. UNITED STATES ENVIRONMENTAL PROJECTION AGENCY WASHINGTON, D.C. 20460 530R90102 ••'AV I 0 I993 OFFICE OF MEMORANDUM SOLID WASTE AND EMERGENCY RESPONSE SUBJECT: Final Monthly Report—RCRA/Superfund Industry Assistance and Emergency Planning and Community Right-To-Know Information Hotline Report for February 1990 FROM: Thea McManus, Project Officer /\ Office of Solid Waste ' VT K> TO: See List of Addresses This Report is prepared and submitted in support of Contract #68-01-7371. I. SIGNIFICANT QUESTIONS AND RESOLVED ISSUES—JANUARY 1990 RCRA 1. Manifesting Requirements and EPA Identificaton Numbers Two facilities, one a nuclear power plant and the other a conventional coal burning power plant, are owned by the same company and occupy adjacent tracts of land divided by a river. The company owns a dam on the river that connects the two tracts. For safety reasons, the dam is not utilized for the transport of hazardous waste between the facilities. A public highway forms the boundary of the properties along one edge. Transport of hazardous waste between the facilities occurs via this public highway. The two facilities currently share one EPA identification number. Can the facilities continue to share one identification number or must each have its own number? Is a manifest required to transport hazardous waste between the facilities? RECEIVED MM 2 9 1990 ------- 1. Manifesting Requirements and EPA Identificaton Numbers (Cont'd) Each of the facilities will be required to obtain its own EPA identificaton number. Due to the safety hazard associated with using the dam to move wastes from one facility to the other, no effective company-controlled connecting right-of-way exists. The facilities are two individual sites. Hazardous wastes transported along the public highway from one site to the other must be accompanied by a manifest in accordance with 40 CFR 262.20, which states that a generator who transports, or offers for transportation, hazardous waste for off-site treatment, storage, or disposal must prepare a manifest. Source: Emily Roth, OSW (202) 382-4777 Research: Jenny Peters 2. Underground Storage Tank Exemptions A facility has a cogeneration process on-site whereby fuel oil #2 is burned to generate hot water, steam, and electricity. The hot water and steam are used on-site whereas the electricity is sent off-site and sold to the local utility. The fuel oil used to power the equipment is stored on-site in a 2,000 gallon underground storage tank. Would this tank be exempt from the underground storage tank regulations of 40 CFR Part 280, under the "consumptive use on-site" exclusion of 40 CFR Part 280.12? Yes, this underground storage tank system is exempt because the fuel oil is used consumptively "on the premises where stored." The preamble to the final rule codifying 40 CFR Part 280 (53 FR 37117) states that the exclusion applies to tanks "storing heating oil that is used at the same site." Although there is no discussion of the status of the byproducts from the consumption of this fuel oil, it does not matter whether the byproducts are themselves used on the premises or elsewhere. It is the comsumption of the fuel oil itself that qualifies the tank for the exemption. Source: Tom Schruben, UST (202) 382-5866 Research: Suzanne Wills ------- 3. Underground Storage Tank Heating Oil Tank Exclusion The definition of underground storage tank contains an exclusion for a "tank used for storing heating oil for consumptive use on the premise where stored." (40 CFR 280.12) Would a utility power plant site with an underground tank of No. 2 fuel oil that was periodically used to power an on-site electrical generator meet the exclusion if the resulting electricity was sold off-site? Yes, the tank would qualify for the exclusion because it meets the three necessary conditions: 1) the definition of "heating oil" includes No. 2 fuel oil; (53 FR 37117) 2) the definition of "consumptive use" means use on the premises, i.e., the oil is used at the same site where stored; (53 FR 37117) and 3) "on the premises where stored" means a tank located on the same property where the stored heating oil is used. (53 FR 37118) The off-site selling of the resultant electricity has no bearing on qualifying for this exclusion. Source: Tom Schruben, UST (202) 382-5866 Research: Cynthia Hess CERCLA 4. Release of an RO "Into the Environment" The April 4,1985 Federal Register (50 FR 13456) discusses releases "into the environment" in relation to requirements for notifying the National Response Center of a release of a hazardous substance in a quantity greater than or equal to its reportable quantity (RQ). According to mis preamble, "Examples of such releases are spills from tanks or valves onto concrete pads or into lined ditches open to the outside air, releases from pipes into open lagoons or ponds, or any other discharges that are not wholly contained within buildings or structures. Such a release, if it occurs in a reportable quantity (e.g., evaporation of an RQ into the air from a dike or concrete pad), must be reported under CERCLA." (50 FR 13462) The parenthetical example might lead one to believe that the amount that evaporated would have to be greater than or equal to an RQ to be reportable. Is this correct? No. In the May 24,1989 Federal Register (54 F.E 22524) EPA addresses this subject when it states, "The Agency considers the stockpiling of an RQ of a hazardous substance to be a release because any activity that involves the placement of a hazardous substance into any unenclosed containment structure wherein the hazardous substance ------- 4. Release of an RO "Into the Environment" (Cont'd) is exposed to the environment is considered a release." (54 FR 22526) EPA further clarifies its position: "Thus, the placement of an RQ of a hazardous substance in an unenclosed structure would constitute a 'release' regardless of whether an RQ of the substance actually volatilizes into the air or migrates into surrounding water or soil." Source: Ivette Vega, OERR (202) 475-7369 Research: Peter Neves SARA 5. SARA Sections 302. 304. and 311/312 Reporting Ranges A facility has a mixture which contains extremely hazardous substances. The Material Safety Data Sheet (MSDS) for the mixture only indicates a range of concentration for its components. For the purposes of reporting under SARA Sections 302, 304, and 311/312 of SARA Title m, should the facility owner/operator report based on the lower, upper, or mid-point concentration of each component? If the MSDS for the mixture indicates only a range of concentration for its components, then for purposes of reporting under SARA Sections 302, 304, and 311/312 of SARA Title HI, the facility owner/operator should use the upper bound concentration when determining the weight of each component in the mixture. Such reporting is consistent with the purpose of Title HI, which is to maximize local communities' opprtunities to know about local chemicals and to plan for emergencies. Source: Kathy Jones, CEPPO (202)475-8353 Kathy Bishop, CEPPO (202) 382-7912 Research: Sicy Jacob 6. SARA Sections 302 and 311/312 Reporting Requirements The Department of the Army leases property from a private citizen and begins to operate a laboratory on the property. The Army totally controls the laboratory. The owner of the land only has a real estate interest in the land and does not control the activities at the laboratory. The owner of the land has no employees at the property. Under SARA sections 302 and 311/312, who is responsible for reporting? ------- 6. SARA Sections 302 and 311/312 Reporting Requirements (Cont'd) The Emergency Planning and Community Right-to-Know Act (Title HI of SARA) does not require reporting by Federal facilities because Federal facilities are not covered in the definition of person under the Act. The Army would have no reporting responsibility under SARA section 302 or sections 311/312. [The Department of the Army has issued a statement urging its facilities to report, but if its facilities do not report they cannot be held liable under SARA Title HI.] However, SARA section 302 provides that the owner or operator of a facility which is subject to the emergency planning requirements must comply with the regulations under that section. Therefore, the owner is responsible for reporting under SARA Section 302. Under SARA section 311/312 the owner or operator of a facility which is required to prepare or have available MSDS's must comply with the requirements of 40 CFR 370, Subpart B. The owner of the facility whose only connection to the facility is a real estate interest and has no employees at the facility would not be required to have MSDS's. Therefore, neither the owner nor the operator (i.e., the Army) would be liable for reporting. Source: Kathy Bishop, CEPPO (202) 382-7812 Kathy Jones, CEPPO (202) 475-8353 Research: Rob Rule 7. SARA Section 313 Reporting Requirements A manufacturing facility was shut down on January 30, 1989. Between January 1, 1989 and January 30, 1989, the facility manufactured a toxic chemical in excess of 25,000 pounds, and 10,000 hours had been worked at the facility. After the manufacturing activities ceased on January 30,1989, six employees remained to work on electrical wiring and warehouse activities. For purposes of reporting under SARA Section 313, does the facility have to add the working hours of the 6 employees to the 10,000 hours worked during January, 1989 in order to determine if 20,000 hours or more were worked at the facility during calendar year 1989? In calculating the working hours, the manufacturing facility has to include the 6 employees who worked after the facility ceased actual manufacturing operations, regardless of the type of work they did [the number of hours worked do not necessary correlate directly to the ------- 7. SARA Section 313 Reporting Requirements (Cont'd) manufacturing activities]. If, during the 1989 calendar year, the total working hours at the facility is equal to or in excess of 20,000 hours, the facility owner and operator is subject to reporting for that calendar year, (see 40 CFR 372.22) Source: Sam Sasnett, OTS (202) 382-3821 Research: Ming Tan 8. SARA Section 313 Reporting Requirements A facility owner sold a quarter of his plant to another company. This purchase transaction was finalized January 15, 1989. The quarter of the plant that was sold was moved to its new location in April of the same year. During the period between sale and move, the entire facility kept operating. For purposes of reporting under SARA Section 313, is the original owner responsible for 1989 reporting for the part of the facility that was sold? From the time of the purchase transaction on January 15, there are two separate facilities with two non-related owners and separate operators. Therefore, the original owner only needs to report three quarters of the facility, if s/he manufactured, processed, or otherwise used a toxic chemical equal to or in excess of a threshold amount for 1989. (NOTE: The original owner would also include in threshold and release calculations any activities that went on in that part of the facility that was sold from the beginning of January 1989 up to the time of the purchase transaction.) The owner of the quarter of the facility also needs to report, if that facility exceeds the reporting threshold during the period of January 15,1989 thru April 1989. Once the facility is moved to its new location, a new threshold determination must be made for the remainder of the calendar year. However, the original owner and purchaser may agree (in their purchase transaction, for example) that the original owner will prepare and submit reports that reflect activities that occured at the portion of the facility that was sold prior to its moving to the new location. Source: Sam Sasnett, OTS (202) 382-3821 Research: Ming Tan ------- 9. SARA Section 313 TRI Identification Numbers The owner/operator of Poultry Products submits a Form R in 1987 and receives a TRI identification number. The following year Poultry Products is bought by Allen Family Foods and reports the new name on its 1988 Form R. Is the TRI identification number changed to reflect the change in the facility name? No, the TRI identification number is established by the first Form R submitted by the facility. This identification number is retained by the facility even if the facility changes ownership and name. This identification number will stay with this facility as long as the facility location does not change. The TRI identification number remains the same even if the facility changes names, production processes, SIC codes, etc. The only time the TRI identification will change is when the facility physically moves to a new location. Source: Doug Sellers, OTS-IMD (202) 382-3598 Research: Rob Rule ------- H. ACTIVITIES—FEBRUARY 1990 1. The RCRA/Superfund Hotline and Emergency Planning and Community Right-to-Know Hotline responded to 17.563 questions and requests for documents in February. The breakdown is as follows: RCRA Superfund UST CEPP Information Calls 4,795 1,278 815 5,117 = 12,005 Call Document Requests 2,864 200 200 651 = 3,915 Written Document Requests 275 15 2 24= 316 Referrals (Calls & Documents) *967 **360 = 1327 Totals 8,901 1,493 1,017 6,152 =17,563 A. RCRA/Superfund Hotline Activities 2. On February 2, 20 and 27, Denise Sines, Hotline Project Director, attended the OSWER Communications Meetings. 3. On February 5, Denise Sines, Hotline Project Director and Craig Campbell, Senior Information Specialist, met with Bruce Diamond, OWPE, to discuss Hotline operations and related enforcement program issues. 4. On February 6, Gwen Herron, Senior Hotline Information Specialist, attended the OUST staff meeting. 5. On February 7, Todd Gold, OSWER, briefed the Hotline on the revised NCP. 6. On February 13, Joe Nixon, Senior Program Manager, attended the OSWER Communication meeting. 7. On February 14, Cynthia Hess, Hotline Information Specialist, briefed the Hotline on how court decisions affect EPA policy. 8. On February 21, Kevin Dunn, Hotline Information Specialist, briefed the Hotline on issues related to the retention of the Bevill Exclusion when co-fired with hazardous waste in boilers and industrial furnaces. "This number represents AH referrals received by the RCRA/Superfund/UST section of the Hotline. This number represents All referrals received by the CEPP section of the Hotline. ------- B. Emergency Planning and Community Right-to-Know Information Hotline Activities 9. On February 28 Kevin Dunn, Hotline Information Specialist, briefed the Hotline on different aspects of the Boiler and Industrial Furnace Rules. 10. On February 1, Rob Rule, Ming Tan, and Henley Jones, Hotline Information Specialists, attended a meeting with Eileen Gibson/OTS- ETD on the uses of the TRI data. 11. On February 1, Bill Whittington, Hotline Information Specialist, attended a screening of the SARA Title HI video "What it Means to You." 12. From February 5 to February 8, Dan Irvin, Hotline Senior Information Specialist, attended a Chemical Safety Audit training course in Philadelphia, PA. 13. On February 6, Tami McNamara, Hotline Information Specialist, attended the Title III Implementation Workgroup meeting on the status of Title in activities. 14. On February 6, Ken Mitchell, Hotline Section Chief, attended the TRI Analysis Coordination Subgroup meeting on TRI data quality and uses. 15. On February 7, Ken Mitchell, Hotline Section Chief, met with Laurie Solomon/CEPPO and Lee Ann duFief/OTS-ETD on the status of the Title HI Hotline. 16. On February 7, Tami McNamara, Hotline Information Specialist, attended the Title HI Outreach Subcommittee meeting on the status of the Title HI communication strategy. 17. On February 7, Rob Rule, Hotline Information Specialist, attended the Regional Section 313 coordinators conference call on the status of Section 313 activities. 18. On February 12, Ken Mitchell, Hotline Section Chief, Jim Buchert, Dan Irvin, and Bill Whittington, Hotline Information Specialists, attended the Section 313 Interpretive Guidance Subgroup meeting on the interpretation of questions related to Section 313. ------- 8. Emergency Planning and Community Right-to-Know Information Hotline Activities (cont'd) 19. On February 13, Ken Mitchell, Hotline Section Chief, attended a meeting with Kathy Franklin/OTS-ETD and Anne Giesecke/EAD at the National Food Processors Association on Section 313 and the food processing industry. 20. On February 14, Ken Mitchell, Hotline Section Chief, attended a meeting with Laurie Solomon/CEPPO and Lee Ann duFief/OTS-ETD on the status of the Title ffl Hotline. 21. On February 14, Tami McNamara, Henley Jones, and Bill Whittington, Hotline Information Specialists, attended the TRIMS staff meeting on Earth Day and a screening of the Title HI video "What it Means to You." 22. On February 24, Tami McNamara, Hotline Information Specialist, attended the CEPPO staff meeting on the status of program office activities. 23. On February 21, Dan Irvin, Hotline Senior Information Specialist, attended the TRIMS staff meeting on the status of Section 313 activities. 24. On February 21, Ming Tan, Hotline Information Specialist, attended the Title HI Outreach Subcommittee meeting on the status of the Title HI communication strategy. 25. On February 21, Bill Whittington and Henley Jones, Hotline Information Specialists, attended a meeting on the response structures in place for responding to oil spills. 26. On February 22, Sicy Jacob, Hotline Information Specialist, attended the NRT meeting on the status of Federal Preparedness and Response activities. 27. On February 22, Dan Irvin, Hotline Senior Information Specialist, attended the Regional Title III Outreach Coordinators conference call on the Status of the Title HI communication strategy. 28. From February 27 to February 28, Tami McNamara, Hotline Information Specialist, attended a meeting sponsored by EPA, the Delaware State Emergency Response Commission, and the Chemical Manufactures Association, entitled "The LEPC, Making it Work." 10 ------- 8. Emergency Planning and Community Right-to-Know Information Hotline Activities (cont'd) 29. On February 27, Sicy Jacob, Bill Whittington, and Henley Jones, Hotline Information Specialists, attended the Regional Section 313 coordinators conference call on the status of Section 313 activities. 30. On February 28, Ken Mitchell, Hotline Section Chief, met with Laurie Solomon/CEPPO on the status of the Title m Hotline. 31. On February 28, Ming Tan, Bill Whittington, and Henley Jones, Hotline Information Specialists, attended the Title III Outreach Subcommittee meeting on the status of the Title El communication strategy. 11 ------- III. ANALYSES OF QUESTIONS—February 1990 RCRA/Superfund Hotline Summary of Calls by EPA Region Total = 11,411 Region 1 Region 2 Region 3 Region 4 Region 5 Region 6 6.1% 8.4% 20.4% 1 1 .4% 16.3% 10.0% Region 7 Region 8 Region 9 Region 10 International Calls 4.0% 10.0% 14.4% 4.3% 0.0% Calls Manufacturers Generators Transporters TSDFs EPAHQ EPA Regions Federal Agencies State Agencies Local Agencies Used Oil Handlers USTO/O RCRA General Information §3010 Notification §260.10 Definitions §260.22 Petitions/Delistinq §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 kg/mo §262 Manifest Information §262 Accumulation §262 Recordkeeping & Reporting §262 International Shipments §263 Transporters 4.4% 14.7% 0.8% 5.0% 0.3% 2.4% 2.6% 3.3% 1 .8% 0.8% 7.6% 461 88 79 45 124 356 371 350 151 71 104 50 116 37 70 84 29 13 39 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 §266 F Precious Metal Reclamation §266 G Spent Lead— Acid Battery Reclamation Subtitle D: Municipal Solid Waste Asbestos/PCBs/Radon Corrective Action Dioxins Household Hazardous Waste Medical/Infectious Waste Liability/Enforcement Minimum Technology Mixed Radioactive Waste Used Oil Waste Minimization Solid Waste Recycling 30.0% 8.7% 2.0% 2.0% 0.6% 0.7% 0.7% 0.7% 8.0% 2.0% 5 53 49 7 1 8 201 78 70 8 28 114 26 3 20 91 80 25 12 ------- RCRA-TSDF/264 and 265 A Scope/Applicability B General Facility Standards C Preparedness/Prevention D Contingency Plans E Manifest/Recordkeeping/Rptg. 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., Biol 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 Upgrading §280.22 Notification §280 C General Operating Red. §280 D Release Detection §280 E Release Rpt. & Investigation 75 23 6 20 20 16 79 45 1 1 27 50 20 10 5 40 8 35 10 171 110 0 31 55 30 20 14 20 30 6 86 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 2 5 1 0 218 70 82 160 8 47 25 30 9 15 42 6 17 35 2,864 7,659 20 30 8 80 35 25 25 9 10 200 1015 13 ------- CERCLA Access & Information Catherine Administrative Record Allocations from Fund ARARs CERCUS Citizen Suits Clean-Up Costs Clean- Up Standards Community Relations Contract Lab Program (CLP) Contractor Indemnification Contracts Definitions Emergency Response Enforcement Exposure Assess./Risk Assess. Federal Facilities Fund Balancing General Grants Hazardous Substances Health/Toxics MRS Liability Mandatory Schedules Natural Resource Damages NBARs NCP Notification NPL Written Request Responses Hotline Responses Referred to EPA Program Offices Referred to other Federal Agencies Referred externally (state, organizations, etc.) Response Form Sent Response Form Sent/FOIA Form Letter Sent/Need More Info. Requests Filled - RCRA - CERCLA -UST SUBTOTAL 45 10 5 33 98 8 17 31 10 10 6 10 15 7 22 27 14 5 70 16 62 25 26 18 8 5 3 45 40 186 0 27 6 0 0 0 0 275 15 2 325 Off-Site Policy On-Site Policy CSHA PA/SI PRPs Public Participation Radon RCRA Interface RD/RA Remedial Removal Response RI/FS ro SARA Interface Settlements SITE Program State Participation State Program Taxes Title lll/Riqht-to-Know CERCLA Document Requests CERCLA SUBTOTOAL Referrals Referrals - EPA HQ Other Hotlines Regions State GPO/NTIS/PIC ORD/Dockets Other SUBTOTAL 10 3 2 15 19 3 4 7 5 18 17 8 21 18 133 1 1 19 18 12 8 50 200 1,478 17 173 160 259 100 170 55 934 14 ------- Emergency Planning Community Right-to-Know Information Hotline Daily/Monthly Summary Report—February 1990 CEPP Total Calls: 5,117 Total Document Requests: 651 Total Written Requests: 24 Distribution of Calls by EPA Regions Region 1 Reaion 2 Region 3 Region 4 Region 5 International 10.3% 10.6% 17.4% 7.7% 23.8% 0.02% Region 6 Region 7 Region 8 Region 9 Region 10 Unknown • 7.2% 4.4% 3.1% 10.5% 3.4% 1.1% 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 ITOTAL Mffl. (%) (Title III General §301-3 Emergency Planning SERCs Notification TPQs Mixtures 4.40% 0.02% 1 .50% 0.60% 1.10% 0.60% 2.10% 2.60% 1 1 .60% 2.70% 2.90% 0.30% 1 .70% 3.00% 4.40% 1 .70% 2.80% 2.30% 1 .50% 1 .90% 1.10% 50.32%| 291 70 59 34 61 28 Distributors Handlers Attorneys Consultants/Engineers Laboratories Trade Associations Public Interest Groups Universities/Academia Insurance Companies Hospitals State Agenties/SERC Fire Departments EPA Local Officials LEPC Farmers Federal Agencies Media/Press Union/Labor Citizens Indians Other SUBTOTAL (%) Delisting EHS Exemptions (SUBTOTAL (%) 2.60% 4.60% 5.20% 13.40% 1 .00% 1 .20% 0.10% 2.00% 0.09% 0.86% 1 .80% 1 .00% 2.30% 1 .60% 1 .00% 0.20% 1.10% 0.60% 0.06% 3.50% 0.06% 3.90% 6.00%l 29 25 (423) 8.70%l Extremely Hazardous Substances OJST/EPCRA 15 ------- §311/5312 General MSDS Reporting Requirements Tier I/I I Regulations Thresholds OSHA Expansion Hazard Categories Mixtures Exemptions ISUBTOTAL (%) (2,267) §313 General Form R Thresholds Phase II Phase III Workshop (Training) Petitions Health Effects Database Mass Balance Study ISUBTOTAL (%) d,826) Referrals osw Preparedness Staff OTS Staff RCRA/Superfund Hotline Regional EPA TSCA Hotline Other REFERRALS SUBTOTAL 476 290 821 467 33 43 61 76 44.70%| 728 759 112 54 1 5 99 18 50 0 36.10%I 88 1 2 83 22 36 128 360 DOCUMENT REQUEST SUBTOTAL 651 WRITTEN REQUESTS SUBTOTAL 24! Training; General §305 Training Grants §305 Emergency Systems Review §126 (SARA) Training Regulations ISUBTOTAL (%) (11) 0.19%l CEPP: Interim Guide Interim Guide 1 1 Chemical Profile NRT-1 Hazard Analysis Risk Communication Title III Workshops Information Management 3 12 8 1 0 0 Prevention ARIP Other [SUBTOTAL (%) (43) 2.64%| Trade Secrets ISUBTOTAL (%) (18) 0.40%l Enforcement [SUBTOTAL (%) (8) 0.20%| Liability ISUBTOTAL (%) (2] 0.04%l Release Notification General Notification Requirements Reportable Quantities RQsvs.TPQs CERCUWs. 5304 Transportation Exemptions 76 29 53 28 28 2 12 ISUBTOTAL (%) (228) 4.34%l RCRA/SUPERFUND/UST/EPCRA CALLS, DOCUMENT REQUSTS AND REFERRALS GRAND TOTAL 17.5631 16 ------- IV. Publications - February. 1990 RCRA The following documents are available through the RCRA Docket at (202) 475-9327: "Report on Minimum Criteria to Assure Data Quality." The Order No. is EPA/530-SW-90-021. "Decision-Makers Guide to Solid Waste Management, Volume I." The following documents are available from the RCRA/Superfund Hotline: "Environmental Fact Sheet: Plastics: The Facts About Production, Use, and Disposal." The Order No. is EPA/530-SW-90-017A. "Environmental Fact Sheet: The Facts About Plastics in the Marine Environment." The Order No. is EPA/530-SW-90-017B. "Environmental Fact Sheet: Plastics: The Facts on Source Reduction." The Order No. is EPA/530-SW-90-017C. "Environmental Fact Sheet: The Facts on Degradable Plastics." The Order No. is EPA/530-SW-90-017D. "Environmental Fact Sheet: The Facts on Recycling Plastics." The Order No. is EPA/530-SW-90-017E. "Office Paper Recycling: An Implementation Manual." The Order No. is EPA/530-SW-90-001. "RCRA Section 3016-1988 Inventory of Federal Hazardous Waste Activities Final Report." 17 ------- RCRA (cont'd) The following documents are available from the sources indicated: "Wastepaper Recycling: Programs of Civil Agencies Waned in the 1980's" is available from the General Accounting Office at (202)275-6241. "Title 40: Code of Federal Regulations" Parts 190-299, dated July 1989, is available from the Government Printing Office at (202) 783-3238. "Overview of Selected EPA Regulations and Guidance Affecting POTW Management" is available from Ohio State University as follows: Instruction Resource Center (IRC) 1200 Chambers Rd., Rm. 310 Columbus, OH 43212 (614) 292-6717 The Order No. is 136-U and the cost is $3.32 per copy. CERCLA The following document is available through the CERCLA Docket at (202) 382-3046: "Hot to Obtain Superfund Information." The OSWER Directive No. is 9200.5-405/FS. The following documents are available from the sources indicated: "OSWER Comparative Risk Project, Executive Summary and Overview" is available from the Office of Research and Development at (513) 569-7562. The Order No. is EPA/540/1-89/003. 'Title 40: Code of Federal Regulations" Parts 300-399 is available from the Government Printing Office at (202) 783-3238. The Order No. is 869-007-00145-1. "Assessment of Technologies for the Remediation of Radioactively Contaminated Superfund Sites: Interim Final Draft" is available from the Office of Radiation Programs at (202) 475-8386. The Order No. is EPA/520/1-89/004. 18 ------- RCRA/Superfund Hotline National Toll Free # 800/424-9346, Washington DC Metro # 202/382-3000 V. FEDERAL REGISTER NOTICES - FEBRUARY 1990 Former Notices With Open Comment Period October 17,1989 (54 FR 42568) (notice) October 31,1989 (54 FR 46012) (proposed policy) December 12,1989 (54 FR 51071) (request for comment) December 20,1989 (54 FR 52190) (proposed rule) December 20,1989 (54 FR 52207) (proposed rule) This notice announces the availability of 30 Draft lexicological Profiles for 48 hazardous substances prepared by the Agency for Toxic Substances and Disease Registry (ATSDR) under the requirements of CERCLA. Comments were accepted until February 16, 1990. The EPA issued a proposed guidance document to implementSectionll9of CERCLA. Section 119 provides the President with discretionary authority to indemnify response action contractors for negligent releases arising out of response action activities at sites on the NPL and removal action sites and to indemnify certain other persons as provided expressly by statute. A December 27,1989 Federal Register notice extended the comment period until February 2,1990. Comments were accepted until February 2,1990. EPA published the "Interim Policy on CERCLA Settlements Involving Municipalities or Municipal Wastes" (referred to as the Municipal Settlement Policy) to inform the public and to solicit public comment. Comments were accepted until February 12,1990. Under the Clean Air Act, EPA proposed the addition of two test methods to Appendix A, Part 60: Method 23 "Determination of Polychlorinated Dibenzofurans from Stationary Sources;" and Method 26 "Determination of Hydrogen Chloride Emissions from Stationary Sources." Method 26 is used to measure hydrogen chloride emission from municipal waste combustion facilities. Comments will be accepted until March 5,1990. Under the Clean Air Act, EPA proposed to add a new performance specification to allow the performance testing of carbon monoxide continuous emissions monitoring systems at municipal waste combustion facilities. Comments will be accepted until March 12, 1990. 19 ------- RCRA/Superfund Hotline National Toll Free # 800/424-9346, Washington DC Metro ft 202/382-3000 December 20,1989 (54 FR 52209) (proposed guidelines) December 20,1989 (54 FR 52251) (proposed rule) December 27,1989 (54 FR 53184) (extension of comment period) December 28,1989 (54 FR 53381) (notice of proposed consent decree) January 2,1990 (55 FR 62) (notice of proposed settlement) January 2,1990 (55 FR 63) (notice of proposed settlement) January 5,1990 (55 FR 501) (notice) Under the Clean Air Act, EPA proposed to add regulations to limit emissions from new, modified, and reconstructed municipal waste combustors. Comments will be accepted until March 1,1990. Under the Clean Air Act EPA proposed to add regulations to limit emissions from new, modified, and reconstructed municipal waste combustors. Comments will be accepted until March 1,1990. EPA extended the comment period on the proposed guidance document for Superfund Response Action Contractor Indemnification published in the October 31, 1989 Federal Register. (54 FR 46012) Comments were accepted until February 2,1990. This notice announces the lodging of a proposed Department of Justice (DOp consent decree pursuant to CERCLA Section 122 in U.S. v. E.I, du Pont Nemours & Company for the 2.7 acre Dupont Impoundment located within the larger 12 acre Lawrence Todtz Superfund Site inCamanche,Iowa. A Tanuary 29.1990. Federal Register notice extended the comment period until February 28, 1990. Comments were accepted until February 28,1990. This notice announces that under Section 122(h) of CERCLA, EPA has agreed to settle claims for past response costs at the Berrien Products Co., Inc., site, Nashville, Georgia, with W. Wesley Moore, individually, and as President of Berrien Products Company, Inc. Comments were accepted until February 1,1990. This notice announces that under Section 122(h) of CERCLA, EPA has agreed to settle claims for past response costs at Nashville Pesticide site, Nashville, Georgia with W. Wesley Moore, individually, and as President of Berrien Products Company, Inc. Comments were accepted until February 1,1990. This notice announces the lodging of a proposed partial consent decree pursuant to CERCLA in U.S. v. Fairchild Industries. Inc.. concerning the Limestone Road site in AlleghenyCounty,Maryland. Comments were accepted until February 4,1990. 20 ------- RCRA/Superfund Hotline National Toll Free # 800/424-9346, Washington DC Metro # 202/382-3000 January 5,1990 (55 FR 502) (notice) January 8,1990 (55 FR 663) (notice of proposed settlement) January 9,1990 (55 FR 788) (notice of proposed consent decree) January 9,1990 (55 FR 788) (notice of proposed consent decree) January 11,1990 (55 FR 1115) (notice of proposed consent decree) January 18,1990 (55 FR 1726) (notice) This notice announces the lodging of a proposed consent decree pursuant to CERCLA in U.S. v. Browning-Ferris Industries of Vermont. Inc.. concerning the Old Springfield Landfill site in the Town of Springfield, Windsor County, Vermont. Comments were accepted until February 4,1990. This notice announces that EPA is proposing to enter into two administrative settlements under CERCLA authority to resolve claims for recovery of costs incurred at Silresim Chemical Corporation Superfund site in Lowell, Massachusetts. Comments were accepted until February 7,1990. This notice announces the lodging of a proposed DOJ consent decree pursuant to CERCLA in U.S. v. General Electric Company concerning the F.T. Rose Disposal Pit site in Lanesborough, Berkshire County, Massachusetts. Comments were accepted until February 8,1990. This notice announces the lodging of a proposed DOJ consent decree pursuant to CERCLA in U.S.v. American Greetings Corp. concerning a hazardous waste site located at the former site of Pristine, Inc. in Reading, Ohio. Comments were accepted until February 8,1990. DOJ is lodging a proposed consent decree pursuant to CERCLA in U.S. v. Yaworski. Inc.. et al.. and State of Connecticut v. Yaworki. Inc.. et al.. for cleanup of the Yaworski Lagoon Superfund site in Canterbury, Connecticut. Comments were accepted until February 10,1990. This notice announces that the Municipal Settlement Discussion Group will meet on February 7, 1990, to facilitate public comment on the interim Superfund Municipal Settlement Policy. Comments were accepted until February 12,1990. 21 ------- RCRA/Superfund Hotline National Toll Free # 800/424-9346, Washington DC Metro # 202/382-3000 January 18,1990 (55 FR1741) (notice of proposed consent decree) January 18,1990 (55 FR 1770) (notice) January 19,1990 (55 FR 1881) (notice of proposed consent decree) January 23,1990 (55 FR 2248) (proposed rule) January 23,1990 (55 FR 2267) (notice of proposed consent decree) January 23,1990 (55 FR 2268) (notice of proposed consent decree) This notice announces the lodging of two proposed DOJ consent decrees in U.S. v. Union Carbide Chemicals and Plastics Company. Inc.. concerning the Reich Farm site, in Dover Township, Ocean county, New Jersey. Comments were accepted until February 17,1990. Agency for Toxic Substances and Disease Registry announces the expected availability of the ATSDR Medical Waste Tracking Act Report, "The Public Health Implications of Medical Waste: A Report to Congress" for review and comment. The draft report is expected to be available to the public on or about January 31,1990. Comments will be accepted 60 days starting from the actual date of release to the public. This notice announces the lodging of a proposed DOJ consent decree pursuant to CERCLA in U.S. v. William K. Martin, et al.. ("BMF/Petro Products"), concerning the BMF/Petro Products reclamation facility in Athens, Alabama. Comments were accepted until February 18, 1990. EPA is proposingtograntapetition submitted by Hoechst Celanese Corporation (formerly Virginia Chemicals Company), Bucks, Alabama, to exclude certain solid wastes generated at its facility from the lists of hazardous wastes contamedin40CFR261.31 and261.32. Comments were accepted until March 9,1990. DOJ is lodging a proposed consent decree pursuant to CERCLAinUS. v. Browning-Ferris Industries. Chemical Services. Inc. etal.. for the Quanta Resources Corp., site in Edgewater, New Jersey. Comments were accepted until February 23,1990. DOJ is lodging a proposed consent decree pursuant to RCRA Section 3008 in U.S. v. Envirite Corporation. Comments were accepted until February 23,1990. 22 ------- RCRA/Superfund Hotline National Toll Free # 800/424-9346, Washington DC Metro # 202/382-3000 January 26,1990 (55 FR 2691) (notice) January 26,1990 (55 FR 2776) (proposed rule) January 29,1990 (55 FR 2847) (proposed rule) January 29,1990 (55 FR 2873) (notice of proposed settlement) January 29,1990 (55 FR 2890) (extension of Comment period) January 31,1990 (55 FR 3237) (notice) This notice announces EPA's intent to grant an exemption to the Midwest Division of National Steel Corporation of Portage, Indiana, for the continued injection of waste pickle liquor (K062) which is restricted from land disposal under RCRA. Comments were accepted until February 26,1990. OSHA is proposing a new rule containing the accreditation procedures for training programs required in 29 CFR1910.120. Comments and information must be received on or before April 26,1990. Requests for public hearings must be received on or before March 27,1990. EPA is re-opening the comment period on a portion of the proposed delisting decision for Bethlehem Steel Corporation, Lackawanna, New York, which appeared in the Federal Register on April 7,1989. (54 FR 14101) This re-opening of the comment period pertains only to the proposed health-based level for benzo(a)pyrene. Comments were accepted until February 20,1990. This notice announces a proposed settlement under Section 122(h) of CERCLA for response costs at the Edmond's Salvage Yard site, Dixie County, Florida, with Commercial Metals Company and Florida Power and Light. Comments were accepted until February 28, 1990. DOJ is extending the comment period on the proposed consent decree in U.S. v. E.I. duPont de Nemours and Company. This notice of proposed consent decree was originally published in the Federal Register on December 28,1989. Comments were accepted until February 28, 1990. This notice announces an EPA workshop on the materials separation requirements in the new source performance standards and emission guidelines for municipal waste combustors that were proposed in the Federal Register on December 20,1989. (54 FR 52209 and 52251) The workshop is open to public attendance, but, not to participate. The workshop was held on February 15, 1990. 23 ------- RCRA/Supeifund Hotline National Toll Free # 800/424-9346, Washington DC Metro # 202/382-3000 January 31,1990 (55 FR 3258) (notice) This notice announces that EPA will transfer to its contractor, Science Applications International Corporation, information submitted to EPA under RCRA Section 3007 for development and maintenance of a data base for the Medical Waste Demonstration Program. The transfer of data occurred no sooner than February 7, 1990. February Federal Register Notices February I,1990 (54 FR 3481) (notice) February 8,1990 (55 FR 4478) (public meeting notice and extension of comment period) February 8,1990 (55 FR 4400) (reopening comment period with notice of data availability) This notice announces the temporary dosing of the RCRA docket for facility reconstruction. The staff will continue to receive written comments on the proposed exclusion (Hoescht Celanese Corporation). The docket was dosed from February 5,1990 through February 9, 1990. This notice announces a public meeting to receive oral comments on the proposed guidance document to implement Section 119 of CERCLA. Also, the period for submission of written comments was extended to February 27,1990. The meeting was held on February 20,1990 in Washington, D.C. This notice reopens the comment period for amending Subtitle C of RCRA hazardous waste testing and monitoring regulations by incorporating the Third Edition of 'Test Methods for Evaluating Solid Waste Physical/Chemical Methods", (SW-846). EPA is considering in addition to the option of promulgating the rulemaking as proposed, (Janaury 23,1989, 54 FR 3212) a number of technical modifications and/or darification to the Third Edition of SW-846, and the indusion of specific QC procedures. Additionally, the Agency is considering deleting Appendices HI and X. (40 CFR Part 261) Comments will be accepted until March 12,1990. 24 ------- RCRA/Superfund Hotline National Toll Free # 800/424-9346, Washington DC Metro # 202/382-3000 February 9,1990 (55 FR 4680) (notice) February 9,1990 (55 F£ 4679) (notice) February 9,1990 (55 FR 4604) (immediate final rule) February 12,1990 (55 FR 9915) (lodging of consent decree) February 12,1990 (55 FR 4916) (lodging of consent decree) February 13,1990 (55 FR 5136) (final rule) This notice announces the Science Advisory Board's Environmental Engineering Committee (EEC) meeting. The meeting will examine a number of topics including leachability initiative, municipal solid waste research, and remedial clean-up in the Superfund Program. The EEC meeting was held February 27-28, 1990, in Washington, DC. This notice announces the availability of a Workshop Report on Use of Human Evidence in Risk Assessment, commenting on the scientific foundation for possible changes in the human, evidence sections of EPA's 1985 Carcinogen Risk Assessment Guidelines. (September 24,1986,51 FR 33992) It is available for viewing at the Public Infornation Reference Unit, EPA Headquarters Library and available for purchase through ORD (Order No. EPA/625/3-90/017). EPA is approving specified RCRA non-HSWA final authorization revisions to the New Mexico hazardous waste management program. Final authorization will be effective April 10,1990,unless adverse public comment shows the need for further review. Comments will be accepted until March 11,1990. This notice announces the lodging of a DOJ consent decree pursuant to CERCLA in U.S. v. Allied Signal. Corporation, et al. This notice announces the lodging of a DOJ consent decree pursuant to CERCLA in U.S. v Great Lakes Development Company, et al. The Agency for Toxic Substances and Disease Registry is finalizing regulations dealingwiththeconduct of ATSDR health assessments and health effects studies. These new regulations, at 42 CFR Part 90, set forth procedures for ATSDR to conduct health assessments under CERCLA and RCRA. These regulations also include procedures for persons to request ATSDR to conduct health assessments, provisions for the notification of parties of the results of health assessments and health effects studies, and provisions for cost recovery accounting. These rules became effective February 13, 1990. ------- RCRA/Superfund Hotline National Toll Free # 800/424-9346, Washington DC Metro # 202/382-3000 February 14,1990 (55 FR 5265) (notice) February 14,1990 (55 FR 5340) (final rule) February 15,1990 (55 FR 5502) (notice) February 16,1990 (55 FR 5600) (notice) February 20,1990 (55 FR 5861) (notice and request for comments) EPA is giving notice of its intent to grant an exemption to Allied-Signal, Inc., Danville, Illinois, for the continued injection of EP-Toxic Arsenic wastes (D004), otherwise prohibited from land disposal under RCRA. Comments will be accepted until March 26,1990. EPA is amending the F019 listing to exclude wastewater treatment sludges from the zirconium phosphating step, when such phosphating is an exclusive process in the aluminum can washing process, because the Agency believes that such sludges do not pose a substantial hazard to human health or the environment and should not be regulated as hazardous waste. In addition, the Agency is removing these zirconium phosphating sludges from the list of hazardous substances under Table 302.4. This regulation became effective February 14,1990. Notice of Agency information collection activities under OMB review. The EPA collection activities include: hazardous waste manifest for generators, transporters, and disposal facilities; financial responsibility requirements for hazardous waste managementfacilities; and use of groundwater data in delisting decisions. EPA published a compliance schedule for Kentucky to modify its hazardous waste program in accordance with 40 CFR Section 271.21(g) to adopt the Federal program modifications. EPA has received a complete application from the State of Mississippi reguesting final approval of its underground storage tank (USD program under Subtitle I of the Resource Conservation and Recovery Act(RCRA). EPA has reviewed Mississippi's application and made the tenative decision mat their program satisfies all requirements necessary for final approval. A public hearing will be held April 3,1990. Comments wil be accepted until April 13,1990. 26 ------- RCRA/Superfund Hotline National ToU Free # 800/424-9346, Washington DC Metro # 202/382-3000 February 21,1990 (55 FR 6045) (notice) February 21,1990 (55 FR 6154) (final rule) February 22,1990 (55 FR 6308) (notice and request for comments) February 22,1990 (55 FR 6309) (notice and request for comments) February 27,1990 (55 FR 6847) (consent decree clarification) This is a notice of Agency information collection activities under OMB review. The EPA information collection activities include: RCRA Hzardous Waste Permit Application Part A; and Notification of Regulated Waste Material. This rule amends the National Contingency Plan (NCP) by revising the National Priorities List (NPL) in 40 CFR Part 300, Apendix B. EPA is adding 71 sites to the NPL, including 14 Federal Facility sites. The EPA will transfer to its contractors information which has been, or will be submitted to EPA under the authority of the Resource Conservation and Recovery Act (RCRA). The EPA contractors are conducting cost and economic analyses of RCRA waste programs and regulations, analyses of environmental and human health effects, cost and risk comparitive analyses, regulatory support, data collection and management which may include support to the RCRA Confidential Business Information Docket. Some of the information may have a claim of business confidentiality. The transfer of information will occur no sooner man March 1,1990. The EPA will transfer to its contractors information which has been submitted under the "Rulemaking Petitions" Regulations (40 CFR 260.20 and 260.22) and under the Hazardous and Solid Waste Amendments (HSWA) of 1984. These firms will use this information to review and assess the completeness of the delisting petitions submitted. Some of die information may have a claim of business confidentiality. The transfer of information will occur no sooner than March 1,1990. EPA gives notice that the U.S. v. Envirite Corporation lodging of a DOJ consent decree on January 23,1990, (55 FR 2268) applies only to the facility located in Thomaston, Connecticut. The consent decree does not apply to, or in any way affect, Envirite's operation at its other facilities. 27 ------- RCRA/Superfund Hotline National Toll Free ft 800/424-9346, Washington DC Metro ft 202/382-3000 February 23,1990 (55 FR 6444) (notice and request for comments) February 26,1990 (FR FR 6640) (response to court remand) February 23,1990 (55 FR 6444) (notice and request for comment) EPA gives notice in accordance with CERCLA that a proposed administrative cost recovery settlement concerning the Edwards Road site in Coalburg, West Virginia was issued by the Agency on December 29, 1989. Comments will be accepted until March 26,1990. EPA gives notice to clarify its use of technology-based standards over risk-based screening levels with respect to Best Demonstrated Available Technology (BOAT) for land disposal restriction regulations as first used in the November 7,1986, final rule (51 FR 40572). On September 15,1989, a panel from theU.S. Circuit Court of Appeals for the District of Columbia found that EPA's selection of technology-based treatment standards were reasonable based upon interpretation of Section 3004(m) of RCRA. The review was based on a number of groups filingpetitions which challenged EPA's technology based standards choice. The panel also concluded that EPA failed to adequately explain its policy preference and remanded the rule to the Agency to either clarify the selection or withdraw the final rule. EPA gives notice in accordance with CERCLA that a proposed administrative cost recovery settlement concerning the Spectron, Inc., site in Elkton, Maryland was issued by the Agency on August 21,1989. Comments will be accepted until March 26,1990. 28 ------- List of Addressees: Ed Abrams, OS-332 Kate Anderson, OS-520 Wayne Anthofer, OS-305 Devereaux Barnes, OS-330 Beth Behrens, EPA-NEIC Frank Biros, OS-500 John Bosky, EPA-Kansas City Susan Bromm, OS-500 Karen Brown, PM-220 Karen Burgin, OS-100 Edmond J. Burks, Region 4 Diane Buxbaum, Region 2 Jayne Carlin, Region 10 Fred Chanania, LE-132S Carlton Chase, PM-214F Richard Qarizio, Region 5 Don R. Clay, OS-100 Steve Cochran, OS-332 Kathy Collier, RTP,NC Elizabeth Cotsworth, OS-343 Hans Crump, OS-210 Becky Cuthbertson, OS-332 Gordon Davidson, OS-500 Elaine Davies, OS-100 Truett DeGeare, OS-301 Bob Dellinger, OS-301 Jeffery Denit, OS-300 Dan Derkics, OS-323 LeeDuFief,TS-779 Dave Eberly, OS-343 Chris Elias, California Department of Health Karen Ellenberger, OS-420 Terry Feldman, A-108 Tim Fields, OS-210 Lisa Friedman, LE-132S John Gilbert, EPA-Cin., OH Diane Glass, SA-ALC/EM, KeUy AFB, TX Al Goodman, EPA-Portland, OR Uoyd Guerci, OS-500 Matt Hale, OS-340 Lynn Hansen, OS-305 Penny Hansen, OS-230 Bill Hanson, OS-220 Cheryl Hawkins, OS-200 Susan Hazen, TS-779 Irene Homer, WH-595 Barbara Hostage, OS-210 Hotline Staff Bob Israel, TS-779 AlvinK.Joe,Jr.,GRC GaryJonesi,LE-134S Ron Josephson, OS-333 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 29 Jim Jowett, OS-210 Thad Juzczak, OS-100 Mitch Kidwell, OS-332 Richard Kinch, OS-322 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 Tapio Kuusinen, PM-223 Steve Leifer,LE-134S Steve Levy, OS-301 Henry Longest, OS-200 Sylvia Lowrance, OS-300 Tom Lueders, Region V, 5HS-26 James Makris, OS-120 Joseph Martone, A-104 Andrea McLaughlin, OS-333 Chet McLaughlin, Region 7 Scott McPhilamy, Region 3 Royal Nadeau, Region 2 ChaePak, Region X 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 Emily Roth, OS-332 Suzanne Rudzinski, OS-342 Dale Ruhter, OS-320 William Sanjour, OS-332 PamSbar,LE-134S Robert Scarberry, OS-333 Mike Shannon, OS-310 Mike Shapiro, ANR-445 Jay Silberman, US Coast Guard, Honolulu, HI Laurie Solomon, OS-210 Elaine Stanley, OS-500 Jack Stanton, A-101 Beverly Thomas, OS-420 Jim Thompson, OS-520 Steve Torok, EPA-Juneau, AK Betty VanEpps, OS-240 L. C Waldo, DOE (DP-122) Hubert Walters, OS-210 Bruce Weddle, OS-301 Steve Wfflhelm, Region 7 Howard Wilson, PM-273 Alex Wolfe, OS-342 Denise Wright, OS-333 Dan Yunnan, OS-100 Tish Zimmerman, OS-220 ------- |