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
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^
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.
-JI 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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