Enforcement Alert: Foundry Industry's Hazardous Waste Management of Major Concern to U.S. EPA

United States
Environmental Protection
Agency
Office of Enforcement
and Compliance
Assurance (2248A)
EPA 300-N-00-001
SEPA Enforcement Alert
Foundry Industry's Hazardous Waste
Management of Major Concern to U.S. EPA
Two goals of the Resource
Conservation and Recovery
Act (RCRA) are to protect
human health and the environment from
-^==theipatentiaLhazardsjpfsastejiisp.osaL
and ensure that wastes are managed in

published peripdiQglly' by'thg;
Office :*-spf J'i'i Regjiiatify-
Enforcement to ; infoliti arid
educate the public and.
regulated community of
important environmental
enforcement issues, recent
trends and significant
enforcement actions.

This information should help
the 'regulated community
anticipate and prevent
violations of federal
environmental law that could
^otherwise lead-to enforcement-
action. Reproduction and wide
dissemination of this newsletter
is encouraged.

See Page 4 for useful
compliance assistance
resources.

Eric V. Schaeffer
Director, Office of
Regulatory Enforcement

Editor: Virginia Bueno
(202) 564-8684
bueno.virginia@epamail.epa.gov
(Please email all address and
name changes or subscription
requests for. this newsletter.) .
Agency to Focus on RCRA Noncompliance
Issues at Foundries Nationwide
~an"environrnentaHy sound manner.
In support of these important envi-
ronmental and public health goals, the
U.S. Environmental Agency (EPA) has
identified the foundry industry as a
national priority as evidence obtained
through Regional and state investiga-
tion indicates that many owners and
operators of foundries are failing to
properly manage hazardous waste.
Noncompliance with RCRA, such as
failing to identify or properly store haz-
ardous wastes, could result in the re-
lease of toxic metals (e.g., lead and
chromium), which may cause serious
threats to public health and the envi-
ronment. Accordingly, EPA has taken
enforcement actions (i.e., imposing
civil penalties and ordering the removal
of lead-contaminated foundry sand),
issued rules, and, along with states, has
heightened its scrutiny of the industry.
In this issue of Enforcement Alert,
EPA highlights:

• EPA's focus on nationwide
foundry noncompliance issues;

• RCRA and regulatory require-
ments for foundry operations; and

• EPA Regional enforcement ef-
forts to determine the scope of poten-
tial RCRA noncompliance by found-
ries, and EPA Region 6's compliance
assistance program to educate local
foundries on the law's requirements.
EPA Looking at Foundry
Noncompliance Nationwide
From information obtained through
Regional investigations, EPA is expand-
ing its focus on foundries nationwide.
Specifically, EPA will be looking at
foundries that are:
• Non-notifiers (i.e., operations
that have failed to notify the states or
EPA of their hazardous waste activi-
ties);
• Failing to characterize hazard-
ous wastes (e.g., foundry sand for
metals content);
• Improperly storing and man-
aging wastes; and
• Operating thermal units with-
out a RCRA permit.
EPA encourages foundry owners
and operators to take affirmative steps
to ensure they are in compliance with
all applicable RCRA requirements.

RCRA Compliance
Requirements for Foundry
Operations
Owners and operators of foundries
may be subject to RCRA and applicable
regulations found at 40 C.F.R. Parts
260-271. Based on field inspection re-
sults and other information, EPA has

Continued on page 2

-------
Enforcement Alert
Continued from page 1

IWif'l
f __ __ _. material
'recycled" if'it is usecC reused ^
iO'C.F.R. | ;
dad Material: A material
IHiM! i* i i 'i-yrfli^, ''SlIWKl, ' Li-BUlli'''.:1!!1 -IN' "i" I'B
"'" Drocessed
., product, or
., ':
-------
Enforcement Alert
Continued from page 2
_ nivers
iSfflT
i'llHirmwWHWIlJauteiliH
IpStudies by Dr, John Drexler
iWt 1J ] • f iPlf V«jiSS*ia-j l' ri.l :!i™ilii»»'-»
ie, Uniyersity of Colorado aim an-
iii
ivestigatibns Center (NElC) cori-
"eluded that adding iron to waste
''],-'- ,- • i !, i IN ? J1 !j, !|| ji I, III Hi,,,'!. |l , l| ', III V Ijj 1||, j|!j||.
fQundry sandcontaminated with
lead" "does not permanently prevent
Jit 1H 11 11 i i I i I I £•1.™-™:-i ir -i F. i{64
.the release.ot lead into the envi-
,ii,;, ^i-iptwiMvuvvvwttaaEi.tii.iti
Tonment. , M : ,,,„„,,,,,,„,,,,,,,,,
! The studies determined mat
, ii ', : ; I1 I'l III i II " ii f I1 ' ' ;! ',' ll-JhiMII' '1 .ill III
(during the Toxicity Characteris-
*ijfc Leaching Procedure (TCLP)(a
Resting procedure used to identify
^hazardous was(e), if metallic iron
:is. present, the lead concentration
in solution will, tie decreased, t>Y
;| 4n oxidation/reduction reaction^tp
; levels that could be below the lead
'characteristic level. If fresh me-
tallic iron is regularly introduced
: iiitp the mixture, then soluble lead
! can be kept at low levels. How-
lever, for example, if the mixture
is placed in a landfill and left alone,
.the iron will,oxidize, therejpy los-
ing its ability to reduce lead ions.
An outside peer review com-
mjHee, formed to evaluate the re-
sults of the studies, supported the
conclusion that: "...treatment of
lead-contaminated sands by mix-
i/ig iron metal filings/powder with
the lead-contaminated sands prior
to disposal does not constitute an
'effective treatment process and zs
'not protective of human health arid
the environment." (See hitp://
'. www. epa.gov/fedrgstr/EPA-WA-
\ TER/19 9'7 (Ma re h/Day-0 J/
tty5419.htm Federal Register rio-
\Jticefor more on these studies).
!'!' V . : ' ;. [i.'h;.- i ' , , , : „ ; I if I il ii, i
cessing Secondary Materials and Bevill
Exclusion Issues; Treatment Standards
for Hazardous Soils, and Exclusion of
Recycled Wood Preserving Wastewa-
ters; Final Rule," published May 26,
1998, in the Federal Register, prohib-
its adding iron filings or other metallic
forms of iron to lead-containing haz-
ardous waste to achieve the land dis-
posal restriction treatment standard for
lead. EPA took this position because
studies, like those performed by the Uni-
versity of Colorado and EPA's National
Enforcement Investigations Center, re-
vealed that the addition of kon only tem-
porarily stabilizes the lead and,-thus, fails
to provide long-term treatment for lead-
containing hazardous wastes.

EPA Regional Enforcement
and Compliance Assistance
Efforts
Over the years, several EPA Regions
have addressed noncompliance issues
at local foundries. For example, in 1995
EPA Region 6 initiated an inspection
program to assess waste management
practices and the scope of noncompli-
ance with environmental regulations at
foundry operations. Based on an inspec-
tion of 27 facilities, the Region found
that a substantial number of foundries
were not complying with hazardous
waste requirements because of a basic
lack of understanding and correct in-
terpretationuf RCRA. Specifically, the
Region found that:"
• 85 percent of these facilities
were subject to regulation under RCRA;
• Nearly one-third of those fa-
cilities subject to RCRA did not notify
the states or EPA of hazardous waste
activity;
• 71 percent of the f acilities were
found to have potential RCRA violations;
and
• 83 percent of the facilities are
in minority and/or economically de-
January 2000
pressed communities.
As a result of its inspections, Re-
gion 6, with the support of several
states, initiated a program that not only
would provide owners and operators
with a better understanding of RCRA,
the Clean Air Act, and Clean Water Act
but also would address specific aspects
of these laws applicable to the metal
casting or foundry industry.
In April 1995, Region 6 and the
Oklahoma Department of Environmen-
tal Quality (ODEQ) introduced the
"Compliance Assistance and Outreach
Pilot Program." As part of the program,
a workshop was held for foundry in-
dustry representatives and members of
the American Foundrymen's Society.
Following the workshop, Oklahoma
foundries were given 90 to 120 days to
correct all compliance problems or self-
report significant violations. ODEQ
took the enforcement lead for found-
ries that did not choose to take advan-
tage of the self-disclosure opportunity.
Programs similar Oklahoma's also were
carried out in Louisiana and Texas.
In addition, Region 6 sponsored a
Foundry Compliance Assistance Con-
ference in March 1996 for local own-
ers and operators to discuss lessons
learned through the pilot program and
to foster greater communication be-
tween the foundry industry and the
Region. As a result of state support,
federal and state enforcement actions,
and compliance assistance efforts, lo-
cal foundries have made improvements
to their manufacturing processes and
waste management practices that help
promote a cleaner and healthier envi-
ronment.
In other parts of the country, EPA
is finding through its investigations that
significant compliance issues remain.
For example, last year EPA Region 7
identified significant violations of RCRA
requirements at foundries (primarily

Continued on page 4

_________ 3
-------
Enforcement Alert

xvEPA
United States
Environmental Protection Agency
Office of Regulatory Enforcement
2201A
Washington, D.C. 20460

Official Business
Penalty for Private Use $300
Continued from page 3
brass foundries) within the Region. In
an inspection of 29 foundries, Region
7 found that:

• 70 percent of the inspected fa-
cilities had potential RCRA violations;

• Typical violations included the
facility's failure to make an adequate
waste determination and, as a result,
potentially mismanaged hazardous
baghouse dust contaminated with lead
and chromium; and

• Other violations had been oc-
curring such as illegal on-site waste
management by piling of wastes; of-
fering hazardous waste for transporta-
tion and disposal at municipal landfills;
not labeling and dating hazardousrwaste^
and failures to cleanup hazardous waste
spills.

EPA's 'Sustainable
Industry' Program
EPA has launched a Sustainable In-
dustry Program for selected industry
sectors, such as the metal casting in-
dustry (e.g., foundries, diecasters). The
program provides industry the oppor-
tunity to partner with EPA and other
key stakeholders in solving environmen-
tal and waste management noncompli-
ance problems. For additional infor-
mation, visit EPA's Sustainable Indus-
try website at http://www.epa.gov/
sustainableindustry or contact: Jerry
Newsome, EPA's Office of Policy and
Reinvention, at (202) 260-8214.

EPA's Audit Policy and
Small Business Policy
EPA has adopted two policies de-
signed to encourage greater compliance
with environmental laws and regulations,
including RCRA. These policies, "In-
centives for Self-Policing, Discovery,
Disclosure, Correction and Prevention
of Violations" (Audit Policy), and
"Policy on Compliance Incentives for
Small Businesses" (Small Business
Policy), provide incentives to conduct
- environmental audits by substantially
reducing penalties for entities that vol-
untarily discover, disclose, and expedi-
tiously correct violations of environ-
mental law. For more information, see
http://www.epa.gov/oeca/auditpol.html
and http://www.epa.gov/oeca/
smbusi.html, respectively.
For more information, contact Mark
Potts, EPA Region 6, Hazardous Waste En-
forcement Branch, at (214)665-6746,
Email: potts.mark@epa.gov; Lynn
Sluganiz, EPA Region 7, RCRA Enforce-
ment and State Programs Branch, at (913)
551-7020, Email: skigantz.lynn@epa.gov;
or Vishnu Katari, Office of Regulatory En-
forcement, RCRA Division, at (202)564-
4004; Email: katarLvishnu@epa.gov.
Useful Comoliance
Assistance Resources
RCRA Enforcement Division:
http://www.epa.gov/oeca/ore/red/

Hazardous Waste Resource
Conservation and Recovery Act
Subtitle C:
http://www.epa.gov/epaoswer/osw/
hazwaste.htm#ldr

Office of Solid Waste (Land
Disposal Restrictions, Phase IV
Treatment Standards Set for
Toxicity Characteristic (TC) Metal
Wastes, Mineral Processing
Wastes, and Contaminated Soil):
http://www.epa.gov/epaoswer/
-hazwaste/ldr/ldrmetal/facls?hlm "•="—'

EPA Compliance Assistance
Centers:
http://www. epa. go v/oeca/mfcac. htm I

EPA's Small Business Gateway:
http://www.epa.gov/smallbusiness

RCRA, Superfund & EPCRA Hotline:
9 a.m. to 6 p.m. ET, Monday through
Friday, except for federal holidays, at
the numbers listed below:

National toll-free number (outside
of DC area): (800) 424-9346; Local
number (within DC area): (703) 412-
9810; National toll-free for the hearing
impaired (TDD): (800) 553-7672
Recycled/Recyclable. Prlntod with Soy/Canola Ink on paper that contains at least 30% recycled fiber
-------
United States
Environmental Protection
Agency
Office of Enforcement
and Compliance
Assurance (2248A)
EPA 300-N-00-001
&EPA Enforcement Alert
r ^B ipp l^i jypasMaii^^l i|^ H^JMlJjj^j
Foundry Industry's Hazardous Waste
Management of Major Concern to U.S. EPA
Two goals of the Resource
Conservation and Recovery
Act (RCRA) are to protect
human health and the environment from
- the-potential hazards of waste disposal
and ensure that wastes are managed in
About

Enforcement Alert
"Enforcement Alert" i~
published periodically by th
Office of Regulatory
Enforcement to inform and
educate the public and
regulated community of
important environmental
enforcement issues, recent
trends and significant
enforcement actions.

This information should help
the regulated community
anticipate and prevent
violations of federal
environmental law that could
otherwise lead to enforcement
action. Reproduction and wide
dissemination of this newsletter
is encouraged.

See Page 4 for useful
compliance assistance
resources.

Eric V. Schaeffer
Director, Office of
Regulatory Enforcement

Editor: Virginia Bueno
(202) 564-8684
bueno.virginia@epamail.epa.gov
(Please email all address and
name changes or subscription
requests for this newsletter.)
Agency to Focus on RCRA Noncompliance
Issues at Foundries Nationwide
ah environmentally sound manner.
In support of these important envi-
ronmental and public health goals, the
U.S. Environmental Agency (EPA) lias
identified the foundry industry as a
national priority as evidence obtained
through Regional and state investiga-
tion indicates that many owners and
operators of foundries are failing to
properly manage hazardous waste.
Noncompliance with RCRA, such as
failing to identify or properly store haz-
ardous wastes, could result in the re-
lease of toxic metals (e.g., lead and
chromium), which may cause serious
threats to public health and the envi-
ronment. Accordingly, EPA has taken
enforcement actions (i.e., imposing
civil penalties and ordering the removal
of lead-contaminated foundry sand),
issued rules, and, along with states, has
heightened its scrutiny of the industry.
In this issue of Enforcement Alert,
EPA highlights:

• EPA's focus on nationwide
foundry noncompliance issues; :

• RCRA and regulatory require-
ments for foundry operations; and

• Non-notifiers (i.e., operations
that have failed to notify the states or
EPA of their hazardous waste activi-
ties);

• Failing to characterize hazard-
ous wastes (e.g., foundry sand for
metals content);

• Improperly storing and man-
aging wastes; and

• Operating thermal units with-
out a RCRA permit.
EPA encourages foundry owners
and operators to take affirmative steps
to ensure they are in compliance with
all applicable RCRA requirements.

identified situations where owners and
operators may not be in compliance due
to incorrect interpretations of environ-
mental requirements. Several of these
requirements are discussed below:
Notification : The owner or operator of
a foundry generating hazardous waste
rhust obtain an EPA Identification Num-
ber (ID) and notify the Agency (or the
state, as appropriate) of the location and
general descriptions of hazardous waste
Activities. The notification must iden-
tify or list the hazardous waste man- .
aged by the facility's owner or opera-
tor. Hazardous waste may not be trans-
ported, treated, stored, or disposed of
without notification of hazardous waste
activity and the use of an EPA ID num-
ber.
Waste Identification: In response to
inquiries from the American
jFoundrymen's Society (AFS), EPA ex-
plained in March 1995 its long-stand-
ing position about how hazardous waste
regulations apply to foundry sand. More
if it is used, reused
xamples are
ntJ
Hefis§~Hrtaregeneration of
Spent Material: A "spent maie-
OT contami-
rsefyJlRepuP j
SrwRcfTlF waT'pro'cluced*""
lpfoces'sfr!ff'T40"C.F.lR. § *
February 2000
specifically, foundry satid (after being
separated from the castings at the
shakeout table) is a "solid waste" that
is subject to RCRA. At this point, the
used foundry sand, a "spent material,"
contains contaminants that must be re-
moved from the sand prior to its reuse
in the making of the molds. Spent
foundry sand may be reclaimed through
regeneration (i.e., removal of contami-
nants); however, the spent foundry
sand is still considered a solid waste
even though it is being recycled.
If a solid waste, such as spent |
foundry sand, is determined to be a
hazardous waste" and is to be recycled,
the waste is subject to 40 C.F.R. §
261.6 as a "recyclable material." Gen-
erally, the following persons must no-
tify EPA (or the state, as appropriate)
of its hazardous waste activity and
comply with certain RCRA regulations:
• Generators and transporters of
recyclable materials;
• Owners and operators of fa-
cilities that store recyclable materials be-
fore they are recycled;
• Owners and operators of fa-
cilities that recycle recyclable materials
without storing them before they are
recycled; and
• Owners and operators of fa-
cilities with hazardous waste manage-
sion standards (e.g., 40 C.F.R. Part 264,
Subpart CC) recycling hazardous
waste.
Once the sand is completely re-
claimed, removed from the reclamation
process, and returned to the mold-mak-
ing process, it ceases to be a waste and
is no longer subject to RCRA. The por-
tion of spent sand that is not returned
to the mold-making process remains a
solid waste and, if applicable, a hazard-
ous waste.
Storage and Management of Hazard-
ous Waste: Hazardous waste generated
or managed at foundries may be treated,
stored, or disposed of in several differ-
ent types of units (e.g., waste piles).
Improper waste management has the
potential to threaten human health,
ground and surface waters, and; soils.
To ensure that hazardous wastes are
managed safely and properly, specific
operating or waste management prac-
tices are required by law-or regulation.
Thermal Units May be Subject to
RCRA: Foundry operations generate a
significant amount of waste sand. Typi-
cally, the spent foundry sand is physi-
cally processed to remove contammants_
prior to reuse iii the process. In reclaim-
ing the spent sand, some foundries may
route this spent sand through a thermal
unit to combust the organic binder ma-
terial in the spent sand. If the spent sand
treated in the thermal unit is a hazard-
ous waste, the thermal unit is consid-
ered subject to RCRA Subtitle'c and
would need a permit. .
i
For more information on these re-
quirements, contact your local EPA Re-
gional Office. ;
Recent Rulemaking
Prohibits Treating Foundry
Sand with Iron Filings
Under RCRA, Land Disposal Re-
strictions (LDR) set treatment standards
and require that hazardous wastes be
j treated -before-they-can- be -disposed of -
in land disposal units. All hazardous
wastes must be treated so that the con-
centration of hazardous constituents is
below a certain level established for
each waste. Treatment is required to
minimize threats to human health and
the environment. ;
"Land Disposal Restrictions-Phase
IV: Final Rule Promulgating Treatment
Standards for Metal Wastes and Min-
eral Processing Wastes; Mineral Pro-
cessing Secondary Materials and Bevill
Continued on page

2
-------
Continued from page 2
, . .,
'i;;, University of Colorado
"
!; i ;: '; '.Studies by Dr." John brexler of" ;
;Uniy.ersity of CoJoradp and an-r j
ej'by Dn ..... Douglas' Kendalf of '"
['the, £PA's Rational 'jEnforcernent1^
i j Investigations Center (NEIQ.cpn- J
Jif: eluded tftat, adding iron to waste J
'fburidry sand contaminated with
i|i!.i|,_'i M , • |, ,, j i,:1 .r^i-'fT!1:! '»- »» T T ......... ,in» ,i .......... iMi- • in i ..... , -d. j^uH
"i lead dote§ not permanently prevent j
ii??^?*11 "'«':,(•,>,*,,. „ . r.^
I] ^urjiig the, Toxicity Characteris-' |
'":' I^^F^^fj^^^V^^i^l^J
testing procedure used to identify J
-
llgi:pfesent,_ the_lead ..... concentration
I in', solution,, 'will 'tie decreased" by
i '-H1-"- . v . -J '• '•; ;:J1 j'i'-'-H-1--'- ..... — '-; '-|N! •'•
Uch;
bhiaracteristic ( level, If fresh me- ^
tb'e, ...kept at low levels. How- j
PS' MiiiirCiR'iiiiili
is placed in a landfill and left alone,
i; the iron will oxidize, thereby los- j
its ability to reduce lead ions.
" ''" ' '
'{• suits of the studies,' supported the'
conclusion that: "... treatment^ ofl
I 'j ijffr iron metal filings/powder with j
•
Jo "disposal does not constitute an '•
-J': 'effective treatment process and is f
1'^.nptprotectiveofhumanhealth^qnd^ _
$ftHe _enviranmre,nt.ii"'i'(See, ht}p:// ]
\, w\vw. epa.gov/fedrgstr/EPA- WA- *
tyi .jfegera! Register no-1 ^
^"tice for more on these studies).
laNJiliifii-pi!::,l iliUii'jiMWFTr'Fiv^.iU.iM
l-il|.J,Mil'lr.. t : . ; = . - II I, l.!li,l',l! Sl»li-.,-Tv, I, ' i „ ,' - IJ-LiI,,!
br"i'iv1t-''i^-v"o.i'^u'^ii|
Exclusion Issues; Treatment Standards
. for Hazardous Soils, and Exclusion of
Recycled Wood Preserving Wastewa-
ters; Final Rule," published May 26,
1998, in the Federal Register,. projiib-
its adding iron filings or other metallic
forms of iron to lead-containing haz-
ardous waste to achieve the land |dis-
posal restriction treatment standard for
lead. EPA took this position because
studies, like those performed by the Uni-
versity of Colorado andEPA's National
Enforcement Investigations Center; re-
vealed that the addition of iron only tem-
porarily stabilizes the lead and, thus, fails
to provide long-term treatment for lead-
containing hazardous wastes. !

• 85 percent of these facilities
were subject to regulation under RCRA;
• Nearly one-third of those fa-
cilities subject to RCRA did not notify
the states or EPA of hazardous waste
activity;

• 71 percent of the facilities were
found to have potential RCRA violations;
and

• 83 percent of the facilities are
in minority and/or economically de-
pressed communities.
As a result of its inspections, Re-
gion 6, with the support of several
states, initiated a program that not only
would provide owners and operators
with a better understanding of RCRA,
the Clean Air Act, and Clean Water Act
but also would address specific aspects
of these laws applicable to the metal
casting or foundry industry.
In April 1995, Region 6 and the
Oklahoma Department of Environmen-
tal Quality (ODEQ) introduced the
"Compliance Assistance and Outreach
Pilot Program."-As part of the program,
a workshop was held for foundry in-
dustry representatives and members of
the American Foundrymen's Society.
Following the workshop, Oklahoma
foundries were given 90 to 120 days to
correct all compliance problems or self-
report significant violations. ODEQ
took the enforcement lead for found-
ries that did not choose to take advan-
tage of the self-disclosure opportunity.
Programs similar Oklahoma's also were
carried out in Louisiana and Texas.
In addition, Region 6 sponsored a
Foundry Compliance Assistance Con-
ference in March 1996 for local own-
ers and operators to discuss lessons
learned through the pilot program and
to foster greater communication be-
tween the foundry industry and the
Region. As a result of state support,
federal and state enforcement actions,
and cgjnpliance assistance ^ffprts, lo-
cal foundries have made improvements
to their manufacturing processes and
waste management practices that help
promote a cleaner and healthier envi-
ronment.

In other parts of the country, EPA
is finding through its investigations that
significant compliance issues remain.
For example, last year EPA Region 7
identified significant violations of RCRA
requirements at foundries (primarily
brass foundries) within the Region. In
February 2000
Continued on page 4

===== 3
-------
i&EPA
United States
Environmental Protection Agency
Office of Regulatory Enforcement
2248A
Washington, D,C. 20460
Official Business
Penalty for Private Use $300

'Enforcement Alert' newsletter
Continued from page 3
an inspection of 29 foundries, Region
7 found that:
• 70 percent of the inspected fa-
cilities had potential RCRA violations;
• Typical violations included the
facility's failure to make an adequate
\vaste determination and, as a result,
potentially mismanaged hazardous
baghouse dust contaminated with lead
and chromium; and
• Other violations had been oc-
cWing such as illegal on-site waste
management by piling of wastes; of-
fering hazardous waste for transporta-
tion and disposal at municipal landfills;
not labeling and dating hazardous waste;
and failures to cleanup hazardous waste"
spills.

EPA's Audit Policy and
Small Business Policy
EPA has adopted two policies de-
signed to encourage greater compliance
with environmental laws and regulations,
including RCRA. These policies, "In-
centives for Self-Policing, Discovery,
Disclosure, Correction and Prevention
of Violations" (Audit Policy), and
"Policy on Compliance Incentives for
Small Businesses" (Small Business
Policy), provide incentives to conduct
environmental audits by substantially
-reducing^penalties for entities th"t vol-
untarily discover, disclose, and expedi-
tiously correct violations of environ-
mental law. For more information, see
http://www.epa.gov/oeca/auditpol.html
and http://www.epa.gov/oeca/
smbusi.html, respectively.
For more information, contact Mark
Potts, EPA Region 6, Hazardous Waste En-
forcement Branch, at (214)665-6746,
Email: potts.mark@epa.gov; Lynn
SlugaTitz, EPA Region 7, RCRA Enforce-
ment and State Programs Branch, at (913)
551-7020, Email: slugantz.fynn@epa.gov;
or Vishnu Katari, Office of Regulatory En-
forcement, RCRA Division, at (202)564-
4004; Email: katari.vishnu@epa.gov.
\ Useful Compliance
Assistance Resources
} • !
; | j
R6RA Enforpejment Division:
http://www.epa;gov/oeca/ore/red/

Hazardous W^ste Resource
Conservation |and Recovery Act
Subtitle C: I
hl!tp://wi/vw.epal.gov/epaoswer/osw/
hizwaste.htm^ldr

Office of Solid Waste (Land
Disposal Restrictions, Phase IV
Treatment Standards Set for
Tbxicity Characteristic (TC) Metal
Wastes!, Mineral Processing
Wastes], and Contaminated Soil):
http://Www.ep4.gov/epaoswer/
hkzwaste/ldr/l^rmetal/facts.htm
i ' I
EPA Compliance Assistance
Centers: j
http://wWw.epaJ.gov/oeca/rnfcac.html

EPA's Small Business Gateway:
hftp://www.epa.gov/smallbusiness

RCRA, Superfund & EPCRA Hotline:
9j a.m. tp 6 p.'mj ET, Monday through
Rriday, except (for federal holidays, at
tljie nurjibers listed below:

tiatioti&l toll-free number (outside
of DC krea): ($00) 424-9346; Local
number, (within1 DC area): (703) 412-
$810; National toll-free for the hearing
Unpaired (TDD): (800) 553-7672
Recycledmccyclabte. Printed with Soy/Canola Ink on paper that contains at least 30% recycled fiber
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