EPA530-R-93-004I
                                                  PB93-922412
     MONTHLY HOTLINE RERQJBI
                     December 1993
                 RCRA/SF/OUST/EPCRA
                           RECEIVED
                                                 LIBRARY. REGION .-.5
    Hotline Questions and Answers  .

    Office of Underground Storage Tanks ....A	 1
    Emergency Planning and Community Right-to-Know Act (EPCRA).... 1
    New Publications

    Resource Conservation and Recovery Act (RCRA)	 5
    Comprehensive Environmental Response, Compensation, and
       Liability Act (CERCLA)	 5
    Emergency Planning and Community Right-to-Know Act (EPCRA).... 6
    Other	 6
    Federal Registers

    Final Rules	 7
    Proposed Rules	 7
    Notices	 8
    Call Analyses

    Calls Answered,
                                          15
    Caller Profiles	 18
    Hotline Topics	 20
RCRA/SF/OUST                   EPCRA
National Toll-Free No.: 800-424-9346    National Toil-Free No.: 800-535-0202
              TDD National Toil-Free No.: 800-553-7672
 This report is prepared and submitted in support at Contract No. 68-WO-0039.
 EPA Project Officer:
Carie VanHook Jasperse. (202) 260-7388
U.S. Environmental Protection Agency
Washington, DC 20460
                                                        Printed on
                                                       Recycled Paper

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                     HOTLINE QUESTIONS AND ANSWERS
                 OUST
1. Mineral  Spirits  as  a  Regulated
   Substance Under the UST Regulations

   Do the underground storage tank (UST)
regulations of 40 CFR Pan 280 apply to tanks
containing mineral spirits?

   Part 280 can apply to underground tanks
containing mineral spirits. The underground
tank regulations apply to any UST holding
regulated substances. The term "regulated
substance" is defined as any CERCLA
hazardous substance (except RCRA hazardous
wastes) and petroleum, including crude oil or
any fraction thereof that is a liquid at standard
temperature and pressure (SWDA §9001(2)
and 40 CFR §280.12). Mineral spirits, also
known as stoddard solvent, naphtha, or white
spirits, are typically refined petroleum
distillates from the light end of crude oil.
Mineral spirits are not specifically identified as
a hazardous substance under CERCLA
§101(14), but are generally petroleum
fractions. Underground tanks containing
petroleum-derived mineral spirits are therefore
subject to regulation as petroleum USTs under
Part 280. It is technically feasible, though
extremely rare, for mineral spirits to be derived
from coal. Coal-derived mineral spirits are
neither petroleum nor a hazardous substance.
Coal-derived mineral spirits would not be
regulated under Part 280 when stored in USTs.
                EPCRA
2. Proprietary  Compounds and  EPCRA
   §§311/312 Reporting

   A facility is storing a product mixture on-
site. Under OSHA regulations, the facility is
required to retain a material safety data sheet
(MSDS)for the mixture. According to the
MSDS, the mixture contains a zinc compound,
but no specific chemical identity or
concentration information is provided.  OSH&
regulations allow chemical manufacturers to
withhold this information from the MSDS under
a trade secrecy claim (29 CFR §1910.1200(i)).
From the MSDS, the owner/operator cannot tell
whether the proprietary compound is a
hazardous chemical (such as zinc
silicofluoride) or an extremely hazardous
substance (such as zinc phosphide).

   To comply with EPCRA §§311 and 312
reporting requirements, the facility must
determine whether this mixture exceeds the
appropriate inventory threshold level.  How
would the facility make this determination?
Once a quantity is calculated, should it be
compared to the hazardous chemical threshold
of10,000 pounds, or should the facility owner
or operator assume the compound is an
extremely hazardous substance (EHS) and
apply the lower threshold?

   Pursuant to 40 CFR §§370.28(a)(l) and (2),
a facility may report on a mixture as a whole or
on each hazardous component of the mixture.
The option of reporting by components,
however, is  not available if the components are

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Hotline Questions and Answers
                            December 1993
not known. In this case, since the MSDS
contains no information on the concentration
of the proprietary zinc compound, the facility
must report the mixture as a whole.

   The next step in evaluating whether a
facility is required to report under EPCRA
§§311 and 312 is to compare the quantities
stored on-site to the appropriate threshold
level codified in 40 CFR §370.20(b).  For
hazardous chemicals that are not EHSs,
reporting is required if the facility has over
10,000 pounds on-site at any one time. For
extremely hazardous substances, reporting is
necessary if the facility has the chemical on-
site in quantities over 500 pounds or the
threshold planning quantity (whichever is
lower).

   In this scenario, the specific identity of the
chemical is not available to the facility owner
or operator.  Because the facility receives an
MSDS for the mixture, the owner or operator
knows that the mixture contains a hazardous
chemical. While the owner or operator has a
duty to make all reasonable efforts to
determine whether or not the substance is an
EHS, if there is no information reasonably
available to the owner or operator to make this
determination, the regulations do not require
reporting the mixture as an EHS. For the zinc
compound mixture, the facility could assume
the mixture contains a hazardous substance
and apply the 10,000-pound threshold level to
the overall weight of the mixture. In addition,
the facility must state that it is "unknown"
whether the mixture contains an EHS by
writing this in the appropriate box on the
applicable form.
3. Sheet Metal  Reporting  and  the
   Exemption for Manufactured Solids
   Under §§311/312

   A facility stores and processes sheet metal
that contains a hazardous chemical requiring
a material safety data sheet (MSDS) under
OSHA's Hazard Communication Standard (29
CFR §1910.1200(c)). The sheet metal, when in
storage, is considered a manufactured solid
and is therefore excluded from the definition
of hazardous chemical under EPCRA
§311(e)(2). Does this exclusion still apply
when the sheet metal is cut, welded, or
brazed?

   The exclusion for manufactured solids in
EPCRA §31 l(e)(2) applies to "[a]ny
substance present as a solid in any
manufactured item to the extent exposure to
that substance does not occur under normal
conditions of use." Sheet metal is considered
a "manufactured item" which is typically
present as  a solid.  To determine whether or
not the sheet metal falls under this exemption,
the owner/operator of the facility must
determine  the extent of exposure to the
substance under normal conditions of use at
that facility. Storing, welding, and cutting can
all be considered "normal conditions of use"
at a facility.  In this example, only the sheet
metal in storage is exempt under §311(e)(2)
because it does not create a potential for
exposure to a hazardous chemical. Cutting,
welding, brazing, or otherwise altering the
form of the sheet metal does create a potential
for exposure, negating the exclusion under
§31 l(e)(2) and subjecting the weight of the
maximum amount of sheet metal used in this
fashion at  any time to reporting requirements
under 40 CFR §370.20(b).

   The regulations at 40 CFR §370.20(b)
state that a facility must submit an MSDS and
a Tier I form (or Tier H form) for any

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December 1993                                                Hotline Questions and Answers
hazardous chemical present at a facility in an
amount greater than 10,000 pounds and for any
extremely hazardous substance present at the
facility in an amount greater than or equal to
500 pounds or the threshold planning quantity,
whichever is tower. The entire weight of the
items to be altered (the non-exempt items) is
counted toward the threshold, not just the
weight of the hazardous chemical in the
section of the item on which work is done.
The weight of the entire piece of sheet metal is
used because the sheet is the manufactured
item; the  exemption cannot apply to a portion
of a manufactured item.

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                      NEW PUBLICATIONS
      HOW TO ORDER
   NT1S Publications are available by calling (703) 487-4650. or writing NHS, 5285 Port Royal Road, Springfield.
   VA 22161.  Use the NTIS Order Number listed under the document
   EPA Publication* are available through the HotUne. Use the EPA Order Number listed under the document
   RCRA/SF/OUST 1 -800-424-9346                    EPCRA/TMe III 1 -800-535-0202
            local 703-412-9810                            local  703-412-9877
                RCRA
TITLE: "WasteWi$e: EPA's Voluntary
Program for Reducing Business Solid Waste"
AVAILABILITY: Hotline
EPA ORDER NO.: EPA530-F-93-018
EPA will take regarding regional and state
involvement in the program. It also provides
information on short-term actions regarding
enforcement, permitting, risk assessment,
inspection, and public participation while the *.
strategy is under development
This brochure provides an introduction to
EPA's WasteWi$e program and presents an
overview of how the program assists
businesses in taking cost-effective actions to
reduce solid waste. It includes information on
strategies such as reducing waste generation,
collecting recyclables, and buying and
manufacturing goods with recycled content
The brochure also provides examples of
businesses that are successfully reducing solid
waste. A registration form for the WasteWi$e
program is included.

TITLE: "Source Reduction and Combustion
of Hazardous Waste: Memorandum From
Richard J. Guimond to Regional
Administrators, Regions I-X; May 18,1993"
AVAILABILITY: Hotline
EPA ORDER NO.: EPA530-F-93-037

This memorandum informs EPA Regional
Administrators of Carol Browner's objectives
for waste minimization and hazardous waste
combustion. It outlines long-term actions that
               CERCLA
TITLE: "The Hazard Ranking System
Guidance Manual: Environmental Fact Sheet"
AVAILABILITY: NTIS
NTIS ORDER NO.:  PB93-963 356

This fact sheet presents a summarization of the
Hazard Ranking System Guidance Manual. It
provides general guidance for individuals
involved in determining Hazardous Ranking
System (HRS) scores and preparing HRS
scoring packages.

TITLE: "Superfund Fact Sheet EPA
Completes Construction at 217 Sites by
September 30,1993"
AVAILABILITY: NTIS
NTIS ORDER NO.:  PB93-963351

This fact sheet provides an overview of
construction completion activities at sites on
the National Priorities List  Specifically, the
fact sheet describes the construction

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New Publications
                                                December 1993
completion list and process, and lists the 217
sites where construction has been completed as
of September 30,1993.
               EPCRA
TITLE: "Pollution Prevention and Right-to-
Know in the Government: Executive Order
12856"
AVAILABILITY: Hotline
EPA ORDER NO.: EPA100-K-93-001

On August 3,1993, President Clinton signed
Executive Order 12856 which requires all
federal facilities to comply with the SARA
Tide in reporting requirements. The
Executive Order also pledges the federal
government to reduce 50 percent of its releases
of §313 toxic chemicals by 1999. This booklet
outlines the principal requirements and goals
of the Executive Order.
                OTHER
TITLE: "Monthly Hotline Report"
AVAILABILITY: NTIS
NTIS ORDER NO.: See below

Yearly Subscription  PB93-922 400
                   530-R-93-004
January 1993


February 1993


March 1993


April 1993
PB93-922401
530-R-93-004a

PB93-922402
530-R-93-004b

PB93-922 403
530-R-93-004c

PB93-922 404
530-R-93-004d
                      May 1993


                      June 1993


                      July 1993


                      August 1993


                      September 1993


                      October 1993


                      November 1993


                      December 1993
PB93-922 405
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530-R-93-0041
                      The reports contain questions that required
                      EPA resolution or were frequently asked,
                      publications availability, Federal Register
                      summaries, and Hotline call statistics.

                      The Monthly Hotline Report Questions and
                      Answers are also available for downloading at
                      no charge from CLU-JN at (301) 589-8366.

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                            FEDERAL REGISTERS
            FINAL RULES
         PROPOSED RULES
EPCRA
'Toxic Chemical Release Reporting;
 Addition of Ozone Depleting Chemicals"
 December 1,1993 (58 EB 63496)

 EPA added 11 hydrochlorofluorocarbons
(HCFCs) to the list of toxic chemkals subject to
reporting under EPCRA §313 and PPA §6607.
The first reports that include these chemicals will be
due July 1,1995, to cover die 1994 reporting year.

'Toxic Chemical Release Reporting;
 Addition of RCRA Chemicals"
 December 1,1993 (58 EB 63500)

 EPA added 21 chemicals and 2 chemical
categories to die list of toxic chemicals subject to
reporting under EPCRA §313 and PPA §6007. All
of these chemicals and chemical categories appear
on the RCRA list of hazardous wastes at 40 CFR
§261.33(0- The first reports that include these
chemicals will be due July 1,1995, to cover the
1994 reporting year.
RCRA
"Financial Assurance Mechanisms for
 Local Government Owners and Operators
 of Municipal Solid Waste Landfill
 (MSWLF) Facilities"
 December 27,1993 (58 EB 68353)
 EPA proposed to amend die financial assurance <
provisions of the MSWLF criteria, which were
promulgated on October 9,1991, under Subdue D
ofRCRA. This proposed rule would add a
financial test and a guarantee to die mechanism
available for securing financial assurance by local
governments. Comments must be submitted on or
before February 25,1994.

EPCRA
" Risk Management Programs for Chemical
 Accidental Release Prevention"
 December 14,1993 (58 EB 65311)

 EPA scheduled an additional public hearing
concerning die risk management programs which
were proposed on October 20,1993 (58 EB 54190).
The hearing is scheduled for January 6,1994, in
Houston, Texas.

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Federal Registers
                            December 1993
                                       'ICES
RCRA

"Land Disposal Restrictions; BASF
 Corporation"
 December 8,1993 (58 EB 64575)

 EPA reissued an exemption to the RCRA land
disposal restrictions » BASF Corporation (BASF)
for the operation of a hazardous waste injection weD
in Geismar, Louisiana. BASF has demonstrated
that there will be no migration of hazardous
constituents from the injection zone of the well
The reissuance is effective November 30,1993.

"Connecticut; Final Determination of
 Adequacy of State/Tribal Municipal Solid
 Waste Permit Program"
 December 15,1993 (58 EB 65591)

 Pursuant to RCRA §4005(cXlXQ, EPA gave
notice of a final determination of full program
adequacy for Connecticut's municipal solid waste
landfill permit program. The determination of
adequacy is effective December 15,1993.

"Alabama; Partial Program Adequacy
 Determination of State/Tribal Municipal
 Solid Waste Permit Program"
 December 17,1993 (58 EB 65982)

 Pursuant to RCRA §4005(cXlXQ, EPA gave
notice of a tentative determination, public hearing,
and public comment period concerning die
adequacy of Alabama's municipal solid waste
landfill permit program. The public hearing is
scheduled for February 10,1994. Comments must
be submitted on or before February  10,1994.
"Nebraska; Final Partial Program
 Determination of Adequacy of State/Tribal
 Municipal Solid Waste Landfill Permit
 Program"
 December 17,1993 (58 EB 65985)

 Pursuant to RCRA §4005(cXlXC). EPA gave
notice of a final determination of partial program
adequacy for Nebraska's municipal solid waste
permit program. The determination of adequacy is
effective December 17,1993.

"Texas; Final Partial Program
 Determination of Adequacy of State/Tribal
 Municipal Solid Waste Landfill Permit
 Program"                             ?
 December 17,1993 (58 EB 65986)

 Pursuant to RCRA §4005(cXlXQ, EPA gave
notice of a final determination of partial program
adequacy for Texas' municipal solid waste landfill
permit program. The determination of adequacy is
effective December 17,1993.

" Hazardous Waste Management System;
 Identification and Listing of Hazardous
 Waste; Extension of Comment Period"
 December 21,1993 (58 EB 67389)

 EPA extended the comment period on the
proposed delisting decision for Conversion
Systems, Inc., in Horsham, Pennsylvania.
Comments must be received on or before January 3,
1994.

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December 1993
                           Federal Registers
                                     NOTICES
 "Montana; Final Determination of Partial
  Adequacy of State/Tribal Municipal Solid
  Waste Permit Program"
  December 21,1993 (58 EB 67408)

  Pursuant to RCRA §40Q5(cXlXQ, EPA gave
 notice of a final determination of partial program
 adequacy for Montana's municipal solid waste
 landfill pennit program. The determination of
 adequacy is effective December 21,1993.

 "Michigan; Partial Program Adequacy
  Determination of State/Tribal Municipal
  Solid Waste Permit Program"
  December 22,1993 (58 EB 67786)

  Pursuant to RCRA §4005(cXlXQ, EPA gave
 notice of a tentative determination, public hearing,
 and public comment period concerning die
 adequacy of Michigan's municipal solid waste
 landfill permit program. The public hearing is
 scheduled for February 4,1994. Comments must be
 received on or before February 4,1994.

 "Oklahoma; Final Determination of
  Adequacy of State/Tribal Municipal Solid
  Waste Permit Program"
  December 28,1993 (58 EB 68643)

  Pursuant to RCRA §40Q5(cXl)(Q, EPA gave
 notice of a final determination of full program
 adequacy for Oklahoma's municipal solid waste
 landfill pennit program. The determination of
 adequacy is effective December 28,1993.

 "Land Disposal Restrictions Exemption;
  Morton International, Inc."
  December 29,1993 (58 EB 68907)

  EPA granted an exemption to the RCRA land
 disposal restrictions to Morton International, Inc., for
 the operation of a waste disposal well in Moss
 Point, Mississippi Morton has demonstrated that
there will be no migration of hazardous constituents
from the injection zone of die well The exemption
is effective November 19,1993.

"Nevada; Adequacy Determination of State/
 Tribal Municipal Solid Waste Permit
 Program
 December 30,1993 (58 EB 69362)

 Pursuant to RCRA §4005(cXlXQ, EPA gave
notice of a tentative determination, public hearing,
and public comment period concerning the
adequacy of Nevada's municipal solid waste landfill
pennit program.  The public hearing is scheduled for
January 31,1994. Comments must be submitted oa
or before January 31,1994.

RCRA/CERCLA/OSHA

" Lead Subcommittee; Public Meeting"
 December 3,1993 (58 EB 63963)

 EPA gave notice of a meeting of die Lead
Subcommittee of die National Advisory Council for
Environmental Policy and Technology (NACEPT)
to be held on December 15,1993, in Washington,
DC The subcommittee will discuss final draft
working papers and review a draft summary of die
subcommittee's report to NACEPT.

CERCLA

"National Priorities List; Charievolx
 Municipal Well Site"
 December 2,1993 (58 EB 63531)

 EPA announced die deletion of die Charlevoix
Municipal Well Site in Charlevoix, Michigan, from
die National Priorities List  This action was taken
because EPA and die State of Michigan determined
that no further cleanup under CERCLA was
appropriate. This action is effective December 2,
1993.

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  Federal Registers
                                                                           December 1993
                                        NOTICES
   ' National Priorities List; Monroe Township    " Proposed Purchaser Agreement; Mid-
   Landfill Site"                                Atlantic Wood Preservers Site"
   December 2,1993 (58 EB 63551)              December 9,1993 (58 EB 64766)
   EPA intends to delete the Monroe Township
  Landfill Site in Monroe, New Jersey, from the
  National Priorities List This action is being taken
  because EPA and die State of New Jersey
  determined that no further cleanup under CERCLA
  is appropriate. Comments must be subnioed on or
  before January 3,1994.

  "National Priorities List; Ringwood Mines/
   Landfill Site"
   December 8,1993 (58 EB 64539)

   EPA intends to delete the Ringwood Mines/
  Landfill Site in Ringwood, New Jersey, from the
  National Priorities List This action is being taken
  because EPA and die State of New Jersey
  determined that no further cleanup under CERCLA
  is appropriate. Comments must be submitted on or
  before January 7,1994.

  " Proposed Puchaser Agreement; Croydon
   TCESIte"
   December 8,1993 (58 EB 64584)

   EPA executed a proposed purchaser agreement
  associated with die Croydon TCE Site in Croydon,
  Pennsylvania, on September 30,1993. The
  settlement would require die purchasees to pay a
  principal payment of $6,000 over a one-year period,
  with interest, to the Hazardous Substances
  Superfund, GinrnOTts must be submitted on or
  before January 7,1994.
 EPA executed a proposed purchaser agreement
associated with die Mid-Atlantic Wood PR
Site in Harmans, Maryland, on September 30,1993.
The settlement would require the purchasees to pay
a principal payment of $10,000 to the Hazardous
Substances Superfund. Comments must be
submitted on or before January 10,1994.

" Proposed Administrative Settlement;
 Capitol Laboratories Assay Site"
 December 13,1993 (58 EB 65182)
                                         ^

 EPA proposed to enter into an administrative
settlement under CERCLA §122(i). The settlement
tequiies the settling parties to reimburse EPA
$35,000 for costs incurred in connection with die
Capitol Laboratories Assay Site in Baltimore,
Maryland. Comments must be submitted on or
before January 12,1994.

" Proposed DeMinimis Settlement; Endicott
 WeJffieWSite"
 December 13,1993 (58 EB 65183)

 EPA proposed to enter into an administrative de.
minimis settlement under CERCLA §1220). The
settlement requires the de minimis parties to
reimburse EPA $50,000 for costs incurred in
connection with die Endicott Wellfield Site in
Endicott, New York. Comments must be submitted
on or before January 12,1994.
10

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December 1993
                             Federal Registers
                                      NOTICES
"Consent Decree; Iron Hill Road Site
  December 14, 1 993 (58 EB 65397)
  A Consent Decree in
         i ft air wa* l^dg^ with 
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  Federal Registers
                              December 1993
                                        NOTICES
  "Consent Decree; Missouri Electric Works,   "National Priorities List; Mobray
   ln
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December 1993                                                        Federal Registers
                                   NOTICES
EPCRA

'Toxics Data Reporting Subcommittee;
 Public Meeting"
 December 17,1993 (58 EB 65982)

 EPA gawiwoa of a two-day meeting of the
Toxics Data Reporting Subcommittee of die
National Advisory Council for Environmental
Policy and Technology on January 13 and 14,1994,
in Washington, DC Comments must be submitted
on or before January 6,1994.
                                                                                 13

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14

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                      CALL ANALYSES
                   CALLS ANSWERED BY HOTLINE
                      December Dally Volume*
                                              RCRA/SF/OUST
                         Emergency Planning and
                         Community RighMo-Know
                   8   9  10  13  14  15 16  17  20  21  22 23  27  28  29 30
                            Year to Date*
RCRA/SF/OUST
January
February
March
April
May
June
July
August
September
October
November
December
Month
11,299
10,688
11,996
10,493
10,035
10,977
11,001
11,125
10,957
10,620
11,010
10,252
Cumulative

21.987
33,983
44,476
54,511
64,488
75,489
86,614
97,571
108,191
119,201
129,453
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW

January
February
March
April
May
June
July
August
September
October
November
December
Month
2,772
4.167
3,772
3,282
4,946
9.026
3,113
2,414
2,317
2,165
2,418
2,100
Cumulative

6,939
10,711
13,993
18,939
27,965
31,078
33,492
35,809
37,974
40,392
42,492
•All calls answered by the Call Management System, the Message Retrieval Line, and the Document Retrieval Line.
                                                                          15

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   Call Analyses
December 1993
                                CALLS ANSWERED BY TYPE
                                   December Daily Volume*
                                                                Questions
                          8   9   10   13  14  15   16   17  20  21   22  23  27   28  29  30
                                         Year to Date*
Questions
January
February
March
April
May
June
Jury
August
September
October
November
December
Month
9,392
11,213
10,771
10,697
10,857
16.286
12,048
11.959
12,281
11,865
11,489
11,252
Cumulative

20,605
31,376
42,073
52,930
69.216
81.264
93.223
105,504
117,369
128,858
140,110
Documents

January
February
March
April
May
June
Jury
August
September
October
November
December
Month
3,652
3,431
4,706
4,034
4,124
4.807
3.865
3.613
3,471
3,658
4,161
3,682
Cumulative

7.083
11,789
15.823
19,947
24,754
28.619
32.232
35,703
39,361
43.522
47,204
Referrals

January
February
March
April
May
June
July
August
September
October
November
December
Month
1,339
1,679
1,378
1,088
893
801
758
820
657
607
675
563
Cumulative

3,018
4,396
5.484
6,377
7,178
7,936
8.756
9,413
10,020
10,695
11,258
   * All calls answered by the Call Management System, the Message Retrieval Line, and die Document Retrieval Line. A single
     call may include multiple questions combined with document requests and referrals.
16

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December 1993
Call Analyses
                      CALLS ANSWERED BY PROGRAM AREA
                                    December 1993*
* Based on 14,934 requests and excludes 563 referrals made from both Hotlines. Includes the Message Retrieval Line
 and the Document Retrieval Line.

                                      Year to Date*
January
February
March
April
May
June
July
August
September
October
November
December
RCRA
Month
63%
(8,230)
60%
(8.805)
58%
(9.043)
61%
(8,945)
53%
(7.992)
43%
(9.129)
62%
(9.856)
62%
(9.872)
63%
(9,899)
62%
(9,683)
61%
(9.573)
61%
(9,086)
Cumulative

62%
(17,035)
60%
(26.078)
60%
(35.023)
59%
(43.015)
56%
(52.144)
57%
(62.000)
57%
(71.872)
58%
(81.771)
58%
(91 ,454)
59%
(101,027)
59%
(110,113)
Superfund
Month
15%
(1.999)
11%
(1 ,570)
14%
(2.150)
13%
(1.848)
11%
(1.583)
10%
(2.020)
14%
(2.171)
16%
(2.347)
16%
(2.470)
16%
(2.444)
14%
(2.254)
13%
(2.025)
Cumulative

13%
(3,569)
13%
(5.719)
13%
(7,567)
13%
(9,150)
12%
(11.170)
12%
(13.341)
13%
(15,688)
13%
(18,158)
13%
(20,602)
13%
(22,856)
13%
(24.881)
OUST
Month
4%
(502)
3%
(484)
4%
(623)
3%
(506)
3%
(415)
2%
(456)
3%
(558)
4%
(638)
4%
(660)
5%
(739)
7%
(1.060)
7%
(1.047)
Cumulative

3%
(986)
4%
(1,609)
4%
(2.115)
3%
(2.530)
3%
(2.986)
3%
(3.544)
3%
(4.182)
3%
(4.842)
4%
(5,581)
4%
(6,641)
4%
(7.688)
Em*rg»m
Community
Month
18%
(2,313)
26%
(3.785)
24%
(3.661)
23%
(3.432)
33%
(4.991)
45%
(9.488)
21%
(3.328)
18%
(2.715)
17%
(2.723)
17%
(2.657)
18%
(2.763)
19%
(2,776)
cy Planning *
Right-to- Know
Cumulative

22%
(6,098)
23%
(9.759)
23%
(13.191)
25%
(18,182)
29%
(27.670)
28%
(30,998)
27%
(33.713)
26%
(36,436)
25%
(39,093)
24%
(41 .856)
24%
(44,632)
                                                                                   17

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  Call Analyses
                                               December 1993
                                 CALLER PROFILE
                                RCRA/OUST Hotline
                     Regulated Community                  6,486
                     Citizens                                408
                     State & Local Gov't/Native American       226
                     Federal Agencies                        235
                     Educational Institutions                    97
                     EPA                                   70
                     Other                                  106
                     Media                                  14
                     Interest Groups                           17
                     Congress                                 1
                     International                              4
                     Referrals*                              373
                     Document Retrieval line*                 720
                     Message Retrieval Line*                  118
                     TOTAL
                                   8^75
            Citizens
               5%
                         Federal Agencies
                               3%
All Others
  4%
                   State/Local Govt/
                   Native American
                         3%
                                                Regulated
                                                Community
      * No caller profile data available.
18

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 December 1993
                              Call Analyses
                             Emergency Planning and
                   Community Rlght-to-Know/Superfund Hotline
     Manufacturer
      Food/Tobacco                   35
      Textiles                        17
      Apparel                         1
      Lumber & Wood                12
      Furniture                       14
      Paper                          14
      Printing & Publishing            20
      Chemicals                     198
      Petroleum & Coal               72
      Rubber and Plastics              38
      Leather                         1
      Stone, Gay & Glass              22
      Primary Metals                  33
      Fabricated Metals               54
      Machinery (Excluding Electrical)   21
      Electrical&Electronic Equipment   45
      Transportation Equipment         20
      Instruments                     10
      Misc. Manufacturing            124
      Subtotal                       751
Consultants/Engineers
Attorneys
Citizens
Public Interest Groups
Educational Institutions
EPA
Federal Agencies
GOCOs
Congress
State Officials/SERCs
Local Officials/LEPCs
Fire Departments
Hospitals/Laboratories
Trade Associations
Union/Labor
Farmers
Distributors
Insurance Companies
Media/Press
Native Americans
International
Other
Referrals*
1,084
 316
 253
   38
   74
   52
 175
   12
   0
   91
   89
   24
   43
   21
   4
   7
   33
   11
   22
   4
   2
 181
 190
                                          TOTAL
                                 3,477
              Attorneys
                 10%
                Consultants/
                Engineers
                   33%
Manufacturers
     23%
                                           All Others
                                              26%
  * No caller profile data available.
                                                                                   19

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  Call Analyses
                                   December 1993
                                  HOTURE TOPICS
   RCRA
   Special Wastes
    Ash
    Mining Wastes, Bevill
    Medical Wastes
    Oil and Gas
   Subtitle C (General)
   Hazardous Waste Id. (General)
    Toxicity Characteristic
    Wood Preserving
    Listing of Used Oil
    Fluff
   Radioactive Mixed Waste
   Delisting Petitions
   Hazardous Waste Recycling
   Generators
    Small Quantity Generators
   Transportation/Transporters
   TSDFs General
    TSDFs Siting Facilities
    TSDFs Capacity
    TSDFs Treatment
    TSDFs Burning
    TSDFs Storage
    TSDFs Disposal
   Land Disposal Restrictions
   Permits and Permitting
   Corrective Action
   Financial Liability/Enforcement
   Test Methods
   Health Effects
   Waste Min /Pollution Prevention
   State Programs
   Hazardous Waste Data
   Household Hazardous Waste
   Subtitle D (General)
    Siting Facilities
    Combustion
   Industrial Waste
    Composting
    Source Reduction/Poll. Prev.
    Grants & Financing
   Procurement (General)
    Building Insulation
    Cement & Products with Fly Ash
   6
  23
  70
   4
 335
  62
  20
  15
   0
  26
  18
 1383
 5581
 196
  75
 228
   1
   4
  56
  67
  62
  48
 4851
 101
 179
  98
  98
  23
  4391
   61
   36
  163
 Paper & Paper Products
 Re-refined Lubricating Oil
 Retread Tires
Solid Waste Recycling (General)
 Aluminum
 Batteries
 Glass
 Paper
 Plastics
 Tires
 Used Oil
Markets (General)
 Aluminum
 Batteries
 Compost
 Glass
 Paper
 Plastics
 Tires
 Used Oil
RCRA General

TOTAL
*
 Includes 1,868 RCRA document requests.
SUPERFUND
General/Misc.
Access & Information Gathering
Administrative Record
ARARs
CERCLIS
Citizen Suits
Claims Against Fund
Clean-Up Costs
    3
    5
    4
  1901
    9
   27
    9
    5
   18
   35
  187
    8
    3
    2
    0
    4
    1
    2
   13
   21
2,046^

9,086*
1,451U  Clean-Up Standards
   25
   48
    6
   24
   18
    4
   14
    5
    3
Community Relations
Contract Lab Program (CLP)
Contractor Indemnification
Contracts
Definitions
Enforcement
Federal Facilities
Hazardous Substances
HRS
Liability
  318
    24
     6
    67
  140
    10
    21
    34
    68
    19
    15
     4
     6
    18
    36
    14
    79
    31
    74
   1 Hot topics for this month.
   Includes 118 message retrievals for Information on the delay in effective date for municipal solid waste landfills and 144
    document retrievals for the "Criteria for Solid Waste Disposal* package and "Safer Disposal for Solid Waste."
   Includes 386 document retrievals for the "Catalog of Hazardous and Solid Waste Publications."
20

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t •
       December 1993

       Local Gov't Reimbursement
       Natural Resource Damages
       NCP
       Notification
       NPL
       Off Site Policy
       OSHA
       PA/SI
       PRPs
       RD/RA
       Reauthprization
       Remedial
       Removal
       RI/FS
       Risk Asscss./Health Effects
       ROD
       RQ
       SACM
       Settlements
       SITE Program
       State Participation
       State Program
       TAGs
       Taxes

       Special Topics
        Oil Pollution Act
        SPCC Regulations
        Radiation Site Cleanup

       TOTAL
    15
    4
    53
    61
   1531
    17
    4
    21
    47
    8
    23
    95
    29
    29
    46
    45
   1551
    34
    56
    15
    9
    8
    7
    5
    17
     7
    78
2,025*
        Includes 589 Superfund document requests.

        OUST
        General/Misc.                   3461-2
        Applicability/Definitions           76
        Regulated Substances              14
        Standards for New Tank Systems    11
        Tank Standards and Upgrading        8
        Operating Requirements             8
        Release Detection                 87
        Release Reporting & Investigation   19
        Corrective Action for USTs         80
        Out-of-Service/Closure            39
        Financial Responsibility         3191
        State Programs                   19
        Liability/Enforcement              11
        LUST Trust Fund                 10
       TOTAL
1,047'
                            Call Analyses

EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW

General Tide HI Questions         151

Emergency Planning (§§301-303):
  General                        71
  Notification Requirements        23
  SERC/LEPC Issues              32
  EHSs/TPQs                    27
  Risk Communication/
   Hazards Analysis               20
 Exemptions                      5
Emergency Release Notification (§304):
  General                        49
  Notification Requirements        41
  Reportable Quantities            98
  CERCLA § 103 vs. SARA §304    43
  ARIP/AHEDB/ERNS             2
  Exemptions                    19
Hazardous Chemical Reporting
(§§311-312):
  General                        77     ?
  MSDS Reporting Requirements    60
  Tier I/O Requirements           148
  Thresholds                     36
  Hazard Categories                7
  Mixtures Reporting              14
  Exemptions                    45
Toxic Chemical Release Inventory (§313):
  General                       120
  Reporting Requirements         126
  Thresholds                     60
  Form R Completion             162
  Supplier Notification             22
  NOTEs/NONs                  12
  Voluntary Revisions             40
  Pollution Prevention, 33/50       20
  Public Access to Data            63
  TRI Database                   38
  Petitions                       39
  TRI Expansion                  45
  Exemptions                    42

General
  Trade Secrets                   13
  Enforcement                   27
  Liability/Citizen Suits             4
  Training                        3
  Chemical-Specific Information    86
  RCRA                        131
        Includes 378 OUST document requests.
        1 Hot topics for this month.
        'Includes 190 document retrievals for "Guide to EPA Materials on USTs."
        •Topics are calculated as the summation of all questions received by the Hotline. A single call may result la
         multiple questions.
                                                    21

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  Call Analyses                                                          December 1993
   Special Topics:
    CAA§112(r)
     General                       43
     RMPs                        312
     List of Regulated Substances     175
     HF Study                      77
    Federal Facilities Executive Order  148

   TOTAL                         2,776*

    Includes 729 Emergency Planning Community
    Right-To-Know document requests.
    TOTAL HOTLINE QUESTIONS,
    DOCUMENT REQUESTS AND
    REFERRALS:
                                  15,497
      • Topics are calculated as the summation of all questions received by the Hotline. A single caB may result in multiple
       questions.
22

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