UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 APR 141983 OFFICE OF SOLID WASTE ANO EMERGENCY RESPONSE MEMORANDUM ^0ST% $ A Ti fw** SUBJECT: RCRA/SUPERFUND HOTLINE MONIHLY STAIUS REPORT - March 1983 Toll Free - 800-424-9346 W&^E/FTS 382-3000, FROM: Carolyn Bafley TProject^Off icer Office or Solid Wasta^382-5235) Barbara Hostage, Project Officer 'AOt) rfaJbcti.— Office of Emergency and Remedial Response (382-79179 TO: Addressees (see attachment) General The Hotline Staff responded to 3,036 calls in March. Approximately 74% of the callers requested information on the RCRA or CERCLA regulations and 26% asked general regulatory questions or requested publications. Technical questions on RCRA totaled 1,831, technical questions on CERCLA totaled 403; general questions totaled 212; and docunent requests totaled 590. Most Frequently Asked frjestions Vfriat is being done about the Chan-Dyne site? What groundwater monitoring reports are required to be sent to the Regions? When do I update my closure cost estimate? Vfriat is the Annual Implicit Price Deflator for 1982? Is the mining waste exclusion still in effect? Vtiat information do I send in Cor my Part B permit application? Is my waste a hazardous waste? Is the guidance docunent on groundwater monitoring for interim status facilities available? Who do I call to report a spill or illegal dunping of hazardous waste? ------- Is the EP toxicity test for total chraniura? Is a RCRA permit needed for cleaning up CERCLA sites? Is my site eligible for CERCLA funding? QUESTIONS/ANSWERS - RCRA Question: If the cost estimate was adjusted for inflation in May 1982, should it be adjusted when the annual update of documents for the financial test is required to be submitted by March 31, 1983? Answer: The cost estimate is only adjusted for inflation annually in May (unless the estimate was required to be revised due to a change in the closure plan). Hence the update for the finanical test would show the same cost estimates as figured in May 1982. Source: Emily Sano Research: Irene Horner and Karen Gale Question: To meet the bond rating for the financial test, which bonds are considered capital or pollution control bonds?. If the last bond was issued two years ago, which rating is used — the one at issuance or the current one? Answer: The bond most recently issued by the cwner or operator is used to see if the canpany meets the bond ratings of Moody's or Standard and Poor's. The current rating of the bond is used. Source: Bnily Sano Research: Irene Horner Question: An interim status facility wishes to add a new hazardous waste management unit. Is this new unit subject to the 264.18 seisnic standards if the unit can be added according to 122.23(c) (3) and (5)? Is the new unit subject to 264.18 if the cwner/ operator has exceeded reconstruction costs and has to submit a full permit application for the unit? Answer: (1) If the change can be made during interim status, the unit is not subject to the seianic standards. The definition of existing facility is satisfied, and a facility can have several units. (2) Part 264.18 applies to new facilities, and this unit is still part of an existing facility. Source: David Fagan and David Sussnan Research: Irene Horner -2- ------- ACTIVITIES The Hotline has received an increased number of calls frcm citizens concerning the National Priority List with the majority of questions on the Chan-Dyne site in Hamilton, OH. The residents of Hanilton are concerned about health problems resulting frcm exposure to the site. Joe Gearo of the Hazardous Site Control Division provided the Hotline with a written update of Chan-Dyne and a contact in Region V to refer the residents to for further assistance. Part B permit application questions have becane more frequent and diversified. Callers are asking more technical questions and are seeking guidance on the adequacy of permit specific items such as waste analysis plans. A pranature press release announcing the proposed rule to list dioxin-containing wastes generated numerous calls during March since this information was published in The New York Times and the Hie Wall Street Journal. The proposed rule did appear in the April 4, 1983 Federal Register. Compliance with the Subpart H financial requiranents has continued to be a major concern and source of confusion for companies. Many ccmpanies are finding it difficult to sort out the various updating requiranents and deadlines for the non-authorized and interim authorized states. Federal Register Notices March 2, 1983 March 4, 1983 March 15, 1983 March 16, 1983 March 29, 1983 March 31, 1983 Extension of canment period on lifetime permits to May 11, 1983 Announcanent of open meeting of Task Force A of the RCRA permit Advisory Committee to be held on March 30, 1983 Announcement of open meeting of Task Force B of the RCRA Permit Advisory Ccmmittee to be held on March 16, 1983 Corrections to February 23, 1983, FR proposals to change waste listing in 261.33 for warfarin and products containing zinc phosphide. Menorandun providing enforcement guidance regarding whether burning lew energy hazardous waste for energy recovery can be considered legitimate re- cycling Corrections to 262.50(b)(l)(iii) regarding address to which hazardous waste export notices must be sent. Granting of Interim Authorization for Phase II, Components A and B, to New Hampshire -3- ------- |