily exempted from  RCRA  regulations  as a
     hazardous  waste),  is  cleaned  up using Fund money,  can the
     Fund collect for the money spent?  If more than  a reportable
     quantity  (RQ)  was  released  in  a  24-hour period,  was the
     release reportable?

          A Comprehensive Environmental Response, Compensation and
          Liability Act (CERCLA)  hazardous substance is defined in
          Section  101(14)  as:  "(A)   any  substance  designated
          pursuant to Section 311(b)(2)(A) of the Federal Water
          Pollution   Control   Act   (FWPCA);  (B)  any element,
          compound,  mixture,  solution  or  substance  designated
          pursuant  to  Section  102  of CERCLA; (C) any hazardous
          waste having  the  characteristics  identified under or
          listed  pursuant  to  Section  3001  of  the Solid Waste
          Disposal Act (but not including any waste the regulation
          of  which  under  the  Solid Waste Disposal Act has been
          suspended by Act of  Congress); (D)  any toxic pollutant
          listed  under   Section  307(a)  of  the  Federal  Water
          Pollution Control Act;  (E)  any hazardous  air pollutant
          listed under Section 112 of the Clean Air Act (CAA); and
          (F)   any  imminently  hazardous  chemical  substance  or
          mixture  with  respect  to  which  the Administrator has
          taken  action  pursuant  to  Section  7   of  the  Toxic
          substances Control Act (TSCA)."

                              —5 —

-------
   7.   Hazardous Substances and Reportable Quantities (Cont'd)

             Under Section 3001(b)(2)(A) of the Resource, Conserva-
             tion  and  Recovery  Act  (RCRA),  Congress   temporarily
             exempted several types of  solid wastes  from regulation
             as  hazardous  wastes,  pending  further  study  by EPA.
             Among the categories of  wastes exempted  were "drilling
             fluids,  produced  waters,  and  other wastes associated
             with  the  exploration,  development,  or production of
             crude oil or natural gas."

             If the  drilling fluids  containing hazardous substances
             designated a CERCLA hazardous substance by any paragraph
             except (C)  exclusively it will be a hazardous substance
             and subject  both  to  liability  under  Section  107 of
             CERCLA  and  Section  103(a)  release reporting require-
             ments.

        Source:   Kirsten Engel (202) 382-7706
        Research: Randy Eicher


C. CEPP

   8.   Section 313: Toxic Release Inventory

        A  manufacturing  facility  removes  PCB-laced oil  that was
        contained in  its on-site  transformers.  Would this activity
        be considered a process  or an  otherwise use  of the  PCB, a
        listed toxic  chemical if  the facility only extracts the PCB
        to dispose of it off-site?

             If the PCB laced oil is  removed from  an on-site trans-
             former for  disposal and  is not replaced with clean PCB
             laced oil, this would not be considered a process or an
             otherwise  use.    Removal  of  a toxic chemical  from an
             article for  disposal does  not constitute  a process or
             otherwise use  activity.  Therefore, this activity would
             not be subject to  threshold  determination   and release
             reporting under SARA Section 313.

        Source:   Larry Longenecker (202) 382-7971
        Research: John Ferris


   9.   Section 304: Release Notification

        Must  any  amount  of  a  listed  chemical  contained  within
        abandoned  or  discarded   barrels,   containers,   or  other
        receptacles  be   considered  to   determine  if   a  specific
        reportable quantity has been exceeded under  the  SARA Section
        304 notification requirements?


                                 -6-

-------
9.   Sectiqri 3J)4_^ Release Notification (Cont'd)

          Section 355.20  (52 FR  13395)  defines a release as "any
          spilling, leaking, pumping, pouring, emitting, emptying,
          discharging, injecting,  escaping, leaching, dumping, or
          disposing into  the environment  (including the abandon-
          ment  pr  discard ing	of  barrels, containers, and other
          receptacl^sj  of  any   hazardous   chemical,  extremely
          hazardous  substance,  or  CERCLA  hazardous substance."
          Therefore, if a facility has abandoned  or discarded any
          barrels, containers,  or other receptacles containing an
          extremely  hazardous  substance  or  a  CERCLA hazardous
          substance  and  the  total  amount present in all of the
          receptacles is in excess  of  its  designated reportable
          quantity and the containers have the potential to result
          in exposure  to  persons  off  site,  the  discarding or
          abandonment  of   the  barrels  should  be  reported  as
          required in Sections 355.40 (52 FR 13396).

     Source:   Kirsten Engel (202) 382-7722
     Research: Kim Jennings
                             -7-

-------
II.  ACTIVITIES
                          1988
     1.   The  RCRA/Superfund  Hotline  and  CEPP  Hotline responded to
          21,16JD questions and request for  documents  in  March.   The
          breakdown is as follows:
                          RCRA

Information Calls        8,080
Call Document Requests     806
Written Document Requests  134
Referrals                2_,JJ27
                        11,047
                                Superfund

                                  1,836
                                    181
                                  2,017
1,040
  389
1,429
2,944
2,858
  536
	329
6,667
13,900
 4,234
   670
 2^356
21,160
A.     RCRA/Superfund Hotline Activities

     2.   On  March  8,  Laurie  Huber  of  the  RCRA/Superfund Hotline
          attended  the  Office  of  Underground  Storage  Tanks  staff
          meeting.

     3.   On March  9, Denise  Sines, Hotline Project Director met with
          Kevin Donovan of the Site Evaluation & Guidance Branch (OERR)
          regarding  Superfund  guidance  and  a  Superfund  Freedom of
          Information Act request.

     4.   On March 14, Denise Sines, Hotline Project Director  met with
          Scott Parrish  of the  Hazard Ranking & Listing Branch (OERR)
          regarding  the  National  Printing  List  and  Hazard Ranking
          System issues.

     5.   On March  14, Denise Sines, Hotline Project Director met with
          Phil Jalbert of the Policy Analysis Section (OERR) concerning
          the Superfund Report to Congress.

     6.   On March  15, Becky Cuthbertson of the RCRA/Superfund Hotline
          met with Paul Mushovic  of  the  Solid  Waste  Review Section
          (OSW) regarding the treatability studies sample exclusion.

     7.   On March 15, Denise Sines, Chris Bryant and Becky Cuthbertson
          of the RCRA/Superfund Hotline met  with  Peg  Anthony  of the
          State  and  Local  Coordination  Branch (OERR) to discuss the
          Technical Assistance Grants Program.

     8.   On March 15, Hubert Watters, Deputy Project Officer  from the
          Emergency  Response  Division  (OERR) briefed the Hotlines on
          Continuous Releases and Federally Permitted Releases.

     9.   On March 16, Paul Beam of  the Site  Evaluation Branch (OERR)
          briefed the  RCRA/Superfund Hotline  on Pre-Remedial Strategy
          and Expanded Site Inspection Guidance.
                                -8-

-------
A.     RCRA/Superfund Hotline Activities (Cont'd)

  10.  On  March  22,  Denise  Sines, Hotline Project Director met with
       Thea McManus, Project  Officer  of  the  Office  of  Solid Waste
       concerning Hotline issues.

  11.  On March  22, Scott  Parrish and  members of  his staff from the
       Hazard   Ranking   &   Listing   Branch   (OERR)   briefed   the
       RCRA/Superfund  Hotline  on  NPL-Dpdate  7,  RCRA  Unwillingness
       Criteria and the RCRA - 44 sites.

  12.  On March 23, Matt Straus of  the Office  of Solid  Waste briefed
       the RCRA/Superfund Hotline.

  13.  On  March  24,  the  RCRA/Superfund Hotline viewed the Technical
       Assistance Grants videotape.

  14.  On March  25, Peg  Anthony of  the State  and Local Coordination
       Branch  (OERR)   briefed  the   RCRA/Superfund  Hotline  on  the
       Technical Assistance Grants program.

  15.  On March 25, Denise Sines, Hotline Project Director met with
       Nerid Maxey of the Office of  Civil Rights  concerning equipment
       for the Hearing Impaired (TDD) regarding Hotline access.

  16.  On March  30, Jan  Wine of  the State Involvement Section (OERR)
       briefed the RCRA/Superfund Hotline on State  Participation Dnder
       SARA.
B.     Emergency Planning & Community Right-To-Know Information jjotline
       Activities

  17.  On March 1, Minda  Sarmiento  of  the  Title  III  Hotline staff
       attended the  Title III Workgroup meeting on the status of Title
       III activities and chemical profiles.

  18.  On March 1 and 11, Denise  Sines and  Robert Costa  of the Title
       III  Hotline  met  with  Anne  Geische  of  the  Office of Toxic
       Substances (OTS) regarding SARA Section 313.

  19.  On March 8 and  22,  members  of  the  Title  III  Hotline staff
       attended the Preparedness Staff meeting.

  20.  On March  10, Robin  Heisler of  the Office  of Toxic Substances
       briefed the Title III Hotline on  the status  of the development
       of the Section 313 public database and upcoming public meeting.

  21.  On  March  11,  Denise  Sines  and Robert Costa of the Title III
       Hotline staff  met with  Lawrence Pratt  of the  Office of Toxic
       Substances regarding Section 313 technical requirements.


                                 -9-

-------
B.      ErnergencyPlanning
       Activities (Cont'd)
Community^Rigjit-To-Know Information Hotline
  22.  On March 11, Denise Sines, Hotline Project Director met with
       Kim Ogden of the Office  of  Solid  Waste  concerning  the Toxic
       Release Inventory Task Force.

  23.  On  March  11  and  28,  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.

  24.  On March 15, Robert Costa of the Title III Hotline  attended the
       Title  III   workgroup  meeting  on  the  status  of  Title  III
       activities.

  25.  On March 23, Robert Costa of the Title III Hotline  attended the
       TRI  public  database  meeting  on the status of public database
       activities.

  26.  On March 29, Kim Jennings of the Title III Hotline  attended the
       Title  III  workgroup  meeting  on  the  status of the Title III
       activities.

  27.  On March 29, Denise Sines and  Robert  Costa  of  the  Title III
       Hotline  met  with  Anastasia  Watson  of the Chemical Emergency
       Preparedness Program concerning Title III Hotline activities.

  28.  On March 30, Minda Sarmiento of  the Title  III Hotline attended
       the public meeting on the Section 313 public database.

  29.  On March  31, Minda  Sarmiento of the Title III Hotline attended
       the  National Response  Team  (NRT)  meeting  on  the  status of
       Federal emergency preparedness and training activities.
                                 -10-

-------
III.  ANALYSES OF QUESTIONS - March 1988

SUMMARY OF CALLS BY GEOGRAPHIC DISTRIBUTION (EPA Regions):

1     6.3	 3    23.1	 5     17.1      7     3.9

                 4
                                                           Grand Total: 14.493
                                                                     10.5
     10.3
                 11.1
                              9.2
             8
              4.3
                   10
3.4
  INTERNATIONAL CALLS
                            0.2
Manufacturers
Generators
Transporters
TSDF's
EPA HQ
EPA Regions
Federal Agencies
5
16
1
6
2
2
2
.3
.8
.4
.5
.9
.9
.7
State Agencies
Local Agencies
Used Oil Handlers
UST 0/0
Consultants
Attorneys
Laboratories
4
1
0
4
30
7
1
.1
.5
.8
.8
.1
.6
.8
Univ. /Researchers
Trade Associations
Insurance Co
Environmental Groups
Press
Citizens
Other
2.
0.
0.
0.
0.
5.
1.
5
5
5
4
3
6
4
General Information
3010 Notification	]
260,               	
260.22 Petitions/Delisting	
       Solid Waste Definition	
       Hazardous Waste Definition
                                            RCRA
                                    755  264/265 TSDF
                                    173
261
261
261
261
261
261
261
261
262
.10
,22
,2
,3
 C
 D
,4
,5
,6
,7
                                    119
                                     63
                          319
                          473
       Characteristic
       Listed HW
            HW
702
                          670
       Exclusions	237
       Small Quantity Generators	167
       Recycling Standards	147
       Container Residues	54
       Generator - General	234
       100-1000 kg/mo	116
       Manifest Info	126
       Accumulation                 171
263
266
266
266

266
266
                     & Reporting_
                     Shipments	
                                    165
                                     32
                                    112
    C
    D
    E

    F
    G
   Recordkeeping
   International
   Transporters	
   Use Constituting Disposal	
   HW Burned  for Energy Recovery	
   Used Oil Burned for
     Energy Recovery	122
   Precious
   Spent
                           81
      Metal Reclamation_
   Lead-Acid Battery
Reclamation
 20
                                     22
A -
B -
C -
D -
E -
F -
G -
H -
I -
J -
K -
L -
M -
N -

0 -
P -
Q -
R -
X -
268
                                         269
                                         270
         Scope/Applicability	
         General Facility Standards_
         Preparedness/Prevention	
         Contingency Plans
                                                                          154
                                                                    48
                                                                     19
                                 25
                                         136
Manifest/Recordkeeping/Reporting 27
Ground Water Monitoring	135
Closure/Post Closure	
Financial Requirements	
Containers	
Tanks
                                                                    94
                                                                    58
                                                                    191
         Surface Impoundments	
         Waste Piles	
         Land Treatment	
         Landfills	
         Liquids in Landfills	
         Incinerator s_	
         Thermal Treatment	
         Chera, Phys, Biol Treatment
         Underground Injection	
         Miscellaneou s_	
         - General	
           Solvent
                                                                     71
                                                                           12
                                                                              15
                                                                              62
                                                                              37
                                                                    67
                                                                     8
                                 30
                                                                   180
         D
                    Waste
subtitle   	
Jsed  Oil  - General_
tousehold Hazardous
lioxins	
[ixed Radioactive  Waste
. sbestos/PCBs/Radon	"
 nfectious Waste
                                 148
                                    115
                                  18
                                     32
              & Dioxins	
      California List Wastes
      Scheduled Thirds	]
      Air Emission Standards
      A - General	
        - Permit Application_
        - Changes to Permits_
        - Special Permits
        - Interim
                                                                   129
                                 99
                                         114
                                                                           12
                                                                              65
                                                                    43
                                                                           15
                                                                     11
                                     48
                                    137
                                     36
 iability/Enforceraent
 orrective Action	
 aste  Minimization	
 inimum Technology	
                                                        Status/LOIS_
                                          -  State  Programs	
                                          -  Administrative
                                          Requirements_
                                                                    56
                                                    Procedures
                                     87
                                     96
                                     75
                                     17
     271
     124
     DOT                	
     OSHA Requirements/HW Training
     Test Methods/HW Technologies^
     RCRA Document Requests	
     SUBTOTAL
                                                                   102
                                                                     15
                                                                           35
                                                                          105
                                                                          806
                                                                        8,886

-------
UNDERGROUND STORAGE TANKS
CERCLA
General
280.10 Applicability
280.11 Interim Prohibition
280.12 Definitions - General
UST
Regulated Substance
280 B New UST Systems - General
280.20 Performance Standards
280.21 Upgrading
280.22 Notification
280 C General Operating
Requirements
280 D Release Detection
280 E Release Reporting and
Investigation
280 F Corrective Action -
Petroleum
280 G Corrective Action -
Hazardous Substances
980 W Dii1-— r>f "-Jpr vi r p /PI n
-------
         Emergency Planning Community Right-to-Know Information Hotline
                        Daily/Monthly Summary Report
                               For March 1988
Total Calls
 6.131
Distribution of Calls by EPA Regions
      7%
     16%
     17%
4
5"
6"
13%
20%
 8%
Callers:
7
8"
9"
Manufacturers
Distributors
Handlers
Attorneys
Consultants/Engineers
Laboratories
Trade Associations
Public Interest Group
Universities/Academia
Insurance Companies
Hospitals
52%
2%
6%
4%
12%
1%
1%
s 1%
1%
.61%
2%
                       Written Responses
                                     536
4%
2%
3%
8%
10	
International;  .08%
Unknown:        1%
                                       State Agencies 	
                                       Fire Depts.    	
                                       EPA            _
                                       Local Officials	
                                       Farmers        	
                                       Federal Agencies
                                       Media/Press    	
                                       Union/Labor    	
                                       Citizens       	
                                       Other
                                            3%
                                            2%
                                            2%
                                            4%
                                           ,52%
                                          .92%
                                           94%
                                           19%
                                          .67%
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 Regulations
Thresholds
517
150
135
75
48
13
2
18
306
118
54
44
19
754
315
711
574









CERCLA vs. Sec. 304
Transportation
Exemptions

Haz. Categories
Mixtures
Exemptions
47
10
15
104
89
183
                                        13

-------
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
1,687
143
0
5
51
31
288
12
125
2
0
97
Document Requests  	2,858
# of Documents Requested  6,660
Referrals;
OTS (Section 313)	4	    RCRA/Superfund Hotline	78
OSHA	94	    Regional EPA  	11
Preparedness Staff	1	    Other 	141
                                      14

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


 IV.   PU BLIC ATIONS__-1_ Jlarch_ _19'8 8

 RCRA

    "Enforcement Actions  Under RCRA  and CERCLA at Federal Facilities"
    is available by calling Jacqueline Theil (OWPE) at (202) 475-8727.

    Hazardous Materials Storage and Handling Handbook is available from
    the Government Printing Office (GPO).  The order number is 008-007-
    03281-0.

    "Land Disposal Restrictions Summary Volume 2  California Wastes" is
    available via Cincinnati.  The publication number is 530-SW-88-012.

    "Report  to  Congress:  Wastes  from Combustion of Coal by Electric
    Utility Power Plants (Final Report)" is  available from  NTIS.  The
    publication number  is PB88-177977.   The  costs are $32.95 - paper
    and $6.95 - microfiche.

    "Report to Congress: Wastes from  Combustion  of  Coal  by Electric
    Utility  Power  Plants  (Appendices)"  is available from NTIS.  The
    publication number is PB88-177985.   The  costs are  $19.95 - paper
    and $6.95 - microfiche.

    The "Report to Congress: EPA's Activities and Accomplishments Under
    RCRA: Fourth Quarter FY86 to  FY87"  is  available  from Cincinnati
    Warehouse (EPA/530-SW-88-007).

    "Waste   Minimization   Bibliography"   dated  September  1987,  is
    available from EPA Headquarters  Library while  supplies last.   It
    will eventually be sent to NTIS.

    "The Waste  Minimization Strategy  Report" is  now available to the
    public.  Callers requesting a copy of the report should contact Pat
    Wheeler with  the Center  for Environmental Research Information at
    513/569-7391.

 CERCLA

    The "Compendium of  Costs  of  Remedial  Technologies  at Hazardous
    Waste Sites" is available from NTIS.  The order number is PB88-113-
    477/AS.

    The "Superfund Hazardous Waste Bibliography" is  available from the
   Office of  Research and Development.  The EPA publication number is
    540-1-87-001.
                                 -15-

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


CERCLA (Cont'd)

   Copies  of   the  "Pre-Remedial  Strategy  for  Implementing  SARA"
   guidance document (OSWER Directive  #9345.2-01)  will  be available
   via the Regions.

   The  "Preliminary  Assessment  Guidance  for FY88" (OSWER Directive
   #9345.0-01) will be available via the Regions.

   Copies of the "Expanded Site Inspection (ESI) Transitional Guidance
   for FY1988"  (OSWER Directive f9345.1-02) will be available via the
   Regions.
DST
   The  OST   publication  entitled   "Process  Affecting  Sub-surface
   Transport of Leaking Underground Tank Fluids" is now available from
   GPO.  The order number is 055-000-00269-0, and the cost is $3.95.

   "Soil-Gas  Measurements   for  Detection   of  Sub-Surface  Organic
   Contamination"  (DST  Publication  #28)  is available through NTIS.
   The order number is #PB87-174-884.   The cost  is $13.95  and $3.00
   handling.

   A  copy  of  the  "Regulatory Impact Analysis of Proposed Financial
   Responsibility   Requirements   for   Underground   Storage   Tanks
   Containing Petroleum"  is available  for Review  and Copying at the
   UST Docket.
                                -16-

-------
                         RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3112
V. FEDERAL REGISTER NOTICES - February 1988
Former1 Notices.with Open CommentPeripd
February 9, 1988; 53 FR 3818
(proposal of financial
assurance requirements for
hazardous substance tanks)
February 11, 1988; 53 FR 4070
(request for public comment)
February 22, 1988; 53 FR 5195
(notice of proposed rule-
making; extension of comment
period)
February 23, 1988; 53 FR 5298
(request for public comment)
March Federal Register Notices

March 2, 1988; 53 FR 6712
(lodging of consent decree
under CERCLA)
In the ANPRM comments and
information are sought regarding
approaches to financial
assurance requirements for
hazardous substance underground
tanks.  The comment period
remains open until April 11,
1988.

This notice requests comments on
the proposed deminimis settle-
ment in accordance with Section
122(i)(l).  The 276 parties will
pay an estimated $11 million
concerning Cannon Engineering
Corp's. four (4) sites in New
England.  The comment period
remained open until March 14,
1988.

Notice extended the comment
period on the proposed redef-
inition 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.
The proposed consent decree
requires Franklin P. Tyson, et
al. to implement a remedial
action at Tyson's Lagoon in
Upper Merion Township,
Pennsylvania.
                                -17-

-------
                       RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3112
March Federal Register Notices (Cont'd)
March 2, 1988; 53 FR 6762
(proposed rule under CERCLA)
March 3, 1988; 53 FR 6822
(notice of EPA strategies
procedure)
March 4, 1988; 53 FR 7073
(correction to 53 FR 6762)
March 9, 1988; 53 FR 7516
(notice of determination to
deny petitions)
March 9, 1988; 53 FR 7582
(lodging of consent decree
under CERCLA)
March 9, 1988; 53 FR 7567
(notice of public meeting)
March 10, 1988; 53 FR 7740
(final rule; correction)
March 10, 1988; 53 FR 7813
(notice of consent decree)
March 11, 1988; 53 FR 7903
(final rule-delisting)
Reportable quantities for
releases of lead and methyl
isocyanate are proposed.  EPA
also proposes to delist ammonium
thiosulfate under 101(14) of
CERCLA and 311 of CWA.

The notice provides EPA's new
procedure for review of delist-
ing petitions.  This is an
effort to reduce processing
time.

The notice provides a typo-
graphical correction to the
proposal on March 2, 1988.

The notice explains the Agency's
intent to deny three petitions
recommending that the EPA drop
the lead constituent in the used
oil fuel specification.

The notice describes a proposed
consent decree lodged against
air products and chemicals
pursuant to releases of
hazardous substances under
CERCLA.

The notice announces a public
meeting to discuss approaches to
make the toxic chemical release
inventory available to the
public via a data base.

The rule corrects errors in the
May 2, 1986, final rule
addressing closure/post-closure
and financial responsibilities
requirements.

The notice is a consent decree
against the Stanley Plating Co.
for violations of RCRA.

The rule excludes from the lists
of hazardous wastes certain
solid wastes generated at the
Denny Farm site in McDowell,
Missouri, by the EPA Mobile
Incineration System.  The rule
was effective March 11, 1988.
                                -18-

-------
                       RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C.
             Metro f202-382-3112
MarchMFederal Registejr^ Notices (Cont'd)
March 14, 1988; 53 FR 8223
(notice of intent to delete
NPL sites)
March 14, 1988; 53 FR 8279
(request for public comment)
March 15, 1988;53 FR 8501
(announcement of workshop)
March 17, 1988; 53 FR 8814
(lodging of consent decree
under CERCLA)
March 17, 1988; 53 FR 8816
(lodging of settlement
stipulation under CERCLA)
March 22, 1988; 53 FR 9358
(notice of availability)
March 22, 1988; 53 FR 9358
(solicitation for applica-
tions )
The notice requests public
comment on EPA's intent to
delete the Varsol spill site,
Miami, Florida, and the Tri-City
Oil Conservationist site, Temple
Terrace, Florida, from the
National Priorities List.

The notice requests public
comment on published guidance
which evaluates mixed funding
settlements under CERCLA.

The notice announces a work-
shop on Expert Systems for
Environmental Management to be
held in April.

The consent decree concerns cost
recovering regarding the Harvey
and Knotts hazardous waste site
in New Castle County, Delaware.

The settlement is in connection
with a proof of claim filed
against Smith International's
Chapter 11 bankruptcy reorgan-
ization proceedings.  The
settlement provides that Smith
will pay one percent (1%) of
EPA'S costs.

The notice announces the avail-
ability of applications for
grant monies to develop innova-
tive in/situ treatment methods
at Superfund sites.  Applica-
tions must be received by May 1,
1988.

The notice solicits applications
by universities to establish
five (5) hazardous substance
research facilities.  Applica-
tions must be received by
June 27, 1988.
                                -19-

-------
                       RCRA/Superfund Hotline
National Toll Free f800-424-9346, Washington, D.C.
             Metro f202-382-3112
March Federal Register^ Notices {Con'td)
March 24, 1988; 53 FR 9700
(proposed administrative
settlement)
March 24, 1988; 53 FR 9736
(interim final rule with
request for comments)
March 25, 1988; 53 FR 9807
(notice of proposed
administrative settlement
and opportunity for Public
comment)
March 25, 1988; 53 FR 9823
(lodging of consent decree
under CERCLA)
March 28, 1988; 53 FR 9944
(notice of clarification)
March 28, 1988; 53 FR 9976
(notice of availability of a
Report to Congress and
announcement of public
comment)
March 28, 1988; 53 FR 9992
(lodging of consent decree
under RCRA)
The notice proposes a settlement
under Section 122(h) of CERCLA
with two parties at the
Pollution Abatement Services
site in  Oswego, New York.
Comments will be received on the
proposal until April 25, 1988.

The interim final rule codifies
the provisions of Section 117(e)
of CERCLA.  It establishes a
formal procedure for communities
near NPL sites to obtain
Technical Assistance Grants
(TAGS) for $50,000.  Comments on
the rule must be received on or
before June 22, 1988.

The notice announces a proposed
settlement pursuant to CERCLA
Section 122 with three (3) PRPs
at a PCB contaminated site in
Escondido, California.  Comments
on the proposed settlement will
be received until April 25,
1988.

The notice announces a consent
decree lodged against Inmar
Associates, Inc., pursuant to
CERCLA Section 106(b) and 107.

The notice clarifies the broad
interpretation of "soil" in the
preamble to the March 19, 1987,
regulations regarding closure of
hazardous waste surface
impoundments.

The notice announces the
availability of the "Report to
Congress:  Wastes from the
Combustion of Coal by Electric
Utility Power Plants" as well as
two public hearings.

The proposed consent decree
resolves a judicial enforcement
action brought by the Dnited
States against Du-Wel Hartford,
Inc.
                                -20-

-------
                       RCRA/Superfund Hotline
National Toll Free #800-424-9346, Washington, D.C. Metro #202-382-3112
March Federal Reg^ister Notices (Cont'd)
March 28, 1988; 53 PR 9993
(lodging of consent decree
under CERCLA)
March 31, 1988; 53 FR 10401
(supplement to proposed rule)
March 31, 1988; 53 FR 10403
(notice of availability of
information)
The proposed consent decree
requires Edward Hines Lumber
Co., and Mid-South Wood Products
of Mena, Inc., of Mena,
Arkansas, to implement an EPA
approved remedial action.

The notice requests comments on
phase-in of a compliance date
associated with financial
responsibilities for underground
storage tanks.

The notice requests comment on
new information made available
by this notice.
                                -21-

-------
Martha Anderson, DORM
Devereaux Barnes, WH-562B
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
Jeffery Denit, WH-562
Bruce Diamond, WH-527
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
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
Steve Hooper, WH-527
Irene Horner, WH-595
Barbara Hostage, WH-548B
Hotline Staff
Phil Jalbert, WH-548D
Alvin K. Joe, Jr., GRC
Gary Jonesi, WH-562
Jim Jowett, WH-548B
Thad Juszczak, WH-562A
Toni 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 Lowrance, WH-562
James Makris, WH-562A
Joseph Martone, A-104
Jack McGraw, WH-562B
Scott McPhilamy, Region 3
Fran Mulhern, Region 3 (3ES40)
Royal Nadeau, Region 2
Margo Oge, TS-779
Mike Petruska, WH-562B
Lawrence Pratt, TS-779
Carl Reeverts, WH-550E
John Riley, WH-548B
Mike Riley, PM-214F
Suzanne Rudzinski, WH-563
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 Willhe1m, Region 7
Dan Yunnan, 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
                                -22-

-------