&EPA
United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2224A)
EPA-305-B-98-009
December 1998
Protocol for Conducting
Environmental Compliance
Audits under the
Comprehensive
Environmental Response,
Compensation, and
Liability Act
EPA Office of Compliance
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Notice
This document has been developed to assist in conducting environmental audits. The use of this document should
be restricted to environmental audits only. For example, areas such as safety, transportation, occupational health,
and fire protection are mentioned solely for clarification purposes. It is a summary of environmental regulations
under CERCLA, but it is not a substitute for a comprehensive knowledge of the regulations themselves. Any
variation between applicable regulations and the summaries contained in this guidance document are unintentional,
and, in the case of such variations, the requirements of the regulations govern.
This document is intended solely as guidance to explain performance objectives for environmental auditors.
Following the steps set forth in this guidance generally should result in compliance with those aspects of the
regulations that it covers. The U.S. Environmental Protection Agency (EPA) does not make any guarantee or
assume any liability with respect to the use of any information or recommendations contained in this document.
Regulated entities requiring additional information or advice should consult a qualified professional.
This guidance does not constitute rulemaking by the EPA and may not be relied on to create a substantive or
procedural right or benefit enforceable, at law or in equity, by any person. EPA may take action at variance with
this guidance and its internal procedures.
Acknowledgments
EPA would like to gratefully acknowledge the support of the U.S. Army Corps of Engineers Construction
Engineering Research Laboratories (CERL) for their assistance in providing suggestions for the overall format of
this document.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Table of Contents
Notice inside cover
Acknowledgments inside cover
Section I: Introduction
Background ii
EPA's Policy on Environmental Audits ii
Purpose of the Protocols for Conducting Environmental Compliance Audits iii
How to Use This Protocol iv
List of Acronyms and Abbreviations v
Section II: Audit Protocol
Applicability 1
Federal Legislation 1
State and Local Regulations 1
Key Compliance Requirements 1
Key Terms and Definitions 4
Typical Records to Review 8
Typical Physical Features to Inspect 8
Index for Checklist Users 8
Checklist 9
Appendices
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under CERCLA
and EPCRA Al
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Section I:
Introduction
Background
The Environmental Protection Agency (EPA) is responsible for ensuring that businesses and organizations comply with
federal laws that protect the public health and the environment. Recently, EPA has begun combining traditional
enforcement activities with more innovative compliance approaches. In its Strategic Plan, the Agency recognizes the
need to assist the regulated community by providing compliance assistance and guidance that will promote improved
compliance and overall environmental performance (see Exhibit 1). EPA encourages regulated entities to recognize
compliance as the floor, rather than the ceiling, of environmental performance by internalizing and implementing sound
environmental practices. As part of that effort, EPA is encouraging the development of self-assessment programs at
individual facilities. Voluntary audit programs play an important role in helping companies meet their obligation to
comply with environmental requirements. Such assessments can be a critical link, not only to improved compliance,
but also to improvements in other aspects of an organization's performance. For example, environmental audits may
identify pollution prevention opportunities that can substantially reduce an organization's operating costs.
Over the years, EPA has encouraged regulated entities to initiate environmental audit programs that support and
document compliance with environmental regulations. EPA has developed this audit protocol to provide regulated
entities with specific guidance in periodically evaluating their compliance with federal environmental requirements.
Exhibit 1 - EPA's Credible Deterrent Goal
Within its Strategic Plan, EPA has established a goal to ensure full compliance with the laws intended to protect human
health and the environment. Within the framework of this goal, EPA's objectives are as follows:
• Identify and reduce significant non-compliance in high priority program areas, while maintaining a strong
enforcement presence in all regulatory program areas,
• Promote the regulated communities' voluntary compliance with environmental requirements through compliance
incentives and assistance programs.
EPA's Policy on Environmental Audits
In 1986, in an effort to encourage the use of environmental auditing, EPA published its "Environmental Auditing Policy
Statement" (see 51 FR 25004). The 1986 audit policy states that "it is EPA policy to encourage the use of
environmental auditing by regulated industries to help achieve and maintain compliance with environmental laws and
regulation, as well as to help identify and correct unregulated environmental hazards." In addition, EPA defined
environmental auditing as "a systematic, documented, periodic, and objective review of facility operations and practices
related to meeting environmental requirements." The policy also identified several objectives for environmental audits:
»• verifying compliance with environmental requirements,
*• evaluating the effectiveness of in-place environmental management systems, and
»• assessing risks from regulated and unregulated materials and practices.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Exhibit 2 - EPA's 1995 Audit Policy
Under the final Audit/Self Policing Policy, EPA will not seek gravity-based penalties and will not recommend
criminal prosecutions for companies that meet the requirements of the Policy. Gravity-based penalties represent
the "seriousness" or punitive portion of penalties over and above the portion representing the economic gain from
non-compliance. The policy requires companies:
• to promptly disclose and correct violations,
• to prevent recurrence of the violation, and
• to remedy environmental harm
The policy excludes:
• repeated violations,
• violations that result in serious actual harm, and
• violations that may present an imminent and substantial endangerment
Corporations remain criminally liable for violations resulting from conscious disregard of their legal duties, and
individuals remain liable for criminal wrongdoing. EPA retains discretion to recover the economic benefit gained
as a result of noncompliance, so that companies will not be able to obtain an economic advantage over their
competitors by delaying investment in compliance. Where violations are discovered by means other than
environmental audits or due diligence efforts, but are promptly disclosed and expeditiously corrected, EPA will
reduce gravity-based penalties by 75% provided that all of the other conditions of the policy are met.
As a result of EPA's new audit policy, through March 1998, 247 companies have disclosed environmental
violations at more than 760 facilities and EPA has reduced or waived penalties for 89 companies and 433 facilities.
The final Audit/Serf-Policing Policy was published in the Federal Register on December 22, 1995 (60 FR 66706).
It took effect on January 22, 1996. For further information, contact the Audit Policy Docket at (202) 260-7548 or
call (202) 564-4187.
In 1995, EPA published "Incentives for Serf-Policing: Discovery, Disclosure, Correction and Prevention of Violations"
which both reaffirmed and expanded its 1986 audit policy. The 1995 audit policy offers major incentives for entities to
discover, disclose and correct environmental violations. Under the 1995 policy, EPA will not seek gravity-based
penalties or recommend criminal charges be brought for violations that are discovered through an "environmental
audit" (as defined in the 1986 audit policy) or a management system reflecting "due diligence" and that are promptly
disclosed and corrected, provided that other important safeguards are met (see Exhibit 2). These safeguards protect
health and the environment by precluding policy relief for violations that cause serious environmental harm or may
have presented an imminent and substantial endangerment, for example.
Purpose of the Protocols for Conducting Environmental Compliance Audits
This protocol, which is part of a set containing other area or statutory specific audit protocols, is a tool to assist you in
conducting environmental audits, which should inform you whether your facility is in compliance with federal
regulations. EPA has developed these audit protocols to assist and encourage businesses and organizations to perform
environmental audits and disclose violations in accordance with EPA's audit policy. The audit protocols are intended to
promote consistency among regulated entities when conducting environmental audits and to ensure that audits are
conducted in a thorough and comprehensive manner.
Each protocol provides guidance on key requirements, defines regulatory terms, and gives an overview of the federal
laws affecting a particular environmental management area. It also includes a checklist containing detailed procedures
for conducting a review of facility conditions. In order to use these documents effectively, you should be familiar with
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
basic environmental auditing practices and the relevant environmental regulations under Title 40 of the Code of Federal
Regulations (CFR). The audit protocols are not intended to be exclusive or limiting with respect to procedures that may
be followed. EPA recognizes that other audit approaches and techniques may be effective in identifying and evaluating
a facility's environmental status and in formulating recommendations to correct observed deficiencies.
These protocols can be used as a basis to implement, upgrade, or benchmark environmental management activities.
The protocols are a management tool for measuring and improving environmental performance by correcting
deficiencies uncovered by the audit (see Exhibit 3). This process is perhaps the key element to a high quality
environmental management program and will function best when an organization identifies the "root causes" of each
audit finding. Root causes are those breakdowns in management oversight, information exchange, and evaluation that
allow environmental problems to recur. Thus, while an organization may have developed an excellent record of dealing
with a symptom, such as spill response, the underlying problem or "root cause" has not been addressed. Furthermore,
identifying the root cause of an audit finding can mean identifying not only the failures that require correction but also
the successes. In each case a root cause analysis should uncover the failures while promoting the successes so that an
organization can make continual progress toward environmental excellence.
1
L
Exhibit 3 - Corrective Acti<
Audit
'
•*>
Identify
Problems
^
^
Improve
Environmental
Mgmt. System
Effectiveness
Fix
Problems
Develop Actions
to Correct
Underlying
Causes
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>„
odel
Analyze
Exceptions for
Cause/Effect
1
Group Findings
for Common
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1
Examine Each
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How to Use This Protocol
To conduct effective compliance audits, the auditor or audit team needs to possess sound working knowledge of the
operations and processes to be reviewed, the relevant regulations that apply to a given facility, and of acceptable
auditing practices. The audit protocol should be used as a planning tool to assist the auditor in understanding the
requirements for conducting a comprehensive audit. This document will provide the user with a generic audit approach
to identify regulatory issues that may require closer examination. Once the general issues are identified through the use
of this protocol, the auditor should perform a more detailed investigation to determine the specific area of
noncompliance to be corrected. The auditor should review federal, state and local environmental requirements and
annotate the protocol, as required, to include other applicable requirements not included in the protocol.
The auditor also should determine which regulatory agency has authority for implementing an environmental program
so that the proper set of regulations is consulted. State programs that implement federally mandated programs may
contain more stringent requirements. This protocol should not be used as a substitute for the applicable regulations.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
IV
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Protocol for Conducting Environmental Compliance Audits under CERCLA
The collective set of the audit protocols developed by EPA is designed to support a wide range of environmental
auditing needs; therefore several of the protocols in this set or sections of an individual protocol may not be applicable
to a particular facility. Each protocol is not intended to be an exhaustive set of procedures; rather it is meant to inform
the auditor, about the degree and quality of evaluation essential to a thorough environmental audit. EPA is aware that
other audit approaches may provide an effective means of identifying and assessing facility environmental status and in
developing corrective actions.
Each protocol contains the following information:
•D List of acronyms and abbreviations used in the document,
•D Applicability - provides guidance on the major activities and operations included in the protocol and a brief
description of how the protocol is applied,
•D Review of federal legislation - identifies key issues associated with the subject protocol area,
•D State and local regulations - identifies typical issues normally addressed in state and local regulations but does not
present individual state/local requirements,
•D Key compliance requirements - summarizes the overall thrust of the regulations for that particular protocol,
•D Key compliance definitions - defines important terms,
•D Typical records to review - highlights documents, permits and other pertinent paperwork that should be reviewed
by an auditor and reconciled against regulatory requirements,
•D Typical physical features to inspect - highlights pollution control equipment, manufacturing and process equipment
and other areas that should be visited and evaluated during an audit,
•D Index for checklist users - outlines different areas of the checklist that may pertain to the facility being audited,
•D Checklist - matches the regulatory requirements with the tasks that should be accomplished by the auditor,
•D Appendices - supporting information for the checklist (e.g., regulatory deadlines, lists of contaminants, wastes, and
required testing procedures). Note: information contained in the appendices is dated and should be verified with a
current version of the applicable federal regulations.
The checklist delineates what should be evaluated during an audit. The left column states either a requirement
mandated by regulation or a good management practice that exceeds the requirements of the federal regulations. Good
management practices are distinguished from regulatory requirements in the checklist by the acronym (MP) and are
printed in italics. The regulatory citation is given in parentheses after the requirement. The right column gives
instructions to help conduct the evaluation. These instructions are performance objectives that should be accomplished
by the auditor. Some of the performance objectives may be simple documentation checks that take only a few minutes;
others may require a time-intensive physical inspection of a facility.
EPA is presently in the process of developing a series of audit protocol application guides to serve as companion
documents to the set of protocols. The application guides will provide the auditor with a matrix which identifies and
cross references certain site-specific activities or unit operations with particular environmental aspects of that activity.
For example, managing hazardous waste containers is a site-specific activity with environmental concerns, such as
possible releases to air, and water, that may require additional review through auditing. By using the application guide
the user can identify facility specific practices that require more in-depth review. In addition, the application guides
will also direct the user to specific protocols and sections (e.g., checklist items) of the protocol to determine areas that
are regulated and require auditing.
List of Acronyms
ACL Alternative concentration limit
ARAR Applicable or relevant and appropriate requirement
CAA Clean Air Act
CAS Chemical Abstract Service
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS CERCLA Information System
CFR Code of Federal Regulations
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
CMS Corrective measures study
CRP Community relations plan
CWA Clean Water Act
EE/CA Engineering evaluation/cost analysis
EPA Environmental Protection Agency
FS Feasibility study
MRS Hazard ranking system
MCL Maximum contaminant level
MCLG Maximum contaminant level goal
MP Management practice
NCP National Contingency Plan
NFRAP No further response action planned
NOV Notice of Violation
NPL National Priorities List
NRC National Response Center
O&M Operations and maintenance
OSC On-scene coordination
PA Preliminary assessment
PL Public law
PRP Potentially responsible party
QAPP Quality assurance project plan
RA Remedial action
RCRA Resource Conservation and Recovery Act
RD Remedial design
RD/RA Remedial design/remedial action
RFA RCRA facility assessment
RI Remedial investigation
RI/FS Remedial investigation/feasibility study
ROD Record of decision
RPM Remedial Project Manager
SARA Superfund Amendments and Reauthorization Act
SDWA Safe Drinking Water Act
SI Site inspection
SWMU Solid waste management units
TRI Toxic Release Inventory
U.S. United States
USC United States Code
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
VI
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Section II:
Audit Protocol
Applicability
This protocol addresses facilities where hazardous substances were released or pose a substantial threat of release. This
document does not include protocols for determining compliance with the Emergency Planning and Community Right-
to-Know Act (EPCRA). These requirements are contained in a separate EPA document, Protocol for Conducting
Compliance Audits under the Emergency Planning and Community Right-to-Know Act (EPA-305-B-98-007). Specific
state regulations are not included in this protocol.
There are numerous environmental regulatory requirements administered by federal, state, and local governments.
Each level of government may have a major impact on areas at the facility that are subject to the audit. Therefore,
auditors are advised to review federal, state, and local regulations in order to perform a comprehensive audit.
Federal Legislation
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980
This act, Public Law (PL) 96-510 (42 U.S. Code (USC) 9601 et seq), as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986 (PL 99-499) provides for liability, compensation, cleanup, and emergency
response for hazardous substances released into the environment and cleanup of inactive hazardous waste disposal
sites. CERCLA, commonly known as "Superfund," established a fund which was financed by hazardous substance
generators to financially support cleanup and response actions of abandoned hazardous waste sites when no financially
responsible party(ies) can be found. The taxing authority for replenishing the "Superfund" tax fund expired in
December 1995. Parties responsible for the contamination of hazardous waste sites are liable for all costs incurred in
the cleanup and remediation process. The EPA has generated and periodically updates a list of sites requiring cleanup
under CERCLA, known as the National Priorities List (NPL).
State and Local Regulations
In addition to the federal requirements mentioned in this document, many states have (or are in the process of
establishing) release reporting requirements and clean-up requirements that place additional responsibilities on facility
owners and operators and other potentially responsible parties. States and localities or states and municipalities may
establish release reporting requirements and other related legal obligations that are more stringent than those under
CERCLA. Therefore, regulated entities that are not subject to the requirements of CERCLA may be subject to state or
local regulations regarding release reporting and site evaluation and clean-up.
Key Compliance Requirements
Hazardous Substance Release Reporting
Under CERCLA Section 103, facilities are required to notify the National Response Center (NRC) immediately if they
release hazardous substances in excess of or equal to reportable quantities. Facilities with continuous and stable
releases have limited notification requirements (40 CFR 302.1 through 302.6, and 302.8).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
National Contingency Plan
Section 104(a) of CERCLA requires that whenever there is a release or the substantial threat of a release of any
pollutant or contaminant to the environment or which may present an imminent and substantial danger to the public
health or welfare, the President is authorized to respond in a manner consistent with the National Contingency Plan
(NCP). The NCP outlines procedures and standards for the cleanup of releases and hazardous waste sites and
establishes the framework for site evaluations, remedial investigations/feasibility studies, remedy selection and design,
removal actions, community involvement, and administrative records. The NCP requires that the cleanup is to be
conducted by the "lead agency" (the definition of which is found in 40 CFR 300.5). Under the NCP, the lead agency is
responsible for conducting the following activities as they apply to the hazardous waste site's situation.
Site Evaluation
If a release has, may have occurred, or could potentially occur, the first requirement is a site evaluation, the goal of
which is to collect data and evaluate releases of hazardous substances, pollutants, or contaminants to determine the
extent of the release and the release's impact to public health and the environment. Tthe regulations which outline the
requirements for a site evaluation are found in 40 CFR 300.420. A site evaluation consists of the following three
components:
• A preliminary assessment (PA), which is a review of existing site information and an off-site reconnaissance, if
appropriate, to determine if further investigations or response actions may be necessary;
• A site inspection (SI), which is an on-site investigation to determine whether a release has occurred, to identify the
preliminary public health and environmental threats associated with the release or potential release, and it includes,
as appropriate, both on- and off-site field sampling and analysis; and
• A review to determine if the site should be included on the NPL.
If it is determined that the site will need remediation actions, then the lead agency is required to conduct a remedial
investigation/feasibility study (or equivalent investigation, e.g., engineering evaluation/cost analysis (EE/CA)), unless
the release "may present an imminent and substantial danger to public health, welfare or the environment," in which
case the lead agency must mitigate the threat through a removal action, or oversee implementation of the removal action
by the potentially responsible party (PRP).
Remedial Investigation/Feasibility Study (RI/FS)
A remedial investigation/feasibility study (RI/FS) is intended to assess site conditions and evaluate remedial alternatives
to the extent necessary to select a site remedy. The regulations promulgated under CERCLA that apply to RI/FSs are in
40 CFR 300.430(a)-(e) and require that an RI/FS consist of the following four steps:
• Project scoping, which is a plan developed by the lead agency or PRP for conducting an RI/FS such that the detail
of analysis is appropriate to the complexity of the release site problems being addressed;
• A remedial investigation, which is the collection of the necessary field data to adequately characterize the release
site in order to assist in developing and evaluating remedial alternatives;
• A risk assessment which, as a component of the RI, characterizes potential threats to human health and the
environment that may be posed by site contaminants in the absence of site remediation; and
• A feasibility study, which is a study of potential remedial alternatives to address site risks.
Following the completion of the RI/FS, a report is prepared by the lead agency or PRP and a public comment period is
held on the proposed remedy (discussed further in 'Community Relations'). Then the lead agency selects a remedy and
the design process commences.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Remedial Selection and Design
The regulations related to the selection and design of a remedy are promulgated at 40 CFR 300.430(f) and describe the
required process. The lead agency must select, in conjunction with the lead regulatory agency, a preferred proposed
alternative for remediation which can be presented to the public (and state) for their review and comment. The public
comments must be considered and a response to comments prepared before the lead agency can issue a Record of
Decision (ROD). Upon receiving new information from the public or regulatory agencies, the lead agency should
reassess its initial remedial alternative determination. The public comments may prompt the lead agency to modify
aspects of their preferred alternative or cause the lead agency to select a different alternative. The lead agency and the
lead regulatory agency will make the final remedy selection decision and they will document that decision in the ROD
before remedial design/remedial action (RD/RA) commences.
Removal Actions
If at any point during the remediation process, a determination has been made that there is an imminent threat to public
health welfare, or the environment, the lead agency is required by CERCLA to take an appropriate removal action to
abate, prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release. When the determination has
been made that a removal action is appropriate, 40 CFR 300.410 requires that the following steps be undertaken as
promptly as possible:
• A removal preliminary assessment which includes the collection or review of readily available information such as
site management practices, information from waste generator, document review, and facility interviews;
• A removal site inspection, if necessary, to gather information that was not obtained during the removal preliminary
assessment; and
• A removal action which is performed in response to a specific release.
The lead agency will have the latitude to respond as necessary to ensure the minimization of harm to public health,
welfare, or the environment.
Community Involvement
Section 117 of CERCLA requires (through 40 CFR 300.430 and 300.435) that the lead agency conduct various
community involvement activities throughout the inactive waste site evaluation process. The intention is to promote
active communication between communities affected by the release site and the PRP's response for implementing
remedial actions. Community involvement activities must be undertaken in the RI/FS, RD/RA, and removal actions
processes and may include interviewing community interest groups and developing a Community Relations Plan
(CRP). The CRP is designed to ensure that the public has been provided the appropriate opportunity to become
involved in site-related decision making, to identify the appropriate activities for ensuring such public involvement, and
to provide the appropriate opportunity for the community to learn about the release site.
Administrative Record
Section 133(k) of CERCLA requires the establishment and maintenance of an administrative record which contains all
documents pertaining to information used or potentially relied upon to select response actions, information on the
RI/FS and RD/RA processes, the ROD and all public comments received. There are specific requirements in CERCLA
that are promulgated at 40 CFR 300.800-300.805 which require the administrative record to be maintained at a central
location near the release site and that it must be easily accessible to community interest groups.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
For further information regarding the CERCLA regulations, contact U.S. EPA's Superfund, RCRA/UST, and
EPCRA Hotline at 800-424-9346 (or 703-412-9810 in the D.C. area) from 9 a.m. to 6 p.m., Monday through
Friday.
This EPA hotline provides up-to-date information on regulations developed under CERCLA (Superfund),
RCRA and the Oil Pollution Act. The hotline can assist with Section 112(r) of the Clean Air Act (CAA) and
Spill Prevention, Control and Countermeasures (SPCC) regulations. The hotline also responds to requests for
relevant documents and can direct the caller to additional tools that provide a more detailed discussion of
specific regulatory requirements.
Key Terms and Definitions
Applicable or Relevant and Appropriate Requirements (ARARs)
Those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated
under federal environmental or state environmental or facility citing laws that, while not "applicable" to a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA site, address problems
or situations sufficiently similar to those encountered at the CERCLA site that their use is well suited to the particular
site. Only those state standards that are identified in a timely manner and are more stringent than federal requirements
may be relevant and appropriate (40 CFR 300.5).
CERCLA Information System (CERCLIS)
EPA's comprehensive database and management system that inventories and tracks releases addressed or needing to be
addressed by the Superfund program. CERCLIS contains the official inventory of CERCLA sites and supports EPA's
site planning and tracking functions. Sites that EPA decides do not warrant moving further in the site evaluation
process are given a "No Further Response Action Planned" (NFRAP) designation in CERCLIS. This means that no
additional federal steps under CERCLA will be taken at the site unless future information so warrants. NFRAP
designated sites are removed from the main CERCLIS database after completion of evaluations; however, information
pertaining to these sites are archived at the lead agency in order to document that these evaluations took place and to
preclude the possibility that evaluations be needlessly repeated. Inclusion of a specific site or area in the CERCLIS
database does not represent a determination of any party's liability, nor does it represent a finding that any response
action is necessary. Sites that are deleted from the NPL are not designated NFRAP sites. Deleted sites are listed in a
separate category in the CERCLIS database (40 CFR 300.5).
Community Involvement Coordinator
Lead agency staff who work with the On-Scene Coordinator/Remedial Project Manager (OSC/RPM) to involve and
inform the public about the Superfund process and response actions in accordance with the interactive community
involvement requirements set forth in the NCP (40 CFR 300.5).
Environment
As defined by section 101(8) of CERCLA, environment means the navigable waters, the waters of the contiguous zone,
and the ocean waters of which the natural resources are under the exclusive management authority of the United States
under the Magnuson Fishery Conservation and Management Act; and any other surface water, ground water, drinking
water supply, land surface or subsurface strata, or ambient air within the United States or under the jurisdiction of the
United States (40 CFR 300.5).
Facility
As defined by section 101(9) of CERCLA, facility means any building, structure, installation, equipment, pipe or
pipeline (including any pipe into a sewer or publicly owned treatment works), well, pit, pond, lagoon, impoundment,
ditch, landfill, storage container, motor vehicle, rolling stock, aircraft, or any site or area, where a hazardous substance
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
has been deposited, stored, disposed of, placed, or otherwise come to be located; but does not include any consumer
product in consumer use or any vessel (40 CFR 300.5).
Feasibility Study (FS)
A study undertaken by the lead agency or PRP to develop and evaluate options for remedial action. The FS emphasizes
data analysis and is generally performed concurrently and in an interactive fashion with the RI, using data gathered
during the RI. The RI data are used to define the objectives of the response action, to develop remedial action
alternatives, and to undertake an initial screening and detailed analysis of the alternatives. The term also refers to a
report that describes the results of the study (40 CFR 300.5).
Hazard Ranking System (HRS)
The method used by EPA to evaluate the relative potential of hazardous substance releases to cause health or safety
problems, or ecological or environmental damage (40 CFR 300.5).
Hazardous Substance
As defined by section 101(4) of CERCLA, any substance designated pursuant to section 31 l(b)(2)(A) of the Clean
Water Act (CWA); any element, compound mixture, solution, or substance designated pursuant to section 102 of
CERCLA; any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the
Solid Waste Disposal Act (but not including any waste the regulation of which under the Solid Waste Disposal Act has
been suspended by Act of Congress); any toxic pollutant listed under section 307(a) of the CWA; any hazardous air
pollutant listed under section 112 of the Clean Air Act; and any imminently hazardous chemical substance or mixture
with respect to which the EPA Administrator has taken action pursuant to section 7 of the Toxic Substances Control
Act. The term does not include petroleum, including crude oil or any fraction thereof which is not otherwise
specifically listed or designated as a hazardous substance in the first sentence of this paragraph, and the term does not
include natural gas, natural gas liquids, liquefied natural gas, or synthetic gas usable for fuel (or mixtures of natural gas
and such synthetic gas (40 CFR 300.5).
Lead Agency
The federal or state agency that provides the On-Scene Coordinator (OSC) or the responsible official for a CERCLA
response action.
Management Practice (MP)
Practices that, although not mandated by law, are encouraged to promote safe operating procedures.
National Priorities List (NPL)
The list, compiled by EPA pursuant to CERCLA section 105, of uncontrolled hazardous substance releases in the
United States that are priorities for long-term remedial evaluation and response (40 CFR 300.5).
Person
An individual, firm, corporation, association, partnership, consortium, joint venture, commercial entity, United States
government, state, municipality, commission, political subdivision of a state, or any interstate body (40 CFR 300.5 and
302.3).
Pollutant or Contaminant
As defined by section 101(33) of CERCLA, pollutant or contaminant includes, but is not limited to, any element,
substance, compound, or mixture, including disease-causing agents, which after release into the environment and upon
exposure, ingestion, inhalation, or assimilation into any organism, either directly from the environment or indirectly by
ingestion through food chains, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities,
cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction) or physical
deformations, in such organisms or their offspring. The term does not include petroleum, including crude oil or any
fraction thereof which is not otherwise specifically listed or designated as a hazardous substance under section
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
101(4)(A) through (F) of CERCLA, nor does it include natural gas of pipeline quality (or mixtures of natural gas and
such synthetic gas). For purposes of the NCP, the term pollutant or contaminant means any pollutant or contaminant
that may present an imminent and substantial danger to public health or welfare (40 CFR 300.5).
Preliminary Assessment (PA)
Review of existing information and an off-site reconnaissance, if appropriate, to determine if a release may require
additional investigation or action. A PA may include an on-site reconnaissance, if appropriate (40 CFR 300.5).
Release
As defined by section 101(22) of CERCLA, release means any spilling, leaking, pumping, pouring, emitting, emptying,
discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or
discarding of barrels, containers, and other closed receptacles containing any hazardous substance or pollutant or
contaminant). It excludes any release which results in exposure to persons solely within a workplace, with respect to a
claim which such persons may assert against the employer of such persons; emissions from the engine exhaust of a
motor vehicle, rolling stock, aircraft, vessel, or pipeline pumping station engine; release of source byproduct, or special
nuclear material from a nuclear incident, as those terms are defined in the Atomic Energy Act of 1954, if such release is
subject to requirements with respect to financial protection established by the Nuclear Regulatory Commission under
section 170 of such Act, or, for the purposes of section 104 of CERCLA or any other response action, any release of
source, byproduct, or special nuclear materials from any processing site designated under section 102(a)(l) or 302(a) of
the Uranium Mill Tailings Radiation Control Act of 1978; and the normal application of fertilizer. For purposes of the
NCP, release also means threat of release (40 CFR 300.5 and 302.3).
Remedial Design (RD)
The technical analysis and procedures which follow the selection of remedy for a site and result in a detailed set of
plans and specifications for implementation of the remedial actions (40 CFR 300.5).
Remedial Investigation (RI)
A process undertaken by the lead agency to determine the nature and extent of the problem presented by the release.
The RI emphasizes data collection and site characterization and is generally performed concurrently and in an
interactive fashion with the feasibility study. The RI includes sampling and monitoring, as necessary, and includes the
gathering of sufficient information to determine the necessity for remedial action and to support the evaluation of
remedial alternatives (40 CFR 300.5).
Remedy or Remedial Action (RA)
Those actions consistent with permanent remedy taken instead of, or in addition to, removal actions in the event of a
release or threatened release of a hazardous substance into the environment, to prevent or minimize the release of
hazardous substances so that they do not migrate to cause substantial danger to present or future public health or
welfare or the environment. The term includes, but is not limited to, such actions at the location of the release as
storage; confinement; perimeter protection using dikes, trenches, or ditches; clay cover; neutralization; cleanup of
released hazardous substances and associated contaminated materials; recycling or reuse diversion, destruction, or
segregation of reactive wastes; dredging or excavations; repair or replacement of leaking containers; collection of
leachate and run-off; on-site treatment or incineration; provision of alternative water supplies; any monitoring
reasonably required to assure that such actions protect the public health and welfare and the environment; and, where
appropriate, post-removal site control activities. The term includes the costs of permanent relocation of residents and
businesses and community facilities (including the cost of providing "alternative land of equivalent value" to an Indian
tribe pursuant to CERCLA section 126(b)) where EPA determines that, alone or in combination with other measures,
such relocation is more cost-effective than, and environmentally preferable to, the transportation, storage, treatment,
destruction, or secure disposition off-site of such hazardous substances, or may otherwise be necessary to protect the
public health or welfare; the term includes off-site transport and off-site storage, treatment, destruction, or secure
disposition of hazardous substances and associated contaminated materials. For the purpose of the NCP, the term also
includes enforcement activities related thereto (40 CFR 300.5).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Remove or Removal
As defined by section 31 l(a)(8) of the CWA, refers to removal of oil or hazardous substances from the water and
shorelines or the taking of such other actions as may be necessary to minimize or mitigate damage to the public health
or welfare or to the environment. As defined by section 101(23) of CERCLA, removal of released hazardous
substances from the environment; such actions as may be necessary taken in the event of the threat of release of
hazardous substances into the environment; such actions as may be necessary to monitor, assess, and evaluate the
release or threat of release of hazardous substances; the disposal of removed material; or the taking of such other
actions as may be necessary to prevent, minimize, or mitigate damage to the public health or welfare or the
environment, which may otherwise result from a release or threat of release. The term includes, in addition, without
being limited to, security fencing or other measures to limit access, provision of alternative water supplies, temporary
evacuation and housing of threatened individuals not otherwise provided for, action taken under section 104(b) of
CERCLA, post-removal site control, where appropriate, and any emergency assistance which may be provided under
the Disaster Relief Act of 1974. For the purpose of the NCP, the term also includes enforcement activities related
thereto (40 CFR 300.5).
Reportable Quantity
That quantity, as set forth in 40 CFR 302, the release of which requires notification pursuant to 40 CFR 302 (40 CFR
302.3).
Site Inspection (SI)
An on-site investigation to determine whether there is a release or potential release and the nature of the associated
threats. The purpose is to augment the data collected in the preliminary assessment and to generate, if necessary,
sampling and other field data to determine if further action or investigation is appropriate (40 CFR 300.5).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Typical Records to Review
• Spill/release records
• Hazardous substance inventory records
• National Response Center Notification Document
• Preliminary Assessment (CERCLA)
• Remedial Investigation documentation
• Soil sample and groundwater monitoring data related to areas targeted for removal and cleanup
• Engineering and cost evaluations
• Sampling and analysis plans.
Typical Physical Features to Inspect
• Cleanup sites
• Disposal sites
• Groundwater monitoring wells
• Contaminated areas
• Treatment technologies employed for site cleanup.
Index for Checklist Users
All Facilities
Release Discovery and Notification
Site Evaluation
Remedial Investigation and Feasibility
Study
Remedial Selection and Design
Removal Action
Refer To
Checklist Items
C.1 through C.3
C. 4 through C.7
C. 8 through C.9
C.10
C.11
C.12
Page Numbers
9
9-10
11-12
13-15
16
17
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Checklist
Regulatory Requirement or
Management Practice:
All Facilities
C.1 The current status of any
ongoing or unresolved Consent
Orders, Compliance
Agreements, Notices of
Violation (NOVs), or equivalent
state enforcement actions
should be examined.
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, or equivalent state
enforcement actions.
For those open items, indicate what corrective action is planned and milestones
established to correct problems.
Determine how many dockets, if any, your facility has.
C.2 Facilities are required to
comply with all applicable
federal regulatory requirements
not contained in this checklist.
Determine if any new regulations have been issued since the finalization of the guide.
If so, annotate checklist to include new standards.
Determine if the facility has activities or facilities which are federally regulated, but not
addressed in this checklist.
Verify that the facility is in compliance with all applicable and newly issued regulations.
C.3 Facilities are required to
abide by state and local
regulations concerning
hazardous materials.
Verify that the facility is abiding by state and local requirements.
Verify that the facility is operating according to permits issued by the state or local
agencies.
(NOTE: Issues typically regulated by state and local agencies include:
- Transportation of hazardous materials
- Notification requirements
- Response plan requirements
- Spill response requirements.)
Release Discovery and Notification
C.4. Facilities that are
determined: 1) to own or
operate, or 2) who at the time
owned or operated, or 3) who
accepted hazardous substances
for transport and selected a
facility at which hazardous
substances are or have been
stored, treated, or disposed of,
are required to notify the EPA
unless such facility has been
properly permitted under RCRA
(40 CFR 302).
Verify that the facility has procedures in place to identify areas where hazardous
substances are or may have been stored, treated, or released at the facility.
Confirm that the facility maintains an inventory of potential inactive waste sites and
determine whether the inventory contains the following information for each site:
- The site location.
- The site history (i.e., types of waste or hazardous substance that may have been
released).
- Facility responses to environmental problems.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Regulatory Requirement or
Management Practice:
C.5. Facilities are required to
notify EPA of the existence of
hazardous waste sites
(CERCLA s. 103, 40 CFR
300.405(b), 300.135(j),
300.120(b)).
Confirm through interviewing facility personnel and reviewing facility release reporting
procedures that the facility has performed the following:
- If any hazardous substances are found to have been stored, treated, or disposed of
at the facility, the EPA is notified of the existence of the site(s) unless the site(s)
has been issued a valid RCRA permit.
- Notified the EPA if the facility accepted hazardous substances for transport and
selected a facility where hazardous substances are or have been stored, treated, or
disposed of without a valid RCRA permit.
- Notified the National Response Center (NRC) when a hazardous substance release
exceeded a CERCLA Reportable Quantity.
- Promptly notified trustees for natural resources of hazardous substance releases
that are injuring or may injure natural resources under their jurisdiction.
C.6. Releases in excess of or
equal to reportable quantities of
hazardous substances shall be
reported to the NRC
immediately (40 CFR 302.1
through 302.6).
Verify that spills in excess of the reportable quantities listed in Appendix A have been
reported. (Also, refer to 40 CFR 302, Table 302.4.)
Verify that a procedure is in place for the notification of the NRC immediately after
becoming aware of the release.
Verify that if mixtures or solutions of hazardous substances are released, except for
radionuclides, it is reported when either of the following occur:
- The quantity of all hazardous constituents of the mixture or solution is known and a
reportable quantity or more of any hazardous constituent is released.
- The quantity of one or more of the hazardous constituents of the mixture or solution
is unknown and the total amount of the mixture or solution released equals or
exceeds the reportable quantity for the hazardous constituent with the lowest
reportable quantity.
(NOTE: Notification requirements for radionuclide releases are not included in this
guide.)
C.7. Facilities with releases
that are continuous and stable
in quantity and rate are required
to meet limited notification
requirements (40 CFR 302.8).
Determine if the facility has any releases that are continuous and stable in quantity
and rate.
Verify that the following notifications have been given:
- Initial telephone notification
- Initial written notification within 30 days of the initial telephone notification
- Follow-up notification within 30 days of the first anniversary date of the initial written
notification
- Notification of changes in:
-- the composition or source of the release
- information submitted in the initial written notification
- the follow-up notification required on the first anniversary date of the initial
written notification
- Notification of when there is an increase in the quantity of the hazardous
substances in any 24-hour period that represents a statistically significant increase.
(NOTE: Instead of the initial written report or follow-up report, the facility may submit a
copy of the Toxic Release Inventory (TRI) form submitted under SARA Title III section
313 for the previous July 1, provided that conditions are met as described in 40 CFR
302.8G).)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Regulatory Requirement or
Management Practice:
Site Evaluation
C.8. When a facility
experiences a hazardous
substance release to the
environment, an evaluation of
the release site must be
performed to determine the
extent of the release and the
release's impact to public health
and the environment. A site
evaluation typically contains the
following three components (40
CFR 300.420):
a. A preliminary assessment
(PA) which is a review of
existing site information and
an off-site reconnaissance,
if appropriate, to determine
if a release may require
further investigations or
removal actions. Typically,
when performing a PA,
facility documents are
reviewed and field sampling
is not conducted.
b. A site inspection (SI) which
is an on-site investigation to
determine whether a
release has occurred and to
identify the preliminary
public health and
environmental threats
associated with the release.
The SI typically builds upon
the information collected
during the PA.
Furthermore, the SI
involves, as appropriate,
both on- and off-site field
sampling and analysis.
c. A review to determine if the
site should be included on
the National Priorities List
(NPL).
Verify that for all potential inactive waste sites, a preliminary assessment (PA) is
conducted that contains at least the following:
- A review of existing information about the release such as:
information on the pathways of exposure;
exposure targets; and
source and nature of release.
- On-site reconnaissance.
- Off-site reconnaissance.
When the facility performs a remedial PA, confirm that the facility completes the EPA
Preliminary Assessment form or its equivalent and that it includes the following
information:
- A description of the release
- A description of the probable nature of the release
- A recommendation on whether further action is warranted, which lead agency
should conduct further action, and whether a site investigation (SI) or removal
action, or both, should be undertaken.
Where the facility has received an interim or final RCRA facility permit, determine
whether the facility has completed a RCRA Facility Assessment (RFA).
For facility Sis verify that, prior to conducting any field sampling, the facility has
developed sampling and analysis plans which consist of the following:
- Afield sampling plan.
- A Quality Assurance Project Plan (QAPP).
Determine whether the facility has included the following information when preparing
an SI:
- A description/history/nature of waste handling
- A description of known contaminants
- A description of pathways of migration of contaminants
- An identification and description of human and environmental targets
- A recommendation on whether further action is warranted.
Determine if the facility determined whether a removal action is appropriate based
upon the information collected during the PA/SI. If so, confirm that the facility initiated
a removal PA pursuant to C.12.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Regulatory Requirement or
Management Practice:
C.9. Sites that meet a certain
criteria may be eligible for
placement on the National
Priorities List (NPL) (40 CFR
300.425(c), (d)).
Confirm that the facility has assisted federal and state agencies in evaluating whether
release sites have met one of the following criteria:
- The release scores sufficiently high pursuant to the Hazard Ranking System.
(NOTE: The Hazard Ranking System is the method used by EPA to evaluate the
relative potential of hazardous substance releases to cause health or safety
problems, ecological damage, or environmental damage.)
- The state has designated a release as its highest priority (a state may have only
one highest priority).
- The release satisfies all of the following criteria:
- the Agency for Toxic Substances and Disease Registry has issued a health
advisory that recommends dissociation of individuals from the release;
the EPA determines that the release poses a significant threat to public health;
- the EPA anticipates that it will be more cost-effective to use its remedial
authority than to use removal authority to respond to the release.
If the facility determines that a release is eligible for placement on the NPL, verify that
the facility has submitted the release score (using HRS model) and has provided the
appropriate backup documentation.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Regulatory Requirement or
Management Practice:
Remedial Investigation and Feasibility Study
C.10. The purpose of the RI/FS
is to assess site conditions and
evaluate remedial alternatives to
the extent necessary to select a
site remedy. Developing and
implementing an RI/FS
generally includes the following
(40 CFR 300.430):
a. Project Scoping - The
facility should have
developed a plan for
conducting an RI/FS such
that the detail of analysis is
appropriate to the
complexity of the release
site problems being
addressed.
b. Remedial Investigation-
The purpose of an Rl is to
collect the necessary field
data to adequately
characterize the release site
in order to assist in
developing and evaluating
remedial alternatives. Site
characterization may be
conducted in one or more
phases to focus sampling
efforts and to better define
the potential threat to
human health or the
environment.
Determine whether the facility has initiated coordination with regulatory agencies to
ensure that both parties have discussed and identified the appropriate sequence
actions necessary to address the release site problems.
Verify that the facility has conducted project scoping to identify the optimal set and
sequence of actions necessary to address the release site problems. Specifically, the
following should be incorporated into the project scope:
- The assembly and evaluation of existing data for the release site, including the
results of any removal actions and PA/SI data.
- The identification of likely response scenarios, potentially applicable technologies,
and operable units that may address site problems.
- The identification of the type, quality, and quantity of the data that will be collected
during the RI/FS.
- The preparation of site-specific health and safety plans that specify, at a minimum,
employee training and protective equipment, medical surveillance requirements,
standard operating procedures, and contingency plan that conforms with 29 CFR
- The development of a sampling and analysis plan that meets the requirements
outlined in C.8.
- The identification of potential federal and state Applicable or Relevant and
Appropriate Requirements (ARARs).
Determine whether the facility has assessed the following factors when conducting an
Rl:
- The physical characteristics of the site (i.e., soils, sediments, geology,
hydrogeology, meteorology, and ecology).
- Characteristics of air, surface water, and ground water.
- The general characteristics of the waste, including quantities, physical state,
concentration, toxicity, ability to bioaccumulate, and mobility.
- The extent to which the source can be adequately identified and characterized (i.e.,
evaluation of the vertical and horizontal extent of contamination).
- Actual and potential exposure routes (i.e., inhalation through airtransport and
ingestion through groundwater or bioaccumulation).
- Actual and potential exposure pathways through environmental media.
Verify that the facility, in conjunction with regulatory agencies, has identified the
potential ARARs for the release site.
For each release site undergoing an Rl, confirm that the facility has conducted a
baseline risk assessment which contains the following:
- A characterization of the current and potential threats to human health and the
environment that may be posed by site contaminants migrating through
environmental media.
- The establishment of acceptable exposure levels for use in developing remedial
alternatives.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Regulatory Requirement or
Management Practice:
C.10. (continued)
c. Risk Assessment - As a
component of the Rl, the
risk assessment should
characterize the current and
potential threats to human
health and the environment
that may be posed by
contact to environmental
media in the absence of site
remediation. Typically, the
risk assessment results will
assist in establishing
acceptable exposure levels
for use in developing
remedial alternatives in the
FS.
d. Feasibility Study - The
purpose of the FS is to
ensure that appropriate
remedial alternatives are
developed and evaluated.
The development and
evaluation of alternatives
should reflect the scope and
complexity of the remedial
action under consideration
and the release site
problems being addressed.
Where the facility has received an interim or final RCRA facility permit, determine
whether the facility has completed the following:
- A RCRA Facility Investigation (RFI) to evaluate whether releases of hazardous
substances may have occurred from Solid Waste Management Units (SWMUs).
Verify that as a part of the FS, the facility has established remedial action objectives
(i.e., acceptable exposure levels that are protective of human health and the
environment) which have been developed by using the following:
- ARARs under federal or state environmental laws.
- Maximum contaminant level goals (MCLGs), established under the Safe Drinking
Water Act, or if the MCLG is determined not to be relevant, the corresponding
maximum contaminant level (MCL).
- Water quality criteria established under sections 303 or 304 of the CWA.
- An alternative concentration limit (ACL) established according to CERCLA section
For source control actions, confirm that the facility has developed alternatives tailored
to the release site conditions that employ the following, as appropriate:
- Treatment techniques that reduce toxicity, mobility, or volume of the release site to
the maximum extent feasible, eliminating or minimizing the need for long-term
management.
- One or more alternatives that involve little or no treatment, but provide protection of
human health and the environment primarily by preventing or controlling exposure
to the release site.
- For groundwater response actions, remedial alternatives which attain site-specific
remediation levels within different time periods and using one or more different
technologies.
Confirm that, as a part of an FS, the facility has developed the following:
- One or more innovative treatment technologies for further consideration.
- A no-action alternative or a no further action alternative, if some removal or
remedial action has already occurred at the release site.
Verify that, to the extent possible, the facility has considered the short- and long-term
aspects of the following criteria to guide the development and screening of remedial
alternatives:
- Effectiveness (i.e., minimization of residual risks and short-term impacts, long-term
protection, quickness of protection).
- Implementability (i.e., technical feasibility and availability).
- Cost (i.e., construction, operation, and maintenance).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Regulatory Requirement or
Management Practice:
C.10. (continued)
Determine whether the facility has performed an analysis of a limited number of
remedial alternatives, which have been considered a viable approach to remedial
action, based on the following:
- Overall protection of human health and the environment.
- Compliance with ARARs.
- Long-term effectiveness and permanence.
- Reduction of toxicity, mobility, or volume.
- Short-term effectiveness.
- Implementability.
- Cost.
- State acceptance.
- Community acceptance.
(NOTE: For facilities with an interim or final RCRA facility permit, federal and state
authorities will request that a Corrective Measures Study (CMS) be performed as part
of a Corrective Action Order (CERCLA Sect. 3008(h)) or corrective action requirement
outlined in a permit application and/or permit (CERCLA Sect. 3004(u) and (v)).)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Regulatory Requirement or
Management Practice:
Remedial Selection and Design
C.11. Upon the completion of
the RI/FS, the lead agency
selects a preferred proposed
alternative for remediation which
can be presented to the public
(and state) for their review and
comment. The public comments
must be considered before the
facility can issue a final remedial
design/remedial action (RD/RA).
Upon receiving new information
from the public or regulatory
agencies, the lead agency
should reassess its initial
remedial alternative
determination. The public
comments may prompt the lead
agency to modify aspects of
their preferred alternative or
cause the lead agency to select
a different alternative. The lead
agency and the lead regulatory
agency will make the final
remedy selection decision and
they will document that decision
in the Record of Decision (ROD)
(40 CFR 300.430(f), 300.435(b),
(c), (f)).
When the facility has, in conjunction with the regulatory agency, identified a preferred
proposed remedial action alternative, verify that the proposed plan has been
presented to the public for comment.
Determine whether the proposed plan presented to the public contains the following:
- A brief summary of the alternatives.
- The rationale used to develop the preferred alternative.
- A summary of comments received from regulatory agencies.
- A summary of any proposed waiver from an ARAR.
Verify that the facility conducts the following community relations activities to support
the selection of the remedy:
- Publishes a notice of availability and a brief analysis of the proposed plan in a
major local newspaper.
- Makes the proposed plan and supporting information available in the Administrative
Record.
- Provides for a public comment period of not less than 30 days.
- Provides for a public meeting at or near the facility during the public comment
period.
- Keeps a transcript of the meeting and makes the transcript available to the public.
- Prepares a written summary of significant comments and new information received
during the public comment period.
Verify that the facility has developed an RD/RA that is consistent with the selected and
implemented remedy as set forth in the ROD.
Confirm that Operations and Maintenance (O&M) measures have been initiated after
the remedial action objectives/goals outlined in the ROD have been achieved.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Regulatory Requirement or
Management Practice:
Removal Action
C.12. At any release site,
regardless of whether the site
has been included on the NPL,
where the facility has made the
determination that there is a
threat to public health, welfare,
or the environment, the facility
may take an appropriate
removal action to abate,
prevent, minimize, stabilize,
mitigate, or eliminate the
release or threat of release.
When the facility has
determined that a removal
action is appropriate, the facility
should undertake the action as
promptly as possible. The action
typically consists of the following
three stages (40 CFR 300.410,
300.415):
a. A removal preliminary
assessment which includes
the collection or review of
readily available information
such as site management
practices, information from
waste generator, document
review, and facility
interviews.
b. A removal site inspection, if
necessary, to gather
information that was not
obtained during the removal
preliminary assessment.
c. A removal action which is
performed in response to a
specific release.
Confirm that the following information has been considered by the facility when
performing a removal preliminary assessment:
- Identification of the source and nature of the release or threat of release.
- Evaluation by the Agency for Toxic Substances and Disease Registry or by other
sources (e.g., state public health agencies) of the threat to public health.
- Evaluation of the magnitude of the threat.
- Evaluation of factors necessary to make the determination of whether a removal is
necessary.
Determine whether a removal site inspection has been performed.
Verify that the facility has documented the results obtained from a removal site
evaluation.
Verify that the facility evaluated the following factors prior to initiating a removal action
to determine whether or not the action was appropriate:
- Actual or potential exposure of contaminants to nearby human populations,
animals, or the food chain.
- Actual or potential contamination of drinking water supplies or sensitive
ecosystems.
- Hazardous substances or contaminants stored at the facility that may pose a threat
of release.
- High levels of hazardous substances or contaminants in surface soils that may
migrate.
- Weather conditions that may cause hazardous substances or contaminants to be
released.
- Threat of fire or explosion.
- The availability of appropriate release response mechanisms.
If the removal action requires a planning period of greater than six months, verify that
the facility has developed the following:
- An Engineering Evaluation/Cost Analysis (EE/CA) on the removal alternatives for
the site.
- A sampling and analysis plan that has been reviewed and approved by the EPA.
If removal actions have been implemented, determine whether the selected action, to
the extent practicable, has contributed to the anticipated long-term remedial action for
the release site.
(NOTE: 40 CFR 300.415(d) provides several removal action examples.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. 18
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Protocol for Conducting Environmental Compliance
Audits under the Comprehensive Environmental Response,
Compensation, and Liability Act
Appendix A:
Consolidated List of Hazardous Substances and Reportable
Quantities Under CERCLA and EPCRA
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Consolidated List of Chemicals Covered Under CERCLA and EPCRA
This consolidated list includes hazardous substances and other chemicals subject to reporting requirements under 40 CFR 302
of CERCLA and EPCRA. This list does not contain all chemicals that are subject to reporting requirements in Sections 311
and 312 of EPCRA. Those hazardous chemicals for which Material Safety Data Sheets (MSDSs) must be developed under the
Occupational Safety and Health Act Hazard Communication Standards are identified by broad criteria, rather than
enumeration. There are over 500,000 such substances that meet the criteria. The consolidated list has been prepared to help
determine whether there is a need to report releases under CERCLA (40 CFR 302) or submit reports under Section 304 or
313 of EPCRA and, for a specific chemical, what reports need to be submitted.
The list includes chemicals under the four following federal statutory provisions:
1. EPCRA Section 302 Extremely Hazardous Substances - The presence of extremely hazardous substances (EHSs) in
sufficient quantities requires certain emergency planning activities to be conducted. Releases of these substances are also
subject to reporting under Section 304 of EPCRA. The final rule listing the extremely hazardous substances and their
threshold planning quantities (TPQs), is found in 40 CFR 355.
2. CERCLA Hazardous Substances - Releases of CERCLA hazardous substances are subject to reporting under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) of 1980. Such
releases are also subject to reporting under Section 304 of EPCRA. CERCLA hazardous substances and their reportable
quantities (RQs) are listed in 40 CFR 302, Table 302.4.
3. EPCRA Section 313 Toxic Chemicals - Emissions or releases of EPCRA Section 313 toxic chemicals must be reported
annually as part of EPCRA's community right-to-know provisions. A list of these toxic chemicals is found in 40 CFR
372.65.
4. RCRA Hazardous Wastes - The consolidated list includes specific chemicals from the RCRA P and U lists only (40 CFR
261.33). RCRA hazardous wastes from the "F" and "K" lists are not included here; such waste streams are also CERCLA
hazardous substances. This listing is provided as an indicator that you may already have data on a specific chemical that
can be used for EPCRA reporting.
There are four columns in the consolidated list corresponding to these four statutory provisions. If a chemical is listed as an
extremely hazardous substance under Section 302, its TPQ is given in the extremely hazardous substance column. Similarly,
the RQ is given for those chemicals that are listed as CERCLA hazardous substances. A key to the symbols used in the
Section 302 and CERCLA columns precedes the list. An "X" in the column for Section 313 indicates that the chemical is
subject to reporting under Section 313.
The letter-and-digit code in the column for 40 CFR 261.33 is the chemical's RCRA hazardous waste code. A blank in any of
these columns indicates that the chemical is not subject to the corresponding statutory authorities.
The Chemical Abstract Service (CAS) registry number is provided for each chemical on the list.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. A1
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Keys to Symbols in the Consolidated Chemical List
+ Indicates polyaromatic compounds (PACs).
* Indicates carbamate wastes under RCRA; statutory one pound RQ applies until RQs are adjusted.
# Indicates diisocyanates.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein. A2
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
This is an alphabetical listing of the consolidated list of chemicals. Numbered chemicals are listed first.
Chemical Name
1 -Amino-2-methylanthraquinone
l-Chloro-l,l-difluoroethane(HCFC-142b)
1 -Chloro- 1 , 1 ,2,2-tetrafluoroethane (HCFC- 124a)
1 -Methylbutadiene
1 -Naphthalamine
1-Propanamine
1-Propanol ,2,3-dibromo-phosphate (3:1)
(1,1 '-Biphenyl)-4,4'diamine, 3,3'-dimethoxy-
(1,1 '-Biphenyl)-4,4'-diamine, 3,3'-dimethyl-
1 , 1 -Dichloro- 1 -fluoroethane (HCFC- 14 1 b)
1 , 1 -Dichloro- 1 ,2,2-trifluoroethane (HCFC- 123b)
1 , 1 -Dichloroethane
1 , 1 -Dichloroethylene
1 , 1 -Dichloropropane
1,1,2-Trichloroethane
1,1,1 ,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
1,2-Benzenedicarboxylic acid, [bis(2-
ethylhexyl)]ester
1,2-Benzenedicarboxylic acid, diethyl ester (diethyl
phthlate)
1 ,2-Benzenediol, 4- [ 1 -hydroxy-2-(methylamino)
ethyl]-
1 ,2-Benzisothiazolin-3(2H)one, 1 , 1 -dioxide
1 ,2-Benzphenanthrene
1,2-Butylene oxide
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
100
100
5,000
10
100
10
1,000
100
1,000
100
100
100
100
1,000
1,000
100
100
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x+
X
Hazardous
Materials
which are
RCRA
wastes
U186
U167
U194
U235
U091
U095
U076
U078
U227
U208
U209
U028
U088
P042
U202
U050
CAS No.
82-28-0
75-68-3
354-25-6
504-60-9
134-32-7
107-10-8
126-72-7
119-90-4
119-93-7
1717-80-6
812-04-4
75-34-3
75-35-4
78-99-9
79-00-5
630-20-6
79-34-5
117-81-7
84-66-2
51-43-4
81-07-2
218-01-9
106-88-7
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A3
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
1 ,2-Dibromo-3-chloropropane
1 ,2-Dibromoethane
1 ,2-Dichloro- 1 ,1 ,2-trifluoroethane (HCFC- 123a)
1 ,2-Dichlorobenzene
1 ,2-Dichloroethane
1,2-Dichloroethylene
1 ,2-Dichloropropane
1 ,2-Dimethylhydrazine
1 ,2-Diphenylhydrazine
1,2-Oxathiolane, 2,2-dioxide
1 ,2-trans-Dichloroethylene
1 ,2,4-Trichlorobenzene
1,2,4,5-Tetrachlorobenzene
1,3-Benzenediol
1,3-Benzodioxole, 5-propyl
1,3-Benzodioxole, 5-)l-l propenyl
1,3-Benzodioxole, 5-) 2,propenyl
1,3-Butadiene
1 ,3-Dichlorobenzene
1 ,3-Dichloropropane
1 ,3-Dichloropropylene
1 ,3-Isobenzofurandione
1,3,5-Tri nitrobenzene
1 ,4-Dichloro-2-butene
1 ,4-Dichlorobenzene
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
1
100
100
1,000
1
10
10
1,000
100
5,000
5,000
10
100
100
10
100
5,000
100
5,000
10
1
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U066
U067
U070
U077
U083
U099
U109
U193
U079
U207
U201
U090
U141
U203
U071
U084
U190
U234
U074
U072
CAS No.
96-12-8
106-93-4
354-23-4
95-50-1
107-06-2
540-59-0
78-87-5
540-73-8
122-66-7
1120-71-4
156-60-5
120-82-1
95-94-3
108-46-3
94-58-6
120-58-1
94-59-7
106-99-0
541-73-1
142-28-9
542-75-6
85-44-9
99-35-4
764-41-0
106-46-7
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A4
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
1,4-Diethylene dioxide (1,4-Dioxane)
1 ,4-Naphthalenedione
2-Acetylaminofluorene
2-Aminoanthraquinone
2-Butanone peroxide
2-Butanone (Methyl ethyl ketone)
2-Butene, 1,4-dichloro-
2-Chloro-l,l,2,2-tetrafluoroethane (HCFC 124)
2-Chloroacetophenone
2-Chloroethyl vinyl ether
2-Chlorophenol
2-Cyclohexyl-4,6-dinitrophenol
2-Ethoxyethanol
2-Furancarboxaldehyde
2-Methoxyethanol
2-Methylpyridine
2-Naphthylamine
2-Nitrophenol
2-Nitropropane
2-Phenylphenol
2-Picoline
2,2-Dichloro- 1,1,1 -trifluoroethane (HCFC- 123)
2,2-Dichloropropionic acid
2,2,4- Trimethylpentane
2,3-Dichloropropene
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
100
5,000
1
10
5,000
1
100
1,000
100
100
1,000
5,000
5,000
10
100
10
5,000
5,000
1,000
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U108
U166
U005
U160
U159
U074
U042
U048
P034
U359
U125
U191
U168
U171
U191
CAS No.
123-91-1
130-15-4
53-96-3
117-79-3
1338-23-4
78-93-3
764-41-0
2837-89-0
532-27-4
110-75-8
95-57-8
131-89-5
110-80-5
98-01-1
109-86-4
109-06-8
91-59-8
88-75-5
79-46-9
90-43-7
109-06-8
306-83-2
75-99-0
540-84-1
78-88-6
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A5
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
2,3,4-Trichlorophenol
2,3,4,6-Tetrachlorophenol
2,3,5-Trichlorophenol
2,3,6-Trichlorophenol
2,3,7,8- Tetrachlorodibenzo p-dioxin (TCDD)
2,4-D acid
2,4-D esters
2,4-D esters
2,4-D esters
2,4-D esters
2,4-D esters
2,4-D esters
2,4-D esters
2,4-D esters
2,4-D esters
2,4-D esters
2,4-Diaminoanisole sulfate
2,4-Diaminotoluene
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,4,5-T esters
2,4,5-T salts
2,4,5-T amines
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
10
10
10
10
1
100
100
100
100
100
100
100
100
100
100
100
10
100
100
10
10
1,000
1,000
5,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U240
U081
U101
P048
U105
CAS No.
15950-66-0
58-90-2
933-78-8
933-75-5
1746-01-6
94-75-7
94-11-1
94-79-1
94-80-4
1320-18-9
1928-38-7
2971-38-2
53467-11-1
1928-61-6
1929-73-3
25168-26-7
39156-41-7
95-80-7
120-83-2
105-67-9
51-28-5
121-14-2
25168-15-4
13560-99-1
1319-72-8
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A6
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
2,4,5- T amines
2,4,5- T amines
2,4,5- T amines
2,4,5- T amines
2,4,5-T esters
2,4,5-T esters
2,4,5-T esters
2,4,5-T esters
2,4,5-T acid
2,4,5-TP acid esters
2,4,5-Trichlorophenol
2,4,6-Tribromophenol
2,4,6-Trichlorophenol
2,5-Dinitrophenol
2,5-Furandione
2,6-Diaminotoluene
2,6-Dichlorophenol
2,6-Dinitrophenol
2,6-Dinitrotoluene
2,6-Xylidine
3,3-Dichlorobenzidine
3,3'-Dimethylbenzidine dihydrochloride
3,4-Dinitrotoluene
3,4,5-Trichlorophenol
3,5-Dichloro-N-( 1 , 1 -dimethyl-2-propynyl)
benzamide
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
5,000
5,000
5,000
5,000
1,000
1,000
1,000
1,000
1,000
100
10
100
10
10
5,000
10
100
10
100
1
10
10
5,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U408
U147
U221
U082
U106
U073
U192
CAS No.
3813-14-7
6369-96-6
6369-97-7
2008-46-0
93-79-8
1928-47-8
2545-59-7
61792-07-2
93-76-5
32534-95-5
95-95-4
118-79-6
88-06-2
329-71-5
108-31-6
823-40-5
87-65-0
573-56-8
606-20-2
87-62-7
91-94-1
612-82-8
610-39-9
609-19-8
23950-58-5
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A7
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
4-Aminoazobenzene
4-Aminobiphenyl
4-Chloro-m-cresol
4-Chlorophenyl phenyl ether
4-Nitrobiphenyl
4,4'-Diaminodiphenyl ether
4,4'-Isopropylidenediphenol
4,4'-Methylene bis(N,N-dimethyl) benzenamine
4,4'-Methylenedianiline
4,4'-Thiodianiline 6-dinitrophenol
4,6-Dinitro-o-cresol
5-Nitro-o-anisidine
5-Nitro-o-toluidine
Acenaphthene
Acenaphthylene
Acetaldehyde
Acetaldehyde, trichloro-
Acetamide
Acetamide, N-(4-ethoxyphenyl)-
Acetamide, N-(aminothi-oxomethyl)-
Acetic acid
Acetic acid, ethyl ester
Acetic acid, fluoro, sodium salt
Acetic acid, lead (2+) salt
Acetic acid, thallium (1+) salt
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
10/10,000
10/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
5,000
5,000
10
10
10
100
100
5,000
1,000
5,000
100
100
1,000
5,000
5,000
10
10
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U039
P047
U181
U001
U034
U187
P002
U112
P058
U144
U214
CAS No.
60-09-3
92-67-1
59-50-7
7005-72-3
92-93-3
101-80-4
80-05-7
101-61-1
101-77-9
139-65-1
534-52-1
99-59-2
99-55-8
83-32-9
208-96-8
75-07-0
75-87-6
60-35-5
62-44-2
591-08-2
64-19-7
141-78-6
62-74-8
301-04-2
563-68-8
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A8
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Acetic anhydride
Acetone
Acetone cyanohydrin
Acetone thiosemicarbazide
Acetonitrile
Acetophenone
Acetyl bromide
Acetyl chloride
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Acrylyl chloride
Aldicarb
Aldicarb sulfone
Adipic acid
Adiponitrile
Aldrin
Allyl alcohol
Allyl chloride
Allylamine
alpha,alpha-Dimethyl phenethylamine
alpha-Endosulfan
alpha-BHC
Aluminum (fume or dust)
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1,000
1,000/10,000
500
1,000/10,000
10,000
100
100/10,000
1,000
500/10,000
1,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
5,000
5,000
10
5,000
5,000
5,000
5,000
1
5,000
5,000
100
1
1*
5,000
1
100
1,000
5,000
1
10
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U002
P069
U003
U004
U006
POOS
U007
U008
U009
P070
P203
P004
POOS
P046
CAS No.
108-24-7
67-64-1
75-86-5
1752-30-3
75-05-8
98-86-2
506-96-7
75-36-5
107-02-8
79-06-1
79-10-7
107-13-1
814-68-6
116-06-3
1646-88-4
45,390
111-69-3
309-00-2
107-18-6
107-05-1
107-11-9
122-09-8
959-98-8
319-84-6
7429-90-5
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A9
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Aluminum oxide (fibrous forms)
Aluminum phosphide
Aluminum sulfate
Aminopterin
Amiton
Amiton oxalate
Amitrole
Ammonia
Ammonium acetate
Ammonium benzoate
Ammonium bicarbonate
Ammonium bichromate
Ammonium bifluoride
Ammonium bisulfite
Ammonium carbamate
Ammonium carbonate
Ammonium chloride
Ammonium chromate
Ammonium citrate, dibasic
Ammonium fluoborate
Ammonium fluoride
Ammonium hydroxide
Ammonium oxalate
Ammonium oxalate
Ammonium oxalate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500
500/10,000
500
100/10,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
100
5,000
10
100
5,000
5,000
5,000
10
100
5,000
5,000
5,000
5,000
10
5,000
5,000
100
1,000
5,000
5,000
5,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P006
U011
CAS No.
1344-28-1
20859-73-8
10043-01-3
54-62-6
78-53-5
3734-97-2
61-82-5
7664-41-7
631-61-8
1863-63-4
1066-33-7
7789-09-5
1341-49-7
10192-30-0
1111-78-0
506-87-6
12125-02-9
7788-98-9
3012-65-5
13826-83-0
12125-01-8
1336-21-6
5972-73-6
6009-70-7
14258-49-2
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A10
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Ammonium picrate
Ammonium silicofluoride
Ammonium sulfamate
Ammonium sulfide
Ammonium sulfite
Ammonium tartrate
Ammonium tartrate
Ammonium thiocyanate
Ammonium vanadate
Amphetamine
Amyl acetate
Analine, 2,4,6-trimethyl-
Aniline
Anthracene
Antimony
Antimony pentachloride
Antimony pentafluoride
Antimony potassium tartrate
Antimony tribromide
Antimony trichloride
Antimony trifluoride
Antimony trioxide
Antimycin A
ANTU (Thiourea, 1-naphthalenyl-)
Aroclor 1016
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1,000
500
1,000
500
1,000/10,000
500/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
10
1,000
5,000
100
5,000
5,000
5,000
5,000
1,000
5,000
500
5,000
5,000
5,000
1,000
100
1,000
1,000
1,000
1,000
100
1
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P009
P119
U012
P072
CAS No.
131-74-8
16919-19-0
7773-06-0
12135-76-1
10196-04-0
14307-43-8
3164-29-2
1762-95-4
7803-55-6
300-62-9
628-63-7
88-05-1
62-53-3
120-12-7
7440-36-0
7647-18-9
7783-70-2
28300-74-5
7789-61-9
10025-91-9
7783-56-4
1309-64-4
1397-94-0
86-88-4
12674-11-2
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A11
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Arsenic
Arsenic acid
Arsenic acid
Arsenic disulfide
Arsenic pentoxide
Arsenic trioxide
Arsenic trisulfide
Arsenous trichloride
Arsine
Arsine, diethyl-
Asbestos
Azaserine
Azinophos-ethyl
Azinophos-methyl
Barban
Barium and compounds
Barium cyanide
Bendiocarb
Bendiocarb phenol
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100/10,000
100/10,000
500
100
100/10,000
10/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1*
10
1*
1*
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P010
P011
P012
P038
U015
U280
P013
U278
U364
CAS No.
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
7440-38-2
1327-52-2
7778-39-4
1303-32-8
1303-28-2
1327-53-3
1303-33-9
7784-34-1
7784-42-1
692-42-2
1332-21-4
115-02-6
2642-71-9
86-50-0
101-27-9
7440-39-3
542-62-1
22781-23-3
22961-82-6
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A12
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Benomyl
Benzal chloride
Benzamide
Benz[a]anthracene
Benz[a]anthracene, 7,12-dimethyl-
Benz[c]acridine
Benzenamine, 2-methyl-5-nitro-
Benzenamine, 2-methyl-, hydrochloride
Benzenamine, 3-(trifluoro-methyl)-
Benzenamine, 4-chloro
Benzenamine, 4-chloro-2-methyl-hydrochloride
Benzenenamine, 4-methyl
Benzenamine, 4-nitro-
Benzenamine4,4'-methylenebis-2-chloro-
Benzenamine, N,N-dimethyl-4-phenylazo-
Benzene
Benzene, l-bromo-4-phenoxy-
Benzene, 1 -(chloromethyl)-4-nitro-
Benzene, 1-methylethyl- (cumene)
Benzene, 1,3-diisocyanatomethyl-
Benzene, chloro-
Benzene, dimethyl-
Benzene, hexachloro-
Benzene, hexahydro- (cyclohexane)
Benzene, m-dimethyl-
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500
500
500/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1*
5,000
10
1
100
100
100
1,000
100
100
5,000
10
10
10
100
5,000
100
100
100
10
1,000
1,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
x+
x+
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U271
U017
U018
U094
U016
U181
U222
P024
U049
U353
P077
U158
U093
U019
U030
U055
U223
U037
U239
U127
U056
U239
CAS No.
17804-35-2
98-87-3
55-21-0
56-55-3
57-97-6
225-51-4
99-55-8
636-21-5
98-16-8
106-47-8
3165-93-3
106-49-0
100-01-6
101-14-4
60-11-7
71-43-2
101-55-3
100-14-1
98-82-8
26471-62-5
108-90-7
1330-20-7
118-74-1
110-82-7
108-38-3
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A13
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Benzene, methyl- (toluene)
Benzene, o-dimethyl-
Benzene, p-dimethyl-
Benzenearsonic acid
Benzenesulfonyl chloride
Benzidine
Benzimidazole, 4,5-dichloro-2-(trifluoromethyl)
Benz[j]aceanthrylene, l,2-dihydro-3-methyl-
Benzo[a]pyrene
Benzo[b]fluoranthene
Benzo[ghi]perylene
Benzoic acid
Benzo[jk]fluorene
Benzo[k]fluoranthene
Benzonitrile
Benzotrichloride
Benzoyl chloride
Benzoyl peroxide
Benzyl chloride
Benzyl cyanide
Beryllium
Beryllium chloride
Beryllium fluoride
Beryllium nitrate
Beryllium nitrate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
10/10,000
500/10,000
100
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1,000
1,000
100
100
1
10
1
1
5,000
5,000
100
5,000
5,000
10
1,000
100
500
10
1
1
1
1
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
x+
x+
x+
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U220
U239
U239
U020
U021
U157
U022
U120
U023
P028
P015
CAS No.
108-88-3
95-47-6
106-42-3
98-05-5
98-09-9
92-87-5
3615-21-2
56-49-5
50-32-8
205-99-2
191-24-2
65-85-0
206-44-0
207-08-9
100-47-0
98-07-7
98-88-4
94-36-0
100-44-7
140-29-4
7440-41-7
7787-47-5
7787-49-7
13597-99-4
7787-55-5
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A14
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
beta-Endosyulfan
beta-BHC
beta-Chloronaphthalene
Bicyclo[2.2. l]heptane-2-carbonitrile, 5-chloro-6-
(methylamino)carbonyl)oxy) imino)-,
Biphenyl
Bis(2-chloroethoxy) methane
Bis(2-chloroisopropyl) ether
Bis(chloromethyl)ketone
Bitoscanate
Boron trichloride
Boron trifluoride
Boron trifluoride compound with methyl ether (1:1)
Bromadiolone
Bromine
Bromoacetone
Bromochlorodifluoromethane (Halon 1211)
Bromoform
Bromotrifluoromethane (Halon 1311)
Brucine
Butanoic acid, 4-[bis(2-chloroethyl)amino]
benzene-
Butyl acetate
Butyl acrylate
Butyl benzyl phthalate
Butylamine
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500/10,000
10/10,000
500/10,000
500
500
1,000
100/10,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
1
5,000
100
1,000
1,000
1,000
100
100
10
5,000
100
1,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U047
U024
U027
P017
U225
P018
U035
CAS No.
33213-65-9
319-85-7
91-58-7
15271-41-7
92-52-4
111-91-1
108-60-1
534-07-6
4044-65-9
10294-34-5
7637-07-2
353-42-4
18772-56-7
7726-95-6
598-31-2
353-59-3
75-25-2
75-63-8
357-57-3
147,985
123-86-4
141-32-2
85-68-7
109-73-9
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A15
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Butyraldehyde
Butyric acid
CI Acid Green 3
CI Basic Green 4
CI Basic Red 1
CI Direct Black 38
CI Direct Blue 6
CI Direct Brown 95
CI Disperse Yellow 3
CI Food Red 5
CI Food Red 15
CI Solvent Orange 7
CI Solvent Yellow 3
CI Solvent Yellow 14
CI Solvent Yellow 34 (Auramine)
CI Vat Yellow 4
Cacodylic acid
Cadmium
Cadmium acetate
Cadmium bromide
Cadmium chloride
Cadmium oxide
Cadmium stearate
Calcium arsenate
Calcium arsenite
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100/10,000
1,000/10,000
500/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
5,000
100
1
10
10
10
10
1
1
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U014
U136
CAS No.
123-72-8
107-92-6
4680-78-8
569-64-2
989-38-8
1937-37-7
2602-46-2
16071-86-6
2832-40-8
3761-53-3
81-88-9
3118-97-6
97-56-3
824-07-0
492-80-8
128-66-5
75-60-5
7440-43-9
543-90-8
7789-42-6
10108-64-2
1306-19-0
2223-93-0
7778-44-1
52740-16-6
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A16
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Calcium carbide
Calcium chromate
Calcium cyanamide
Calcium cyanide
Calcium dodecylbenzene sulfonate
Calcium hypochlorite
Cantharidin
Caprolactam
Captan
Carbachol chloride
Carbamic acid, ethyl ester
Carbamic acid, methyl- nitroso, ethyl ester
Carbamic acid, methyl-o- (((2,4-dimethyl-l,3
dithiolan-2-yl)methylene)amino)-
Carbamic chloride, dimethyl-
Carbamothioic acid, dipropyl-, S-(phenylmethyl)
ester
Carbaryl
Carbendazim
Carbofuran
Carbofuran phenol
Carbon disulfide
Carbon oxyfluoride
Carbon tetrachloride
Carbonyl sulfide
Carbophenothion
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100/10,000
500/10,000
100/10,000
10/10,000
10,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
10
10
1,000
10
1,000
10
5,000
10
100
1
1*
1
1*
100
1*
10
1*
100
1,000
10
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U032
P021
U238
U178
P185
U097
U387
U279
U372
P127
U367
P022
U033
U211
CAS No.
75-20-7
13765-19-0
156-62-7
592-01-8
26264-06-2
7778-54-3
56-25-7
105-60-2
133-06-2
51-83-2
51-79-6
615-53-2
26419-73-8
79-44-7
52888-80-9
63-25-2
10605-21-7
1563-66-2
1563-38-8
75-15-0
353-50-4
56-23-5
463-58-1
786-19-6
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A17
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Carbosulfan
Catechol
Chloramben
Chlordane
Chlorfenvinfos
Chlorinated fluorocarbon (Freon 1 13)
Chlorine
Chlorine cyanide
Chlorine dioxide
Chlormephos
Chlormequat chloride
Chlornaphazine
Chloroacetaldehyde
Chloroacetic acid
Chlorobenzilate
Chlorodibromomethane
Chlorodifluoromethane (HCFC-22)
Chloroethane
Chloroethanol
Chloroethyl chloroformate
Chloroform
Chloromethyl methyl ether
Chlorophacinone
Chloroprene
Chlorosulfonic acid
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1,000
500
100
500
100/10,000
100/10,000
500
1,000
10,000
100
100/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1*
100
100
1
10
10
100
1,000
100
10
100
100
10
10
100
1,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P189
U036
P033
U026
P023
U038
U044
U046
CAS No.
55285-14-8
120-80-9
133-90-4
57-74-9
470-90-6
76-13-1
7782-50-5
506-77-4
10049-04-4
24934-91-6
999-81-5
494-03-1
107-20-0
79-11-8
510-15-6
124-48-1
75-45-6
75-00-3
107-07-3
627-11-2
67-66-3
107-30-2
3691-35-8
126-99-8
7790-94-5
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A18
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Chlorotetrafluoroethane
Chlorothalonil
Chloroxuron
Chlorpyrifos
Chlorthiophos
Chromic acetate
Chromic acid
Chromic acid
Chromic chloride
Chromic sulfate
Chromium
Chromous chloride
Cobalt
Cobalt,((2,2'-l,2- ethanediylbis (ni-
trilomethylidyne))bis(6-fluorophenylato))(2-)-
N,N',O,O')-
Cobalt carbonyl
Cobaltous bromide
Cobaltous formate
Cobaltous sulfamate
Colchicine
Copper
Copper cyanide
Coumaphos
Coumatetralyl
Creosote
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500/10,000
500
1/10,000
100/10,000
10/10,000
10/10,000
100/10,000
500/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
1,000
10
10
1,000
5,000
1,000
1,000
1,000
1,000
5,000
10
10
1
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P029
U051
CAS No.
63938-10-3
1897-45-6
1982-47-4
2921-88-2
21923-23-9
1066-30-4
11115-74-5
7738-94-5
10025-73-7
10101-53-8
7440-47-3
10049-05-5
7440-48-4
62207-76-5
10210-68-1
7789-43-7
544-18-3
14017-41-5
64-86-8
7440-50-8
544-92-3
56-72-4
5836-29-3
8001-58-9
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A19
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Cresol(s) (mixed isomers)
Crimidine
Crotonaldehyde
Crotonaldehyde, (E)-
Cumene hydroperoxide
Cupferron
Cupric acetate
Cupric chloride
Cupric nitrate
Cupric oxalate
Cupric sulfate
Cupric sulfate, ammoniated
Cupric tartrate
Cyanides (soluble cyanide salts and complexes)
Cyanogen
Cyanogen bromide
Cyanogen iodide
Cyanophos
Cyanuric fluoride
Cyclohexanone
Cycloheximide
Cyclohexylamine
Cyclophosphamide
D-Glucopyranose, 2-deoxy-2-(3-methyl-3-
nitrosoureido)-
Daunomycin
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100/10,000
1,000
1,000
500/10,000
1,000/10,000
100/10,000
10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
100
100
100
10
100
10
100
100
10
100
100
10
100
1,000
1,000
100
5,000
10
1
10
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U052
U053
U053
U096
P030
P031
U246
U057
U058
U206
U059
CAS No.
1319-77-3
535-89-7
4170-30-3
123-73-9
80-15-9
135-20-6
142-71-2
7447-39-4
3251-23-8
5893-66-3
7758-98-7
10380-29-7
815-82-7
57-12-5
460-19-5
506-68-3
506-78-5
2636-26-2
675-14-9
108-94-1
66-81-9
108-91-8
50-18-0
18883-66-4
20830-81-3
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A20
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
DDD
DDE
DDE
DDT
Decaborane(14)
Decabromodiphenyl oxide
Delta-BHC
Demeton
Demeton-S-methyl
Di-(2-ethylhexyl)phthlate (DEHP)
Di-n-octyl phthalate
Di-n-propylnitrosamine (N-Nitrosodi-n-
propylamine)
Dialifor
Diallate
Diaminotoluene (mixed isomers)
Diaminotoluene
Diazinon
Diazomethane
Dibenz[a,i]pyrene
Dibenz[a,h] anthracene
Dibenzofuran
Diborane
Dibromotetrafluorethane (Halon 2402)
Dibutyl phthalate
Dicamba
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500/10,000
500
500
100/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
1
5,000
1
1
100
5,000
10
100
10
10
1
100
10
1
100
100
10
1,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
x+
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U060
U061
U028
U107
Ulll
U062
U221
U221
U064
U063
U069
CAS No.
72-54-8
72-55-9
3547-04-4
50-29-3
17702-41-9
1163-19-5
319-86-8
8065-48-3
919-86-8
117-81-7
117-84-0
621-64-7
10311-84-9
2303-16-4
25376-45-8
496-72-0
333-41-5
334-88-3
189-55-9
53-70-3
132-64-9
19287-45-7
124-73-2
84-74-2
1918-00-9
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A21
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Dichlone
Dichloro- 1 , 1 ,2-trifluoroethane
Dichlorobenil
Dichlorobenzene (mixed isomers)
Dichlorobromomethane
Dichlorodifluoromethane (CFC-12)
Dichloroethyl ether
Dichloromethyl ether
Dichloromethylphenylsilane
Dichloropropane
Dichloropropane-dichloropropene (mixture)
Dichloropropene
Dichlorotetrafluoroethane (CFC-1 14)
Dichlorotrifluoroethane
Dichlorvos
Dicofol
Dicrotophos
Dieldrin
Diepoxybutane
Diethanolamine
Diethyl chlorophosphate
Diethyl-p-nitrophenylphosphate
Diethyl sulfate
Diethylamine
Diethylstilbestrol
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
10,000
100
1,000
1,000
100
500
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
100
100
5,000
5,000
10
10
1,000
100
100
10
10
1
10
100
100
10
100
1
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U075
U025
P016
P037
U085
P041
U089
CAS No.
117-80-6
90454-18-5
1194-65-6
25321-22-6
75-27-4
75-71-8
111-44-4
542-88-1
149-74-6
26638-19-7
8003-19-8
26952-23-8
76-14-2
34077-87-7
62-73-7
115-32-2
141-66-2
60-57-1
1464-53-5
111-42-2
814-49-3
311-45-5
64-67-5
109-89-7
56-53-1
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A22
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Digitoxin
Diglycidyl ether
Digoxin
Dihydrosafrole
Diisopropylfluorophosphate
Dimefox
Dimethoate
Dimethylformamide
Dimethyl-p-phenylenediamine
Dimethyl phosphorochloridothioate
Dimethyl phthalate
Dimethyl sulfate
Dimethylamine
Dimethyldichlorosilane
Dimethylhydrazine
Dimetilan
Dinitrobenzene (mixed isomers)
Dinitrophenol
Dinitrotoluene (mixed isomers)
Dinoseb
Dinoterb
Dioxathion
Diphacinone
Diphenylamine
Diphosphoramide, octamethyl-
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100/10,000
1,000
10/10,000
100
500
500/10,000
10/10,000
500
500
500
1,000
500/10,000
100/10,000
500/10,000
500
10/10,000
100
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
10
100
10
100
5,000
100
1,000
10
1*
100
10
10
1,000
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U090
P043
P044
U102
U103
U092
U098
P191
P020
P085
CAS No.
71-63-6
2238-07-5
20830-75-5
94-58-6
55-91-4
115-26-4
60-51-5
25,173
99-98-9
2524-03-0
131-11-3
77-78-1
124-40-3
75-78-5
57-14-7
644-64-4
25154-54-5
25550-58-7
25321-14-6
88-85-7
1420-07-1
78-34-2
82-66-6
122-39-4
152-16-9
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A23
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Dipropylamine
Diquat
Diquat
Disulfoton
Dithiazinine iodide
Dithiobiuret
Diuron
Dodecylbenzenesulfonic acid
Emetine, dihydrochloride
Endosulfan
Endosulfan sulfate
Endothall
Endothion
Endrin
Endrin aldehyde
Epichlorohydrin
EPN
Ergocalciferol
Ergotamine tartrate
Ethanamine, N-ethyl-N-nitroso-
Ethane, l,l'-oxybis-
Ethanesulfonyl chloride, 2-chloro-
Ethanethioamide
Ethanimidothioic acid, 2-(dimethylamino)-N-
hydroxy-
Ethanol, 1 ,2-dichloro-acetate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500
500/10,000
100/10,000
1/10,000
10/10,000
500/10,000
500/10,000
1,000
100/10,000
1,000/10,000
500/10,000
500
1,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
5,000
1,000
1,000
1
100
100
1,000
1
1
1,000
1
1
100
1
100
10
1*
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U110
P039
P049
P050
P088
P051
U041
U174
U117
U218
U394
CAS No.
142-84-7
85-00-7
2764-72-9
298-04-4
514-73-8
541-53-7
330-54-1
27176-87-0
316-42-7
115-29-7
1031-07-8
145-73-3
2778-04-3
72-20-8
7421-93-4
106-89-8
2104-64-5
50-14-6
379-79-3
55-18-5
60-29-7
1622-32-8
62-55-5
30558-43-1
10140-87-1
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A24
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Ethanol, 2,2'-(nitroso imino) bis-
Ethanol, 2,2'-oxybis-, dicarbamate
Ethene, chloro-
Ethion
Ethoprophos
Ethyl acrylate
Ethyl chloroformate
Ethyl methacrylate
Ethyl methanesulfonate
Ethylbenzene
Ethylbis(2-chloroethyl)amine
Ethylene
Ethylene glycol
Ethylene oxide
Ethylene thiourea
Ethylenebisdithiocarbamic acid, salts & esters
Ethylenediamine
Ethylenediamine tetra-acetic acid (EDTA)
Ethyleneimine
Ethylenethiocyanate
Ethylidene dichloride
Famphur
Fenamiphos
Fensulfothion
Ferric ammonium citrate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1,000
1,000
500
1,000
10,000
500
10,000
10/10,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
1*
1
10
1,000
1,000
1
1,000
5,000
10
10
5,000
5,000
5,000
1
1,000
1,000
1,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U173
U395
U043
U113
U118
U119
U115
U116
U114
P054
U076
P097
CAS No.
1116-54-7
5952-26-1
75-01-4
563-12-2
13194-48-4
140-88-5
541-41-3
97-63-2
62-50-0
100-41-4
538-07-8
74-85-1
107-21-1
75-21-8
96-45-7
111-54-6
107-15-3
60-00-4
151-56-4
542-90-5
75-34-3
52-85-7
22224-92-6
115-90-2
1185-57-5
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A25
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Ferric ammonium oxalate
Ferric ammonium oxalate
Ferric chloride
Ferric fluoride
Ferric nitrate
Ferric sulfate
Ferrous ammonium sulfate
Ferrous chloride
Ferrous sulfate
Ferrous sulfate
Fluenetil
Fluometuron
Fluorene
Fluorine
Fluoroacetamide
Fluoroacetic acid
Fluoroacetyl chloride
Fluorouracil
Fonofos
Formaldehyde
Formaldehyde cyanohydrin
Formetanate hydrochloride
Formic acid
Formothion
Formparanate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100/10,000
500
100/10,000
10/10,000
10
500/10,000
500
500
1,000
500/10,000
100
100/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1,000
1,000
1,000
100
1,000
1,000
1,000
100
1,000
1,000
5,000
10
100
100
1*
5,000
1*
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P056
P057
U122
P198
U123
P197
CAS No.
2944-67-4
55488-87-4
7705-08-0
7783-50-8
10421-48-4
10028-22-5
10045-89-3
7758-94-3
7720-78-7
7782-63-0
4301-50-2
2164-17-2
86-73-7
7782-41-4
640-19-7
144-49-0
359-06-8
51-21-8
944-22-9
50-00-0
107-16-4
23422-53-9
64-18-6
2540-82-1
17702-57-7
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A26
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Fosthietan
Fuberidazole
Fulminic acid, mercury (II) salt
Fumaric acid
Furan
Furan, tetrahydro-
Gallium trichloride
Glycidylaldehyde
Guanidine, N-nitroso-N methyl-lST-nitrc
Heptachlor
Heptachlor epoxide
Hexachloro- 1 ,3-tmtadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloronaphthalene
Hexachlorophene
Hexachloropropene
Hexaethyl tetraphosphate
Hexamethylene-l,6-diisocyanate
Hexamethylenediamine, NJSf'-dibutyl-
Hexamethylphosphoramide
Hexane
Hydrazine
Hydrazine sulfate
Hydrochloric acid (hydrogen chloride (aerosol
forms only))
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500
100/10,000
500
500/10,000
100
1,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
10
5,000
100
1,000
10
10
1
1
1
10
100
100
1,000
100
100
500
1
5,000
1
5,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X*
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P065
U124
U213
U126
U163
P059
U128
U130
U131
U132
U243
P062
U133
CAS No.
21548-32-3
3878-19-1
628-86-4
110-17-8
110-00-9
109-99-9
13450-90-3
765-34-4
70-25-7
76-44-8
1024-57-3
87-68-3
77-47-4
67-72-1
1335-87-1
70-30-4
1888-71-7
757-58-4
300,380
4835-11-4
680-31-9
110-54-3
302-01-2
10034-93-2
7647-01-0
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A27
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Hydrochloric acid
Hydrochloric acid (cone. 37% or greater)
Hydrocyanic acid
Hydrogen fluoride
Hydrogen peroxide (cone > 52%)
Hydrogen selenide
Hydrogen sulfide
Hydroquinone
Indeno(l,2,3-cd)pyrene
Iron, pentacarbonyl-
iso-Amyl acetate
iso-Butyl acetate
iso-Butylamine
iso-Butyric acid
Isobenzan
Isobutyl alcohol
Isobutyraldehyde
Isobutyronitrile
Isocyanic acid, 3,4-dichlorophenyl ester
Isodrin
Isophorone
Isophorone diisocyanate
Isoprene
Isopropanolamine dodecyclbenzene sulfonate
Isopropyl alcohol (mfg- strong acid processes)
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100
100
1,000
10
500
500/10,000
100
100/10,000
1,000
500/10,000
100/10,000
100
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
5,000
5,000
10
100
100
100
100
5,000
5,000
1,000
5,000
5,000
1
5,000
100
1,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
x+
X
X
X
X*
X
Hazardous
Materials
which are
RCRA
wastes
P063
U134
U135
U137
U140
P060
CAS No.
7647-01-0
7647-01-0
74-90-8
7664-39-3
7722-84-1
7783-07-5
7783-06-4
123-31-9
193-39-5
13463-40-06
123-92-2
110-19-0
78-81-9
79-31-2
297-78-9
78-83-1
78-84-2
78-82-0
102-36-3
465-73-6
78-59-1
4098-71-9
78-79-5
42504-46-1
67-63-0
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A28
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Isopropyl chloroformate
Isopropylmethylpyrazolyl dimethylcarbamate
Kepone
Lactonitrile
Lasiocarpine
Lead
Lead arsenate
Lead arsenate
Lead arsenate
Lead chloride
Lead fluoborate
Lead fluoride
Lead iodide
Lead nitrate
Lead phosphate
Lead stearate
Lead stearate
Lead stearate
Lead stearate
Lead subacetate
Lead sulfate
Lead sulfate
Lead sulfide
Lead thiocyanate
Leptophos
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1,000
500
1,000
500/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1*
1
10
10
1
1
1
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Toxic
Chemicals 40
CFR
372.65(a)
X
Hazardous
Materials
which are
RCRA
wastes
P192
U142
U143
U145
U146
CAS No.
108-23-6
119-38-0
143-50-0
78-97-7
303-34-4
7439-92-1
10102-48-4
7645-25-2
7784-40-9
7758-95-4
13814-96-5
7783-46-2
10101-63-0
10099-74-8
7446-27-7
1072-35-1
52652-59-2
7428-48-0
56189-09-4
1335-32-6
15739-80-7
7446-14-2
1314-87-0
592-87-0
21609-90-5
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A29
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Lewisite
Lindane
Lithium chromate
Lithium hydride
m-Cresol
m-Dinitrobenzene
m-Nitrophenol
m-Nitrotoluene
Malathion
Maleic acid
Maleic anhydride
Maleic hydrazide
Malononitrile
Maneb
Manganese
Manganese, bis(dimethylcarbamodithioato-S,S')
Manganese, tricarbonyl methylcyclopentadienyl
Mechlorethamine
Melphalan
Mephosfolan
Mercuric acetate
Mercuric chloride
Mercuric cyanide
Mercuric nitrate
Mercuric oxide
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
10
1,000/10,000
100
500/10,000
100
10
500
500/10,000
500/10,000
500/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
10
1,000
100
100
1,000
100
5,000
5,000
5,000
1,000
1*
1
1
10
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U129
U052
U147
U148
U149
P196
U150
CAS No.
541-25-3
58-89-9
14307-35-8
7580-67-8
108-39-4
99-65-0
554-84-7
99-08-1
121-75-5
110-16-7
123-33-1
109-77-3
12427-38-2
7439-96-5
15339-36-3
12108-13-3
51-75-2
148-82-3
950-10-7
1600-27-7
7487-94-7
592-04-1
10045-94-0
21908-53-2
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A30
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Mercuric sulfate
Mercuric thiocyanate
Mercurous nitrate
Mercurous nitrate
Mercury
Methacrolein diacetate
Methacrylic anhydride
Methacryloyl chloride
Methacryloyloxyethyl isocyanate
Methacrylonitrile
Methamidophos
Methanesulfenyl chloride, trichloro-
Methanesulfonyl fluoride
Methanol
Methapyrilene
Methidathion
Methiocarb
Methomyl
Methoxychlor
Methoxyethylmercuric acetate
Methyl 2-chloroacrylate
Methyl acrylate
Methyl bromide
Methyl chloride
Methyl chlorocarbonate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1,000
500
100
100
500
100/10,000
500
1,000
500/10,000
500/10,000
500/10,000
500/10,000
1,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
10
10
10
10
1
1,000
100
5,000
5,000
10
100
1
500
1,000
100
1,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U151
U152
U154
U155
P199
P066
U247
U029
U045
U156
CAS No.
7783-35-9
592-85-8
7782-86-7
10415-75-5
7439-97-6
10476-95-6
760-93-0
920-46-7
30674-80-7
126-98-7
10265-92-6
594-42-3
558-25-8
67-56-1
91-80-5
950-37-8
2032-65-7
16752-77-5
72-43-5
151-38-2
80-63-7
96-33-3
74-83-9
74-87-3
79-22-1
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A31
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Methyl chloroform
Methyl chloroformate (Methylchlorocarbonate)
Methyl hydrazine
Methyl iodide
Methyl isobutyl ketone
Methyl isocyanate
Methyl isothiocyanate
Methyl mercaptan
Methyl methacrylate
Methyl phenkapton
Methyl phosphonic dichloride
Methyl tert-butyl ether
Methyl thiocyanate
Methyl vinyl ketone
Methylenebis(phenylisocyanate) (MBI)
Methylene bromide
Methylene chloride
Methylmercuric dicyanamide
Methylthiouracil
Methyltrichlorosilane
Metolcarb
Mevinphos
Mexacarbate
Michler's ketone
Mitomycin C
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500
500
500
500
500
500
100
10,000
10
500/10,000
500
100/10,000
500
500/10,000
500/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1,000
1,000
10
100
5,000
10
100
1,000
1,000
5,000
1,000
1,000
10
1*
10
1,000
10
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X*
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U226
U156
P068
U138
U161
P064
U153
U162
U068
U080
U164
P190
P128
U010
CAS No.
71-55-6
79-22-1
60-34-4
74-88-4
108-10-1
624-83-9
556-61-1
74-93-1
80-62-6
3735-23-7
676-97-1
1634-04-4
556-64-9
78-94-4
101-68-8
74-95-3
75-09-2
502-39-6
56-04-2
75-79-6
1129-41-5
7786-34-7
315-18-4
90-94-8
50-07-7
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A32
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Molybdenum trioxide
Moncrotophos
(Mono)chloropentafluoroethane (CFC 115)
Monoethylamine
Monomethylamine
Muscimol
Mustard gas
n-Butyl alcohol
N,N-Diethylaniline
N,N-Diethylhydrazine
N,N-Dimethylaniline
N-Nitrosodi-n-butylamine
N-Nitroso-N-ethylurea
N-Nitroso-N-methylurea
N-Nitrosodiphenylamine
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
N-Nitrosonornicotine
N-Nitrosopiperidine
N-Nitrosopyrrolidine
Naled
Naphthalene
Naphthenic acid
Nickel
Nickel ammonium sulfate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
10/10,000
500/10,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
100
100
1,000
5,000
1,000
10
100
10
1
1
100
10
1
10
1
10
100
100
100
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P007
U031
U086
U172
U176
U177
P084
U179
U180
U165
CAS No.
1313-27-5
6923-22-4
76-15-3
75-04-7
74-89-5
2763-96-4
505-60-2
71-36-3
91-66-7
1615-80-1
121-69-7
924-16-3
759-73-9
684-93-5
86-30-6
4549-40-0
59-89-2
16543-55-8
100-75-4
930-55-2
300-76-5
91-20-3
1338-24-5
7440-02-0
15699-18-0
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A33
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Nickel carbonyl
Nickel chloride
Nickel chloride
Nickel cyanide
Nickel hydroxide
Nickel nitrate
Nickel sulfate
Nicotine
Nicotine sulfate
Nitric acid
Nitric oxide
Nitrilotriacetic acid
Nitrobenzene
Nitrocyclohexane
Nitrofen
Nitrogen dioxide
Nitrogen dioxide
Nitroglycerine
Nitrophenol (mixed isomers)
Nitrosodimethylamine
Nitrotoluene
Norbormide
O,O-Diethyl S-methyl dithiophosphate
o-Anisidine
o-Anisidine hydrochloride
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1
100
100/10,000
1,000
100
10,000
500
100
1,000
100/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
10
100
100
10
10
100
100
100
100
1,000
10
1,000
10
10
10
100
10
1,000
100
5,000
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P073
P074
P075
P076
U169
P078
P081
P082
U087
CAS No.
13463-39-3
37211-05-5
7718-54-9
557-19-7
12054-48-7
14216-75-2
7786-81-4
54-11-5
65-30-5
7697-37-2
10102-43-9
139-13-9
98-95-3
1 122-60-7
1836-75-5
10102-44-0
10544-72-6
55-63-0
25154-55-6
62-75-9
1321-12-6
991-42-4
3288-58-2
90-04-0
134-29-2
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A34
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
o-Cresol
o-Di nitrobenzene
o-Nitrotoluene
o-Toluidine
o-Toluidine hydrochloride
Octachloronaphthalene
Osmium tetroxide
Ouabain
Oxamyl
Oxetane, 3,3- bis(chloromethyl)-
Oxydisulfoton
Ozone
p-Anisidine
p-Benzoquinone
p-Cresidine
p-Cresol
p-Di nitrobenzene
p-Nitrophenol
p-Nitrosodiphenylamine
p-Nitrotoluene
p-Phenylenediamine
Paraformaldehyde
Paraldehyde
Paraquat dichloride
Paraquat methosulfate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1,000/10,000
100/10,000
100/10,000
500
500
100
10/10,000
10/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
100
100
1,000
100
100
1,000
1*
10
100
100
100
1,000
5,000
1,000
1,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U052
U328
U222
P087
P194
U197
U052
U170
U182
CAS No.
95-48-7
528-29-0
88-72-2
95-53-4
636-21-5
2234-13-1
20816-12-0
630-60-4
23135-22-0
78-71-7
2497-07-6
10028-15-6
104-94-9
106-51-4
120-71-8
106-44-5
100-25-4
100-02-7
156-10-5
99-99-0
106-50-3
30525-89-4
123-63-7
1910-42-5
2074-50-2
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A35
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Parathion
Parathion, methyl
Paris green (Cuprie acetoarsenite)
Pentaborane
Pentachlorobenzene
Pentachloroethane
Pentachloronitrobenzene
Pentachlorophenol
Pentadecyclamine
Peracetic acid
Phenanthrene
Phenol
Phenol, 2,2'-thiobis [4-chloro-6-methyl
Phenol, 3-(l-methylethyl), methylcarbamate
Phenoxarsine, 10,10'-oxydi-
Phenyl dichloroarsine
Phenylhydrazine hydrochloride
Phenylmercury acetate
Phenylsilatrane
Phenylthiourea
Phorate
Phosacetim
Phosfolan
Phosgene
Phosmet
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100
100/10,000
500/10,000
500
100/10,000
500
500/10,000
100/10,000
500/10,000
500/10,000
500
1,000/10,000
500/10,000
100/10,000
100/10,000
10
100/10,000
100/10,000
10
10/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
10
100
1
10
10
100
10
5,000
1,000
1*
1
100
100
10
10
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P089
P071
U183
U184
U185
U188
P202
P036
P092
P093
P094
P095
CAS No.
56-38-2
298-00-0
12002-03-8
19624-22-7
608-93-5
76-01-7
82-68-8
87-86-5
2570-26-5
79-121-0
85-01-8
108-95-2
4418-66-0
64-00-6
58-36-6
696-28-6
59-88-1
62-38-4
2097-19-0
103-85-5
298-02-2
4104-14-7
947-02-4
75-44-5
732-11-6
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A36
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Phosphamidon
Phosphine
Phosphonothioic acid, methyl-, O-(4-nitrophenyl)
O-phenyl ester
Phosphonothioic acid, methyl-, O-ethyl O-(4-
(methylthio)phenyl ester
Phosphonothioic acid, methyl-, S-(2-(bis(l-
methylethyl)amino)ethyl O-ethyl ester
Phosphoric acid
Phosphoric acid, dimethyl 4-(methylthio)phenyl
ester
Phosphorothioc acid, O,O-diethyl, O-pyrazinyl
ester
Phosphorothioic acid, O,O-dimethyl-S-(2-
methylthio)ethyl est
Phosphorus
Phosphorus oxychloride
Phosphorus pentachloride
Phosphorus pentasulfide
Phosphorus trichloride
Physostigmine
Physostigmine, salicylate (1:1)
Picric acid
Picrotoxin
Piperidine
Pirimifos-ethyl
Polychlorinated biphenyls
Potassium arsenate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100
500
500
500
100
500
500
500
100
500
500
1,000
100/10,000
100/10,000
500/10,000
1,000
1,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
100
5,000
100
1
1,000
100
1,000
1*
1*
1
1
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P096
P040
U189
P204
P188
CAS No.
13171-21-6
7803-51-2
2665-30-7
2703-13-1
50782-69-9
7664-38-2
3254-63-5
297-97-2
2587-90-8
7723-14-0
10025-87-3
10026-13-8
1314-80-3
7719-12-2
57-47-6
57-64-7
88-89-1
124-87-8
110-89-4
23505-41-1
1336-36-3
7784-41-0
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A37
-------
Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Potassium arsenite
Potassium bichromate
Potassium chromate
Potassium cyanide
Potassium hydroxide
Potassium N-methyldithiocarbamate
Potassium permanganate
Potassium silver cyanide
Promecarb
Pronamide
Propargite
Propargyl alcohol
Propargyl bromide
Propham
Propiolactone, beta-
Propionaldehyde
Propionic acid
Propionic acid, 2-(2,4,5-trichlorophenoxy)-
Propionic anhydride
Propionitrile
Propionitrile, 3-chloro-
Propiophenone, 4'-amino-
Propoxur
Propyl chloroformate
Propylene (Propene)
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500/10,000
100
500
500/10,000
10
500
500
1,000
100/10,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1
10
10
10
1,000
100
1
1*
5,000
10
1,000
1*
10
1,000
5,000
100
5,000
10
1,000
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P098
P099
P201
U192
P102
U373
P101
P027
U411
CAS No.
10124-50-2
7778-50-9
7789-00-6
151-50-8
1310-58-3
137-41-7
7722-64-7
506-61-6
2631-37-0
23950-58-5
2312-35-8
107-19-7
106-96-7
122-42-9
57-57-8
123-38-6
79-09-4
93-72-1
123-62-6
107-12-0
542-76-7
70-69-9
114-26-1
109-61-5
115-07-1
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A38
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Propylene oxide
Propyleneimine
Prothoate
Pyrene
Pyrethrins
Pyrethrins
Pyrethrins
Pyridine
Pyridine, 2-methyl-5-vinyl-
Pyridine, 4-amino-
Pyridine, 4-nitro-l -oxide
Pyriminil
Quinoline
Reserpine
Salcomine
Sarin
sec-Amyl acetate
sec-Butyl acetate
sec-Butyl alcohol
sec-Butylamine
sec-Butylamine
Selenious acid
Selenium
Selenium dioxide
Selenium oxychloride
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
10,000
10,000
100/10,000
1,000/10,000
500
500/10,000
500/10,000
100/10,000
500/10,000
10
1,000/10,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
100
1
5,000
1
1
1
1,000
1,000
5,000
5,000
5,000
5,000
1,000
1,000
10
100
10
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P067
U196
POOS
U200
U204
CAS No.
75-56-9
75-55-8
2275-18-5
129-00-0
121-21-1
121-29-9
8003-34-7
110-86-1
140-76-1
504-24-5
1124-33-0
53558-25-1
91-22-5
50-55-5
14167-18-1
107-44-8
626-38-0
105-46-4
78-92-2
13952-84-6
513-49-5
7783-00-8
7782-49-2
7446-08-4
7791-23-3
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A39
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Selenium sulfide
Selenourea
Semicarbazide hydrochloride
Silane, (4-aminobutyl) diethoxymethyl-
Silver
Silver cyanide
Silver nitrate
Simazine
Sodium
Sodium arsenate
Sodium arsenite
Sodium azide (Na(N3))
Sodium bichromate
Sodium bifluoride
Sodium bisulfite
Sodium cacodylate
Sodium chromate
Sodium cyanide (Na(CN))
Sodium dodecylbenzene sulfonate
Sodium fluoride
Sodium fluoroacetate
Sodium hydrosulfide
Sodium hydroxide
Sodium hypochlorite
Sodium hypochlorite
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1,000/10,000
1,000
1,000/10,000
500/10,000
500
100/10,000
100
10/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
10
1,000
1,000
1
1
10
1
1
1,000
10
100
5,000
10
10
1,000
1,000
10
5,000
1,000
100
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U205
P103
P104
P105
P106
P058
CAS No.
7488-56-4
630-10-4
563-41-7
3037-72-7
7440-22-4
506-64-9
7761-88-8
122-34-9
7440-23-5
7631-89-2
7784-46-5
26628-22-8
10588-01-9
1333-83-1
7631-90-5
124-65-2
7775-11-3
143-33-9
25155-30-0
7681-49-4
62-74-8
16721-80-5
1310-73-2
10022-70-5
7681-52-9
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A40
-------
Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Sodium methylate
Sodium nitrite
Sodium pentachlorophenate
Sodium phosphate, dibasic
Sodium phosphate, dibasic
Sodium phosphate, dibasic
Sodium phosphate, tribasic
Sodium phosphate, tribasic
Sodium phosphate, tribasic
Sodium phosphate, tribasic
Sodium phosphate, tribasic
Sodium phosphate, tribasic
Sodium selenate
Sodium selenite
Sodium selenite
Sodium tellurite
Strannane, acetoxy-triphenyl-
Strontium chromate
Strychnine
Strychnine, sulfate
Styrene
Styrene oxide
Sulfotep
Sulfoxide, 3-chloropropyl octyl
Sulfur dioxide
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100/10,000
100/10,000
500/10,000
500/10,000
100/10,000
100/10,000
500
500
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1,000
100
5,000
5,000
5,000
5,000
5,000
5,000
5,000
5,000
5,000
100
100
100
10
10
10
1,000
100
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P108
P109
CAS No.
124-41-4
7632-00-0
131-52-2
10039-32-4
10140-65-5
7558-79-4
10101-89-0
10124-56-8
10361-89-4
7601-54-9
7758-29-4
7785-84-4
13410-01-0
10102-18-8
7782-82-3
10102-20-2
900-95-8
7789-06-2
57-24-9
60-41-3
100-42-5
96-09-3
3689-24-5
3569-57-1
7446-09-5
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A41
-------
Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Sulfur monochloride
Sulfur tetrafluoride
Sulfur trioxide
Sulfuric acid
Sulfuric acid (aerosol forms only)
Sulfuric acid (fuming)
Tabun
Tellurium hexafluoride
Terbufos
tert-Amyl acetate
tert-Butyl acetate
tert-Butyl alcohol
tert-Butylamine
Tetrachloroethylene
Tetrachlorvinphos
Tetraethyl lead
Tetraethyl pyrophosphate
Tetraethyl tin
Tetramethyl lead
Tetranitromethane
Thallic oxide
Thallium
Thallium (I) carbonate
Thallium (I) sulfate
Thallium (I) nitrate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100
100
1,000
1,000
10
100
100
100
500
100
100
500
100/10,000
100/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1,000
1,000
1,000
1,000
5,000
5,000
1,000
100
10
100
10
100
1,000
100
100
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U210
P110
Pill
PI 12
P113
U215
U217
CAS No.
12771-08-3
7783-60-0
7446-11-9
7664-93-9
7664-93-9
8014-95-7
77-81-6
7783-80-4
13071-79-9
625-16-1
540-88-5
75-65-0
75-64-9
127-18-4
961-11-5
78-00-2
107-49-3
597-64-8
75-74-1
509-14-8
1314-32-5
7440-28-0
6533-73-9
10031-59-1
10102-45-1
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A42
-------
Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Thallium (I) selenide
Thallous chloride
Thallous malonate
Thallous sulfate
Thiocarbazide
Thiodicarb
Thiofanox
Thiophanate-methyl
Thiophenol
Thiosemicarbazide
Thiourea
Thiourea, (2-chlorophenyl)-
Thiourea, (2- methylphenyl)-
Thiram
Thorium dioxide
Titanium dioxide
Titanium tetrachloride
Toluene 2,4-diisocyanate
Toluene 2,6-diisocyanate
Toxaphene (Campheclor)
Trans- 1 ,4-dichlorobutene
Triallate
Triamiphos
Triaziquone
Triazofos
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
100/10,000
100/10,000
100/10,000
1,000/10,000
100/10,000
500
100/10,000
100/10,000
500/10,000
100
500
100
500/10,000
500
500/10,000
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1,000
100
100
1*
100
1*
100
100
10
100
10
1,000
100
100
1
1*
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P114
U216
P115
U410
P045
U409
POM
P116
U219
P026
U244
P123
U389
CAS No.
12039-52-0
2,151,976
2757-18-8
7446-18-6
2231-57-4
59669-26-0
39196-18-4
23564-05-8
108-98-5
79-19-6
62-56-6
5344-82-1
614-78-8
137-26-8
1314-20-1
13463-67-7
7550-45-0
584-84-9
91-08-7
8001-35-2
110-57-6
2303-17-5
1031-47-6
68-76-8
24017-47-8
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A43
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Trichlorfon
Trichloroacetyl chloride
Trichloro(chloromethyl) silane
Trichloro(dichlorophenyl) silane
Trichloroethylene
Trichloroethylsilane
Trichlorofluoromethane (CFC- 11)
Trichloronate
Trichlorophenol
Trichlorophenylsilane
Triethanolamine dodecylbenzene sulfonate
Triethoxy silane
Triethylamine
Trifluralin
Trimethylamine
Trimethylchlorosilane
Trimethylolpropane phosphite
Trimethyltin chloride
Triphenyltin chloride
Tris(2-chloroethyl) amine
Trypan blue
Uracil mustard
Uranyl acetate
Uranyl nitrate
Uranyl nitrate
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500
100
500
500
500
500
500
1,000
100/10,000
500/10,000
500/10,000
100
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
100
100
5,000
10
1,000
5,000
10
100
10
10
100
100
100
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
U228
U121
U404
U236
U237
CAS No.
52-68-6
76-02-8
1558-25-4
27137-85-5
79-01-6
115-21-9
75-69-4
327-98-0
25167-82-2
98-13-5
27323-41-7
998-30-1
121-44-8
1582-09-8
75-50-3
75-77-4
824-11-3
1066-45-1
639-58-7
555-77-1
72-57-1
66-75-1
541-09-3
10102-06-4
36478-76-9
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A44
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Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Valinomycin
Vanadium (fume or dust)
Vanadium pentoxide
Vanadyl sulfate
Vinyl acetate
Vinyl bromide
Warfarin
Warfarin and salts, cone. > 0.3%
Warfarin sodium
Xylenol
Xylylene dichloride
Zinc
Zinc (fume or dust)
Zinc acetate
Zinc ammonium chloride
Zinc ammonium chloride
Zinc ammonium chloride
Zinc borate
Zinc bromide
Zinc carbonate
Zinc chloride
Zinc cyanide
Zinc, dichloro(4,4-dimethyl-
5(((methylamino)carbonyl)oxy)imino)
pentanenitrile)-, (T-4)-
Zinc fluoride
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
1,000/10,000
100/10,000
1,000
500/10,000
100/10,000
100/10,000
100/10,000
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1,000
1,000
5,000
100
100
100
100
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
10
1,000
Toxic
Chemicals 40
CFR
372.65(a)
X
X
X
X
X
X
Hazardous
Materials
which are
RCRA
wastes
P120
P001
P001
P121
CAS No.
2001-95-8
7440-62-2
1314-62-1
27774-13-6
108-05-4
593-60-2
81-81-2
81-81-2
129-06-6
1300-71-6
28347-13-9
7440-66-6
7440-66-6
557-34-6
52628-25-8
14639-97-5
14639-98-6
1332-07-6
7699-45-8
3486-35-9
7646-85-7
557-21-1
58270-08-9
7783-49-5
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A45
-------
Protocol for Conducting Environmental Compliance Audits under CERCLA
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under
CERCLA and EPCRA
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Chemical Name
Zinc formate
Zinc hydrosulfite
Zinc nitrate
Zinc phenolsulfonate
Zinc phosphide
Zinc silicofluoride
Zinc sulfate
Zineb
Ziram
Zirconium nitrate
Zirconium potassium fluoride
Zirconium sulfate
Zirconium tetrachloride
Extremely
Hazardous
Substances
40 CFR 355
(TPQ, Ibs.)
500
Hazardous
Substances
40 CFR 302. 4
(RQ, Ibs.)
1,000
1,000
1,000
5,000
100
5,000
1,000
1*
5,000
1,000
5,000
5,000
Toxic
Chemicals 40
CFR
372.65(a)
X
Hazardous
Materials
which are
RCRA
wastes
P122
P205
CAS No.
557-41-5
7779-86-4
7779-88-6
127-82-2
1314-84-7
16871-71-9
7733-02-0
12122-67-7
137-30-4
13746-89-9
16923-95-8
14644-61-2
10026-11-6
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A46
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