¦ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ,^|WASHINGTON, D.C. 20460 31 23 £2 MEMORANDUM OFFICE OF SOLID WASTE ANO EMERGENCY RESPONSE WW WW WW I U0TI TWF monthi y STATUS REPORT - June 1982 Toll Free - 800-424-9346 Wdsii DC/TTS - 382-3000 FROM: Carolyn Barley, Project Officer f.//, /Sy** Office of Solid Waste (382-4505) . // J Barbara Hostage, Project Officer Office of Emergency and Remedial Response (245-3057]r TO: Addressees (see attachment) General The Hotline staff responded to 2,520 calls in June. Approximately 81% of the callers requested information on the RCRA or CERCLA regulations and 19% asked general regulatory questions or requested publications. Technical questions on RCRA totaled 1,149 and 'technical questions on CERCLA totaled 278. Most Frequently Asked Questions Do the financial requirements apply to me? How do I fill in the paragraphs in Part 264.151(g)? Is my waste a hazardous waste? When is the annual report due? When doing the comparisons of background groundwater parameters to current parameters, do I compare each well to itself or to the upgradient well? What must be done when recycling a hazardous waste? Is a comprehensive list of hazardous substances available? Where are the sites located that have notified under Section 103(c)? Resolution of Difficult Questions Question: Does the National Envionmental Policy Act (NEPA) require CERCLA sites to have environmental^-TTfipact statements. ------- (2) Resolution: According to Doug Conen, Honey Analysis Branch, OERR, NEPA is involved when federal dollars are spent on remedial action, but environmental impact statements are not usually required for CERCLA sites. Section 1506.11 of NEPA exempts any CERCLA emergency actions from NEPA. The proposed National Contingency Plan outlines several levels of assessments and environmental impacts. Question: Part 265.143(d) allows an owner/operator to submit a letter from an insurer stating that the insurer is considering issuance of ¦ .. . -• t . 3» * • wmc wmici / ujjcl a cur all CA ir'd Q3yS 10 submit the certificate of insurance to EPA. Can an insurance agent submit a similar letter stating that he is searching for an insurer? Resolution John Skinner and the Office of Enforcement will notify the Regions :hat licensed brokers may issue a letter stating that the broker is seeking insurance on behalf of the owner/operator. This will give the owner/operator a 90 day extension as in Part 265.143(d). Question: What should be <^one if an owner/operator has both sudden and non-sudden liability coverage by July 15, 1982? Resolution: If the Part 264.151(g) financial test is used for sudden and non-sudden coverage, the owner/operator may wish to add a separate letter noting that the coverage is for both. Then the Region will not„expect later notification of non-sudden coverage. Question: If an endorsement or certificate of insurance is used for both sudden and non-sudden insurance, how is the distinction made between sudden and non-sudden? Resolution: According to Emily Sano, sudden and non-sudden may be added to indicate the monetary limits in the wording where excess carrier language has also been allowed. Special Projects The Hotline staff is continuing to assist the Office of Management Information Analysis (OMIA), OSW in conducting a pre-test of a Regulatory Impact Analysis (RIA) questionnaire. A total' of 41 calls have been recieved on the RIA question- naire. The Hotline staff has also been asked by OMIA to verify to callers that WE STAT, a contract firm represents EPA when calling TSDF's and generators to confirm Part.A.and notification information. WESTAT is giving the Hotline's telephone number to those facility owners/operators and generators who wish this confirmation. This Hotline has received 122 calls requesting verification. Callers wishing additional information are being referred to Mike Burns. In addition to these projects, Emily Sano and Carole Ansheles, Resource Recovery Branch, OSW have asked the Hotline staff to continue to summarize questions received on the financial requirements. Attachment ------- |