22 FEB 1983
The Hotline Staff responded to 4,580 calls in January. Approximately
59% of the callers requested information on the RCRA or CERCLA regulations and
41% asked general regulatory questions or requested publications. Technical
questions on RCRA totaled 1,535, technical questions on CERCLA totaled 572, and
docunent requests totaled 1,235.
Most Frequently Asked Questions
What is the status of the 1982 Annual Report?
When doing groundwater monitoring under Part 265, do I compare my upgradient
well data to the dcwngraaient well data; or do I ccmpare the downgradient data
to the previous year's downgradient data?
Is my waste a hazardous waste?
Are the land disposal regulations effective January 26, 1983?
With what regulations does my disposal facility canply after January 26?
Questions on complying with the January 16, 1983, deadline for non-sudden and
accidental liability insurance.
Why _iŁ a site in my ccnmunity on the National Priorities List?
Why isn' t a site in my ccnmunity on the List?
What is the purpose of the National Contingency Plan?
A \
Toll Free - 800-424-9346
Wash DC/FTS 382-3000
Carolyn Barley, Project Officer
Office of Solid W&ste (382-5235)	7
Barbara Hostage, Project Officer )6a^6a/ici>	1
Office of Emergency and Ranedial Response (382-7917)
Addressees (see attachment)

What criteria were used to score the National Priority List?
Are the sites on the NPL listed in order of funding priority?
What will be done to clean-up the sites?
What role do the States play?
Hew much liability do responsible parties have?
How many sites were reviewed?
When will, my site be cleaned up?
Question:	Can a transporter consolidate manifested shipments of hazardous
waste at a transfer facility by transferring wastes in druns
to a tank truck for bulk delivery to a TSDF? All of the
druns contain wastes with the same DOT shipping description.
Answer:	If the transporter were ccmbining waste with different DOT
shipping descriptions into a single container, the transporter
would be mixing wastes and must canply with the Part 262
regulations. Since in this instance no mixing of different
EOT waste types occurs, there is no requirement for a new
manifest. (The preamble to the Dec. 31, 1980, interim final
rule on storage by transporters at transfer facilities solicited
ccrments on. whether regulatory controls over the consolidation
of shipments and mixing of hazardous waste by transporters is
warranted). If the containers are empty according to section
261.7, they are not subject to further RCRA regulations.
Source: Carolyn Barley, Rolf Hill, anu Claire Welty
Research: Irene Horner
Question:	A wastewater which is not identified or listed in 40 CFR
Part 261 is placed in a surface impoundment for dewatering.
A constituent of the wastewater is reactive when dry.
Does the surface impoundment becane subject to RCRA if it
never dries out during its active life?
Answer:	The surface impoundment becanes subject to RCRA when it dries
cut after receiving its fine>.l volume of waste. If the waste
is iinnediately removed as it becanes reactive (dewatered),
then the operator would be a generator for that waste. If
the waste dries out first and becomes reactive, then the surface
impoundment would be subject to the regulations.
Source: Fred Lindsey
Research: Irene Horner

The citation in paragraph 2 of Section 122.23(e), "Grounds
for termination of interim status" is incorrect. What is
the correct citation?
Answer:	The correct citation is Section 122.22(a)(5) or a direct
referral to Section 3005(e) of RCRA.
Source: Debbie Wblpe
Research: Karen Gale
miuL to uic ^i.ciiv,c kctweai a ntcuixi.et>c ui&crepancy anu an
unmanifested waste?
Answer:	Unmanifested wastes are wastes which are not accompanied by
shipping documents which meet the information requirements
of section 262.21. That is, if any of the information re-
quired by section 262.21 is not on the shipping docunent, the
docunent does not meet the definition of a manifest. Manifest
discrepancies are differences between the quantity or type
of waste designated on the manifest or shipping paper and
the quantity or type of waste actually received at a facility.
Source: Rolf Hill
Research: Irene Horner
Question:	What is the difference between "cancellation" and "ter-
mination" of an insurance policy under Section 264.151(i)
(2)(d) and (e)?
Answer:	Cancellation occurs during the active life of the policy
(i.e., cancellation for non-payment of the premium).
Termination occurs when a policy runs its course and is
not renewed.
Source: Bniiy Sano
Research: Karen Gale
Polychlorinated Biphenyls
Seme confusion has arisen regarding whether PCB materials (substances
having a PCB concentration of 50 ppn or greater) are regulated under RCRA.
The confusion seems to have resulted frcm a memo fran OSW, OTS, and Enforce-
ment to Region IV concerning a facility in that Region. The memo was interpreted
by Glen Kuntz, OTS to mean that if a PCB material regulated under 40 CFR Part
761 is also identified or listed in 40 CFR Part 261, it is subject to regulation
under both TSCA and RCRA.
While the RCRA regulations are silent on this issue, several preamble references
(45 FR 33086 and 33173, 46 FR 2846, 7668 and 22145) state that until RCRA incor-
porates PCB disposal regulations, the management of PCB's remains under TSCA
PCB regulatiotiar This interpretation was confirmed by Lisa Friedman (OGC) and
passed along to. Glen Kuntz.

The number of document requests and CERCLA technical questions in-
creased sharply during January. This increase is attributed to the
December 30, 1982, publication of the National Priority List. The
Hotline has received over 600 requests for this publication and for
information on the sites listed.
On January 19th, Tony Baney, Jack Kooyocmjian, Barbara Hostage, and
Mike Barclay met with Lt. Harlin Henderson and LTJG Carla Ridnour at the
Mat* 1 nnal Pocrysneo Panfay TK®
NFC personnel on the regulatory impact analysis for the "reportable
quantity/designation of hazardous substances" rulemaking package. NliC
supplied sane of the raw data which went into the package and had requested
a briefing on the results. A tour of the facilities was also provided.
On January 28th, Tony Baney and Carolyn Barley met with John Palmisano,
OPRM to discuss the development of an information management system which
would facilitate compliance with RCRA by using Agency generated environ-
mental auditing procedures. Mr. Palmisano plans to visit the Hotline to gain
a better understanding of the types of questions received and the processes
used to answer those questions.
January 3, 1983	Proposed Rule - amends section 262.34 to allow
satellite accunulation
January 10, 1983	ANPRM - Department of Interior requests information
for rulemaking for Section 301(c) of CERCLA
January 11, 1983	California Phase II Component A' interim authorization
(excludes surface impoundnents)
January 19, 1983	Final Rule - clarifies that permits are not needed for
immediate response to discharges (spills)
January 19, 1983	Proposed Amendment - applicability of Part 265 to
facilities which fail to fully qualify for interim
January 20, 1983	Interim Final Rule - amends wording of section 261.6
(b) to clarify applicability to ocnmercial chemical
products. Also, updates applicability of Part 264,
subparts A-L to certain recycling facilities
January 27, 1983	Permit Advisory Carmittee announcement
January 28, 1983	Final Rule - generator, treatment, storage, and
disposal facility biennial report requirements
January 28, 1983	Kentucky Phase II, Components A and B Interim
January 28, 1983	Final guidelines for the Federal procurement of
cement and concrete containing fly ash