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\	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
/	WASHINGTON, D C. 20460
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OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
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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?

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(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.
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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.

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