EPA/530-SW-91-093L
                                                 FB92-131 368
 Pin! I?
     MONTHLY HOTLINE REPORT
                     December 1991
                                     t
               RCRA/SF/OUST andj
Emergency Planning and Community Right-to-Know
Hotline Questions and Answers                 f

      Resource Conservation and Recovery Act (RCRA)	
      Comprehensive Environmental Response, Compensation and
       Liability Act (CERCLA)	
      Emergency Planning and Community Right-to-Know	
                                                               2
                                                               3
   New Publications

         Resource Conservation and Recovery Act (RCRA)
   Federal Registers
         Final Rules	  6
         Proposed Rules	  7
         Notices	  7
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   Call Analyses
         Calls Answered	   9
         Caller Profiles	  12
         Hotline Topics	  14
RCRA/SF/OUST Hotline
National Toll Free No.: 800-424-9346
                              Emergency Planning and Community
                              Right-to-Know Hotline
                              National Toll Free No.: 800-535-0202
This report is prepared and submitted in support of Cantract No. 68-WO-0039.
EPA Project Officer:
               Barbara Roth. (202) 260-2858
               U S. Environmental Protection Agency
               Washington, DC 20460
                                                         Pnn'ed
                                                       Recycled

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                          HOTLINE QUESTIONS AND ANSWERS
                   RCRA
1. Reclaimed Spent Wood Preservative
   Exclusion in 40 CFR Section 261.4(a)(9)

   In the December 6,1990, Federal Register (55
FR 50450), EPA promulgated hazardous waste
listings for three wastes generated from wood
preserving processes: F032, F034, andF035.
These listings include spent wood preserving
solutions which are often collected on drip pads,
reclaimed (usually by means of filtration or oil/
water separation), and reused again in wood
preserving processes. If a wood preserving facility
uses reclaimed spent preservative (F032, F034, or
F035) to treat wood products which are
subsequently placed on the land, would the
reclaimed spent preservative be regulated as a
hazardous waste under the derived-from rule (40
CFR §261.3(c)(2)) since it is derived from the
treatment (reclamation) of a listed waste?

   No.  Although in the general case, materials
reclaimed from hazardous wastes that are used in a
manner  constituting disposal continue to be
regulated  as solid and, if hazardous, hazardous
wastes,  an exclusion from regulation  as solid and,
thus, as  hazardous wastes  was promulgated with
the new listings for reclaimed spent wood
preserving solutions that are reused for their
intended purpose.

    Generally, the derived-from rule in 40 CFR
§261.3(c)(2) classifies any solid waste derived
from the treatment, storage, or disposal of a listed
hazardous waste as that hazardous waste. There is
an exception to this rule.  In §261.3(c)(2)(i), a
material that is reclaimed from a hazardous waste
and used beneficially, e.g., used as a product, is
no longer considered a solid waste, and thus is
not a hazardous waste.  This exception does not
apply, however, when a reclaimed material is
used, burned for energy recovery, or used in a
manner constituting disposal. Because in this
case the wood products treated with the reclaimed
wood preserving solutions are placed on the land
(used in a manner constituting disposal), the
§261.3(c)(2)(i) exclusion would not apply to the
reclaimed preservatives or to the treated wood
products. Thus, the preservatives and the  wood
products would be regulated as derived-from
listed hazardous wastes. In the December 6,
1990, final rule, however, the Agency stated that
"regulating reclaimed spent preservative and
products made with reclaimed spent preservative
was not and is not EPA's intent." To implement
this intent, an exclusion from the definition of
solid waste was promulgated under §261.4(a)(9),
which excludes from the definition of solid waste
those spent wood preserving solutions and waste
waters that have been reclaimed and will be
reused for their original intended purpose. Thus,
under 40 CFR §261.4(a)(9), once spent wood
preserving solutions are reclaimed and have been
returned to the process (i.e., the work tank), the
reclaimed solutions used for their intended
purpose (wood preserving) are not solid wastes
and thus not hazardous wastes.. Note  that this
exclusion does not apply to the recycling process
(the recycling unit would be  exempt from
permitting under §261.6(c)), or to any prior
management of the spent preservative.  Also,  noic
that the wording of the §261.4(a)(9) exemption
was corrected in the July 1, 1991. Federal
Register notice. (56 ER 30192).

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     Hotline Questions and Answers
                                                                             December 1991
 2.  SW-846 Test Methods

    Are the test methods published in "Test Methods
for Evaluating Solid Waste, Physical/Chemical
 Methods," known as SW-846, required to show
 compliance with 40 CFR Pan 268 land disposal
 restrictions (LDR) in situations where the treatment
 standard is expressed as a concentration?  Are SW-
 846 methods required to show compliance with Part
 261, Subpart C hazardous waste characteristics?

    Generally,  the test methods found in SW-846 are
 not required but are intended to serve as guidance.
 EPA recommends these methods for evaluating
 solid waste and the Agency will use the
 recommended  methods in enforcement situations.
 There are a handful of exceptions to this rule where
 specific test methods are required.

    Compliance with LDR  for wastes that have a
 treatment standard expressed as constituent
 concentrations in wastes (CCW, §268.43) can be
 shown using any appropriate method. This section
 does not specifically require the use of
 SW-846 methods.  If the waste treatment standard is
 expressed as constituent concentrations in waste
 extracts (CCWE, §268.41), then the Toxicity
 Characteristic  Leaching Procedure (TCLP), which is
 specifically referenced in §268.41 (a), must be
 performed.  Following that, however, any
 appropriate method may be used to determine
 concentrations of hazardous constituents in the
 extract and to show compliance with LDR.

    Similarly, in identifying Part 261, Subpart C
 characteristics, §262.11 provides that a generator
 has the option  of applying knowledge of the
 hazardous characteristics of the waste in light of the
 materials or the processes used, or testing the
 material to determine whether or not it is a
 hazardous waste. If the generator chooses to test, he
 must use the method prescribed in Subpart C of 40
 CFR Pan 261. The toxicity characteristic,  for
 example, references method 1311, the TCLP, which
must be used to obtain an extract of the waste.
Following that, as with LDR, any appropriate
method may be used to analyze the extract for
hazardous constituents.  In determining the
characteristic of ignitability, the regulations
reference two specific test methods, the Pensky-
Martens (method 1010) and the Setaflash
(method 1020), either of which must be
employed when testing. The characteristic of
corrosivity also references a specific test
method. If the generator chooses to test the pH
of a given waste stream, method 9040 must be
used.

   Several other regulatory sections also require
the use of SW-846 test methods.  For example,
in completing a petition to delist a waste from a
specific facility, SW-846 methods must be used
in accordance with §260.22.
                CERCLA
3.  Differences Between Class I and
    Class II CERCLA Section 109
    Penalties

    CERCLA §109 authorizes administrative
assessment of two types of civil penalties: Class
I and Class II.  What are the differences
between these two types of penalties and how do
they differ from judicial assessments?

    Class I and Class II penalties under
§ 109 of CERCLA differ from each other with
respect to the amount of penalty collected and
the procedure for assessing the penalty.  EPA
may assess Class I penalties at not more than
$25,000 pgr violation of certain CERCLA
requirements listed in §109(a). Class II
violations may be assessed at not more than
$25,000 per day per violation of certain
CERCLA requirements listed in §109(b).
Further, the Agency can assess a Class II penalt>
of up to 575,000 per day for subsequent  or
second violations.

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  December 1991
                Hotline Questions and Answers
    OSWER Directive 9841.1 discusses the
administrative penalty assessment procedures
for each type of violation. Both Class I and
Class II violators have the opportunity for an
administrative hearing concerning the penalty
assessment.  Only Class II hearings, however,
are required to use the formal adjudicatory
procedures contained in §554 of the
Administrative Procedures Act. The statute also
provides an opportunity for judicial review of
both Class I and II administrative penalties
assessed. Class I parties may seek review
before the U.S. District Court, while Class II
parties may petition the appropriate U.S. Court
of Appeals.

    While administrative penalties are assessed
by EPA, a judicial assessment may be sought by
the Agency through the Department of Justice in
a U.S. District Court. The list of CERCLA
requirements subject to judicial assessment
under this section is provided in §109(c). The
court can assess a penalty of not more than
$25,000 per day of the violation for the first
violation and not more than $75,000 per day for
a second or subsequent violation.  Judicial
assessment of other civil penalties under
CERCLA is also addressed in other sections of
the statute (e.g., §104(e)).
        EMERGENCY PLANNING AND
       COMMUNITY RIGHT-TO-KNOW
4. Section 313:  Supplier Notification
   Requirements

   The regulations at 40 CFR Section
372.45(c)(l) state that "[t]he person shall
provide the written notice described in
paragraph (b) of this section to each recipient
of the mixture or trade name product with at
least the first shipment of each mixture or trade
name product to each recipient in each calendar
year beginning January 1,1989." Is the
supplier required to notify customers if a §313
toxic chemical that is present in the mixture is
later delisted by EPA, since the chemical is no
longer a §313 toxic chemical?

   As stated in 40 CFR §372.45(c)(l), the
supplier is only required to notify recipients if
the mixture or trade name product contains a
listed toxic chemical. The supplier is not
responsible for providing modified notice as an
immediate result of the Agency's delisting
activity. If the mixture contains other §313
toxic chemicals, then the supplier would simply
delete the delisted chemical from the next year's
notification.

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D
f 	
^
1
NEW
\
PUBLICATIONS
     HOW TO ORDER
   NT1S Publications are available by calling (703) 487-4650, or writing NTIS, 5285 Port Royal Road, Springfield,
   VA 22161. Be sure to include the NTIS Order Number listed under the document.
   Hotline Publications are available through the RCRA/Superfund/OUST Hotline by calling a Document
   Specialist at 1-800-424-9346.  Be sure to include the EPA Order Number (if any) listed under the document.
                 RCRA
TITLE:  "EPA Proposed Treatment Standards
for 20 Newly Listed Hazardous Wastes and
Construction Debris"
AVAILABILITY:  Hotline
EPA ORDER NO.: EPA/530-SW-91-081

Proposal for Land Disposal Restrictions
treatment standards for 20 newly listed wastes
that are based on identified best demonstrated
available  technologies for the treatment of
these wastes.
                CERCLA
TITLE:  "ECO Update; Ecological
Assessment of Superfund Sites: An
Overview"
AVAILABILITY: NTIS
NTIS ORDER NO.:  PB92-963 335

Updates framework for ecological studies and
assessment in the Superfund remedial process.
The document offers a description of
ecological assessment components and a
discussion of how they fit into the Remedial
Investigation and Feasibility Study process.
TITLE:  "Risk Assessment Guidance for
Superfund:  Volume 1 - Human Health
Evaluation Manual (Pan B)"
AVAILABILITY:  NTIS
NTIS ORDER NO.: PB92-963 333

Part B of a three-pan series. Pan A addresses
the baseline risk assessment. Pan B provides
guidance on using U.S. EPA toxicity values and
exposure information to derive risk-based
preliminary remedial goals for a CERCLA site.
Pan C addresses human health risk evaluations
of remedial alternatives.

TITLE:  "Risk Assessment Guidance for
Superfund: Volume I - Human Health
Evaluation Manual (Pan C)"
AVAILABILITY:  NTIS
NTIS ORDER NO.: PB92-963 334

Pan C of a three-pan series. Pan A addresses
the baseline risk assessment. Pan B addresses
the development of risk-based preliminary
remediation goals. Pan C provides guidance on
the human health risk evaluations of remedial
alternatives that are  conducted during the
feasibility study, during selection and document-
ation of a remedy, and during and after remedy
implemention.

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December 1991
Publications
                CERCLA
TITLE: "Revision of Policy Regarding
Superfund Project Assignment Between
Alternative Remedial Contracting Strategy
Contractors and the U.S. Army Corps of
Engineers"
AVAILABILITY: NTIS
NTIS ORDER NO.: PB92-963 327

Revises the policy for assigning Superfund
remedial work to EPA Alternatives Remedial
Contracting Strategy contractors and the U.S.
Army Corps of Engineers.

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                            FEDERAL REGISTERS
             FINAL RULES
RCRA
"Interim Status Standards for Downgradient   "EPA Grants an Exclusion to Reynolds
 Ground-Water Monitoring Wells "            Metals Company"
 December 23,1991 (56 FR 66365)            December 30,1991 (56 FR 67198)
   EPA is revising its policy with respect to
the deletion of sites from the National Priorities
List (NPL). Agency policy had linked deletion
from the NPL with the five-year reviews
conducted pursuant to Section 121(c) of
CERCLA. The Agency has now determined
that the two processes should be managed
separately.

 "Final Amendment to Exclusion"
  December 27,1991 (56 FR 66997)

   EPA finalized a proposed amendment to an
exclusion previously granted to the EPA
Mobile Incineration System. In amending the
exclusion, the Agency is transferring the
exclusion to wastes to be generated by a
different incinerator that is owned and operated
by Aptus Incorporated.
   EPA granted a final exclusion from the lists
of hazardous waste generated at Reynolds
Metals Company, in response to a petition
submitted under 40 CFR Section 260.20.

OUST

"UST Financial Responsibility Extended
 Compliance  Date"
 December 23,1991 (56 FR 66369)

   The final rule modifies the compliance dates
under the 40 CFR Section 280.9 l(d) by
extending the compliance deadline for
petroleum marketing firms owning one to 12
USTs at more than one facility, or fewer than
100 USTs at a single facility, and nonmarketers
with a net worth of less than $20 million from
October 26, 1991, to December 31, 1993.
Copies of RCRA Federal Registers are available through the Hotline by calling a Document Specialist at
1-800-424-9346.

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December 1991
                             Federal Registers
         PROPOSED RULES
RCRA
"Modified Wood Preserving Standards"
 December 5,1991 (56 FR 63848)

   EPA is "proposing to amend the RCRA
regulations by modifying Subpart W standards
for drip pads and modifying the listings of
F032, F034 and F035. Final action on these
issues will result in the removal of the wood
preserving administrative stay (56 FR 27332).

SUPERFUND

"Proposed fie. Mlnimis Settlement with
 I. Jones Recycling"
 December 4,1991  (56 F_B 63514)

   EPA announces a proposed settlement under
Section 122(g) of CERCLA to resolve the
liabilities of four dŁ minimis parties for response
costs at the I. Jones Recycling, Clinton Street
facility, in Fort Wayne, Indiana.
              NOTICES
RCRA
"Cancellation of Mining Waste Meeting"
  December 4,1991 (56 FR 63513)

   EPA announces the cancellation of FACA
Committee Meeting on the Policy Dialogue
Committee on Mining Waste.

SUPERFUND

"Notice of Proposed Settlement"
  December 16,1991 (56 Ffi 65254)

   EPA gives notice of a proposed
administrative cost recovery settlement with
Copies of RCRA Federal Registers are available through
1-300-424.9346.
 Eager Beaver Lumber Company, in Townville,
 Pennsylvania.  Comments will be received for a
 period of 30 days.

 "Intention to Delete Westline Site from
  NPL"
  December 17,1991 (56 Ffi 65462)

    EPA announces its intention to delete the
 Westline Site from the National Priorities List,
 and requests comments on this action.
 Comments must be submitted on or before
 January  16, 1992.

 "Proposed Cost Recovery Settlement"
  December 20,1991 (56 FR 66034)

    EPA gives notice of a proposed
 administrative cost recovery settlement to
 resolve a claim under Section 107 of CERCLA
 against the Southern Pacific Transportation
 Company. Comments are requested.

 "De-linking Policy"
  December 24,1991 (56 FR 66601)

    EPA is revising its policy with respect to
 deletion  of sites from the National Priorities
 List (NPL) under CERCLA. Former Agency
 policy linked deletion from NPL with the five-
 year reviews. EPA has now determined that the
 two processes should be managed seperately.

 OUST

 "Advisory Committee Meeting"
  December 26,1991 (56 EB 66865)

    The Class II Underground Injection
 Advisory Committee announces a meeting on
 Tuesday and Wednesday, January 21 and 22. in
 Alexandria, Virginia, to continue work on
 construction and areas of review for Class II
 Injection Wells.
the Hotline by calling a Document Specialist at

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Federal Registers
                                                                      December 1991
                                    NOTICES
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW

"Notice of Final Cancellation Orders"
 December 2,1991 (56 FR 61248)

 On September 4, 1991, EPA announced
 receipt of requests for voluntary
 cancellation of registrations for products
 containing 2- ethyl- 1,3-hexanediol.  Final
 orders of cancellation have been issued,
 and distribution, sale or use of existing
 stocks is prohibited as of October 4,  1991.

"Notice of Issuance of Intent to
 Suspend Pesticide Registration"
 December 11,1991 (56 FR 61248)

   EPA has issued notices of intent to
suspend pesticide registrations pursuant to
Section 3(c)(2)(B) of the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA).
The notices were issued following issuance of
data call-in notices by the Agency and the
failure of registrants subject to the data call-in
notices to take appropriate steps to secure the
data required to be submitted to the Agency.
"Notice of Voluntary Cancellation of
 Pesticide Products Containing
 Ethylparathion"
 December 13,1991 (56 Ffi 65061)

   This notice, pursuant to Section 4(i)(5)(D) of
the FIFRA, announces EPA's intent to cancel
certain parathion registrations due to requests for
voluntary cancellation, and registrants failure to
pay the maintenance fee due on March 1, 1991.
After publication of this notice, distribution and
sale of canceled parathion products will only be
permitted if such sale, distribution, or use is
consistent with the terms of the Cancellation
Order.

GENERAL

"Fifth Update of the Compliance Docket"
 December 12,1991 (56 FR 64898)

   EPA gives notice of the fifth update of the
Federal Agency Hazardous Waste Compliance
Docket. This notice also includes a section
comprising revisions to the previous Docket list.

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                           CALL ANALYSES
       500
       450
       400
       350
       300
       250
       200
       150
       100
        50
         0
                        CALLS ANSWERED BY HOTLINE
December Daily Volume*
              fc_      RCRA/SF/OUST
                        \.
     Emergency Planning and
     Community Right-to-Know
           2  3  4  5 6  9  10 11 12 13 16 17 18 19 20 23 24 26 27 30 31
                             Year-To-Date Volume*
    140000 -p
    120000 -•
    100000 -•
     80000 -•
     60000 -•
     40000 -•
     20000 •-
            RCRA/SF/OUST _
               t       -^a
                Emergency Planning and
                Community Right-to-Know
           Jan   Feb   Mar   Apr  May  Jun   Jul  Aug  Sept  Oct  Nov  Dec
* All calls answered by the Call Management System

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Call Analyses
                                                                         December 1991
500 y
450 ••
400
350 -•
300 ••
250 -•
200 -•
150 >Ť
100 --
 50 i*
  0 --
                            CALLS ANSWERED BY TYPE
                               December Daily Volume*
                                                  Questions
                                        ^ť     Referrals *Vť*Ťť.
                                      -J—I	1	1-
-I	1	1	1	1	1	1	1
             2  3  4   5   6  9 10  11  12 13  16 17 18 19 20 23 24 26 27  30  31
                                 Year-to-Date Volume*
                                                                            Grand Total
            Jan  Feb   Mar  Apr  May  Jun   Jul  Aug  Sept  Oct  Nov   Dec
* Ail calls answered by the Call Management System. A single call may result in multiple questions combined with documcr.i
requests and referrals.
10

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December 1991
Call Analyses
                      CALLS ANSWERED BY PROGRAM AREA
                                    December 1991*
  Based on 11,381 questions posed and excludes 1,240 referrals made from both Hotlines
                                  Year-at-a-Glance*
  1991
  Based on 177,779 questions posed and excludes 23,635 referrals made from both Hotlines

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Call Analyses
                                                                 December 1991
                             CALLER PROFILE
                            RCRA/SF/OUST Hotline


                    Regulated Community                    6,271
                    Citizens                                703
                    State & Local Gov't./Native American        357
                    Federal Agencies                         189
                    Educational Institutions                    136
                    EPA                                   121
                    Other                                   94
                    Media                                  30
                    Interest Groups                           97
                    Congress                                 0
                    Referrals                              1,006
                    Internationals                            15

                    TOTAL                              9,019
                 State/Local Gov't/
                 Native American
                      4%
Federal
Agencies
    Citizens
      9%
                                                Regulated
                                               Community
 12

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December 1991
                                        Call Analyses
                             Emergency Planning and
                        Community Right-to-Know Hotline
   Manufacturer
    Food/Tobacco                   50
    Textiles                        11
    Apparel                          2
    Lumber & Wood                10
    Furniture                         5
    Paper                          19
    Printing & Publishing            33
    Chemicals                     206
    Petroleum & Coal               43
    Rubber and Plastics              14
    Leather                          5
    Stone, Clay & Glass                9
    Primary Metals                  42
    Fabricated Metals               57
    Machinery (Excluding Electrical)   25
    Electrical&Electronic Equipment   39
    Transportation Equipment         20
    Instruments                       6
    Misc. Manufacturing             18
    Not Able to Determine            46
         Consultants/Engineers
         Attorneys
         Citizens
         All Others
           Trade Associations
           Public Interest Groups
           Universities/Academia
           Insurance Companies
           Hospitals
           State Agencies/SERC
           Fire Departments
           EPA
           Local Officials
           LEPC
           Farmers
           Federal Agencies
         Media/Press
           Union/Labor
           Distributors
         Indians
           Laboratories
           Misc.
         Referrals
         Internationals

         TOTAL
  374
  110
  157

   13
   29
   78
    0
   12
   84
   17
   56
   45
  *37
    0
  '30
   12
    0
  ' 10
    0
   16
  113
  234
    3

2,090
                     Citizens
                      8%
Attorneys
   6%
  Consultants/
  Engineers
     20%
                                 All Others
                                   30%

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Call Analyses
                                                                    December 1991
                               HOTLINE TOPICS
 RCRA
 General/Misc.
 Special Wastes
  Ash
  Bevill
  Medical
  Oil and Gas
 Subtitle C Wastes
 Hazardous Waste
 Identification General
 Toxicity Characteristic
 Wood Preserving
 Used Oil
 Fluff
 Mixed Waste
 Delisting & Petitions
 Hazardous Waste Recycling
 Generators
 Small Quantity Generators
 Transporters
 Treatment, Storage & Disposal
 Facilities
 General Facility Standards
 Siting
 Capacity
 Treatment
 Burning
 Storage
 Disposal
 Land Disposal Restrictions
 Permits & Interim Status
 Corrective Action
 Financial Assurance
 Liability/Enforcement
 Test Methods
 Health Effects
 Pollution Prevention/Waste Min.
 State Programs
 Hazardous Waste Data
 Subtitle D Wastes
 Household Hazardous Waste
 Subtitle D Facilities
 General Facility Standards
  Siting
  Combustion
 Industrial Wastes
 Composting
 Source Reduction
 Grants & Financing
 Procurement
  General
                          630*

                            0
                           21
                           147
                             1
                         1206*
                           190
                            41
                           113
                             0
                            17
                            43
                           164
                          414*
                           136
                            98
                           167
                             3
                             0
                           137
                            93
                            79
                            74
                          341*
                           110
                           139
                             0
                            63
                           108
                             0
                            30
                            54
                             4

                            74

                           129
                             5
                             1
                             0
                             8
                             0
                             0

                             0
 Building Insulation                 0
 Cement & Products with Fly Ash    0
 Paper & Paper Products             2
 Re-refined Lubricating Oil          0
 Retread Tires                     1
Solid Waste Recycling
 General                         173
 Aluminum                        3
 Batteries                          7
 Glass                            3
 Paper                            6
 Plastics                          13
 Tires                             9
 Used Oil                         145
Markets
 General                         43
 Aluminum                        3
 Batteries                          3
 Compost                          6
 Glass                            3
 Paper                            3
 Plastics                          2
 Tires                             8
Used Oil                          7
Document Requests              1,663

TOTAL                       6,943

SUPERFUND

General/Misc.                     78
Access & Information Gathering     33
Administrative Record              2
Allocations from Fund              7
ARARs                          41
CERCLIS                      103*
Citizen Suits                       5
Clean-Up Costs                     5
Clean-Up Standards                 16
Community Relations               16
Contract Lab Program (CLP)         16
Contractor Indemnification           4
Contracts                          9
Definitions                        9
Emergency Response                9
Enforcement                       36
Exposure AssessTRisk Assess.        23
Federal Facilities                   12
Fund Balancing                    4
Grants                            2
 14
* Hot topics for this reporting period
• Topics are calculated as the summation of all questions received by the Hotline. A single call may result In multiple
  questions.

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December 1991
                             Call Analyses
Hazardous Substances             71
Health/Toxics                    13
HRS                            30
Liability                         50
Mandatory Schedules               0
Natural Resource Damages          3
NBARs                           2
NCP                            53
Notification                      49
NPL                           101*
Off Site Policy                    9
On Site Policy                    8
OSHA                           4
PA/SI                            9
PRPs                            14
Public Participation               10
RCRA Interface                   3
RD/RA                          21
Remedial                        18
Removal                         17
Response                        14
RI/FS                           19
ROD                            28
RQ                           119*
SARA Interface                   17
Settlements                       8
SITE Program                    22
State Participation                  4
State Program                     5
Taxes                           13
Title in/Right-to-Know            34
Document Requests              443

TOTAL                       1,641

OUST
General/Misc.                    82
Applicability/Definitions           61
Regulated Substances              13
Standards for New Tank Systems    13
Tank Standards and Upgrading      13
Operating Requirements           12
Release Detection                 35
Release Reporting  & Investigation    0
Corrective Action for USTs         13
Out-of-Service/Closure            36
Financial Responsibility        189*
State Programs                   14
Liability/Enforcement              9
LUST Trust Fund                  4
Document Requests               111

TOTAL                        605
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW

Title HI General                   74

§301-3 Emergency Planning
  General                        80
  SERCs/LEPC                   18
  Notification                      4
  Mixtures                         7
  Extremely Hazardous Substances 44*
  Delisting EHS                     6
  Exemptions                    12

§304:
  General                        64
  Notification Requirements        18
  Reportable Quantities            33
  RQs vs. TPQs                   11
  Transportation                     7
  Exemptions                    11

§311/312:
  General                       112*
  MSDS Reporting Requirements    38
  Tier I/n Regulations             80
  Thresholds                     53
  OSHA Expansion                14
  Hazard Categories               11
  Mixtures                       18
  Exemptions                    35

§313:
  Form R                      381*
  Thresholds                     37
  Phase I                        32
  Phase n                       11
  Phase m                         2
  Workshop (Training)          119*
  Petitions                       23
  Health Effects                    4
  Database                       44
  Exemptions                    43

Training:
  General                         5
  §305 Training Grants              0
  §305 Emergency Systems Review   0
  § 126 (SARA) Training Regulations  0
   * Hot topics for this reporting period
   • Topics are calculated as the summation of all questions received by the Hotline. A single call may result In multiple
     questions.

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Call Analyses                                                           December 1991
              „  ..                        Trade Secrets                         5
       .       Guide               0       Enforcement                          8
  Chemical Profile                  1       Liability                              2
  i;RT~i .   .  .                    *       Document Requests                  628
  Hazard Analysis                   0                   n
  Risk Communication              0
  Title m Workshops                0
  Information Management           0
  Prevention ARIP                  0
  Other                          95
TOTAL HOTLINE QUESTIONS,
DOCUMENT REQUESTS AND
REFERRALS:                  12,621
   * Hot topics for this reporting period
   • Topics are calculated as the summation of all questions received by the Hotline. A single call may result in multiple
    questions.

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