Final Monthly Report: RCRA/Superfund Industry Assistance And Emergency Planning And Community Right-To-Know Information Hotline Report. April 1983


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i	^	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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MAY 20, 1983
OFFICE OF
SOLlO WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: RCRA/SUPERFUND HOTLINE MONTHLY STATUS REPORT - April 1983
Toll Free - 800-424-9346
Wash DC/FTS 382-3000
FROM: Carolyn Barley, Project Officer \£cndcua) /f&oiautfL. 
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What annual Implicit Price Deflator is appropriate to use in revising my
cost estimates for my financial assurance requirements in my State?
Will the deadline for comments on the National Priority List be extended
past the current February 28., 1983 deadline?
Could my cements to the National Priority List possibly result in the
inclusion of another site on the list?
Will EPA revise the National Priority List in the future?
QUESTIONS/ANSWERS - RCKA
Question:	P030 is "soluble cyanide salts, not otherwise specified." is
potassium ferricyanide P030? It is soluble but not toxic.
Answer:	A compound is only P030 if HCN would form when exposed to
acidic conditions.
Source: David Friedman
Research: Irene Horner
Question:	Does any part of a container storage Part B permit application
need to be certified by a professional engineer; and, if so, does
the professional engineer need to be registered in the State the
facility is in?
Answer:	No technical data needs to be certified for container storage.
Other units like tanks that do require certification are not
limited to State certified PE's, but the Region should be con-
sulted .
Source: Dave tag art
Research: Irene Homer
Question:	Can the owner/operator of a facility cancel or terminate his
policy without giving the insurance ccmpany the 60 or 30 days
the insurance ccmpany needs in order to give EPA 60 to 30 days
notice of cancellation?
Answer:	The insurance ccmpany is bound by the certificate or endorsement
to give proper notice. There is no requirement for the facility
to give the insurance company advance notice. The insurance
company could protect itself against this in its contract with
the facility.
Source: Karen Gale
Research: Irene Horner
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Question: The closure/post-closure cost estimates were first required May
19, 1981. The cost estimates were to be adjusted for inflation
within 30 days after each anniversary 6f the date on which the
first estimate was prepared (265.142(b)). Hie wording of the
regulation has caused sane confusion:
1)	If your first estimate was prepared prior to May 19, 1981,
do you adjust it within 30 days of the anniversary of the
first date it was prepared, or do you change to a May 19
schedule?
2)	If you were late in preparing your first estimate, do you
change to a May 19 scnedule or continue on the late schedule?
3)	If ycu prepared your first estimate on May 19, 1981, but had
a change in capacity resulting in new plans and new estimates
mid-year, do you then use the mid-year revision as the new
date so that your future adjusted revisions will be on a
mid-year schedule, or do you return to the May 19 schedule?
1) Change to the May 19 schedule.
Answer:
Question:
Anwser:
2)	Change to the May 19 schedule.
3)	Your revised closure plans will result in new cost estimates,
as the first estimates. Consider those estimates as the first
estimates and continue on the mid-year schedule.
Source: Carole Ansheles and Qnily Sano
Research: Karen Gale
If a material is 80% solid and 20% water, can the PH be measured
under 261.22(a)(1)?
It is still testable if it contains free liquids (water). The
agueous phase of the proposed paint filter test could be used to
determine if there are free liquids.
Source Karen Gale
Research: Florence Richardson
Question:
Answer:
Benzene fran a storage tank leaked into the ground water. This leak
occurred before November 19, 1980. The groundwater is now pimped
out and treated in a surface impoundment. Is the surface impound-
ment receiving a hazardous waste?
If a material is a listed hazardous waste, you must classify
it as a hazardous waste even though the leak occurred prior
to Novsnber 19, 1980. Pimping the water is an activity under
261.2(b), so, 261.3(a)(2)(iv) applies. Therefore, the surface
impoundment is reoeiving U019, benzene. When a site is "re-
activated," (cleaned-up, waste removed, etc.), the facility
must canply with the hazardous^waste regulations. See the
December 31, 1980, FR preamble, p. 86969.
Source: Matt Straus ^nd Steve Silverman
Research: Karen Gale and-Tony Baney
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Question: Section 265.93(b) requires an initial background arithmetic
mean and variance for each of the §265.92(b) (3) indicator
parameters. Hew should the calculation be done if three of
the four values are reported as below detection limits.
Answer:	This question applies to total organic carbon and total organic
halogen only. The desired detection limit for total organic
carbon is lmg/1 and for total organic halogen, 5ug/l. The
above values for these two parameters should be used in the
required statistical canpanies when values are reported as
K^l 
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