RAMP Revised Waste In & Request

[VERNIG.PETER@FORUM.VA.GOV]

Information:  This concerns the RAMP Industries Superfund Site.
 
I have just finished my reply to the Request for Additional Information
Any of you out there that had liquid waste of any kind go to Ramp should
read the Enclosure [In my letter it's 3] "PROTOCOLS USED TO DETERMINE
WASTE-IN/WASTE OUT VOLUMES" the Section titled "Tracking Waste Categories"
This says that all liquid waste has been classified as "Liquid Hazardous
Scintillation Waste" or LHSW.
 
If waste was manifested as Liquid Scintillation Waste or LSC or what
ever, that designation will probably stick unless the manifest clearly
says Non-hazardous or not containing toluene or xylene.  But if you
had another kind of liquid waste it is being classed as hazardous.  In
our case aqueous liquid waste, so identified on the manifests.  I talked
with Ms Pokorney, the EPA Enforcement Specialist for the Ramp Site and
she indicated I should challenge that classification in the same manner
you may challenge the waste in or waste out numbers.
 
Ms. Pokorney indicated that the waste-in volume numbers would be modified
by some to be determined method to reflec relative hazard in assessing
a pro-rated portion of the clean up costs.
 
REgards
Peter G. Vernig, VA Medical Center, Denver, vernig.peter@forum.va.gov
 
This message does not reflect the opinion of the Denver VA Medical Center,
Dept. of Veterans Affairs, or U.S. Government or any of it's agencies.
It is the authors opinion only.