v.lC S*4. \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY / WASHINGTON, D C. 20460 «o'*" Qc.4- 9% W> OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE CIID lCrT. ft^n* /Piiftrnrniin u^Tl Tur haiitmi w r\r**A«T f « ~ - juriM unu rluiLiiit nvJiuriLl oimiuo ncruru - aeyLeniuer i vac Toll Free - 800-424-9346 Wash DC/FTS - 382-3000 FROM: Carolyn Barley, Project Officer Office of Solid Waste (382-4505) Barbara Hostage, Project Officer <$&ibQA/yj ^lociOGL' Office of Emergency and Remedial Response (245-305/) TO: Addressees (see attachment) General The Hotline staff responded to 3,746 calls 1n September. This is an increase of 916 calls over the number received 1n any one month since the Hotline began operation 1n October 1980. Approximately 51% of the callers requested information on the RCRA or CERCLA regulations, 19.5% asked general regulatory questions or requested publications, and 29.5% asked questions pertaining to the RCRA Regulatory Impact Analysis. Technical questions on RCRA totaled 1,625 and technical questions on CERCLA totaled 286. Approximately 75% of the callers were from industry, 15% from EPA and State Agencies, and 10% from trade assolcations, private citizens, etc. Most Frequently Asked Questions What is the status of the RCRA annual report? What 1s my liability under RCRA or CERCLA for wastes which I generated in the past and which are now causing an environmental problem? Is a list of CERCLA hazardous substances available for which I am CURRENTLY re- sponsible for notification under Sec. 103 (a & b)? Given my current waste management practices (I.e., I handle only small quanity generator wastes, or I only store wastes less than 90 days), am I subject to the interim status, requlrements because I filed Part A of the permit application. £an I use the wastewater exemption (40 CFR 265.l[c][10] for my facility? ------- (2) VJhat advantage is it to me to close my surface impoundment, landfill, etc. prior to it becoming a "regulated unit"? Requests for information on the RCRA reauthorization bill. Requests for information on the expenditure of Superfund monies on site clean-up. w/mi €i v**"* ^ ttt t ~ ^ — a. ^ • . .W. • jwu 1.IL.1L .><- -Ul wl 'y^lTi 1A V j. X X ^>71 U*)UXtUCIlL.,3 to determine your background levels? Resolution: You first test for the Appendix VIII constituents when your detection monitoring program results in a statistically significant increase in parameters (See '264.98[hi). Your background levels will be those upgradient of your facility. Ouestion If a solid waste later becanes regulated by the Agency as a hazardous waste, does the compliance period (under 264.96 [a] include the time, when disposal of the solid waste occurs? What if you dispose of municipal waste and later decide to dispose of hazardous waste? Resolution: The compliance period is the number of years equal to the active life of the waste management area (including any waste management activity prior to permitting, and the closure period). "Any waste management activity" includes both situations des- cribed. Ouestion: Are there any disadvantages to being a regulated unit if you close prior to getting a permit (but after January 26, 1983)? Refsolution: As a regulated unit, if your post-closure ground-water monitoring establishes contamination, the Agency can request the Part R of your permit application. You would ultimately receive apermit consisting of Part 264, Subpart F, including corrective action. Special Projects: The Hotline staff continued to provide assistance to the Office of Management Information Analysis, OSW by answering calls on the RIA questionnaire which was sent to 13,000 generators and facility owners/operators. Although, WESTAT is listed on the questionnaire as the primary source of help, questionnaire recipients have called the Hotline (732 telephone inquiries in September) for additional help. ------- |