st*j* \ 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 ------- RCRA/Superfund Hotline July 1984 Report Page 2 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 ------- RCRA/Superfund Hotline J"ly 1984 Report Page 3 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 ------- RCRA/Superfund Hotline July 1984 Report Page 4 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 ------- RCRA/Superfund Hotline July 1984 Report Page 5 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 ------- RCRA/Superfund Hotline July 1984 Report Page 6 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 ------- RCRA/Superfund Hotline July 19.84 Report Page 7 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). ------- RCRA/Superfund Hotline July 1984 Report Page 8 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. ------- 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 ------- |