MONTHLY HOTLINE REI
October 1997
RCRA, Superfund, and EPCRA
EPA530-R-97-005J
SUB-9224-97-010
ENVIRONMENTAL PROTECTION AQENCY
LIBRARY BFfilflN
Hotline Questions & Answers
Resource Conservation and Recovery Act (RCRA) 1
Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA) 1
Clean Air Act (CAA Section 112(r)) 3
New Publications
Resource Conservation and Recovery Act (RCRA) 5
Underground Storage Tanks (UST) 6
Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA) ..' 6
Emergency Planning and Community Right-to-Know (EPCRA) 8
Federal Registers
Final Rules 11
Proposed Rules 12
Notices 13
Call Analyses ,
Caller Profiles 19
Hotline Topics 21
RCRA, Superfund, and EPCRA
National Toil-Free No.: 800-424-9346
Local: 703-412-9810
TDD National Toil-Free No.: 800-553-7672
This report is prepared and submitted in support of Contract No. 68-W6-0016.
Judi Kane, Project Officer
Sheretta Dixon, Alternate Project Officer
U.S. Environmental Protection Agency
Washington, DC 20460
Printed on
Recycled Paper
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MONTHLY HOTLINE REPORT
AVAILABILITY
Electronic Availability
The Monthly Hotline Report Questions and
Answers are also available for downloading at
no charge from the CLU-IN bulletin board via
modem at (301) 589-8366 or telnet at clu-
iri.epa.gov. After registering, select Directory
8 from the file submenu. CLU-IN also has the
Monthly Hotline Reports available via the
World Wide Web (WWW) at
ftp'.//clu-in.com/download/hotline/
The complete text of the 1991 (November and
December only), 1992, 1993, 1994, 1995, and
1996 Monthly Hotline Reports may be
accessed via the WWW. Go to the Hotline
Home Page at
http://www.epa.gov/epaoswer/hotline/
and select "Monthly Hotline Reports."
The Hotline maintains an electronic mailing
list named HOTLINE_OSWER. Subscribers
will have Hotline announcements and Monthly
Hotline Reports e-mailed to them as they are
released, at no charge.
• To subscribe to the Hotline electronic
mailing list send an e-mail to:
listserver@unixmail.rtpnc.epa.gov
Subject: SUBSCRIBE TO LISTSERVERS
Message: SUBSCRIBE
HOTLINE_OSWER your first name your
last name
For example, SUBSCRIBE
HOTLINEJDSWER JOHN SMITH
• To receive the Help file with useful
commands for users send an e-mail to:
Listserver @ unixmail .rtpnc .epa.gov
Subject: HELP
Message: HELP
National Technical Information Service
(NTIS)
The Monthly Hotline Report can be ordered
through NTIS at (703) 487-4650. The NTIS
order numbers are as follows:
Yearly Subscription SUB-9224-97-000
January 1997 SUB-9224-97-001
February 1997
March 1997
April 1997
May 1997
June 1997
July 1997
August 1997
September 1997
October 1997
RCRA Docket
SUB-9224-97-002
SUB-9224-97-003
SUB-9224-97-004
SUB-9224-97-005
SUB-9224-97-006
SUB-9224-97-007
SUB-9224-97-008
SUB-9224-97-009
SUB-9224-97-010
EPA and state personnel can order the Monthly
Hotline Report from the RCRA Docket at
(703) 603-9230. The order number for the 1997
yearly subscription is EPA530-R-97-005.
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HOTLINE QUESTIONS. AND ANSWERS
RCRA
1. Changing Financial Assurance
Mechanisms During Post-Closure
A permitted treatment, storage, and
disposal facility (TSDF) uses the financial test
to satisfy the 30-year maintenance and
monitoring post-closure period financial
assurance requirements (40 CFR
§264.145(f)). If the owner or operator no
longer passes the financial test, he must
establish an alternative financial assurance
mechanism to fund the remainder of post-
closure care. One option is to use a trust
fund. If the facility chooses to utilize a trust
fund for the remainder of the post-closure
period, what would be the pay-in period?
The facility does not have a pay-in period.
The owner or operator must establish a fully
funded trust fund that can immediately cover
all remaining costs of post-closure care. If an
owner or operator initially chooses the trust
fund as the financial assurance mechanism,
the owner or operator would contribute
annually to the trust fund over the term of the
initial RCRA permit, or over the remaining
operating life of the facility, whichever period
is shorter, as specified in the closure plan
(§264.145(a)(3)). If the owner or operator
switched from the financial test or any other
mechanism to the trust fund during the
operating life of the facility, the first payment
into the trust fund would have to equal the
amount the fund would have contained if the
trust fund were used initially (§264.145(a)(5)).
In both cases, by the time the facility began
the post-closure period, the fund would
contain enough money to cover the full cost of
post-closure care. In contrast, phasing
payments into a trust fund during a post-
closure pay-in period would not meet the
requirement that the facility provide full
funding for post-closure at the time of post-
closure activity.
A TSDF switching to a trust fund during
post-closure must ensure that the first payment
into the fund is the full amount to cover post-
closure care, since the facility would need to
draw from that fund immediately in the event
that it must cover the costs of monitoring and
maintenance. The facility in the example has
to either switch to a fully funded trust fund, or
establish some other financial assurance
mechanism. This guidance also applies to
interim status facilities.
CERCLA
2. RCRA Storage Requirements as an
ARAR at Superfund Sites
CERCLA §121(d)(2) specifies that
hazardous substances remaining on-site
during Superfund remedial actions must meet
federal standards, requirements, criteria, and
limitations, or more stringent state
requirements that are determined to be legally
applicable or relevant and appropriate
(ARAR) at the site. This includes the
hazardous waste management requirements
under RCRA. Under RCRA, a person who
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Hotline Questions & Answers
October 1997
generates 1,000 kg or more of hazardous
waste per month must comply with the large-
quantity generator (LQG) requirements under
40 CFR §262.34, which include a 90-day time
limit for the storage of hazardous waste. If an
LQG exceeds this time limit, he is considered
an operator of a treatment, storage, and
disposal facility (TSDF) subject to facility
standards in 40 CFR Parts 264 and 265 and
the permit requirements of 40 CFR Part 270.
If a person conducting a Superfund remedial
action generates over 1,000 kg per month of
RCRA hazardous waste during a Superfund
site remediation and exceeds the 90-day
storage time limit, must the generator meet the
TSDF and permitting requirements as ARARs?
Superfund on-site remedial actions must
meet the substantive requirements of ARARs
(CERCLA §121(d); 40 CFR §300.430(00) ^
(i)(A)). The LQG must comply with the
substantive requirements of the RCRA general
TSDF standards found in 40 CFR Parts 264
and 265, but not the permit requirements,
considered administrative requirements, found
in 40 CFR Part 270. Substantive requirements
are those requirements that pertain directly to
actions or conditions in the environment.
While Superfund cleanups will comply with all
the substantive requirements that permits
enforce, such as storage and treatment
standards, on-site activities are not required to
obtain the actual permit papers, or to obtain the
approval of state or local administrative bodies
(CERCLA §121(e)). The Superfund program
has its own set of administrative procedures
which assure proper implementation of site
cleanup. This policy avoids the application of
additional or conflicting administrative
requirements from other laws which could
result in unnecessary delays.
CAA
3. Mixtures and Flammable Regulated
Substance Thresholds
A stationary source has in a process a
mixture containing 9,000 pounds of butane and
1,001 pounds of water. The mixture meets the
criteria for a National Fire Protection
Association flammability rating of 4 (NFPA 4).
Is this process covered under the RMP
regulations?
Yes. The entire weight of a mixture
containing a regulated flammable substance
must be counted for threshold determination if
the mixture itself meets the NFPA 4 criteria.
The regulations at 40 CFR §68.115(b)(2), as
originally promulgated in the January 31,
1994, Federal Register (59 FR 4478), stated
that the entire weight of a mixture containing a
regulated flammable substance in
concentrations greater than one percent was to
be counted for threshold determination, unless
the owner or operator could demonstrate that
the mixture did not meet NFPA 4 boiling point
(BP) and flash point (FP) criteria. Regulated
flammable substances, when in mixtures that
did not meet the BP and FP criteria, were
exempt from threshold determination
(§68.115(b)(2)).
In the April 15, 1996, Federal Register (61
FR 16598), EPA proposed to clarify the
original method of threshold determination for
mixtures containing regulated flammable
substances. The proposed rule would exempt
from threshold determination mixtures
containing a regulated flammable substance in
concentrations greater than one percent that do
not meet the full NFPA 4 definition, and not
just the BP and FP criteria. EPA expects to
issue a final rule within the next year. While
the proposed amendments are being finalized,
EPA has stayed the original provisions of 40
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October 1997
Hotline Questions & Answers
CFR §68.115(b)(2) such that mixtures
containing regulated flammable substances
must meet the proposed NFPA 4 criteria (not
just the BP and FP criteria) in order to be
considered toward thresholds (§68.2). Because
this mixture meets NFPA 4, it is not affected
by the stay and the entire quantity of the
mixture must be counted toward the butane
threshold.
4. Interconnected Vessels and the
Definition of Process
According to the definition of "process" at
40 CFR §68.3, any group of vessels that are
interconnected is considered to be a single
process. If a stationary source has two
interconnected vessels, one containing 6,000
pounds of butane and the other 6,000 pounds
of propane, is this a covered process under 40
CFR Part 68?
No. Although the two interconnected
vessels are considered a single process, in
order for that process to be subject to the risk
management program regulations it must
contain more than a threshold quantity of a
regulated substance (40 CFR §68.10(a)). The
threshold quantity for both butane and propane
(and all other regulated flammable substances)
is 10,000 pounds (§68.130). The amounts of
different regulated substances present in a
single process need not be aggregated to
determine whether a threshold is exceeded. If,
at any time, however, more than 10,000
pounds of either butane or propane is present
in a process, that process would be covered by
the regulations at 40 CFR Part 68. Although
the process as described is not subject to Part
68, it is subject to Clean Air Act § 112(r)( 1),
the general duty clause.
However, if butane and propane were
present as a mixture in the process, then the
threshold quantity must be calculated
differently. Because a mixture of propane and
butane would meet the NFPA 4 flammability
criteria, the entire weight of the mixture would
need to be treated as the regulated substance,
and therefore aggregated toward the threshold
quantity.
5. OSHA Process Safety Management
Standards and Personnel Training
Under the risk management program
regulations at 40 CFR Part 68, sources with
Program 2 and Program 3 covered processes
are required to develop prevention programs
that include personnel training. Will
compliance with the training requirements
under OSHA's Process Safety Management
standard (PSM) automatically satisfy the
training requirements under 40 CFR §§68.54
and 68.71?
Yes. The training requirements for
Program 3 processes at 40 CFR §68.71 have
been adopted verbatim from the OSHA PSM,
with minor wording changes to address
statutory differences (61 FR 31712; June 20,
1996). EPA anticipates that sources whose
processes are already in compliance with
OSHA PSM will not need to take any
additional steps to comply with the Program 3
prevention program (61 FR 31673; June 20,
1996).
The training requirements for Program 2
processes at 40 CFR §68.54 are a streamlined
version of the OSHA PSM training
requirements, the primary difference being that
the OSHA documentation requirements have
been omitted (61 FR 31711; June 20, 1996).
Additionally, training conducted to comply
with other federal or state rules or industry-
specific standards or codes may be used to
demonstrate compliance with .the Program 2
training requirements (40 CFR §68.54(c)).
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NEW PUBLICATIONS
HOW TO ORDER
NTIS Publications are available by calling (703) 487-4650, or writing NTIS, 5285 Port Royal Road,
Springfield, VA 22161. Use the NTIS Order Number listed under the document.
EPA Publications are available through the Hotline. Use the EPA Order Number listed under the document.
RCRA, Superfund, and EPCRA National Toil-Free No.: (800) 424-9346
Local: (703)412-9810 TDD National Toll-Free No.: (800) 553-7672
EPA's fax-on-demand service distributes selected publications noted by a "fax-on-demand" number. To order
these documents, from your fax machine dial (202) 651-2060 (for OSW documents), (202) 651-2061 (for CEPPO
documents), and (202) 651-2062 (for OERR documents), and follow the instructions provided by the voice prompt,
using the fax-on-demand number noted. Please call the Hotline for detailed instructions on
using the fax-on-demand service.
EPA Publications Available on the Internet
You may access certain documents electronically by using this server:
World Wide Web (WWW): http://www.epa.gov
Documents on the WWW server may be located by using the on-line search functions.
Note: As of March 31, 1997, materials previously available from the Gopher server (gopher.epa.gov) will be
archived and henceforth available via the Internet solely on the World Wide Web server.
RCRA
TITLE: Native American Network
AVAILABILITY: Hotline
EPA ORDER NO: EPA530-N-97-006
This issue features the White Mountain
Apache tribe's efforts to close a former dump
site and discusses two new EPA grant
programs for Indian country. Other articles
include the formation of the Tribal Association
on Solid Waste and Emergency Response
(TASWER), EPA's Solid Waste Circuit Rider
program, new flexibility for small landfills,
and expansion of the WasteWi$e program to
tribal governments.
TITLE: Measuring Recycling: A Guide for
State & Local Governments
AVAILABILITY: Hotline
EPA ORDER NO: EPA530-R-97-011
This guide is designed to help state and local
agencies measure municipal solid waste
(MSW) recycling. It contains instructions,
definitions, case studies, tips, forms, and
worksheets to help calculate an MSW rate.
TITLE: WasteWi$e Update: Donation
Programs
AVAILABILITY: Hotline
EPA ORDER NO: EPA530-N-97-006
This issue highlights various donation
strategies implemented by WasteWi$e
partners. The issue discusses successfully
implemented programs, gives donation
program ideas, and emphasizes the importance
and practicality of donating excess products to
local organizations and other interested parties.
TITLE: Donation and Reuse Resource Listing
AVAILABILITY: Hotline
EPA ORDER NO: EPA530-N-97-005a
This document provides information on ten
programs that collect discarded textiles and
offers ways to integrate textile recycling into
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New Publications
October 1997
existing textile infrastructure. The document
also offers tips for initiating other textile
recycling programs, such as partnerships with
local charities and nonprofit organizations, and
includes a listing of companies that accept
non-industrial textiles.
TITLE: Source Reduction Program Potential
Manual: A Planning Tool
AVAILABILITY: Hotline
EPA ORDER NO: EPA530-R-97-002
This manual is designed to help local solid
waste managers determine the potential impact
of various source reduction options. The
manual examines the portions of different
wastestream categories that could be addressed
by specific source reduction programs.
TITLE: RCRA: Reducing Risk From Waste
AVAILABILITY: Hotline
EPA ORDER NO: EPA530-K-97-004
This publication gives a broad summary of the
RCRA program and regulations, including the
roles of EPA, states, tribes, the public, and the
regulated community. A glossary of terms
commonly associated with RCRA is provided,
as well as examples and definitions of various
types of hazardous wastestreams.
TITLE: Full Cost Accounting for Municipal
Solid Waste: A Handbook
AVAILABILITY: Hotline
EPA ORDER NO: EPA530-R-95-041
This handbook was developed to promote a
better understanding of the costs associated
with municipal solid waste services, and
answer questions about full cost accounting
(FCA). The handbook teaches how to
assemble necessary data, calculate full cost
information from available data, and report the
results of your FCA to government officials
and residents. Various case studies show how
communities across the country have
implemented FCA successfully.
UST
TITLE: Ordering Information on
Underground Storage Tanks
AVAILABILITY: Hotline
EPA ORDER NO.: EPA510-F-97-010
This brochure describes documents pertaining
to the UST program and their availability.
Highlighted documents pertain to the 1998
deadline requirements, federal UST
requirements, corrective action, and release
detection. The brochure also provides ordering
information for UST videos.
TITLE: Session Highlights from the Sixth
Annual State Fund Administrators Conference
AVAILABILITY: Hotline
EPA ORDER NO.: EPA510-B-97-008
This document is a collection of highlights
from notes taken by individual attendees at the
Sixth Annual State Fund Administrators
Conference, held in Sacramento, California, on
June 16-18, 1997. Included in the document
are questions and answers on various
environmental topics. Session topics'include
state fund issues, remediation, contamination,
corrective action, and natural attenuation.
CERCLA
TITLE: Superfund Innovative Technology
Evaluation (SITE) Technology Profiles - Ninth
Edition
AVAILABILITY: ORD/Internet
EPA ORDER NO.: EPA540-R-97-502
URL: http://www.epa.gov/ORD/SITE/
This report summarizes the development and
implementation of technologies involved in the
SITE program. The SITE program assesses
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October 1997
New Publications
innovative remediation, characterization, and
monitoring technologies for uncontrolled
hazardous waste sites.
TITLE: Superfund Today: Focus on Risk
Assessment
AVAILABILITY: NCEPI/Internet
EPA ORDER NO.: EPA540-K-96-003
URL: http://www.epa.gov/superfund/oerr/
comtools/index.htm
This issue of Superfund Today profiles the
human health risk assessment process under
CERCLA and presents a case study. The
document also discusses common cleanup
approaches that reduce risks.
TITLE: Rules of Thumb for Superfund
Remedy Selection
AVAILABILITY: NTIS/Internet
NTIS ORDER NO.: PB97-963 301
URL: http://www.epa.gov/superfund/oerr/
tec hres/rulesthm/abstract. htm
This guidance document describes basic
principles and expectations that should be
considered during the Superfund remedy
selection process. It also consolidates and
summarizes key elements from various remedy
selection guidance documents and policies.
TITLE: State Participation in Federal-Lead
Removal Actions
AVAILABILITY: NTIS
NTIS ORDER NO.: PB96-963 414
This fact sheet includes methods for on-scene
coordinators, remedial project managers, and
other Superfund personnel to encourage state
participation in federal-lead Superfund
removal actions.
TITLE: Health Effects Assessment Summary
Tables FY 1997 Update
AVAILABILITY: NTIS
NTIS ORDER NO.: PB97-921 199
The Health Effects Assessment Summary
Tables (HEAST) is a comprehensive listing of
provisional risk assessment information
relative to the oral and inhalation exposure
pathways for chemicals of interest to
Superfund, RCRA, and other EPA programs.
TITLE: Issuance of the Interim Policy on
Settlement of CERCLA §106(b)(l) Penalty
Claims and §107(c)(3) Punitive Damages
Claims for Noncompliance with
Administrative Orders
AVAILABILITY: NTIS
NTIS ORDER NO.: PB97-208 086
This policy addresses settlement of CERCLA
§106(b)(l) civil penalties and §107(c)(3)
punitive damages claims for noncompliance
with administrative orders. The intent of the
policy is to make calculations of CERCLA
civil penalties and punitive damages for
purposes of settlement a fair and effective
process for deterring noncompliance.
TITLE: CERCLA Coordination with Natural
Resource Trustees
AVAILABILITY: NTIS
NTIS ORDER NO.: PB97-963 248
This memorandum provides direction for
ensuring that the CERCLA requirements for
coordination with natural resources trustees are
met. It also clarifies the natural resources
trustees activities that are eligible for CERCLA
funds.
. 7
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New Publications
October 1997
TITLE: Clarification of the Role of
Applicable or Relevant and Appropriate
Requirements (ARARs) in Establishing
Preliminary Remediation'Goals under
CERCLA
AVAILABILITY: NTIS
NTIS ORDER NO.: PB97-963 246
This memorandum clarifies the relationship
between the two key remedy selection
mandates of CERCLA. The document
describes instances in which EPA may
establish preliminary remediation goals
(PRGs) at levels more protective than required
by ARARs.
TITLE: Establishment of Cleanup Levels for
CERCLA Sites with Radioactive
Contamination
AVAILABILITY: NTIS
NTIS ORDER NO.: PB97-963 210
This memorandum presents guidance for
establishing protective cleanup levels for
radioactive contamination at CERCLA sites.
Policies outlined in this memo cover all
radioactive contaminants, including radon, that
are of concern at a particular site. This
directive is limited to providing guidance on
the protection of human health and does not
address levels necessary to protect ecological
receptors.
EPCRA
TITLE: 1997 Annual Letter from CEPPO to
SERCs
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: N/A
URL: http://www.epa.gov/ceppo/pubs/serc-
97.html
This letter summarizes CEPPO's efforts to
implement CAA §112(r) and EPCRA in the
past year. It also describes other CEPPO
activities, such as counterterrorism, LEPC
surveys, and distribution of CAMEO to SERCs
and LEPCs.
TITLE: Letter from Labor Secretary Herman
and EPA Administrator Browner to Congress
re: EPA/OSHA Joint Accident Investigation
Program (September 5, 1997)
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: N/A
URL: http://www.epa.gov/swercepp/pubs.html
A letter to Congress describing the
coordination between EPA and OSHA to
investigate the root causes of chemical
accidents, improve chemical safety, and
prevent future accidents.
TITLE: Nationwide Survey of LEPC Data
Management Practices
AVAILABILITY: Hotline
EPA ORDER NO.: EPA550-R-97-001
This survey, conducted by the George
Washington University, investigates the use of
computers by LEPCs to manage data reported
under EPCRA. The survey also collected
information on LEPCs' use of CAMEO and
hazardous chemical inventory data in
emergency planning activities.
TITLE: Nationwide Survey of LEPC Data
Management Practices: Summary
AVAILABILITY: Hotline
EPA ORDER NO.: N/A
This fact sheet summarizes the nationwide
survey of LEPC data management practices
report, including the survey methodology and
results.
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October 1997
New Publications
TITLE: Chemical Safety Alert: Shaft Blow-
Out Hazard of Check and Butterfly Valves
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: EPA550-F-97-002f
URL: http://www.epa.gov/swercepp/acc-
his.html
EPA has published this alert to increase
awareness among facilities, SERCs, LEPCs,
and emergency responders of the possible
hazards of catastrophic failure of certain types
of check and butterfly valves. The alert
provides a bibliography of potentially
applicable statutes, regulations, codes, and
standards.
TITLE: Chemical Safety Alert: Explosion
Hazard From Ammonium Nitrate
AVAILABILITY: Hotline
EPA ORDER NO.: EPA550-F-97-002d
EPA has published this alert to increase
awareness among facilities of the possible
explosive hazards of ammonium nitrate among
facilities, SERCs, LEPCs, and emergency
responders. The alert provides a bibliography
of potentially applicable statutes, regulations,
codes, and standards.
TITLE: EPA/OSHA Joint Chemical Accident
Investigation Report: Napp Technologies, Inc.,
Lodi, New Jersey
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: EPA550-R-97-002
URL: http://www.epa.gov/swercepp/acc-
his.html
EPA and OSHA present the results of their
joint investigation of the explosion and fire at
the Napp Technologies Plant in Lodi, New
Jersey. The report includes significant facts
and causes of the accident, analysis,
recommendations, and outcomes of the
settlement between OSHA and Napp
Technologies.
TITLE: Section 313 Emergency Planning and
Community Right-to-Know Act Guidance for
Chemical Distribution Facilities, Version 1.0
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: N/A
URL: http://www.epa.gov/opptintr/tri/
industry.htm
EPA has developed this guidance manual to
assist chemical distribution facilities in
understanding the requirements of EPCRA
§313. The manual provides an overview of
§313, instructs facilities in making threshold
determinations, details estimation of releases
from chemical distribution facilities, and
provides a bibliography of references.
TITLE: Section 313 Emergency Planning and
Community Right-to-Know Act Guidance for
Coal Mining Facilities, Version 1.0
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: N/A
URL: http://www.epa.gov/opptintr/tri/
industry.htm
EPA has developed this guidance manual to
assist facilities that mine coal in understanding
the requirements of EPCRA §313. The manual
provides an overview of §313, instructs
facilities in making threshold determinations,
details estimation of releases from coal mining
facilities, and provides a bibliography of
references.
TITLE: Section 313 Emergency Planning and
Community Right-to-Know Act Guidance for
Metal Mining Facilities, Version 1.0
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: N/A
URL: http://www.epa.gov/opptintr/tri/
industry.htm
EPA has developed this guidance manual to
assist metal mining facilities in understanding
the requirements of EPCRA §313. The manual
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New Publications
OctobeM997
provides an overview of §313, instructs
facilities in making threshold determinations,
details estimation of releases from metal
mining facilities, and provides a bibliography
of references.
TITLE: Section 313 Emergency Planning and
Community Right-to-Know Act Guidance for
Petroleum Bulk Storage Facilities, Version 1.0
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: N/A
URL: http://www.epa.gov/opptintr/tri/
industry.htm
EPA has developed this guidance manual to
assist petroleum bulk storage facilities in
understanding the requirements of EPCRA
§313. The manual provides an overview of
§313, instructs facilities in making threshold
determinations, details estimation of releases
from petroleum storage, and provides a
bibliography of references.
TITLE: Section 313 Emergency Planning and
Community Right-to-Know Act Guidance for
Electricity Generating Facilities, Version 1.0
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: N/A
URL: http://www.epa.gov/opptintr/tri/
industry.htm
EPA has developed this guidance manual to
assist facilities that generate electricity in
understanding the requirements of EPCRA
§313. The manual provides an overview of
§313, instructs facilities in making threshold
determinations, details estimation of releases
from electricity generating facilities, discusses
how various activities at these facilities must
be reported, and provides a bibliography of
references.
TITLE: Section 313 Emergency Planning and
Community Right-to-Know Act Guidance for
RCRA Subtitle C TSD and Solvent Recovery'
Facilities, Version 1.0
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: N/A
URL: http://www.epa.gov/opptintr/tri/
industry.htm
EPA has developed this guidance manual to
assist RCRA Subtitle C treatment, storage, and
disposal (TSD) facilities and solvent recovery
facilities in understanding the requirements of
EPCRA §313. the manual provides an
overview of §313, instructs facilities in making
threshold determinations, details estimation of
releases from Subtitle C TSD and solvent
recovery facilities, and provides a bibliography
of references.
10
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FEDERAL REGISTERS
You may order copies of all major RCRA, Superfund, and EPCRA Federal Registers by calling the Hotline.
RCRA, Superfund, and EPCRA National Toil-Free No.: (800) 424-9346
Local: (703)412-9810 TDD National Toil-Free No.: (800) 553-7672
Electronic Availability
Federal Registers from October 1994 to the present related to the Hotline's program areas are accessible via
EPA's Public Access Servers. The servers are accessible at:
World Wide Web: http://www.epa.gov
FTP: ftp.epa.gov
EPA Federal Registers are organized by date on the World Wide Web (starting from October 1994).
Go to: http://WTWw.epa.gov/fedrgstr
For RCRA/UST and selected CERCLA Federal Registers, choose: Federal Register (FR) • Waste.
For selected EPCRA Federal Registers, choose: Federal Register (FR) - Toxic Release Inventory.
FINAL RULES
RCRA
"Revisions to Criteria for Municipal
Solid Waste Landfills"
October 2,1997 (62 FR 51606)
EPA confirmed the effective date of a final
rule, published July 29, 1997 (62 FR 40708),
which allows states to establish more flexible
final cover and methane monitoring
requirements for municipal solid waste
landfills. Congress granted EPA the authority
to allow this flexibility in the Land Disposal
Program Flexibility Act of 1996. The
effective date remains October 27, 1997.
"Project XL Site-Specific Rulemaking
for Merck & Co., Inc., Stonewall Plant"
October 8,1997 (62 FR 52622)
EPA provided site-specific relief from
certain Clean Air Act and RCRA requirements
to Merck & Co.'s Stonewall Plant in Elkton,
Virginia. EPA exempted Merck & Co., Inc.,
from RCRA air emission standards in 40 CFR
Parts 264 and 265, Subparts AA, BB, and CC.
This rule became effective October 8, 1997.
"Presidential Determination on
Classified Information Concerning the
Air Force's Operating Location Near
Groom Lake, Nevada"
October 8,1997 (62 FR 52647)
The President exempted the Air Force's
operating location near Groom Lake, Nevada,
from any solid waste abatement regulation
which would require the disclosure of
classified information.
11
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Federal Registers
October 1997
"New Hampshire Hazardous Waste
Management Program, Corrections"
October 10,1997 (62 FR 52951)
State program, corrections.
"Identification and Listing of
Hazardous Waste; Final Exclusion"
October 24,1997 (62 FR 55344)
EPA granted, under §§260.20 and 260.22, a
delisting for F019 sludge generated at GM's
Orion Assembly Center in Lake Orion,
Michigan. This delisting was proposed
April 18, 1997 (62 FR 19087). The effective
date of the delisting is October 24, 1997.
CERCLA
"Notice of Partial Deletion; Saegertown
Industrial Area Site"
October 6,1997 (62 FR 52032)
Notice of partial deletion.
"Notice of Deletion; Frit Industries
Superfund Site"
October 14,1997 (62 FR 53246)
Notice of deletion.
"Notice of Deletion; LaGrand Sanitary
Landfill Superfund Site"
October 23,1997 (62 FR 55178)
Notice of deletion.
"Notice of Deletion; Bowers Landfill
Superfund Site"
October 29,1997 (62 FR 56105)
Notice of deletion.
"Notice of Deletion; Northern
Engraving Corporation Superfund
Site"
October 29,1997 (62 FR 56106)
Notice of deletion.
PROPOSED RULES
RCRA
"Criteria for the Certification and
Recertification of the Waste Isolation
Pilot Plant's (WIPP) compliance with
the 40 CFR Part 191 Disposal
Regulations; Certification Decision
Proposed Rule "
October 30,1997 (62 F_R 58792)
EPA proposed to certify that the Department
of Energy (DOE) WIPP meets the disposal
regulations set forth in 40 CFR Part 191.
Section 8(d) of the Land Withdrawal Act of
1992 requires certification before EPA can
allow the placement of radioactive waste in
the WIPP. EPA must receive comments on or
before February 27, 1998.
CERCLA
"Notice of Intent to Delete; Monsanto
Superfund Site"
October 6,1997 (62 FR 52072)
Notice of intent to delete.
"Notice of Intent for Partial Deletion;
Prewitt Abandoned Refinery
Superfund Site"
October 9,1997 (62 FB 52674)
Notice of intent for partial deletion.
12
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October 1997
Federal Registers
"Notice of Intent to Delete; Cleve Reber
Super-fund Site"
October 6,1997 (62 FR 52072)
Notice of intent to delete.
"Notice of Intent to Delete; North
Hollywood Dump Superfund Site"
October 10,1997 (62 FR 52961)
Notice of intent to delete.
NOTICES
All Programs
"Review and Evaluation of EPA
Standards Regarding Children's
Health Protection from Environmental
Risks"
October 3,1997 (62 FR 51854)
EPA announced that it is seeking
recommendations for review of human health
protection standards, particularly as they relate
to children's health. EPA must receive written
comments on or before December 2; 1997.
"Common Sense Initiative Council
(CSIC)"
October 17,1997 (62 FR 54107)
EPA announced the times and dates of the
CSIC Meeting, and the CSIC Petroleum
Refining and Printing Sector Subcommittee
Meetings.
"Public Meetings Regarding
Environmental Information"
October 23,1997 (62 FR 55248)
EPA announced the dates and cities of 19
public meetings regarding the public's use of
environmental information.
"Statement of Regulatory Priorities;
Regulatory Plan"
October 29,1997 (62 FR. 57141)
EPA published its regulatory plan, which
contains a description of the most significant
regulatory actions the Agency expects to issue
in the current fiscal year or thereafter. The
plan contains a statement of regulatory
priorities and separate entries for each included
action.
"Semiannual Regulatory Agenda"
October 29,1997 (62 FR 58080)
EPA published its regulatory agenda, a
semiannual summary of current and planned
rulemakings and. Agency actions completed
since the previous publication of the agenda.
RCRA
"Performance Based Measurement
System"
October 6,1997 (62 FR 52098)
EPA announced its intent to implement a
Performance Based Measurement System
(PBMS) on a program-specific basis. PBMS
will specify the criteria by which the regulated
community can select analytical test methods
to meet the requirements of a particular
regulatory program, as opposed to specifying
the analytical test method itself. The RCRA
docket must receive comments on or before
November 5, 1997.
"Project XL Final Project Agreement"
October 7,1997 (62 FR 52334)
EPA announced a Final Project Agreement
(FPA) between EPA, the New Hampshire
Department of Environmental Services, the
New York Department of Environmental
13
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Federal Registers
October 1997
NOTICES
Conservation, and the HADCO Corporation.
The FPA seeks to determine the environmental
and economic costs and benefits of relaxing
RCRA regulatory control of wastewater
treatment sludge (F006) from HADCO
Corporation's facilities in New York and New
Hampshire.
"Submission for OMB Review;
Standards for Performance for Air
Emission Standards for Tanks,
Surface Impoundments and
Containers"
October 21,1997 (62 FR 54630)
EPA submitted the following information
collection request (ICR) for Office of
Management and Budget (OMB) review and
extension: Standards for Performance for Air
Emission Standards for Tanks, Surface
Impoundments and Containers, 40 CFR Part
264, Subpart CC and 40 CFR Part 265 Subpart
CC; OMB Control Number 2060-0318; EPA
ICR Number 1593.03. Comments must be
submitted on or before November 20, 1997.
"Notice of Intent to Prepare a Hanford
Site Solid (Radioactive and
Hazardous) Waste Program;
Environmental Impact Statement,
Richland, Washington"
October 27,1997 (62 FR 55615)
DOE announced its intent to prepare an
environmental impact statement (EIS) for the
Hanford Site Solid Waste program. This
program manages low-level, mixed low-level,
transuranic and mixed transuranic radioactive
wastes, as well as hazardous wastes, and
contaminated equipment.
"Regulatory Reinvention (XL) Pilot
Projects"
October 27,1997 (62 FR 55637)
EPA announced a Project XL FPA between
West Virginia Department of Environmental
Protection, and OSi Specialties, Sisterville,
West Virginia. OSi intends to adopt pollution
abatement strategies which will produce
environmental benefits greater than the
currently applicable regulations; EPA will, in
exchange, propose to exclude OSi from Parts
264 and 265, Subpart CC, air emission
standards, as well as other requirements.
"Proposed Collection; Comment
Request Entitled Environmentally
Sound Products"
October 28,1997 (62 FR 55788)
The Department of Defense (DoD), GSA, and
NASA announced their intent to submit to
OMB for review and extension a currently
approved ICR concerning environmentally
sound products; OMB Control Number 9000-
0134. Comments must be submitted on or
before December 29, 1997. This information
collection request complies with RCRA §6002
affirmative procurement program
requirements.
"Joint EPA/State Agreement To Pursue
Regulatory Innovation; Draft"
October 29,1997 (62 FR 56182)
EPA announced and solicited comment on a
draft "Joint EPA/State Agreement to Pursue
Regulatory Innovation." The Agreement,
prepared by EPA and the Environmental
Council of the States (ECOS), aims to improve
the efficiency and effectiveness of
environmental regulation. EPA provides an
14
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October 1997
Federal Registers
NOTICES
example of a tiered permit system for
hazardous waste recycling facilities which are
currently exempt from permitting requirements
in Part 270. EPA must receive comments on
or before November 28, 1997.
CERCLA
"Council on Environmental Quality;
Notice of Meeting Postponement"
October 2,1997 (62 FR 51660)
The Council on Environmental Quality is
postponing a public meeting to discuss the
development of a memorandum of
understanding on coordinating environmental
response and natural resource restoration,
initially scheduled for October 3, 1997. The
meeting is rescheduled for December 2, 1997.
"Announcement of Proposal Deadline
for the Competition for the 1998
National Brownfields Assessment
Demonstration Grants"
October 9,1997 (62 FR 52720)
EPA announced that it will begin to accept
proposals for the National Brownfields
Assessment Pilots on October 9, 1997. The
Brownfield pilots are designed to test cleanup
methods and facilitate coordinated cleanup and
redevelopment efforts on the state aind local
levels. EPA expects to select approximately
100 additional pilots by May 1998, with each
receiving funds up to $200,000 over two years.
The deadlines for the 1998 assessment pilots
are December 15, 1997, and March 23, 1998.
EPCRA
"Forum on State and Tribal Toxics
Action (FOSTTA) Projects; Open
Meetings"
October 3,1997 (62 FR 51857)
EPA announced that FOSTTA will hold
public meetings on October 20 and 21, 1997.
FOSTTA is made up of a coordinating
committee, and four issue-specific projects,
including a Toxics Release Inventory Project.
"Notice of Public Meetings on the Toxic
Release Inventory Reporting Form"
October 22,1997 (62 F_B 54847)
EPA announced that it plans to hold nine
public meetings over the next year to solicit
comments on the Toxic Release Inventory
(TRI) reporting Form R. Dates for the first
three meetings are contained in the notice.
"Notice of Moving of Emergency
Planning and Community-Right-to-
Know Act Reporting Center"
October 29,1997 (62 FR 56164)
EPA announced that the EPCRA Reporting
Center will move to a new location on
November 3, 1997. This move will only affect
those individuals submitting Toxic Release
Inventory reporting forms by courier or other
direct delivery service. The new address is
contained in the notice.
15
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Federal Registers
October 1997
NOTICES
ATSDR
"Availability of Draft Toxicological
Profiles"
October 28,1997 (62 F_B 55816)
As required under CERCLA, the Agency for
Toxic Substances and Disease Registry
(ATSDR) announced the availability of ten
updated draft toxicological profiles for
hazardous substances and three new drafts for
review and comment.
"Availability of Draft Toxicological
Profiles"
October 28,, 1997 (62 FB 55818)
As required under CERCLA, ATSDR
announced the availability of five updated draft
toxicological profiles for hazardous substances
and three new drafts for review and comment.
PPA
"Notice of Availability of Pollution
Prevention Grants and Announcement
of FinancialAssistance Programs
Eligible for Review"
October 1,1997 (62 FR 51465)
EPA announced that it expects to have
approximately $5 million available in fiscal
year 1998 for grants and cooperative
agreements under the Prevention Incentives for
States (PPIS) grant program. The funds are
targeted at state and tribal programs that
address the reduction or prevention of
pollution. .:-._-._- - _- _..
OPA
"Oil Pollution Prevention; Non-
Transportation Related Onshore
Facilities; Denial of Petition"
October 20,1997 (63 FR 54508)
EPA announced the denial of a petition
requesting the modification of the facility
response plan (FRP) rule to exclude certain
facilities that handle, store, or transport animal
fats and vegetable oils. EPA believes that the
petition did not substantiate any need to
differentiate between these types of oils and
petroleum based oil under the FRP rule.
Settlements and Consent Decrees
"Consent Decree; United States v. Marine
Shale Processors, Inc."
October 1, 1997 (62 FR 51489)
"Consent Decree; United States v. Vogel
Paint and Wax Co."
October 1, 1997 (62 FR 51490)
"Proposed Settlement; Brockton Gas
Works Superfund Site, Brockton,
Massachusetts"
October 2, 1997 (62 £R 51659)
"Proposed Settlement; Spruce Street Site,
Anchorage, AK"
October 3, 1997 (62 FR 51857)
"Consent Decree; United States v. Blue
Ridge Electric Membership Corp. et al."
October 6>.1997 (62EB5Z150)
"Consent Decree; United States v. Ray O.
Parker & Son, etal."
October 6, 1997 (62 FB 52150)
16
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October 1997
Federal Registers
NOTICES
"Consent Decree; United States v. Seattle
Disposal Company, et al."
October 6, 1997 (62 FR 52151)
"Consent Decree; United States v. Case
Corporation, et al."
October 8, 1997 (62 F_B 52574)
"Proposed Settlement; McAdoo
Associates Site-Blaine Street, Schuylkill
County, Pennsylvania"
October 14, 1997 (62 FR 53331)
"Proposed Administrative Settlement;
South Bay Superfund Site"
October 15, 1997 (62 F_B 53627)
"Consent Decree; United States and State
of Indiana v. A.M. Choitz, etal."
October 15, 1997 (62 FJR 53653)
"Consent Decree; United States v. H.
Brown Co., etal."
October 15, 1997 (62 FR 53654)
"Consent Decree; United States v.
MacGillis & Gibbs Co. and Soo Line
Railroad Co."
October 15, 1997 (62 FR 53654)
"Consent Decree; United States v. Case
Corporation, et al."
October 15, 1997 (62 F_B 52574)
"Consent Decree; United States v. John
Reardon and Paul Reardon"
October 15, 1997 (62 F_B 52575)
"Consent Decree; United States v.
RohmTech? Inc."
October 15, 1997 (62 £B 52575)
"Consent Decree; United States v. Taylor,
etal."
October 15, 1997 (62 FR 52576)
"Consent Decree; United States v.
Washington Central Railroad Company,
Inc., etal."
October 15, 1997 (62 FJR 52576)
"Consent Decree; United States v.
Cleveland Industrial Center, et al."
October 16, 1997 (62 FR 53802)
"Proposed Perspective Purchaser
Agreement; Kane and Lombard
Superfund Site"
October 17,1997 (62 FB 54108)
"Consent Decree; United States v.
Trustees of Boston University "
October 21, 1997 (62 FR 54652)
"Notice of Settlement; Text Tin Superfund
Site, Texas City, Texas"
October 21, 1997 (62 £R 54653)
"Consent Decree; United States v. Four
Winns, a division of Recreational Boat
Group, LP."
October 27, 1997 (62 FR 55658)
"Proposed Settlement; Yakima Plating
Company, Yakima, Washington"
October 29, 1997 (62 FB 56190)
"Proposed Administrative Order on
Consent; Butterfield Canyon Site"
October 30, 1997 (62 FR 58730)
17
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Federal Registers
October 1997
NOTICES
"Proposed Administrative Order on
Consent; Herriman Residential Soils
Removal Action Site"
October 30, 19977 (62 FR 58730)
"Consent Decree; United States v. Alaska
Railroad Corporation, et al."
October 30, 1997 (62 FR 58747)
"Proposed Covenant Not to Sue; College
of the Canyons Smelter Site"
October 31, 1997 (62 FR 58970)
18
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CALL ANALYSES
This month, the Hotline responded to a total of 16,964 questions and document requests.
CALLER PROFILE
RCRA/UST Hotline
Regulated Community
Citizens
State & Local Government
Native Americans
Federal Agencies
Educational Institutions
EPA
Media
Interest Groups
Congress
International
Other
Referrals*
Transfers to EPCRA/Superfund Hotline*
Document Retrieval Line*
Message Retrieval Line*
TOTAL NUMBER OF CALLERS
3,102
497
167
17
87
169
90
17
71
3
2
0
471
66.
199
289
5,247
1 No caller profile data available.
19
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Call Analyses
October 1997
Emergency Planning and Community Right-to-Know Act/
Superfund Hotline
Manufacturers
Food/Tobacco 15
Textiles 9
Apparel • 26
Lumber & Wood 5
Furniture 14
Paper 10
Printing & Publishing 24
Chemicals 46
Petroleum & Coal 27
Rubber and Plastics 7,
Leather 6
Stone, Clay & Glass 2
Primary Metals 9
Fabricated Metals 14
Machinery (Excluding Electrical) 4
Electrical & Electronic Equipment 18
Transportation Equipment 32
Instruments 9
Misc. Manufacturing 81
Subtotal 358
Consultants/Engineers ' 1,924
Attorneys 351
Citizens 324
Public Interest Groups 46
Educational Institutions 57
EPA 63
Federal Agencies 31
GOCOs 0
Congress 2
State Officials/SERC 79
Local Officials/LEPCs 35
Fire Departments 31
Hospitals/Laboratories 31
Trade Associations 3
Union/Labor 2
Farmers 1
Distributors 31
Insurance Companies 9
Media/Press 17
Native Americans 0
International 1
Other 102
Referrals* 272
Transfers to RCRA/UST Hotline* 204
Document Retrieval Line* 0
Message Retrieval Line* 266
* No caller profile data available.
TOTAL NUMBER OF CALLERS 3,882
20
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October 1997
Call Analyses
HOTLINE TOPICS
RCRA
RCRA GENERAL
SUBTITLE C
Hazardous Waste Id. - General
Characteristics
Listings
Mixture Rule
Derived-From
Contained-In Policy
Sampling
Solid and Hazardous Waste Exclusions
Radioactive Mixed Waste
Delisting Petitions
Definition of Solid Waste/Hazardous
Waste Recycling
Large Quantity Generators
Small Quantity Generators
CESQGs
Transporters
Exports/Imports
TSDFs
General Facility Standards
Unit Standards
Air Emissions
Combustion - General
BIFs
Incinerators
Draft Strategy
Waste Minimization
LDR
Applicability
Notifications/Certification
Treatment Standards
Permits and Permitting
State Programs
Financial Assurance
Closure/Post-Closure
Corrective Action
Enforcement
Hazardous Waste Data
Test Methods
Indian Lands
Used Oil Standards
Military Munitions
OTHER WASTES
Ash
Bevill Amendment (Mining Waste)
Medical Wastes
Oil and Gas
70S1
5951
4601
5101
96
62
1451
28
233
23
18
3911
5381
1871
140
101
23
2511
2471
142
25
26
31
7
181
178'
120
3511
1721
147
27
91
196
118
42
106
17
187
22
2
26
170
31
SUBTITLE D
Household Hazardous Wastes
Subtitle D - General
Technical Standards
Industrial Wastes
Municipal Wastes
Indian Lands
Financial Assurance
Solid Waste Recycling/Markets -
General
Aluminum
Batteries
Glass
Paper
Plastics
Tires
Used Oil
Composting
Procurement
Source Reduction/Pollution Prevention
Grants and Financing
TOTAL QUESTIONS
* Includes 2,107 RCRA document requests.
UST
General/Misc.
Applicability/Definitions
Regulated Substances
Closure
1998 Deadline
Standards for New Tank Systems
Tank Standards and Upgrading
Replacing/Closing
Release Detection
Reporting Requirements
Operating Requirements
Corrective Action for USTs
Financial Responsibility
Enforcement
State Programs
Private Sector
Indian Lands
LUST General/Miscellaneous
RBCA
Technologies
Solvency/Cost Controls
TOTAL QUESTIONS
* Includes 494 UST document requests.
89
131
19
17
155
11
9
4521
11
8
0
25
24
18
52
18
92
61
12
8,375*
194
1331
30
54
1911
126
1011
64
1111
29
26
51
62
13
29
6
5
18
5
1
3
1,252*
1 Hot topics for this month
1 Topics are calculated as the summation of all questions received by the Hotline. A single call may result in
multiple questions.
21
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Call Analyses
October 1997
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
General:
General Title HI Questions
Trade Secrets
Enforcement
Liability/Citizen Suits
Training
Chemical-Specific Information
3931
11
58
0
211
1141
Emergency Planning (§§301-303):
General
Notification Requirements
SERC/LEPC Issues
EHSsATPQs '
Risk Communication/
Hazards Analysis
Exemptions
Emergency Release Notification (§304):
General
Notification Requirements
Reportable Quantities
CERCLA §103 vs. SARA §304
ARIP/AHEDB/ERNS .
Exemptions
Hazardous Chemical Reporting
(§§311-312):
General
MSDS Reporting Requirements
Tier I/II Requirements
Thresholds
Hazard Categories
Mixtures Reporting
Exemptions
1411
15
33
41
891
0
67
89
65
64
4
6
2741
82
164
421
6
2
29
Toxic Chemical Release Inventory (§313):
General
APR
Reporting Requirements
Thresholds
Form R Completion
Supplier Notification
NOTEs/NOSEs/NONs
Voluntary Revisions
Pollution Prevention 33/50
Public Access to Data
TRI Database
Petitions
TRI Expansion
2871
41
373
991
2451
14
1
65
23
74
62
4
154
Exemptions
Special Topics:
CAA §112 General
RMPs
List of Regulated Substances
Federal Facilities Executive Order
561
331'
2691
201
0
TOTAL QUESTIONS 4,109
*Includes 897 Emergency Planning and Community
Right-to-Know document requests
SUPERFUND
General/Misc.
Access & Information Gathering
Administrative Improvements
General
Environmental Justice/Brownfields
S ACM/Presumptive Remedies
Soil Screening Levels
Administrative Record
ARARs
CERCLIS
Citizen Suits
Claims Against Fund
Clean-Up Costs
Clean-Up Standards
Community Involvement
Contract Lab Program (CLP)
Contractor Indemnification
Contracts
Definitions
Enforcement
Federal Facilities
Hazardous Substances
HRS
Liability
Local Gov't Reimbursement
Natural Resource Damages
NCP
Notification
NPL
Off Site Rule
OSHA
PA/SI
PRPs
RD/RA
Reauthorization
311
32
41
199'
15
34
11
81
107'
4
9
32
53
21
16
5
17
411
115
1
1741
12
136
4
21
24
112
2741
31
19
29
74
28
19
22
1 Hot topics for this month
1 Topics are calculated as the summation of all questions received by the Hotline. A single call may result in
multiple questions.
-------
October 1997 Call Analyses
Remedial 81
Removal 29
RI/FS 25
Risk Assess./Health Effects 102
ROD 41
RQ 2311
Settlements 53
SITE Program 11
State Participation 12
State Program 34
TAGs 3
Taxes 2
Special Topics
Oil Pollution Act 1401
SPCC Regulations 3481
Lead Contamination 4
TOTAL QUESTIONS 3,228"
"•Includes 384 Superfund document requests.
TOTAL HOTLINE QUESTIONS
AND DOCUMENT REQUESTS: 16,964
1 Hot topics for this month
1 Topics are calculated as the summation of all questions received by the Hotline. A single call may result in
multiple questions.
23
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