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


J* %	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
J	WASHINGTON, D.C. 20460
rt«S&
NOV 23 m
MEMORANDUM	office of
"	SOLID WASTE AND EMERGENCY RESPONSE
SUBJECT: RCRA/Superfund Hotline Monthly Status Report — We'i'rmbiiig 1984
(800-426-9346; FTS 8-382-3000; Washington, DC area 382-3000)
FROM: Carolyn Barley, Project Officer
Office of Solid Waste (382-5235)	yT"	/j
Barbara Hostage, Project Officer		
Office of Emergency and Remedial Response (382-2186) 0
TO:	Addressees
I. ACTIVITIES
The Hotline responded to 4,056 questions and requests for documents
in October.
II. INFORMATION UPDATE
The purpose of this section is to list rulemakings and publications
that have been published or are being developed and should be
published within the next few months.
RCRA
1.	President Reagan signed the RCRA Reauthorization bill (PL 98-616)
on November 8, 1984. Copies of the bill may be obtained from the
Documents Office of Congress at (202) 225-3456.
2.	The revised Definition of Solid Waste final rule is scheduled to be
published in late December or January. This rule will modify the
definition of solid waste and the applicability of RCRA standards
to recycled solid wastes.
3.	The October 1, 1984, Federal Register (49 FR 38786) proposed four
amendments concerning EPA's test methods (SW-846), ground-water
testing requirements, ground-water screening tests, and a hierarchical
approach for ground-water testing. (See Section VII in this report for
further information.)
CERCLA
1.	The revised National Contingency Plan (NCP) is at the Office of
Management and Budget (0MB) for review. It is expected to be
published in the Federal Register in late December cr January.
2.	The Reportable Quantity (RQ) final rule is also at OMB for review.
It is expected to be published in the Federal Register in December
or January.

-------
-2-
3. The Remedial Investigation and Feasibility Study (RI/FS) guidance documents
are currently undergoing internal Agency review. The Feasibility Study
document will soon be undergoing Red Border review, then sent to OMB for
review. The Remedial Investigation document has not reached this review
stage yet. The documents should be available within several months.
III. SPECIAL SECTION: NATIONAL PRIORITIES LIST UPDATE »2
On October 2, 1984, Lee Thcmas, Assistant Administrator for the Office of
Solid Waste and Emergency Response, announced the proposed addition of 244 sites
to the National Priorites List (NPL). These proposed additions to the NPL will
bring the total number of proposed and final NPL sites to 786. The Hotline is
accepting requests for informational materials on Update #2.
IV. SIGNIFICANT QUESTIONS AND RESOLVED ISSUES
A. RCRA
1.	At land treatment units, operators often dump the waste to be treated on the
ground, and within a few hours or a day, spread it on the land treatment
area. Does this dumping of waste constitute storage in a waste pile subject
to regulation?
This process is typical at nany land treatment units. It may not be
viewed as storage in a waste pile if the waste is dumped on the actual
treatment area, and only remains for a limited period of time prior to
spreading. If the waste is dumped in an area other than the treatment
area, then it should be regulated as a waste pile or landfill. In
general, though, EPA does not recamaend such dumping and spreading of
waste as an adequate land application procedure since the waste is not
applied evenly. EPA would specify another method of application in the
permit for the land treatment unit.
Source: Mike Flynn (382-4489)
Research: Denise Wright
2.	Solid wastes that result from the extraction, beneficiation, and processing
of ores and minerals (including coal) are excluded from the RCRA regulations
per §261.4(b)(7). Solvents are often used to clean the equipment used for
such extraction, beneficiation, and processing. Are these cleaning solvents
also exempted per §261.4(b)(7) or are they RCRA hazardous wastes?
The §261.4(b)(7) exemption is for wastes which are generated in direct
association with the extraction, beneficiation, and processing of ores
and minerals. The cleaning of equipment with solvents is not directly
associated with these processes. Therefore, solvents used in cleaning
the machinery would be RCRA hazardous wastes.if they are listed or raee
a §261 Subpart C characteristic.
Source: Alan Corson (382-4770)
Research: Hilary Sommer

-------
-3-
B. CRRfTA
1. The Hazard Ranking System (HPS) is used to evaluate the relative potential of
uncontrolled hazardous substance sites to cause risk or danger to public
health cr welfare cr the environment. Evaluators assign three HRS scores to
a hazardous site:
1)	Migration;
2)	Fire and explosion; and
3)	Direct contact.
The migration scare computed fran components fee three "pathways" (air,
surface water, groundwater), is used as the principal basis for listing
sites on the National Priorities List. The minimum score for listing is
28.50. The other two scares, fire and explosion and direct contact, are
used to determine if an emergency situation exists, possibly warranting
an emergency removal action. Is there a minimum score that triggers an
emergency removal?
There is no minixium score that triggers an emergency removal action.
Any site having a scare greater than zero could trigger a field
investigation by the appropriate Region. A field investigation may
include sampling to determine the extent of contamination. The
results of the field investigation will assist in the determination
of whether a removal is necessary.
Source: Hans Crump (382-3328)
Research: Tom Gainer

-------
-4-
V. ANALYSES OF QUESTIONS
Hie Hotline responded to 4,056 questions and requests for documents in October. Of the
questions asked, the percentage of callers was:
Generators	26 %
Transporters	2 %
TSDF' s	12 %
EPA H3's	2 %
State Agencies	9 %
Consultants	26 %
Press	2 %
EPA Regions
6 «
Federal Agencies 3%
Trade Associations 2 %
Citizens	
Others
5 %
5 %
More calls were received from Region 3 than from any other Region. Breakdown by Region:
1 6 %	3 22 %	5 18%	74%	99%
2 14 % 4 12 %

6 8% 85% 10 2%

Canada 0%



RCRA

TSDF

General Information
307
A-Scope/Applicabi1itv
73
Notification (3010)
49
B-General Facility Standards
24
Definitions (260.10)
52
C-Preparedness/Prevent i on
14 i
Petitions/Delistinq (260.22)
31
D-Contingency Plans
19^
Definitions (261.2 & 3)
73
E-Manifest/Reccrdkeepinq/Reportinq
7
Exclusions (261.4)
67
F-Groundwater Monitcrinq
69
Small Quantity Generator (261.5)
90
G-Closure/Poet-Closure
66
Recycle/Reclaim (261.6)
102
H-Financial Requirements
25
Container Residues (261.7)
37
I-Containers
45
Waste ID (261 C&D)
421
J-Tanks
55
262 Generator

K-Surface Impoundments
65
Manifest Infomation
116
L-Waste Piles
4
Pre-transport
22
M-Land Treatment
13
Accumulation
67
N-Landfills
41
Recordkeepinq & Reportinq
14
O-Incineratcrs
16
International Shipments
4
P-Thermal Treatment
5
263 Transporter
40
Q-Chemical, Physical, Biological Treat.
3
270 B - Permit Application
77
R-Underground Injection
6
D - Chanaes to Permits
14
X-Misoellaneous Facility
6
F - Special Permits
5
Y-Experimental
0
G - Interim Status
50
266/267
0
271 State Proqrams
105


124 Decision Makinq
7
CERCLA General
139


Hazardous Substances/RQ
83
Liability/Enfcrcement
35
Hazardous Site/NPL/104
181
Other /Referrals
287
NCP
34
Document Reauests
222
TaxesARS
10
RCRA Reauthorization
595

-------
-5-
VI. PUBLICATIONS
RCRA
1. "Summary of the 1984 Anendments to RCRA" is available through the RCRA
docket. The Hotline will accept requests far this sunmary.
CERCLA
1. "Hazardous Waste Sites: Description of Sites in Update #2 to the National
Priorities List," October 1984, HW 8.4, is available fran EPA's Hazardous
Site Control Division. The Hotline will accept requests for this publication.
2. "National Priorities Lists 786 Current and Proposed Sites in Order of
Ranking and by States," October 1984, HW 7.2, is also available frcra EPA's
Hazardous Site Control Division. The Hotline will accept requests.
3. "Superfund Comprehensive Acccmplishments Plan (SCAP)" sunmarizing all
planned site-related activities, including removal, remedial, and enforcement
projects for Fiscal Year (FY) 1985 is available in sections from the OERR
Staff as follows:
Remedial: Kirby Biggs (202) 382-7993
Removal: Steve Heare (202) 382-2206
Enforcement: Kirk Maconaughy (202) 382-4836
(SCAP replaces RAP(Remedial Accomplishment Plan))
VII. FEDERAL REGISTER NOTICES
October 1, 1984 49 FR 38786 Four Amendments were proposed. First, an amendment
was proposed making EPA Publication "Test Methods
for Evaluating Solid Waste" (SW-846) mandatory.
Second, the Agency proposed to eliminate certain
groundwater testing requirements in circumstances
where no test methods exist, or the constituent
inmediately converts to another sutetanoe on
contact with water. Third, the Agency proposed
to allow the use of screening tests for ground-water
monitoring to test for classes of constituents.
Finally, the Agency proposed a conceptual hierarchical
approach (screening) for ground-water testing.

-------
-6-
October 1, 1984 49 FR 38671 Tentative approval to grant New Hampshire final
authorization under RCRA.
October 4, 1984 49 FR 39175 Tentative approval to grant Vermont final authorization
under RCRA.
October 5, 1984 49 FR 39328 North Dakota granted final authorization effective
at 1:00 p.m. on October 19, 1984.
October 10, 1984 49 FR 39683 Utah granted final authorization effective 1:00
P.M. on October 24, 1984.
October 11, 1984 49 FR 39929 Lodging of consent decree pursuant to RCRA and
CERCLA in United States v. Berlin and Farro Liquid
Incineration, Inc., et al., Civil Action No. 84-CV-
8473-FL in the U.S. District Court for the Eastern
District of Michigan.
October 12, 1984 49 FR 40055 Tentative approval to grant Arkansas final authorization
under RCRA.
October 15, 1984 49 FR 40320 EPA proposes the second update to the National
Priorities List.
October 17, 1984 49 FR 40610 Tentative approval to grant Massachusetts final
authorization under RCRA.
October 19, 1984 49 FR 41036 Colorado granted final authorization effective 1:00
p.m. on October 19, 1984.
October 22, 1984 49 FR 42138 EPA published its Regulatory Agenda.
October 23, 1984 49 FT* 42580 Delisting petitions sutmitted under 40 CFR 260.20
and 260.22 were published to exclude from the
hazardous waste listings in 40 CFR 261.31 and
261.32.
October 24, 1984 49 FR 42759 Tentative approval to grant Kansas final authorization
under RCRA.
October 24, 1984 49 FR 42761 Tentative approval to grant New Mexico final authorization
under RCRA.
October 25, 1984 49 FR 42959 Tentative approval to grant South Carolina final
authorization under RCRA.
October 26, 1984 49 FR 43072 Tentative approval to grant Maryland final authorization
under RCRA.

-------
-7-
ADDRESSEES
John Skinner, WH-562
Mike Cook, WH-562
Eileen Claussen, WH-562
Robert Knox, WH-562
Carl Reeverts, WH-562
Devarah Zeitlin, WH-562
Cora Beebe, WH-562A
Jack McGraw, WH-562A
John Lehman, WH-565
Fred Lindsey, WH-565
Bruce Weddle, WH-563
Clan Rastatter, WH-563
Elizabeth Cotsworth, WH-563
Penny Hansen, WH-565
Alan Corson, WH-565
Ken Shuster, WH-565
Dale Ruhter, WH-565
William Sanjour, WH-563
Walter Kovalick, WH548
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, WH-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 Kosakcwski, 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 Darrler, EPA - Edison, NJ
John Gilbert, EPA - Cincinnati, OH
Thad Juszczak, WH-562A
Jack Stanton, WH-548B
John Riley, WH-548B
Mike Flaherty, WH-548B
Jack Kooyoomjian, WH-548B
Rick Horner, WH-548B
John Bosky, EPA - Kansas City, KS
Hazardous Waste Division Directors, Regions I-X
Hazardous Waste Management Branch Chiefs, Regions I-X

-------