Final Monthly Report: RCRA/Superfund Industry Assistance And Emergency Planning And Community Right-To-Know Information Hotline Report. July 1984


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\	UNJTED STATES ENVIRONMENTAL PROTECTION AGENCY
J	WASHINGTON. D.C. 20460
AUGUST 20, 1984
OFFICE OF
MEMORANDUM	SOLID WASTE AND EMERGENCY RESPONSE
SUBJECT: RCRA/Superfund Hotline Monthly Status Report -- July 1984
FROM: Carolyn Barley, Project OffiJ&i)
Office of Solid Waste (382-5235)
Barbara Hostage, Project Officer	yksteoe_
Office of Emergency and Remedial Response	(382-218$
TO:	Addressees
I.	ACTIVITIES
The Hotline responded to 4,145 questions and requests for documents
in July.
Over 50% of all document requests were for the draft Technical
Resource Document "Hydrologic Evaluation of Landfill Performance
Model."
II.	SIGNIFICANT QUESTIONS AND RESOLVED ISSUES
A. RCRA
1. When does one make the determination that a waste is liquid or
solid prior to disposal in a landfill? The waste in question is
normally solid but liquifies at temperatures reached in the
vehicle transporting it to the site (>140° F) and occasionally
at anbient desert surface temperatures (120°F in the summer).
The material will solidify over a short period of time.
The phase of the waste should be determined just prior to
disposal. In this case, the waste is liquified during
transportation but will solidify over a short period of
time. Therefore, it is proper to allow the shipment of
containers to stabilize or solidify before performing the
free liquid test. It is permissable to use best engineering
judgment.
Source: Paul Cassidy
Research: Ken Jennings

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RCRA/Superfund Hotline
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2.	What is the status of RCRA Part 264 Subpart 0 (Chen/Physical/Biol.
Treatment)?
As it has gained experience with the hazardous waste program,
EPA has determined that very little treatment occurs in
units meeting the definition of chemical, physical or
biological treatment units as found in Subpart Q. Most
treatment units qualify as other types of units (e.g. tanks,
surface impoundments, land treatment units) that are
subject to the requirements of other Subparts. EPA intends
to promulgate a set of standards for miscellaneous facilities
under a new Subpart X in Part 261. Tb the extent units
exist that fall within Subpart 0 of Part 265, they will
be addressed by Subpart X for permitting purposes.
Source: Fred Lindsey
Research: Ttom Gainer
3.	Smelter slag waste buried around 1900 is currently being excavated.
Is this waste excluded under 261.4(b)(4)?
The exclusion in §261.4(b)(4) covers boiler slag (nolten
bottom ash) but does not cover smelter slag. The smelter
slag would probably fall under the mining exclusion
(§261.4(b)(7)) as the processing of ores and minerals.
Source: John Heffelfinger
Research: Tom Gainer
4.	A natural gas production company injects methanol into well heads
to keep them from freezing during the winter months. The water/
natural gas/methanol mixture is piped through a central piping
station where the natural gas is separated from the water/methanol
mixture. The water/methanol mixture is piped to a lined pond
and finally discharged to a series of percolation ponds. The
discharge to the percolation ponds is regulated under the State
ground-water permit program. The methanol is ignitable; however,
it eventually volatilizes into the atmosphere. Is the methanol/
water mixture excluded from regulation according to 261.4(b)(5)?
Yes; the mixture is excluded according to 261.4(b)(5). This
exclusion is specifically referenced in section 3001(b)(2)(A)
of RCRA. A report to Congress on the excluded waste is directed
under section 8002 of RCRA.
Source: Dexter Hinckley
Research: Bill Rusin

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5.	a. How does one perform the EP toxicity test on oily wastes?
Hie waste in question does not pass through the filter and is
iimiscible in water.
b. Is there another extraction procedure test for such wastes?
a.	Hie EP toxicity test is conducted using the filtrate
fran filtering a sample. Solid or oily material that do not
pass through the filter are subject to the EP extraction and
the resulting extract analyzed to determine if the waste is
hazardous.
b.	There is a variation of the EP toxicity test specifically
for oily wastes which is used in the delisting program. It
is not regulatory, however, under 261.24. A copy of this
procedure may be obtained for use in experiments from Todd
Kimmell USEPA OSW by calling (202) 382-4795.
Source: Dave Friednan
Research: Ken Jennings
6.	Is baghouse dust (from an incinerator that burns a non-fossil
fuel) that is EP toxic for heavy metals, a sludge for the purposes
of recycling according to 261.6?
Baghouse dust that is not excluded under 261.4(b)(4) is
considered a sludge according to the definition in 260.10.
Therefore, if hazardous by the characteristic,the baghouse
dust is subject to regulation under 261.6(b) with respect to
transportation and storage.
Source: Alan Corson
Research: Bill Rusin
7.	A drum of listed wastes is dumped into an on-site wastewater
treatment facility at a laboratory operation. Is this covered
by the lab exclusion in §261.3(a)(iv)(E)?
This activity is not covered in the lab exclusion. §261.3(a)
(iv)(E) was meant to cover small amounts of wastes added essentially
unavoidably to large volumes of process wastewater. Examples
include laboratory spills washed into a sink drain, and residues
from the washing of glassware which are carried in the washwater
into the sewer.
Source: Alan Oorson
Research: Tbm Gainer

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8.	What is the status of Appendix A to SW-846 titled "Sampling and
Analysis Methods for Hazardous Waste Incineration"?
"Sanpling and Analysis Methods for Hazardous Waste Incineration"
will not be issued as Appendix A to SW-846. Rather, it will
be incorporated throughout the document as appropriate. The
proposed changes are currently in Red Border review, it is -
anticipated that the changes will be available through NTIS.
Oontact David Friedman at 382-4770 for more information.
Source: Efevid Friedman
Research: Bill Rusin
9.	A small quantity generator (SQG) who always generates less than
1000 kg. of hazardous waste per month exceeds his 1000 kg.
accumulation limit and consequently dates and marks "Hazardous
Waste" on the drums per 261.5(f). During the 90-day accumulation
period, additional small quantities of waste are generated and
these partially full drums are assigned accumulation start
dates. The original 1000 kg. of regulated waste is shipped
off-site while the partially full drums remain. Can the SQG
remove or cover the dates and markings on the partially full
drums?
No; any waste generated and accumulated after the SQG
accumulation limit is exceeded is also subject to 262
regulation because the total accumulation is still above the
SQG limit. Even when the original 1000 kg. of regulated
waste is shipped off-site, the remaining partially full
drums are still regulated and must be removed within their
respective 90-day limits per 261.5(f). Hence, the start
dates and "Hazardous Waste" markings cannot be removed or
covered.
Source: Jacqui Sales
Reserach: Tom Gainer
B. CERCLA
1. a. What is the purpose of "SKIM" (Spill Clean-up Inventory)?
b. How does one access SKIM?
a.	SKIM is a computer data base managed by the Coast Guard.
SKIM identifies Federal and private oil spill equipment that
can be used in case of spills. On-scene Coordinators and
private parties gain rapid information on the location of
response and support equipment. The NPL addresses SKIM in
§300.37.
b.	SKIM can be accessed through the local Coast Guard Marine
Safety Office.
Source: Steve Heare
Research: Torn Gainer

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2.	What is the minimum Hazardous Ranking Score for inclusion on
the National Priority List (NPL) and is that score derived frcm
the migration, fire and explosion and direct contact scores?
The minimum score is equal to or greater than 28.50 unless
it is a State designated top priority site. State designated
sites have no minimum score requirement. The score used is
the migration score only. The fire and explosion and direct
contact scores are used to identify emergency situations
that require removal action.
Source: Joe Gearo
Research: Gordon Davidson
3.	Arcording to CERCLA section 111(e)(2), "in any fiscal year, 85% of
the money credited to the Fund under Title II of this Act shall
be available only for the purposes specified in paragraphs 1,
2, and 4 of subsection (a) of this section." What does this
statement mean?
A minimum of eighty-five percent of the Hazardous Substance
Response Trust Fund money is earmarked for removal and
remedied actions and related costs as described in the NCP.
Source: Steve Atkinson
Research: Ken Jennings
4.	Who pays the operational and maintenance (O&M) costs of NPL sites?
Section 104(c)(3) of CERCIA requires that the State make
an assurance to assume responsibility for all operation and
maintenance (O&M) costs for the expected life of each remedial
action as determined by the EPA and the State. As stated in
"State Participation in the Remedial Program," the EPA may,
for a period not to exceed one year after completion of remedial
response activities, share in the cost of any required O&M.
These costs will be shared on the same percentage basis as
costs for other remedial implementation activities found in
the cooperative agreement.
Source: Jan Wine
Research: Tbm Gainer

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IV. ANALYSES OF QUESTIONS
The Hotline responded to 4,145 questions and requests for documents in July. Of the
questions asked, the percentage of callers was:
Generators	29.0%	 State Agencies	10.0%
Transporters	2.3%	 Consultants	26.4%
TSDF' s	9.3%	 Press	<1%
EPA HQ's	<1%	Trade Asstciations	1.1%
EPA Regions 	5.0%	 Citizens	7.0%
Federal Agencies 2.9%	Others 5.W
More calls were received from Regions 3 and 5 than in any other Region.
Breakdown by Region:
1	7.9%	 3	19.4%	5 19.4%	7 4.0%	9	9.2%
2	14.0%	 4	10.9%	6 8.4% 8 4.3% 10 2.5%
Canada <1%
RCRA	TSDF
General Information
331
A-Scope/Applicability
140
Notification (3010)
50
B-General Facility Standards
35
Definitions (260.10)
72
C-Preparedness Prevention
17
Petitions/Delisting (260.22)
37
D-Contingency Plans
20
Definitions (261.2 & 3)
148
E-Manifest/Recordkeeping/Reporting
25
Exclusions (261.4)
61
F-Groundwater Monitoring
52
Small Quantity Generator (261.5)
109
G-Closure/Pos t-Closure
69
Recycle/Reclaim (261.6)
160
H-Financial Reguirements
36
Container Residues (261.7)
37
I-Containers
31
Waste ID (261 C&D)
421
J-Tanks
37
262 Generator
Manifest Info
129
K-Surface Impoundments
L-Waste Piles
23
5
Pre-transport
18
M-Land Treatment
8
Accumulation
87
N-Landfills
31
Recordkeeping & Reporting
24
0-Incinerators
41
International Shipments
11
P-Thermal Treatment
2
263 Transporter
47
Q-Chemical, Physical, Biological Treat.
, 3
270 B - Permit Application
90
R-Underground Injection
2
D - Chanqes to Permits
28
X-Misc. Facility
1
F - Special Permits
1
Y-Experimental
1
G - Interim Status
59
266/267
2
271 State Programs
116


124 Decision Makinq
12
CERCLA General
215


Hazardous Substances/RQ
105
General

Hazardous Site/NPL/104
89
Li ab i 1 i ty/En fore emen t
55
NCP
32
Other/Referrals
361
Taxes/IRS
9
Document Requests
650

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RCRA/Superfund Hotline
July 19.84 Report
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V.	PUBLICATION INFORMATION
A.	RCRA
1.	"Assessing the Releases and Costs Associated with Truck Transport
of Hazardous Waste" is available from the National Technical Information
Service (NTIS), order number PB-84-224468, $16.00. The executive sunmary
of this report (EPA/530-SW-84-008) is available from the RCRA Docket.
2.	"Permit Applicant's Guidance Manual for Hazardous Waste Land Treatment,
Storage and Disposal Facilities" is now available from the U.S. Government
Printing Office, stock number 055-000-00240-1, $13.00.
3.	"Procedures Manual for Groundwater Monitoring at Solid Waste Disposal
Facilities," formerly SW-611, is available from NTIS, order number
PB84-174820, $23.50.
B.	CERCLA
1.	Memorandum titled "Guidance Regarding CERCLA Enforcement Against Bankrupt
Parties" from Courtney Price, dated May 24, 1984, is available through Heidi
Hughes at 382-3109.
2.	Memorandum titled "Liability of Corporate Shareholders and Successor
Corporations for Abandoned Sites Under CERCLA" from Courtney Price, dated
June 13, 1984, is available through Ted Firetog at 475-8782.
VI.	FEDERAL REGISTER NOTICES
July 5, 1984 49FR27585
EPA has determined that further information is
needed to process Utah's application for final
authorization. The Agency's concerns are pre-
sented in the notice.
July 9, 1984 49FR27942
The Agency explains how it will allot funds
remaining after the first round of awards uncter
3012 of RCRA.
July 10, 1984 49FR28074
The Agency finds South Dakota's application for
final authorization to be deficient.
49FR28076
July 11, 1984 49FR28245
49FR28274
The Agency finds North Dakota's application for final
authorization to be lacking necessary information.
EPA announces the award of final authorization
to Montana effective July 25, 1984.
EPA announces the availability of the Permit
Applicant's Guidance Manual for Hazardous Waste
Treatment, Storage, and Disposal Facilities
through GPO (055-000-00240-1).

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July 18, 1984 49FR29192
July 20, 1984 49FR29377
49FR29418
49FR29524
July 23, 1984 49FR29625
July 26, 1984 49FR30072
July 30, 1984 49FR30309
EPA announces the final rule amending Subpart H
of the NCP by specifying testing and data require-
ments for. inclusion of a dispersant, surface
collecting agent, or biological additive on the
NCP Product Schedule.
Massachusetts is awarded interim authorization
Phase II, Components A, B, and C effective
August 3, 1984.
The Agency announces the availability for viewing
and comment at the RCRA docket of additional in-
formation pertinent to the proposed new definition
of solid waste (4/4/83).
EPA proposes to amend its RCRA facility permitting
regulations to allow a standard form to be used for
generators who store waste on-site in above-ground
tanks or containers. This action purportedly will
streamline the permitting process. Comments will be
accepted until September 18, 1984.
GPO phone number printed July 11, 1984 (49FR28274)
is corrected to 783-3238.
West Virginia is granted an extension to
January 26, 1985, for acquiring final authorizatic
Alabama interim authorization Phase I has reverted
to EPA due to the State's inability to amend its
regulations to conform to the Federal version in a
timely fashion. Effective August 1, 1984.

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ADDRESSEES
John Skinner, VH-562
Mike Cook, WH-562
Eileen Claussen, WH-562
Robert Knox, WH-562
Carl Reeverts, WH-562
Cora Beebe, WH-562A
Jack McGraw, WH-562A
John Lehman, WH-565
Fred Lindsey, WH-565
Bruce Weddle, WH-563
Lee Daneker, UM-563
Elizabeth Cotsworth, WH-563
Stephen Lingle, WH-565
Alan Corson, WH-565
Ken Shuster, VM-565
Dale Ruhter, WH-565
William Sanjour, WH-563
Truett DeGeare, WH-563
Steve Levy, WH-563
Peter Guerrero, WH-563
John Thompson, WH-563
Mike Shannon, WH-563
Susan Mann, WH-563
George Garland, WH-562
William Hedeman, VM-548
Elaine Stanley, WH-548
James Makris, WH-548A
Robert Landers, WH-548A
Jim Jowett, WH-548B
Henry Van Cleave, DOD/DLA
Russ Wyer, WH-548E
Bill Hanson, WH-548E
Mary Ann Froehlich, WH-548D
Carol Lawson, A-107
Marc Jones, PM-220
John Palmisano, PM-223
Sam Napolitano, PM-220
Gene Lucero, WH-527
Frank Biras, WH-527
Lee Herwig, A-104
Tony Montrone, WH-527
Pete Rosenberg, WH-527
Mike Kosakowski, WH-527
Barbara Elkus, WH-527
Hotline Staff
Alvin K. Joe, Jr., Geo/Resource
Sue Moreland (ASTSWMO)
Diane McCreary, Region III Library
Joyce Baker, Region III Library
Lisa Friedman, LE-132S
Steve Dorrler, EPA - Edison, NJ
John Gilbert, EPA - Cincinnati, OH
Jack Stanton, WH-548B
John Riley, WH-548B
Mike Flaherty, WH-548B
Jack Kooyocmjian, WH-548B
Rick Horner, WH-548B
Hazardous Waste Division Directors, Regions I-X
Hazardous Waste Management Branch Chiefs, Regions I-X

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