*  £ JSfa\         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
     S|u>r/                      WASHINGTON, D.C. 20460

                                                        530R88110
                                        JAN   5
        MEMORANDUM                                              OFFIC"
                                                            SOLID WASTE 
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2. Financial Assurance

Three  treatment, storage and  disposal facilities (TSDFs)  are  wholly owned
subsidiaries of one company.   The three facilities need financial coverage for
nonsudden accidental occurrences:  $3 million per occurrence  and $6 million
annual aggregate.  Must the parent company provide the $3 million/$6 million
for each facility  (a cumulative of  $9  million/$18 million) or can all  of the
facilities be covered by the $3 million/$6 million?

   An owner or operator of a hazardous waste treatment, storage, or disposal
   facility, or a group of such facilities must demonstrate liability coverage in the
   amounts of $3 million  per  occurrence  and $6 million  aggregate  (40  CFR
   Section 264.147(b)). As explained in the April 16,1982 Federal Register (47 FR
   16544), liability coverage is required on an owner or operator basis rather than
   a facility basis. The annual aggregate coverage requirement takes into account
   the risk of multiple occurrences among facilities owned by one company (47
   FR  16546).  Therefore, the company that owns three TSDFs as subsidiaries is
   only required to have $3 million/$6 million nonsudden accidental coverage,
   not $9 million/$18 million.

Source:        Mark Pollins     (202) 382-4780                            \
Research:      Renee Pannebaker

3. Definition of Wastewater Treatment Unit

On September 2,1988 (53 FR 34079), EPA published a clarification concerning the
scope  of the  wastewater treatment  unit exemption (see  40  CFR Section
264.1(g)(6)). One aspect of this clarification concerned whether or not a tank
system is "dedicated" to an on-site wastewater treatment facility.  Specifically,
EPA stated, "...if a tank system, in addition to be being used in conjunction with
an on-site wastewater treatment facility, is used on a routine or occasional basis
to store or treat a hazardous wastewater prior to shipment off-site for treatment,
storage or disposal, it is not covered by this exemption [emphasis added]."

Hazardous  waste tanks which  are part  of  wastewater  treatment facilities
sometimes have waste removed from them for off-site disposal.  Examples of
this situation include hazardous waste accumulation tanks (dedicated  to on-site
wastewater treatment facilities) which must occasionally be cleaned out, and also
those tanks which produce (on a routine basis) filter cakes or sludge residues as
part of the wastewater treatment process.  Does the removal  of these wastes from
tanks for off-site disposal preclude these tanks from qualifying for the wastewater
treatment unit  exemption?

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  3. Definition of Wastewater Treatment Unit (Cont'd)

    EPA stated that the wastewater treatment unit exemption applies to "any tank
    system that manages hazardous wastewater and is dedicated for use with an
    on-site wastewater treatment facility" (53 FR 34080). The removal of waste-
    water treatment sludges or tank bottoms for off-site disposal from  tanks
    should not disqualify these tanks from the  exemption, provided that this
    occurs as part of normal wastewater treatment activities.  The removal and
    off-site disposal of treatment sludges and tank bottoms are not necessarily
    indications that the tanks in question are being used in a manner other than
    for on-site wastewater treatment; on the contrary, the generation of tank
    bottoms  and filter  cakes is  a  common  process in wastewater  treatment
    operations. The definition of a wastewater treatment unit (Section 260.10, as
    amended in 53 FR 34079)  includes tanks which generate and accumulate
    wastewater treatment sludges (either solid,  semi-solid, or liquid) or tanks
    which treat  or store  wastewater  treatment sludges. The intent  of  the
    September 2,  1988 notice was to clarify that the exemption does not apply to
    those tanks that are used to store or treat a hazardous waste/wastewater prior
    to shipment (either on a part-time or full-time basis) to off-site facilities rather
    than manage it in an  on-site wastewater treatment facility.                :

  Source:       William Kline    (202) 382-7917
  Research:      Ross Elliott
B. CERCLA

  4. Preauthorization for Superfund Reimbursements

  What constitutes an emergency removal action for  which Superfund money
  might be initially allocated; and  when a  private party takes initiative and
  performs an emergency removal, under what conditions may that private party
  be reimbursed from the fund?

    Fund money may be allocated for an emergency removal if there is a release
    or threat of a release of a hazardous substance into the environment or if
    there is a release or threat of a release of a pollutant or contaminant which
    poses an imminent and substantial danger to public health or welfare per
    CERCLA Section 104(a)(l)(A, B).  The degree of danger will be assessed by a
    Regional EPA representative per 40 CFR Section 300.65(B)(2)(i-vii).   For
    example, a notification to the National Response Center (NRC) under Section
    103(a) or to the Region under Section 103(c) will trigger government attention
    to the situation  (40  CFR Sections 300.63(a-c) and 300.36(a)). An on-scene
    coordinator (OSC) will  assess the site to determine  if an imminent threat
    exists and if Superfund money should be allocated for response, per 40 CFR
    Section 300.63(d).

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     4. Preauthorization for Superfund Reimbursements (Cont'd)
     If a private party performs an emergency removal action (or remedial action),
     he/she  may  be  eligible for reimbursement, but  the action must be
     ^reauthorized per CERCLA Section lll(a)(2) and 40 CFR Section 300.25(d)(2)(i,
     ii, iii). Response costs (removal or remedial action) will be reimbursed if they
     are "reasonable" per 53 FR 8283, March 14,1988. However, no reimbursement
     would be possible for situations in which emergency measures must be taken
     immediately because of time required for the preauthorization process, per 53
     FR 8282, March  14, 1988.  (It should be noted that not all  removals are
     emergencies.)   If a party is unable to determine whether sufficient time is
     available for obtaining preauthorization, he/she should contact the NRC or
     the Region for guidance.
 Source:
 Research:
Bill Ross
Mary Stevens
(202) 382-4645
C CEPP

  5. Sections 311/312: Transportation Exemption for Breakout Tanks in a Pipeline

  A transportation firm owns a pipeline that transports oil to an intermediate
  storage tank at their pumping station.  At die pumping station the oil is sold and
  sent by a secondary pipeline to the purchaser. The transportation firm also owns
  the secondary pipelines until the pipelines reach a valve in front of a purchaser's
  tank.

  The transportation  firm sends 10,000 gallons of oil to the intermediate storage
  tank. Of mis oil, 5,000 gallons are purchased by company A, so the transportation
  firm then directs the 5,000 gallons into the pipeline leading to company A. Is the
  oil stored in the  intermediate storage tank exempt from Sections 311 and 312
  reporting under Section 327 transportation exemption?
                        Intermeddle
                        Storage Tank

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 5. Sections 311/312: Transportation Exemption for Breakout Tanks in a Pipeline
   (Cont'd)

   Section 327 of SARA Title III exempts from any Title HI reporting
   requirement other than the Section 304 notification obligation substances or
   chemicals in transportation or being stored incident to transportation,
   including the transportation and distribution of natural gas.  In a final rule
   promulgated April 22,1988 (52 FR 13378,13385) the Agency interpreted this
   provision to exempt from Title in reporting the transportation of substances
   in pipelines. The Agency stated, 'Title DI does not apply to the transportation
   of any substance or chemical, including transportation by pipeline, except as
   provided in Section 304."

   As Title  III does not itself define "pipeline," the Agency will refer to the
   definition found in regulations implementing the Hazardous Materials
   Transportation  Act  (HMTA) and  promulgated by  the  Department of
   Transportation.  EPA believes the HMTA to be appropriate as a reference
   because of  Congress' explicit reference to that Act in the legislative history
   referring to the Section 327  transportation exemption.  In the Conference
   Report, Congress stated that  limiting the exemption for storage incident to'
   transportation to those chemicals under active shipping papers was consistent
   with the  HMTA.

   Department of  Transportation regulations implementing the HMTA define
   "pipeline" as "all parts of a pipeline facility through which a hazardous liquid
   moves in transportation, including, but not limited to, line pipe,  valves and
   other appurtenances connected to line pipe,  pumping  units, fabricated
   assemblies  associated with pumping units,  metering  and  delivery stations
   and  fabricated  assemblies therein, and breakout tanks."   (49 CFR 195.2.)
   "Breakout tanks" in turn, are defined under these same regulations as "a tank
   used to (a)  relieve surges in a hazardous liquid pipeline system or (b) receive
   and  store  hazardous liquid transported by pipeline for reinjection and
   continued transportation by pipeline."

   Because  the intermediate storage tank  owned by  the transportation  firm
   described above receives and  stores hazardous liquid transported by pipeline
   for  reinjection  and  continued  transportation  by  pipeline,  it  meets this
   definition  of  "breakout tank" included within  the  Department of
   Transportation definition of "pipeline." Therefore, EPA would interpret that
   the  oil contained  in such an  intermediate tank would  be exempt from
   reporting under the Section 327 transportation exemption.

Source:         Al  Garnett, Dept. of Transportation, OPS
Research:      John Ferris

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6. Section 303: Hazard Analysis
When calculating vulnerability zone distances, how would the quantity released
(QR) be handled for an extremely hazardous substance (EHS) in solution?

   If the EHS is in solution, a facility can make a rough estimate of the QR using
   equation (1) on page G-2 of the 'Technical Guidance for Hazards Analysis." 5
   the facility  has information on the physical properties of the EHS in solution,
   this data can be input into equation (1) to get the QR of the EHS.
   Equation (1) QR
   Where:
               QR
               MW
               K
               A
               VP

               R
               Tl
            (60 sec/min x MW x K x A x VP x 929
            R x (Tl + 273) x (760 mm Hg/atm) x 454 g/lb

            Rate of release to air (Ibs/min);
            Molecular weight (g/g mole);
            Gas phase mass transfer coefficient (cm/sec);
            Surface area of spilled material (ft2);
            Vapor pressure of material at temperature Tl (mm
            Hg);
            82.05 atm on 3/g mole K; and
            Temperature at which the chemical is stored
   If the physical properties of the EHS in solution are not available, the QR can
   be estimated using the physical properties of the EHS. This would reflect the
   QR of the EHS in its pure form.  Since the EHS is in solution, the QR would
   need to be multiplied by the mole fraction of the EHS in solution to accurately
   reflect the QR of the EHS.  If the facility only has the weight fraction of the
   EHS in solution, the weight fraction can be used instead of the mole fraction
   to estimate the QR of the EHS.
Source:
Vanessa Rodriguez/OTS
Craig Matthiesen/OTS
John Gustufson/OSWER-PS
Jim Buchert
(202) 475-9596
(202) 382-3694
(202) 382-3315
The  term "government  corporation"  appears in the Title  in definition of
"person" (Section 329).  How should  this term be defined  and, considering
Federal facilities  are exempt under Title in,  does this term include Federal
government corporations?

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7. Title HI General (Cont'd)

   In general, a "government corporation" refers to a corporation established
   and organized by a governmental unit and which is owned or controlled by a
   governmental unit.   Government corporations include  State, local and
   Federal corporations and are likely to be listed in the legal code of the relevant
   governmental entity.  For  purposes of Federal government corporations,
   Congress has defined the term "government corporation" in 31 U.S.C. Section
   9109.  Under this provision, a Federal government corporation refers to a
   "mixed-ownership government  corporation"  and  a  "wholly  owned
   government  corporation."   Section 9109 goes  on  to  list  the Federal
   government corporations  that  meet this definition (e.g., Amtrak, FDIC,
   Export-Import Bank, Commodity Credit Corporation, etc.).

   As to the second part of the question, whether the sovereign immunity of the
   U.S. government extends to Federal government corporations in the Title HI
   context, the answer is generally no, as Congress has not accorded government
   corporations the same immunity that the United States itself possesses. That
   is, Federal government corporations are usually invested with the power "to
   sue and be sued."  The U.S. Supreme Court has read this language to mean
   that Congress waived sovereign immunity for the government  corporation.
   While courts have limited the sovereign waiver resulting from the "sue and
   be sued" language in  specific contexts, the express inclusion of government
   corporations within the Title HI definition of "person" makes it unlikely that
   Congress  intended to relieve  Federal  government  corporations of the
   obligation to comply with the Act.  Thus Federal government corporations  as
   defined in 31 U.S.C. Section 9109, are subject to the requirements of Title m.

Source:         Ivy Main         (202) 382-7706
               Kirsten Engel      (202) 382-7706
Research:      Stephanie Portalski

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II. ACTIVITIES-OCTOBER 1988
  1. The RCRA/Superfund Hotline and Emergency Planning and Community
    Right-to-Know Hotline responded to 17,811 questions and requests for
    documents in October. The breakdown is as follows:

                            RCRA    Superfund   UST    CEPP
Information Calls
Call Document Requests
Written Document Requests
Referrals
6,666
1,743
116
1,166
1,443
149
1,958
1,389
1,814 = 11,881
814 = 4,095
274 = 390
279 = 1,445
Totals                       9,691        1,592     3347   3,181  = 17,811
A. RCRA/Superfund Hotline Activities

 2. On October 17, 24, and 31, Chris Bryant, Hotline Section Chief attended the
    Office of Solid Waste (OSW) Communications Workgroup meetings.

 3. On October 18, Laurie Huber, Hotline Information Specialist, reviewed the
    videotape entitled, "Beyond Business as Usual An Alternative to Land
    Disposal."

 4. On October 18 and 19, Denise Sines, Hotline Project Director met with Hubert
    Waiters, Office of Emergency and Remedial Response (OERR) Deputy Project
    Officer, concerning Hotline issues.

 5. On October 19, Dan Derkics, OSW briefed the RCRA/Superfund Hotline on the
    Bevill Wastes Exclusion.

 6. On October 20, Bill Fortune, OSW briefed the RCRA/Superfund Hotline on the
    First Third Land Disposal Restrictions.

 7. On October 24, Mary Stevens, Hotline Information Specialist attended the OUST
    briefing on Financial Responsibility Requirements.

 8. On October 24, Denise Sines, Hotline Project Director met with Thea McManus,
    Office of Solid Waste and Emergency Response (OSWER) Project Officer,
    concerning  Hotline issues.

 9. On October 27, Kurt Patrizi, Section Chief for the Safe Drinking Water Hotline
    briefed the RCRA/Superfund Hotline on the Safe Drinking Water Act.
                                    8

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

  10. On October 31, Denise Sines, Hotline Project Director met with Thea
     McManus, OSWER Project Officer, Hubert Walters, OERR Deputy Project
     Officer and Lynn Hansen, OSW regarding the technical device for the deaf
     (TDD).

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

  11. On October 4 and 18, the Title ffl Hotline staff attended the Preparedness Staff
     meeting on the status of program office activities.

  12. On October 5 and 12, the Title m Hotline staff attended the Title HI Outreach
     Subcommittee meeting on the status of Title in communications strategy.

  13. On October 6, Minda Sarmiento, Hotline Information Specialist attended  the
     EPA Workshop for Federal Facilities on complying with Title ffl.

  14. On October 6, Jon Roland, Hotline Information Specialist attended a
     teleconference by Peter Sandman of Rutgers University, on communicating
     risks to the general public.

  15. On October 11, Jim Styers, Hotline Information Specialist attended the Title HI
     Workgroup meeting on the status of Title in activities.

  16. On October 12, Jon Roland, Hotline Information Specialist attended a
     presentation by Virginia Polytechnical Institute (VPI) on the Hazards Analysis
     Research project that VPI is conducting for EPA.

  17. On October 6,13,20, 27 and 28, Denise Sines, Hotline Project Director, and
     Robert Costa, Hotline Section Chief, met with Lawrence Pratt, Office of Toxic
     Substances and Anastasia Watson, Preparedness Staff, on the status of the Title
     ffl Hotline.

  18. On October 17, Jim Styers, Hotline Information Specialist and Robert Costa,
     Hotline Section Chief, attended the conference call with EPA Regional
     Preparedness Coordinators on the status of Title ffl activities.

  19. On October 20, Kurt Patrizi, Section Chief for the Safe Drinking Water Hotline
     briefed the Title HI Hotline on the Safe Drinking Water Act and cross-cutting
     issues.

 20. On October 24, John Ferris, Hotline Information Specialist attended the
     conference call with the FEMA/EPA Regional Title m Coordinators on the
     status of Tide m activities.

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B. Emergency Planning and Community Right-to-Know Hotline Activities (Cont'd)

  21. On October 25, Stephanie Portalski, Hotline Information Specialist attended
     the Title HI Workgroup meeting on the status of Title HI activities.

  22. On October 26 and 27, Minda Sarmiento, Hotline Information Specialist
     attended the meeting on EPA Enforcement at GOCO facilities.

  23. On October 26, John Ferris, Hotline Information Specialist, and Robert Costa,
     Hotline Section Chief, attended a presentation by Dow Chemical Co., on the
     status of its outreach  activities for Title HI.

  24. On October 27, Jim Styers, Hotline Information Specialist attended the
     National Response Team meeting on the status of Federal preparedness and
     response activities.

  25. On October 27, Jim Buchert,  Hotline Information Specialist attended the
     conference call with EPA Regional Outreach Coordinators on the status of the
     Title in communications strategy.
                                      10

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 III.   ANALYSES OF QUESTIONS - October 1988
                                                      Grand  Total  = 14,630
                              RCRA/Superfund  Hotline
Summary of Calls by EPA Region
 Region 1
 Region 2
 Region 3
Region 4
Region 5
Region 6
Calls
RCRA
 6%
Region 7
 9%
Region 8
20%
Region 9
11%
Region 10
18%
10%
International Calls
 4%
 4%
12%
 5%
 0%
Manufacturers
Generators
Transporters
TSDFs
EPAHQ
EPA Regions
Federal Agencies
State Agencies
Local Agencies
Used Oil Handlers
USTO/O
4%
15%
1%
6%
1%
2%
2%
5%
4%
1%
13%
Consultants
Attorneys
Laboratories
Univ ./Researchers
Trade Assodatons
Insurance Co.'s
Environmental Groups
Press
Citizens
Other

25%
8%
2%
2%
1%
0%
1%
1%
5%
t%

General Information
§3010  Notification
§260.10 Definitions
427
8266 C Use Constituting Disposal
 105
§266 D HW Burned
 107
             for Energy Recovery
                                              S266 E Used Oil Burned
                                                           for Energy Recovery
                                              8266 F Precious Metal Reclamation
                                              Waste Minimization
  21
  57
                                               68
                                               21
                                              §266 G Spent Lead-Acid
                                                           Battery Reclamation	25
Subtitle D
Asbestos/PCBs/Radon
Corrective Action
Dioxins
Household Hazardous Waste
Infectious Waste
Liability/Enforcement
Minimum Technology
Mixed Radioactive Waste
Used Oil
635
126
65
21
31
62
83
16
31
105
                                                30
                                          11

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 RCRA-TSDF/264  and  265
A Scope/Applicability
B General Facility Standards
C Preparedness/Prevention
D Contingency Plans
E Manifest/Recordkeeping/Reportin<
F Ground-Water Monitoring
G Closure/Post Closure
H Financial Requirements
1 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., Btol Treatment

115
26
1 0
24
24
69
96
59
52
127
41
9
9
35
18
49
5
4

R Underground Injection
X Miscellaneous
§268 General
§268 Solvent & Dioxins
§268 California List Wastes
§268 Schedled Thirds
§269 Air Emissions Standards
§270 A General
§270 B Permit Application
§270 D Changes to Permits
§270 F Special Permits
§270 G Interim Status/LOIS
§271 State Programs
§124 Administrative Procedures
DOT Requirements
OSHA Reauirements/HW Training
Test Methods/HW Technologies
RCRA Document Requests
SUBTOTAL
4
28
177
170
129
290
5
53
49
37
13
64
56
6
1 4
41
115
1.743
8.409
Underground Storage Tanks
General
   678      §280 F Corrective Action Petroleum
            §280 G Corrective Action
48
Hazardous Substances
§280 H Out-of-Service/Closure
§280 I Financial Responsibility
§281 State UST Proorams
Liability
Enforcement
LUST Trust Fund
Other Provisions
UST Document Reouests
UST SUBTOTAL
1 9
143
153
36
20
12
15
3
1.389
3,347
Referrals
Referrals - EPA HQ
    70
Other Hotlines
   153
Regions
   150
State
   314
GPO/NTIS/PIC/ORD/Dockets
   414
Other
    65
SUBTOTAL
1.166
                                            12

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CERCLA
Access & Information Gathering
Administrative Record
Allocations from Fund
ARARs
CERCUS
Citizen Suits
Clean-Up Costs
Clean-Up Standards
Community Relations
Contract Lab Proaram (CLP)
Contractor Indemnification
Contracts
Definitions
Emergency Response
Enforcement
Exposure AssessVRisk Assess.
Federal Facilities
Fund Balancing
General
Grants
Hazardous Substances
Health/Toxics
MRS
Liability
Mandatory Schedules
Natural Resource Damages
NBARs
NCP
Notification
NPL
46
5
1 1
48
88
8
25
45
14
16
5
14
27
5
42
17
10
6
34
8
102
17
50
77
1
1
5
48
36
148
Off-Site Policy
On-OSite Policy
OSW
PA/SI
PRPs
Public Participation
Radon
RCRA Interface
RD/RA
Remedial
Removal
Response
RI/FS
RCD
FD
SARA Interface
Settlements
SITE Program
State Participation
State Program
Taxes
Title lll/Riaht-to-Know
CERCLA Document Reauests
CERCLA SUBTOTOAL

27
9
23
1 7
26
4
13
10
1 0
40
28
13
45
30
86
1 7
27
18
10
5
4
22
149
1 ,592

Written Request Responses
                                       TOTAL CALLS, DOCUMENT
                                          REQUESTS  and REFERRALS 14.630
                                      13

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Emergency  Planning Community Right-to-Know Information  Hotline
         Dally/Monthly Summary  Report - October  1988
Total Calls: 2,907
Distribution of Calls by EPA Regions
Region 1
Region 2
Region 3
Region 4
Region 5
International
Manufacturers
20 Food
21 Tobacco
22 Textiles
23 Apparel
24 Lumber & Wood
25 Furniture
26 Paper
27 Printing & Publishing
28 Chemicals
29 Petroleum & Coal
30 Rubber and Plastics
31 Leather
32 Stone. Clav & Glass
33 Primary Metals
34 Fabricated Metals
35 Machinery (Excluding Electrical
36 Electrical & Electronic Eguipmer
37 Transportation Eguipment
38 Instruments
39 Misc. Manufacturing
Not Able to Determine
iTotal Mfg. (%)

(Title III General
§301-3 Emergency Planning
SERCs
Notification
TPQs
Mixtures
Extremely Hazardous Substances
6%
10%
20%
12%
21%
0%

2.60%
0.00%
0.30%
0.20%
0.50%
0.20%
0.60%
1.80%
8.70%
1.50%
3.30%
0.10%
2.20%
1.00%
4.60%
1.30%
3.10%
1.90%
0.90%
0.70%
2.40%
38.00%l

310
312
129
105
103
20
332
Total Document Requests:
Total Written Requests:
Region 6
Region 7
Region 8
Region 9
Region 10
Unknown
Distributors
Handlers
Attorneys
Consultants/Engineers
Laboratories
Trade Associations
Public Interest Groups
Universities/ Academia
Insurance Companies
Hospitals
State Aoendes/SERC
Fire Departments
EPA
Local Officials
LEPC
Farmers
Federal Agencies
Media/Press
Union/ Labor
Citizens
Indians
Other

Total (%)

Delisting EHS
Exemptions

ITotal (%)
814
274
8%
5%
5%
10%
2%
1%
2.90%
9.70%
3.60%
14.00%
0.90%
1.90%
1.10%
2.60%
0.70%
1 .40%
3.90%
1.50%
2.50%
2.30%
3.20%
0.50%
1.10%
0.80%
0.00%
3.90%
0.20%
1.10%

7.00%|

13
21

23.00%l
                                 14

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§311/8312
General
MSDS Reporting Requirements
Tier l/ll Regulations
Thresholds
OSHA Expansion
Hazard Categories
Mixtures
Exemptions
iTotal (%)
§313
General
Form R
Thresholds
Phase II
Phase III
Workshop (Training)
Petitions
Health Effects
Database
Mass Balance Studv
iTotal (%)
Referrals
OSHA
Preparedness Staff
OTS Staff
RCRA/Superfund Hotline
Regional EPA
TSCA Hotline
Other
Total Referrals
383
276
227
278
103
34
37
122
33%l

508
236
155
45
2
5
16
3
1 1
3
22%l

83
1
1
92
9
9
84
279

Document Requests:
No. of Documents Reoue«ted:
814
2.043
Training: General
§305 Training Grants
§305 Emergency Systems Review
§126 (SARA) Training Regulations
ITotal (%)
CEPP: Interim Guide
Chemical Profile
NRT-1
Hazard Analysis
Risk Communication
Title III Workshops
Information Management
Prevention ARIP
Other
ITotal (%)
Trade Secrets
iTotil (%)
Enforcement
ITotal (%)
Liability
ITotal (%)
Release Notification
General
Notification Reauirements
Reoortable Quantities
RQSV8.TPQS
CERCLAVS.S304
Transportation
Exemptions
ITotal (%)
10
1 0
9
22
1%l
4
16
48
50
6
2
5
1
147
6%l
-38
0.80%l
41
0.90%|
3
0.06%l

74
36
52
16
50
7
22
5.80%t
15

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                            RCRA/Superfund Hotline
           National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
IV. PUBLICATIONS-OCTOBER 1988

 RCRA

   The following documents are available from the National Technical Information
   Service (NTIS) at (703) 487-4650.

    —Background  Document:  RCRA Subtitle C—Hazardous Waste  Management,
      Sections 3001 and 250.14 Infectious Waste. The order number is  PB89-102-594.

    —The 1986 National Screening Survey. The order number is PB89-106-058.

    —A Report to Congress; Solid Waste Disposal in the U.S., Volumes I and II.
      The order numbers are:  (1) PB89-110-381, and (II) PB89-110-399.

   Future Risk Research Strategies for the 1990 's.  Produced by the Science
   Advisory Board, is available by calling Cheryl Bentley at (202) 382-2552.

   Recycling, a brochure on solid waste recycling is available via the Cincinnati
   warehouse.  The order number is EPA/530-SW-88-050.
 CERCLA

   Superfund Exposure Assessment Manual.   Preprint copies are available from the
   CERCLA Docket

   Compendium of  Superfund Field Operations Manual:  Volume L  A  limited
   supply is now available from NTIS. The cost is $50.00 and the order number is
   PB88-181-557.

   Documenting Decisions Not To Take Cost Recovery Actions  with the OSWER
   Directive No. 9832.11 and Superfund Cost Recovery Strategy with the OSWER
   Directive No. 9632.13, are available via the Hotline. Route requests to Deborah
   Lebow(OS-510).
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                            RCRA/Superfund Hotline
           National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
V. FEDERAL REGISTER NOTICES-OCTOBER 1988
Former Notices with Open Comment Period
June 27,1988; 53 FR 24141
(availability of two documents
with request for review
and  comment)
July 19,1988; 53 £E 27268
(proposal to clarify the
Federally Permitted Release
exemption)
August 4,1988; 53 FR 29428
(proposed rule)
August 9,1988; 53 EE 30002
(policy statement)
This notice announces the availability of two
external review drafts for public review and
comment. The documents involve the
updated assessments for 22,7$ Tetrachlor-
dibenzo-p-Dioxin (2,3,7,8-TCDD). xhe
Agency made these documents available
for public review and comment until July 6,
1988.  Comments must have been
postmarked by October 5,1988.

This is an interpretative rule proposing
to clarify the Federally permitted release
exemption from CERCLA release, reporting
and liability provisions Sections 101(10), 103,
106, and 107 and also, Section 311 of the
Clean Water Act.  The official comment
period was extended to October 19,1988.

This proposed rule establishes arbitration
procedures for small Superfund Cost
Recovery claims under CERCLA Section
107(a) and Section 122(h). Comments must
have been submitted on or before October 3,
1988.

This notice solicits comments on additional
criteria for determining when the owner or
operator of a site is considered unable to pay
for addressing the contamination at a RCRA-
regulated site, and therefore, the site should
be proposed for the NFL.  Comments were
accepted on or before October 11,1988.
                                     17

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                             RCRA/Superfund Hotline
           National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
August 30,1988; 53 FR 33314
(proposed rule)
August 31,1988; 53 £R 33618
(notice of draft guidance, request
for comments)
September 2,1988; 53 £R 34173
(notice of proposed consent decree)
September 7,1988; 53 ER 34593
(notice of proposed consent decree)
The proposal revises the criteria toe
classification of solid waste ifopfff*1 facilities
and practices set forth in 40 CPU Part 257.
This proposed action would amend Part 257
by including information requirements for
certain solid waste disposal facilities and sets
forth specific requirements for municipal
solid waste landfills in Part 258. These
specific requirements include location
restrictions, facility design and operating
criteria, ground-water monitoring
requirements, corrective action, and
closure /post-closure care. Comments must
be submitted on or before November 30,
1988.

This notice presents draft guidance to States
for meeting the capacity assurance
requirements under Section 104(c)(9) of
CERCLA as amended by SARA. Comments
were accepted on or before October 17,1988.

This notice announces the lodging of a
proposed consent decree in U.S. v. Hoechst
Celanese Corporation.  Comments were
accepted by the Department of Justice (DOp
until October 2,1988.

This notice announces the lodging of a
proposed consent decree  in U.S. v. The
Tones Graham Brown Foundation, Inc.
Comments were accepted by DOJ until
October 7,1988.
                                     18

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                            RCRA/Superfund Hotline
           National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
September 8,1988; 53 FR 34758
(notice of correction)
September 9,1988; 53 FR 35110
(notice of proposed settlement)
September 13,1988; 53 FR 35373
(notice of proposed settlement)
September 13,1988; 53 £R 35373
(notice of proposed settlement)
September 15,1988; 53 FR 35836
(determination for final
authorization)
September 16,1988; 53 FR 36070
(notice of proposed rule)
This notice clarifies errors made in the final
authorization of South Carolina's hazard-
ous waste program, published on August 5,
1988 (53 FR 29461). This notice corrected the
effective date for the final authorization of
South Carolina, and extended the comment
period deadline to October 6,1988.

This notice announces a proposed
settlement under Section 122(h) of CERCLA
between EPA and Atlanta Gas Light
Company, Atlanta, GA, for the Rome Coal
Tar Site.  Comments were accepted until
October 9,1988.

This notice announces a  proposed settlement
under Section 122(h) of CERCLA between
EPA and Mr. J. Harvey Cleveland, Jr.
Comments were accepted until October 13,
1988.

This notice announces a  proposed settlement
between EPA and a potentially responsible
party (PRP) at the Clayton Ballfield Site,
Clayton, NC. EPA accepted comments
until October 13,1988.

Notice of tentative determination for final
authorization on application of Florida for
program revision. Comments were
accepted  by October 13,1988.

Notice to grant a one-time exclusion from
the lists of hazardous  wastes for Clay-
Equipment, Cedar Falls, Iowa waste stream.
Comments were accepted until October 31,
1988.
                                     19

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                            RCRA/Superfund Hotline
           National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
September 20,1988; 53 FR 36489
(notice of proposed settlement)
September 21,1988; 53 FR 36661
(notice of consent decree)
September 22,1988; 53 £R 36869
(notice of intent to delete from
theNPL)
September 22,1988; 53 ER 36883
(notice of availability)
September 23,1988; 53 FR 37051
(notice of proposed settlement)
September 23,1988; 53 £& 37005
(notice of extended comment
period)
September 26,1988; 53 £E 37344
(notice of proposed settlement)
This notice announces the proposed
settlement pursuant to Section 122(h) of
CERCLA for the Bostic Equipment Garage
Drum Site, Holly Ridge, NC.  Comments
were accepted on or before October 20,1988.

This notice announces the lodging of a
consent decree pursuant to CERCLA against
Goodyear Tire and Rubber Co., in the U.S.
District Court for Arizona. Comments were
accepted on or before October 31,1988.

The EPA announces its intent to delete a sitt
from the NFL. The site is the New Castle
Steel Site, New Castle County, DE.
Comments were accepted on or before
October 24,1988.-

The EPA announces availability of a draft
report entitled,  The Solid Waste  Dilemma:
An Agenda for Action.  Comments will be
accepted until November 21,1988.

Notice of proposed CERCLA settlement with
EPA and Space Park East, Ltd. Comments
were accepted until October 24,1988.

Comment period extended for the Federal
permitted release reporting exemption.
Comments were  accepted until October 19,
1988.

EPA proposes a 100% settlement with
Mr. Boykin and Mr. Halphen for clean-up
costs pursuant to CERCLA. Comments were
accepted until October 26,1988.
                                     20

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                            RCRA/Superfund Hotline
           National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
September 27,1988; 53 FR 37601
(notice of proposed rule)
September 27,1988; 53 FR 37643
(notice of proposed settlement)
September 28,1988; 53 Fg 37803
(notice of proposed petition)
September 28,1988; 53 FR 37808
(denial of proposed petition)
October Federal Registers

October 4,1988; 53 £B 38950
(final rule)
October 4,1988; 53 ER 38975
(OMB notice)
EPA proposes to grant a one-time exclusion
of certain solid wastes generated by Merck
& Co., Elkton, WV, from the lists of
hazardous wastes contained in 40 CFR
Section 261.31 and Section 261.32. Comments
will be accepted until November 14,1988.

EPA proposes settlement with Sherwin-
Williams for response costs at the Simpson
Road Drum Site, Atlanta, GA. Comments
were accepted until October 27,1988.

The EPA proposes to deny  a petition
submitted by Weirton Steel Corporation in
Weirton, VA, to exclude certain solid waste*
from the lists of hazardous  wastes.
Comments will be accepted until
November 14,1988.

The EPA is proposing to deny a petition
submitted by the Brush Wellman Corp.,
Bedford, OH, to exclude on a one-time basis,
certain solid wastes from the lists of
hazardous wastes. Comments will be
accepted until November 14,1988.
This final rule announces EPA's approval
of revisions made to Nebraska's hazardous
waste program. Comments will be received
on or before November 3,1988.

This notice announces Information
Collection Requests (ICRs) forwarded to OMB
for review from EPA pursuant to the
Paperwork Reduction Act. This notice
includes OMB's disapproval of portions of
the proposed Subtitle D landfill criteria. (53
FR 33315)
                                     21

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                             RCRA/Superfund Hotline
            National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
October 5,1988; 53 FR 39161
(proposed consent decree)
October 11,1988; 53 FR 39720
(final rule)
October 12,1988; 53 FR 39785
(notice of extension)
October 12,1988; 53 FR 39813
(consent decree notice)
October 14,1988; 53 FR 40316
(correction notice)
October 14,1988; 53 ER 40282
(consent decree notice)
This notice announces the lodging of a
proposed consent decree in the U.S. District
Court for the Southern District of Indiana in
U.S. v. Aresta. Inc., pursuant to RCRA.
Comments will be received by the DOJ until
November 4, 1988.

EPA promulgated final regulations changing
the statistical method required to be used
when a facility evaluates its ground-water
monitoring data. This rule changes the use
of Cochran's Approximation to the Behrens-
Fisher Student's t-test.  This rule finalizes
five different statistical methods.

This EPA  notice extends the comment period'
for the draft state hazardous waste capacity
assurance guidance.  The previous  deadline
for comments of September 30,1988 has been
extended until October 17,1988.

The DOJ will receive comments on a
consent decree which has been lodged against
Canadyne-Georgia Corp. et. al., pursuant to
CERCLA.  Comments will be accepted until
November 11,1988.

The EPA published a correction notice to the
proposed  identification and listing exclusion
(delisting) which appeared in the
September 27,1988 Federal Register.

The DOJ will receive comments on a
consent decree which has been lodged
pursuant to RCRA against Techalloy Co. for
LOIS  (Loss of Interim Status) violations.
Comments will be accepted until
November 13,1988.
                                      22

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           !                 RCRA/Superfund Hotline
           National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
October 17,1988; 53 FR 40692
(proposed rulemaking)
October 17,1988; 53 £R 40490
(notice of availability)
October 17,1988; 53 FR 40490
(proposed settlement)
October 17,1988; 53 FR 40499
(lodging of consent decree)
October 19,1988; 53 ER 40908
(notice of deletion from NFL)
This rulemaking proposes the application of
worker protection standards for employees
engaged in hazardous waste operations
pursuant to Section 126(f) of SARA.  This
proposal extends the OSHA requirements as
proposed in the August 10,1987 (52 FR 29620)
Federal Register, to State and local employees
in States without approved OSHA programs.
Comments must be received by
November 16, 1988.

The Agency is developing a Municipal
Settlement Policy to address issues related to
notifying and bringing municipalities mat
are responsible parties into the Superfund
settlement process. The  minutes from the
discussion group meeting of August 4,1988,  -
are available upon request. An additional
discussion group meeting was scheduled for
October 20,1988.

The EPA proposes to settle a claim under
Section 107 of CERCLA for response costs
incurred at the Summit National  Site in
Deerfield, OH.  Comments must be received
by November 16,1988.

The Agency is lodging a  consent decree
pursuant to CERCLA as proposed in U.S. v.
Fairchild Industries. Inc^et. al. for the
Limestone Road Site in Allegheny County,
MD. DOJ will accept comments until
November 16,1988.

This notice announces EPA's intention to
delete from the National Priorities List (NPL)
the Cooper Road Site, Voorhees Township,
NJ. Comments will be accepted until
November 18,1988.
                                     23

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                             RCRA/Superfund Hotline
            National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
October 19,1988; 53 FR 40910
(notice of deletion from NPL)
October 20,1988; 53 FR 41164
(final rule)
October 20,1988; 53 £S 41210
(notice to extend comment
period)
October 20,1988; 53 FR 41250
(lodging of consent decree)
October 20,1988; 53 £R 41280
(revision notice)
October 20,1988; 53 EB 41288
(proposed rule)
This notice announces EPA's intention to
delete from the NPL the Krysowaty Farm
Site, Voorhees Township NJ. Comments
will be accepted until November 18,1988.

This immediate final rule approves the State
of Kentucky's hazardous waste program
revisions, which authorize the regulation of
the hazardous waste component of
radioactive mixed waste.  Comments on
EPA's approval will be accepted until
November 21,1988.

This notice extends the comment period for
the proposed criteria for solid waste disposal
facilities (53 FR 33313). Comments will be
accepted until November 30,1988.

This notice announces the lodging of a
proposed consent decree pursuant to
CERCLA in U.S. v. Outboard Marine Corp.,
in the District Court for the Northern District
of Illinois.  Comments will be accepted until
November  19,1988.

This notice contains the revised priority list
of hazardous substances found at NPL sites.
This list is the "second 100" priority list of
hazardous substances, the first 100 having
been published in 52 FR 12866. No comment
deadline.

This proposed rule eliminates from the
mining waste exclusion most wastes from
the processing of ores and minerals. Also
included is the list of processing wastes
which are covered by the exclusion (Section
261.4(b)(7)). Comments will be accepted until
November 21,1988.
                                     24

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                             RCRA/Superfund Hotline
            National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
October 21,1988; 53 FR 41424
(partial consent decree notice)
October 24,1988; 53 FR 41649
(notice of correction)
October 24,1988; 53 £R 41615
(notice of availability)
October 24,1988; 53 FR 42492
(semi-annual regulatory agenda)
to
October 25,1988; 53 FR 43050
(notice of proposed consent
decree)
October 26,1988; S3 £R 43400
(proposed rule)
This notice announces the lodging of a
proposed partial consent decree pursuant to
CERCLA in U.S. v. Thomas Solvent
Company, et. al.. in the District Court for
the Western District of Michigan.
Comments will be received until
November 20,1988.

This notice publishes technical corrections to
the final rule regarding permit modifications
for hazardous waste management facilities
(53 £S 37912). These corrections affect
Section 270.42.

This notice announces the availability of
EPA's Report to Congress: Solid Waste
Disposal in the United States. This report
was prepared in response to the  1984
Hazardous and Solid  Waste Amendments to
the Resource Conservation and  Recovery
Act.

EPA revises and issues its semi-annual
regulatory agenda. The agenda  is published
keep interested parties informed of the
progress of EPA regulations.

The DOJ proposes a consent decree
against the Ford Motor Co., for remedial
actions at  the Speigelberg Landfill in
Greenoak  Township, MI. DOJ will receive
comments until November 24, 1988.

The EPA proposes rules implementing
the Congressionally-mandated prohibitions
on the underground injection of selected
hazardous wastes.  This  notice sets forth
restrictions for certain first-third wastes.
Comments must be received on or before
December 27,1988.
                                     25

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                            RCRA/Superfund Hotline
            National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
October 26,1988; 53 FR 43269
(notice of SAB meeting)
October 26,1988; 53 FR 43322
(final rule)
October 26,1988; 53 FR 43279
(notice of consent decree)
October 31,1988; 53 FR 43878
(final rule)
October 31,1988; 53 £E 43881
(final rule)
This notice announces that the Science
Advisory Board (SAB) will be holding a two-
day meeting of the Dioxin Panel on
November 29-30,1988.

The EPA promulgated the financial
responsibility requirements applicable to
owners and operators of underground
storage tanks containing petroleum under
Section 9003 (c) and (d) of RCRA.  This rule
establishes  requirements for demonstrating
financial responsibility and for taking
corrective action.  This rule becomes effective
January 24,1988.

The DOJ has lodged a consent decree in EPA
v. Burns, et. al.. for cost recovery pursuant to
Section 107 of CERCLA for costs incurred at
the "UMP" site in Gonic, NH. Comments
will be received until November 26,1988.

This final rule removes  the chemical iron
dextran (ferric dextran) from the list of
commercial chemical products in 40 CFR
Section 261.33.  This rule also removes iron
dextran from the list  of hazardous
constituents in Appendix Vffl of Part 261,
and from the list of CERCLA hazardous
substances  in Section 302.4.

This final rule removes  the chemical
strontium sulphide from the list of
commercial chemical products in 40 CFR
Section 261.33.  This  rule also removes
strontium sulphide from the list of
hazardous  constituents in Appendix vm of
Part 261, and from the list of CERCLA
hazardous  substances in Section 302.4
                                     26

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List of Addressees:
Devereaux Barnes, OS-330
Jim Berlow, OS-322
Frank Biros, OS-500
George Bonina, OS-310
John Bosky, EPA-Kansas City
Susan Bromm, OS-500
Karen Brown, PM-220
Diane Buxbaum, Region 2
Jon Cannon, OS-100
Jayne Carlin, Region 10
Fred Chanania, LE-132S
Richard Clarizio, Region 5
Kathy CoUier,  RTF, NC
Elizabeth Cotsworth, OS-343
Wayne Crane, PM-273F
Hans Crump, OS-210
Gordon Davidson, OS-500
Elaine Davies, OS-301
Truett DeGeare, OS-301
Bob Dellinger,  OS-332
Jeffery Denit, OS-300
Bruce Diamond, OS-500
Melinda Downing, DOE
Lee DuFief, TS-779
Karen Ellenberger, OS-100
Tim Fields, OS-210
Lisa Friedman, LE-132S
George Garland, OS-342
John Gilbert, EPA-Cin., OH
Al Goodman, EPA-Portland, OR
Uoyd Guerci, OS-500
Matt Hale, OS-340
Lynn Hansen, OS-305
Penny Hansen, OS-230
BiU Hanson, OS-220
Betti Harris, Region 7
Cheryl Hawkins, OS-200
Steve Hooper, OS-500
Irene Homer, WH-595
Barbara Hostage, OS-210
Hotline Staff
Bob Israel, TS-779
Phil Jalbert, OS-240
Alvin K. Joe, Jr., GRC
Garyjonesi, LE-134S
Jim Jowett, OS-210
Thad Juzczak, OS-100
Bob Kievit, EPA-Olympia, WA
Robert Knox, OS-130
Mike Kosakowski, OS-51
Walter Kovalick, OS-200
Tapio Kuusinen, PM-223
Steve Leifer, LE-134S
Steve Levy, OS-301
Henry Longest, OS-200
Sylvia Lowrance, OS-300
James Makris, OS-120
Joseph Martone, A-104
Scott McPhilamy, Region 3
Margaret Milligan, PM-214F
Royal Nadeau, Region 2
Mike Petruska, OS-332
Lawrence Pratt, ANR-464
Steve Provant, EPA-Boise, ID
Carl Reeverts, WH-550E
John Riley, OS-210
Suzanne Rudzinski, OS-343
Dale Ruhter, OS-320
William Sanjour, OS-332
Pam Sbar, LE-134S
Mike Shannon, OS-310
Mike Shapiro, TS-779
Elaine Stanley, OS-500
Jack Stanton, A-101
Steve Torok, EPA-Juneau, AK
Betty VanEpps, OS-240
Anastasia Watson, OS-120
Bruce Weddfe, OS-301
Steve Willhebn, Region 7
Dan Yunnan, OS-100
Tish Zimmerman, OS-220
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
                                         27

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