UNITED STATES ENVIRONMENTAL PROTECTION
                          WASHINGTON, D.C. 20460        -«— I V «-
                                             530R89105
                                 25 IS89
                                                              OFFICE OF
                                                    SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT:  Final Monthly Repori^-RCRA/Superfund Industrial Assistance
           Hotline and Emergency Planning and Community Right-To-
           Know Information and Title III Hotline Report for March 1989
FROM:     Thea McManus, Project
           Office of Solid Waste            NJ

           Hubert Watters, Deputy Project Officer
           Office of Emergency and Remedial Response

TO:        See List of Addressees

      This report is prepared and submitted in support of Contract #68-01-7371.


I. SIGNIFICANT CflTRSTTO^ ANT* RFSOT.VFTi ISSITFfi—MARCH 1989

 A.  RCRA

   1.  Mixed Waste and Land Ban

   The   owner/operator  of   a   facility  generates  a   liquid  mixed
   hazardous/radioactive waste. The waste  contains F006  waste as well as
   California list metals above the levels specified in RCRA Section 3004(d)(2). Is
   this waste subject to the land disposal restrictions? If so, which land disposal
   restrictions apply?

      According to the August 17, 1988, Federal Register (53 FR 31202), First
      Third waste mixed with radioactive waste is  moved to the Third Third
      schedule, whether that First Third waste has a  treatment standard
      associated  with it or not.  Section 268.10 identifies F006 waste as a First
      Third Waste, thus mixed waste which contains F006 will not be subject to
      the land disposal restrictions until May 8, 1990. However, this action only
      affects First Third wastes mixed with radioactive wastes.   Mixed waste
      containing spent solvents, dioxins and California  list  wastes or mixed
      radioactive/First Third waste that also contains spent solvents, dioxins, and
      California list waste (i.e., wastes prohibited under Sections 268.30, 268.31,
      268.32) would stall be subject to the land disposal restrictions associated with

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1. Mixed Waste and Land Ban (Cont'd)

   those wastes.  However, this  is only  true  in  unauthorized states  or
   authorized states that do not have mixed-waste authority.  Therefore, mixed
   waste which  contains F006 and California list metal wastes must only
   comply with  the land disposal  restrictions in Section 3004(d) of RCRA.
   Sections 3004(d) states that California list metal wastes were prohibited
   from land disposal as of July 8,  1987 unless the waste meets the statutory
   prohibition standards in  Section 3004(d)(2)(B).  However, if the State in
   which the facility is located is authorized for the base RCRA program, and
   the State has not yet received mixed waste authorization, the waste is not
   considered hazardous and the land ban does not apply.

Source:       Rhonda Craig    (202)382-4770
Research:     Kim Jennings    (202)382-3112
2.  Definition of Spent Solvent

The owner of a metal working facility uses a cutting oil to cool and lubricate
metals during a drilling process.  The cutting oil is purchased as a product
and consists of 80% 1,1,1-trichloroethane and 20% lubricating oil.  When spent,
the fluid is sent for disposal. Would this material meet the F002 listing found
in 40 CFR Section 261.31?

   This question was addressed originally in the RCRA/ Superfund Industrial
   Assistance  Hotline Monthly Report for April, 1988.  At that time, the
   Agency viewed the material in question as an F002 hazardous waste in
   accordance  with 40 CFR Section 261.31. Since that time, the Agency has
   amended the answer previously given to read as follows: The December 31,
   1985, Federal Register (53 FR 53316) specifies which materials are covered
   by the spent solvent listings in 40 CFR Section 261.31. One of the key  factors
   in meeting the F001-F0*05 hazardous waste listing is determining how or for
   what the material  was used.  In order to meet listings, the material must
   be used for its solvent properties. More specifically, the December 31, 1985,
   Federal Register specifies that "the spent solvent listings cover only those
   solvents that are used for  their solvent properties, that is, to solubilize
   (dissolve) or mobilize other constituents.   For example, solvents used in
   degreasing, cleaning, fabric scouring, as diluents, extractants, reaction
   and synthesis media, and  similar areas are covered under  the listings
   (when spent). A solvent is considered 'spent' when it has been used and is
   no  longer fit  for use without being regenerated, reclaimed, or otherwise
   reprocessed (50 FR 53316)."  However, the December 31, 1985, Federal
   Register also specifies that "process wastes where solvents were used as
   reactants  or ingredients in the  formulation of commercial  chemical
   products are not covered by the listing. The products  themselves are also
   not covered (50 Efi 53316)."  The 1,1,1-trichloroethane, in this circumstance
   is being used as a cooling ingredient in the formulation of product cutting
   oil.  The metal working facility is using the cutting oil to coat and lubricate

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2.  Definition of Spent Solvent (Coni'd)

   metals during their drilling operation.  When the cutting oil can no longer
   be used, it meets the definition of a spent material in 40 CFR 261.1(c)(l).
   However, even though the cutting  oil meets the definition of a spent
   material, it does not meet the spent solvent listing because the cutting oil
   formulation was not used as a solvent as described by the December 31, 1985
   Federal Register.  Likewise, the 1,1,1-trichloroethane is an ingredient in
   the cutting oil and this is not a use covered by the F001-F005 spent solvent
   listings found in 40 CFR Section 261.31. Therefore, the spent cutting oil in
   this circumstance does not meet the spent  solvent hazardous waste listings
   found in 40 CFR Section 261.31.

Source:        Ron Josephson   (202)475-6715
Research:     Steven Campbell  (202)382-3112
3.  KQ61 Waste

Emission control dust/sludge from the primary production of steel in electric
arc furnaces is listed as K061 waste under RCRA.  A facility owner uses an
electric arc furnace (EAF) to make steel billets.  Is the emission control dust
from this EAF a K061 waste?

   On December 18, 1978, (43 Efi 58959), EPA originally proposed the K061
   listing  under SIC code 3312 as "iron making: electric furnace  dust and
   sludge."   The  American  Iron  and Steel Institute commented  that the
   electric furnace process is only used for steel making and not iron  and steel
   making as listed in 1978.  In response to this comment,  EPA promulgated
   the listing on May 19, 1980, (45 FR 33124) as "emission control dust/sludge
   from  the electric furnace production of  steel."   The American
   Foundryman's  Society'then pointed out that the Agency had insufficient
   data to show that foundry  electric furnace emission control dusts and
   sludges were sufficiently similar in composition to warrant inclusion in the
   same listing.  Therefore, on November 12, 1980, the Agency modified the
   listing  of K061 to what it is today clarifying that the  listing applies to
   "primary" steel producers only (see 45 FR 74892).  The Agency intended only
   to distinguish steel production from other metal production processes (i.e.,
   foundry operations) when it added the word "primary" to the  November 12,
   1980, lilting (45 FR 74892). Foundry emission control dust is  excluded from
   the scope of K061 listing (see Figure 1 attached).

   In summary, steel producers using scrap metal in  an EAF  will generate
   K061 waste from their emission control equipment.  For  example, emission
   control  dust generated from  EAFs  used to produce "semi-finished goods"
   such as steel billets or rolled  steel, is regulated  as K061 waste when
   disposed. However, emission control dust and sludge from foundry

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3.  KQ61 Waste (Cont'd)

   operations that use EAFs remain excluded from the context of the K061
   listing and may only be identified as a hazardous waste if it exhibits any
   characteristics of hazardous waste per 40 CFR Part 261, Subpart C.

Source:        Robert Scarberry        (202) 382-5203
              Ron Josephson         (202) 475-6715
Research:     Renee Pannebaker      (202)382-3112

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SCRAP
METAL'
                                  Figure 1
                      STEEL  PRODUCTION
Bloom Billit
 and Stab
 Rolling
         Air Pollution
        Control Equip
          (wet.dry)
                                                            Finish
                                                            Product
                                                           Procssing
        Dust/Sludge
          K061
       RAW
    MATERIALS
                              FOUNDRY:
             Mold
           Pouring and
             Cooling

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4. Spent Solvents in Scintallation Cocktails
A nuclear power facility  owner/operator generates a low level radioactive
wastewater.  In order to measure the activity of the radionuclides in the
wastewater (a  measurement of radioactivity), the owner mixes four parts
radioactive wastewater to 19 parts of a scintillation cocktail (xylene with traces
of p-terphenyl).   In the  resultant mixture, beta  particles  from  the
radionuclides excite the p-terphenyl, which emits photons. The photons are
detected in a scintillometer which amplifies  and counts the photons  on a
photomultiplier tube.  This count provides a measurable level of radioactivity.
The xylene contributes nothing to  the above-described reaction and counting
mechanism, other than  providing a  suspension media.  After the  testing
procedure,  the  cocktail becomes a solid waste when it is discarded.  Is the
liquid waste identified as a F003  listed hazardous waste or only as a D001
ignitable characteristic waste?
  Radioactive
    Water
Scintillation
 Cocktail
Scintillometer
Hazardous
  Waste
 Radionuclides
 Xylene +
X>terphenyl
    With
photomutblier
    tube
    F003
    Spent
   Sokent
   In this particular process, the xylene is serving as a reaction media, in
   which the p-terphenyl and radioactive wastewater are suspended in order
   to allow a reaction to occur.  The reaction in the xylene medium permits
   actual photon counting to determine radioactive levels.  The preamble
   language of the December 31, 1985, Federal Register (50 FR 53316) clarified
   the listing of spent solvents, F001-F005:  tjhe spent solvent listings cover
   only those 'solvents' that are used for their solvent properties—that is, to
   solubilize (dissolve) or mobilize other constituents.  For example, solvents
   used for  degreasing, cleaning, fabric scouring, as diluents, extractants,
   reaction  and  synthesis  media...  ." A December 6, 1988, letter  from
   Devereaux Barnes, Director,  Characterization and Assessment Division,
   Office of Solid Waste to Arthur Moretta, EPA, Revion V,  reiterated this
   point: "The spent solvent listings cover those streams that are used to
   solubilize or mobilize other constituents." An argument that the xylene is
   used as a reactant or ingredient in the formation of a commercial chemical
   product and therefore not covered by the listing is not sound; the xylene is

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  4. Spent Solvents in Scintallation Cocktails (Cont'd)

    neither a reactant nor an ingredient  in a commercial chemical product.
    The used scintillation cocktail containing xylene is defined as EPA listed
    hazardous waste F003.

  Source:        Ron Josephson   (202)475-6715
  Research:     Todd Glass       (202)488-1487
  5. UST Release Detection

  An UST owner/operator chooses manual tank gauging as the sole method for
  release detection for a 400-gallon petroleum tank in accordance with 40 CFR
  Section  280.41.  Manual tank gauging involves taking measurements  of
  substance levels at the  beginning and  ending of a 36-hour period where no
  liquid is added or removed from the tank (see Section 280.43(b)).  Must the
  owner/operator take measurements every week where the tank is not used for
  a 36-hour period  or may he take measurements once a  month?  If the
  owner/operator takes measurements weekly at the beginning and ending of a
  36-hour period, should  he compare variations in his  measurements  to the
  weekly or monthly standard?

    Manual tank gauging must be done weekly for a period of at least 36 hours.
    This does not mean that an owner/operator has to shut down the operation
    of his or her tank for a 36-hour period during a normal five-day work week.
    The owner/operator may choose to manual tank gauge over the weekend
    (see 53 FR 37202).The owner/operator must compare variations between the
    beginning and  ending measurements to the  weekly standard.  Once a
    month,  the owner/operator should average the last four weekly measure-
    ments and compare  the average to the monthly standard.  The weekly
    standard will detect  any sudden  large releases and the monthly standard
    may catch gradual releases.  In  effect, if the  variation in measurements
    exceeds the weekly  or monthly standards, then the owner/operator is
    subject to the requirements of Subpart E, Release Reporting, Investigation
    and Confirmation per Section 280.43(b)(4).

  Source:        Tom Young      (202)465-7261
  Research:      Susan Brugler   (202) 382-3112
B. CEPP

  6. Code: III 311/2 E. Sections 311/312 Exemptions

  An oil corporation's pipeline facility contains three kinds of tanks.  One type is
  a breakout tank used to receive and store hazardous liquids transported by a
  pipeline for reinjection and continued transportation by the corporation's

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6.  Code:  in 311/2 E. Sections 311/312 Exemptions (Cont'd)

pipeline.  Another type is used to receive and  store hazardous liquid for
delivery to pipelines owned by another corporation.  The third type of tank
receives and stores hazardous liquids for delivery  to tank trucks and other
modes of transportation.  Would any tanks be covered by Section 327, the
transportation exemption to Title III?

   Section 327 of SARA  Title III exempts  from any  Title III 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, 1987, (52 FR 13378,13385) the Agency interpreted this
   provision  to exempt from  Title  III reporting  the  transportation of
   substances in pipelines.  The Agency stated,  "Title III does not apply to the
   transportation of any substance  or chemical,  including transportation by
   pipelines, 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 (DOT).
   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.  DOT regulations  implementing the HMTA
   define "pipeline"  as "all parts  of  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 statings and fabricated  assemblies therein, and breakout  tanks"
   under 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."  DOT
   includes the first two types of tanks within its definition of "pipeline" but not
   the third type  of tank.  The first type of tank is a breakout tank (49 CFR
   Section 195.2)  and as such is part of the pipeline regulated by DOT.  The
   second and third types of tanks are examples  of delivery stations.  The
   delivery station which injects the hazardous substance into someone else's
   pipeline is  part of the  "pipeline" under DOT regulations.  The delivery
   station  which  delivers the hazardous substance  to other modes  of
   transportation is called a terminal and is not  included within the DOT
   definition of pipeline. Terminals are thus not covered by the transportation
   exemption in Section 327 of SARA Title III.The transportation exemption
   would apply to  the substances in the first two types of tanks and they would
   be exempt from all of Title III except Section 304. The substance in  the
   third tank would not be covered by the transportation exemption. Section

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6. Code: III 311/2 E. Sections 311/312 Exemptions (Cont'd)

    327 of Title III exempts substances from the requirements of the Title,
   except Section 304, if those substances are in transportation or are stored
   incident to transportation.

Source:       Frank Fulton/DOT Pipeline Safety Officer   (202) 3664595
              Kirsten Engel/OGC     (202)382-7722
              Kathy Brody/CEPP      (202) 382-8353
Research:     John Ferris            (202)479-2449
              Jon Roland            (202)479-2449
              Jim Buchert           (202)479-2449
7. Section 311:  Information Request

Under Section  311, 40 CFR 370.30, a local emergency planning committee
(LEPC) can request a material safety data sheet (MSDS) from a facility for a
hazardous  chemical which is present  at the facility below 10,000 pounds.
Would the  facility need to  supply an MSDS to the LEPC if the material in
question was not a hazardous chemical as defined under 40 CFR 370.2?  For
example, could an LEPC request that a facility submit an MSDS for a chemical
which is used  in  a  research laboratory under the direct  supervision of a
technically  qualified individual?

   The LEPC can only request the MSDS for a substance which is defined as a
   hazardous chemical under 40 CFR 370.2.  Since  a substance  used in a
   research laboratory under the direct supervision of a technically qualified
   individual is not a hazardous chemical as defined by 40 CFR  370.2, the
   facility does not need to submit the MSDS for this substance to the LEPC.

Source:        Kathy Brody, CEPP      (202)475-8353
Research:     Jim Buchert           (202)479-2449

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II. ACTIVITIES — MARCH 1989

   1.  The RCRA/Superfund Hotline and Emergency Planning and Community
     Right-to-Know Hotline responded to 16,858 questions and requests for
     documents in March. The breakdown is as follows:

                                          Superfund   UST   CEPP
Information Calls
Call Document Requests
Written Document Requests
Referrals
4,038
1,898
308
777
Totals 7,021
RCRA/Superfund Hotline Activities
685
154
839
58
177
235
6,263
1,359
719
422
8,763
= 11,044
= 3,588
= 1,027
= 1,199
= 16,858
   2. On March 2, Denise Sines, Hotline Project Director, met with Hubert
     Watters, Deputy Project Officer, OERR, concerning Hotline special projects.

   3. On March 9, Denise Sines, Hotline Project Director, met with Thea
     McManus, Project Officer, OSW, concerning Hotline procedures.

   4. On March 13, Denise Sines, Hotline Project Director, met with Phil Jalbert,
     OERR, concerning a Hotline special project in support of OERR.

   5. On March 14 and March 20, Denise Sines Hotline Project Director, and
     Michelle Lamoreaux, Hotline Property Control Officer, met with the EPA
     Property Office regarding Hotline inventory.

   6. On March 16, Denise Sines, Hotline Project Director, and Chris Bryant,
     Hotline Section Chief, met with Thea McManus, Project Officer, OSW, and
     Kathy Bruneske, RCRA Docket, concerning a recycling project.

   7. On March 27, Denise Sines, Hotline Project Director, and Gwen Herron,
     Hotline Information Specialist, met with Betti Van Epps, OERR, regarding
     an ongoing OERR project.

   8. On March 29, Denise Sines, Hotline Project Director, met with Thea
     McManus, Project Officer,  OSW regarding Hotline operations and projects.

   9. On March 6, 13, 20 and 27 Chris Bryant and Joe Nixon, Hotline Section
     Chiefs, attended the OSWER Communications Meetings.

   10. On March 13, Chris Bryant, Hotline Section Chief, met with Betti Van
     Epps, OERR, regarding an ongoing OERR project.
                                    10

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

   11. On March 17, Becky Cuthbertson and Paul Mushovic, OSW, briefed the
      Hotline on the interim final rule on the standard for the Tracking and
      Management of Medical Waste.

   12. On March 20, Paul Mushovic, OSW, briefed the Hotline on the Interim
      Final Rule on Standards for the Tracking and Management of Medical
      Waste.

   13. On March 21, Joe Nixon, Hotline Section Chief, attended the OUST staff
      meeting.

   14. On March 28, Phil Jalbert, OERR, briefed the Hotline on the "Superfund
      Annual Report to Congress."

   15. On March 30, George Kleevic, Hotline Senior Information Specialist,
      briefed the Hotline on a regulatory/policy issue regarding the identification
      of Commercial Chemical Products as listed Hazardous Wastes.

B. Emergency Planning and Community Right-to-Know

   16. On March 1, Anita Bartera and Dan Irvin of the Title III Hotline staff
      attended the hearing on the Kansas City Exposition before the House
      Subcommittee on Employment and Housing of the Committee on
      Government Operations.

   17. On March 1, 8,15, & 22 the Title IH Hotline staff attended the Title III
      Outreach Subcommittee meetings on the status of Title III
      communications strategy.

   18. On March 1, 8,15, 22, & 29, Denise Sines, Hotline Project Director, and
      Robert Costa of the Tifle HI Hotline met with Lee Ann duFief/OTS and
      Laurie Solomon/CEPP on the status of the Title III Hotline.

   19. On March 7 & 21, the Title III Hotline staff attended the Preparedness
      Staff meetings on status of program office activities.

   20. On March 8, Robert Costa of the Title III Hotline staff attended the
      conference call with Regional Counsel on the status of Title III
      enforcement and legal issues.

   21. On March 10, Jon Roland of the Tile HI Hotline staff attended a meeting on
      the status of the baseline study.

   22. On March 13, Jim Buchert of the Title  in Hotline staff attended the
      conference call with the FEMA/EPA Regional Title III coordinators on
      status of Title in activities.
                                    11

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

   23.  On March 13-17, Jon Roland of the Title III Hotline staff participated in the
       Chemical Safety Audit training held in San Francisco, CA.

   24.  On March 14, Dan Irvin and Minda Sarmiento of the Title III Hotline staff
       attended the Title III Workgroup meeting on the status of Title III
       activities.

   25.  On March 14, Robert Costa of the Title III Hotline staff met with Phil
       Jalbert of OERR to discuss the process of printing and distributing
       documents.

   26.  On March 15, Robert Costa of the Title III Hotline staff attended the
       Regional Preparedness coordinators meeting on the status of Regional
       Title HI activities.

   27.  On March 21-22, the Title III Hotline staff participated in the training
       course on Section 313 compliance held by EPA.

   28.  On March 23, Dan Irvin and Robert Costa of the Title HI Hotline staff
       attended the workshop for trade associations on status of Title III outreach
       activities.

   29.  On March 23, Robert Costa of the Title HI Hotline staff attended TRIMS
       staff meeting on the status of Section 313 activities.

   30.  On March 28, Minda Sarmiento of the Title III Hotline staff attended the
       Title III Workgroup meeting on the status of Title III activities.

   31.  On March 30, Jon Roland of the Title III Hotline staff attended the
       conference call with  Regional outreach coordinators to discuss the status
       of Title HI outreach  activities.

   32.  On March 30, Minda Sarmiento of the Title III Hotline staff attended
       TRIMS staff meeting on the  status of Section 313 activities.
                                     12

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ANALYSES OF QUESTIONS—March 1989
                       RCRA/Superfund  Hotline
                                            Grand  Total = 8,095
Summary of Calls bv EPA Reqion
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
5%
9%
27%
10%
17%
8%
Region 7
Region 8
Region 9
Region 10
International Calls
4%
5%
12%
4%
0%
Calls
Manufacturers
Generators
Transporters
TSDFs
EPAHQ
EPA Regions
Federal Agencies
State Agencies
Local Agencies
Used Oil Handlers
USTOO
RCRA
General Information
§3010 Notification
§260.10 Definitions
§260.22 Petitions/Delisting
§261.2 Solid Waste Definition
§261.3 Hazardous Waste Definition
§261 C Characteristic Haz. Waste
§261 D Listed Haz. Waste
§261.4 Exclusions
§261.5 Small Quantity Generators
§261.6 Recycling Standards
§261.7 Container Residues
§262 Generator-General
§262 100-1000 ko/mo

§262 Manifest IMPflMtlon
§262 Accumulation
§262 Recordkeeoino & Reoortino,
§262 International Shipments
§263 Transporters
5%
14%
1 %
5%
2%
2%
2%
3%
2%
1%
10%

482
68
76
104
170
272
296
255
105
68
48
26
94
40
46
85
13
15
42
Consultants
Attorneys
Laboratories
Univ ./Researchers
Trade Associatons
Insurance Co.'s
Environmental Groups
Press
Citizens
Other

§266 C Use Constituting Disposal
§266 D HW Burned for Energy Rec.
§266 E Used Oil Burned for Energy
Recovery
§266F Precious Metal Reclamation
§266G Spent Lead— Acid Battery
Reclamation
Subtitle D: Municipal Solid Waste
Subtitle D: Other
Asbestos/PCBs/Radon
Corrective Action
Dioxins
Household Hazardous Waste
Medical/Infectious Waste
Liability/Enforcement
Minimum Technology
Mixed Radioactive Waste
Used Oil
Waste Minimization
30%
9%
3%
2%
1%
1 %
1%
0%
6%
1%

6
44

33
1 0

3
91
1 09
53
45
40
27
0
33
5
25
49
1 1
                                  13

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RCRA-TSDF/264 and 265
A Scope/Apolteabilitv
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
Underground Storage Tanks
General
$280.10 Applicability
§280.11 Interm Prohibition
§280.12 Definitions • General
UST
Regulated Substance
§280 B New UST Systems - General
§280.20 Performance Stds.
§280.21 Upqrading
§280.22 Notification
§280 C General Operating Reg.
§280 0 Release Detection
§280 E Release Rot. ft Investigation
83
1 6
5
5
15
46
61
56
32
72
23
3
5
36
8
38
5
8

187
97
3
46
50
25
10
9
28
14
7
73
1 1
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 Requirements/HW Training
Test Methods/HW Technologies
RCRA Document Requests
SUBTOTAL

§280 F Corrective Action Petroleum
§280 G Corrective Action
Hazardous Substances
§280 H Out-of-Service/Closure
§280 I Financial Responsibility
§281 State UST Programs
Liability
Enforcement
LUST Trust Fund
Other Provisions
UST Document Requests
UST SUBTOTAL

0
1 5
127
45
44
96
7
41
20
1 1
6
24
34
1
9
20
137
1 ,898
5,936

20

8
69
124
25
31
1 7
7
3
1 77
235

14

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CERCLA
Access & Information Catherine
Administrative Record
Allocations from Fund
ARARs
CERCUS
Citizen Suits
Clean-Up Costs
Clean-Uo Standards
Community Relations
Contract Lab Program (CLP)
Contractor Indemnification
Contracts
Definitions
Emergency Response
Enforcement
Exposure AssessJRisk Assess.
Federal Facilities
Fund Balancing
General
Grants
Hazardous Substances
Health/Toxics
HRS
Liability
Mandatory Schedules
Natural Resource Damaaes
NBARs
NCP
Notification
NPL
Written Reauest Responses
Referred to EPA Prooram Offices
Referred to otnar rariarU AMndM
Referred external* fatftte.
MMiitmionii. etc.)
Response Form Sum
Response Form StnVFOtA
43 Off-Site Policy
4 On-Site Policy
2 OSHA
20 PA/SI
5 8 PRPs
1 Public Participation
6 Radon
1 1 RCRA Interface
1 1 RD/RA
8 Remedial
4 Removal
5 Response
4 RI/FS
1 RCD
1 4 R3
8 SARA Interface
8 Settlements
2 SITE Program
9 State Participation
1 State Program
63 Taxes
1 6 Title lll/Right-to-Know
1 4 CERCLA Document Reouests
3 7 CERCLA SUBTOTOAL
0
2
0
35
15
129



50
10

50


Form Letter Sent/Need More Info.
Requests Filled • RCRA
198
• CERCLA
-UST
SUBTOTAL
308
Referrals
Referrals - EPA HQ
Other Hotlines
Regions
State
GPO/NTIS/PIC/ORD/Dockets
Other
SUBTOTAL
7
3
5
7
9
1
0
8
4
1 2
6
5
1 4
1 4
44
5
7
10
5
6
4
31
154
839

83
94
115
219
219
47
777

TOTAL CALLS, DOCUMENT
REOUESTS and REFERRALS
8,095

15

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Emtrgtncy  Planning  Community  Rlght-to-Know  Information  Hotline
          Daily/Monthly  Summary  Report—March  1989
Total Calls: 6,263
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. Clay & Glass
33 Primary Metals
34 Fabricated Metals
35 Machinery (Excluding Electrical
36 Electrical & Electronic Equipmer
37 Transportation Equipment
38 Instruments
39 Misc. Manufacturing
Not Able to Determine
(Total Mfa. (%)

(Title ill General
§301-3 Emergency Planning
SEFCs
Notification
TPQs
Mixtures
Extremely Hazardous Substances
6%
10%
17%
12%
21%
1%
-
2.10%
0.01%
0.70%
0.28%
0.57%
0.70%
1 .20%
1.70%
11.60%
1.80%
3.00%
0.14%
1.70%
1.90%
4.90%
1.30%
0.60%
2.00%
0.47%
0.67%
1.00%
39.00%l

446
280
203
76
96
27
303
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 Agencies/SERC
Fire Departments
EPA
Local Officials
LEPC
Farmers
Federal Agencies
Media/Press
Union/Labor
Citizens
Indians
Other

Total (%)

Delisting EHS
Exemptions

(Total (%)
1,359
422
5%
4%
2%
8%
2%
1%
3.70%
9.70%
4.80%
12.20%
0.78%
1.50%
0.86%
1.60%
0.54%
0.84%
2.40%
1.00%
2.00%
1.50%
1.70%
1.00%
1.00%
0.68%
0.17%
2.70%
0.00%
0.55%

5.10%

26
35

11.90%
                               16

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§31 1/5312
General
MSDS Reporting Requirements
Tier I/I I 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 Study
ITotal (%)
Referrala
OSHA
Preparedness Staff
OTS Staff
RCRA/Superfund Hotline
Regional EPA
TSCA Hotline
Other
Total Referrala
745
218
701
720
1 18
1 18
147
197
34%l

1.591
525
353
442
3
22
21 1
26
72
1
37%l

129
0
1
136
22
37
97
422

(Total Document ftoou««ts:
1 . 3 5 9l
Training: General
§305 Trainina 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
ITotal (%)
Enforcement
ITotal (%)
Liability
ITotal (%)
Release Notification
General
Notification Requirements
Reportable Quantities
RQsvs. TPQs
CERCLA vs. 5304
Transportation
Exemptions
ITotal (%)
1 2
5
1 1
57
1%l
9
22
26
50
1 8
5
6
5
246
4%|
40
0.45%l
79
0 . 9 0 %l
38
0.43%

1 12
70
68
38
69
1 0
33
5 %
17

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                           RCRA/Superfund Hotline
          National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
IV. PUBLICATIONS—MARCH 1989

 RCRA

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

   No Migration Variances To Hazardous Waste Land Disposal Prohibitions
   Guidance Manual For Petitioners;  PB89-160-006, $15.95 paper copy, $6.95
   microfiche.

   Underground Storage Tank Corrective Action Technology;  (EPA/625/6-87-015);
   PB87-171278; $28.95 paper copy, $6.96 microfiche.

   Evaluation of the B.E.S.T. TM Solvent Extraction Sludge Treatment
   Technology Twenty -Four Hour Test; (EPA/600/2-88/051); PB88-245907; $19.95
   paper copy, $6.95 microfiche.

   Spray Combustion Studies of Surrogate Hazardous Waste Incineration;
   (EPA/600/2-88/050); PB88-246095; $14.95 paper copy, $6.95 microfiche.

   Engineering Assessment of EDB Pesticide Destruction Technologies;
   (EPA/600/2-88/056); PB89-110118/AS; $19.95 paper copy, $6.95 microfiche.

   Determination and Enhancement of Anaerobic Dehalogenation:  Degradation
   of Chlorinated Organics in Aqueous Systems;  (EPA/600/2-88/054); PB89-
   110282/AS; $14.95 paper copy, $6.95  microfiche.


 The following documents are available from the RCRA Docket:

   Draft Subtitle D Risk Model Background Document

      •     Appendix B, Leachate Quality Submodel
      •     Appendix D, Dose I Risk Estimation Submodel
      •     Appendix G, Chemical Database
 The following documents are available from the Public Information
 Center:

  Background Information:  National Priorities List, Final Rule, March 1989,
  Publication HW-10.6.
                                    18

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RCRA (Cont'd)

 National Priorities List Supplementary Lists and Supporting Materials,
 March 1989, Publication HW-10.65.

 Descriptions of 101 Sites Placed on the Final National Priorities List in March
 1989, Publication HW-8.15.

 Descriptions of 273 Sites placed on the Final National Priorities List as of
 March 1989, Publication HW-8.16.
CERCLA

The following document is available from the Superfund Docket:

 Analysis Alternatives to the Superfund Hazard Ranking System
                                    19

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                           RCRA/Superfund Hotline
          National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
V. FEDERAL REGISTER NOTICES —MARCH 1989

Former Notices With Onen Comment Period
January 23,1989; 54 £E 3212
(proposed rule)
January 23,1989; 54 FR 3388
(proposed rule)
January 27,1989; 54 Efi 4132
(final rule)
January 30,1989; 54 FJJ 4334
(notice)
January 30,1980; 54 £B 4335
(notice)
EPA proposes to revise certain test
methods under Subtitle C. EPA is also
proposing to add several new test methods
which will appear in the Third Edition of
SW-846.  Comments will be received until
March 9,  1989.

EPA is proposing to designate 232
extremely hazardous substances (EHSs) to
the list of hazardous substances.
Comments must be submitted by March 24,
1989.

This rule establishes administrative
requirements for CERCLA funded
cooperative agreements, and Superfund
State Contracts necessary to implement cost
recovery actions. Comments on this
interim final rule will be accepted until
April 27,1989.

EPA announces a request for applica-
tions for Superfund research regarding the
development of biodegradation methods for
wastes at Superfund Sites.  Applications
must be received by March 1, 1989.

This is a notice of proposed settlement
under CERCLA between EPA and KEM
Manufacturing for response costs at Zenith
Chemical Company in Dalton, Georgia.
Comments will be received until March 1,
1989.
                                    20

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                           RCRA/Superfund Hotline
          National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
February 3,1989; 54 FR 5500
(proposed rule)
February 6,1989; 54 FR 5746
(proposed rule)
February 7,1989; 54 FR 6038
(notice of proposed consent decree)
February 7,1989; 54 FR 6039
(lodging of proposed consent
decree)
February 8,1989; 54 F_B 6153
(notice of extension)
February 16,1989; 54 £fi 7113
(notice)
February 21,1989; 54 £E 7488
(lodging of proposed consent decree)
EPA proposes to approve revisions to
Texas' State hazardous waste program.
Comments will be accepted until March 6,
1989.

EPA proposes regulations to set
standards for the Disposal of Sewage
Sludge.  These standards apply to publicly
owned treatment works (POTWs) and
privately owned treatment works that
generate or treat domestic sewage sludge.
Comments will be received until August 7,
1989.

The Department of Justice (DOJ) is
giving notice of a proposed consent decree
filed in  U.S. v. Rnyr^flrk Industries, et
al.  Comments will be accepted until
March 9, 1989.

DOJ announces the lodging of a
proposed consent decree pursuant to
CERCLA and RCRA in U.S. v. Stauffer
Chemical Co.. et al.  Comments will be
accepted until March 9, 1989.

This notice announces the  extension
of the HRS and NCP comment period to
March 23, 1989.

This notice announces the lodging of
proposed consent decree pursuant to RCRA
in U.S. v. Modern Plating Corp. Comments
will be accepted until March 18, 1989.

DOJ announces a lodging of a proposed
consent decree pursuant to CERCLA
Section  106 and Section 107 in ILS. v.
et al. DOJ will accept comments until
March 23,1989.
                                    21

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                           RCRA/Superfund Hotline
          National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
February 21,1989; 54 FR 7470
(proposed rule)
February 21,1989; 54 EE 7417
(final rule)
February 21,1989; 54 £E 7420
(final rule)
February 21,1989; 54 FJJ 7422
(final rule)
February 23,1989; 54 FR 7893
(proposed rule)
February 28,1989; 54 FJJ 8393'
(notice)
EPA is proposing to settle a claim
under Section 107 of CERCLA for response
costs incurred at the DOW Chemical Co.
Site in Midland, Michigan. Comments
must be received by March 23, 1989.

The State of Utah is receiving final
authorization to implement RCRA and
certain HSWA provisions. The effective
date is March 7,1989.

EPA is approving Michigan's amend-
ments to  its State hazardous  waste program
for implementation.  This authorization is
effective April 24,1989.

EPA is approving Wisconsin's amend-
ments to  its State hazardous  waste program
for implementation.  This authorization is
effective April 24,1989.

DOJ is lodging a proposed consent decree
in U.S. v. Seafab Metal Corn.  DOJ will
receive comments until March 24,  1989.

This is a  notice of a proposed  settle-
ment pursuant to CERCLA Section 122(h)
with Frank Redding at the Linecrest Way
Site, Decatur, Georgia.  Comments will be
accepted  until March 30, 1989.
Marc
March 3, 1989; 54 £B 10512
(final rule)
EPA is revising the NPL by adding eight
Federal facility sites to the Federal Section
of the NPL, expanding two Federal facility
sites already on the NPL and ^classifying
one site already on the NPL to a Federal
facility site.
                                    22

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                           RCRA/Superfund Hotline
          National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
March 13,1989; 54 EB 10520
(notice)
March 13,1989; 54 EE 10388
(extended comment period)
March 13,1989; 54 EB 10420
(notice)
March 15,1989; 54 EB 10713
(notice)
March 16,1989 54 EE 10986
(final rule)

March 17,1989; 54 EB 11203
(notice)
March 22,1989; 64 EB 11706
(final rule)
March 23,1989; 54 EB 11949
(notice)
EPA is announcing a policy for placing on
the NPL sites located on Federally-owned or
operated facilities that meet the NPL
eligibility criteria set out in the NCP.

EPA is extending the comment period to the
Notice of Proposed Rulemaking published
in the January 23,1989 Federal Register (54
EB3212).  The NPRM deals with the
incorporation of the 3rd edition of the SW-
846 into RCRA regulations, the update of
SW-846 and the mandate of the quality
control procedures.

EPA is announcing its proposed settlement
for response costs at the C.D. Buff Site in
Una, South Carolina. EPA is  also
requesting public comment on this proposed
settlement until April 12,1989.

This notice announces the OMB extension
for the RCRA Part A permit application
[extended to December 31,1991] and the
OMB extension of EPA Form 8700-12
[extended to June 30,1989].

EPA announces  approval of Kentucky's
hazardous waste program revisions.

This notice announces the deletion of the
New Castle Steel Site in New Castle,
Delaware  from the NPL.

EPA grants final exclusion from the lists of
hazardous wastes for wastes generated by
Roanoke Electric Steel Corporation,
Roanoke, Virginia in response to a
delisting petition.

This notice announces the deletion of the
Wade (ABM) Site in Delaware County,
Pennsylvania  from the NPL.
                                    23

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                           RCRA/Superfund Hotline
          National Toll Free #800/424-9346, Washington DC Metro #202/382-3000
March 24,1989; 54 EE 12247
(proposed rule)
March 24,1989; 54 EE 12326
(interim final rule)
will

March 27,1989; 54 Efi 12495
(notice)
March 28,1989; 54 EE 12659
(notice)
March 31,1989; 54 £B 13296
(final rule)
March 31,198*, 64 EE 13294
(correction)
EPA proposes to delete the Voortman Farm
Site from the NPL. Comments accepted
until May 1,1989.

This interim final rule identifies medical
wastes as well as sets forth the regulations
for implementing the demonstration
tracking program under the Medical Waste
Tracking Act. This rule is effective June 22,
1989, through June 22, 1991.  Comments
be accepted until May 23,1989.

This notice announces the lodging of a
consent decree pursuant to CERCLA in
U.S. vs. Virginia Electric and Power
Company in Virginia and requests
comments until  April 26, 1989.

This notice announces EPA's intent to
delete the Cecil  Lindsey site, located in
Jackson County, Arkansas, from the NPL
and requests comment on this action until
May 3,1989.

EPA revises the National Priorities List
(NPL) by the addition of 93 sites. Also,
4 sites are removed from the proposed
NPL. This results in 1,163 final and
proposed sites now on the NPL.

EPA makes  corrections to rules appearing
in the March 16, 1989, Federal Register
concerning Kentucky's final authorization
of the State hazardous waste management
program.
                                    24

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 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
 Steve Cochran, EH-562B
 Kathy  Collier, RTF, NC
 Elizabeth Cotsworth, OS-343
 Rhonda Craig, OS-333
 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
 Melinda Downing, DOE
 Lee DuFief, TS-779
 Karen Ellenberger, OS-100
 Terry Feldman, A-108
 Tim Fields, OS-210
 Lisa Friedman, LE-132S
 John Gilbert, EPA-Cin., OH
 Al Goodman, EPA-Portland, OR
 Lloyd Guerci, OS-500
 Matt Hale, OS-340
 Lynn Hansen, OS-305
 Penny Hansen, OS-230
 Bill Hanson, OS-220
 Cheryl Hawkins, OS-200
 Steve Hooper, OS-500
 Irene Homer, WH-595
 Barbara Ho«Mft, OS-210
 Hotline Staff
 Bob Israel, TS-779
 Phil Jalbert,  OS-240
Alvin K. Joe, Jr., GRC
Gary Jonesi, LE-134S
Jim Jowett, OS-210
Thad Juzczak, OS-100
Julie Klaas, OS-510
William Kline,  OS-322
Bob Kievit, EPA-Olympia, WA
Robert Knox, OS-130
Mike Kosakowski, OS-510
Walter Kovalick, OS-200
Steve Kovash, PM-214F
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
Chet McLaughlin, Region 7
Scott McPhilamy, Region 3
Royal Nadeau, Region 2
Mike Petruska, OS-332
Lawrence Pratt, ANR-464
Steve Provant, EPA-Boise, ID
Barbara Ramsey, A-104
Carl Reeverts,  WH-550E
John Riley, OS-210
Suzanne Rudzinski, OS-342
Dale Ruhter, OS-320
Debbie Rutherford, OS-400
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
Bruce Weddle, OS-301
Steve Willhelm, Region 7
Alex Wolfe, OS-342
Dan Yurman, 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
                                         25

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