\	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
/	WASHINGTON, D.C. 20460
DECEMBER 17, 1982
MEMORANDUM	office of
————	SOLID WASTE AND EMERGENCY RESPONSE
SUBJECT: RCRA/SUPERFUND HOTI IMF MflNTHI Y STATIK RFDflPT..Mnwomhor 1009 1
Toll Free 800-424-9346
Washington. DC 382-3000
FROM: Carolyn Barley, Project OfficeiC	-6
Office of Solid Waste (382-5235)
Barbara Hostage, Project Officer r	-Y--y
Office of Emergency and Remedial Response*(245-3057v j
TO:	Addressees (See Attachment)
The Hotline Staff responded to 2,759 calls in November. Approximately
83% of the callers requested information on the RCRA/CERCLA regulations and
17% asked general regulatory questions or requested publications. Technical
questions on RCRA totaled 1,641 and technical questions on CERCLA totaled 648.
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
Will a RCRA Annual Report be required for 1982?
Will there by an extension o* the January 10, 1983 "due date" for
the RCRA Annual Report (especially for New York and New Jersey)?
Questions on the applicabi1ity of the RCRA Annual Report to
particular situations?
When will EPA lower the small quantity generator limits to 100kg
from the current 1000kg?
When will the Agency promulgate a final rule on the National
Uniform Manifest?
When will the Agency publish the list of reportable quantities?
If I don't accept waste in my land disposal facility after
January 26, 1983, do I have to go through closure?
When will the list of 400 priority sites be published?
What regulations apply to small quantity generators?
Is my waste a hazardous waste?

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(2)
What regulations apply if I recycle my waste?
If I failed to notify under CERCLA 103(c), what should I do?
Additional calls on RCRA permit applications (Part B submittals),
changes during interim status, closure plans, and changes
from storage under interim status to 90 day accumulation.
QUESTION: When a RCRA TSDF in an interim authorized State has Part B of
f h P DA rmi ^ f S11oH f n P hnw sro t ho f i nan/ği al
handled? The facility was in the corporate financial test
under paragraph 4 of 264.151(g).
RESOLUTION: Sections 122.25(a) (15) ar.d (a) (17) require copies of the
financial mechanisms adopted in compliance witfi 264.143 and
264.147 as applicable. These requirements are based on the
assumption that the owners or operators of existing facilities
are in compliance with Federal interim status standards. The
premise does not apply in States with Phase I Authorization,
and liability coverage does not apply in States which applied
for Phase II authorization by April 16, 1982 (123.129(a)(2)).
Facilities in those States which meet the above description do
not have 264 or 265 standards in effect. These facilities are
only required to submit financial instruments prior to the final
permit disposition. The Agency points out that owners/operators
have less resistance during public review of the draft permit if
the financial assurances have been provided prior to public comment
At that time, the facilities should be listed in paragraph 1.
Prior to submission, the Region may accept letters submitted in
July 1982 as indications of the type of mechanism to be adopted.
The figures would still show the appropriate amount of financial
coverage but would be located in paragraph 4 rather than
paragraph 1.
Resolution of Questions (RCRA)
QUESTION: If a generator sells his company, can enforcement action be taken
if the notification is not updated?
Does the new generator actually have an ID number?
RESOLUTION: The regulations do not require change of ownership notification;
no enforcement action proceeding would be taken. The change in
ownership would not affect the use of the identification number,
which tends to be facility (site) specific. However, notifying
the Region would facilitate recordkeeping for EPA.
Source: Amy Schaffer
Research: Irene Horner
RCRA Annual Report
The bulk'mailing of the RCRA Annual Report^forms (with the exception of
New York and Mew Jersey, which were mailed in early December) was completed
on November 24th. As a result of the mailing, 142 calls, were received con-
cerning the availability of the form, who must file the form, and the
information required on the form. The Hotline has been working closely with
Bob Axelrad on this effort.

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