UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON, D.C. 20460
                            DEC 18  1991

MEMORANDUM                                             oF(ticeo*;ftif.
                                              SOLID WASTE AND EMERGENCV RESPONSE

SUBJECTS  RCRA/Superfund/OUST/and Community Right-to-Know Hotline
          Revised Monthly Hotline Report

FROM:   x?fe¥iiW&a^zetti, Director
          Communications, Analysis and Budget Division,  OSW

TOt       Addressees  (See List)


     The purpose of this memorandum is to provide you with the
revised Monthly Hotline Report  for the RCRA/Superfund Hotline.
As you will recall, earlier this year, we sent you a  survey
requesting your feedback concerning the usefulness of the Monthly
Hotline Report.  Your comments  were well-received and served as
the foundation for restructuring the Report and  streamlining the
process for its production and  distribution.

     Specifically, you requested a "Question and Answer" section
that included questions from ail affected Hotline OSWER program
areas.  Everyone surveyed also  commented on the  timeliness
factor.  Since the Report then  was issued two to three  months
behind*the current month, the  "Publications" and "Federal
pagtster" sections did not  contain up-to-date information.

     Based on the survey results, we revised the Report changing
its format, expanding and refining the content,  and  implementing
procedures to streamline Report production and distribution.  I
have attached your copy of  the revised Monthly Hotline  Report.

     To improve public access  and meet an unusually  high demand
from non-Agency requestors, we have arranged  for the Monthly
Hotline Report to be  available through the National  Technical
Information Service  (NTIS).  A Monthly Hotline Report Index for
each calendar year and an Annual Report that  contains a
compilation of the current  year's  questions will also be
available from NTIS.

     Thanks again for your  response to our  survey.   We hope you
enjoy our revised, user-friendly Monthly Hotline ReportI

Attachments
                                                          Printed on fl«cycfed Paper

-------
 LIST OF ADDRESSEES^
 EdAbrams,OS-112
 Jennifer Anderson, EPA-Reg. 7
 Kate Anderson, OS-520
 Beth Behrens, EPA-NEIC
 Kathy Bishop, OS-210
 John Bosky, EPA-Kansas City
 BreU Bowhan, DOE-Idaho
 Susan Bromm, OS-SOO
 Karen Brown, A-149C
 Nancy Browne, OS-520
 Karen Burgan, OS-110
 Edmond Burks, EPA-Reg. 5
 Heather Burns, BAH
 Diane Buxbaum, EPA-Reg. 2
 Sabrina Callihan, DOE
 Carol Carbone, EPA-Reg. 1
 Sonia Chambers, EPA-Reg. 5
 Richard Clarizio, EPA-Reg. 5
 Don R. Clay, OS-100
 Jerry Clifford, EPA-Reg. 9
 Bill Cosgrove, EPA-Reg. 4
 Clinton Cox, EPA-Alabama
 MikeCullens,OS-240
 Becky Cuthbertson, OS-332
 Elaine Davies, OS-100
 JefferyDenit,OS-300
 Lynn DePont, OS-305
 Director, RED, LE-134S
 DaveEberly,OS-343
 Chris Elias, CA DepL of Health
 Terry Escarda, CA DepL of Health
 Lisa Friedman, LE-132S
 John Gilbert, EPA-Cinn.
 Diane Glass, Kelly AFB, TX
 Alan Goodman, EPA-Portland, OR
 Kristan Goschen, EPA-Reg. 8
John  Gorman, EPA-Reg. 2
Hinton Howard, EPA-Reg. 5
Henry Hudson, EPA-Reg. 4
Susan Hutcherson, EPA-Reg. 10
Harriet L. Jones, EPA-Reg. 7
Kathy Jones, OS-210
Gary Jonesi, LE-134S
RonJosephson,OS-333
Tony Jover, OS-120
Robert Kayser, OS-333
Mitch Kidwell, OS-332
Bob Kievit, EPA- Olympia, WA
Jerry Killiane, GAO
William Kline, OS-322W
Robert Knox,OS-130
Dan Kovacks, BAH
Walter Kovalick, OS-110
DaveLeotta,PM-214F
Henry Longest, OS-100
JimLoomis, FLERC
Sylvia Lowrance, OS-300
Tom Lueders, EPA-Reg. 5
James Makris, OS-120
Andrea McLaughlin, OS-220W
Chet McLaughlin, EPA-Reg. 7
Dorothy McManus, OS-120
Tami McNamara, TS-779
Scott McPhilamy, EPA-Reg. 3
Charlotte Mooney, OS-332
Robert Morby, EPA-Reg. 7
Royal Nadeau, EPA-Reg. 2
Beverly Negri, EPA-Reg. 6
Susan OTCeefe, LE-134S
ChaePak, EPA-Reg. 10
Myra Perez, EPA-Houston
Mark Phillips, EPA-Reg. 3
Steve Provant, EPA-Bbise, ID
Jim Radle, Jr., EPA-Reg. 9
CarlReeverts,WH-550E
John Riley, OS-210
DaleRuhter,OS-341
Debbie Rutherford, OS-420WF
William Sanjour, OS-330
Sam Sasnett, TS-779
Tim Schoepke, TS-793
Jay Silberman, US Coast Guard
Stergios Spanos, NH DES
Elaine Stanley, OS-SOO
Kathie Stein, LE-134S
Beverly Thomas, OS-420WF
Christine Thomas, BAH
Jim Thompson, OS-520
Linda Thompson, LE-134S
Robert Thompson, A-104
Steve Torok, EPA-Juneau, AK
Harriett Tregoning, PM-220
Betti VanEpps, OS-240
David Van Slyke, LE-134S
Barbara Wagner, EPA-Reg. 8
Howard Wilson, PM-273
Denise Wright, OS-332
Tish Zimmerman, OS-220
                                OSW Deputy Division Directors
                                OSW Branch Chiefs
                                Hardous Waste Management Branch Chiefs, Regions I-X
                                Regional Counsel, Regions I-X
                                Regional Libraries, Regions I-X

-------
     MONTHLY HOTLINE  REPORT
                      October 1991

                  RCRA/SF/OUST and
    Emergency Planning and Community Right-to-Know
   Hotline Questions and Answers

         Resource Conservation and Recovery Act (RCRA)	 1
         Office of Underground Storage Tanks (OUST)	 2
         Emergency Planning and Community Right-to-Know	 3



   New Publications

         Resource Conservation and Recovery Act (RCRA)	 4





   Federal Registers

         Proposed Rules	 6
         Notices	 6




   Call Analyses

         Calls Answered	  10
         Caller Profiles	.	  13
         Hotline Topics	  15
RCRA/SF/OUST Hotline
National Toll Free No.: 800-424-9346
               Emergency Planning and Community
               Right-to-Know Hotline
               National Toll Free No.: 800-535-0202
This report is prepared and submitted in support of Contract No. 68-WO-0039.
EPA Project Officer:
Barbara Roth. (202) 260-2858
U.S. Environmental Protection Agency
Washington. DC 20460
                                                        Printed on
                                                      Recycled Paper

-------
                          HOTLINE QUESTIONS AND ANSWERS
1.
                   RCRA
Application of the Sham Recycling
Policy to Certified Boilers and Industrial
Furnaces
    The February 21,1991, Federal Register (56
FR 7134) promulgated regulations for hazardous
waste boilers and industrial furnaces (BIFs) in 40
CFR Part 266, Subpart H. The preamble (page
7183) to the rule explains that prior to certification
of compliance with the emissions standards under
Section 266,103(c), BIFs (other than BIFs burning
waste solely as an ingredient or solely for material
recovery) must comply with EPA's sham recycling
policy published in the March 16,1983, Federal
Register. (48 F_R 11157)  This policy requires
burners of hazardous waste who claim that their
burning activities constitute legitimate recycling to
demonstrate that the waste has a heating value of
5,000 Btu/lb or more. How does the sham
recycling policy apply to BIFs which have certified
compliance with the Section 266.103(c) air
emissions standards under the BIF rule?

    Certified BIFs are no longer required to prove
that the wastes they are burning have an as-
generated heating value of 5,000 Btu/lb or more.
The requirement that burning be protective of
human health and the environment is now satisfied
through compliance with emissions standards.  The
February 21,1991, BIF rule states that the sham
recycling policy stays in effect (except for wastes
fed solely as an ingredient or solely for material
recovery) until an existing facility certifies
compliance with the emissions standards of
Section 266.103(c). (56 FR 7149)
The 5,000 Btu/lb policy was intended to prevent
the burning of hazardous wastes for destruction
purposes (i.e., incineration) rather than for energy
recovery in units which do not meet incinerator
standards. Wastes going to boilers which are not
legitimately burning for energy recovery are
likely to vent hazardous contaminants to the
atmosphere as unburned or partially burned
combustion products, presenting a risk to human
health and the environment.  By requiring burners
to demonstrate that a waste's heating value is
greater than or equal to 5,000 Btu/lb, the Agency
is able to assure a high enough temperature and
long enough residence time in the boiler to
destroy  hazardous constituents at a rate which is
protective of human health and the environment.
After certification of compliance, however,
protection of human health and the environment
will be achieved through the new air emission
standards.

2.  TSDF Closure/Post-Closure After Loss
    of Interim Status

Pursuant to 40 CFR §270.73(c)(2), a Subtitle C
land disposal facility lost its interim status due to
the owner/operator's failure to submit
certification that the facility was in compliance
with all applicable groundwater monitoring and
financial responsibility requirements. The
owner/operator has been told by his enforcement
agency that he is required to close his facility in
accordance with 40 CFR Part 265, Subpart G
closure  standards. If the facility has lost its
interim status to operate, why should the owner/
operator be required to comply with interim
status standards to close the facility?

-------
    Hotline Questions and Answers
                                                                             October 1991
   According to 40 CFR §265. l(b), the standards of
Part 265 are applicable to interim status facilities
until Part 265 closure and post-closure responsi-
bilities are fulfilled. As EPA explained in the
preamble to its November 21,1984, amendments to
the applicability sections of Part 265 (49 ER 46094),
EPA has statutory authority under §3004 to enforce
the Part 265 standards at facilities which no longer
have interim status to operate.  The preamble
explains that such facilities must close in accordance
with 40 CFR Part 265, Subpart G.
    The September 25,1985, F^1*ra1 Register (50
ER. 38949), specifically indicates that compliance
with all applicable closure and post-closure
requirements specified in 40 CFR 265, Subpart G is
required when a facility has lost its interim status
due to the owner/operator's failure to submit
certification of compliance with all applicable
groundwater monitoring and financial requirements
(40 CFR §270.73(c)(2))  to the Regional
Administrator. Such a facility owner/operator must,
in accordance with 40 CFR §§265.112(d)(3)(i) and
265.118(e)(l), submit a closure and post-closure
plan to the Regional Administrator no later than 15
days after termination of interim status.
3.
Regulation of Clean Air Act Amendment
Hazardous Air Pollutants Under 40 CFR
Part 280
   Section 301 of the Clean Air Act Amendments
of 1990 modifies the Clean Air Act (CAA) of 1986
fry incorporating within section 112 a list of 189
hazardous air pollutants. Many of these pollutants
were not previously regulated under the CAA.
Would an underground storage tank (UST)
containing a newly designated CAA hazardous air
Pollutant be subject to the standards promulgated
in 40 CFR Part 280?
   Yes. Owners or operators of USTs containing
regulated substances, as defined in §280.12, must
comply with the Part 280 standards. A regulated
substance is any hazardous substance designated
pursuant to section 101(14) of the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA) (excluding any substance
regulated as a hazardous waste under Subtitle C of
the Resource Conservation and Recovery Act
(RCRA)), and petroleum products or any fraction
thereof.  The term hazardous substance under
section 101(14) of CERCLA is defined as any
substance designated pursuant to Section 3001 of
RCRA, section 112 of the CAA, sections 307(a)
and 311 (b)(2)(A) of the Federal Water Pollution
Act, section 7 of the Toxic Substances Control
Act, and any substance so designated in section
102 of CERCLA. When a substance is added
under a statute identified in CERCLA section
101(14), it would then become a CERCLA
hazardous substance by  statutory definition and,
therefore, become a regulated substance under Part
280. Although the new  CAA substances that were
not previously CERCLA hazardous substances
have not yet been codified in §302.4 (the
regulatory list of CERCLA hazardous substances),
any underground storage tank storing these
substances must be in compliance with the
requirements of 40 CFR Part 280 regulations.
NOTE:  Any of the new substances or chemical
categories added to the CAA that are CERCLA
hazardous substances or petroleum products, e.g.,
ethylene glycol, are subject to regulation under
Part 280 and this would not change.
                                                  EMERGENCY PLANNING AND
                                                 COMMUNITY RIGHT-TO-KNOW
                                            4. Section 313: Threshold Determination

                                               A facility covered under Section 313 of
                                            EPCRA has met a reporting threshold for

-------
    October 1991                                                  Hotline Questions and Answers


ammonia. A sewage system within the facility           No. The ammonia present in the sewage is
collects human waste from different parts of the     derived from the employees working at the
facility. The ammonia present in the sewage is not  plant and is subject to the personal use
involved in any manufacturing, processing, or       exemption (40 CFR §372.38(c)). Therefore,
other use activities at the facility. Since the facility  even though the facility has exceeded an
has already exceeded an activity threshold for       activity threshold, they would not be required
ammonia, are they required to report the releases   to report the exempted releases of ammonia.
of ammonia that are emitted in the sewage?

-------
                      NEW PUBLICATIONS
      HOW TO ORDER
   NTIS Publications are available by calling (703) 487-4650, or writing NTIS, 5285 Port Royal Road, Springfield,
   VA 22161.  Be sure to include the NTIS Order Number listed under the document.
   Hotline Publications are available through the RCRA/Superfund/OUST Hotline by calling a Document
   Specialist at 1-800-424-9346. Be sure to include the EPA Order Number (if any) listed under the document.
                  RCRA
 TITLE:  "EPA Intends to Provide Guidance
 on Use of Terms Recycled & Recyclable"
 AVAILABILITY: Hotline
 EPA ORDER NO.: EPA/530-SW-91-072

 Provides voluntary guidance on specific terms
 and their uses to help educate consumers and
 advise marketers.

 TITLE:  "Modifications Proposed for Wood
 Preserving Regulations"
 AVAILABILITY: Hotline
 EPA ORDER NO.: EPA/530-SW-91-074

 EPA is proposing to revise the wood
 preserving rule to develop more practical drip
 pad management and design standards. This
 notice will provide an opportunity for public
 comment on implementation problems
 involved with the wood preserving rule.

 TITLE: "Proposal to List Wastes Generated
 During the Manufacture of Chlorinated
 Toluenes"
 AVAILABILITY: Hotline
 NTIS ORDER NO.: EPA/530-SW-91-033

 Lists, as hazardous, three wastestreams
 generated by the production of chlorinated
toluenes.
TITLE: "National Survey of Hazardous
Waste Generators and Treatment, Storage and
Disposal Facilities in 1986: Hazardous Waste
Generation and Management"
AVAILABILITY:  Hotline
EPA ORDER NO.: EPA/530-SW-91-075

Provides comprehensive information
describing the entire universe of hazardous
waste management activities.

TITLE: "Regulatory Impact Analysis for
Final Criteria For Municipal  Solid Waste
Landfills"
AVAILABILITY:  Hotline
EPA ORDER NO.: EPA/530-SW-91-073A

Impact analysis for final criteria for municipal
solid waste landfills.

TITLE: "Addendum: Regulatory Impact
Analysis for Final Criteria For Municipal Solid
Waste Landfills."
AVAILABILITY: Hotline
EPA ORDER NO.: EPA/530-SW-91-073B.

Addendum to impact analysis for municipal
solid waste landfill final criteria.

-------
                             FEDERAL REGISTERS
         PROPOSED RULES
               NOTICES
RCRA
RCRA
"Proposed Listing of Chlorinated Toluenes"
October 11,1991 (56 EB 51592)

   EPA is proposing to amend the regulations for
hazardous waste management under RCRA by
listing three wastes generated during the production
of "chlorinated toluenes." The effect of this
proposed regulation, if promulgated, is that these
three wastes will be subject to regulation as a
hazardous waste under 40 CFR Parts 124,262-266,
268,270, and 271. EPA is also proposing
amendments to regulations promulgated under
CERCLA in 40 CFR Part 302, designating the
wastes proposed for listing as CERCLA hazardous
substances and establishing reportable quantities
applicable to these wastes. Comments were
received until December 10,1991.

"Amendment of Conditional Exclusion "
October 25,1991 (56 EB 55257)

   EPA is proposing to amend an upfixmt
conditional exclusion, previously granted on March
11,1988, for certain wastes that were generated by
the incineration of cancelled 2,4,5 T and Silver
pesticide products using the EPA Mobile
Incineration System (MIS) in McDowell Missouri.
Specifically, the Agency is proposing to transfer the
March 1988 exclusion to wastes  to be generated
from the same materials by a different, state-of-the-
art incinerator that is owned and operated by Aptus,
Incorporated, located in Cofifeyvilte, Kansas.  The
Agency is also proposing to modify verification
testing requirements.
"Recycled and Recyclable Marketing
Claims"
October 2,1991 (56 EB 49992)

   EPA solicited comments on a number of
options it is considering for guidance on the use
of the terms "recycled" and "recyclable," and the
recycling emblem in environmental marketing
claims. Comments must be received on or before
December 31,1991. EPA also announced a
public meeting held on November 13 and 14,
1991, to receive oral comments on the options
outlined in this notice. Requests to present oral
testimony must be received on or before October
28,1991.

"Used Oil Public Meetings"
October 11,1991  (56 EH 51389)

   EPA announces that three public meetings
were held on October 24 and 25,1991, to discuss
the Agency's recent action concerning the
regulations of used oil and other issues related to
used oil.

"BP Chemicals LDR Exemption"
October 28,1991  (56 EB 55500)

   EPA gives notice that a modification of an
approved exemption to the Land Disposal
Restrictions under RCRA has been granted to BP
Chemicals for the Gass I injection wells located
at Port Lavaca, Texas.
Copies of RCRA Federal Registers are available through the Hotline by calling a Document Specialist at
1-800-424-9346.

-------
  Federal Registers
                            October 1991
                                     NOTICES
 RCRA

 "Meeting on Class II Underground
 Injection Wells"
 October 31,1991 (56 EB 56077)

    EPA gives notice of a meeting to discuss the
 issues surrounding the guidances, construction,
 and areas of review requirements for class n
 (related to oil and gas) underground injection
 wells.

 SUPERFUND

 "United States v. CftY Qf Kentwood.
 Michigan"
 October 9,1991 (56 EB 50947)

    DOJ gives notice of a proposed Consent
 Decree in United States v. Hty of Kentwood.
 Michigan, lodged with the U.S. District Court for
 the Western District of Michigan. Comments
 were accepted for a period of 30 days.

 "United States v. AVX Corporation, et al."
 October 10,1991  (56 EB 51238)

    DOJ gives notice of a proposed Consent
 Decree in United States v. AVX Corporation et
 aL, lodged with U.S. District Court for the
 District of Massachusetts. Comments were
 accepted for a period of 30 days.

 "United  States v.  Marathon Battery
 Company"
 October 10,1991  (56 EB 51238)

    DOJ gives notice of a proposed Consent
 Decree in United States v. Marathon Battery
 Company, lodged in the U.S. District Court for
 the Southern District of New York. Comments
 were accepted for a period of 30 days.
"United States v. Mexico Feed and Seed
Co.. et al."
October 10,1991 (56 EB 51239)

   DOJ gives notice of a proposed Consent
Decree in United States v. Mexico Feed and Seed
Co.. et al.. lodged with the U.S. District Court for
the Eastern District of Missouri Comments were
accepted for a period of 30 days.

"United States v. Schlumberger
Industries. Inc."
October 10,1991 (56 EB 51239)

   DOJ gives notice of a proposed Consent
Decree in United Stajeg v. Schlumberger
Industries. Inc.. lodged with the U.S. District
Court for the Southtem District of Illinois.
Comments were accepted for a period of 30 days.

"United States v. Wards Cove Packing
Company. Inc."
October 10,1991 (56 EB 51240)

   DOJ gives notice of a proposed Consent
Decree in United States v. Wards Cove Packing
Company. Inc.. lodged with the U.S. District
Court for the Western District of Washington.
Comments were accepted for a period of 30 days.

"Hazardous Substance  Task Force
Meeting"
October 11,1991 (56 EB 51626)

   EPA announced a meeting on October 29,
1991, to assist the Agency and the InterAgency
Hazardous Substance Task Force in identifying
innovative, nontraditional approaches that may
be used to prevent and better control accidental
releases of chemicals that may pose a hazard to
human health, or the environment
Copies of RCRA Federal Registers are available through the Hotline by calling a Document Specialist at .
1-800-424-9346.

-------
October 1991
                                    NOTICES
                                                                    Federal Registers
SUPERFUND

"Proposed Cost Recovery Settlement
with Westinghouse Electric Corporation"
October 15,1991 (56 EB 57717)

   EPA proposed to enter into a cost recovery
settlement agreement under section 122(h)(l) of
CERCLA with Westinghouse Electric
Corporation for response costs incurred at the
Baker Residence Site in Muncie, Indiana.
Comments were received on or before
November 14,1991.

"Proposed Settlement with GTE
Products Corporation"
October 16,1991 (56 EB 51895)

   EPA gives notice of a proposed settlement to
resolve claims under section 122(h) of CERCLA
for response costs at the Southern Desk Cabinet
Site in Hickory, North Carolina, with GTE
Products Corporation.  Comments on this
proposed settlement were accepted for a period of
30 days.

"Proposed Settlement with Mimms
Enterprises and Coral International, Inc."
October 16,1991 (56 EB 51895)

   EPA gives notice of a proposed settlement to
resolve claims under section 122(h) of CERCLA
for response costs  at the Maxi-EM, Inc.,
Hydrofluoric Acid Release Site in Atlanta,
Georgia, with Mimms Enterprises and Coral
International, Inc.  Comments on this proposed
settlement were accepted for a period of 30 days.
"Revised Priority List"
October 17,1991 (56 EB 52166)

   EPA provides a revised priority list of 275
hazardous substances based on the most
comprehensive information currently available
for substances found at NPL sites. This list
prioritizes hazardous substances most commonly
found at NPL facilities that, in their sole
discretion, are determined to pose the most
significant potential threat to human health. This
notice also identifies additional substances whose
total score did not differ considerably from
substances near the lower end of the revised
priority list Furthermore, this notice provides
substances identified on previous priority lists but
not included on the revised priority list

"Proposed Settlement with Kalama
Specialty Chemical, Inc."
October 23,1991 (56 EB 54862)

    EPA gives notice of a proposed settlement to
resolve claims under section 122(h) of CERCLA
for response costs at the Kalama Specialty
Chemical Site in Beaufort, South Carolina, with
Kalama Specialty Chemical, Inc. Comments on
this proposed settlement were accepted for a
period of 30 days.

"Proposed  Settlement with  Union
Chemical Company, Inc."
October 29,1991 (56 EB 55674)

    EPA is proposing to enter into a dfi minimis
administrative settlement pursuant to section
 122(g)(4) of CERCLA to resolve claims for
recovery of cost incurred at the Union Chemical
Company, Inc., Superfund Site in South Hope,
 Maine.  Comments were provided on or before
 November 29,1991.

-------
 Federal Registers
                                     NOTICES
                              October 1991
 SUPERFUND
OUST
 "Proposed Settlement for Actions Taken   "Approval of North Dakota's UST
 at Waterboro Patent Leather"             Program"
 October 29,1991 (56 EB 55675)            October 11,1991 (56 EB 51333)
    EPA is proposing to enter an administrative
 settlement to address claims under section 122(h)
 of CERCLA to resolve the liability of Antonio
 Andreotolla and North East Hide and Fur
 Corporation for costs incurred by EPA in
 conducting response actions at the Waterboro
 Patent Leather Superfund site in Waterboro,
 Maine.

 "Liquids Release Test"
 October 29,1991 (56 EB 55646)

   EPA provides the results of a single
 laboratory and multi-laboratory collaborative
 study on an improved liquids release test (LRT),
 and requests comments on these results and
 specific issues concerning the LRT.  Comments
must be submitted on or before January 13,1992.
   EPA announces final approval of North
Dakota's underground storage tank program
under Subtitle I of RCRA. EPA is granting final
approval to the state to operate its program unless
adverse public comment shows the need for
further review. Comments were received by the
close of business on November 12,1991.

GENERAL

"Regulatory Agenda"
October 21,1991 (56 EB 54012)

   EPA provides specific information on the
status of regulations that are under development,
revision and review at the Agency.

-------
                           CALL ANALYSES
                        CALLS ANSWERED BY HOTLINE
                           October Daily Volume*

                                           RCRA/SF/OUST
       600  -p
       500  -.
    vt
   O
400 -
300 -
200 -
c
100 -
o -
•
•
Emergency Planning and
Community Right-to-Know
•
. n S_r^ r»tj-o""a ^TJ^ *"" ^J"^ *~^ff
— 1— I 	 1 	 1— 1 	 1 	 1 	 1 	 1 	 1 1 1 	 1 	 1— I 	 1 — 1 I
|11,938|
X,
I 2,727 |
i i i
Grand Total
1 14.665

           1  23478  9101115161718212223242528293031

                           Quarter-To-Date Volume*
      12000 T
      10000 -.
      8000 ..
    i
6000 -.
      4000 - •
      2000 -•
                                       RCRA/SF/OUST
                                       Emergency Planning and
                                       Community Right-to-Know
         August
                             September
October
All calls answered by the Call Management System.

-------
 Call Analyses
October 1991
                               CALLS ANSWERED BY TYPE
                                    October Daily Volume*
         800 T
         700 . .
        600 . .
        500 • .
      • 400

      I
        300 - .
        200  -
        100  .
                                                                 Questions/Referrals
                                                                    Documents
                                                                                        Grand Total
      I  16.841  I
                              8   9  10  11   15  16  17   18  21   22   23  24  25   28  29  30  31
                                  Quarter-to-Date Volume4
       14000 -r
       12000  • •
       10000  . .
       8000  • •
    K  6000  . .
       4000
       2000  - •
                                                                 Questions/Referrals
                                                                 Documents
          August
   	1
    October
* All calls answered by the Call Management System. A single call may result in multiple questions combined with document
requests and referrals.
10

-------
October 1991
Call Analyses
                       CALLS ANSWERED BY PROGRAM AREA
                                      October 1991*
  Based on 14,659 questions posed and excludes 2.182 referrals made from both Hotlines
                                 Quarter-at-a-Glance*
 ' Aug. Sept, Oct 91
  Based on 40,817 questions posed and excludes 6,419 referrals made from both Hotlines
                                                                                       11

-------
 Call Analyses
                                October 1991
                              CALLER PROFILE
                            RCRA/SF/OUST Hotline
                    Regulated Community                   8,757
                    Citizens                                804
                    State & Local Gov't./Native American        517
                    Federal Agencies                         280
                    Educational Institutions                    307
                    EPA                                  242
                    Other                                  196
                    Media                                  81
                    Interest Groups                          202
                    Congress                                0
                    Referrals                             1.417

                    TOTAL                             12^03
               State/Local Gov't/
                Native American
                     5%
 Federal
Agencies
  2%
             Citizens
              7%
                                              Regulated
                                             Community
                                                77% ,
12

-------
October 1991
                               Call Analyses
                             Emergency Planning and
                        Community Right-to-Know Hotline
   Manufacturer
    Food/Tobacco                   36
    Textiles                        21
    Apparel                         3
    Lumber & Wood                12
    Furniture                       18
    Paper                          16
    Printing & Publishing            24
    Chemicals                     298
    Petroleum & Coal               41
    Rubber and Plastics              40
    Leather                          1
    Stone, Clay & Glass              29
    Primary Metals                  32
    Fabricated Metals              103
    Machinery (Excluding Electrical)   16
    Electrical&Electronic Equipment   66
    Transportation Equipment         47
    Instruments                      9
    Misc. Manufacturing             39
    Not Able to Determine          113
Consultants/Engineers
Attorneys
Citizens
All Others
  Trade Associations
  Public Interest Groups
  Universities/Academia
  Insurance Companies
  Hospitals
  State Agencies/SERC
  Fire Departments
  EPA
  Local Officials
  LEPC
  Farmers
  Federal Agencies
  Media/Press
  Union/Labor
  Distributors
  Indians
  Laboratories
  Misc.
Referrals

TOTAL
  512
  131
  216

   23
   31
  137
    5
   13
   96
   16
  121
   13
   31
    3
   28
   31
    0
   24
    0
   16
  171
  765

3,347
                 All Others
                   30%
      Citizens
        8%
          Attorneys
             5%
                                                      Manufacturers
                                                          37%
                          Consultants/Engineers
                                 20%

-------
Call Analyses
                                                                      October 1991
                               HOTLINE TOPICS
 RCRA
 General/Misc.
 Special Wastes
  Ash
  Bevill
  Medical
  Oil and Gas
 Subtitle C Wastes
 Hazardous Waste
 Identification General
 Toxicity Characteristic
 Wood Preserving
 Used Oil
 Fluff
 Mixed Waste
 Delisting & Petitions
 Hazardous Waste Recycling
 Generators
 Small Quantity Generators
 Transporters
 Treatment, Storage & Disposal
 Facilities
 General Facility Standards
 Siting
 Capacity
 Treatment
 Burning
 Storage
 Disposal
 Land Disposal Restrictions
 Permits & Interim Status
 Corrective Action
 Financial Assurance
 Liability/Enforcement
 Test Methods
 Health Effects
 Pollution Prevention/Waste Min.
 State Programs
 Hazardous Waste Data
 Subtitle D Wastes
 Household Hazardous Waste
 Subtitle D Facilities
 General Facility Standards
 Siting
 Combustion
 Industrial Wastes
 Composting
 Source Reduction
 Grants & Financing
 Procurement
 General
                          1,031*
                              1
                            22
                            111
                              4
                          1,604*
                           217
                            28
                           366
                             0
                            20
                            29
                           143
                           479*
                           105
                           123
                           178
                             3
                             1
                           358
                           158
                           120
                            61
                           564*
                           116
                           168
                            34
                            83
                           140
                             0
                            46
                            50
                             7

                            90

                           589*
                            13
                             3
                             0
                             0
                             2
                             4

                             0
 Building Insulation                0
 Cement & Products with Fly Ash     0
 Paper & Paper Products             0
 Re-refined Lubricating Oil          0
 Retread Tires                     0
Solid Waste Recycling
 General                        176
 Aluminum                       2
 Batteries                        2
 Glass                           3
 Paper                           5
 Plastics                         12
 Tires                            4
 Used Oil                        0
Markets
 General                         67
 Aluminum                       3
 Batteries                        2
 Compost                        3
 Glass                           1
 Paper                           1
 Plastics                         2
 Tires                            0
 Used Oil                         0

TOTAL                      7,354


SUPERFUND

General/Misc.                   65*
Access & Information Gathering     34
Administrative Record               1
Allocations from Fund               8
ARARs                          40
CERCLIS                      113*
Citizen Suits                       6
Clean-Up Costs                   11
Clean-Up Standards                20
Community Relations                9
 Contract Lab Program (CLP)        30
Contractor Indemnification           6
 Contracts                         7
Definitions                       21
 Emergency Response               6
Enforcement                      26
Exposure Assess./Risk Assess.       22
 Federal Facilities                  23
Fund Balancing                    2
Grants                             1
14
* Hot topics for this reporting period
• Topics are calculated as the summation of all questions received by the Hotline. A single call may result In multiple
  questions.

-------
October 1991
                                        Call Analyses
 Hazardous Substances
 Health/Toxics
 HRS
 Liability
 Mandatory Schedules
 Natural Resource Damages
 NBARs
 NCP
 Notification
 NPL
 Off Site Policy
 On Site Policy
 OSHA
 PA/SI
 PRPs
 Public Participation
 RCRA Interface
 RD/RA
 Remedial
 Removal
 Response
 RI/FS
 ROD
 RQ
 SARA Interface
 Settlements
 SITE Program
 State Participation
 State Program
 Taxes
 Title ID/Right-to-Know

 TOTAL


 OUST


 General/Misc.
 Applicability/Definitions
 Regulated Substances
 Standards for New Tank Systems
 Tank Standards and Upgrading
 OperatingRequirements
 Release Detection
 Release Reporting & Investigation
 Corrective Action for USTs
 Out-of-Service/Closure
 Financial Responsibility
 State Programs
Liability^Enforcement
LUST Trust Fund

SUBTOTAL
  156*
    9
   40
   98*
    0
    4
    1
   49
   53
  141*
    6
    3
    2
   20
   15
    4
    6
    6
   32
   19
    5
   30
   25
  198*
    4
    8
   26
   11
    7
    8
   25

1,462
  89*
  54*
  14
  13
   6
  20
  20
  19
  22
  101*
 325*
  14
  18
   4

 719
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW


  Title IK General                230

  §301-3 Emergency Planning
  General                       110
  SERCs/LEPC                   23
  Notification                    15
  Mixtures                        6
  Extremely Hazardous Substances   56
  Delisting EHS                    6
  Exemptions                    31

§304:
  General                        86
  Notification Requirements        35
  Reportable Quantities            40
  RQs vs. TPQs                   20
  Transportation                   15
  Exemptions                    17

§311/312:
  General                      185*
  MSDS Reporting Requirements    56
  Tier I/II Regulations             68
  Thresholds                     46
  OSHA Expansion               11
  Hazard Categories               22
  Mixtures                       27
  Exemptions                    51

§313:
  Form R                      407*
  Thresholds                    61*
  Phase I                        72
  Phase II                       31*
  Phase IH                       16
  Workshop (Training)             16
  Petitions                       40
  Health Effects                   21
  Database                       91
  Exemptions                    76

Training:
  General                         2
  §305 Training Grants              0
  §305 Emergency Systems Review   1
  § 126 (SARA) Training Regulations  1
   * Hot topics for this reporting period
   • Topics are calculated as the summation of all questions received by the Hotline. A single call may result in multiple
    questions.
                                                                                15

-------
Call Analyses                                                           October 1991


General:                                  Trade Secrets                       15
  CEPP Interim Guide               0      Enforcement                        9
  Chemical Profile                  0      Liability                            1
  NRT-1                           1
  Hazard Analysis                   0
  Risk Communication               0      TOTAL                         2,191
  Title IE Workshops                0
  Information Management           0
  Prevention ARIP                  0
  Other                         174*
TOTAL HOTLINE QUESTIONS,
DOCUMENT REQUESTS AND
REFERRALS:                 16,841
  * Hot topics for this reporting period
  • Topics are calculated as the summation of all questions received by the Hotline. A single call may result In multiple
    questions.

-------