k i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY rJ WASHINGTON, D.C. 20460 JP NOVEMBER 30, 1982 MEMORANDUM off.ceof SOLID WASTE AND |MERGENCY RESPONSE SUBJECT: RCRA/SUPERFUND HOTLINE MONTHLY STATUS REPORT - October 198? ioi i rree - buu-4Z4-yj4b Washington, DC -382-3000 - FROM: Carolyn Barley, Project Office^"" Office of Solid Waste (382-5235) f f CJ- Barbara Hostage, Project Officer Office of Emergency and Remedial Response (245-3057) TO: Addressees (See Attachment) The Hotline staff responded to 3,328 calls in October. Approximately 63% of the callers requested information on the RCRA or CERCLA regulations, 26% asked general regulatory questions or requested publications, and 11% asked questions pertaining to the RCRA Regulatory Impact Analysis. Technical questions on RCRA totaled 1,630 and technical questions on CERCLA totaled 460. Approximately 75% of the callers were from industry, 15% from EPA and State Agencies, and 10% from trade associations, private citizens, etc. Most Frequently Asked Questions What is the status of the RCRA annual report? Has the Agency published its proposed comprehensive CERCLA hazardous substance 1i st yet? What are the hazardous substances for which I am currently responsible for reporting under Section 103 (a & b) of CERCLA? Am I subject to the Federal RCRA standards if my facility is in a State with Interim Authorization? Requests for information on the RCRA re-authorization bill (especially for the small quantity generator changes). Resolution of Questions QUESTION: If a State has Phase II Component A Interim Authorization, can that State write a permit for a surface impoundment under the regulations promulgated on 1/12/81 or must the State wait until it is approved for Component C and use the 7/26/82 regulations? RESOLUTION: The surface impoundment regulations of 1/12/81 cover only treatment and/or storage units. The regulations require a double liner and leachate detection, collection and removal system. The ------- 12) comment in Section 264.233 (b)(1)(ii) requires that the bottom liner be highly impermeable (thus acting as a secondary containment system). States authorized on the basis of the 1/12/81 standards may issue permits to facilities which meet those standards until the standards are changed on 1/26/83. These design requirements could satisfy the 7/26/82 exemption requirements from the groundwater protection standards (264.222), thereby allowing the State to issue permits under the 1/12/81 regulations which would meet the 7/26/82 requirements. RESEARCH: Tony Baney QUESTION: If a surface impoundment does not accept any hazardous waste after 1/26/83 and is called to submit Part B of its permit application, which Subparts of the 264 regulations would apply? RESOLUTION: Currently Subparts A-E, G, H, K would apply but Subpart F (ground- water protection) would not. Because of the wording in 264.90(a), such a unit is currently not subject to groundwater protection under Subpart F of Part 264. The impoundment would, however, be subject to groundwater monitoring requirements under Part 265. This may be amended in the future. SOURCE: John Lehman RESEARCH: Tony Baney QUESTION: Does the exemption for mixtures of hazardous waste and domestic sewage extend to privately owned sewers and wastewater treatment units which eventually discharge to a publicly-owned treatment works? RESOLUTION: Although RCRA does not define "sewer system", it is not the Agency's intent to include private sewers or wastewater treatment units up-stream from the point where pre-treatment standards (Section 307(b) of CWA) would apply to wastes going by a sewer to a publicly-owned treatment works. SOURCE: John Lehman RESEARCH: Tony Baney Special Projects: Assistance to the Office of Management, Information and Analysis, OSW on the Regulatory Impact Analysis is winding down. George Garland, MIAD informed the Hotline that anyone requesting an extension can be given one over the phone (to October 30 if their due date was prior to October 15 and to November 15 if their due date was after October 15). Extension is contingent upon the immediate submission of a letter to George stating that an extension is necessary. At the request of Bob Axelrad, OSW, the Hotline staff reviewed the annual report form and submitted comments to Bob. In addition several of the Hotline staff attended DOT'S hazardous materials transportation training course to familiarize themselves with the interface of DOT'S and EPA's hazardous wastes, materials, and substances transportation regulations. ------- |