NOVEMBER 30, 1982
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Washington, DC -382-3000	-
FROM: Carolyn Barley, Project Office^""
Office of Solid Waste (382-5235) f	f
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

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
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.