,\	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C. 20460
O


MEMORANDUM
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SO'.'O WASTS a ND € \l: "GENC * rt €	36
SUEJECT: RCRVSuperfund Hotline Status Report - June 1985
FROM: Carolyn Barley, Project Officer v / / ., y	-^Xct
Office of Solid Waste (382-2217)	^ ^
Barbara Hostage, Project Officer		^
Office of Emergency and Remedial JJp^ponse (382—2
TO:	See addressees
I.	ACTIVITIES
A.	The Hotline responded to 7,237 questions and requests for documents in June.
B.	Charlotte Mooney and Jim Ginley were hired as Information Specialist trainees.
Ms. Mooney has a BS in Geology from the University of Pennsylvania. Mr. Ginley
has a BS in Biology from Kenyon College and a MEM (Environmental Management)
frcm Duke University.
C.	On June 20th Matt Straus worked with Hotline staff to address complex Solid
Waste questions.
II.	SIGNIFICANT QUESTIONS AND RESOLVED ISSUES
A. RCRA
Corrective Action
1. A treatment facility is applying for a Resource Conservation and Recovery Act
(RCRA) §3005 operating permit. This facility currently manages scrap metal
destined for reclamation. On January 4, 1985, (50 ER 614), the Agency declared
that scrap metal, when recycled, is a Subtitle C waste. Concurrently, the
Agency announced that it would not regulate scrap metal destined for recycling
at this time. Because this facility is seeking a §3005 operating permit,
the facility must address releases of hazardous waste or constituents frcm
any solid waste management unit pursuant to §3004(u) (corrective action).
Must this facility address the unregulated scrap metal management area con-
cerning releases?
Even though scrap metal destined for recycling is not regulated, it is
considered a solid waste. Thus, a release of a hazardous waste or constituent
at the scrap metal management area (solid waste management unit) must be
addressed pursuant to §3004(u) of RCRA.
Source: Dave Fagan (202) 382-4497

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Solvent Mixture
2.	The April 30, 1985, Federal Register (50 FT* 18378) contained a proposal to list
solvent mixtures in 40 CFR §261.31 "containing, in total, ten percent or more by
volume of one or more of the following solvents..." Does the 10% criterion apply to
the solvent mixture before it is used and becomes a waste or as it exits in the,
waste stream? For example, a wastewater stream contains 5% solvents and 95% water.
Would one consider whether the solvent fraction used in the process contains at
least 10% of one or more of the listed solvents; or would one consider the
percentage of solvent in the waste water stream?
Cne would apply this solvent mixture ""rule to the mixture as it is used (prior
to becoming a waste). One would determine whether the original solvent mixture
(before use) contained more than 10% of the listed solvents. If so, the waste
stream is covered, regardless of the percentage of solvent in the-waste stream.
Source: Jaqueline Sales (202) 382-4807
Partial Closure
3.	The owner/operator (o/o) of a permitted facility plans to remove a tank from service.
His permit does not address removal of the tank. Must the permit be modified to
reflect this tank removal?
Removing the tank would constitute partial closure of the facility. The closure
plan should address this situation according to §264.112(a)(1). Since the permit
does not cover partial closure, the o/o must amend his plan. Section 264.112(b)
requires the o/o to amend his plan whenever changes in operating plans (e.g.,
tank removal) affect the closure plan. lb amend the closure plan to address
partial closure, the o/o must comply with the standards for major modifications
for permits under §270.41. The o/o should amend his plan to address all antici-
pated partial closures so that he need only modify his permit once.
Source: Susan Hughes (202) 382-4790
Snail Quantity Generators
4.	International Fabricare is a trade association that represents dry cleaning and
laundry establishments. This industry will be affected by the new Snail Quantity
Generator (SQG) program pursuant to the Hazardous and Solid Waste Amendments (HSWA)
of 1984 (P.L. 98-616). Starting August 5, 1985, SQGs generating between 100 kg. and
1000 kg. per month must accompany hazardous waste shipments with a Uniform Hazardous
Waste Manifest. One of the items on the manifest that must be completed is item 12,
"Containers." "Containers" specifies the number and type of containers. On desig-
nating the container type, the SQG completing the manifest must select one of 12
types. Dry cleaners sometimes package and ship hazardous wastes in plastic bottles,
similar to Clorox bottles. How should item 12 be completed?
Once a hazardous waste is packaged per DOT/EPA regulations, the container
must be categorized according to item 12 on the manifest. A plastic
bottle would be categorized as "DF.n "DF" means fiberboard or plastic
drums, barrels, or kegs. In obtaining and completing the manifest, the
SQG should first contact the State regulatory agency responsible for
hazardous waste management as provided in 40 CFR 262.21. The State
agency will provide information regarding where to obtain the manifest
and how to complete the portions required by the State, if any.

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More inportantly the SQG must package and label the hazardous was,te according to
DOT regulations specified in 49 CFR Parts 172, 173, 178, and 179. All RCRA hazar-
dous wastes which are subject to 40 CFR Part 262 manifest vrequirements are also -
hazardous materials subject to DOT shipping requirements (40 CFR §263.10). In
complying with DOT requirements, technical assistance is available fran DOT by
calling the Office of Hazardous Materials Regulations, Materials Transportation
Bureau at (202) 426-2075.
Source: Curt (Xrercast (202) 382-4761
Carolyn Barley (202) 382-2217
Corrective Action
S. Section 3004(u) of HSWA authorizes corrective action for continuing releases at solid
waste management units. This provison is applicable to all permits issued after
November 8, 1984. In order to implement 3004(u), permit writers need infopnation on
solid waste management units and associated releases. Since guidance for this provision
has not been completed, what is the Agency's policy regarding collection of continuing
release data under 3004(u)?
Headquarters recommended to the Regions in RCRA Reauthorization Statutory Inter-
pretation (RSI) #3 dated Februrary 5, 1985, that several actions can be taken to
implement this new corrective action requirement prior to issuance of guidance
packages. Headquarters recommends that a notice be sent to each facility whose
Part B has been requested and for which a final determination was not made prior to
November 8, 1984. This notice should provide a general explanation of the new
corrective action provision, and the fact that additional information must be sub-
mitted to satisfy the new requirements. Such information includes physical and
operating characteristics of the units, and descriptions of any releases fran such
units.
Source: Virginia Steiner (202) 475-9321
Dave Fagan	(202) 382-4497
i. CERCLA
Reportable Quantity
An interim status surface impoundment receives listed hazardous waste. The reportable
quantity (PQ) for this particular waste is one pound. Since a call is necessary to the
National Response Center for any release of a reportable quantity into the environment,
must the owner/operator of the surface impoundment call the National Response Center each
time one pound of this hazardous waste is placed in his surface impoundment?
CERCLA 103(a) exempts federally permitted releases from reporting requirements. A
federally permitted release, defined in CERCLA section 101(10)(E), includes releases
in compliance with a legally enforceable final permit issued pursuant to RCRA §3005
(a) through (d) when such permit specifically identifies the hazardous substances
and makes such substances subject to a standard of practice, control procedure, or
bioassay limitation or condition, or other control on the hazardous substances in
such releases.
In addition, the April 4, 1985, Federal Register (50 re 13456), carments further on
the intention of this exclusion to include interim status facilities. Specifically,
it states that EPA believes that the disposal of hazardous substances at a disposal
facility in accordance with EPA regulations is not subject to CERCLA notification
provisions.
Source: Jack Koqyoanjian (202) 382-4130

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The Hotline responded to 7,237 questions and requests for documents in June. Of the
ANALYSES OF QUESTIONS
questions asked, the percentage of callers was:
Local Agencies 	1.2%
More calls were received by Region 3 than frcm any other Region. Breakdown 'by Region:
1 6.5%	3 23.3%	5 17.8%	7 4.3%	9 8.5%
2 12.4%	4 11.2%	 6 8.0%	8 4.5%	10 2.9%
Canada <1%	England <1%
RCRA	TSDF
General Information	222	 A-Scope/Applicability_	121
Jotification (3010)	88	 B-General Facility Standards	40
)efinitions (260.10)	101	 C-Preparedness Prevention	14
'etitions/Delisting (260.22)	88	 D-Contingency Plans	.	27
)efinitions (261.2 & 3)	147		E-Manifest/Recordkeeping/Reportinq 24
ixclusions (261.4)	127	 F-Groundwater Monitoring	88
Small Quantity Generator (261.5) 244	 G-Closure/Post-Closure	85
Recycle/Reclaim (261.6)	242	 H-Financial Requirements	38
Container Residues (261.7)	50	 I-Containers	76
teste ID (261 C&D)	456	 J-Tanks	100
262	Generator	K-Surface Impoundments	81
Manifest Info_	101	 L-Waste Piles	15
Pre—transport	43	M-Land Treatment	12
Ac emulation 	94	 N-Landf ills 	83
Recordkeeping & Reporting 41	 O-Incinerators	33
International Shipments	10	 P-Thermal Treatment	9
263	Transporter	59		Q-Chemical, Physical, Biological Treat.	19
270 B - Permit Application	90	 R-Underground Injection	11
D - Changes to Permits	29	 X-Miscellaneous Facility	3
F - Special Permits	7	 Y-Experimental	7
G - Interim Status	100	 266/267		106
271 State Programs	 103	
L24 Decision Making	8	 CERCLA General/Overview	122
RCRA Amendments	" -1821	Hazardous Substances/RQ	150
;	NCP		62
1. i ab i 1 i tv/Enf orcement 	87	 Taxes/I RS/PCLTF	10
Dther/Referrals		268	 Removal	36
Document Requests	999	 Reroedial/NPL	99
CERCLA Reauthorization	11	 On-site policy	27
Off-site Policy	2£
ERRIS/Notif ication	14
Liability/Enforcement	65

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IV. PUBLICATIONS
RCRA
"Alternate Concentration Limit Guidance Based on §264.94(b) criteria, Part I,
Information Required in ACL Demonstrations, Draft," June, 1985. Copies
are available frcm Vernon Meyers at (202) 382-4495
"Draft Minimum Technology Guidance on Double Liner Systems for Landfills
and Surface Impoundments - Design, Construction, and Operation," May 24, 1985,
EPA/530-SW-85-014. The Hotline will take requests.
"Fate of Selected Trace Metals in the Petroleum Refining Industry,"
June 5, 1985. Copies are available from the RCRA Docket. Copying charges
are $9.80. The Hotline will take requests.
"Permit Applicants Guidance Manual for Exposure Information Requirements
Under RCRA 3019, Final," July 3, 1985. Copies are available frcm the EPA
Regional Offices.
CERCLA
"Draft Superfund Health Assessment Manual," May 22, 1985. Copies are
available from the Superfund Docket. Copying charges are $37.50. The
Hotline will take requests.

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FEDERAL REGISTER NOTICES
Open Ccrment Period:
May 28, 1985: 50 FR 21772
(proposed LUST notification)
May 31, 1985: 50 FR 23250
(proposed schedule for Land
Disposal Restrictions)
A proposed rule for notification of undergound
storage tanks containing regulated substances
as defined in RCRA Subtitle I §9002. Conments
are due by July 15, 1985.
A proposed schedule for evaluating the order in
which to ban listed hazardous waste from land
disposal. Garments are due by July 30, 1985.
June Federal Register Notices:
•June 3, 1985: 50 FR 23359
(0MB clearance for information
collection requests from EPA)
June 5, 1985: 50 FR 23721
(proposed delisting for wastes
from EPA's Mobile Incinerator)
June 10, 1985: 50 FR 24362
(proposal to streamline
revisions to State hazardous
waste programs)
June 12, 1985: 50 FR 23658
(corrections to the proposed
delisting of waste frcm EPA's
Mobile Incinerator)
June 26, 1985: 50 FR 26389
(Notice of availability of API
report on burning hazardous
waste fuel)
June 26, 1985: 50 FR 26444
(proposed permitting standards
for underground tanks)
June 27, 1985: 50 FR 26562
(Notice of withdrawl of approval
of RCRA Interim Authorization
for Iowa)
A notice of OMB clearance for various EPA
information collection requests.
A proposed delisting for wastes generated fran
EPA's Mobile Incinerator System located in
McDowell, Missouri. Comments are due by
July 5, 1985.
A proposed rule to streamline and improve the
revision process of State hazardous waste
programs and increase public participation.
Comments are due by July 10, 1985.
A correction to the proposal on June 5,
to delist wastes generated at EPA's
Mobile Incinerator.
1985,
A notice of availability of API's report on
petroleum refining wastes burned as fuels.
This report is entitled "Fate of Selected
Trace metals in the Petroleum Refining
Industry."
A proposed rule for permitting standards for
tank systems storing or treating hazardous
waste. Ccrments are due by August 26, 1985.
Notice of reversion of the Interim Authorized
State of Iowa back to EPA control. Reversion
of the program is effective July 1, 1985.

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Cora Beebe, VW-562A
Frank Biros, WH-527
George Bonina, VH-563
Karen Brown, PM-220
John Bosky, EPA - Kansas City, KS
Eileen Claussen, WH-562
Henry Van Cleave, DOD/DLA
Pat Cohn, WH-527
Mike Cook, WH-562
Peter Cook, WH-527
Alan Corson, WH-565
Elizabeth Cotsworth, WH-563
Hans Crump, WH-548B
Truett DeGeare, WH-563
Steve Dorrler, EPA - Edison, NJ
Barbara Elkus, WH-527
Tim Fields, WH-548B
Ellaine Fitzback, WH-527
Lisa Friedman, LE-132S
George Garland, WH-562
John Gilbert, EPA - Cincinnati, OH
Iantha Gilmore, WH-562
Peter Guerrero, WH-563
Penny Hansen, WH-565
Bill Hanson, WH-548E
Betti Harris, EPA-Region VII
William Hedeman, WH-548
Lee Herwig, A-104
Rick Horner, WH-548B
Hotline Staff
Phil Jalbert, WH-548D
Alvin K. Joe, Jr., Geo/Resource
Jim Jowett, WH-548B
Ihad Juszczak, WH-562A
Robert Knox, WH-562
Jack Kooyoomjian, WH-548B
Mike Kosakowski, WH-527
Jerry Kotas, WH-527
Walter Kovalick, WH548
Donald Kraft, WH-548D
Tapio Kuusinen, PM-223
Robert Landers, EMSL/LV
Carol Lawson, A-107
John Lehman, VH-565
Steve Levy, WH-563
Fred Lindsey, WH-565
Gene Lucero, WH-527
James Makris, WH-548A
Susan Mann, WH-563
Jack McGraw, WH-562A
Tbny Montrone, WH-527
Sue More land (ASTSVWO)
Sam Napolitano, PM-220
Dean Nelson, A-104
Jim O'Leary, WH-562
Christina Parker, WH-562
Karen Reed, PM-273
John Riley, WH-548B
Clem Rastatter, WH-563
Dale Ruhter, WH-565
William Sanjour, WH-563
Pam Sbar, LE-134S
Mike Shaanon, WH-563
Ken Shuster, WH-565
John Skinner, WH-562
Elaine Stanley, WH-548
Jack Stanton, WH-527
Bruce Weddle, WH-563
Steve Wilhelm, Region VII
Russ Wyer, WH-548E
Hazardous Waste Division Directors, Regions I-X
Hazardous Waste Management Branch Chiefs, Regions I-X
Regional Counsel, Regions I-X
Regional Libraries, Regions I-X

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