DRAFT
TECHNICAL BASE FOR DESIGNATION OF HAZARDOUS SUBSTANCES
AND ASSIGNMENT OF REPORTABLE QUANTITIES
A Report to the
Emergency Response Division
Office of Emergency and Remedial Response
United States Environmental Protection Agency
Prepared by
Rockwell International Corporation
Environmental Monitoring & Services Center
2421 West Hillcrest Drive
Newbury Park, California 91320
October 30, 1981
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DRAFT
TECHNICAL BASE FOR DESIGNATION OF HAZARDOUS SUBSTANCES
AND ASSIGNMENT OF REPORTABLE QUANTITIES
A Report to the
Emergency Response Division
Office of Emergency and Remedial Response
United States Environmental Protection Agency
Prepared by
Rockwell International Corporation
Environmental Monitoring & Services Center
2421 West Hi 11 crest Drive
Newbury Park, California 91320
October 30, 1981
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FOREWORD
This draft report was prepared to provide the U.S. Environmental Pro-
tection Agency Emergency Response Division with technical assistance for
issuing regulations pursuant to Sections 102 and 103 (a,b) of the Compre-
hensive Emergency Response and Liability Act. Principal authors were
F. C. Gunderloy, Jr., M. Kirsch, G. R. Ricci, P. Scofield, arid R. S. Smith.
The guidance of P. Holtzclaw, Dr. K. J. Kooyoomjian, and John Riley is
gratefully acknowledged. A preliminary draft was also reviewed by
J. Lounsbury, D. Patrick, and J. Cross, whose comments have been incorpor-
ated into this revision. Leo McCarthy of the Oil and Hazardous Materials
Spills Branch, MERL, Edison, New Jersey, served as Project Officer and pro-
vided invaluable advice in the preparation of this document.
"If a better system is thine, impart it, else make use of mine."
Homer
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CONTENTS
Foreword
1. Introduction and Summary
2. Issues
3. Recommendations
4. History of Designation
5. Designation of Hazardous Substances
6. Assignment of Reportable Quantities
7. Radionuclides
8. Data Management System 8-1
9. Experts and Centers of Excellence 9-1
Appendi ces
A Definitions A-l
B List of Hazardous Substances From Prior Regulations B-l
C Candidate List of Hazardous Substances, Priority 1 C-l
D Candidate List of Hazardous Substances, Priority 2 D-l
E Hazard Index E-l
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SECTION 1
INTRODUCTION AND SUMMARY
Under Section 102 of CERCLA, or Superfund (PL 96-510), the Administrator
of the United States Environmental Protection Agency is authorized to designate
as hazardous substances any chemicals deemed appropriate in addition to those
so defined in Section 101(14) of the Act. This section also permits the
assignment of a Reportable Quantity for the designated hazardous substances.
To quote from the appropriate sections of the Act:
Sec. 102.(a) The Administrator shall promulgate and revise as may be
appropriate, regulations designating as hazardous substances, in addition
to those referred to in section 101(14) of this title, such elements,
compounds, mixtures, solutions, and substances which, when released into
the environment may present substantial danger to the public health or
welfare or the environment, and shall promulgate regulations establishing
that quantity of any hazardous substance the release of which shall be
reported pursuant to section 103 of this title. The Administrator may
determine that one single quantity shall be the reportable quantity for
any hazardous substance, regardless of the medium into which the hazardous
substance is released.
(b) Unless and until superseded by regulations establishing a reportable
quantity under subsection (a) of this section for any hazardous substance
as defined in section 101(14) of this title, (1) a quantity of one pound,
or (2) for those hazardous substances for which reportable quantities have
been established pursuant to section 311(b)(4) of the Federal Water
Pollution Control Act, such reportable quantity, shall be deemed that
quantity, the release of which requires notification pursuant to section
103(a) or (b) of this title.
Sec. 101(14) "hazardous substance" means (A) any substance designated
pursuant to section 311(b)(2)(A) of the Federal Water Pollution Control
Act, (B) any element, compound, mixture, solution, or substance designated
pursuant to section 102 of this Act, (C) 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), (D) any toxic pollutant listed under section 307(a) of the
Federal Water Pollution Control Act, (E) any hazardous air pollutant
listed under section 112 of the Clean Air Act, and (F) any imminently
hazardous chemical substance or mixture with respect to which the Admin-
istrator has taken action pursuant to section 7 of the Toxic Substances
Act. The term does not include petroleum, including crude oil or any
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fraction thereof which is not otherwise specifically listed or designated
as a hazardous substance under subparagraphs (A) through (F) 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).
The above definition clearly includes as hazardous substances those
promulgated in 40CFR116 under section 311 of the Clean Water Act for which
reportable quantities, RQs, have been established under 40CFR117, and many
substances under section 307(a) of this Act and under several other acts for
which no RQ has been established except the one pound specified in section
102(b)(1) of Superfund.
The primary motivation for passage of CERCLA was concern for the danger to
human health presented by the many dump sites (such as Love Canal) scattered
throughout the country from which improperly disposed of chemicals are entering
the environment and endangering the public health and welfare and the environ-
ment. One major purpose of CERCLA is to provide a mechanism for cleaning up the
"orphan" dump sites. In addition, to prevent further occurrences, the Act also
requires that releases of the designated hazardous substances above the
assigned reportable quantity (with some allowable specified exemptions) be
reported to the National Response Center. This early reporting requirement is
designed to permit an emergency response, when appropriate, to prevent esca-
lation of the hazard created by the release.
INTENT OF CONGRESS
The Senate Report No. 96-848 to accompany S.1480 (the Superfund bill)
provides considerable insight into the intent of the Senate. "The range of
problems explored by the Committee went beyond waste disposal. Senator
Stafford addressed these in his opening remarks at the first hearing on March
18, 1979.
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Mr. Chairman, it is important to emphasize, I think, at the outset that
these hearings deal with more than just the problem of abandoned hazard-
ous waste sites. The orphaned site problem is important, and it is
justly receiving a great deal of attention. Mot only are water supplies
being contaminated, but untold number of innocent persons are exposed to
extremely toxic and hazardous chemicals. Some places, such as Love
Canal, have become environmental ghettos. But these hearings are to
inquire into the universal problems caused by the release of toxics into
the environment.
If these hearings were to deal only with the Love Canal or Toone, Tenn.,
we would be neglecting the radium sites in Denver. And if we were to
deal with the Denver sites as well, we would still be neglecting PCBs in
the Hudson River and PBBs in Michigan." (p.10)
These opening comments clarify the breadth of problems that the Senate
intended to solve. In addition to purely chemical hazards, the radium sites
in Denver are mentioned, implying that the intention is to address the haz-
ards associated with radionuclides.
The Senate Committee Report contains an extensive discussion of the
definition of hazardous substance and of reportable quantity (pp. 24-30).
This discussion points out "two basic mechanisms for substances to be desig-
nated as hazardous ... The first under section 2(b)(13)(A) through (E) is
through the operation of the statute itself" [This section became section
101(14)(A) through (F) in the statute]. The discussion goes on to list all
the 297 hazardous substances promulgated under section 311 of the Clean Water
Act and names the six hazardous air pollutants under section 112 of the Clean
Air Act (arsenic was designated a hazardous air pollutant on June 5, 1980 in
45FR37886). With respect to hazardous wastes, the Committee Report states:
Any material which is listed as a hazardous waste under section 3001
(including listed process wastes) or identified as a hazardous waste
pursuant to the characteristics published under section 3001 is a haz-
ardous substance uhder S. 1480.
At the present time the Environmental Protection Agency has promulgated
rules providing for the identification and listing of hazardous waste at
40 CFR Part 261 (45 FR 33119, May 19, 1980). These regulations must be
referred to to determine the hazardous wastes and their constituents
which are hazardous substances for purposes of S. 1480. Any material
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listed as a hazardous waste or hazardous constituent is a hazardous
substance for the purpose of S. 1480 regardless of whether it is a
waste.
This last sentence appears to require that all hazardous wastes and hazardous
constituents (Appendix VIII) listed in 40CFR261 be designated as hazardous
substances whether or not they are wastes. The Senate committee report goes
on:
The second basic mechanism for designating hazardous substances ... is
the addition of substances just for the purposes of this bill ... [Sec-
tion 102] authorizes the President to designate as hazardous substances
those compounds, elements, mixtures, and solutions which may present
substantial danger to public health and welfare and the environment.
This provision essentially authorizes the President to augment the
existing lists of hazardous substances derived from existing statutes.
The language of this provision has a lower threshold for designation
than that currently in place in section 311(b)(2) of the Clean Water
Act. This is intended to afford the President broad discretion in
designating substances which may adversely affect public health or the
environment.
Executive Order 12316 has delegated to the Administrator of the EPA the
Presidential authority mentioned in the paragraph above.
In connection with the reportable quantities, the Senate Committee
Report comments that [Section 102]
also authorizes the President to establish for each additional hazardous
substance so designated a single quantity which, if released, discharged,
or disposed of, must be reported ... This does not in any way imply or
require that such quantities be determined for any other hazardous sub-
stances.
The intention is to permit, but not necessarily to require, that the
second mechanism for designation actually be invoked or that new reportable
quantities be assigned.
SUMMARY
The primary objective of this study is to provide the decision-makers
with the technical information upon which to base a choice among possible
alternatives, including ways of maximizing the net social benefit as required
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by Executive Order 12291. The regulatory impact analysis is addressed in a
companion report to be submitted by ICF, Incorporated.
The major thrust of the study on development of a candidate list for
designation and hazardous substances and on strategies for RQ assignment
appears in sections 5 and 6, respectively. A detailed description of those
radionuclides to be included in Superfund, a possible mechanism for notifica-
tion of radionuclide releases and of various strategies for RQ assignment
appear in Section 7.
An important historical item in this review is the recognition that
aquatic toxicity, used to develop the RQs that appear in 40CFR117, refers not
to human toxicity, but fresh- and salt-water animal toxicity such as the
fathead minnow and brine shrimp. Accordingly, aquatic toxicity is considered
as a public welfare factor rather than a public health factor when used in the
rating and ranking systems discussed in Sections 5 and 6.
Possible approaches to the designation of hazardous substances are con-
sidered along with advantages and disadvantages of each. Using the EPA
Chemical Activities Status Report as one major starting point, a number of
screening steps are taken to reduce the 4100 compounds to 1085 compounds that
are candidates for designation, since they are already regulated pursuant to
other statutes. Along the way, the Department of Transportation Hazardous
Materials List (4-9CFR172.101 and .102) and the International Agency for
Research on Cancer List of Carcinogens are also incorporated into the screen-
ing procedure. The final candidate list consists of 917 substances (including
the specific and nonspecific F and K wastes from RCRA) and appears in Appendix
B, where the legislative authority for each compound regulated is indicated
explicitly.
The history of developing RQs for hazardous substances pursuant to the
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Clean Water Act includes many steps in which the quantity was linked to the
degree of harm it could cause because the language in the Act (until amended
on October 14, 1978) required this link. Because of this history, it is felt
that any further designation of hazardous substances and/or assignment of RQs
will be greatly strengthened by building upon the earlier experience.
Accordingly, although Superfund permits assigning RQs based primarily on
administrative convenience and practicality (i.e., by considering only the
information necessary to ensure that the appropriate response powers pursuant
to CERCLA Section 104 could be activated in a manageable fashion), other
alternative approaches to assigning RQs are also considered. For each
approach, advantages and disadvantages are examined. The approach developed
in most detail is that referred to as Hazard Index, a technique for calcu-
lating a single numerical value from a variety of criteria. The Hazard Index
was applied to a typical set of already designated 27 hazardous substances.
Various ways of combining the hazard criteria in the Hazard Index resulted in
different numerical values, and they, in turn, produced different rankings of
the representative hazardous substances. The particular rankings selected
for RQ development may be based on toxicity alone, or may include environ-
mental factors. A comparison of the rankings is an important result reported
herein.
Radionuclides and facilities that appear to come under Superfund juris-
diction are described. A possible notification-of-release procedure that
employs the in-place mechanisms to a large extent is described. A method for
assignment of RQs for radionuclides is developed. It should be noted that
because of their characteristics the expected RQ for many (if not all) radio-
nuclides (in radioactivity units) may have a weight much smaller than one
pound.
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The Chemical Information System, CIS, data base was used to generate
information on many of the compounds of interest and to assist in the screen-
ing process during the preparation of the candidate hazardous substance list.
It is also expected that the CIS will be useful to provide a retrievable com-
puterized storage for the CERCLA-specific information being generated under
this program.
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SECTION 2
ISSUES
ISSUES IN THE DESIGNATION PROCESS
The strategy for designation described in this report raises several
issues which need addressing.
1. The first issue is the designation of the hazardous waste which when
tested according to procedures listed in 40CFR261, Subpart C, for
Ignitability, Corrosivity, Reactivity, and Toxicity fall into the
classification of hazard, the so-called ICRT wastes, or those which
are identified as the D series. These wastes are not identified
with any specific manufacturing process and if when tested have one
or more of the charcteristics of ICRT fall under the RCRA regula-
tions. This category of hazardous wastes contains essentially an
unlimited number of hazardous substances which cannot be identified
for designation. It might be possible to include in the designation
a category of hazardous substances which includes all wastes which
are positive to one or more of the ICRT tests. If this 1s done then
a reportable quantity for that category must be established (see
Section 6). Alternatively, it might be practical not to designate
these wastes, and rely upon the wastes as "pollutants and contami-
nants." By this strategy, the Government could respond if they knew
that a release could occur. This has the advantage that an RQ need
not be established for any of the ICRT wastes, but has the dis-
advantage that a release of the waste need not be reported. An
economic evaluation of the benefits of designating or not designa-
ting the ICRT wastes should be determined before a final recom-
mendation is made.
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2. We have used as a gate an LD^q or LD-jQ for oral toxicity of 500
mg/kg. This is the "one-swallow" lethal dose for a 15 kg (33 lb)
child. All substances having this toxicity or greater (i.e., an
LD^q value of 500 mg/kg or lower) were retained on the list.* One
can argue that this is too restrictive a toxicity limit, and should
be lowered to 50 mg/kg which is the DOT limit for "Poison, Class B."
We have elected to follow a worst case scenario because if there
were a release the probability of a child ingesting the released
substance is more likely than a mature adult doing so, since the
child would have less concern for poisons than an adult. We would,
of course, be pleased to consider other criteria in establishing an
oral toxicity limit.
3. We included on the regulated list all the substances listed pursuant
to the Safe Drinking Water Act (SDWA) and the Federal Insecticide
Fungicide and Rodenticide Act (FIFRA), even though these acts are
not specifically mentioned in CERCLA Section 101(14). The reason
these were included is that we view the regulations resulting from
CERCLA to be the comprehensive definition of hazardous materials,
regardless of environmental medium. It would seem to be technically
contradictory to have a substance listed as hazardous in an EPA
regulation pursuant to SDWA and FIFRA, and not a hazardous substance
pursuant to CERCLA. We further would recommend that as the regu-
lations of SDWA and FIFRA are amended to include other substances,
that the designation of substances in the regulations of CERCLA be
* Note: The lower the numerical LDcq value, the greater the toxicity, i.e.,
the smaller the amount needed to proauce a toxic effect, the more poisonous
it is considered to be.
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amended accordingly, notwithstanding the fact that lists in SDWA
and FIFRA are regulated for entirely different reasons than the
list of CERCLA.
However, it can also be argued that FIFRA and SDWA were excluded
from CERCLA Section 101(14) by intent. The issue is one of
whether CERCLA, if it is indeed to be the inclusive act for all
substances regardless of medium, is also to encompass the materi-
als regulated in all prior acts, whether specifically mentioned in
Section 101(14) or not.
4. We have used annual production to establish lists of varying pri-
ority. However, it must be remembered that in the regulation
promulgated pursuant to 311 of CWA (40CFR116) production level was
one of the criteria used to decide whether materials were listed
or not. The 311 regulation did not apply to multimedia as the
CERCLA regulation, but it can still be argued that a production
level criterion should be applied as a measure of risk of expo-
sure. We welcome a dialog on this issue since the use of the
10,000,000 lb. production quantity would eliminate all but 275
additional substances from the listings. Perhaps all materials
given fn Appendices C and D should be subjected to the HI (Hazard
Index) test and the rankings of those substances compared with
those of legislated substances. By this procedure it would be
possible to at least compare the degree of hazard.
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ISSUES IN THE RQ ASSIGNMENT PROCESS
1. Achieving consensus among the various interested groups on a
mutually acceptable approach to RQ assignment will require consid-
erable compromise. Some groups may favor a rationale that empha-
sizes potential hazards and tends to produce low RQs, while others
may prefer a rationale that tends in the opposite direction.
2. After acceptance of a particular rationale is achieved, details of
the method for assigning RQs will need to be worked out. For
example, if the Hazard Index (HI) is chosen as the preferred
rationale, the details of the factors to be considered, the rating
scales and the weighting factors will have to be established, and
finally the preferred relation between HI and RQ will need to be
selected. (Some of the possible alternatives are described in this
report.)
The statutory text of CERCLA allows, but does not require, the determin-
ation of a single RQ without regard to the medium into which the hazardous
substance may be released. Upon analysis of the legislative history, how-
ever, it seems reasonably clear that Congress intended that the RQ be a
single, multimedia value determined without regard to the circumstances sur-
rounding the release. As stated in the legislative history documented in the
Senate Report of the Committee on Environment and Public Works that accom-
panied S 1480:
...A single quantity is to be determined for each hazardous substance,
and this single quantity requires notification upon release into any
environmental medium. It would virtually be impossible to determine a
single quantity applicable to al' media while at the same time linking
such quantity to any subjective concept of harm. (Emphasis added.)
The legislative history further states that:
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...It is essential that such quantities be relatively simple for
those subject to notification requirements to understand and comply
with...and that Administrative feasibility and practicality should
be primary factors.
In light of Congressional intent and in the spirit of the present Adminis-
tration's regulatory relief philosophy, reportable quantities which vary
depending on environmental medium are not necessary and should not be
assigned.
ISSUES WITH RESPECT TO RADIONUCLIDES
1. Since radionuclides are regulated under other Acts than CERCLA and
by other agencies than the EPA, coordination will be essential
both to avoid duplication of effort and prevent the absence of
response when release occurs,
2. The Nuclear Regulatory Commission noted important deficiencies in
existing emergency response plans for fuel fabrication facilities.
For example, the plans failed to describe adequately the means for
measurement and assessment of accidental releases of radioactive
materials and arrangements for prompt notification of Federal,
State, and local Government agencies (46 FR 29712). This illus-
trates the existence of problems in the detection and assessment
of accidental releases of radionulcides even for professionals.
3. The responsibility for reporting the release of a quantity of a
designated hazardous substance in excess of its RQ implies that
the "operators must have knowledge that such a release has occurred.
The circumstances under which it 1s believed that such knowledge
exists may not always be clear. For example, when it is known
that radionuclides are released, but the particular radionuclide
released is not known, the quantity released is not easily
determined.
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SECTION 3
RECOMMENDATIONS
The next major steps to be taken to provide the technical basis for
issuing regulations under Superfund Sections 102 and 103 (a and b) are:
1. Provide a "quick-fix" basis for adjusting RQs of the CERCLA Sec-
tion 101(14) materials (both upward and downward) to emphasize the
importance of human toxicity, including the specific and nonspeci-
fic wastes (F and K lists) and the ICRT wastes.
2. Devise multimedia strategies for RQs of all hazardous substances.
3. Complete the basis for designation and RQ assignment for radio-
nuclides.
4. When agreement on rationale is reached, calculate (or assign) RQs
to all designated hazardous substances.
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SECTION 4
HISTORY OF DESIGNATION AND RQ ASSIGNMENT
Since the starting point for designation of hazardous substances and for
the assignment of reportable quantities under Superfund is the analogous
development under Section 311 of the Clean Water Act, that development is
reviewed in this section.
DEVELOPMENT OF 40CFR116 AND 117
Legislative authority for these regulations resided originally in Section
311(b)(4) of the FWPCA Amendments of 1972 (PL 92-500) which states:
(4) The President shall by regulation to be issued as soon as possible
after the date of enactment of this paragraph, determine for the purposes
of this section those quantities of oil and any hazardous substance the
discharge of which, at such times, locations, circumstances, and condi-
tions, will be harmful to the public health or welfare of the United
States including, but not limited to, fish, shellfish, wildlife, and
public and private property, shorelines, and beaches except that in the
case of the discharge of oil into or upon the waters of the contiguous
zone, only those discharges which threaten the fishery resources of the
contiguous zone or threaten to pollute or contribute to the pollution of
the territory or the territorial sea of the United States may be deter-
mined to be harmful.
On August 3, 1973, Executive Order 11735 delegated the authority of the
President under Section 311(b)(4) to the Administrator of the EPA.
An ANPRM was published on August 22, 1974 (39FR30466-71) for the desig-
nation of hazardous substances and the determination of their removability.
When the NPRM was issued, on December 30, 1975 (40FR59960-60017), 59 candidate
substances were deleted\from the earlier 11st because of low spill potential.
The remaining substances proposed for designation as hazardous were so listed
because of the criteria quoted below:
In summary, the proposed selection criteria for hazardous substances
are as follows: any element, compound, or mixture thereof, possesses
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sufficient danger potential to be designated as a hazardous substance,
if it is lethal to:
(a) One-half of a test population of aquatic animals in 96 hours or
less at a concentration of 500 milligrams per liter (mg/1) or
less; or
(b) One-half of a test population of animals in 14 days or less when
administered as a single oral dose equal to or less than 50 milli-
grams per kilogram (mg/kg) of body weight; or
(c) One-half of a test population of animals in 14 days or less when
dermally exposed to an amount equal to or less than 200 mg/kg of
body weight for 24 hours; or
(d) One-half of a test population of animals in 14 days or less when
exposed to a vapor concentration equal to or less than 20 cubic
centimeters per cubic meter (volume/volume) in air for 1 hour; or
(e) Aquatic flora as measured by a 50% decrease in cell count, biomass,
or photosynthetic ability in 14 days or less at concentrations
equal to or less than 100 milligrams per liter (mg/T).
In addition to meeting one or more of the above acute lethality criteria,
a candidate substance must have a reasonable potential for beinq dis-
charged. Factors considered in making this evaluation include (1) past
spill history, (2) production quantity, (3) use and distribution patterns,
and (4) value of the substance.
Substances were proposed for designation as hazardous on the basis of
the following toxicological properties:
1.
Aquatic animal toxicity
2.
Oral mammalian toxicity
3.
Dermal mammalian toxicity
4.
Inhalation mammalian toxicity
5.
Phytotoxicity
The method proposed for determining harmful quantities was based on a
modification of the hazardous material classification system developed by the
Intergovernmental Maritime Consultative Organization (IMC0) in conjunction
with acute toxicity data. Substances were divided into four categories on
the basis of relative hazard to the environment and the smallest common com-
mercial container size (one pound/454 grams) was defined as the harmful
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quantity for all members of the most highly toxic categories (other categor-
ies were thereafter assigned harmful quantities on a proportional basis). The
EPA chose to use this methodology after detailed consideration of alternative
methods suggested by Battelle Northwest (EPA 440/9-75-005) were rejected
because of "excessive complexity; incomplete or conflicting data; difficulty
visualized in implementation." (40 FR 59985) In determining harmful quanti-
ties, the designated hazardous substances were classified into four categories
depending on its LC5Q toward the aquatic test animals in a 96-hour test.
These categories are tabulated below (40FR59989).
EPA CATEGORIES FOR HARMFUL QUANTITY DETERMINATION
Representative Harmful Quantity
Category Range lb (kg)
A LC50* < 1 ppm 1.0 (0.454)
B 1 ppm £ LC50 <10 ppm 10 (4.54)
C 10 ppm <_ LC50 < 100 ppm) 100 (45.4)
D** 100 ppm<£ LC50 < 500 ppm 500 (227)
* LC50 means that concentration of material which is lethal to one-half
of the test population of aquatic animals upon continuous exposure for
96 hours or less.
** The basic IMCO criterion for Category D aquatic toxicity is 96-hr.
LC50 values of 100-1000 ppm. The selection criteria for materials
proposed in 40 CFR Part 116 eliminated any material with a 96-hr. LC50 in
excess of 500 ppm. Thus, the representative toxicity range for Category
D proposed here has been changed to 100-500 ppm.
The representative range means that substances in Category A have LC50
values of less than 1 ppm, Category B substances have LC50 values of 1
ppm or greater up to 10 ppm, Category C substances have LC50 values of 10
ppm or greater up to 100 ppm, and Category D substances have LC50 vvalues
of 100 ppm up to ar\d including 500 ppm.
On March 13, 1978, EPA promulgated Part 116 as a modification of an
international categorization system (43FR10474-10488). The toxicological
properties were modified to consider only the aquatic toxicity of the sub-
stances. The effect of this modification on the final designation 1s that
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toxicological effects other than aquatic are not considered in the priority
list of hazardous substances. This decision was based upon the problems in
the initial system, which required "subjective judgments that could lead to
alternative decisions." (43 FR 10475)
Toxicological data for individual substances used in determining harmful
quantities were derived from the compendium of information fact sheets en-
titled Hazardous Substances Fact Sheets, 1977, which are available from the
Environmental Protection Agency. In addition, other primary sources of data
were: Water Quality Criteria Federal Water Pollution Control Administration,
1968, Water Quality Criteria 1972, EPA, March 1973, and Quality Criteria for
Water, EPA 440/9-76-023, July 1976.
Some thirty-odd substances that appeared on the proposed list were not
included on the list as promulgated for various reasons. CAS registry numbers
were included in the promulgated list of Part 116.
Harmful quantity categories (40CFR118) were modified to adjust the in-
equity of the factor of 10 difference between Categories D and C, C and B, and
B and A, while permitting Category A to range over more than three orders of
magnitude. Therefore, another category was added, X, to encompass substances
with IC5Q values of less than 0.1 mg/1 and designated the basic unit of 1
pound as the harmful quantity. The designated harmful quantities for Cate-
gories A, B, C, and D were changed to 10, 100, 1000, and 5000 pounds, respec-
tively. The modified table is shown below (with obvious typographical errors
corrected).
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Category
X
Toxicity Range
LC50 <0.1 mg/1
Harmful Quantity
lb (kg)
1.0 (0.454)
A
B
C
D
0.1 mg/1
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a discharge is not dependent on a show of actual harm; the degree of harm and
other relevant factors are instead examined in assessing civil penalties. The
final rule was published August 29, 1979, and took effect a month later with
essentially the same RQs as in the re-proposed Part 117.
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SECTION 5
DESIGNATION OF HAZARDOUS SUBSTANCES
INTRODUCTION
The ultimate objective of this task is to provide a candidate list of
hazardous substances which, when issued as part of the final promulgated
regulation, will provide the basis for a notification system with benefits
outweighing costs.
This section covers the needs for developing a.list of hazardous
substances to be designated, the strategies for developing the list, the
source of the starting list, and finally the list itself.
RATIONALE FOR A LIST
CERCLA Section 102(a) states:
The Administrator shall promulgate and revise as may be appropriate,
regulations designating as hazardous substances, in addition to
those referred to in Section 101(14) of this title, such elements,
compounds, mixtures, solutions, and substances which, when released
into the environment, may present substantial danger to the public
health or welfare or the environment ...
The operative language clearly permits, but does not require, that sub-
stances be designated as hazardous beyond those defined in Section 101(14).
Once a substance has been designated, the release of some minimum quantity
to the environment will trigger notification of the National Response
Center (NRC), and if response is necessary, the affected state or Federal
agency can react to assure protection of human health and welfare by
requiring the releaser to clean up. If the releaser does not clean up,
and the substance is on the list and has been released in quantities
5-1
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above the designated quantity, the appropriate agency is then authorized
to clean it up with funds through CERCLA, Section 104 or via the mechanism
of Section 311 of the Clean Water Act. However, that same section author-
izes the President to clean up (or react to a threat) any "pollutant or
contaminant which presents imminent and substantial danger to the public
health or welfare." The releaser, however, is not required to report a
release of a pollutant or contaminant not on the list of hazardous substances.
Accordingly, the list must include all materials that constitute a substantial
hazard when released, or the government may not become aware of incidents
and problems with releases of such materials in a timely manner.
The purpose, therefore, for having a 1 list, is to provide both the
government and the regulated community with guidelines for the identification
of such hazardous substances which will require a report to the National
Response Center upon their release.
STRATEGIES FOR DESIGNATION
Although CERCLA provides EPA broad discretionary authority for
designation of hazardous substances, logic dictates that the list must be
balanced. On one hand, a complete list of all substances likely to be
manufactured or transported would compromise the value of the system
because the National Response Center (NRC) would need to divert resources
to processing an excessive number of reports, most of which would not
require response action. On the other hand* an inadequate list might
result in failure of the appropriate agency to respond when necessary.
Thus a need exists for developing balanced and meaningful criteria for
those substances to be designated.
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The designation of a substance as hazardous depends primarily upon
the effect of the properties of the substance on human health and welfare
and on the environment. However, these effects should be such that they
present a danger sufficient enough to require a response action. That is,
some limiting value must be placed on any deleterious property that is
used as a solution criterion.
With these concepts in mind, a number of strategies for preparing
the list of candidates for designation can be considered, as given below.
Strategy 1. Retain only those substances listed pursuant to the
Regulations from the Acts listed in Section 101(14).
If this is used, no further designation is necessary. These sub-
stances are those appearing in the forthcoming Interpretative Notice.
The advantages of this strategy are obvious: (a) no further action in
the designation process is required, (b) the regulated community need not
change any of its present procedures, since they are already responsive
under current regulations, and (c) the list would keep pace with the
changes in the regulations pursuant to the CERCLA Section 101(14) Acts,
since any change in those regulations automatically triggers the same
change in the CERCLA regulations, and (d) such a list meets the minimum
requirement of the Act.
The disadvantages are: (a) many hazardous substances are not present
on any of the lists, since the largest list (40CFR116 pursuant to Section 311
of the Clean Water Act) was derived based on aquatic toxicity (not human
toxicity) and omits many carcinogenic, flammable, explosive, corrosive,
and reactive materials, (b) the legislated list does not consider hazardous
substances considered from all other Acts, for instance, regulations
pursuant to the Safe Drinking Water Act, the Federal Insecticide, Fungicide,
5-3
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and Rodenticide Act, (c) the list does not include all the materials the
Department of Transportation has designated as hazardous (pursuant to the
Hazardous Materials Transportation Act), nor all the known or suspected
carcinogens.
Strategy 2. Use a comprehensive list such as that of the 55,000 chemicals
listed in the Toxic Substances Control Act Chemical Substance inventory
The advantages are: (a) essentially everything that is hazardous
would be included, (b) the list is in existence and no further evaluation
need be made, (c) the list meets the requirement of CERCLA. The dis-
advantages are obvious: (a) the list is intended to be used as an
inventory, and the degree of hazard of many of the listed materials is
either nil or so low as to be essentially non-existent, (b) a severe
economic impact would be placed on the regulated community since this
would present a substantial change in their current practices, and
(c) the National Response Center would be flooded with telephone calls,
compromising the intent and effectiveness of the system.
Strategy 3. Assign a Blue Ribbon Committee to select the new substances
to be designated
The advantages are: (a) a select group of experts would judge what
goes on the list, and thus each substance would then have been considered
by an expert impartial committee, making the validity of the list
incontrovertible, (b) a multiplicity of technical and, perhaps, socio-
logical views would have been aired in arriving at a list. The disadvantages
are: (a) reaching on agreement of a list by independent experts may
require an extensive period of time, (b) technical criteria should be
provided to the committee in order to arrive at a common jumping off
point and these criteria might be difficult for the committee to agree
upon.
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Strategy 4. Establish a Hazard Index Rating and rank all candidate
hazardous substances by its degree of harm.
A hazard index (HI) is a method to quantify value judgments about a
substance's relative environmental impact or potential for causing harm.
It provides a direct way to consider basic data clearly related to hazard,
and allows a rank assessment based on degree of hazard. An in-depth
discussion of the HI is given in Section 6. The HI discussion is in the
section on strategies for Reportable Quantities since its use, it turns
out, is more applicable to reportable quantities requirements than to
designations. However, there are some advantages to the use of HI for
designations, such as: (a) it provides a quantitative measure of the
hazard of a substance, (b) it takes advantage of all available basic
data, and (c) it provides a ranking, thus enabling a cutoff point to
satisfy a selected definition of hazard. There are also many disadvantages
for its use in designation: (a) data gaps exist which could lead to
omission of hazardous substances, (b) HI (as developed) does not consider
economic factors, and (c) it may be difficult to have HI accepted by the
interested community as the sole criterion for designation.
Strategy 5. Establish a set of "gates" based upon criteria related to
hazard, and apply these to a master list or list of substances.
This strategy contemplates starting off with a major list of substances,
and adding or deleting substances depending upon the effects on human health
or the environment. The advantages of this strategy are: (a) it allows for
all technical considerations to be given to a substance, (b) it permits other
considerations as welU such as economics, quantity of production, likelihood
of release, etc., and (c) it is flexible by permitting a larger or smaller
list depending on.the limits placed on the criteria. The disadvantages are:
(a) the lower or upper criteria of hazard must be established and all
interested parties may not agree on the value selected.
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Selection of Strategy
Based on the above discussion, it turns out that no one strategy is
100% perfect, and that a combination of strategies gets us to the major
goal of providing a list of designated hazardous substances which when
promulgated will provide more benefits than they will cost. Accordingly,
for the purposes of developing a candidate list, we have relied on Strategy 5,
recognizing, of course, that CERCLA provides the Administrator the use of
broad discretion in revising such lists. At a later date we will include
the use of HI as a check and balance of the final candidate list, when
the fact sheets (as described in Section 8) have been completed. We have
selected this combined strategy since it provides the best compromise of
all the listed strategies by using available technical data, clearly
identified criteria, and consideration of all other Acts not listed in
Section 101(14). This strategy also provides a technical baseline from
which any other interested party could perform a further screening for
deletion or addition to the final candidate list.
STEPS IN THE DESIGNATION PROCESS
The following steps are necessary to arrive at a final candidate list.
1. Select listing categories.
An initial restriction is applied to limit the designation
process to individual chemical compounds and to wastes. In
particular, radionuclides are addressed separately (see
Section 7).
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2. Establish a Master List
This master list must have all the substances which should be con-
sidered for designation. We have selected as the master list the
EPA's Chemical Activity Status Report, EPA 560/13-80-040, because it
provides the listing of all substances which have already been
designated under various Acts and also those which are being con-
sidered for further regulation.
3. Establish first-level screening criteria
These criteria are the "gates" which will be used for the
first screening.
4. Perform the first-level screening.based on the criteria.
5. Add to the list materials from the DOT tables of Hazardous Materials
and from the International Agency for Research on Cancer list of
known or suspected carcinogens.
6. Cross-check with the original regulation listings to ensure
that all legislated substances as required by CERCLA Sec-
tion 101(14) are still on the list, and that no materials not
so legislated have been inadvertently identified as such.
7. Split the list into two parts: one including all the materials
that are currently regulated by the EPA under various acts
(the regulated list), the other including all materials not
so regulated (the supplemental list).
8. Complete the regulated list by adding the specific and nonr
specific RCR^ wastes ("the f and K lists).
9. Prioritize the supplemental list according to annual production
quantities.
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This procedure is shown graphically in Figure 5-1.
Future steps to be taken include reviewing the list with the interested
community and considering their comments. The economic impact of the list on
the regulated community will also be evaluated. Benefits derived from adding
or deleting newly designated substances will be considered.
The following discussion provides details of the steps in the
designation process.
Step 1. Select the Listing Categories
The primary decision was that of electing to address radionuclides
as a totally separate and distinct subject area. The technical and
regulatory basis for this decision is covered in detail in Section 7.
Step 2 - Establish a Master List
The EPA's Office of Pesticides and Toxic Substances has been compiling
information on all the chemicals in which several program offices within the
EPA have an interest. They recently issued the Chemical Activities Status
Report (second edition), EPA 560/13-80-040 a & b, which lists all the
chemicals in this data base and provides such information as the technical
basis for listing, legislative mandate, or nonlegislative reason for
listing. In addition, the information on each chemical is also accessible
through a machine-searchable data base, EPACASR-2.
Using the EPACASR as the starting point for the comprehensive list
assures that we are consistent with all of the EPA's interests. The
introduction to this report describes the sources of the listings as follows:
5-8
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EPACASR-2 Data
Base Sorting
Priority 1: Production Level 10,000,000 lb/yr. or greater
-^Priority 2: Production Level 1,000,000-10,000,000 lb/yr.
-^•Priority 3: Production Level Less Than 1,000,000 lb/yr.
CASR List
Establish
Priorities
Intermediate
List #1
Add RCRA Wastes
Intermediate
List n
Intermediate
List #3
Crosscheck Against
Regulated Lists
Select Listing
Categories
IARC List of Carcinogens
Chemical Activities
Status Report
Regulated
Candidate List
Supplemental Candidate
List
DOT Hazardous Materials
Tables (49'CFR 172.101
and 172.102)
Apply Initial
Selection Criteria
(Legal, Hazard, &
Urgency Factors)
Figure 5-1. Development of Comprehensive Hazardous Substances
Candidate List
5-9
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Clean Air Act
o Criteria Pollutants designated under Section 109 of the Act
(40CFR50).
o Chemicals addressed under new source performance standards
(Section 111) (40CFR60)
o National Emission Standards for Hazardous Air Pollutants (Section
112) (40CFR61)
o Assessments in Progress, obtained from the Office of the DAA,
Air Quality Planning and Standards
Clean Water Act
o OHM-TADS (Oil and Hazardous Materials Technical Assistance Data),
obtained from Oil and Special Materials Control Division; kept under
authority of Section 311, and used to support the National Contin-
gency Plan (spill response)
o Hazardous Spill Regulations. Promulgated or proposed under Section
311 of the Act, 40CFR116.
o Toxic Substance Effluent Regulations proposed and promulgated under
Section 307(a) of the Act, and obtained from 40CFR129, and the
Criteria and Standards Division,
o Water Quality Criteria proposed under Section 304 of the Act.
Included in consent decree, and obtained from the FR Notices of
March 18, July 28, and October 1, 1979.
Note.: Effluent Guidelines were not included because they are not
chemical-specific; however, controlling certain gross para-
meters will afford an unspecified degree of reduction in
certain toxic chemicals.
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Federal Insecticide, Fungicide, and Rodenticide Act
o Major cancellations and suspensions, obtained from a compilation
prepared by the Pesticide Enforcement Branch. This includes partial
as well as total cancellation (e.g., the most hazardous uses may be
cancelled, and other uses permitted with or without restrictions,
o Rebuttable Presumption Against Registration (RPAR) issued under the
reregistrati on authorities of Section 6 is the normal first step
toward cancelling or modifying pesticide registrations, although
RPAR may not result in such action,
o Preregulatory assessments address those substances being considered
for RPAR.
o Restricted use pesticides are those that must be applied only by
certified applicators.
Resource Conservation and Recovery Act
o Chemicals designated as hazardous under Section 3001, obtained
from 40CFR261.
Safe Drinking Water Act
o Interim Primary Drinking Water Regulations promulgated under
40CFR141.
o Interim Secondary Drinking Water Regulations, obtained from the FR
Notice of March 31, 1977.
o Indicators of Industrial Pollution used to determine need to treat
water supplies, from the FR Notice of February 9, 1978.
o Chemicals und^r review'for possible regulation, from ODW.
Toxic Substances Control Act
o Testing recommendations by the Interagency Testing Committee (ITC),
under Section 4(e) authority. (FR Notices)
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o Preregulatory Assessments: Chemical Hazard Identification Profiles
(CHIPs) and Phase I reviews, as obtained from the Office of Toxic
Substances (CHIPs are summary reviews of readily available litera-
ture which present information characterization, uses, and effects
of chemicals. Phase I reviews involve detailed study of secondary
information sources),
o Chemicals regulated under Section 6, and proposed for reporting
rules under Section 8(a).
Other
o Office of Research and Development/Carcinogen Assessment Group
reviews to support assessment under the foregoing statutes. Listing
supplied by CAG.
o ORD projects, from a search of the Office of Research and Develop-
ment Information System and communications with project officers.
Details of the CASR List
The CASR list is a computer print-out of each of the materials
covered in the Chemical Activities Status Report, with each material
listed only once and using the chemical nomenclature as given in the 9th
Cumulative Index of the Chemical Abstracts Service. It contains approxi-
mately 4100 entires, and was provided by Eleanor Merrick of the EPA's
Toxic Integration Staff, who is in charge of the CASR project.* In
addition, Ms. Merrick also provided printouts showing which entries on
the list were there because they were already covered in promulgated
regulations, which were there because they were being listed in proposed
or in-development regulations, and which were merely "of interest."
*It should be noted that the alphabetical index published in the hard copy of
Chemical Activities Status Report was not a satisfactory starting list for
our purposes because it contains synonyms as well as the primary name, and is
approximately 13,000 entries in length.
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The CASR list is not absolutely alphabetical, since the data base
management program used in machine sorting the lists employs a combina-
tion of alphabetical and numerical fields to generate its final listings.
The program first assembles everything within a given alphabetical field,
then sorts numerically within that field, printing out low-numbered items
first, and finally printing unnumbered items in alphabetical sequence.
Thus the materials
Benzene
Benzene, bromo-
Benzene, 1,3-dichloro-
Benzene, 1,2-diethyl-
are listed by the CASR program in the following order:
Benzene, 1,2-diethyl-
Benzene, 1,3-dichloro-
Benzene
Benzene, bromo-
Despite this peculiarity, the CASR list proved to be easy to use, and served
as an excellent starting point in developing the final candidate list.
Step 3 - Establish and Apply First-Level Screening Criteria
The 4100 chemicals on the CASR list fall into three categories:
CAT 1: Those already listed in promulgated regulations (under CAA, CWA,
SDWA, TSCA, FIFRA, and RCRA)
CAT 2: Those listed in proposed or in-development regulations {primarily
under TSCA)
CAT 3: "Of Interest." That is, there is some associated EPA concern or
activity, but there is no urgent need for regulatory action.
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A set of "gates" was developed and applied as the first-level screening
of the CASR list. Gates are of two types: entry or retention gates, which
either keep things on the list or allow new substances to be added, and exit
gates which allow substances to drop off the list.
Retention Gates
1. All substances from the regulations pursuant to the Clean Air Act,
the Clean Water Act, Toxic Substance Control Act, and the Resource
Conservation and Recovery Act including the Hazardous Constituents
(Appendix VIII)
2. All substances from the regulations pursuant to the Safe Drinking
Water Act and the Federal Insecticide, Fungicide, and Rodenticide
Act
Thus all CAT 1 are retained.
3. Known or suspected carcinogens, as identified in the CASR listing
or in the Registry of the Toxic Effects of Chemical Substances
(RTECS)*
4. Materials hazardous to the health, for any of the following reasons:
a. An oral toxicity value (LD^g or LD-jQ) of less than 500 milli-
grams per kilogram of body weight or lower. This value is
derived from work on another Rockwell program, using a scenario
in which it is presumed that a small child (a "toddler") is
exposed to a toxic material under circumstances that would
allow him to take on good swallow of such a material.
This scenario was first discussed with personnel at Children's
Hospital in Los Angeles, California, who subsequently referred
* The Registry is a compendium maintained and published by the U.S. Department
of Health and Human Services. The latest hardcopy was issued in 1979. The
data is also accessible via the Chemical Information System, and this format
includes updated material updated in 1980-1981 (see Section 8, p. 8-6).
5-14
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us to one of the nation's foremost authorities on problems of
poisoning children, Dr. Howard Mossensen at the Nassau County
Medical Center in Long Island, New York. Dr. Mossensen agreed
that this scenario would be a reasonable one, and conservative
enough to provide a high degree of protection in the event of
such an exposure.
A good swallow by a small child amounts to about 4 to 4.5
cubic centimeters. For a toddler weighing 15 kilograms, this
works out to a dose of 300 milligrams per kilogram of body
weight, assuming an ingested material of unit density. To
provide for a safety margin (allowing for lower body weights
and/or higher density materials), a limiting toxicity value of
500 milligrams per kilogram of body weight* was chosen. For
reference purposes, aspirin, a notorious toxicant for chil-
dren, has a recorded low lethal dose of 81 milligrams per
kilogram, sodium chloride (common salt), a recorded low lethal
dose of 500 milligrams per kilogram.
It is of interest to note that applying this same series
of calculations to the "standard man" (70 kilogram body weight,
swallow volume of 21 cubic centimeters) also yields a value of
500 milligrams per kilogram of body weight for the limiting
toxicity value. However, adults are much less likely to
ingest foreign materials than are children.
Data Yor assessing toxicity were taken from RTECS for the
most part, with occasional reference to The Merck Index, 9th
Edition. Whenever available, the low lethal dose (LDlo) for
humans was used to make the decision on a particular compound.
* Note: The higher this toxicity value, the less toxic is the material.
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If this was not available, the LDgg for any mammalian species
was used. It is recognized, of course, that data from other
mammals, while it affords a reasonable approximation of human
response, is not an absol-ute. However, it must also be under-
stood that human toxicity data is derived largely from iso-
lated cases of accidental poisoning, and statistically valid
results from toxicity studies on larger human populations are
available in very, very, few cases indeed,
b. Other health effects: teratogenicity, mutagenicity, irritant
effect on the eyes, skin, or lungs, and evidence for bioaccu-
mulation. Again, RTECS was used as the primary source of
data, and evidence for one of the effects in any mammalian
species was considered sufficient reason for retaining a
chemical on the list.
5. Corrosives, as identified in the CASR list or in RTECS. Corrosive
is taken not only to mean the capability for attacking metal (e.g.,
RCRA regulation 40CFR261.22) but also in the health hazard sense of
"causing ulceration or necrosis to flash" (DOT definition).
6. Flammables, using either the DOT criteria as listed in the Hazard-
ous Materials Tables (49CFR171.101 and 171.102) and/or the National
Fire Protection Association (NFPA) ratings in their publication
Fire Protection Guide on Hazardous Materials.
In the DOT'S tables, the distinction between flammability and
combustibility was generally related to the chain length of the
material. This is particularly true of aliphatic compounds. For
instance, amyl acetate (pentyl acetate, 7 carbon atoms) is listed
as a flammable liquid, while ethyl butyl acetate (hexylacetate, 8
5-16
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carbon atoms) is listed as a combustible liquid. Thus, without
having to try and find numerical data on flash points, one can
quickly decide whether any compound in this class should be classed
as flammable or not simply by knowing its chain length.
The NFPA uses 5 categories to assess "susceptibility to burning"
as follows:
4 Very flammable gases or very volatile flammable liquids.
Shut off flow and keep cooling water streams on exposed
tanks or containers.
3 Materials which can be ignited under almost all normal
temperature "conditions. Water may be ineffective because
of low flash point.
2 Materials which must be moderately heated before ignition
will occur. Water spray may be used to extinguish the
fire because the material can be cooled below its flash
point.
1 Materials that must be preheated before ignition can
occur. Water may cause frothing if it gets below the
surface of the liquid and turns to steam. However, water
fog gently applied to the surface will cause a frothing
which will extinguish the fire.
0 Materials that will not burn
Falling into either Category 3 or 4 above was considered sufficient reason
for retaining a material\on the list.
7. Oxidizers and explosives
Exit Gates
1. Petroleum, petroleum fractions, and natural gas (methane) as man-
dated by CERLCA.
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2. Aliphatic species (hydrocarbons, esters, alcohols, amines, acids,
etc.), if:
(a) They were rated combustible, but not flammable, by DOT or the
National Fire Protection Association. As noted above, flam-
mability and combustibility can be related to chain length.
Thus, as in the example used above, any simple ester with a
chain length of eight carbon atoms or more would drop off the
list at this point. With respect to the NFPA rating system,
items on the 0-2 categories would drop off.
(b) They were nontoxic and noncorrosive
3. High Polymers. This term is an abbreviated form of "High Molecular
Weight Polymers," and is meant to designate those polymeric macro-
molecular species that are both solid and without detectable vapor
pressure at ambient temperature,
4. Sugars, polyols, glycols, and esters and ethers thereof. [1,2-
Propanediol was originally identified as an "Acute Hazardous Waste"
under the RCRA regulations (45FR33125, 19 May 1980), but was later
deleted (45FR78533, 25 November 1980)].
5. Nonregulated freons
6. Low-toxicity natural products (amino acids, etc.)
7. Medicinals
Step 4 - Complete the First-Level Screening
! - ¦-
As-a final step in the first-level screening, we applied what may be
called an "Urgency" factor. That is, we reviewed all CAT 3 chemicals (i.e.,
of interest), and unless they had been tagged with a specific hazard during
the prior technical review, they were eliminated from further consideration
at this point.
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This procedure eliminated many chemicals with relatively innocuous
properties, such as benzenemethanol (benzyl alcohol), sodium acetate, and
borax. However, it also eliminated a number of materials that are closely
related to others that remain on the list either because of prior regulatory
action or because the retention gates kept them there. For instance, 1,1-
dibromoethane drops off, and the reason is that the compound is a rarity (no
commercial production or use) and what little toxicity data are available on
the material do not indicate that it is hazardous.
During all of this procedure we relied heavily -on the Chemical Informa-
tion System to check nomenclature, to identify additional sources of informa-
tion, and in particular, to provide data on fcarcinogenicity and toxicity from
the RTECS (Registry of the Toxic Effects of Chemical Substances) data base.
At the end of this overall application of selection criteria, Inter-
mediate List #1 contained about 2600 entries.
Step 5 Addition of DOT and IARC Listings
The Department of Transporation publishes two lists, the Hazardous
materials Table (49CFR172.101) and Optional Hazardous Materials Table
(49CFR172.102). These tables show the restrictions, packaging standards, and
labelling requirements for about 2000 chemicals, with the "optional" table
more closely following the international conventions in such areas. From this
list were selected another 430 chemicals, on the following basis:
1. They were not already on the original CASR list.
2. They required the following labels:
Flammable (liquid or solid)
Oxidizer
Peroxide
Poison B
Corrosive
Dangerous When Wet
Spontaneously Combustible
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The International Agency for Research on Cancer has published a summary
list of 142 chemicals from its monographs 1-20 of those compounds that have
"sufficient evidence of carcinogenicity in experimental animals." Review of
these showed that 20 of them were not already on the original CASR list.
In reviewing these two lists and comparing them with the CASR listings,
the Chemical Information System was again our major tool, using the SANSS
(Structure and Nomenclature Search System) to obtain the CAS numbers, the 9th
Collective Index nomenclature, or simply to cross-check identities.
With these two additions, the result became Intermediate List #2, which
contained approximately 3100 entries.
Step 6 - Perform Listing Cross-check
Up to this point, we had relied entirely on the CASR generated listings
to identify materials from the various regulations. However, as a safeguard
we now cross-checked each entry against the actual regulation itself, to be
sure that no material designated in the regulations had been inadvertently
omitted, or that no material had been mistakenly identified as regulated when
it was not. At the same time, we reviewed and added to the list the various
isomers where the regulations spelled out "all isomers" and made sure that if
an isomer were identified by both a specific CAS number and a general CAS
number that both were entered.
Also, certain regulated substances, because they are not specific,
require that more than one entry be made on the list to be sure that all
possible variations of the compound be covered. For instance "Pyrethrins"
generates two entries and "Aflatoxins" generates twelve.
One material on the list, "Ferric Cyanide," from the RCRA Hazardous
Constituents list, remains somewhat of an enigma. Technically, there is no
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such compound as ferric cyanide if we take the strict approach that this
should be the name for a compound formulated as Fe(CN)g. However, checking
with the Chemical Abstract Service, we were told that "Iron Cyanide" is a
synonym for ferric ferricyanide, Fe[Fe((CN)g], and have accordingly identi-
fied "Ferric Cyanide" by the equivalent CAS registry number.
Intermediate List #3, after this cross check and after adding all appro-
priate isomers, contained about 3200 entries.
Step 7--Split the List
At this point, the list was separated into two parts: the regulated
list and the supplemental candidate list. The regulated list consists of 833
entries (including 25 PCB's listed by CAS registry number alone), all of
which are currently subject to specific regulations under one of the environ-
mental acts: FIFRA, RCRA, SDWA, CAA, CWA, and TSCA. Of these, 53 are not
mandated by CERCLA Section 101(14), since they derive from either FIFRA or
Appendix VIII of RCRA, and are not covered under any other act. These are as
follows:
FIFRA Only:
51317 Benzoic acid, 2,3,6-trichloro-
58366 lOH-Phenoxarsine, 10,10- oxybis
72560 Benzene, 1,1'(2,2-dichloroethy1idene)bis(4-ethyl)
78342 Phosphorodithioic acid, S.S'-l,4-dioxane-2,3-diyl
0,0,0',0'-tetraethyl ester
97187 Phenol, 2,2'-thiobis (4,6-dichloro)
115902 Phosphorothioic acid, 0,0-diethyl 0-[4-(methyl-sulfinyl)
phenyl] ester
118752 2,5-Cyclohexadiene-l,4-dione, 2,3,5,6-tetrachloro
750685 Urea, N'-(4-chlorophenyl)-N,N-dimethyl
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470906 Phosphoric acid, 2-chloro-l-(2,4-dichlorophenyl-
ethenyl diethyl ester
578949 Phenarsazine, 10-chloro-5,10 dihydro
944229 Phosphonodithioic acid, ethyl-, 0-ethyl, S-phenyl ester
1918021 2-Pyridinecarboxylic acid", 4-amino-3,5,6-trichloro-
2385855 1,3,4-Methano-lH-cyclobuta[c,d]pentalene, 1,1a,2,2,3,3a,
4,5,5,5a,6-dodecachloro-octahydro-
3861765 lH-Benzimidazole-l-ethanamine, 2-[(4-chloro-phenyl)methyl]
-N,N-diethyl5-nitro-
4685147 4,4'-Bipyridinium, 1,1'-dimethyl
6923224 Phosphoric acid, dimethyl 1-methyl-2-(methyl-amino)-3-oxo-
1-propenyl ester
8001501 Strobane
8065483 Phosphorothioic acid, 0,0-diethyl 0-[2-(ethyl-thio)ethyl]
ester, mixt with 0,0-diethyl S-[2-(ethylthio)ethyl] phosphoro-
thioate
10103614 Arsenic acid (H3As04), copper salt
13171216 Phosphoric acid, 2-chloro-3-(diethylamino)-l-methyl-3-oxo-
1-propenyl dimethyl ester
22224926 Phosphoramidic acid, (1-methylethyl), ethyl 3-methyl-4-
(methylthio) phenyl ester
23135220 Ethanimidothioic acid, 2-(dimethylamino)-N-[[(methylamino)
carbonyl]oxy]-2-oxo, methyl ester
33089611 Methanimidamide, N'-(2,4-dimethyl phenyl)-N-[[(2,4-
Dimetnyl phenyl)imino]methyl ]-N-faethyl -
61788338 TerpheynyT, chlorinated
RCRA Appendix VIII Only:
1162658 Aflatoxin B1
1165395 Aflatoxin 61
1402682 Aflatoxin
6795239 Aflatoxin Ml
688570 Aflatoxin M2
5-22
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7220817 Aflatoxin B2
7241987 Aflatoxin G2
17878545 Aflatoxin B2a
20421107 Aflatoxin G2a
29611038 Aflatoxin RO
32215024 Aflatoxin PI
52819962 Aflatoxin Q1
98055 Arsonic acid, phenyl
205823 Benzo(j)fluoranthene
92671 (1,1'-Biphenyl)-4-amine
226368 Dibenz(a, h)acridine
224420 Dibenz(a,j)acridine
194592 7H Dibenzo(c,g)carbazole
51752 Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl
55867 Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl, hydrochloride
126852 Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl, N-oxide
302705 Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl,
N-oxide, hydrochloride
66275 Methanesulfonic acid, methyl ester
16543558 Nornicotine, N-nitroso
7530054 Oxirane, 2-chloromethyl-3-methyl
126681 Phosphorothioic acid, 0,0,0-triethyl ester
108601 Propane, 2,2'-oxybis(l-chloro
56575 Quinoline, 4-nitro, 1-oxide
95498 Benzene, l-chloro-2-methyl-
106434 Benzene, l-chloro-4-methyl
96184 Propane, 1,2,3-trichloro
52244 Aziridine, 1,1',1"-phosphinothioylidynetris
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14901087 beta-D-Glucopyranoside, (methyl-0NN-azoxy)methy1
13256229 Glycine, N-methyl-N-nitroso-
6358538 2-Naphthalenol, l-[(2,5-dimethyoxyphenyl)azo]
51525 4(lH)-Pyrimidinone, 2,3-dihydro-6-propyl-2-thioxo-
59892 Morphcline, 4-nitroso
FIFRA and RCRA Appendix VIII only
85687 1,2-Benzenedicarboxylic acid, butyl phenylmethyl ester
140578 Sulfurous acid, 2 chloroethyl 2-(4-(1,1-dimethylethyl)
phenoxyl)-1-methyl ethyl ester
Step 8 Complete the Regulated List
To complete the list of regulated materials, the RCRA specific and
nonspecific wastes, as listed in 40CFR251.31 and 261.32, have been added.
These lists are sometimes called the F and K lists, and bring the total
number of entries on the regulated list up to 917.
The regulated list is given as Appendix B. The act under which the
material has been regulated is also shown, and in the case of RCRA, the
specific list within the regulation is also indicated.
It should be noted that since this list derives from the CASR list, it
still retains the mixed numberical/alphabetical order that results from the
EPACASR2 sorting procedure. Prior to publication in a regulation, the
following is recommended:
1. That the list be resorted in true alphabetical fashion, ignoring
numerical fields
2. That two other companion-lists be generated:
a, A list sorted by CAS number
b. An alphabetical list using common names and synonyms taken
from the original regulation wherever possible.
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Step 9--Prioritize the Supplemental List
As a final step, the supplemental list of chemicals was divided into
three sections:
Priority 1 - These materials produced in annual-quantities of 10,000,000
pounds or more.
Priority 2 - Those materials produced in annual quantities of 1,000,000
to 10,000,000 pounds.
Priority 3 - Those produced in annual quantities of less than 1,000,000
pounds.
Production quantity was used in developing regulations under the Clean
Water Act, Section 311 as a measure of risk, since there is generally more
chance of spill an contamination of waterways in cases of materials produced
in large quanity. In those regulations, production at greater than 10,000,000
lb/yr was one of the necessary designation criteria. However, since CERCLA
covers many more circumstances than spills into waterways, it may not be
appropriate to apply the same criteria here. Accordingly, we have used
production level only as a measure of importance. Note that regulation of
a high-volume material is likely to have a greater economic impact than
regulating a low-volume one, and the level of production will be of concern
in later cost-benefit studies.
The data for these evaluations again came from the Chemical Information
System, using TSCAPP (The Toxic Substances Control Act Plant and Production
Data). According to the information displayed in the introduction to this
data base, the latest ufklate of this material was in August 1981, but this
is in reference only to new materials added to the data base. The bulk of
the information was gathered in 1977. However, four years is really a very
short time in terms of the chemical industry, and these data are believed
to be still valid.
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The three lists generated by this process contain 275 Priority 1
materials, 509 Priority 2 materials, and approximately 1600 Priority 3
materials. The Priority 1 and 2 materials are given in Appendices C and D
respectively. The Priority 3 list has been relegated to the Rockwell files
for the time being, but can be provided whenever needed.
Each item on thse two lists is accompanied by a code designating a
primary reason for it being considered hazardous, as follows:
Co = Corrosive
F = Flammable
Fs = Flammable Solid
H = Health Hazard (Includes carcinogenicity, toxicity, and
all other health hazards)
H/W = Hazardous When Wet
X = Oxidizer or Explosive
Py = Pyrophoric
Only one primary reason is given for each material, but this does
not exclude the material from being equally hazardous for one or more
additional reasons.
As with the regulated materials lists, these two lists still retain
the peculiar sorting characteristics of the original CASR list, and should
be alphabetized and supplemented with numerically-ordered and synonym
lists before final publication.
Of those compounds added from DOT and IARC tables in preparing
Intermediate List #2, only nine remain on the Priority 1 list. These
are (listed by increasing CAS number):
75194 Cyclopropane
79414 2-Propenoic acid, 2-methyl
115106 Methane, oxybis
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116143 Ethene, tetrafluoro-
563473 1-Propane, 3-chloro-2-methyl
7681381 Sulfuric acid, monosodium salt
7757791 Nitric acid, potassium salt
8049170 Ferrosilicon
26545733 Propanol, dichloro
An additional six such compounds are found in the Priority 2 List,
as follows:
98124 Si lane, trichlorocyclohexyl
4098719 Cyclohexane, Sisocyanatol(isocyanatomethyl)-l,3,3-trimethyl
7778747 Perchloric acid, potassium salt
9007130 Calcium resinate
9010699 Resin acid, zinc salt
9056386 Starch, nitrate
Issues in the Designation Process
The use of the strategy for designation raises several issues which
need addressing.
1. The first issue is the designation of the hazardous waste which
when tested according to procedures listed in Part 261 for Ignit-
ability, Corrosivity, Reactivity, and Toxicity fall into the
classification of hazard, the so-called ICRT wastes, or those
which are identified as the D series. These wastes are not
identified with any specific manufacturing process and if when
tested have one or more of the charcteristies of ICRT fall under
the RCRA regulations. This category of hazardous wastes contains
essentially an unlimited number of hazardous substances which
cannot be identified for designation. It might be possible to
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include in the designation of a category of hazardous substances
which includes all wastes which are positive to one or more of the
ICRT tests. If this is done then a reportable quantity for that
category must be established (see Section 6). Alternatively, it
might be practical not to designate these wastes, and rely upon the
wastes as "pollutants and contaminants," By this strategy, the
Government could respond if they knew that a release could occur.
This has the advantage that an RQ need not be established for any
of the ICRT wastes, but has the disadvantage that a release of the
waste need not be reported. An economic evaluation of the bene-
fits of designating or not designating the ICRT wastes should be
determined before a final recommendation is made.
2. We have used as a gate an LD5Q or LD^Q for oral toxicity of 500
mg/kg. This is the "one-swallow" lethal dose for a 15 kg (33 lb)
child. All substances having this toxicity or greater (i.e., a
j
value of 500 mg/kg or lower) were retained on the list.* One can
argue that this is too restrictive a toxicity limit, and should be
lowered to 50 mg/kg which is the DOT limit for "Poison, Class B."
We have elected to follow a worst case scenario because if there
were a release the probability of a child ingesting the released
substance is more likely than a mature adult doing so, since the
child would have less concern for poisons than an adult. We of
course would be pleased to consider other criteria in establishing
an oral toxicity limit."
* Note: The 1ower the numerical value, the greater the toxicity, i.e., the
smaller the amount needed to produce a toxic effect, the more poisonous it
is considered to be.
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in establishing an oral toxicity limit.
3. We included on the regulated list all the substances listed
pursuant to the SDWA and FIFRA, even though these acts are not
specifically mentioned in CERCLA Section 101(14). The reason
these were included is that we view the regulations resulting
from CERCLA to be the comprehensive definition of hazardous
materials, regardless of environmental medium. It would seem to
be technically contradictory to have a substance listed as hazard-
ous in an EPA regulation pursuant to SDWA and FIFRA, and not a
hazardous substance pursuant to CERCLA. We further would recommend
that as the regulations of SDWA and"FIFRA are amended to include
other substances, that the designation of substances in the
regulations of CERCLA be amended accordingly, notwithstanding the
fact that lists in SDWA and FIFRA are regulated for entirely
different reasons than the list of CERCLA.
However, it can also be argued that FIFRA and SDWA were excluded
from CERCLA Section 101(14) by intent. The issue is one of
whether CERCLA, if it is indeed to be the inclusive act for all
substances regardless of medium, is also to encompass the mate-
rials regulated in all prior acts, whether specifically mentioned
in Section 101(14) or not.
4. We have used annual production to establish lists of varying
priority. However, it must be remembered that 1n the regulation
promulgated pursuant to 311 of CWA (40CFR116) production level
was one of the criteria used to decide whether materials were
listed or* not. The 311 regulation did not apply to multimedia as
the CERCLA regulation but it can still be argued that a produc-
tion level criterion should be applied as a measure of risk of
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exposure. We welcome a dialog on this issue since the use of the
10,000,000 lb. production quantity would eliminate all but 275
additional substances from the listings. Perhaps all materials
given in Appendices C and D should be subjected to the HI test
and the rankings of those substances compared with those of
legislated substances. By this procedure it would be possible to
at least compare the degree of hazard.
5. Radionuclides were not addressed in this designation process.
They are treated separately {Section 7).
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SECTION 6
REPORTABLE QUANTITIES
This section describes the various approaches investigated to determine
the method of assignment of reportable quantities (RQ's) to CERCLA designated
hazardous substances specified in Section 101(14) and 102 of the Act. The
legislative basis of the RQ concept is discussed as well as the pros and cons
of the various strategies of RQ assignment.
THE CONCEPT OF REPORTABLE QUANTITIES
As stated in the legislative history and the language of the statute
itself, a CERCLA reportable quantity (RQ) provides the triggering mechanism by
which notification of releases into the environment of hazardous substances are
reported to the National Response Center under Section 103(a). Although
Section 102 establishes a link between "hazardous substance" and a concept
of harm or hazard by the phrase, "...may present substantial danger to the
public health or welfare or the environment it is important to note that
the language of the Act makes no reference to such a link between the RQ and a
concept of harm or hazard. The legislative history documented in the Senate
Report of the Committee on Environment and Public Works that accompanied the
Senate version of CERCLA, SI480, states the rationale:
The provision intentionally omits from the requirement to determine
"reporting" quantities any reference to harm or hazard. A single quantity
is to be determined for each hazardous substance, and this single quantity
requires notification upon release into any environmental medium. It
would be virtually impossible to determine a single quantity applicable
to all media while at the same time linking such Quantity to anv subjec-
tive concept of harm
It is essential that such quantities be relatively simple for those
subject to notification requirements to understand and comply with. Since
releases in such quantities trigger notification requirements, but do not,
in and of themselves, give rise to other liabilities under this Act, the
Presidents' (sic) broad discretion to select quantities will not unfairly
burden those persons subject to the Act.
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In determining reportable quantities under this paragraph [Section 3(a)(2)],
the President may consider any factors deemed relevant to administering the
reporting requirement or the President's other responsibilities under this
Act. Administrative feasibility and practicality should be primary factors.
In addition, the President may revise such regulations from time to time if
under-reporting or over-reporting is occurring under existing regulations.
(Emphasis added.)(Senate Report, p. 29).
Congress designed CERCLA to be a legislative "umbrella" under which the
problems outlined in Section 1 of this report could be addressed comprehensively.
The Senate Report states:
The bill (S.1480) is not intended to replace other laws which aim to
correct a variety of toxic chemical concerns. The Clean Air Act,
the Clean Water Act, the Toxic Substances Control Act, the Solid Waste
Disposal Act, and other statutes are only beginning to build regulatory
foundations to address the wide range of toxic contamination incidents.
The reported bill, S.1480, is structured to complement these laws.
(Senate Report, p. 12).
Because of this, the legislative text specifies no hazardous substance
designation criteria for those substances not covered under Section 101(14)
except that a "hazardous substance" under Section 102 must be one that ma^
present substantial danger to the public health, welfare or the environment.
In reference to the earlier Senate version of Section 102, the Senate Report
for S.1480 states:
Section 3(a)(2) authorizes the President to designate as hazardous sub-
stances those compounds, elements, mixtures, and solutions which may
present substantial danger to public health and welfare and the environ-
ment, This provision essentially authorizes the President to augment the
existing lists of hazardous substances derived from existing statutes
(see Section 2(b)(13)(A), (B), (C), (D), and (E)). The language of this
provision has a lower threshold for designation than that currently in
place in Section 311(b)(2) of the Clean Water Act. This is intended to
afford the President broad discretion in designating substances which
may adversely affect public health or the environment, (Emphasis added.)
(Senate Report, p. 28).
In combination, the process of hazardous substance designation and the
assignment of RQ's comprise one of the Act's major mechanirms to protect the
public health and environment.
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Hazardous substance designation defines what is to be regulated and the
assignment of RQ's defines to what extent releases will be reported for
possible federal response pursuant to Section 104. The appropriate RQ should
therefore reflect not only current Federal priorities, but should be responsive-;
to changing conditions that govern the use and disposal of hazardous substances
in the United States. Regulatory realities may make these objectives difficult
to achieve.
Prior to the enactment of CERCLA, the provisions of the Federal Water
Pollution Control Act (Clean Water Act (CWA)) required the determination of what
was originally referred to as "harmful quantities." Section 311(b)(4) of the
Federal Water Pollution Control Act Ammendments of 1972 (PL 92-500) stated:
The President shall by regulation to be issued as soon as possible after
the date of enactment of this paragraph, determine for the purposes of
this section those quantities of oil and any hazardous substance the
discharge of which, at such times, locations, circumstances, and con-
ditions will be harmful to the public health or welfare of the United
States including, but not limited to, fish, shellfish, wildlife, and
public and private property, shorelines, and beaches except that in the
case of the discharge of oil into or upon the waters of the contiguous
zone, only those discharges which threaten the fishery resources of the
contiguous zone or threaten to pollute or contribute to the pollution of
the territory or the territorial sea of the United States may be deter-
mined to be harmful. (Emphasis added.)
As the result of a law suit initiated by the Manufacturing Chemists
Association in 1978, Congress revised the CWA by statutory amendment (PL 95-
576) and changed the "harmful quantities" (first proposed in 40CFR118,
December 30, 1975) which trigger the provisions of Section 311, to quantities
which "may be harmful", and by deleting the reference to specific circumstances
and conditions surrounding a discharge. The revised language states:
The President shall tfy regulation determine for the purposes of this
section those quantities of oil and any hazardous substances the discharge
of which may be harmful to the public health or welfare of the United
States, including but not limited to fish, shellfish, wildlife, and public
and private property, shorelines, and beaches. (Emphasis added.)
(Section 311(b)(4)).
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According to the preamble of the proposed rulemaking of 40 CFR Part 117
(44FR10271) dated February 16, 1979, Congress intended that the determination
of quantities "which may be harmful" would not require an assessment of actual
harm in the variety of circumstances in which hazardous substances might be
discharged. The deletion of all language specifying times, locations, cir-
cumstances, and conditions from the applicable parts of Section 311 illustrates
this point. The preamble goes on to state, "Congress intended that the deter-
mination be based on the chemical and toxic properties of the substance itself,
not the circumstances surrounding its release." Pursuant to this philosophy,
the regulatory term "harmful quantity" was changed to "reportable quantity."
Reportable quantities now "...need only be a rational generalized prediction of
those quantities which may be harmful." Thus the duty to notify authorities
under Section 311 is predicated on the degree of harm and other relevant factors
instead of a verification of actual harm. Detetrmination of the degree of harm
vs. actual harm allows the use of intrinsic and generic criteria in establishing
what quantities of hazardous substances "may be harmful/which is more in line
with the present ability to predict the fate and effects of hazardous substances
in the environment.
Even though the regulatory mechanisms established under CERCLA are modeled
after the CWA with respect to the designation of hazardous substances and
assignment of RQs, distinct differences in the statutory language of the two
acts result in two different RQ concepts. To the extent that the CWA will act
as a precedent in developing the technical and legal basis for RQ assignment
pursuant to CERCLA, the differences in the conceptual framework of RQ assign-
ment under each act should be understood.
Most significant is that the statutory language of CERCLA allows the
Administrator (EPA) to assign RQs without necessarily linking the specific RQ
6-4
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to a concept of harm or degree of harm. RQ assignments pursuant to the CWA
have all been determined by a method that, in contrast, considers the degree of
harm posed by the toxicological properties of designated hazardous substances
in relation to the aquatic medium. In addition, the statutory text of CERCLA
allows, but does not require, the determination of a single RQ without regard
to the medium into which the hazardous substance may be released, even though
the legislative history presents valid reasons for a single RQ (Senate
Report, p. 29). The CWA is concerned with the restoration and maintenance of
the nation's navigable waters with respect to their biological, physical, and
chemical integrity, and therefore does not consider releases to other media in
assigning RQs.
Regardless of the language of the Act and legislative history that allows
the Administrator to assign CERCLA RQ's on the basis of administrative feasi-
bility and practicality, from its inception, this study has emphasized the
development of strategies that tie RQ assignment to a concept of hazard based
on appropriate and factual criteria. It was felt that such an orientation
will provide the best assurance to EPA that the forthcoming regulations will
be based on sound, objective, and technically justifiable considerations.
APPROACHES TO ASSIGNMENT OF RQs
Several alternative strategies have been considered for the assignment of
RQs for CERCLA designated hazardous substances. In keeping with the require-
ments of the Act, EPA policy, and administrative considerations, the various
strategies were formulated to be flexible, simple, logical, defensible, and to
reflect the state-of-the-art within the strictures of what could conceivably be
implemented. To date, six major approaches appear to be viable options.
They are:
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1. Administrative Feasibility and Practicality
This strategy is founded on the intent of Congress which suggests that
RQ assignment be primarily based on "administrative feasibility and
practicality" (Senate Report, p. 29). The criteria used to consti-
tute such a strategy should allow the Administrator to implement a
system of reporting that would insure that all releases that have
the potential for serious environmental and human health consequences
be reported to the National Response Center (NRC). This strategy
makes no attempt to link the assigned RQ to an assessment of a
hazardous substance's potential for causing harm.
2. Scenarios
This alternative employs part fact and part assumption to predict
an appropriate RQ based on the hazardous substances potential for
causing harm via multimedia pathways. Generic assumptions are used
to characterize the environmental media as well as the fate and
effects of the specific hazardous substance. RQ's are calculated
directly by the use of a general formula representative of the facts
and assumptions governing the scenarios.
3. Fate and Effects Research
This strategy involves the sponsoring of research programs designed
to resolve the outstanding issues concerning the fate and effects of
hazardous substances in the environment. RQ's would then be assigned
on the basis of specific knowledge of a hazardous substance's multi-
media behavior and potential for harm.
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4. Hazard Indices
This strategy employs the use of scientific criteria in specified
combinations for the purpose of rating the hazard potential of
various hazardous substances. RQ assignments are then made on the
basis of the ranking hierarchy.
5. Combined Approach—Hazard Index Combined with Administrative Feasibility
This strategy entails the use of a hazard index rating scheme to rank
the relative hazard potential of all designated hazardous substances.
The RQ's assigned to the various ranges of hazard rank are then
adjusted up or down based on considerations of administrative
feasibility and practicality. This "fine tuning" can use both
scientific and "real world" considerations for the final assign-
ment of the RQ value.
6. Selective Criteria Processing
In this strategy RQ assignments are based on a series of individual
and/or a combination of criteria that allow segregation of designated
hazardous substances into separate categories. Each category reflects
proven or suspected environmental hazards based on scientific informa-
tion, and RQ's are then assigned to each category based on assessments
of the reporting necessary to respond to or evaluate the need to
respond to specific release incidents.
Each strategy was evaluated 1n detail, and those that showed least promise
of fulfilling the program's objectives received appropriately less attention.
The strategies cited abov^ provide many options within the six major alterna-
tives by the consideration of various permutations and combinations of their
basic elements. Each alternative strategy, its pros and cons, and permutations
is addressed below. Also discussed 1s the strategy proposed by the Chemical
Manufacturers Association (CMA) to the EPA for revising the one-pound RQs
6-7
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specified by Congress for all legislated hazardous substances other than those
listed under Section 311 of the CWA.
Administrative Feasibility and Practicality
As mentioned previously, the legislative history and language of the Act
empowers the Administrator (EPA) to exercise broad discretion in both desig-
nation and the assignment of RQs to hazardous substances designated pursuant to
CERCLA Section 102(a) and (b). Consistent with the Act's intent and purpose,
RQs are not necessarily required to be linked to a concept of harm or hazard.
The operative language in Section 102(a), "The Administrator shall promulgate
and revise as may be appropriate regulations designating as hazardous
substances...such substances which, when released into the environment may
present substantial danger to the public health or welfare or the environ-
ment, ..." implies that the link to harm or hazard must be established during
the designation step. This means, according to the above interpretation, that
once a substance has been designated as hazardous for the purposes of the
statute, it has the potential of causing substantial danger to the public
health, welfare, or the environment without regard to specific amounts released
or the media pathway involved.
In expressing the need for a comprehensive bill (S.1480) to address all
releases of hazardous substances, Senator Stafford (Rep-VT) reasoned:
For 3 years, the Senate has worked on a bill that would respond to
emergencies caused by chemical poisons, and to seek to discourage the
release of those chemicals into the environment. In many ways, the
Senate bill is analogous to the natural disaster assistance programs
we have enacted into law. When those natural disaster assistance laws
were enacted, no one suggested that we should respond to floods, but
not to earthquakes. It makes no more sense to make that kind of distinc-
tion when dealing with chemical emergencies than it does when
dealing with naturil emergencies.
...There is simply no good reason for us to respond to one type of
release of a poison but not another. The test should not be whether
poison was released into river water rather than into well water, or
by toxic waste buried in the ground rather than toxic waste discharged
to the ground. The test should be whether the poison was released.
I assure you that the victim does not care to make those distinctions,
nor should the Congress. (Congressional Record, p. S.14967).
6-8
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As illustrated by this passage, the intent of Congress was to establish
a comprehensive response capability regardless of the type of release or the
media involved. Furthermore, the definition of a hazardous substance was
made intentionaly broad so as to allow regulation of such substances before
they could substantiate their harmfulness by their release into the environment.
The text on Page 29 of the Senate Report explains:
This generic definition (of a hazardous substance originally defined in
S.1480) is included because hazardous substances characteristically are
not included on a governmental list until after they have demonstrated
their danger by killing or injuring people or causing significant environ-
mental damages. The actual listing of a substance lags behind release
and exposure by years and sometimes decades. This happens even though
the persons responsible for manufacturing or handling the substances
usually know, either through experience or scientific studies, the
substance's dangerous propensities.
...Some substances have not been included on one of the relevant
lists even after they have, in fact, caused grievous injuries.
In reference to the role that RQ's would have in activating such a
comprehensive notification and response mechanism* Senator Randolph (Dem. W.VA)
explained in the following text how earlier versions of S.1480 reflected the
sponsor's concern that alj_ hazardous substance releases be reported for
possible Federal response.
Another change in Government notification from that in S.1480 involves
the establishment and use of reportable quantities of hazardous substances
under Section 102. The earlier Senate proposals authorized regulations
establishing reportable quantities for hazardous substances, but required
reporting of alj_ releases of a hazardous substance.
Authority to designate additional hazardous substances and to establish
reportable quantities for all hazardous substances is retained, but
reporting of releases 1s now limited to those involving such reportable
quantities. To assure that reporting eommenses immediately upon enactment,
Section 102(b) establishes a reportable quantity of one pound for all
hazardous substances\ (except those already designated under the Clean
Water Act) unless and until superseded by any regulations issued after
the act's passage. (Emphasis added.)(Congressional Record, p. S.14965).
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It seems clear from the above that Congress wanted to know about all
releases of hazardous substances regardless of type or specific amount, and
considered RQ's only as a way to provide a logical administrative tool for
notification. Thus, the method for establishing RQs should be determined by
considering only the information necessary to ensure that the appropriate
response powers pursuant to CERCLA Section 104 can be activated in a manageable
fashion.
Consistent with present EPA policy, the Federal Government wishes to
confine NRC notification to releases that present true emergency situations
requiring immediate response in order to prevent or ameliorate dangerous con-
sequences to public health, welfare, or environment. Since RQs must be
assigned a priori to the specific circumstances surrounding the actual release
of any designated hazardous substance, RQs could conceivably be based on an
assessment of release potential and/or magnitude. Even though one person
adversely affected by a release of a hazardous substance is one too many, true
emergencies warranting federal response are typically incidents that affect
tens, hundreds, and thousands of people at a time. Factors that relate to
release potential and magnitude not connected directly to the intrinsic prop-
erties of hazardous substances themselves are: (1) production volume, (2)
transportation modes, (3) distribution data, (4) containerization, (5) size of
typical bulk shipments, and (6) spill histories and/or accident frequencies of
applicable transportation modes and stationary sources. The data base con-
taining this information can be accessed through use of the CIS system, DOT
regulations, and other computer data bases compiled by EPA and DOT. Specific
data bases that may provide this information are:
o Pollution Incident Reporting System (PIRS)
o Hazardous Materials Information System (HMIS)
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o Spill Prevention Control and Countermeasures (SPCC)
o Hazardous Materials Incidents Reported to U.S. EPA Regional Offices
for October 1977 through September 1979
o Chemicals in Commerce Information System (CCIS)
"Hand searches" for other data related to release incidents may be possible
through records provided by trade organizations and insurance companies.
Any one of the above criteria, or combination thereof, could be used to classify
hazardous substances with respect to a specific RQ. Similar to the classifica-
tion system developed under Section 311 of the CWA, RQ categories could be
established as 1, 10, 100, 1000, and 5000 lb. reflecting appropriate categories
of the selected criteria. As appropriate, RQ categories different from those
established pursuant to the CWA could be set to more nearly reflect production
volume, containerization, and bulk shipment size instead of assessments of
potential harm or hazard.
For instance, if the containerization, bulk shipment size, and production
volume were chosen as the RQ assignment criteria, materials shipped in the
largest containers and produced in the largest amounts should have an appro-
priately small RQ, since the probabilities of releases potentially resulting in
large spills would be highest. This would ensure that early notification would
be made for these potentially disastrous situations. Of course, special cate-
gories of substances, such as carcinogens, could be assigned specific RQs
regardless of the above criteria, since these pose special risks to the public
health.
Using a hypothetical example, Substance X 1s manufactured in quantities of
10 million lb. per year apd is shipped in containers of 100, 1000, and 5000 lb.
Following the entries in the table below, 1t is evident that 67% of the bulk
shipments per year contain 10,000 lb. of substance X in containers of 1000 lb.
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and 100 lb. sizes in a ratio of approximately 1.7:1 respectively. Thirty-three
percent of the bulk shipments contain 5,000 lb. of Substance X in containers of
equivalent size. The RQ in this example would be most logically set somewhere
between 100 lb. and 5000 lb. If the RQ was set at 5000 lb. then a value of the
entire contents of a barge in an accident would have to occur in order for
notification to be triggered. If the RQ was set at 100 lb., an accidental
breakage of just one container in handling would require notification. However,
if the RQ was set at 1000 lb., 67% of the bulk shipments would be required to
report if 10% of their containers were ruptured, 10 containers in the case of
truck transport, and one container in the case of rail transport. This RQ
would not require reporting for accidental handling incidents involving one or
two 100 lb. containers and would require the reporting of incidents that would
potentially involve the release of the total 5000 lb. of the chemical in a
barge accident. Catastrophic releases involving rail shipments usually occur
as the result of multiple car derailments. Hence, incidents of this kind would
not likely rupture more than one tank, and hence, would require reporting.
Examination of spill histories and accident frequencies of various transporta-
tion modes would supply qualifying data that would either confirm or deny the
logic of the RQ based on generalizations about typical accidental releases.
% of Production Container # of Containers Bulk Shipment Shipments/Yr.
Vol. Transported Size per Shipment Size (% of Total)
Truck (30%) 100 lb. 100 (Boxes) 10,000 lb. 300 (25%)
Barge (20%) 5,000 lb. 1 (Tank) 5,000 lb. 400 (33%)
Rail (50%) 1,000 lb. 10 (Cars) 10,000 lb. 500 (42%)
The obvious benefit of adopting this strategy is that it is extremely
flexible. Substances could be assigned an RQ based on "special considerations"
not necessarily tied to one set of invariant criteria. In addition, if different
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sets of multiple or single criteria were used to assign RQ's to specific groups
of hazardous substances, different RQ ranges could be used to best ensure
notification of the incidents most likely to require Federal assistance. The
data base for measures of release potential and/or magnitude is relatively good
(with respect to other data concerning the fate and effects of substances in
the environment), and could be used to essentially avoid scientific controversy
as to what specific amounts are "of concern" for purposes of notification. If,
on the other hand, EPA chose not to establish a range of RQs and simply assigned
all designated hazardous substances a 1-lb. RQ, then the statutory language of
CERCLA itself would provide the firmest and most justifiable basis upon which
to establish such a quantity.
There are several major disadvantages to adopting the administrative
feasibility and practicality approach. Regardless of the statutory mandate
allowing broad discretion in assigning RQs, this approach risks being criti-
cised as arbitrary and capricious, since considerable disagreement may exist
on the use and significance of the chosen criteria. This approach does not
firmly link RQs to harm or hazard as in the case of RQs assigned under Section
311 of the CWA. Accordingly, the contrast between the two approaches may not
provide the interested community with the impression that EPA is following a
consistent policy toward hazardous substances. Depending upon the specifics,
classifications that assign only one or two categories of RQs (e.g., 1 lb and
1,000 lb) may be too costly to the regulated community, in consideration of
monitoring and reporting requirements, and too broad so as to cause adminis-
trative paralysis due to "over-reporting."
In sum, this strategy appears to be viable for use by itself or in
combination with a more rigorous strategy for RQ assignment. If used in
combination with another strategy, consideration of administrative feasibility
and practicality would allow "special cases" to be handled by appropriate
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"fine tuning" of specific RQ's. In either case, the legislative history and
the language of the statute presents ample justification for the use of such a
strategy for RQ assignment.
Scenarios
The use of scenarios in providing a basis for regulation is well estab-
lished and is perpetuated by the regulatory apparatus itself. For instance,
scenarios are maintained by the regulations that govern the preparation of
Environmental Impact Statements. The requirements are found in 40CFR1502.22
in the heart of regulations resulting from the National Environmental Policy
Act (NEPA). They state: "If the agency proceeds ... (to evaluate an action
that has adverse impacts important to a decision that cannot be evaluated or
is based on data too expensive to obtain), ... it shall include a worst-case
analysis and an indication of the probability or improbability of its occurrence."
From the regulatory standpoint, scenarios are attempts to define the phenomena
and consequences of an event lacking the data necessary to describe it purely
on an empirical basis. For the purposes under discussion, "scenario develop-
ment" is defined as "the art of selection and compilation of a specific set of
circumstances conceived to describe a projected course of events."
Scenarios are considered a viable alternative for assignment of RQs in
cases where the state-of-the art will not support detailed evaluations of the
fate and effects of substances in the environment (assuming that RQs will be
assessed by their relative hazard potential in the media). Scenarios can be
developed for any purpose using part fact and part assumption to "model" the
behavior of substances released into various media pathways. Incomplete data
can be assembled, for instance, to describe what would happen if a release to
the soil led to contamination of groundwater that was eventually ingested.
Such a scenario was developed during the early phases of the program and
resulted in the determination that scenarios which "model" fate and effects
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of hazardous substances in a comprehensive manner are by their nature complex
and subject to controversy. Scenarios that define simpler systems, such as
transportation, accidents, etc., would logically be more justifiable since
the phenomena are far less complex, and hence, less controversial. What follows
is an example of a scenario used to calculate RQs on the basis of scientific
knowledge concerning the fate and effects of a substance in the groundwater
environment. It will serve to illustrate some of the pros and cons of
scenarios, in general, as a strategy for RQ assignment.
RQ Assignment for Chloroform—An Example
A recent paper by Dacre, et al. (1980) develops the concept of relating
an acceptable daily dose of a toxic substance (Dy) to safe concentrations of
the substance in various media, specifically water and soil. This concept is
not new since Dacre's work essentially adapts earlier, more comprehensive
studies by CIel and, et al. (1977) in the development of the Multimedia Environ-
mental Goals Project sponsored by EPA. Other methods of calculating the
minimum safe exposure doses of environmental pollutants are more rigorous
(Walsh, et al., 1979)', but these generally have limited application and
require specialized data resources to complete the equations. Dacre's procedure
was adapted for purposes of illustration because of its general applicability,
its relative simplicity, and because this method is representative of most
that propose to calculate safe exposure doses of toxic substances.
Adaptation of the methodology proposed by Dacre, et al., (1980), permits
the calculation of the maximum quantity of a hazardous substance that will be
equal to the "threshold" above which human health effects are evident in the
case of chronic exposure. The method is linked to a scenario with the follow-
ing assumptions:
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1. The dose-response relationship for humans indicates that there is
some finite exposure dose below which the rates of the biological
protective processes of detoxification, excretion and injury-repair
keep pace with or exceed the rates of exposure, absorption, and
injury production. In short, the threshold dose concept applies.
2. The environment, in this example, neither mitigates nor enhances
the toxic potency of a released chemical.
3. The pollutant pathway is soil-groundwater-man.
4. The lifetime average daily dose (LADD) for one individual is
equal to the acceptable daily dose of a toxic substance (DT).
5. The hazardous substance is completely mixed in water.
6. Carcinogenic potential is not considered a criterion for RQ assignment.
Consider the scenario of a release of an amount (NR) of the hazardous
substance, chloroform, into the soil. Chloroform has an oral-rat LDgg toxicity
of 800 mg/kg. The substance is assumed to percolate through the soil and
enter an aquifer pumped by a single well used for household consumption. If
all of the substance eventually enters the well water and the average daily
use per individual is assumed to be 400 liters, of which 2 liters (0.5%) is
ingested, then the lifetime average daily dose (LADD) for one individual
weighing 70 kg and living 70 years is:
• 005 x Np q i -i
LADD a = 2.8 x 10"y Np kg"' day"1 (1)
70 kg x 25,500 days x 1 person
Since the most likely toxicity value to be found in the literature is an
ingestion LD^q, usually for rats and mice, Dacre et al. (1980) equated the
acceptable daily dose (D^) in terms of the LD^q for a given toxic substance.
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This was done, because there is seldom enough information to permit extra-
polation of LDjjq data to a dosage which kills only a very small fraction
(e.g., 1%) of the animals, or to determine an acceptable risk level.
Based on experimental studies, Handy and Schindler (1976) assumed a safe
limit for the continuous human intake of a toxic substance to be approximately
5 x 10"4 times its LD5Q value. They also assumed a biological half-life of
30 days, which implies a disappearance rate of 2.31% per day. If the daily
intake of the toxic substance is made equal to the daily disappearance rate at
the safe concentration limit, then that safe concentration is maintained:
DT = 2.31 x 10"2 x 5 x 10"4 x LDg0 = 1.2 x 10"5 x LD5Q mg kg"1 day"1 (2)
Assumption #4 gives us the relationship:
Dt - LADD, or
[1.2 x 10~5 day_1][LD50 mg kg"1] = [2.8 x 10"9 kg"1 day"1] NR
(3)
Making the conversion from mg to lb yields:
[1.2 x 10"5 day'^CLDgQ mg kg'1][2.205 x 10"6 lb mg'1]
= N,
R
2.8 x 10"9 kg"1 day"1
or
[9.1 x 10"3 lb mg"1 kg][LD5Q mg kg"1] = NR
(4)
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For Chloroform, substituting 800 mg/kg for the LDgQ value into Equation (4) gives:
[9.1 x 10~3 lb nig"1 kg][800 mg kg"^] = NR = 7.3 lb
In this scenario, the form of Equation (4) can be reduced to k x LD^q =
Nr where k, in the units specified, is a constant representative of the
assumptions cited.
Taking this scenario further, partition coefficients that represent the
relative manner in which NR is passed through this media pathway can be incor-
porated into the calculation. Recent studies have indicated that there appears
to be a linear relationship between the n-octanol/water partition coefficient
for a given organic chemical and the tendency for it to be sorbed into the
soil matrix (Kanaga and Goring, 1978; and Karickoff, et a!., 1978).
Based on this general relationship, the NR value can be modified to
account for chloroform's hydrophobic properties. In addition to the six basic
assumptions provided earlier, two more are needed to support the scenario.
1. The n-octanol/water partition coefficient (Kowj » defined as the
ratio of the equilibrium concentration of a chemical in n-octanol
, to the concentration of a chemical in water ^Cwj is an
accurate measure of soil sorption.
K = Co
ow p
w
2. The ratio (K ) of the equilibrium concentration or amount of an
5 W
organic chemical in water (C, 0* N,,) to the concentration or amount
ww —
in any soil matrix (C„ or N ) is equal to the n-octanol/water
T 5 S
partition coefficient, i.e.,
Cs N
K = K * — or ri—
sw ow s, \
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Considering the same release scenario as before, the addition of the
partitioning effect in the environment takes into account that the soil matrix
sorbs a chemical proportional to Kgw and the remainder enters the groundwater.
The n-octanol/water partition coefficient for chloroform is 93.325 (Leo, A.,
et al., 1971), and thus if all the substance enters the soil, only one part in
93.325 is left unsorbed by the soil matrix. Therefore the percentage of NR
that reaches the groundwater is equal to 1.07%. Assuming the same conditions
as before, with the average daily household use per individual equal to 400
liters, 2 liters of which are ingested (0.5%), the average daily dose (LADO)
for one individual weighing 70 kg and living 70 years is:
LADD = '°05_X_,Q1Q7 X Nr = 3.0 x 10"11 Nr kg^day"1 (5)
70 kg x 25,500 days x 1 person
Using the same logical sequence of steps defined by Equations (2) through (4) yields:
[0.85 lb mg"1 kg][LD50 mg kg"1] = NR (6)
which can be reduced to the form
k x LD50 x KQW = Nr (Where k is equal to 9.1 x 10"3 lb mg-1kg) (7)
Solving Equation (6) or (7) yields an NR value of 679.8 lb. This means that
to receive an LADD equal to the Dy for chloroform, 679.8 lb will have to be
released into the environment, of which 7.3 lb will actually be ingested
during a lifetime.
On the basis of a chemical's K , adaptation of this partitioning technique
UW
could, in theory, be used to adjust the NR value commensurate with a substance's
sorption potential within a selected pathway. In the above example, the RQ
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for chloroform would be 680 lbs (RQ = 1000 lb) or 7 lb (RQ = 10 lb), depending
on which version of the scenario is selected for use.
The above method is similar to that used in EPA's proposed amendment to
40CFR Part 117 (45 FR 46097-46099, July 9, 1980) for the assignment of reportable
quantities for hazardous substances on the basis of carcinogenicity. In that
proposed amendment, the RQ equation takes the form N = 9.85/B which calculates
the number of pounds of a substance, N, having a carcinogenic potency, B, that
would result in a lifetime cancer risk of 10~® The "B" factor for each
compound is equal to the slope of the dose-response line derived from linear
extrapolations of dose-response data (incidence of tumors in animals). The
constant, 9.85, was derived using specific units and a set of assumptions
incorporated into a scenario similar to the one described above. Both scenarios
are directly related to one basic data element, the LDgg toxicity and the "B"
factor, carcinogenic potency.
NR = k x LD50 N = 9.85 x 1/B
The value of the constants in the two equations represent the character of
the contrived scenario in the specified units. As of October 1981, the
proposed amendment remains unimplemented.
Analysis-
Close examination of this and similar methodologies show how scenarios
allow the direct calculation of RQs, a valuable feature, but are alr.o vulnerable
to criticism as being arbitrary. Regardless of the particulars of the scenario,
examination of the equations shows that, in essence, the value (in this
case the RQ) is directly related to the basic data element, a measurement of
toxicity. From this perspective, the entire scenario can be potentially viewed
as nothing more than "playing with numbers".
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The choice and value of the parameters in equations (1) and (2) could
be changed without necessarily violating accepted scientific principles. Any
such change would result in RQs being either higher or lower than the one
calculated above. In this way, scenarios can be manipulated to "justify" a
set of high RQs or low RQs for a group of substances that can be viewed as
either a "blessing or a curse" from the regulatory standpoint. The carcinogen
scenario developed in 45 FR 46097-46099 is another example of this phenomenon
where the basic determination of an RQ value rests with the"B" factor as
a measure of a substance's carcinogenic potency.
From the standpoint of a "devil's advocate", since the basic assumptions
cited in the groundwater scenario are simplistic and, in the strictest sense,
subject to controversy, the scenario can be seen as serving no purpose other
than to obfuscate any apparent link between toxicity and an appropriate RQ.
This fact may provide ample grounds for arguing the inappropriateness of the
entire methodology as a strategy for regulatory management. The scenario
route to an RQ, in this case, appears to be simply a convoluted way of Indexing
substances on the basis of toxicity. Typically, scenarios 1n this application
are similar in concept to the ones discussed, in that they are based on some
basic data elements that act as an index of the quantity to be assessed as
opposed to its actual measurement.
Scenarios can be useful for the purposes at hand, if they are kept simple
and do not involve highly complex phenomena that may be subject to considerable
controversy. Often simple scenarios are universally "accepted" by the scientific
community when consistent lack of data or knowledge forces generalizations
about natural phenomena. The fact that certain ones are standardized allows
some procedural uniformity and comparison of results. In the field of toxi-
cology, some of the most familiar ones Involve standardized assumptions about
absorption factors, transfer coefficients, dose/ concentration relationships,
dietary intake, life expectancy, reference volumes, and the like.
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Scenarios may be useful in defining RQs on the basis of release or
exposure potential. Spill incident scenarios could be designed using data
related to the most common mode of transport, the most common container type,
size and bulk shipment, production volume, accident frequency, and related
spill history. Other than CIS, data bases that could supply this information
are:
o Pollution Incident Reporting System (PIRS)
o Hazardous Materials Information System (HMIS)
o Spill Prevention Control and Countemeasures (SPCC)
o Hazardous Materials Incidents Reported to U.S. EPA Regional
Offices for October 1977 through September 1979
o Chemicals in Commerce Information System (CCIS)
This information could be accessed in addition to that obtained by "hand
searches" to provide data useful in defining what type and size of spills are
most representative for a given substance. Reportable Quantities could then
be based on a scale representing the probable magnitude and likelihood of a
release. The smallest RQs would be reserved for substances that have the
highest production volume and are shipped in the largest containers {or bulk
shipments). A spill incident, in the "worst case", would most likely be equal
to the release of the entire contents of the vehicle load or container. Such
an incident, in the case of a railroad tank car, would involve thousands of
gallons of hazardous substances, certainly a reportable event. Hazardous
substances of low production volume shipped predominantly in the smallest
containers and the smallest bulk shipments, would have RQs higher than the
largest single vehicle load. Such an RQ would assure that multi-vehicle acci-
dental releases would be reported, an event more likely to require federal
assistance.
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In sum, scenarios are useful ways to relate basic data to a set of assumed
conditions, events, and circumstances. Data gaps can be "filled" by reasonable
assumptions or data extrapolations to provide a useful description for the
purpose of regulation. These advantages are magnified when "real-world"
considerations are used in simple form and in noncontroversial areas.
The disadvantages in the use of scenarios for regulatory purposes are
that any assumptions used to complete a scenario may be viewed as arbitrary by
the interested community. Also, in the case of transportation accident
scenarios, any RQ assigned using this approach will not directly link the RQ
to a concept of harm or hazard. However, if that link to harm is firmly
established during the designation step, then RQs could be assigned by trans-
portation-related scenarios and still be consistent with the legislative
mandate (see the discussion on the Concept of Reportable Quantities).
Fate and Effects Research
Establishing RQs by hazard assessment using sound and detailed knowledge
of the principal factors governing the fate and effects of hazardous substances
in the environment would be,from the standpoint of rigor and defendability, an
ideal strategy for a regulatory program under CERCLA that links RQs to a
concept of harm. Unfortunately, at this time,data limitations and the state-
of-the-art will not support the broad and uniform application of such an
approach. In a recent report by the Institute of Medicine, National Academy
of Science (1981), the state of knowledge 1n fate and effects research was
addressed:
There seldom 1s a simple relationship between environmental hazards and
health effects. The contribution of a given environmental factor can
vary, depending on the conditions under which 1t 1s encountered, the
presence of other factors 1n the environment that may modify Its effects,
and the susceptibility of the population exposed. A given substance can
lead to multiple health problems, and people are exposed to a variety of
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potentially hazardous substances in their surroundings. It is extremely
difficult to determine causes of health problems that result from rela-
tively low levels of exposure, especially if the resulting health problems
occur after a long latent period and have no features specifically identi-
fying them as environmentally caused. The need for new kinds of data is,
therefore, great.
The report went on to conclude that, "At present there is not a
good theoretical basis for extrapolating results of animal studies to estimate
human risk." Even in this light, the numerous difficulties in extrapolating
toxicological data from laboratory animals to man are small compared with
those of evaluating the toxicological hazards of chemicals to the whole
environmental biospectrum. Review of acute toxicity data of some pesticides,
for example, in a large number of species suggest that the variance of inter-
species response in nonmammalian organisms is probably even larger than the
factor of 10 to 12 estimated in susceptibility differences between mice and
men (Murphy, 1978). Clearly, hazard assessment of substances in the environ-
ment suffers from a universal lack of integrated data related to dose-response,
bioaccumulation, persistence, and transport phenomena within the environmental
media.
The scientific literature has just recently been concerned with the
quantification of the fate and effects of chemicals in the environment, and
work to date that could be classified as "model development" has been oriented
toward well-defined, limited systems of carefully controlled variables.
Application of these scientific developments to the task at hand can only be
made in a generic sense.
The uncertainty in the state-of-the-art is well illustrated by the
opposite conclusions reached in two recent publications dealing with the
causes of cancer. In one (Re1f, 1981), cancer is said to be caused mostly by
environmental factors. Studies are cited supporting the view that the work-
place, radiation, diet, and water and air pollution may all contribute to the
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development of cancer. On the other hand, in a study commissioned by the Con-
gressional Office of Technology Assessment, Doll and Peto (1981) claim that
the only new cancer-producing hazard introduced in recent decades is cigarette
smoking. Such major differences of opinion demonstrate clearly that fate and
effects phenomena are extremely complicated, and that much remains to be done
to resolve the ambiguities. Since it would require a wealth of information to
adequately describe the fate and effects of all substances under all the
possible environmental circumstances of interest, the purely scientific
approach, at this time, seems to have only limited applicability for RQ
assignment considering the apparent and immediate need for regulatory relief.
In the instance where a 1-lb. RQ is mandated by the statute itself (CERCLA
Section 102), the need for regulatory relief is particulary urgent.
However, in a generic sense, research and development could play an
important role in assigning RQs, given a sufficient amount of time. The wide
range of data scattered among many different sources needs to be integrated in
a comprehensive fashion, and where major data gaps exist, they need to be
filled by appropriate research. Research, with time and adequate funding,
could resolve discrepancies or ambiguites that now exist. Such a long-range
program would delay implementation of the needed regulations, however, and
would be very resource-intensive. Further, the legislative history of CERCLA
clearly recognized these pit-falls and provided language allowing broad adminis
tratlve discretion in the absence of data.
With respect to hazardous substances, assessments of the basic phenomena
governing the following subject areas should receive a high priority in any
such research effort.
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1. Determination of absorption factors and transfer coefficients
2. Mammalian, human, and interspecies toxicosis correlations
3. Toxic substance degradation rates within the media
4. Synergism
5. Determination of ambient background levels
6. Determination of media transfer coefficients
7. Comprehensive synthesis of existing data
8. Structure/activity correlations
9. Determination of factors controlling bioaccumulation
10. Adsorption coefficient for soils and sediments
11. Standardization bioassoy methodologies
Advancing the state-of-the-art in these major areas would substantially aid
in the defendability of RQs assigned pursuant to CERCLA on the basis of their
propensity to cause harm.
Hazard Index
If the concept of hazard is to be considered in setting reportable quantities,
an alternative strategy which accomplishes this is utilization of a hazard index.
The hazard index is an objective scoring system designed to assess the relative
potential threat to human health and to the environment of chemical substances
released to the air, water (both surface waters and groundwater) and soil.
The system consists of various rating factors used to examine the types of
hazards that may result and, to the extent possible, the potential degree
of hazard. Each rating factor has a defined rating scale by which substances
receive numerical scores based on known data. The rating factors are combined
in an equation to arrive at a sirgle unitless number that is used to rank a
chemical relative to other chemicals processed through the same equation.
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Under this strategy, the hazard index rating values would serve as
a basis for RQ assignment. The hazard index rating value would be grouped
and tied to specific categories of RQs based on "best engineering judg-
ment" in a manner similar to and consistent with the judicially approved
list pursuant to Section 311 of the Clean Water Act (CWA). Generally, the
higher the HI value, the lower will be the corresponding RQ, as shown in
Table 6-1. The HI values presented in this table are used only for the
purpose of example and are not associated with any specific rating system.
The actual link between HI and RQ can only be established after a par-
ticular equation is chosen.
While this strategy is not necessarily the most implementable and
justifiable, it offers the following advantages: (1) the hazard index can
relate to all media; (2) it can include a wide range of criteria that link
a substance to a concept of hazard; (3) it can provide an impartial,
objective, and uniform rating mechanism which can be applied to a wide
variety of hazardous substances; (4) it is a simple and direct way to
evaluate a large data base with respect to Intrinsic properties; (5) it
relies on what is known about a substance and therefore, it presumes a
substance to be "innocent until proven guilty"; and finally, (6) the HI
system of rating hazardous substances will allow administrative discretion
to adjust RQ values on a caseby-case basis, depending upon production
volume, geographical distribution, or other considerations.
The primary disadvantage of the hazard Index approach 1s that there
is no single, absolute, and scientifically acceptable hazard Index which
can be applied. The rating of hazardous substances can be accomplished in
a number of ways, and by the use of any number of criteria. Hazard rating
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TABLE 6-1
ASSIGNMENT OF RQs TO HAZARD INDEX RATINGS
HI RQ
50
X
1 lb.
40
A
10 lb.
30
B
100 lb.
20
C
1000 lb.
10
D
5000 lh.
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values, and consequently relative rankings, can vary widely since dif-
ferent equations proceed from different definitions of hazard. For this
reason, the hazard index introduces elements of subjectivity and decisions
may result from personal preference, creating disagreement at various
levels of review. Other disadvantages of the hazard index approach are:
(1) the hazard index must rely on judgemental considerations to link the
HI ratings to RQ assignments*, (2) in cases where the data base is limited
and data are missing, the hazard index does not measure degree of potential
hazard; (3) rating values are on a nonlinear scalei (4) because of limita-
tions in the available data base, the hazard index does not measure chronic
toxicity; and (5) the hazard index does not measure difficulty of cleanup,
the public perception of hazard, exposure and distribution, or other
considerations that may be pertinent in specific spill or exposure situations.
Four alternative equations which have been derived in this study for
rating hazardous substances are shown in Table 6-2 and are discussed in
greater detail in Appendix E. These alternatives differ in logic and in
the number of potential health and environmental effects rating factors
considered. The rating factors which have been considered in the develop-
ment of each equation are also shown below each equation 1n Table 6-2.
The approach taken during this study was to select criteria for
evaluation of hazardous substances 1n such a way that the most Important
health and environmental effects were Included for conslderation? The
criteria which have been considered to a greater or lesser extent in
development of each of the four alternative equations fall Into four
general categories as outlined below:
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TABLE 6-2. ALTERNATIVE HAZARD INDEX EQUATIONS AND RATING FACTORS
EQUATION 1
HI * (Carcinogenicity) ~ (Mutagenicity) + (Teratogenicity) + (Human Toxicity) + (Manmallan Toxicity)
cr>
ut
o
EQUATION 2
HI ¦ {HealtN Effects) + (Welfare Effects) + (Aggravating Effects)
. Carcinogenicity
. Mutagenicity
. Teratogenicity
. Human Toxicity
. Manmallan Toxicity
HI = [(Health Effects)
. Carcinogenicity
. Human Toxicity
. Manmallan Toxicity
Fl amiability
Exploslvity
Corroslvlty
Reactivity
Persistence
Bioaccumulatlon
Toxic Combustion
Products
EQUATION 3
x (Aggravating Health\ + (Welfare Effects)]
» F»rfnr« '
Factors
. Bioaccumulatlon
. Persistence
. Flammablllty
. Exploslvity
. Corroslvlty
. Reactivity
(Mitigating Effects)
. Innocuous Trans-
formation Products
. Evaporation Potential
/Aggravating/Mitigating \
'Transformation Products'
. Mitigating (Innocuous
Products)
. Aggravating
(Hazardous Products)
EQUATION 4
HI = (Health Effects) + (Welfare Effects) +
. Carcinogenicity
. Mutagenicity
. Teratogenicity
. Toxicity
- Inhalation
- Ingestion
- Dermal
. Ignltabillty
. Reactivity
. Aquatic Toxicity
( Environmental
1 Mobility
. Volatility
. Solubility
\ + / Aggravating \
' VCharacteristics '
Characteristics
fiioaccumulation
Persistence
-------
A. Health Effects
o Carcinogenicity
o Mutagenicity
o Teratogenicity
o Toxicity (Human and Mammalian)
B. Human Welfare Effects
o Flammability
o Explosivity
o Corrosivity
o Reactivity
o Aquatic Toxicity
C. Aggravating Characteristics
o Persistence
o Bioaccumulation
o Toxic Combustion Products
D. Physical and Biological Transformation Characteristics
o Hydrolysis
o Photolysis
o Oxidation
o Biolysis
E. Environmental Mobility
o Volatility
o Solubility
Basically, five steps were followed in developing the HI:
1. Determine the technical^criteria
2. Derive alternative equations
3. Establish appropriate rating scales for the rating factors
4. Test each equation on a selected list of 27 substances
5. Provide a final ranking list
6-31
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Table 6-3 presents for each of the 27 test substances (arranged alpha-
betically) the HI values calculated using each of the alternative equations.
Column I lists the values obtained from the first equation. Column Ila lists
the values obtained from the second, without using weighting factors, and
Column lib lists the values obtained from the second using various weighting
factors. Columns III and IV list the HI values obtained from the third and
fourth alternative equations respectively. The larger the HI value, the
more hazardous a substance is.
For the purpose of comparison, Figure 6-1 presents graphically the range
and the variance in the relative rankings for each hazardous substance. The
equation from which each data point was taken is denoted. The range of
differences in the relative rankings obtained by the various alternative
equations can be quite large. However, in several cases, the relative rankings
fall fairly close together (i.e., acrolein, benzene, carbon disulfide, carbon
tetrachloride, chloroform, nitric acid, and PCB's). It is clear from this
figure that the relative ranking of chemicals depends very much on the number
of selected criteria and the emphasis placed on these criteria in each equation.
The relative rankings of the 27 hazardous substances are summarized in Table E-21
of Appendix E according to the alternative equations.
Combined Approach
To assign RQs based on a hazard index and to "fine tune" the rankings on
a case-by-case basis using programmatic options designed to incorporate
administrative feasibility and practicality into the decision-making process
is a viable strategy for meeting the regulatory objectives. This "combined"
approach could be employed in the following manner.
6-32
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TABLE 6-3
HAZARD INDEX SCORES DETERMINED FROM THE ALTERNTIVE EQUATIONS
I
Ila
lib
III
IV
Acetyl Bromide
3
24
49
26
14
Acetylene
3
14
29
18
16
Acrolein
10
25
109
28
27
Acrylonitrile
8
23
69
26
30
Amnonium Bichromate
7
16
61
17
20
Benzene
7
18
63
20
18
Benzidine
9
13
74
10
18
Benzo(a)pyrene
7
9
48
3
12
B1s(2-ethylhexyl)phthalate
7
8
44
2
16
Carbon Disulfide
11
26
105
27
29
Carbon Tetrachloride
9
22
93
26
26
Chloroform
11
24
105
29
24
DOT
8
15
79
18
19
Heptachlor Epoxide
9
11
60
6
13
Methyl Chloride
4
21
47
24
17
Nitric Acid
8
18
74
21
20
N-Nitrosodimethylamine
12
19
121
12
18
PCB's
5
14
58
10
14
Phenol
6
18
68
18
18
Phosgene
8
19
79
20
14
Phosphorus (White)
11
31
122
41
20
Potassium Permanganate
4
10
30
12
16
Sodium Amide
3
18
35
28
19
Sodium Dichromate
9
17
74
20
22
2,4,6-TNT
2
14
32
15
12
Vinyl Chloride
8
23
67
26
26
Vlnylidene Chloride
8
20
66
21
23
RANGE OF VALUES
Low
2
8
29
2
9
High
12
31
122
41
30
6-33
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FIGURE 6-1. VARIANCE IN THE RELATIVE RANKINGS OF SELECTED HAZARDOUS SUBSTANCES
ZB
V
2«>
XA
26'
U-y
J
i i ) 1
1
c
/,? 8
-2A
20
3
26
.IB
to
-4
X!
-4-
;?z
X6
,*-8
-'3
,2*3
,V
—I 1 b
-------
First, substances could be screened for the purposes of designation,
and those qualified hazardous substances could be uniformly rated by use of
a multicriteria hazard index designed to establish potential degrees of hazard
(see discussion on Hazard Indices above.) As with any rating scheme, data
gaps and the choice of the selection criteria will allow certain substances to
be rated imprecisely relative to their "absolute" hazard potential. However,
the hazard index will provide a uniform and basic rating methodology that can
be augmented by case-by-case consideration of other criteria. Using data that
define the practical or "real world" considerations pertaining to a substance's
use, distribution, and general "profile", etc., would allow RQ ranks to be
adjusted up or down based on the exercise of the broad discretionary powers
allowed the Administrator under the Act. Such case-by-case assessment could
be related to (1) extent of a substance's geographic distribution, (2) production
volume, (3) most probable mode of transport, (4) type and volume of container!'zation,
(5) amount of typical bulk shipments, (6) spill history, (7) special scientific
considerations, e.g., extreme carcinogenicity, and (8) other considerations that
reflect a substance's perceived hazard with respect to the interested community.
The choice of criteria for this "fine-tuning" are related primarily to
the assessment of a substance's exposure potential or spill risk, the size or
amount of typical release, and perceived hazard that is suspected, but not
conclusively proved with respect to the public and the scientific community.
Case-by-case assessment of these types of considerations would allow the
Administrator to exercise broad flexibility and discretion and, at the same
time, be responsive to a hazard indexing scheme that allows an evaluation of
what is actually known about a substance's potential hazard. In short, there
appears to be "something for everybody" in this approach.
6-35
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Another way of applying this strategy would be to employ the basic criteria
selected for use in the hazard index in the designation phase as a series of
"on-the-list," "off-the-1ist" decisions. Once the list has been compiled,
case-by-case assessment of RQs using the Administrator's best judgment as to
what RQ rank should be set, using the previously mentioned criteria, could also
be a viable option (see Strategy 6 below).
The advantage of the "combined" approach is that it allows a rational
method of blending available data related to hazard potential with other criteria
related to a substance's "real world" use. As the final assignment of RQs is
a process of "fine tuning" on the basis of "real world" considerations related
to administrative feasibility, flexibility is maintained even though known
data related to a substance's propensity for harm is assessed in a uniform and
consistent manner by means of a rating scheme. This flexibility, justified
under the guise of the broad discretion afforded the Administrator to assign
RQs, has as its base a rating scheme that considers only what is known about
a substance's hazard potential. It presumes a substance to be "innocent until
proven guilty" and does so in a verifiably consistent and well precedented
manner.
The disadvantage is that the nature or lack of available data related to
hazard potential may result in inadequate resolution between substances that
may indeed have vast differences in their relative potential for causing harm.
In addition, RQ assignments will be made practically on arbitrary considerations
of concepts not directly related to hazard potential.
Selective Criteria Processing
An alternative approach to the hazard index aid linking the HI to an RQ
would be to base RQ assignments on either individual criteria or a combination
of criteria that allow segregation of substances into separate categories. This
could be done in one of three ways.
6-36
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In the first, the RQ assignments could be based primarily on a single
health effect criterion such as mammalian toxicity. Specific categories of
RQs (say, 1, 10, 100, 1000, 5000 lb) could be established for specific ranges
of mammalian toxicity (i.e., oral rat LD5q data) as was similarly done under
Section 311 of the Clean Water Act which used aquatic toxicity exclusively.
The advantages of this approach are: (1) it is simple and less compli-
cated than the HI system; (2) it relates to some subjective link to potential
harm to human health; and (3) it allows for broad administrative feasibility
and practicality considerations to be incorporated in the assignment of the
RQ categories. The major disadvantage of this approach, however, is its
reliance on a single criterion which is subject to the limitations and validity
of the available data base. Also the implied extrapolation from experimental
animal data to human effects is fraught with uncertainties. Finally, it ignores
potential hazards to other ecological populations as well as hazards that are
not related to toxicity.
In the second option, a selected set of hazard criteria (i.e., carcinogenicity,
mammalian toxicity, ignitability, reactivity, and aquatic toxicity) could be
associated individually with categories of RQs following the RQ framework
established under Section 311 of the CWA. For example, specific categories of
RQs (say 1, 10, 100, 1000, 5000 lb) would be established for specific ranges
of mammalian and aquatic toxicity, specific flammability ratings, specific
reactivity ratings, etc. The RQ category assignments are based on "best
technical judgment" and assessment of the reporting levels necessary for the
Federal government to respond to. The final RQ for each designated substance
could then be determined either from the arithmetic average or a weightec average
of the individual RQs assigned by each criterion.
6-37
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The third option involves a limited set of hazard criteria which are
prioritized in a sequential "gating" mechanism as shown in Figure 6-2.
The criteria are prioritized as follows: carcinogenicity > toxicity >
explosivity > flammability reactivity. The toxicity component is subdivided
into two categories: (1) acutely toxic (LD5q <50 mg/kg), and (2) toxic
(LD^q - 50-500 mg/kg). To use this approach, the first question asked is:
"Is the designated substance carcinogenic?" If the data indicate the substance
to be a positive carcinogen or it is reasonably suspected based on scientific
evidence, then the RQ assignment would be automatically made into a low cate-
gory (e.g., 1 lb) and the other criteria need not be considered. The rationale
for this first step is that carcinogens are a special category of hazardous
substances with no known threshold levels. The concern of the interested
community is such that carcinogens should be regulated in a more stringent
manner than substances which are hazardous for other reasons. If the substance
was determined not to be carcinogenic, then it must be classified as to whether
it was toxic (LD5Q 50-500 mg/kg) or acutely toxic (LD5q < 50 mg/kg). If it
proved to be acutely toxic, then the RQ assignment would again automatically be
made into a generally low RQ category (e.g., 10 lb). For such acutely toxic
substances it would not be necessary to consider the remaining criteria (explo-
sivity, flammabilty, reactivity). Finally, if the substance was not carcinogenic
but its toxicity was of reasonable concern, an initially high RQ would be
assigned (e.g., 5000 lb) and this RQ could then be adjusted after evaluation of
its explosive potential, flammability, potential, and reactivity. That is, if
the substance was only toxic, its RQ might be assigned in the 5000 lb category.
If it was toxic and also explosive, flammable, and highly reactive, the 5000 Id
RQ could be lowered, say to 10 lb. If it was toxic and explosive, its RQ might
be adjusted say to 100 lb. If it was toxic, flammable, and reactive, its RQ
could be assigned to the category of say, 1000 lb.
6-38
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FIGURE 6-2
EXAMPLE DIAGRAM OF CRITERIA PRIORITIZATION
Is the Designated
Substance Carcinogenic?
No
V
Toxic
(LD5Q 50-500 mg/kg)
Acutely Toxic
(LD50 < 50 mg/kg)
5000 lb. RQ
10 lb. RQ
Further
Evaluation
>r
Toxic
Explosive
Flammable
Reactive
Toxic
Explosive
Toxic
Flammable
Reactive
10 lb. RQ
100 lb. RQ
1000 lb. RQ
1 lb. RQ
6-39
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Chemical Manufacturers Association (CMA) Strategy
The strategy proposed by the Chemical Manufacturers Association (CMA) to
the EPA on May 28, 1981, for revising the l-1b. RQs is based upon the existing
RQ framework established under Section 311 of the Clean Water Act (40CFR117)
which is based solely on aquatic toxicity. It begins by grouping hazardous
substances regulated by other laws, particularly the Resource Conservation and
Recovery Act (RCRA), into categories, and then analyses the substances in these
same categories which have RQs established under Section 311 of the CWA. Using
this generic approach, an RQ is established for the particular hazardous
substance category.
The following categories of hazardous substances or wastes were analyzed
for purposes of revising the 1 lb. RQ.
o The P-List (acute hazardous wastes) of RCRA (Section 261.33(e)).
o The U-List (toxic wastes) of RCRA (Section 261.33(f)).
o The four characteristics established by RCRA for identifying hazardous
wastes that are not listed wastes:
Ignitabllity (Section 261.21)
Corrosivity (Section 261.22)
Reactivity (Section 261.23)
EP Toxicity (Section 261.24)
o The F- and K- Lists of RCRA (Section 261.31 and Section 261.32).
o Toxic water pollutants listed under authority of Section 307 of the
Clean Water Act which are not Identified as hazardous substances
under 311-CWA or hazardous wastes under Section 261 of RCRA.
For the elements listed as toxic pollutants, CMA utilizes 311-CWA RQs
for compounds containing those elements, as technical guides for deriving
6-40
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the RQs for those elements. The use of elemental compounds as guides can
result in serious underestimation of the toxicity of the hazardous substance
involved.
The proposed revisions for the P-list and U-list of RCRA were based on
further categorization for those compounds as pesticides and non-pesticides.
Weighted average RQs for such categories were calculated for the 311-CWA
substances and assigned for the non-311-CWA substances on the P- and U-Lists.
A similar approach using other pertinent characteristics was used to derive
revised RQs for the other categories of hazardous substances.
Although the rationale of the CMA strategy is clearly stated and the RQ
adjustments are logically made for the assumptions given, such an approach is
not entirely justifiable since the 311 RQs are based entirely on aquatic
toxicity (i.e., on tests on species such as fathead minnow and brine shrimp)
which bears no known relation to human toxicity. Also, aquatic toxicity is not
the most relevant concern for a spill on permeable soil overlying an important
aquifer near a human population. The assignment of RQs should be more directly
related to a health component to reflect congressional Intent.
Besides relying too heavily on aquatic toxicity, the CMA approach 1s
scientifically inaccurate. As is pointed out 1n the Environmental Defense
Fund's evaluation of this strategy (EDF, July 17, 1981):
...the approach used by CMA 1s predicated on the assumption that a separa-
tion of pesticides and non-pesticides 1s scientifically valid and that a
weighted average for these two artificially created groups accurately
reflects the distribution of RQs within each group...there is substantial
overlap between 311-CWA RQs for pesticides and non-pesticides on the "P"
and "U" lists. Thus the separation of the "P" and "U" lists Into two
classifications 1s arbitrary and has no reasonable relationship to the
toxicity of particular substances. In addition, the RQs for both pesticides
and non-pesticides 1n the 311 11st vary widely and do not fall intoT
normal distribution. Thus, a weighted average Is an 1napproorlate"repre-
sentation of either class.
6-41
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If this type of approach were to be used, however, other characteristics
which reflect a human health component (i.e., carcinogenicity, human or
mammalian toxicity, etc.) should be included in the analysis.
ISSUES RAISED BY RQ STRATEGIES
1. How can a consensus be established that will allow the forthcoming
regulation to be founded on an RQ linked to a hazard index?
There are no certain answers to questions of this nature. However, adequate
precedent for linking RQs to an indexing system has already been established
pursuant to Section 311 of the Clean Water Act. At the core of the system, RQ
ranks are assigned on the basis of a hierarchy of aquatic toxicity ratings for
CWA designated hazardous substances. In this case, the link that established
the equivalence between an RQ category and a toxicity category was the philo-
sophy that discharges of the most toxic substances should require reporting
based on quantities equivalent to the smallest amounts commercially packaged
(one pound). Since toxicity is assumed to increase logarithmically, establish-
ment of the other RQ categories followed in kind. Regulations established
under Section 311 of the CWA have been successfully implemented and provide
some reassurance that a CERCLA regulation founded on the same basic principles
will have similar success.
Although CERCLA is different from the CWA in many respects, the underlying
concepts with regard to RQs are essentially the same. The differences are
manifest mainly in the latitude and discretion afforded the Administrator to
assign an RQ based on criteria not directly linked to a substance's potential
for causing harm. With this legislative foundation, linking a hazard index
category to a RQ category based on a similar philosophy established under
Section 311 of the CWA is decidedly a viable option.
6-42
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2. Should Reportable Quantities vary depending on Environmental Medium?
The statutory text of CERCLA allows, but does not require, the determination
of a single RQ without regard to the medium into which the hazardous substance
may be released. Upon analysis of the legislative history, however, it seems
reasonably clear that Congress intended that the CERCLA reportable quantity (RQ)
be a single, multimedia RQ determined without regard to the circumstances
surrounding the release. As stated in the legislative history documented in
the Senate Report of the Committee on Enviornment and Public Works that accom-
panied the Senate version of CERCLA, S 1480:
...A single quantity is to be determined for each hazardous substance, and
this single quantity requires notification upon release into an^ environ-
mental medium. It would virtually be impossible to determine a single
quantity applicable to all media while at the same time linking such
quantity to any subjective concept of harm. (Emphasis added.)
The legislative history further states that:
...It is essential that such quantities be relatively simple for those
subject to notification requirements to understand and comply with...and
that Administrative feasibility and practicality should be primary
factors.
In light of Congressional intent and in the spirit of the present Adminis-
tration's regulatory relief philosophy, reportable quantities which vary
depending on environmental medium are not necessary and should not be assigned.
Beyond these considerations, such an approach would be even more difficult from
a technical veiwpoint because it requires a further resolution in the causative
link to harm, which is not supported by the available data base on fate and
effect of hazardous substances.
3. What about the economic effects of assigning various RQs for designated
substances?
The exact economic effects of assigning various RQs for designated substances
cannot be stated at the present time without performing a sensitivity analysis
on the economic Impact. ICF, Inc. is actively working toward a resolution of
this Issue. However, 1t would be reasonable to assume that such a regulatory
strategy may be too costly to Implement and could result in a great deal of
confusion or opposing points of view.
6-43
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REFERENCES
Chang, S., K. Barrett, S. Haus, arid A. Piatt, 1981; Site Ranking Model for
Determining Remedial Action Priorities Among Uncontrolled Hazardous Substances
Facilities: The Mitre Corporation.
Cleland, J. G. & Kingsbury, J. L., 1977; Multimedia Environmental Goals for
Environmental Assessment, Vol. 1: U.S. EPA Report No. 600/7-77-136a.
Dacre, J. C., Rosenblatt, D. H., and Cogley, D. R., 1980; Preliminary Pollu-
tant Limit Values for Human Health Effects: Environmental Science & Technol-
ogy, Vol, 14, No. 7, pp, 778-788.
Doll R. and R. Peto, The Causes of Cancer: Quantitative Estimates of Avoid-
able Risks of Cancer in the United States Today: J. National Cancer Institute
1981, summarized in Chemical & Engineering News, August 17, 1981, pp. 32-34.
Handy, R. and Schindler, A., 1976; Estimation of Permissible Concentrations of
Pollutants for Continuous Exposure: EPA Report No. 600/12-76-155, p. 61.
Hann and Jensen, 1977; Water Quality Characteristics of Hazardous Materials:
Texas A & M University.
Institute of Medicine, 1981; Costs of Environment-Related Health Effects: A
Plan for Continuing Study; National Academy Press, Washington D.C., p. 9.
Kanaga, E. E. & Goring, C.A.I., 1978; Relationship Between Water Solubility,
Soil Sorption, Octanol-Water Partitioning & Bioconcentration of Chemicals in
Biota: American Society of Testing Materials, 3rd Aquatic Toxicology Sympo-
sium, New Orleans, Louisiana.
Karickoff, S. W., Brown, D. S., & Scott, T. A., 1978; Sorption of Hydrophobic
Pollutants on Natural Sediments: EPA Internal Report, Environmental Research
Laboratory, Athens, Georgia.
Kufs, C., et al., 1980, Methodology for Rating the Hazard Potential of
Waste Disposal Sites: JRB Associates, Inc., May 5.
LeGrand, H. E., and H. S. Brown, 1980, Evaluation of Ground Water Contamina-
tion Potential from Waste Disposal Sources.
LeGrand, H. E., 1980; A Standardized System for Evaluating Waste Disposal
Sites, National Well Water Association.
Leo, A., Hansch, C., and Elkins, D., 1971; Partition Coefficients and Their
Uses: Chemical Reviews, Vol. 71, No. 6"," pp. 525-555.
Loomis, T,, 1974; Essentials of Toxicology; Lea & Febiger, Philadelphia.
Murphy, S. D., 1978; Toxicolog-ical Dynamics: In: Dynamics, Exposure and
Hazard Assessment of Toxic Chemicals: R. Hague, editor. Ann Arbor Science
Publishers, Ann Arbor, Michigan, 496 pp.
6-44
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National Fire Protection Association (NFPA), National Fire Codes, Vol. 13,
No. 49, 1977.
Reif, A. E., 1981; The Causes of Cancer: American Scientist, Vol. 69, 438-
447.
Ross, Robert H., and Paul Lu, 1981; Chemical Scoring System Development: U.S.
Environmental Protection Agency, Chemical Scoring System Development (Draft)
Washington, D.C., Interagency Agreement No. 79DX0856.
Sax, N. I., Dangerous Properties of Industrial Materials, 5th Ed., 1979.
State of Michigan Department of Natural Resources; 1980; Critical Materials
Register. Environmental Protection Bureau. Pub. 48335324.
Stoll, D. R., 1970; 4th Symposium on Loss Prevention, Vol. 4, p. 16.
U.S. Coast Guard, 1973; Evaluation of the Hazard of Bulk Water Transportation
of Industrial Chemicals; Report No. AD 775756.
Walsh, P. J., Killough, G. G., & Rohwer, P. S., 1978; Composite Hazard Index
for Assessing Limiting Exposures to Environmental Pollutants: Formulations
and Derivation: Environmental Science & Technology, Vol. 12, No. 7, pp. 799-
807.
6-45
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SECTION 7
RADIONUCLIDES
INTRODUCTION
The legislative history makes it clear that the inclusion of radionuclides
as hazardous substances under Superfund (CERCLA) did not occur by happenstance.
Although radionuclides are included in the definition of hazardous substance
in Section 101(14)e because they constitute one of the materials named as a
hazardous air pollutant pursuant to Section 112 of the Clean Air Act, radio-
active materials were discussed explicitly early in the legislative develop-
ment. Mention of the Atomic Energy Act of 1954 in connection with the defini-
tion of "release" in Section 101(22) further supports the conclusion that the
legislative intent was to include radionuclides under Superfund, at least
under some circumstances.
The authority to designate radionuclides as hazardous substances and,
therefore, assignment of RQs arises from Including in Section 101(14)e of
Superfund "any hazardous air pollutant listed under Section 112 of the Clean
Air Act."
The response authority of CERCLA expressly excludes two types of radio-
active releases that are subject to financial protection or remedial action
directives under prior law (Entwisle, 1981):
o Release of any source, by-product, or special nuclear material from
a nuclear incident "subject to" financial protection requirements
established under SI70 of the Atomic Energy Act (AEA).
o Release of any source, by-product or special nuclear material from a
site designated under the Uranium Mill Tailings Radiation Control
Act of 1978.
7-1
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This section is divided into three parts. The first part pertains to
EPA's legislative jurisdiction for inclusion of radionuclides into Superfund.
The legislative analysis was primarily developed by the Environmental Law
Institute (Entwisle, 1981) under contract to Rockwell International. Also
included in this part is a draft list of designated radionuclides. The second
part presents a discussion of existing regulatory responsibilities and notifi-
cation mechanisms for emergency response activities. A suggested notification
approach for Nuclear Regulatory Commission (NRC) or agreement state licensees
is through an interagency or intergovernmental system- rather than direct
notification from the responsible party to the National Response Center (NRC-
II)*. However, for materials such as naturally occurring and accelerator-
produced materials (NARM), direct notification would be required due to the
nonuniformity of regulatory controls. The third part is devoted to the
development of Reportable Quantities (RQs) for radionuclides. This part is
subdivided into three main topics: (1) Development of an emergency response
notification level, (2) methodology establishment for RQs, and (3) issues
concerning radionuclides and Superfund.
LEGISLATIVE JURISDICTION
Inclusion/Exclusion of Radionuclides in Superfund
Section 101(14) defines "hazardous substances" covered by Superfund as
"...any hazardous air pollutant listed under Section 112 of the Clean Air
Act..."
* In this section, NRC means the Nuclear Regulatory Commission. The National
Response Center is abbreviated NRC-II.
7-2
-------
Section 112 of the Clean Air Act defines a "hazardous air pollutant" as
"an air pollutant to which no ambient air quality standard is applicable and
which in the judgment of the Administrator causes or contributes to, air
pollution which may reasonably be anticipated to result in an increase in
mortality or an increase in serious irreversible, or incapacitating reversible
illness."
Section 122(a) of the Clean Air Act directed EPA to study radioactive
pollutants (including source materials, special nuclear material, and by-
product material), cadmium, arsenic and polycyclic organic matter and their
effects, "...in ambient air to determine whether they cause or contribute to
air pollution which may reasonably be anticipated to endanger public health."
Therefore, Section 112 and 122 of the Clean Air Act allowed for the inclusion
of radionuclides, generally, into coverage by Superfund.
Federally permitted releases are exempt from Superfund1s notification and
penalty mandate as stated in Section 103(a). Section (101)(10) defines "fed-
erally permitted release" as..."(k) any release of source, special nuclear, or
by product material, as those terms are defined in the Atomic Energy Act of
1954, in compliance with a legally enforceable license, permit, regulations or
order issued pursuant to the Atomic Energy Act of 1954."
In Section 101(22), Superfund defines releases as "any spilling, inject-
ing, escaping, leaching, dumping, or disposing into the environment, but
excludes ...(c) release of source, by-product, 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 (author's emphasis added) 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 this Title or any other response action, any release of source, by-product
7-3
-------
or special nuclear material from any processing site designated under Section
102(a)(1) or 302(a) of the Uranium Mill Tailings Radiation Control Act of
1978,..."
Radioactive releases that are not specifically excluded under these
provisions could be subject to CERCLA's response authority.
Excluded Radioactive Releases
Two major sources of radioactive releases are exempt from CERCLA's re-
sponse authority: (1) releases of source, by-product or special nuclear
material that result from a "nuclear incident" which, is "subject to" financial
protection under SI70 of the AEA otherwise known as the Price Anderson Act, or
(2) releases from any processing site designated under SI02(a)(1) or 302(a) of
the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA).
Atomic Energy Act - Section 170
Section 170 of the Atomic Energy Act (AEA), otherwise known as the Price
Anderson Act, established a system of Government indemnity and license condi-
tions requiring certain licensees to have financial protection for damages
caused by nuclear incidents (42 FR 46).
Nuclear incident is defined in ST 1(a) of the AEA as:
...any occurrance, including an extraordinary nuclear occurrence, within
or outside the United States, causing bodily injury, sickness, disease,
or death, or loss of or damage to property, or loss of use of property,
arising out of or resulting from the radioactive, toxic, explosive, or
other hazardous properties of source, special nuclear, or by-product
material.
It appears from this definition that to constitute a "nuclear incident,"
a release of source, special nuclear, or by-product material must at a minimum
cause bodily injury or damage to property. Releases which damage only certain
natural resources would not necessarily be considered nuclear incidents since
such resources may not be viewed as "property" in the traditional sense of
7-4
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"ownership," legal title, or the exclusive right of possession and enjoyment.
Thus, only those releases of source, by-product, or special nuclear material
which cause bodily harm or property damage may be excluded from CERCLA,
because these could be considered nuclear incidents (Entwisle, 1981).
In addition, to be excluded from CERCLA4s definition of a release under
SI01(22)(c) • a nuclear incident must be "subject to" financial requirements
under SI70 of the AEA.
Section 170(a) states that each license issued under Section 103, which
is concerned with production and utilization facilities (nuclear reactors);
Section 104, that pertains to utilization facilities for use in medical ther-
apy, and utilization and production facilities useful for research and develop-
ment activities; and Section 185, that affects licenses to construct or modify
production or utilization facilities, shall maintain financial protection to
cover public liability claims.
Therefore, releases of source, by-product, or special nuclear material
from these licensees and fuel reprocessing plants (SI70(c)) are beyond CERCLA's
response authority.
All other phases in the fuel cycle under NRC's jurisdiction are regulated
by materials licenses for source, special nuclear material (SNM) and by-
product material. These licensees are not statutorily required to have financial
protection as a license condition
It has been the NRC's policy to require financial protection under SI70
of the AEA as a condition of materials licenses for plutonium processing and
Plutonium fuel fabrication facilities with inventories equal to or above
designated quantities (42 FR 46). There are currently five such facilities in
existence (Entwisle, 1981).
7-5
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There are two possible interpretations of CERCLA's coverage of such
releases: (1) CERCLA's response authority excludes only releases from materials
licensees that, in fact, must maintain financial protection under the AEA, or
(2) CERCLA excludes al1 source, by-product, or special nuclear releases from
materials licensees since the NRC may require any material licensee to main-
tain financial protection. Under this latter interpretation, all releases of
such radioactive substances from material and facilities licensees would be
excluded from CERCLA's response authority provisions (Entwisle, 1981).
The legislative history of Section 101(22) of CERCLA explains the exclu-
sion and suggests that CERCLA include radioactive releases that may maintain
financial protection but do not in fact do so, _ Successive drafts of the
Senate bill enlarged the exclusion of nuclear releases from CERCLA's response
authority. The earliest printed version of the bill contained no exclusions
from the definition of release (S1480a). A subsequent draft excluded from
"release" those releases that "result in liability under Section 170 of the
(AEA) under a waiver of defenses specified in Subsection n of such section
(SI480b)." This amounted to excluding from CERCLA's response authority only
those releases from extraordinary nuclear occurrences (ENOs) (the most severe
type of nuclear incident under the AEA). An even later draft excluded from
CERCLA a nuclear release, "to the extent such release is covered by financial
protection required...under Section 170 of (the AEA)." (emphasis added)
(S1480c). This language excluded releases from any_ nuclear incident (not
just an ENO) "to the extent" it was covered by financial protection. In
addition, the language of this later draft suggested that only those releases
that were, in fact, covered by financial protection would be excluded (at
least partially) from CERCLA (Entwisle, 1981).
7-6
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The current statute excludes releases from nuclear incidents if they are
"subject to" financial protection requirements under the AEA. Therefore, the
key modification requiring elucidation occurred in the last two drafts of the
bill, where the definition of excluded release changed from those "covered by"
financial protection requirements to those "subject to" such requirements
(Entwisle, 1981).
Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA)
The second exclusion in SI01(22)(c) of CERCLA, pertains to radioactive
releases from mill tailings sites. The provision states:
...release...excludes...(c)...for purposes of Section 104 of this title
or any other response action, any release of source, by-product or special
nuclear material from any processing site .designated under Section 102(a)(1)
or 302(a) of the Uranium Mill Tailings Radiation Control Act of 1978.
This phrase states that the sites identified in UMTRCA are excluded from
remedial/removal activities but not from the notification requirements.
SI02(a)(1 ) of UMTRCA lists approximately 20 locations at which the Secre-
tary of Energy must designate processing sites for remedial action. It also
gives the Secretary the discretion to designate additional sites for such
action. Furthermore, S302(a) of UMTRCA gives the Secretary of Energy the
discretion, if the NRC determines that the public health, safety, and environ-
ment cannot otherwise be protected, to designate two specific processing sites
for remedial action.
Pursuant to the authority granted in UMTRCA, the Secretary, of Energy in
1979 designated 25 inactive uranium processing sites. Releases of source, by-
product or special nuclear material from any of these 25 processing sites are
excluded from CERCLA's response authority (00E, 1979).
Naturally Occurring and Accelerator Produced Materials (NARM)
It should be noted with respect to both the AEA and UMTRCA exclusions,
that source, by-product, and special nuclear material do not include all radio-
7-7
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active substances. Some "naturally occurring" radioactive materials (e.g.,
radium, radon, and daughters) and man-made radioactive materials (e.g., pro-
duced in accelerators or cyclotrons) are not included in the definition of
source, by-product, or special nuclear material. Thus, they would not be
excluded from the definition of release under S101(22) of CERCLA, and EPA
would not be precluded from exercising response authority over such substances
(Entwisle, 1981).
Conflicts Between CERCLA and Price Anderson
The financial protection schemes of the two Acts seem to have different
purposes: CERCLA's scheme is set up to remove from the environment substances
that are hazardous to the public health and welfare and to restore the envi-
ronment to its previous condition, whereas, SI70 of the AEA was enacted to
cover liability claims (tort claims for bodily injury, property damage, etc.).
Thus, even if CERCLA's response authority exists for every radioactive release
not indemnified under the AEA, it is not certain that tort victims will be
able to recover damages (Entwisle, 1981).
Designation of Radionuclides Under Superfund
There are a number of facilities that use radioactive material but are
not production and utilization facilities and so are not required by regula-
tion to maintain financial protection for public liability. Since these
facilities and associated materials are excluded from Price Anderson, they
could be covered by Superfund. The other exclusions in Section 101(22)(c) of
Superfund are those 25 processing sites included in the Uranium Mill Tailings
Radiation Control Act (UMTRCA), Section 102(a)(1) and 302(a). These are the
only exclusion comments for radionuclides in Superfund. Therefore, naturally
occurring and accelerator-produced radioactive material (NARM) is also covered
7-8
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by Superfund, as mentioned above. Table 7-1 identifies the major types of
facilities and materials that could be covered by Superfund. Table 7-2 illus-
trates by use of a matrix the materials that are associated with the facili-
ties identified in Table 7-1. These materials are further detailed in a list
of designated radionuclides for Superfund in Table 7-3.
The list in Table 7-3 was developed based on the following criteria:
1. The radionuclides are used, generated, or stored in conjunction with
the facilities shown in Tables 7-1 and 7-2.
2. The radionuclides have a half-life greater than or equal to 7 days;
however, there are a few exceptions, e.g., Rn-222 and Mo99/Tc-99m.
3. The radionuclides are commercially" available isotopes and decay
products that meet the half-life criteria of number 2, above.
4. They are naturally occurring radionuclides and decay products that
meet the half-life criterion of number 2, above.
The 7-day half-life criterion was chosen to designate radionuclides that
could require possible Superfund response, since the need for response
activities would be limited for radionuclides with shorter half-lives (ap-
proximately 99% of a radioactive material decays within 7 half-lives).
Those radionuclides with a half-life less than 7 days that are on the
list are either widely used commercially, e.g., Mo-99/Tc-99m, or are readily
dispersed and have long-lived parents, such as Rn-222.
The mode of formation and/or use of the designated radionuclides is
depicted in Table 7-3.
7-9
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TABLE 7-1
FACILITIES COVERED BY SUPERFUND
Uranium Conversion Facilities
Low Level Waste Disposal Sites
Fuel Fabrication Facilities (Non-Plutonium)
Radioisotope Processing Facilities - Accelerator Produced
Spent Fuel Facilities/High Level Waste Disposal Sites
(may be covered by Section 170 at a later date)
Active Uranium Mills and Mines
(except those facilities exempt from Section 104
by Section 102(a)(1) and 302(a) UMTRCA)
Phosphate Industry
MATERIALS COVERED BY SUPERFUND
Source, by-product, Special Nuclear Material - (associated with
the above facilities)
Naturally Occurring and Accelerator-Produced Radioactive
Materials (NARM)
7-10
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TABLE 7-2
MATRIX OF MATERIALS TO FACILITIES COVERED BY SUPERFUND
Materials
Facilities
Accelerator
Natural
SNM
By-Product
Source
Waste Disposal
Sites
X
X
X
X
X
U-Conversion
Facilities
X
X
ll-Fabrication
X
X
Radiopharmaceutical
Accelerator
X
Active Uranium Mills
X
X
Active Uranium Mines
X
X
Phosphate Industry
X
7-11
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TABLE 7-3
RADIONUCLIDES SUBJECT TO DESIGNATION UNDER SUPERFUND
Mode of
Mode of
Radionuclides
Formation *
Radionuclides
Formation *
Ac-225
(N
Cm-245
(B
Ac-227
(N
Cm-246
(B
Am-241
(B
Cm-247
(B
Am-242
(B
Cm-248
(B
Am-243
(B
Er-169
(B
Sb-124**
(B
Eu-152
(B
Sb-125
(B
Eu-154**
(B
Ar-37
{A
Eu-155
(B
As-73
(A
(B)
Fe-55
(A
(B)
As-74
(A
(B)
Fe-59
(B
Ba-131
(B
Gd-153
(B
Ba-133**
(B
Ge-68
(A
Ba-140**
(B
Ge-71
(B
Bk-249
(B
Au-195
(A
Be-7
(A
(N)(B)
Hf-175
(A
Bi-206
(A
(B)
Hf-181
(B
Bi-207
(A
(B)
Ho-166m
(B
Cd-109
(A
Hg-203
(B
Cd-115m
(B
H-3
(N
(B)
Ca-45
(B
In-114m
(B
Ca-47
(B
In-115
{N
(B)
Cf-249
(B
1-125
(A
(B)
Cf-250
(B
1-129
(B
Cf-251
(B
1-131
(B
Cf-252
(B
(B)
Ir-190
(A
(B)
C-14
(N
Ir-192**
(B
Ce-139
(A
Kr-85
(B
Ce-141
(B
La-138
(N
Ce-142
(N
Pb-210
(N
Ce-144
(B
K-40
(N
Cs-131
(A
(B)
Lu-177
(B
Cs-135
(B
Lu-176
(N
Cs-136
(B
Mn-54
(A
(B)
Cs-137**
(B
Hg-203
(B
CI-36
(B
(B)
Nd-144
(B
(N)
Cr-51
(A
Nd-147
(B
Co-56
(A
Np-237
(B
Co-57
(A
(B)
Mo-99
(B
Co-58
(A
(B)
Ni -59
(B
Co-60**
(B
Ni -63
(B
Cm-242
(B
Nb-93m
(B
Cm-243
(B
Nb-95
(B
Cm-244
(B
Os-185
(B
7-12
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TABLE 7-3 (Continued)
Mode of Mode of
Radionuclides Formation* Radionuclides Formation*
OS-191
(B)
Pd-103
C A) (B >
P-32
(N)(B)
Pt-190
(N)
Pt-192
(N)
Pu-238
(SNM)
Pu-239
(SNM)
Pu-240
(SNM)
Pu-241
(SNM)
Pu-242
(SNM)
Pu-244
(SNM)
Pa-231
(N)
Pa-233
(N)
Po-208
(A)
Po-210
(N)(B)
Pr-143
(B)
Pm-147
(B)
Pa-231
(N)
Ra-223
(N)
Ra-226**
(N)
Ra-228
(N)
Rn-222
(N)
Re-183
(B)
Rh-102m
(A)
Rb-84
(A)
Rb-86
(B)
Rb-87
(N)(B)
Ru-103
(B)
Ru-106
(B)
Sm-147
(B)(N)
Sm-151
(B)
Sc-46
(B)
Se-75
(B)
Ag-105
(A (B)
Ag-llOm
(B)
Ag-111
(B)
Na-22**
(A)(N)
Sr-85
(B)
Sr-89
(B)
Sr-90
(B)
S-35
(N)(B)
Ta-182
(B)
Tc-96
(B)
Tc-97m
(A)(B)
Tc-97
(B)
Tc-99m
(B)(A)
Tc-99
(B)
Te-125m
(B)
Te-127m
(B)
Te-129m
(B)
Te-131m
(B)
Tb-160
(B)
11-200
(B)
Tl-201
(B)
T1-202
(A)(B)
T1-204
(B)
Th-227
(N)
Th-228
(N)
Th-230
(N)
Th-232
(N)
Th-nat;
(N)(S)
Th-234
(N)
Tm-170
(B)
Tm-171
(B)
Sn-113
(A)(B)
W-181
(B)
W-185
(B)
U-232
(B)
U-233
(SNM)
U-234
(N)
U-235
(SNM)
U-236
(B)
U-238
N)
U-nat &/or
U-depleted
jS)(N)
V-48
(A)(B)
Yb-169**
(B)(A)
Zn-65
(B)
Zr-93
(B)
Zr-95
(B)
*Mode of formation or use:
N - Natural
B - Byproduct
A - Accelerator
SNM - Special Nuclear Material
S - Source
-------
EXISTING REGULATORY CRITERIA FOR EMERGENCY ACTIVITIES
Introduction
Discussed herein are existing emergency response, notification, respon-
sibilities, and cost recovery mechanisms for the nuclear industry. The Nuclear
Regulatory Commission (NRC) requires immediate or 24-hour notification of the
conditions from an incident as outlined in 10 CFR 20.403(a) and (b). The NRC
recently required that certain licensees prepare on-site contingency plans for
actions to be taken in the event of an accident to limit off-site releases of
radioactive materials, among other purposes. The development of the plan
requires characterization of several classes of emergency situations and then
relates them to response levels.
The Environmental Protection Agency (EPA) developed protective action
guides (PAG's) to provide guidance to State, local, and other officials on
criteria to use in planning protective actions for radiological emergencies
that could present a hazard to the public.
The Federal Emergency Management Agency (FEMA) has developed the "Master
Plan" for incidents at nuclear power plants. This "Plan" includes agency
responsibilities, notification, and Federal response management mechanisms.
FEMA plans to begin development of similar types of "plans" for other nuclear
facilities within the next year. Basic emergency response mechanisms developed
for the nuclear power plants are discussed herein, for it is possible that the
basic notification mechanism for emergency response could be similar. The
notification, responsibilities of the involved parties, and cost recovery
mechanisms for transportation accidents are discussed. Finally, there is a
discussion of the possibility of including the Superfund notification scheme
within those that already exist or are about to be developed.
7-14
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Emergency Response--T.ypes of Situations
The general types of situations that would require possible emergency
response activities and notification can be categorized into accidents and
incidents. An accident is defined as an unintentional and undesirable occur-
rence. An incident is defined as an occurrence of seemingly minor importance
that can lead to serious consequences. The major difference between the
definitions is that the incident could have been an intentional occurrence
initially, but the consequences or results of the occurrence were undesirable.
Chapter 0502 of the U.S. Nuclear Regulatory Commission NRC Manual, "NRC
Incident Response Program," (NRC, 1978) defines incident as:
Any occurrence which, by itself or its consequences, poses an actual or
potential hazard to public health and safety, property, or the environ-
ment; or an actual or potential threat to the safeguards of licensed
facilities or materials...
Existing Criteria
10 CFR 20 Standards for Protection Against Radiation
Each licensee is required to immediately, or within 24 hours, notify the
NRC of any incident that caused or threatens to cause exposures, elevated
concentrations, loss of worktime, and damage to property in excess of the
criteria established in 10 CFR 20.403(a) and (b), respectively, as shown in
Figure 7-1.
7-15
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FIGURE 7-1
§ 20.403 Notifications of incidents.
(a) Immediate notification. Each li-
censee shall immediately notify by
telephone and telegraph, mailgram, or
facsimile, the Director of the appropri-
ate NBC Regional Office listed in Ap-
pendix D of any incident involving by-
product, source, or special nuclear ma-
terial possessed by him and which may
have caused or threatens to cause:
(1) Exposure of the whole body of
any individual to 25 rems or more of
radiation; exposure of the skin of the
whole body of any individual of 150
rems or more or radiation; or exposure
of the feet, ankles, hands or forearms
of any individual to 375 rems or more
of radiation; or
(2) The release of radioactive materi-
al in concentrations which, if averaged
over a period of 24 hours, would
exceed 5,000 times the limits specified
for such materials in Appendix B,
Table II; or
(3) A loss of one working week or
more of the operation of any facilities
affected; or
(4) Damage to property in excess of
$200,000.
(b) Twenty-Jour hour notification.
Each licensee shall within 24 hours
notify by telephone and telegraph,
mailgram, or facsimile, the Director of
the appropriate NRC Regional Office
listed in Appendix D of any incident
involving licensed material possessed
by him and which may have caused or
threatens to cause:
(1) Exposure of the whole body of
any individual to 5 rems or more of ra-
diation; exposure of the skin of the
whole body of any individual to 30
rems or more of radiation; or exposure
of the feet, ankles, hands, or forearms
to 75 rems or more of radiation; or
(2) The release of radioactive materi-
al in concentrations which, if averaged
over a period of 24 hours, would
exceed 500 times the limits specified
for such material*, in Appendix B,
Table II; or
(3) A loss of one day or more of the
operation of any facilities affected; or
(4) Damage to property in excess of
$2,000.
7-16
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Proposed Rulemaking Emergency Preparedness—Contingency Plans
The Three Mile Island nuclear reactor accident precipitated the need for
improvements in emergency preparedness planning and coordination for some NRC-
licensed activities. Emergency planning requirements were strengthened for
nuclear power reactors (10 CFR 50.47 and Appendix E, 10 CFR 50) and the NRC
prepared orders that other licensed activities—fuel processing and fabrica-
tion, uranium conversion facilities, and radioisotope installations—were
required to develop comprehensive on-site contingency plans.
The NRC plans to extend these requirements to uranium mills and other
source materials licensees (46 FR 29712). The NRC determined that previously
submitted plans for fuel fabrication plants d4sc!osed important deficiencies.
The plans did not adequately describe (1) the means for measurement and
assessment of accidental releases of radioactive materials, (2) the arrange-
ments for prompt notification of Federal, State, and Local Government agen-
cies, and (3) plans for recovery actions that would restore safe conditions
following an accident.
Development of the plan requires characterization of classes of credible
emergencies that might occur and description of radiological contingency
measures for each class of emergency. A NRC-recorranended classification
scheme, classifying emergency situations into four categories, 1s shown in
Figure 7-2. Each recommended category of emergency situations includes in the
licensee actions prompt notification of state and local off-site authorities.
Protective Action Guides (PAG's)
The protective action guides (PAG's) were developed by Environmental
Protection Agency, Office of Radiation Programs. The MG's were developed by
the EPA in conformance with a Federal Register Notice of Interagency
7-17
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FIGURE 7-2
RECOMMENDED CLASSIFICATION SCHEME
CI ass Class Description
Notification of Unusual Event Unusual events are in process or have
occurred which indicate a potential
degradation of the level of safety of
the plant. Ho releases of radioactive
material requiring off-site response
or monitoring are expected unless
further degradation of safety systems
occurs.
Alert Events are in process or have occurred
which involve an actual or potential
substantial degradation of the level
of safety of the plant. Any releases
are expected to be limited to small
fractions of the EPA Protective
Action Guideline exposure levels.
Site Area Emergency Events are in process or have occurred
which involve actual or likely major
failures of plant functions needed for
protection of the public. Off-site
releases are not expected to exceed
EPA Protective Actuion Guideline
exposure levels except near site boundary.
General Emergency Events are in process or have occurred
which involve actual or imminent loss of
confinement integrity. Releases can be
reasonably expected to exceed EPA Pro-
tective Action Guideline exposure levels
off-site for more than the immediate site
area.
7-18
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Responsibilities for nuclear incident response planning dated January 17,
1973. The PAG's were prepared to provide guidance to state, local, and
other officials on criteria to use in planning protective actions for radio-
logical emergencies that could present a hazard to the public. The States
have the primary responsibility of protection of public health.
The PAG's provide for three broad pathways of radiation:
1. Exposure from airborne radioactive releases
2. Exposure through the food chain
3. Exposure from radioactive materials deposited on the ground
Different PAG's are developed for each pathway of exposure since dif-
ferent criteria of risk, loss, and benefit are involved.
PAG's have been developed for exposure from airborne radioactive re-
leases for the general population as shown in Table 7-4. PAG's are in the
draft form for food and animal feeds. The draft PAG's for food and animal
feeds are shown in Table 7-5.
Federal Emergency Management Agency
On December 7, 1979, the President directed the Federal Emergency
Management Agency (FEMA) to head all activities associated with the off-site
planning and response to all Federal off-site nuclear emergency planning and
response. FEMA was also delegated^the authority for the development and
promulgation of the National Radiological Emergency Preparedness/Response
Plan for Commercial Nuclear Power Plant Accidents, otherwise known as the
Master Plan (45 FR 84910).
According to recent information, similar plans will be developed for
other types of nuclear facilities such as those of concern to Superfund
(Sanders, 1981). Developments of these plans could most likely involve similar
7-19
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TABLE 7-4
PROTECTIVE ACTION GUIDES FOR EXPOSURE TO
AIRBORNE RADIOACTIVE MATERIAL
Projected
Dose (rem)
General Population
1-5
whole body
Thyroid
5-25
TABLE 7-5
DRAFT PROTECTIVE ACTION GUIDES FOR
FOOD AND ANIMAL FEEDS
Projected Dose
(rem)
Preventive PAG
Whole body, major portion 0.5
of body including active
marrow
Thyroid 1.5
Emergency PAG
Whole body 5
Thyroid 15
7-20
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types of mechanisms as those developed for nuclear power plants. These plans
are expected to be developed within the next year. The plan provides a net-
work for management of the Federal off-site responses to radiological acci-
dents. It includes notification procedures and description for the inter-
action between the Federal response and that of the states. Prior to notifying
the Federal Government of an accident and pursuant to NRC regulations, the
licensee would be required to classify the accident, based on its estimated
severity. Each category initiates a specific notification scheme which in
each case includes the NRC as shown in Figure 7-3. State and Local agencies
are to be notified by the licensee as well as by the NRC.
Cost Recovery. According to the Master Plan, FEMA has the responsibility
to develop procedures for reimbursement of Federal agencies for resources
expended in responding to a radiological accident. If the accident is de-
clared an emergency, monies for response activities are readily available
(Sanders, 1981). On the other hand, if the accident is not declared an emer-
gency, reimbursement for response activities could be difficult, if the
responsible party did not have adequate funds.
Radiological Transportation Incident/Accident Response Mechanisms
The Department of Transportation (DOT) defines any material in which the
radioactivity exceeds 0.002 microcurie per gram as radioactive material (49
CFR Parts 170-179). They include by-product, source, and special nuclear
material as defined in Section IJ of the Atomic Energy Act of 1954 and in the
regulations of the Nuclear Regulatory Commission and naturally occurring and
accelerator-produced radioactive materials (NARM) as defined in the Suggested
State Regulations for Control of Radiation (NRC 1977).
7-21
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FIGURE 7-3
FEDERAL NOTIFICATION SCHEME
Yes
licensee
Federal i;eneies
whose rjd"':':osica1 ¦
xanitirir.g usabili-
ties ara repaired
rgcsrji agsnc^es
Xhitg House
Congress
* ET = Executive Team
7-23
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The carrier has the primary responsibility to notify DOT, State, Local
authorities, the shipper and the driver's management as soon as the accident
has occurred. Immediate notification of DOT is required if fire, leakage,
spillage, or suspected radioactive contamination occurs involving shipment of
radioactive material as stated in the Code of Federal Regulations, Title 49,
Section 171.15(a)(4).
According to the Memorandum of Understanding (M0(J) for transportation of
radioactive materials (44 FR 38691), DOT will promptly notify the NRC of
accidents, incidents, and instances of actual or suspected leakage involving
radioactive material package if such an event occurs in transit. Figure 7-4
illustrates the regulatory agency notification scheme for transportation
accidents. Also, the NRC will encourage the Agreement States and the DOT will
encourage the non-Agreement states to impose incident reporting requirement on
shippers and receivers subject to the State's jurisdiction (44 FR 38691).
Cost Recovery. The cost of cleanup and any liability for damages to life
or property resulting from the incident are borne, in most cases, initially by
the carrier. In most cases, the fixing of such costs and the real responsi-
bility for them will be determined in the courts. In some cases, indemnity
coverage would be provided under private insurance or under Price Anderson
Liability Coverage (NRC, 1977).
Notification/Response Management Schemes Involving ttte National Response Center
The discussions above Included description of existing or planned notifi-
cation and cost recovery mechanisms. It is considered important to utilize
existing mechanisms if possible to avoid dual authority and notification
conflicts.
7-23
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FIGURE 7-4
REGULATORY AGENCY NOTIFICATION MECHANISM FOR
TRANSPORTATION ACCIDENTS/INCIDENTS
CARRIER
DOT
INVESTIGATIVE
AGENCY
STATE
NRC
7-24
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CERCLA Section 103(a) states:
Any person in charge of a vessel or an off-shore or on-shore facility,
shall, as soon as he has knowledge of any release (other than a federally
permitted release) of a hazardous substance from such vessel or facility
in quantities equal to or greater than those determined pursuant to
Section 102 of this title, immediately notify the National Response
Center...
However, the RQ levels that Superfund would consider for possible emer-
gency response activity, would, in most cases, be reported to the responsible
regulatory agency, e.g., 10 CFR 20.403 and licensee action for actual or
threatened on-site emergency situations, pursuant to contingency plans and
49 CFR 171.15(a)(4). Therefore, for emergency response activities a possible
approach for notification of the National Response Center (NRC-II) would be
through an intergovernmental (State to NRC-II) or interagency (NRC to NRC-II)
network. This approach would be primarily applicable for NRC or agreement
state licensees.
For materials such as NARM that are not uniformly regulated throughout
the United States, the person in charge of the facility would be required to
notify the National Response Center. This approach could eliminate possible
dual notification requirements for licensees but would require direct notifi-
cation from facilities that possessed materials (NARM) not uniformly regulated
in the United States.
DEVELOPMENT RQ'S FOR RADIONUCLIDES
Three basic steps are required to develop reportable quantities for
radionuclides: (1) Establish a notification level, (2) Develop a methodology
for RQ assignment, and (3) Categorize the designated radionuclides as required.
Within each of these steps are other mechanisms required to achieve the final
goal, which are RQs for radionuclides.
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Emergency Response Notification Levels
Basic assumptions must be made to determine what levels should trigger
the emergency reponse mechanism, and therefore help to develop a notification
level.
1. An emergency situation results from abnormal conditions.
2. Those abnormal conditions that require emergency action may
vary in duration,
3. A notification level should be set below levels that would
impact the general public significantly.
4. The notification level should be set such that the steps taken and
the magnitude of action may be minimal so that emergency
response activities may be cost effective.
It should be noted that for remedial purposes a second notification
level may be useful. However, this possibility is not considered further
herein.
Determination of an Emergency Response Notification Level
The whole body dose equivalent of 0.5 rem was selected as the recommended
emergency response notification level. However, the process of determining
numerical limits for radiation standards is one of risk assessment. This
process, in which risk considerations are an important factor in the decision
making, consists of two elements: determination of "acceptable risk" and
determination of the probability that an event will occur (BRH, 1981).
The emergency response notification level assumes that a release has
occurred or there is a substantial threat of a release. The estimation of
the probabilities that an accident/incident will occur is not considered
in this report.
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Currently, there are two processes in use for determining "acceptable
risk" for radiation exposures. The first process is the application of the
life table method developed by Bunger, Cook, and Barrick (Bunger, 1981) for
examining the risk of death from exposure of workers to low level ionizing
radiation. This method provides estimates of the expectation of premature
death and the resultant life shortening. The methodology facilitates the
analysis of changes in assumed dose-response relationships, dose levels, and
age ranges at times of exposure. In this article, the radiation exposure
risks were then compared to national statistics for the risk of death from on-
the-job accidents not related to radiation. This methodology could be adapted
to estimate risks from low level ionizing radiation exposure to any population
or sub-group of the population for which the life table would be available or
can be constructed.
However, this methodology has been limited to occupational hazards and
has not been used in examining risk for the general population, or for criti-
cal groups within the population.
The second process for determining risk is used in a draft document
prepared by the Bureau of Radiological Health (BRH, 1981). This document
compares the risk from natural disasters and the variation in "natural radia-
tion background" to the radiation risk associated with the dose-equivalent
limit of 0.5 rem whole body and major organs and 1.5 rem thyroid. This
analysis is referenced (BRH, 1981) and can be used to support the recommended
notification level for Superfund.
The suggested dose-equivalent level (0.5 rem whole body) is In conformity
with current U.S. radiation protection practice and is the level recommended
by the National Council on Radiation Protection and Measurement (NCRP, 1971),
and International Commission on Radiation Protection (ICRP, 1959)(ICRP,
1977). The basis for utilizing the 0.5 rem dose commitment limit rather than
7-27
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the 1-5 rem as recommended in the emergency PAG's is also discussed in the
draft document (BRH, 1981). Excerpts from the document follow:
The Preventive PAG dose commitment limit may be viewed as equivalent to
the average projected radiation dose which could be avoided by initiating
protective actions. Situations under which Emergency PAG limits are
applicable are those in which maximum radiation exposures might be anti-
cipated and in which a smaller number of individuals might be exposed.
Hence, the relationship between the Preventive PAG's and the Emergency
PAG's is analogous to the relationship between anticipated average doses
to the population and maximum doses to an individual.
The intent, however, is to take action at the Preventive PAG, and thus
avoid levels approaching the Emergency PAG. The Emergency PAG is thus an
upper limit which is most applicable to the maximally exposed individual.
Two approaches that one could consider in the assignment of Reportable
Quantities (RQ's) for radionuclides, are as follows:
1. The RQ for radionuclides would be the recommended whole body dose-
equivalent level of 0.5 rem.
2. Utilization of the recommended dose-equivalent notification level as
a basis for calculations to develop RQs.
The first approach would have the following apparent advantages:
1. The RQ assignment for all radionuclides would be the same. This
would yield a "multimedia" designation. This would be the dose to
an individual regardless of the medium that would require notifi-
cation.
2. Utilization of the dose for the RQ would reduce the assumptions made
in calculating reportable quantities, e.g., if the RQ were in
activity or weight units of measure.
However, calculating the potential dose received by the general public
may be difficult and time-consuming.
The second approach would have the following advantages:
1. The designations could be based on generally worst-case situations
that would take into account critical pathways, critical groups,
etc.
7-28
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2. This designation would strictly adhere to the criteria established
in Section 102(a) that a single "quantity" shall be the reportable
quantity for any hazardous substance, regardless of medium. Dose
is not a "quantity" designation.
A disadvantage of the second approach is that the establishment of a
notification level based on dose-equivalent is required regardless of RQ
assignment, and assumptions would be necessary to develop the RQ1s in activ-
ity units of measure.
Units of Measure
Section 102(a) of CERCLA, specifies that a single quantity may be the
reportable quantity for any hazardous substance, regardless of medium.
Quantity for radionuclides is defined as activity levels which describe
the amount of radioactivity. The basic event that characterizes a radio-
active nuclide is the transformation of its nucleus into the nucleus of
another species. This transformation is known as decay, and there may be
several modes of decay for a given nuclide. The number of nuclear transfor-
mations occurring per unit of time is called the activity. The activity of
radioactive material is generally expressed in terms of the curie or frac-
tion of a curie which is 3.7 x 10^ atom disintegrations per second. The SI
unit for activity is the becquerel, which is equal to 1 disintegration per
second.
The other hazardous substances being considered under Superfund will be
utilizing weight in units of pounds (lb). This unit of measure would not be
particularly applicable to radionuclides due to the small quantities of cer-
tain radioactive materials that could cause harm to a human being. Activity
levels are more applicable to RQ assignments. The actual weight of the RQ
of many radionuclides will likely be much less than one pound.
7-29
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Assumptions - RQ Methodology
The operative language of CERCLA leads to choosing a quantity or quan-
tities rather than a dose for RQ1s for radionuclides. There cannot be a
single quantity for all radionuclides. They must be evaluated either indi-
vidually or in groups. For the purposes of this Section, the methodology
should be based on: (1) critical pathways, e.g., inhalation, ingestion,
external radiation exposure, and (2) effects to the sensitive segment of the
population.
Methodology Alternatives
Two methodologies will be discussed for establishing RQ designations.
One method involves use of the Annual Limits on Intake (ALI) that are being
developed for workers (ICRP, 1979), and involves development of factors to
extrapolate the ALI for the worker to the general public.
The other methodology involves the use and modification of the Limiting
Possession Limits (LPL) developed by Nuclear Regulatory Commission (NRC,
1981). Licensees that possessed quantities of radionuclides as derived by the
LPL formula that could cause exposures to the general public at emergency PAG
levels, are required to develop an emergency contingency plan.
The methodologies for calculating dose are currently being revised. The
International Commission on Radiological Protection (ICRP, 1977) revised its
recommendations on internal exposure by derived weighting factors which rep-
resent the proportion of risk resulting from a given tissue to the total
cancer risk when the whole body is irradiated uniformly. The weighting
factors are based on the best estimates of the risk of production of cancer
from single-organ exposure, compared to the risk of malignancy from whole-body
exposure (Shapiro, 1981).
7-30
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It appears that the regulatory agencies are in a transition period because
the methodologies for calculating dose are being revised. The "new" metho-
dology was used in the development of the ALI's. It is recommended that this
methodology be used in the development of RQ's based on the Limited Possession
Limits (LPL's), if this approach is selected.
Annual Limit on Intake Methodology. The approach of the International
Commission on Radiological Protection (ICRP, 1979) is to specify limits for
the total intake in a year. Designated as the Annual Limit on Intake (ALI),
this is the radioactivity taken into the body (by ingestion or inhalation)
that will impart a dose equivalent equal to the basic annual occupational
limit of 5 rem (50 mSv) of uniform whole-body*irradiation. For almost all
radionuclides, the dose imparted results from irradiation over the lifetime of
the radioactivity in the body. In the case of the few radionuclides which
have very long effective half-lives in the body, the limit on intake for one
year is the activity that will impart a dose of 5 rem in the next 50 years.
For application to the general public, age-specific ALI's must be developed.
As it may be noted, the ALI's have been developed for occupational
exposure, which means Its calculations are based on an adult. The critical
group for exposure to ionizing radiation in the general public is typically
children. ALI's have not been developed for the general public basically due
to the lack of information of the effects of radiation damagef and risk on
other age groups than the standard man.
As stated (ICRP, 1979):
The Commission does not recommend the use of the data and the models
described in this report to estimate committed dose equivalent to members
of the population, for example from radionuclides 1n the environment, by
adjustment solely on the basis of differences in mass of organs or magni-
tude of intake. While some insight into population exposure may be
obtained from the data, they were not collected with this purpose 1n
mind.
7-31
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Regulatory exposure limits for the general public are one-tenth of the
occupational exposure limits. The development of Maximum Permissible Concen-
trations (MPC's) for the general public were based on Maximum Permissible Body
Burdens (MPBB's) to the critical organ which were 1/1Oth of occupational
MPC's. The MPC's also assume that the exposure time is 3 times as great per
year for the general public as for an occupational worker.
Since the reportable quantities developed would serve as guidelines based
on a dose notification level, it is conceivable to modify the occupational
ALI's to reflect possible effects to the general public.
ALI's may be adjusted in two steps: (1) by dividing by a factor of 10 to
convert the occupational dose equivalent limit of 5 rem to 0.5 rem for the
general public, and (2) by dividing by a factor that would take account of the
sensitive group(s) in the population.
Advantages/Disadvantages. The advantages to utilizing this approach or
facsimile is as follows:
1. ALI's have been calculated for occupational exposures utilizing the
current method for dose calculations (ICRP, 1977).
2. The modification of the ALI is based on a divisor
for the critical group, which takes into account a number of effects
that are complex and yield a more comprehensive way of evaluating
the effects of radiation to an individual than basing it solely on a
critical organ.
The disadvantages of this approach are as follows:
1. The divisor that would be chosen could over- or underestimate
effects to the sensitive group.
2. The data used in ALI's calculation are not meant to be used for the
general public.
7-32
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Limiting Possession Limits (NRC, 1981). The Limiting Possession Limits
(LPL's) were developed by the Nuclear Regulatory Commission. They were
developed to upgrade radiological contingency planning for those licensed
fuel cycle and major materials facilities which have the potential for
accidents that could result in off-site doses exceeding 1 rem to the whole
body, 5 rem to the thyroid, or 3 rem to the other critical organs. The
radiation doses of 1 rem whole body, and 5 rem to the thyroid were the lower
limits of the PAG's derived for airborne radiological releases.
Figure 7-5 shows the formula the NRC used to calculate the LPL's.
Inhalation was considered the critical pathway except for those radionuclides
in which submersion in an airborne cloud was" the acute exposure pathway.
The ingestion pathway was not considered likely to cause prompt acute expo-
sures to individuals, and therefore, was not considered limiting enough for
the analysis.
Estimates of release fractions, the portions of inventories of radio-
active materials that could be airborne in an accident, were based on experi-
ence and generic physical and chemical forms of the radionuclide involved
since there was insufficient data available to make an analysis. The release
fraction ranges from zero for encapsulated materials and "special form"
materials to one for volatile and/or combustible radionuclides.
A fraction of the materials released, called the "Intercept fraction,"
would be inhaled and therefore contribute to radiation dose. An intercept
fraction of 10"6 for off-site exposures (Brodsky, 1980)(Brodsky, 1965) cor-
3
responds to a breathing rate of 20 m /day and an atmospheric relative con-
-3 3
centration value X/Q of 4 x 10 sec/m , when the receptor 1s present through
out the entire release event. An atmospheric relative concentration value of
7-34
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FIGURE 7-5
Estimates of quantities of materials, which could lead to significant
off-site doses and to overexposures of workers from accidents, that require
protective actions have been based upon the relationship:
Dn
Q s DCF RI
n
Where Q = Limiting possession limit, i.e., the quantity of radionuclide
authorized to be possessed and assumed subject to an accidental
release
Dn= Doses requiring protective actions, rem
DCFn = The inhalation dose conversion factor for the limiting body organ
R = Release fraction likely to be dispersed in a severe real accident
I = Intercept fraction that could be inhaled by an individual
7-34
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_3
4 x 10 was used and considered a typical value for fuel cycle and materials
licensee installations. This value corresponds to the ground level relative
concentration experienced 150 meters from a ground level release under stable
meteorological conditions.
Modification of the LPL's Equation for Superfund. The doses used in the
LPL's correspond to the emergency PAG's developed for airborne releases. The
suggested whole body dose equivalent for a Superfund notification is 0.5 rem
therefore, the numerical value for the dose used in the LPL could be changed.
The intercept fraction would also be modified to take into account differences
in distance from the release. Accidents involving the facilities specified in
the LPL's derived by the NRC, generally have a fixed boundary at a distance
from the receptor on the order of 150 meters; however, in a transportation
accident the distance between the receptor and the released materials could be
much less. The suggested distance from a release to the receptor would be 15
meters. This could take into account the "worst case" distance, where the
receptor was present throughout the entire release. The formula to calculate
RQ's for Superfund is shown in Figure 7-6. This formula was modified to meet
the conditions specified in (ICRP, 1977). The LPL's calculated by the NRC are
for radionuclides commonly associated with the fuel cycle and licensed mate-
rials facilities. Superfund is also concerned with the radionuclides asso-
ciated with other types of facilities and materials, e.g., Idw level waste
disposal sites and naturally occurring and accelerator produced radioactive
materials (NARM). Therefore, the release fractions may need to be determined
for the additional radionuclides. If there is Insufficient information on the
release fraction of a particular radionuclide, one (1.0) would be used to
calculate the RQ.
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FIGURE 7-6
MODIFICATION OF THE LPL FORMULA FOR RQ DETERMINATION
R • I [DCFWB + E wt DCFt]
Q = Reportable Quantity
D = Dose required for Notification Level
n
R = Release Factor
I = Intercept fraction
DCFyg = Dose conversion factor for whole body, e.g., submersion
s in contaminated air
w't = Weighting factor for tissue (t)
DCFt = Dose conversation factor for tissue (t)
7-36
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Advantages/Disadvantages. The main advantage of utilizing this approach
is that it takes into account "real" events that could surround a release
from a facility and/or transportation accident/incident.
The main disadvantage of utilizing this approach is that the RQ could be
overly conservative, especially for a fixed facility.
Direct Gamma Radiation Effects
For some radionuclides, exposure to external gamma radiation could be
the critical pathway. For example, a sealed radiographic source lost or
spilled in a transportation accident, could present a substantial direct
gamma radiation exposure hazard. Examples of gamma emitters are depicted in
Table 7-3. The formula used to.calculate gamma radiation exposure rates is
shown in Figure 7-8.
Two methods of incorporating direct gamma radiation effects to RQs would
be (1) develop RQs for those radionuclides that exhibit direct gamma radia-
tion effects as the critical pathway; or (2) establish an external gamma
radiation exposure rate, regardless of specific radionuclide, that would
require notification.
Establishment of a direct gamma radiation exposure rate would be re-
quired for both methods. As stated earlier, the operative language of CERCLA
leads to choosing a quantity or quantities rather than dose or exposure rate
for RQs for radionuclides. Therefore, the first method would be recommended.
The RQ derived from the formula in Figure 7-8, if more restrictive, would
supersede the RQ based on intake of the radionuclide Into the body, as the
/
critical pathway.
Categorization
As stated in Part 2 of this section, if the dose notification level were
to be used for the reportable quantities (RQ) determination, the term "radio-
nuclides" would be the only designation. If the other methodologies for RQ
7-37
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FIGURE 7-8
FORMULA FOR EXTERNAL GAMMA RADIATION
where
D
r = Specific exposure rate constant (^r_Q^ @ 1 m)
C = Number of curies
r = Distance from the source in meters (m)
X = Exposure rate, R/hr (roentgen/hr)
7-38
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determination were utilized, the radionuclides would need to be individually
listed as shown in Table 7-3, or categorized, which could reduce the number
of designations for radionuclides. This part discusses two possible ap-
proaches for categorization of radionuclides:
1. The toxicity classification of radionuclides developed by
the International Atomic Energy Agency (IAEA, 1963)
2. Eight groups developed by Allen Brodsky that correspond to the
relative magnitudes of the radionuclides maximum radiotoxicities
(Brodsky, (a)1980).
Both approaches group the radionuclides according to the risk of bio-
logical injury when they are incorporated into the human body. Those radio-
nuclides for which direct gamma radiation may be the limiting factor would be
evaluated on a case-by-case basis and placed in the group whose limiting
activity levels based on potential health effects would be similar.
Toxicity Classification--(IAEA, 1963)
The International Atomic Energy Agency developed a toxicity classifica-
tion for radionuclides. The purpose of this classification was to make a
toxicity grading of the radionuclides according to the risk of biological
injury which they may cause when they become incorporated in the human body.
Due to the wide range of toxicities in this classification, three main groups
were distinguished. However, it was recognized that the group of medium
toxicity nuclides may cover too wide a range of toxicity and therefore, four
groups also were derived.
There are three ways 1n which radionuclides normally enter the body; by
absorption through the skin, by Ingestion, and by Inhalation. Inhalation was
the mode used 1n the basic toxicity classification. A further consideration 1n
making the toxicity grading is the rate at which the radioactivity is inhaled—
continuous Intake or an intake of short duration. The latter case would be
7-39
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applicable to those only likely to be in contact with radioactivity once in a
lifetime—for example, members of the public who inhale radioactive material
after an accidental release to the environment. The classification is based
on the ICRP values for maximum permissible concentrations in air (MPC) for
continuous inhalation, however, the classification is also applicable to a
single intake.
The calculations used for development of this toxicity classification
were based on the doses delivered to the critical organ. However, for our
purposes, the method used for the toxicity grading would not vary greatly if
the method for dose calculations was updated (ICRP, 1977); therefore, the
groupings as they exist (IAEA, 1963) would remain basically unchanged. Table
7-6 shows radionuclides arranged in the order of their most restrictive (MPC)
value as determined (IAEA, 1963).
Brodsky's Eight Groups--(Brodsky (a), 1980)
In the article, "Determining Industrial Hygiene Requirements for Instal-
lations Using Radioactive Materials," a set of guidelines was proposed as an
aid in determining the specific facilities, equipment, and procedures required
for operations involving radioactive materials. The guidelines were illus-
trated by the development of a table that groups commonly used radionuclides
in eight groups that correspond to the relative magnitudes of their maximum
radiotoxicities, The eight groups were chosen to correspond to the eight
orders of magnitude over which the maximum doses per curie range when radio-
active material is delivered in a single intake by inhalation.
As mentioned in the (IAEA, 1963) toxicity classification, the use of
single intakes by inhalation may seem to apply only to accidental situations,
however, the same ordering of radionuclides would occur if the groups were
selected on the basis of permissable concentrations for continuous intake.
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StiAFT
TABLE 7-6
RADIONUCLIDES ARRANGED IN ORDER OF THEIR MOST RESTRICTIVE
(MPC)a VALUE
HIGH TOXICITY
P*231, Cf2^9. Th-Nai. Pu239, Pu240. Pu242 Th232, Pu238. Ac227. Th230, Np23T_, Th218, Am241. Am243,
Cm243. Cm245, Cm24®, Cf250, Cf252 Cm244, U232, Ra22®. Hi228, Smi47,U-Nat. Nd144, U238. Pu241,
^210, O230i U233> u234, ^,235 ^236 Cm24Si Th227 ^210 Ra223 Sr3Q,
MEDIUM TOXICITY
Upper Sub-Otoup A
(U224. P*30. Bk249. I129. Ell"4 Ru1Q6. Ce144 B121Q, At211, Na22 Co60_ AglJOm, [126 t131_ c.134
Eu l52&3yr) c,137 B£207. Ph2*2, Ac22®, In"4™, Sb"4, Ti"2. CI36, Sc46, Sb125, Ir192. Tl2"4, Ca4S,
Mn54, Y91. it95. St89, Cdll8m, to115, Te12Tm, Te129m [133, BiMQ, Tbi60 _ fm170. Hf18*, Th234.
Lower Sub-Group 3
p32 v48, Fe" Co8®, Nl«3, z„«S, Rfagg, gfaS?, Xe99, Cdl<», Sn113. Pm147. Sm181. Ot188. Hg203, A!78.
Y90, Zr97, Nb95. Ru103, Agl°5, Snl", O138. Eul", w183, Bt212, K42, Ai74. Se15, Sias, Nb93m.
Ij93, Tel2Sra, Tel32. [138, U140( Tm"l, wl«l. wl8S, NlS* Sc48, MaSSi r93, re97®, Sb^ Cel42_
p,142 1^183, [,134, Bl206, Ci47, Co57( Cl7at »83iCdUSi Tt131m, 0,138, fti43, H018fl, ^188, p,233,
Mo99, C®*43. Dyl«8. TeM, Agl". IMS, Ndl47, PmM9, r.188, Au198, T120S, s38, &91, oi"3. Zn89">,
AI73. A»77 St82, r92, Tc97. Wl°9, B«131. Sm153, Eul82f»-2h), Ck|l»9, Et"9, w"7. Oil9!, ft*90.
p,193, Rn22®, Rn222, ~ Sc47. Mn88, Nl»9 Nl«», K»87, Ru"8 Rh"8, I134, Ell7!, Ybl78, u"7. Rel«7,
p,m, *191, A«l9S. Np239. SI®1, F«58, Wl°3, T«W. Aul®4. Tl200. Tl201, Be7, A41. Cu®4,
Hgl37, Th23\ Ndl49. RUW, m 115m, ftSM, C138, DylSS, Cf81, fl8, cM, J&88m, T«l29, Xe*38, Cj131,
LOW TOXICITY
H3, Zn89, Ce71, Mb97, In1131"1, Ci134m, Pt193m, P»197m( Co88m> Kl8S< x«l33. Oi191m, Xe1311",
yairn 8,8501, Tc90ra. Rhl03"1. A37.
7-41
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As pointed out in the article (Brodsky (a), 1980), the calculations were
based on inhalation; however, the relative group of radionuclides would also
be consistent within one order of magnitude if based on relative ingestion
toxicity.
It was also pointed out the maximum dose per curie inhaled varies over
about nine orders of magnitude or more. It was found that the use of only
three groups may result in applying similar safeguards to two radionuclides
that could differ by a factor of approximately 1,000 in relative toxicity.
Therefore, a grouping of 3 or 4 could lead to over-estimates of relative
toxicity by a factor of 1,000. This could also affect the quantities that
would be derived for Superfund.
The radionuclides were arranged in order of dose per curie as shown in
Table 7-7. Based on the assumption that the relative ordering of the maximum
dose per curie inhaled, the radionculides are arranged in groups each of
which covers a factor of 10 in relative radiotoxicity.
This methodology and grouping was developed for occupational exposure.
However, the categorization methodology could be used for RQ assignment
because the groups would not greatly vary. The use of only 3 or 4 groups
could lead to over-estimates of relative toxicity by a factor of 1000
(Brodsky(a), 1980) within each group. If categorization is to be used for RQ
designation for radionuclides, the Brodsky approach would be preferred.
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TABLE 7-7
TYPICAL RADIONUCLIDES WITHIN THE
EIGHT GROUPS BASED ON RELATIVE TOXICITY
Group Radionuclide
I H-3
C-14
II Cr-51
Fe-55
III Ce-1'41
Sr-85
Fe-59
IV Hf-181
CI-36
Tm-170
V 1-129
Tc-99m
VI Ra-223
Sr-90
U-235 (+ ]% U-234)
VII Ra-226
Cm-244
VIII Am-243
Th-230
Pu-239
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Issues Concerning Radionuclides arid Superfund
Some issues were not fully developed in this section that concern the
inclusion of radionuclides into Superfund. An administrative issue is that
radionuclides are regulated under other Acts than Superfund and by other
agencies than the EPA. It would be desirable to coordinate activities be-
tween the responsible agencies to reduce duplication of notification and
response activities.
Technical issues include the following:
1. The NRC noted important deficiencies in existing emergency response
plans for fuel fabrication facilities. For example, the plans
failed to describe adequately the means for measurement and assess-
ment of accidental releases of radioactive materials and arrange-
ments for prompt notification of Federal, State, and local Govern-
ment agencies (46 FR 29712). This illustrates that there are
problems involved in detection and assessment of accidental re-
leases of radionuclides even for professionals. Also illustrated
was that there are existing notification inconsistencies for uni-
formly regulated materials. It appears evident that these problems
would exist and perhaps be magnified for materials not uniformly
regulated by the States, e.g., NARM.
2. The difference between the definition of removal and remedial acti-
vities denotes two types of effort. Therefore, the notification
level associated with remedial activities especially concerning
"non-beneficial" facilities or sites, e.g., orphan disposal sites,
could be established at a lower level than required for possible
emergency response activities.
7-44
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Conclusion
Superfund is a comprehensive act that will be able to deliver assistance
to State and Local and Federal agencies if a release occurs of a hazardous
substance, pollutant or contaminants to protect public health and welfare and
the environment.
As pointed out in Part 1 of this section, radionuclides are considered a
hazardous substance because they are named as a hazardous air pollutant by
Section 112 of the Clean Air Act. Releases of radionuclides, in certain
instances as defined by Section 101(22)(c), will be required to be reported
if a given "quantity" has been exceeded except for those facilities covered
by Section 170 of the Atomic Energy Act (AEA). Removal and remedial activi-
ties could be provided for radiological releases, except for the facilities
and materials covered by Section 170 of the AEA, the sites delineated in
Sections 102(a)(1) or 302(a) of the Uranium Mill Tailings Radiation Control
Act (UMTRCA), and releases at federally owned facilities, as indicated in
Section 111(d)(3) of Superfund.
Radiological materials and facilities are, for the most part, tightly
regulated and the regulations are tightly enforced. There are existing noti-
fication mechanisms that Superfund could perhaps tap. This approach would
lessen the number of notifications required by a licensee of the Nuclear
Regulatory Commission (NRC) or Agreement State. Notification by the state
and/or responsible federal agency to the National Response Center is a
suggested approach. Direct notification would be required from facilities
that possessed materials, such as NARM, not uniformly regulated.
The suggested emergency response notification level for Superfund whole
body dose-equivalent is 0.5 rem. This exposure is generally considered the
7-45
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upper limit for the general public exposure. This level is sufficiently low
to prevent significant harm to the general public. Thus, it allows for
possible planning activities and response activities that could be cost
effective.
According to Section 102(b)(2) of Superfund, a single quantity is de-
sired for any hazardous substance regardless of the medium. The designation
of one pound is not appropriate for radionuclides. There are two possible
approaches: (1) utilization of a dose, or (2) utilization of a "quantity"
for RQ's. The advantages of using a dose designation is that it is a multi-
media designation but it is not a "quantity." Activity is the "quantity"
unit of measure for radionuclides. To obtain a "quantity" designation, two
approaches were discussed: (1) the use of the Annual Limit on Intake (ALI)
modified to generally reflect possible general public intake values, and (2)
modification of the formula used to establish the Limiting Possession Limits
(LPL's) that were derived by the Nuclear Regulatory Commission (NRC, 1981).
Modification of the LPL formula appears to be the best method for deriving
RQ's.
The "reportable quantity" will be based on a dose. The dose is the
important element in the development of RQ's. Once the RQ's are developed by
the prescribed method for the designated radionuclides, the two approaches
for actual RQ designation would be: (1) list the RQ for each designated
radionuclide, or (2) categorize the radionuclides in some manner into groups
according to relative toxicity and assign the same RQ to all members of the
same group. If categorization is the chosen approach, the methodology and
groupings derived by A. Brodsky in "Determining Industrial Hygiene Require-
ments for Installations using Radioactive Materials," would be recommended.
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REFERENCES
(Brodsky, 1965); Brodsky, A., May-June 1965, "Determining Industrial Hygiene
Requirements for Installations Using Radioactive Materials," American
Industrial Hygiene Association Journal, Vol. 26, pp. 294-310.
(Brodsky, 1980); Brodsky, A., December 1980, "Resuspension Factors and
Probabilities of Intake of Material in Process (or "Is 10~5, A
Magic Number in Health Physics?"), Health Physics, Vol. 39,
No. 6, pp. 992-1000.
(Brodsky(a), 1980); Bordsky, A., June 1980, "Determining Industrial Hygiene
Requirements for Installations Using Radioactive Materials," Health
Physics, Vol. 38, pp. 1155-1171.
(Bunger, 1981); Bunger, B. M., Cook, J. R., Barrick.M. K., April 1981,
"Life Table Methodology for Evaluating Radiation Risk: An Applica-
tion Based on Occupational Exposures," Health Physics, Vol. 40.
(BHR, 1981); Shleien, B., Schmidt, 6. D., ChUcchierini, R. P., July 1981,
Draft--"Background for Protective Action Recommendations; Accidental
Radioactive Contamination of Food and Animal Feeds," Bureau of
Radiological Health, Food and Drug Administration.
(DOE, 1979); Department of Energy, December 1979, Annual Status Report on
the Inactive Uranium Mill Tailing Site Remedial Action Program,
D0E/EV-0060.
(Entwisle, 1981); Entwisle, E., Trauberman, J., May 13, 1981, "EPA's Response
Authority for Radioactive Substances Under the Comprehensive Environ-
mental Response Compensation and Liability Act," Environmental Law
Institute, Wasington, D.C.
(EPA, 1975); Environmental Protection Agency, September 1975, (Revised
June, 1980), Manual of Pr°tgcti°n Action Guides and Protection Actions
for Nuclear Incidents, EPA-52Q/1-75-0Q1, Washington, D.C.
(42 FR 46), Federal Register, Monday, January 3, 1977, "Title 10-Energy,
Chapter 1-Nuclear Regulatory Commission, Part 140-Financ1al Protection
Requirements and Indemnity Agreements," Vol. 42, No. ITpp. 46-54.
(44 FR 38690); Federal Register, Monday, July 2, 1979, Department of Trans-
portation, NRC, "Transportation of Radioactive Materials, Memorandum
of Understanding," Vol. 44, No. 128, pp. 38690-38691.
(45 FR 84910); Federal Register, December 23, 1980, "National Radiological
Emergency Preparedness/Response Plan for Commercial Nuclear Power
Plant" Accidents (Master Plan), Vol. 45, No. 248, pp. 84910-84917.
(46 FR 29712); Federal Register, June 3, 1981, "Upgraded Emergency Prepared-
ness for Certain Fuel Cycle and Materials Licensees," Vol. 49, No. 106,
pp. 29712.
7-47
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(IAEA, 1963); International Atomic Energy Agency, 1963, A Basic Toxicity
Classification of Radionuclides, Technical Reports Series No. 15,
Vienna.
(ICRP, 1959); International Commission on Radiological Protection, 1959,
Report of Conmittee II on Permissable Dose for Internal Radiation,
ICRP "Publication 2, Pergamon Press,. Oxford.
(ICRP, 1977); International Commission on Radiation Protection, 1977,
Recommendations of the International Commission on Radiological
Protection, Publication #26, Vol. 1, No. 3, Pergamon Press, New York.
(ICRP, 1979); International Commission on Radiological Protection, 1979,
Limits for Intakes of Radionuclides by Workers, Annals of the ICRP,
ICRP Publication 30, Part I, Vol. 2, No. 34, Pergamon Press, New York.
(NCRP, 1971); National Council on Radiation Protection and Measurements,
January 15, 1971, Basic Radiation Protection Criteria, NCRP Report
No. 39, NCRP Publications, Washington, D.C.
(NRC, 1977); Nuclear Regulatory Commission, June 1977, Regulatory and
Other Responsibilities as Related to Transporation Accidents,
NUREG 0179, PB-269 625, NTIS, Washington, D.C.
(Sanders, 1981); Sanders, M., September 22, 1981, FEMA, Telephone Conver-
sation.
(SI480a); S.1480, July 11 , 1979, S2(16).
(S.14806); S.1480, Staff Working Paper No. 2, June 2, 1980, S2(16)(B)(ii).
(S.1480c); S.1480, July 11, 1980, S2(16)(B)(ii).
(Shapiro, 1980); Shapiro, J., 1981, Radiation Protection: A Guide for
Scientists and Physicians, 2nd Edition, Harvard University Press,
Cambridge, Massachusetts.
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SECTION 8
DATA MANAGEMENT SYSTEM
THE NIH/EPA CHEMICAL INFORMATION SYSTEM (CIS)
Fein-Marquart Associates, Inc., of Baltimore, Maryland, conducts a pro-
gram to design, develop, implement, install, and maintain the CIS for the U.S.
Environmental Protection Agency, the National Institute of Health, and the
National Bureau of Standards. The CIS is a collection of computerized data
storage and retrieval modules for chemical information. Each of these modules
is essentially a "stand-alone" system dealing with a particular aspect of
chemistry. However, they are all prepared according to a standard set of CIS
guidelines so that they can share the same utility software and conmunicate
among each other. In this way, it is relatively easy to conduct composite
searches dealing with these various aspects of chemistry, and similarly to
display, in association with retrieved compounds, information stored in the
data bases associated with the various modules.
The modules (components) of the CIS are listed below, and the structure
of the CIS is depicted in Figure 8-1.
SANSS
MSSS
CRYST
CNMR
MLAB
CLAB
RTECS
CAMSEQ-II
OHM/TADS
PDSM
FRSS
XTAL
WDROP
NMRLIT
CTCP
TSCAPP
MAIL
8-1
Structure and Nomenclature Search System
Mass Spectral Search System
X-Ray Crystallographic Search System
Carbon 13 NMR Search System
Mathematical Modeling Laboratory
Cluster Analysis Laboratory
Registry of Toxic Effects of Chemical Substances
Conformational Analysis Programs
Oil and Haz. Materials/Tecb. Assist. Data System
JCPOS Powder Diffraction Search Match
Federal Register Search System
Single Crystal Reduction and Search System
Water Distribution Register of Organic Pollutants
NMR Literature Search System
Clinical Tox. of Commercial Products Search System
Toxic Substance Control Act Plant & Production Data
MAIL System
-------
8 Wig
OHM/TADS
Water
DROP
FRSS
SANSS
CNMR
MSSS
CRY ST
CAS
Registry
Number
CAMSEQ
XTAL
NMRLIT
PDSM
CTCP
RTECS
TSCAPP
MAIL
Figure 8-1. Structure of the CIS.
8-2
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The modules of the CIS communicate among themselves by stored lists of
Registry Numbers, for the most part supplied by Chemical Abstracts Service. In
the case of some modules, for example CTCP, WaterDROP, and Federal Register
Search System, the retrievals are, more exactly, represented internally by
"Citations," where each citation contains a specific reference to a compound
(represented by its Registry Number). A given list of citations is automati-
cally converted to a list of the pure Registry Numbers of all the compounds
referenced in that list when it was generated. In some modules, where more
than one "entry" for a Registry Number is possible, a subidentifier is ap-
pended to the Registry Number. As an example, there are cases when more than
one crystalline form for a compound exists, and, therefore, more than one
entry for a compound might be found in a list of one or more Registry Numbers
being generated and stored. For instance, within the Structure and Nomencla-
ture Search System (SANSS) one might ask for all compounds containing a par-
ticular structural fragment, or with a name or synonym containing a certain
name fragment, or having a molecular formula satisfying certain broad cri-
teria. The answer to each such query is a stored file containing a 11st of the
Registry Numbers for those compounds satisfying the criteria specified.
For essentially all the compounds 1n the CIS the following Information is
available:
o CAS Registry Number
o Structure
o The chemical name and molecular formula in accordance with the
introductory sections of the Toxic Substances Control Act, Chemical
Substances Inventory, Volume 1, May 1979
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o CAS Index Name(s)
o A list of sources of further information
o Other names and synonyms by which the substances are commonly
known in commerce and manufacturing
In addition, as described in the following sections, much additional infor-
mation, e.g., mass spectrum, toxicity data, regulation, is also available for
many of the compounds.
The following sections will discuss briefly the features of each of the
CIS components that are most useful to the Reportable Quantities program.
Oil and Hazardous Materials/Technical Assistance Data System (OHM/TADS)
OHM/TADS is a collection of interactive computer programs which allow
searching of the Environmental Protection Agency's Oil and Hazardous Materials/
Technical Assistance Data System (OHM/TADS). This data system provides neces-
sary technical support for the assessment of potential or actual dangers
encountered as a result of the discharge of oil or hazardous substances.
OHM/TADS contains data for any material which has been designated an oil or
hazardous material by the EPA. Currently there is information in the system
for about 1,100 substances. While the primary function of this data base is
to provide emergency information to spill response team personnel, it can also
be regarded as a general source of diverse information on hazardous sub-
stances. OHM/TADS data has been gathered from the open literature.
OHM/TADS searches are based on the 126 subjects into which all infor-
mation in the data base has been categorized. These subjects are generally
referred to as "fields." For example, the MAT field contains the material
name, and the DRK field contains the recommended drinking water limits. Every
material in the data base has information in the MAT field, but information
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may not be available on every subject for the material of interest. Perhaps
the necessary measurement has not been made; for example, the boiling point
(BLP field) may not be known. One can list all of the information available
for a particular chemical or restrict the listing to only the fields of
interest.
OHM/TADS allows a search for materials with certain values of specified
properties (for example, the specific gravity or vapor pressure) or ranges of
those properties. OHM/TADS also provides recommended methods for disposing of
spilled materials (the DIS field), and for notifying proper authorities (DSN
field).
Structure and Nomenclature Search System (SANSS)
The SANSS module data base is designed to contain an entry for each
compound included in the data bases associated with the other individual CIS
components. Each such entry includes, as available: CAS Registry Number;
systematic name (8th CI and/or 9th CI); synonyms and trade names; molecular
formula; connection table, and references to other sources of information.
Currently there are approximately 200,000 substances in the data base. One
can query this system for compounds having a wide variety of characteristics.
For example, one can search for al 1^ compounds having a specific structural
fragment contained within it. To accomplish this the user described the two-
dimensional structural fragment by means of simple typed commands. The system
can also be searched on the basis of name (either complete, or partial); ring
system; specific functional groups; molecular formula (complete, partial, or
ranged); molecular weight, and atom count.
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Acute Toxicity Data from the NIOSH Registry j$ #
of Toxic Effects of Chemical Substances (RTFCS)
The search and retrieval system for the NIOSH Registry of Toxic Effects
of Chemical Substances (RTECS) is based on the NIOSH publication of the same
name. Each quarter, a completely updated magnetic tape copy of the RTECS
publication is processed, and the data base for the interactive search and
retrieval system is replaced. Currently there is information in the system
for 40,861 compounds.
The direct search allows the user to display, for a given list of corn-
pounds, the CAS Registry Number, the RTECS Registry Number, and the details of
each published toxicity measurement for each compound, including literature
references.
Alternatively, the user may ask for all entries relating to specific end
effects (e.g., eye irritation) on specific classes of animals (e.g., rabbits)
for specific means of application, having dosage within a given range. The
result of such a query is a list of Registry Numbers which can then be used to
display RTECS data or to obtain information from other modules of the CIS.
Federal Register Search System (FRSS)
The FRSS was established to accumulate regulations, rules, standards, and
guidelines involving chemical substances, and to provide a means of access to
up-to-date information regarding the status of such regulations and standards.
In this system, a "citation" consists of the mention in the FR of a chemical,
substance, material, or product. If the cited substance is a mixture, each of
its components (if mentioned in the article) are themselves the objects of
other citations, with full cross-referencing information in all of the cita-
tions. Each citation includes: the substance name(s) and CAS Registry Num-
ber, if any; the FR volume and page number; the type of FR article (Notice,
8-6
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Proposed Rule, Final Rule); the agency and/or office; the CFR sections, if
any, affected; references to prior FR articles; a descriptive string of
"Keywords" and ordinary English words that, when expanded for presentation to
the user, form an abstract of the intent of the article; specific dates upon
which certain actions will take place (effective date, public hearings, etc.);
and annotated cross-references to citations for other, related substances.
Guidelines, proposed guidelines, standards, and any non-regulatory but recom-
mended criteria for dealing with a particular substance are also entered.
The primary FR citation is, of course, to the article in which the sub-
stance appears; this gives the user immediate access to the article. As
touched on above, subsequent CFR and FR citations give the user a whole back-
ground of specific information, as well as providing access to the actual CFR
and FR documents themselves. A significant implication of this compilation of
information is that the system can assist the user in gaining not merely
facts, but an understanding of the regulatory history of the substance, and
potentially a projection of its regulatory future.
It is important to note that the abstract contained in this system tells
the user what the article is about—not what it actually says. It was deemed
critical to the design of the data analysis process that there should be no
temptation for the user to reference to the content of this system as the
"legal" authority for his actions. This system 1s a method of locating and
identifying Federal Register articles of Interest to specific users; it is
deliberately not an alternative to the Federal Register itself.
The FRSS contains data beginning with the Issue of January 1, 1978, and
1s updated at least weekly; currently (as of March 26, 1981) there are 78,032
citations in the system.
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Clinical Toxicology of Commercial Products (CTCP)
CTCP is an on-line interactive data base based on the book of the same
title by Drs. Gosselin, Hodge, Smith, and Gleason. In it is contained infor-
mation about approximately 20,000 commercial products, consisting of their
manufacturer, uses, and composition. For the chemicals comprising a product
the CAS Registry Number, concentration, and indication of toxicity (if appli-
cable) are given. As any consumer knows, the composition of a product is
subject to significant change from time to time, even if the trade name under
which it is marketed remains the same. However, it is often critical to know
the composition of earlier versions of a specific product—for example, in the
case where a child may have ingested the contents of an old bottle. Thus,
prior formulations are retained whenever possible.
The data base may be searched against essentially all of its fields. For
example, one might inquire about all compounds containing phosphoric acid
which are used as fertilizers.
Toxic Substances Control Act Plant & Production Data (TSCAPP)
The TSCAPP data base is the production and plant site information asso-
ciated with the Toxic Substances Control Act (TSCA) Chemical Substance Inven-
tory: Initial Inventory. This information was originally contained in two
tape files in the CICIS - Chemical Production Information Tape, which is
documented in NTIS Computer Products Data Sheet - Accession No. PB80-155153,
EPA Report No. EPA/OE-80/005.
The TSCAPP data base contains two separate sets of entries: one of
production information concerning the production of a single substance in a
plant; another set of entries containing information about plants. These two
8-8
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sets of entries are accessed by different commands, but can be combined In
various ways for display. For example, searches performed by CAS number will
allow assessment of the total annual production of a given compound, and the
manufacturing sites can be Identified.
THE CERCLA REPORTABLE QUANTITIES FILE
Several steps have been taken to develop the RQ public record file. The
first of these is the establishment of a "hard copy" catalog of items to be
included in the file. The second is the establishment of appropriate links
with the EPA computer system that will allow generating part of the file from
Information already in data bases available to the EPA, and also setting up an
ADP index to the file that will allow machine-searching. Each of these oper-
ations is discussed in more detail below.
Cataloging System
The "hard copy" catalog of Items to be entered in the CERCLA Reportable
Quantities file is being developed initially from documents currently held and
considered relevant by the Rockwell EMSC staff. After one iteration the list
of filing categories and subclasses currently 1n use is shown In Table 8-1.
Categories have been included to accommodate Items under development by other
subcontracts (I.e., the "Comment Letters" Category No. VII.
Each document's nature is being recorded on an indexing sheet, as shown
by the sample in Table 8-1, This Information will eventually be uncoded and
become the basis for the ADP index. As noted, the "CONTENTS" section 1s used
to record a few key descriptor words, and if the title of the Item already has
enough such descriptors* the entry made 1s simply "See Title,"
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TABLE 8-1
FILING CATEGORIES AND SUBCLASSES
CERCLA REPORTABLE QUANTITIES FILE
I. Law and Legislation
a. CERCLA
b. Legislative Review
c. Congressional Reports
d. Related Law/Legislative Review
II. Regulations
a. Drafts/Typewritten Versions
b. Federal Register Reprints/Copies
c. Related/Reference Regulations
d. Procedural Items
III. Chemicals - Non-Radioactive
a. Data Sheets
b. Data Base Information
c. Lists
d. General References
(Note 1) e. Specific References
f. General References
g. Selection Criteria
IV. Radionuclides
a. Lists
b. Background Information
c. Hazards/Effects
d. Laws/Regulations
e. Hazard/Risk Analysis
f. General References
g. Media-Specific Information (Air/Land/Water)
h. Spill/Release Information
V. Reportable Quantities
a. Scenarios/Strategies/Models
b. Supporting Development
c. Calculations/Determinations
d. Hazard Indices
VI. Comment Letters
a. Chemical
(Note 2) b. Classification Methods
(continued)
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TABLE 8-1 (Continued)
-a us u "(V
VII. Experts/Centers of ExcelIsnce
a. Identification
b. Qua!ifications
c. Support Provided
VIII. Media-Specific Information
a. Land
b. Air
c. Water
IX. Contractor Reports
a. 8i-Monthly/Monthly/Semi-Monthly/Weekly
b. Interim/Drafts
c. Final
d. Work Statements
e. Formats
X. Spill/Release Information
(Note 1) a. Specific References
b. Summary Reports
c. Data Base Information
XI. Economic Effects/Factors
(Note 3) a. General Refrences
b. Summary Reports
c. Use/Application
XII. Memoranda of Record
a. Meetings
b. Trip Reports
c. Symposia Notes
d. Letters
e. Notes
XIII. Background/General Information
a. Books
b. Handbooks
c. Guides
d. Reports
e. Articles
Note 1. "Specific Reference" means reference to a specific chemical material
a specific waste by name.
Mots 2. Additional subclasses to be developed when comment letters become
available. Will accommodate classification method used by VIAR.
Note 3. To be exnanded and/or revised to accommodate ICr input.
-------
Table 8-2
Sample Indexing Sheet
I. LAW 4 LEGISLATION
SUBCLASS:
DATE:
TITLE:
ORIGIN:
CONTENTS:
(Note: if the title is self-explanatory and contains sufficient
descriptive key words, the entry here is "SEE TITLE")
CROSS REFERENCE:
(Other pertinent categories and subclasses under which the document
should also be listed are given here)
AVAILABILITY:
(Three choices: 1) File [a copy will be actually kept in the file]
2) Available EPA Library
3) Any Technical Library)
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Document availability will be indicated in the final index as follows:
FILE - A hard copy of the document will be placed in the file. This
includes all reports from sources other than the EPA.
AVAILABLE EPA LIBRARY - This entry is being used primarily for EPA re-
ports that are available in the EPA headquarters library in Washington, DC.
Arrangements have been made with Mrs. Sami Klein, the EPA head librarian, to
check on all documents so listed and assure that they are indeed available.
However, if a document is judged to be particulary pertinent, a hard copy
will be placed in the file as well.
ANY TECHNICAL LIBRARY This entry is being used for standard reference
works, handbooks, and textbooks. Again, if a document is judged particularly
pertinent, a hard copy is obtained for the file. A good example of this is
the 1979 two-volume Registry of Toxic Effects of Chemical Substances (RTECS),
which is certainly a key reference, and a copy of this has been purchased to
go into file.
Once the ADP index system is developed and in place, it will be possible
to search for any document in the file at least in the following ways:
1. By any category of subclass
2. By keywords of contents or title entries
3. By date or origin
Additional search and ranking modes for data on fact sheets will also be
developed as these items are Incorporated Into the files.
Computerization Tasks-
Two computerization tasks have been defined:
Task 1 Computerization of chemical fact sheets
Task 2 Computerization of the Reportable Quantities File
To elaborate on these:
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Task 1 - The need to computerize chemical fact sheets. The computeriza-
tion should include the following capabilities:
a) Fact Sheet Entry
b) Fact Sheet Updating and/or Modification
c) Fact Sheet Retrieval by Any of Several as Yet Undefined
Keys. Retrieval Includes Printing of the Sheet.
Task 2 - The Reportable Quantities requires the same capabilities as
the fact sheet, however, the number of keys (categories)
for storage/retrieval probably will be larger.
After consultation with the Project Officer, and several meetings between
her and appropriate EPA personnel, it was decided that the EPA computer system
in Washington would be used. Mr. Steve Heller of EPA-Washington has been our
contact.
Opening a New File in CIS for CERCLA
Opening a special file within CIS to contain the CERCLA data, consisting
of candidate and designated substances and RQs as well as the document record
appears to be highly desirable. As indicated in the excerpt of a trip report
made by the Rockwell Manager of Computer Applications, reproduced below,
clarification of the role of Fein-Manquart is setting up this data file is
essential before proceeding.
"The original intent of this trip, based on information from Dr. A1 Fein
of Fein-Marquart and Steve Heller of the EPA, was to acquire the knowl-
edge necessary to install the two new data bases (Fact Sheets and Legal
File) into the existing CIS data base.
The initial discussions, on Wednesday, July 29, 1981, were centered
around the purpose of the trip. Dr. Fein was under the impression that
the first day was to be spent in training in the use of the ICS, while I
was under the impression that all the time (2 days) was to be spent in
training in the installation of our data bases. At that point, Dr. Fein
explained that the installation of new data bases into CIS was quite
8-14
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complicated and they (Fein-Marquart) would most likely have to do the
major portion of the work.
In addition, since the CIS system has limited formatting (display)
capabilities, Dr. Fein felt that a custom display module would be
necessary in order to provide a display which would suit our needs for
both the Fact Sheets and the Legal File data. This module would also
have to be written by Fein-Marquart.
The remainder of the day, Wednesday, was spent in setting up the actual
mnemonic definitions which will be used by the system for the Fact
Sheets. This process involves choosing codes (1-6 characters), field
numbers, search method and field definitions for each data field to be
used.
A document called TDRS a Textual Document Retrieval System, by Joe R.
McDaniel, Staff Member, Fein-Marquart Associates, was given to me.
This document, a slightly revised version of a document given to us by
Rudy Potenzone of the EPA, represents the only written documentation of
the installation process presented to me, and this document is not
complete. There were sections which Mr. McDaniel had which He did not
give me with the explanation that they were still under development and
not ready for distribution.
The contents of this document, though somewhat helpful, are far from
complete. It is quite obvious that very little, if any written docu-
mentation exists for the actual CIS software. There may be some docu-
mentation within the code itself; however, I do not have copies of the
code at this time, although Dr. Fein agreed to send copies of that data
to me.
Thursday, July 30, 1981, was spent in defining the requirements for our
custom display modules and the anticipated needs for further consulting
during the installation phase.
Although Fein-Marquart was quite cooperative, and they seem extremely
competent, it is quite clear that they intend to guard against outside
intervention into their system. By this I mean that they have not Intent
of letting other firms make software modification to the system such as
would be required to add our data base. They will happy, for a, fee, to
make such modifications for us, but do not seem willing to actually show
us how to do it ourselves.
This 1s quite understandable from their point of view, since CIS repre-
sents a major portion of their business base; however, It will make 1t
quite awkward from our standpoint, since we will be dependent upon them
for whatever modification need to be made.
Additionally, there seems to be very little, 1f any documentation on the
software Itself, although there are decent users' manuals for system
operation.
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SECTION 9
COMMENTS AND EXPERTS
When the program was begun in February 1981, 1t was expected that the
interpretive notice on Sections 102, 103(a,b) would shortly appear 1n the
Federal Register. Since public comments were Invited in that notice for up
to 60 days after publication, plans were also made to respond to those com-
ments. These plans included ways of classifying, organizing, and responding
to such comments. The following discussion presents an overall approach for
dealing with these comments. A system for classifying the comments is also
proposed. Finally, a 11st of topics that commentators are likely to address
and necessary professional disciplines to assist comment responses Is pro-
vided. A start was also made at compiling a specific list of available
experts and centers of excellence for the necessary professional disciplines.
This list 1s short, since the effort was Interrupted when it became clear
that publication of the notice was being delayed,
COMMENTS HANDLING APPROACH
The summary comments handling approach 1s presented 1n Table 9-1. A
proposed comment classification system and a comment topics/experts matrix
are being provided herewith.
As comments are received, they will be classified and organized accord-
ing to the above system. Then, the comments will be distributed to appropri-
ate EMSC staff/experts/centers of excellence for preparation of technical
responses. It was planned to Integrate the total comments and their responses
Into a Response to Comments Report. This Response to Comments Report would
then form a basis for symposia, public meetings and other dialogue with
9-1
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TABLE 9-1. SUMMARY COMMENTS HANDLING APPROACH
*
Accompli shment/Deli verable
Proposed Comment Classification System
Proposed Topics/Experts Matrix
Final Comment Classification System
Subcontract for Administrative Handling
List of Available Experts/Centers of Excellence
Classified and Organized Comments
Response to Comments Report
industrial groups, public interest and environmental groups, and federal/state
agencies in Phase II.
Comments Classification System
A proposed classification system is presented in Table 9-2. The classi-
fication objective is to first assemble public comments by rational techni-
cal categories for use in response preparation, and second, evaluate total
comments by summary tabulations.
Of course, the potential list of issues or topics of comments reflect
the entire activity of designated adjustments to reportable quantities. The
basic issues deal with the following:
o What is a hazardous substance?
o What constitutes a release?
o Is the reportable quantity appropriate?
These questions form the framework for comments classification.
9-2
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TABLE 9-2. COMMENTS CLASSIFICATION SYSTEM FORMAT
Identification
Comment Number
Organization/Individual Name
Organ i zati on/Indi v i dua1 Category
Industry, Public Interest/Environmental, Government Agency, Other
SIC
Geographic Location
State
Issue/Topic
Medium
Air, Water, Land, Groundwater
Substance
Each Designated Hazardous Substance
Persons Subject to the Notification Requirement
Hazardous Substance Designation Process
Release Potential/Mechanism
Reportable Quantity Level
Exemptions
9-3
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u ^ ^
Anticipated Comment Topics/Necessary Experts " »
Table 9-3 presents a topics/experts matrix identifying in greater
detail potential issues or topics that commentators may address, scientific
or technical knowledge necessary to respond to respective comments, and
professional disciplines normally associated with each field.
EXPERTS
A short list of experts fulfilling the needs of the expected comments
appears below. As mentioned earlier, this list is incomplete, because this
task was interrupted shortly after it was begun due to unexpected delays in
the publication of the interpretive notice.
Martin Alexander
Laboratory of Soil Microbiology
Department of Agronomy
Cornell University
Ithaca, NY 14853
Biodegradation in water and soil
Bruce N. Ames
Professor of Biochemistry
University of Califronia
Berkeley, CA
Carcinogenicity testing
Henry T, Appleton
Syracuse Research Corporation
Merrill Lane
Syracuse, NY 13210
Fate and effects of toxic chemicals in water
Etcyl H. Blair
The Dow Chemical Company
Midland, MI 48640
Transport and fate studies
David R. Brown
Associate Professor and Director, Toxicology Program
Northeastern University
Boston, MA
Industrial toxicology, safety evaluation
James L, Burchfiel
Children's Hospital Medical Center
Boston, MA
Neurophysiology effects of toxicants
9-4
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im
TABLE 9-3. COMMENT TOPICS/EXPERTS MATRIX
Required
Scientific/Technical
Issue or Topic
Knowledge Professional Discipline
Hazardous Substance
Designation
Concept of selection
criteria
Criteria themselves
Effects basis
Acute vs chronic effects
Synergism and antagonism
between substances
Human, animal, plant
subject selection
Concentration level
setting
Testing period
Identification specificity
Hazardous Substance
Release Potential
Form of use
Production rate
Substance handling
Modes of distribution/
shipping
Value consideration
Spill history
Toxicity
Carcinogenicity
Mutagenicity
Teratogenicity
Aquatic ecological
effects
Terrestrial ecologi-
cal effects
Bioaccumulation
Ignltability
Corroslvity
Reactivity
Production processes
Packagfng
Distribution
Product
transportation
Toxicologists
Occupational safety/
health specialists
Aquatic ecologists
Terrestrial ecologists
Biostatisticians
Epidemiologists
Explosive/fire
specialists
Manufacturing chemists/
engineers
Transportation officers
Health/safety officers
(continued)
9-5
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TABLE 9-3 (Continued)
Issue or Topic
Required
Scientific/Technical
Knowledge
Professional Discipline
Hazardous Substance
Release Mechanism
Ways substances
enter environment
Reportable Quantity
Determi nation
Physical/chemical
characteristics
of releases
Dispersion, trans-
port, persistence,
transformation,
accumulation of
substances
Manufacturing chemists/
engineers
Health/safety officers
Hydrologlsts
Meteorologists
Environmental
scientists
Basis for level
Relationship to
hazardous level
Multimedia treatment
Accidental/episodic vs
routine continuous/
intermittent releases
Overall environ-
mental impact
Environmental samp-
ling and analysis
Health, safety
officers
Occupational health,
safety specialists
Environmental samp-
ling/analytical
specialists
Release time period
Measurement capability
Information availability
Cost impact to comply
with notification
-------
Wendell L. Dilling
Environmental Sciences Research Laboratory
The Dow Chemical Company
Midland, MI 48640
Photochemical decomposition of organic compounds
Frank H. Duffy
Children's Hospital Medical Center
Boston, MA
Neuorophysiology effects of toxicants
Walter J. Farmer
Department of Soil and Environmental Sciences
University of California
Riverside, CA 92521
Behavior of toxic organic chemicals in the vapor phase
J. G. Fox
Division of Laboratory Animal Medicine
Massachusetts Institute of Technology
Cambridge, MA 02139
N-nitroso compounds
James J. Geraghty
Geraghty & Miller Inc.
6800 Jericho Turnpike
Syosset, NY 11791
Groundwater
Ray Harbison
University of Arkansas
Little Rock, AR
Toxicology
Fred C. Hart
Fred C. Hart Associates
New York, NY
General strategies
L. H. Keith
Radian Corporation
Austin, TX 78766
Chemical analysis of toxic chemicals
Richard A. Kltnerle
Monsanto Company
St. Louis, MO 63166
Hazard evaluation
M.A.Q. Khan
Department of Biological Sciences
University of Illinois at Chicago Circle
Chicago, IL 60680
Chlorinated hydrocarbon pesticides
9-7
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William Lijinsky
Chemical Carcinogenesis Program
Frederick Cavero Research Center
Frederick, MD 21701
Carcinogenicity
Kenneth J. Macek
EG&G
Bionomics Aquatic Toxicology Laboratory
Wareham, MA 02571
Bioconcentration and elimination
Donald Mackay
Department of Chemical Engineering and Applied Chemistry
University of Toronto
Toronto, Ontario M5S1A4
Dispersion of contaminants into water and air
Theodore Mill
SRI International
Menlo Park, CA 94025
Fate of chemicals
Sheldon D. Murphy
Division of Toxicology
Department of Pharmacology
University of Texas Medical School at Houston
Houston, TX 77025
Toxicology
Randy Mott
Zuchert, Scoutt & Rosenberger
Washington, DC
Benefit/cost analysis
Efraim Racher
Cornell University
Ithaca, NY 14853
Carcinogenicity
Arnold E. Reif
Research Professor of Pathology
Boston University School of Medicine
Boston City Hospital
Boston, MA 02118
Causes of cancer
9-8
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APPENDIX A
DEFINITIONS
The Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA) was designed to complement previously existing regulatory
programs under the Clean Air Act (CAA), Clean Water Act (CWA), Toxic Substances
Control Act (TSCA), and the Resource Conservation and Recovery Act (RCRA). As
an "umbrella" act, CERCLA's operative language and definitions has the poten-
tial to be in conflict with the language of acts that are directly affected by
its provisions. To provide assurance that any inconsistencies in the defini-
tions of the above acts do not pose a threat to the intended functioning of the
statute, all the definitions of the CAA, CWA, TSCA, and RCRA were reviewed for
potential conflicts and/or inconcistencies with CERCLA.
The definitions for all terms cited in the acts and compiled below were
screened for inconsistencies. Where inconsistencies were found, the records
were searched to uncover the basis and rationale for the discrepancies. The
only definitions that were found to be Inconsistent enough to warrant comment
consistent with the purpose of this task are as follows:
"Onshore facility" - CERCLA vs CWA
"Owner or operator" - CERCLA vs CWA vs CAA
"Person" - CERCLA vs CWA vs RCRA
"Pollutant" - CERCLA vs CWA
"Remove or removal" - CERCLA vs CWA
"Vessel" - CERCLA vs CWA
It should be kept in mind that the purpose of this analysis was to ensure
that the language of the various definitions, as 1t relates to CERCLA, is
consistent and clear enough to facilitate enactment of the applicable sections
A-l
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of CERCLA pertaining to the designation of hazardous substances and the deter-
mination of their reportable quantities. The analysis of definition incon-
sistencies therefore was restricted to the terms' legal implications regarding
the provisions of Sections 102 and 103.
Although several definitions were found to be materially inconsistent, the
nature of the inconsistencies was primarily related to the broad scope of
CERCLA in contrast to the more restricted scopes of the other Acts. The
inconsistencies between the various definitions identified above appear to
present no problem to either the interpretation or the enforceability of the
applicable sections of CERCLA.
In addition to the above analysis, the text of CERCLA was reviewed in
light of current EPA policy and the Act's legislative history for terms that
might require definition over and above the meaning established by their
common English usage.
TERM INCONSISTENCES
"ONSHORE FACILITY"
o [CERCLA - Sec. 101(18)] means any facility (including, but not
limited to, motor vehicles and rolling stock) of any kind located in,
on, or under any land or non-navigable waters within the United
States.
o [CWA - Sec. 311(a)(1), section specific 3] means any facility
(including, but not limited to, motor vehicles and rolling stock) of
any kind located in, on, or under any .land within the United States
other than submerged land.
"Onshore facility" is essentially defined the same in the two acts except
that the CERCLA definition includes "non-navigable waters" as a specification
as to where an onshore facility is to be located, and the CWA definition
excludes "submerged lands" from its specification of facility location.
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The inclusion of "non-navigable waters" within the CERCLA definition
appears to be related to the scope of the Act's provisions pursuant to Sections
102(a) and 103(a) in that releases to the environment denote all_ media path-
ways. Since the term "offshore facility" under CERCLA is defined with respect
to "navigable waters" only (which is identical to the CWA definition), the
inclusion of "non-navigable waters" within the CERCLA definition is consistent
with the intent and scope of the Act. The differences noted above should not
present any conflict with respect to the provisions of Section 103(a). More
importantly, Section 304(c) of CERCLA provides that any conflicts between
CERCLA and Section 311 of the CWA will be resolved in CERCLA's favor.
"OWNER or OPERATOR"
o [CERCLA - Sec. 101(20)] means (A)(i) in the case of a vessel, any
person owning, oeprating, or chartering by demise, such vessel, (1i)
in the case of an onshore facility or an offshore facility, any
person owning or operating such facility, and (Hi) in the case of
any abandoned facility, any person who owned, operated, or otherwise
controlled activities at such facility Immediately prior to such
abandonment. Such term does not include a person who, without
participating 1n the management of a vessel or facility, holds indi-
cia of ownership primarily to protect his security interest in the
vessel or facility.
(B) in the case of a hazardous substance which has been accepted for
transportation by a common or contract carrier and except as provided
in Section 107(a)(3) or (4) of this Act, (1) the term "owner or
operator" shall mean such common carrier or other bona fide for-hire
carrier acting as an independent contractor during such transporta-
tion, (11) the shipper of such hazardous substance strall not be
considered to have caused or contributed to any release during such
transportation which resulted solely from circumstances or conditions
beyond his control;
(C) in the case of a hazardous substance which has been delivered by
a common or contract carrier to a disposal or treatment facility and
except as provided 1n Section 107(a)(3) or (4) (1) the term "owner or
operator" shall not Include such common or contract carrier, and (11)
such common or contract carrier shall not be considered to have
caused or contributed to any release at such disposal or treatment
facility resulting from circumstances or conditions beyond its
control.
A-3
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o [CWA - Sec. 311(a)(6), section specific 311] means (A) in the case of
a vessel, any person owning, operating, or chartering by demise, such
vessel, and (B) in the case of an onshore facility, and an offshore
facility, any person owning or operating such onshore facility or
offshore facility, and (C) in the case of any abandoned offshore
facility, the person who owned or operated such facility immediately
prior to such abandonment.
o [CAA - Sec. 112(a)(3), section specific 112] shall have the same
meaning as such terms have under section 111(a). (Section 111(a)(5)
of the CAA defines "owner or operator" as "any person who owns,
leases, operates, controls, or supervises a stationary source.")
The meaning'of the term "owner or operator" as defined by the above three
acts differ significantly. The CWA definition restricts its language in the
case of abandoned facilities to offshore facilities and is silent with respect
to the CERCLA definition in clarifying who is an "owner or operator" in the
case of hazardous substances that are accepted and/or delivered by a common or
contract carrier. The CAA definition relates the term in question to a "sta-
tionary source" that includes under Section 111(a)(3) "any building, structure,
facility, or installation which emits or may emit any air pollutant."
The scope of CERCLA's legislative mandate requires that the term "owner or
operator" be extended to establish legal responsibility for virtually all the
ways a release can enter the environment. As such, the Act defines the term
with respect to transportation of hazardous substances as well as making no
distinction between an "offshore facility" or an "onshore facility" in the case
of an abandoned facility. The CWA is limited in scope to include navigable
waters only and therefore is restricted in its language to the "offshore"
environment with respect to abandoned facilities. In any event, the provisions
for conflict resolution under Section 304(c) of CERCLA apply.
The CAA's reference to a "stationary source" in its definition of the term
"owner or operator" can be related to the same concept of facility as covered
by the other two acts in consideration of the definition of "stationary source"
A-4
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under Section 112(a)(3) of the CAA. The CAA specifies that "any building,
structure, facility, or installation which emits or may emit any air pollutant"
is considered a "stationary source" under its definition. Consequently the
language of the CAA does allow releases of air pollutants from a facility to be
tied to the language of establishing legal responsibility under the Act.
"PERSON"
o [CERCLA - Sec. 101(21)] means 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.
o [CWA - Sec. 311(a)(7), section specific 311] includes an Individual,
firm, corporation, association, and a partnership.
o [RCRA - Sec. 1004(15)] means an individual, trust, firm, joint stock
company, corporation (including a government corporation), partner-
ship, association, State, municipality, commission, political sub-
division of a State, or any Interstate body.
Under CERCLA, CWA, RCRA, and CAA there are seven separate definitions of
"person." Of the definitions cited above that relate to applicable sections of
the various acts, each includes individual, firm, corporation, association, and
partnership in their specification of "person." Both CERCLA and RCRA also
include state, municipality, commission, political subdivision, and Interstate
body 1n their definitions. The CERCLA definition Is the only definition to
include consortium, joint venture, cofnmercial entity, and U.S.-Government in
its language.
The definition under CERCLA 1s more broad, in keeping with the scope and
provisions of the Act. The term's broad scope should not present a conflict
with the provisions of the other acts.
"POLLUTANT" (or "CONTAMINANT" - CERCLA)
o [CERCLA - Sec. 104(a)(2), section specific 104] shall Include, but
not be 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
A-5
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into any organism, either directly from the environment or indirectly
by ingestion through food chains, will or may reasonably be antici-
pated 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 and any
fraction thereof which is not otherwise specifically listed or
designated as hazardous substances under Section 101(14)(A) through
(F) of this title, nor does it include natural gas, liquefied natural
gas, or synthetic gas of pipeline quality (or mixtures of natural gas
and such synthetic gas).
o [CWA - Sec. 502(6), except as provided] means dredged spoil, solid
waste, incinerator residue, sewage, garbage, sewage sludge, muni-
tions, chemical wastes, biological materials, radioactive materials,
heat, wrecked or discarded equipment, rock, sand, cellar dirt and
industrial, municipal, and agricultural waste discharged into water.
This term does not mean (A) "sewage from vessels" within the meaning
of Section 312 of this Act; or (B) water, gas, or other material
which is injected into a well to facilitate production of oil or gas,
or water derived in association with oil or gas production and
disposed of in a well, if the well used either to facilitate produc-
tion or for disposal purposes is approved by authority of the State
in which the well is located, and if such State determines that such
injection or disposal will not result in the degradation of ground or
surface water resources.
The term under CERCLA is broadly defined to include essentially every sort
of substance, including "disease-causing agents," that can be released into the
environment and shows a link to death, disease, etc. exclusive of petroleum or
natural gas. The term under CWA is narrowly defined to include specific sub-
stances, including heat, that are discharged into water, exclusive of "sewage
from vessels" or other material injected into wells to facilitate oil and gas
production. In addition, water derived from a State-approved production well
that is reinjected or disposed of is also exempt from the definition.
Since CERCLA contains a broad mandate to provide authority to respond to
all releases into the environment, the definition of "pollutant" contains no
restrictions as to specific media pathways. No apparent conflict exists
A-6
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between response authorities of the two acts as a result of the differences in
their respective definitions. If conflicts were present, the provisions of
Section 304(c) would apply.
"REMOVE or REMOVAL"
o [CERCLA - Sec. 101(23)] means the cleanup or 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 to the environ-
ment, 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 this Act, and any emergency assistance which may be pro-
vided under the Disaster Relief Act of 1974.
o [CWA - Sec. 311(a)(8), section specific 311] refers to removal of
the 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, including, but not
limited to, fish, shellfish, wildlife, and public and private prop-
erty, shorelines, and beaches.
The definition in the CWA refers to removal of oil and hazardous sub-
stances from waters and shorelines, as well as "other actions that may be
necessary to minimize or mitigate damage." The CERCLA definition is more
comprehensive as it specifies actions for removal and cleanup of hazardous
substances from the environment with no specification of media pathways.
CERCLA also includes actions that are authorized to monitor and assess releases
or threats of release. Since the term "Hazardous Substance" as defined 1n
CERCLA specifically excludes petroleum, the actions under tne definition of
"remove or removal" pursuant to CERCLA does not extend to petroleum releases.
The implications are that authority for removing petroleum from the environment
A-7
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falls outside the authority of CERCLA and comes under the provisions of Section
311(c)(1) of the CWA.
"VESSEL"
o [CERCLA - Sec. 101(28)] means every description of watercraft or
other artificial contrivance used, or capable of being used, as a
means of transportation on water.
o [CWA - Sec. 311(a)(3), section specific 311] means every description
of watercraft or other artificial contrivance used, or capable of
being used, as a means of transportation on water other than a public
vessel.
The only difference in the definition of terms under the two acts is the
exclusion of "public vessel" from the definition under the CWA. The implica-
tion is that CERCLA pertains to aJJ_ types of vessels under its provisions,
which is entirely consistent with its legislative mandate.
NEW DEFINITIONS
"REPORTABLE QUANTITY" [Section 102(b)]
means a quantity of a hazardous substance as set forth in subsection 1,
the release of which requires notice as set forth in subsection 2. Blank
subsections refer to forthcoming regulations pursuant to Sections 102(b)
and 103(a) that list RQs and prescribe notification instructions, re-
spectively.
"MIXTURE" [Section 102(a)]
means any combination of two or more substances in varying proportions
that retain their own individual properties.
"PUBLIC WELFARE" [Section 102(a)]
includes, but is not limited to, private and public property, economic and
aesthetic values, weather, visibility, animals, crops, man-made materials,
and personal comfort and well-being.
"AFFECTED STATE" [Section 103(a)]
means that state or states within which a release occurs, or that state or
states that may be materially influenced by such a release originating
beyond its borders.
A-8
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"WORKPLACE" [Section 101(22)(A)]
means a facility that is totally enclosed such that a release of a haz-
ardous substance within its confines cannot enter the environment.
"SUBSTANTIAL THREAT OF RELEASE" [Section 104(a)(1)(A)]
means an imminent event that requires an immediate response in accordance
with subsection 1 in order to prevent such a release. (The blank subsec-
tion refers to forthcoming regulations describing the type of responses
authorized by the Act in Sections 104, and the National Contingency Plan.)
"IN CHARGE" [Section 103(b)]
means, in the case of a vessel or facility, exercising control of oper-
ations or custody at the time of a release of a hazardous substance equal
to or greater than its reportable quantity as set forth in subsection 1.
(The blank subsection refers to forthcoming regulations that list RQs for
designated hazardous substances.)
"STABLE IN QUANTITY AND RATE" [Section 103(f)(2)]
in the case of routine continuous or anticipated intermittent releases
means within normal limits characteristic of the circumstances of the
release.
"CONSUMER PRODUCT IN CONSUMER USE" [Section 101(9)(B)]
means any article sold to a consumer for that person's use, consumption,
or enjoyment in or around a household, residence, school, 1n recreation or
otherwise.
"NUCLEAR INCIDENT, SOURCE, BYPRODUCT, SPECIAL NUCLEAR MATERIAL" TSection
101(22)(cT]
means the same as those terms as defined in the Atomic Energy Act of 1954.
"NORMAL APPLICATION OF FERTILIZER" [Section 101(22)]
means application 1n accordance with label instructions and consistent
with the product's customary uses.
"PUBLIC RECORD" [Section 101(10)]
means the NPDES permit application or the NPDES permit Itself and the
"record for final permit" as defined in 40 CFR Part 124.122.
"TOXIC POLLUTANT" [Section 101(14)(D)]
means the same as those listed under Section 307(a)(1) of the Federal
Water Pollution Control Act.
A-9
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"HAZARDOUS AIR POLLUTANT" [Section 101(14)(E)]
means the same as those listed under Section 112 of the Clean Air Act.
"IMMINENTLY HAZARDOUS CHEMICAL SUBSTANCE OR MIXTURE" [Section 306(a)]
means the same as those that are subject to action by the Administrator
pursuant to Section 7 of the Toxic Substances Control Act.
"HAZARDOUS MATERIAL" [Section 306(a)]
means the same as that defined under 49 CFR Part 171 pursuant to the
Hazardous Material Transportation Act.
"PUBLIC HEALTH" [Section 102(a)]
means human health and well-being of the population of the United States.
"STATISTICALLY SIGNIFICANT INCREASE" [Section 103(f)(2)]
means, in the case of routine, continuous, or anticipated intermittent
releases, a statistical increase as measured by the student's t-test at a
level of significance set forth in subsection 1. (Blank subsection
refers to forthcoming regulations that will explain, in detail, the pro-
cedures for obtaining the appropriate statistical measures.)
COMPILATION OF TERMS
The compilation of terms from the several related acts follows in alpha-
betical order.
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DEFINITIONS
This is an alphabetized compilation of all defined terms cited In the following
acts:
1. The Comprehensive Environmental Response, Compensation, and Liability Act
of 1980. (CERCLA)
2. The Federal Water Pollution Control Act, as amended by the Clean Water Act
of 1977 (Commonly Referred to as the Clean Water Act) (CWA).
3. The Toxic Substances Control Act (TSCA)
4. The Clean A1r Act (CAA)
5. The Resource Conservation and Recovery Act of 1976 (RCRA)
Reference Citations Format:
Act - Text location, part of act to which definition applies): Example -
CWA - Sec. 112(a), SS 109-112) Term applies to the entire act, except as
noted. Underlined words 1n definitions and, as appropriate, paragraph
spacing are for editorial emphasis only.
SS means Section Specific
TS means Title Specific
PS means Paragraph Specific
CS means Chapter Specific
A-11
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TABLE CF CONTENTS
Academic Year A-1!7
Act o£ God A-17
Administrator A-17
Air Pollutant A-13
Air Pollution Gontrol Agency A-18
As Expeditiously as Practicable • . A-19
Barrel A-19
Baseline Concentration A-19
Baseline Model Year A-20
Basin A-20
Best Available Gontrol Technology A-20
Biological Monitoring A-21
Board A-21
Category of Chemical Substances A-21
Category of Mixtures A-21
Chemical Substance A-22
Citizen A-2
Claim A-2
Claimant A-2
Commenced A-23
Commerce A-23
Commercial Vessels A-23
Comprehensive Planning ^-23
Construction A-24
Contaminant ^-25
Contiguous Zone ^-25
Control
Crude Oil A"2C
Damages A-2G
Dealer A-2G
Delayed Compliance Order A-26
Demonstration A-27
Designed for Emission Control A-27
Discharge A-27
Discharge of a Pollutant A-28
Dispersion Technique A-20
Disposal A-28
Distribution in Commerce A-29
Domestic Crude Oil A-29
Drinking W&ter Supply A-29
Effects on Wslfare A-30
Effluent Limitations A-30
Effluent Standard or Limitation Under This Aot A-30
Eligible Treatment Wbrks A-31
Emission Standard or Limitation A-31
A-12
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TABLE of CONTENTS (Cont'd)
Environment A-32
Evidence A-32
Existing Source A-32
Existing Vessel A-33
Facility . A-33
Federal Agency . A-33
Federal Government A-33
Federal Land Manager A-33
Federally Permitted Release A-34
Food A-35
Fractional Part of Barrel A-35
Fractional Part of Ton A-36
Fuel Economy improvement Standard A-36
Fund or Trust F\ond A-36
Gasoline A-36
Graywater A-36
Ground Vfeter . A-37
Guarantor A-37
Halocarbon A-37
Hazardous Air Pollutant A-37
Hazardous Substance A-38
Hazardous W&ste A-39
Hazardous teste Generation A-39
Hazardous Vfcste Management ......... A-40
Health and Safety Study A-40
Heavy Duty Vehicle A-40
High Terrain Area A-40
Imminently Hazardous Chemical Substance A-41
Implementation A-41
Importer A-41
Indirect Source A-41
Indirect Source Review Program ....^ A-42
Industrial User A-42
Inland Oil Barge A-42
Inland Waiters of the United States A-42
Institution of Higher Education
Intermunicipal Agency J""43
Interstate Agency A-43
Interstate Air dilution Control Agency A-43
Jurisdiction of the united States ......... A-43
Liable or Liability . A-44
Light Duty Chicles and Engines A-44
Long-Term Contract A-44
Low Terrain Area
-------
•mBLE OF CONTENTS (Cont'd)
Low-ESnission Vehicle A-45
Lowest Achievable Emission Rate A-45
Lubricating Oil A-45
Major Etaitting Facility A-45
Major Stationary Source A-46
Management of Parking Supply A-47
Mandatory Class I Federal Areas A-47
Manifest A-47
Marmade Air Pollution A-47
Manufacture A-48
Manufacturer A-48
Manufacturer Parts . A-48
Marine Sanitation Device A-49
Means of Emission Limitation A-49
Mixture A-49
Model Year
Modification
A-50
Modified {*50
Motor Vehicle I^"^~
Municipality .. ..........
National Contingency Plan A-51
Natural Resources ........ A-52
Navigable Waters A-52
Necessary Preconstruction Approvals or Permits A-52
New Chemical Substance A-52
New Motor Vehicle A-53
New Motor Vfehicle Ehgine A-53
New Source A-53
New Vessel A-54
Nonattainment Area ...... A-54
Not Feasible to Prescribe A Standard of Performanc . . A-54
Not Feasible to Prescribe an Ehission Standard A-54
Ocean ..... .•••>•...>• A—55
Offshore Facility ^-55
Oil J";*
Onshore Facility .....
Open Dump ""if,
Operator
Organization
Owner A"56
Owner or Operator . A-5t>
Parking Surcharge Regulation A-58
Person A-58
Petroleum Product A-59
Point Source . A-59
Pollutant ............ A-60
A-14
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TABLE CF CONTENTS (Cont'd)
Pollution .... A-60
Preferential Bus/C&rpool Lane A-f-1
premises -J"6]
Primary Standard Attainment Date . A-G»
Process • A-61
Processor ...... ..... ^-61
Procurement ^"6*
Procuring Agency A-61
Public Vessel ....... A-62
Qualified Hazardous W&ste Disposal Facility A-62
Qualified Substance A-63
Qualified Use A-63
He-Refined Oil . A-63
Reasonable Elirther Progress A-63
Recoverable A-63
Recovered Material ......... A-64
Recovered Resources A-64
Recycled Oil A-64
R6fln€r #«•~••••»••••••*•••••••••••••* A-64
Refineries vhich Produce Natural Gasoline A~64
Refinery A-65
Regional Authority A-65
Release A-65
Remedy or Remedial Action .......... ... A-66
Remove or Removal A-67
Replacement A-68
Resource Conservation A-68
Resource Recovery A-68
Resource Recovery Facility , . A-69
Resource Recovery System „ A-69
Respond or Response A-69
Retail Price Ar69
Sanitary Landfill A-69
Sanitation Services ........... — . . A-69
Schedule and Timetable of Osmpil lance A-69
Schedule of Compliance A-70
Secretary A-70
Serious Bodily Injury . A-70
Sevage A-70
Sludge A-71
Small Refinery . A-71
Solid Waste A-71
Solid Waste Management ............ ..... A-71
Solid Wfcste Management Facility ................. A-71
Solid Vtaste Planning A-72
Source ....... ........... A-72
Standard of Performance A-73
A-15
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TOBIE OF CONTENTS (Cont'd)
Standards for the Development of Test Data A-73
State A-74
State Authority . A-74
State W&ter Pollution Gontrol Agency A-74
Stationary Source A-75
Storage A-75
Stratosphere A-75
Sustained-Use Motor Vehicle A-75
Taxable Chemical A-76
Technological Systems A-76
Territorial Sea A-i76
Territorial Seas A-78
Ton A-78
Totally Enclosed Manner A-78
Toxic Pollutant ..... A-78
Transport or Transportation A-79
Treatment A-79
Treatment Wbrks A-80
Ultimate Purchaser A-80
United States A-80
United states Refinery A-81
Used Oil A-82
Vessel A-82
Village A-82
virgin Material A-82
Visibility Impairment or impairment of visibility A-83
A-16
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"ACADEMIC YEAR"
1. means an academic year or its equivalent, as determined by the
Administrator.
(CWA - Sec. 112(a), SS 109-112)
"ACT OF GOD"
1. means an unanticipated grave natural disaster or other natural phenomenon
of an exceptional, inevitable, and irresistible character, the effects of
which could not have been prevented or avoided by the exercise of due
care or foresight.
(CERCLA - Sec. 101(1))
2. means an act occasioned by an unanticipated grave natural disaster.
(CWA - Sec. 311(a) (12), SS 311)
"ADMINISTRATOR"
1. means the Administrator of the Uhited States Environmental Protection
Agency.
(CERCLA - Sec. 101(2))
2. means the Administrator of the Environmental Protection Agency.
(TSCA - Sec. 3(1))
3. means the Administrator of the Environmental Protection Agency.
(CAA - Sec. 302(a))
4. means the Administrator of the Environmental Protection Agency
(RCRA - Sec. 1004(1))
A-T7
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"AIR POLLUTANT"
1. means any air pollution agent or combination of such agents, including a
physical, chemical, biological, radioactive (including source material,
special nuclear material, and by-product material) substance or matter
which is emitted into or otherwise enters the ambient air.
(CAA - Sec. 302(g))
"AIR POLLUTION CONTROL AGENCY"
1. means any of the following:
(A)A single State agency designated by the Governor of that State as the
official State air pollution control agency for purposes of this Act.
(B) An agency established by two or more States and having substantial
powers or duties pertaining to the prevention and control of air
pollution.
(C) A city, county, or other local government health authority, or, in
case of any city, county, or other local goverment in which is an agency
other than the health authority charged with responsibility for enforcing
ordinances or laws relating to the prevention ard control of air
pollution, such other agency.
(D) An agency of two or more municipalities located in the same State or
in different States and having substantial powers or duties pertaining to
the prevention and control of air pollution.
(CAA - Sec. 302(b))
A-18
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"AS EXPEDITIOUSLY AS PRACTICABLE"
1. means as expeditiously as practicable but in no event later than five
years after the date of approval of a plan revision under this section
(or the date of promulgation of such a plan revision in the case of
action by the Ailministrator under section 110(c) for purpose of this
section.)
(CAA - Sec. 169A(g)(4), SS l«9fc)
"BARREL"
1. means forty-two Uhited States gallons at sixty degrees Fahrenheit.
(CERCLA - Sec. 101(3))
2. means 42 United States gallons.
(CERCLA -Title II, Subtitle A, Chapter 38,Subchapter A,
Sec. 4512(a) (8), CS 38A)
3. means 42 United states gallons at <50 degrees Fahrenheit.
(CWA - Sec. .311(a) (13), SS 311)
"BASELINE CONCENTRATION"
1. means, with respect to a pollutant, the ambient concentration levels
vfcich exist at the time of the first application for a permit in an area
subject to this part, based pn air quality data available in the
Environmental Protection Agency or a State air pollution control agency
and on such monitoring data as the permit applicant is required to
submit. Such ambient concentration levels shall take into account all
projected emissions in, or which may affect, such area from any major
emitting facility on which construction commenced prior to January <5,
1975, but which has not begun operation by the date of the baseline air
quality concentration determination. Emissions of sulfur oxides and
particulate matter from amy major emitting facility on which construction
commenced after January 6, 1975, shall not be included in the baseline
and shall be counted against the maximum allowable increases in pollutant
concentrations established under this part.
(CAA - Sec. 169(4), PSC)
A—19
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"BASELINE MODEL YEAR"
1. means, with respect to any pollutant emitted from any vehicle or engine,
or class or category thereof, the model year immediately preceding the
model year in which Federal standards applicable to such vehicle or
engine, or class or category thereof, first applied with respect to such
pollutant.
(CAA - Sec. 202(a) (3) (A) (v) , PS 202(a) (3) (A) (v))
"BASIN"
1. includes, but is not limited to, rivers and their tributaries, streams,
coastal waters, sounds, estuaries, bays, lakes, and portions thereof, as
well as the lands drained thereby.
(CWA - SS 102(c) (3) ,SS 102(C))
"BEST available control TECHNOLOGY"
1. means an emission limitation based on the maximum degree of reduction of
each pollutant subject to regulation under this Act emitted from or which
results from any major emitting facility, which the permitting authority,
on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such
facility through application of production, processes and available
methods, systems, and techniques, including fuel cleaning or treatment or
innovative fuel combustion techniques for control of each such pollutant.
In no event shall application of'best available control technology'
result in emissions of any pollutants which will exceed the emissions
allowed by any applicable standard established pursuant to section 111 or
112 of this act.
(CAA - Sec. 169(3), PSC)
A-20
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"BIOLOGICAL MONITORING"
1. shall mean the determination of the effects on aquatic life, including
accumulation of pollutants in tissue, in receiving waters due to the
discharge of pollutants (A) by techniques and procedures, including
sampling of organisms representative of appropriate levels of the food
chain appropriate to the volume and the physical, chemical, and
biological characteristics of the effluent, and (B) at appropriate
frequencies and locations.
(CWA - Sec. 502(15)), Except as provided
"BOARD"
1. means the Low-Emission Vfehicle Certification Board.
(CAA - Sec. 212(a) (1), SS 212)
"CATEGORY OF CHEMICAL SUBSTANCES"
1. means a group of chemical substances the members of which are similar in
molecular structure, in physical, chemical, or biological properties, in
use, or in mode of entrance into the hunan body or into the environment,
or the members of which are in some other way suitable for classification
as such for* purposes of this Act, except that such term does not mean a
group of chemical substances which are grouped together solely on the
basis of their being new chemical substances.
(TSCA - Sec. 26(b) (2) (A), SS 26(b) (1))
"CATEGORY OF MIXTURES"
1. means a group of mixtures the members of which are similar in molecular
structure, in physical, chemical, or biological properties, in use, or in
the mode of entrance into the hunan body or into the environment, or the
members of which are in some other way suitable for classification as
such for purposes of this Act.
(TSCA - Sec. 26(b) (•?) (B), SS 26(b) (1))
A-21
-------
"CHEMICAL SUBSTANCE"
1. means (A) any organic or inorganic substance of a particular molecular
identity, including (i) any combination of such substances occurring in
whole or in part as a result of a chemical reaction or occurring in
nature, and (ii) any element or uncombined radical.
(B) Such term does not include (i) any mixture, (ii) any pesticide (as
defined in the Federal Insecticide, Fungicide, and Itodenticide Act) vhen
manufactured, processed, or distributed in commerce for use as a
pesticide, (iii) tobacco or any tobacco product, (iv) any source
material, special material, or by product material (as such terms are
defined in the Atomic Ehergy Pet of 1954 and regulations issued under
such Art) , (v) any article the sale of which is subject to the tax
imposed by section 4181 or 4221 or any other provision of such Code), and
(vi) any food, food additive, drug, cosmetic, or device (as such terms
are defined in section 201 of the Federal Ebod, Drug, and Cbanetic Pet)
when manufactured, processed or distributed in commerce for use as a
food, food additive, drug, coanetic, or device. (Except as provided in
subparagraph (B) of Sec. 3.)
(TSCA - Sec. 3(2)(A))
"CITIZEN"
1. means a person or persons having an interest vhich is or may be adversely
affected.
(CWA - Sec. 505(g), SS 505)
"CLAIM"
1. means a demand in writing for a sum certain.
(CERCLA - Sec. 101(4))
"CLAIMANT?"
1. means any person who presents a claim for compensation under this Pet.
(CERCLA - Sec. 101(5))
A-22
-------
"COMMENCED"
1. as applied to construction of a major emitting facility means that the
owner or operator has obtained all necessary preconstruction approvals or
permits required by Federal, State, or local air pollution emissions and
air quality laws or regulations and either has (i) begun, or caused to
begin, a continuous program of physical on-site construction of the
facility of (ii) entered into binding agreements or contractual
obligations, which cannot be canceled or modified without substantial
loss to the owner or operator, to undertake a program of construction of
the facility to be completed within a reasonable time.
(CAA - Sec. 169(2)(A), PSC)
"COMMERCE"
1. means trade, traffic, transportation, or other commerce (A) between a
place in a State and any place outside of such State, or (B) which
affects trade, traffic, transportation, or commerce described in clause
(A).
(TSCA - Sec. 3(3))
2. means (A) commerce between any place in any State and any place outside
thereof; and (B) commerce vholly within the District of Golunbia.
(CAA - Sec. 21
-------
"CONSTRUCTION"
1. means any one or more of the following: preliminary planning to
determine the feasibility of treatment works, engineering, architectural,
legal, fiscal, or economic investigations or studies, surveys, designs,
plans, working drawings, specifications, procedures, or other necessary
actions, erection, building, acquisition, alteration, remodeling,
improvement, or extension of treatment works, or the inspection or
supervision of any of the foregoing items.
(CWA - Sec. 212(1), TS II)
2. means any placement, assembly, or installation of facilities or equipnent
(including contractual obligations to purchase such facilities or
equipment) at the premises where such equipnent will be used, including
preparation work at such premises.
(CWA - Sec. 306(a)(5), SS 306)
3. when used in connection with any source of facility, includes the
modification (as defined in section 111(a)) of any source or facility.
(CAA - Sec. 169(2) (Q , PSC)
4. with respect to any project of construction under this Act, means (A) the
erection or building of new structures and acquisition of lands or
interests therein, or the acquisition, replacement, expansion,
remodeling,, alteration, modernization, or extension of existing
structures, and
(B) the acquisition and installation of initial equipment of, or required
in connection with, new or newly acquired structures or the expanded,
remodeled, altered, modernized or extended part of existing structures
(including trucks and other motor vehicles, and tractors, cranes, and
other machinery) necessary for the proper utilization and operation of
the facility after completion of the project; and includes preliminary
planning to determine the economic and engineering feasibility and the
public health and safety aspects of the project, the engineering,
architectural, legal, fiscal, and economic investigations and studies,
and any surveys, designs, plans, working drawings, specifications, and
other action necessary for the carrying out of the project, and
(C) the inspection and supervision of the process of carrying out the
project to completion.
(RCRA - Sec. 1004(2))
At 24
-------
"CONTAMINANT"
1. shall include, but not be 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 routation,
physiological malfunctions (Including malfunctions in reproduction) or
physical deformations, in such organisms or their offspring.
The term does not include petroleum, including crude oil and any fraction
thereof which Fs not otherwise specifically listed or designated as
hazardous substances under section 101 (14) (A) through (F) of this title,
nor does it include natural gas, liquefied natural gas, or synthetic gas
of pipeline quality (of mixtures of natural gas arri such synthetic gas).
(CERCLA - SEC. 104(a) (2), SS 104)
"CONTIGUOUS ZONE"
1. shall have the meaning provided in section 502 of the Federal tteter
Pollution Control Act.
(CERCLA - Sec. 101(30))
2. means the entire zone established or to be established by
States under article 24 of the Convention on the "territorial
Contiguous Zone.
(CWA - Sec. 311(a) (9), SS 311)
3. means the entire zone established or to be established by
States under article 24 of the Convention of the Territorial
Contiguous Zone.
(CWA - Sec. 502(9)), Except as provided
the United
Sea and the
the United
Sea and the
A-25
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"CONTROL"
1. of a corporation means ownership of more than 50 percent of its stock.
(CAA - Sec. 325(c)(2), SS 325)
"CRUDE OIL"
1. includes crude oil condensates and natural gasoline.
(CERCLA -Title II, Subtitle A, Chapter 38, Subchapter Af
Sec. 4612(a) (1), CS 38A)
"DAMAGES"
1. means damages for injury or loss of natural resources as set forth in
section 107(a) or 111(b) of this Pet.
(CERCLA - Sec. 101(6))
"DEALER"
1. means any parson who is engaged in the sale or the distribution of new
motor vehicles or new motor vehicle engines to the ultimate purchaser.
(CAA - sec. 216(4), TS II)
"DELAYED COMPLIANCE ORDER"
1. means an order issued by the State or by the Administrator to an existing
stationary source, postponing the date required under an applicable
implementation plan for compliance by such source with any requirement of
such plan.
(CAA - Sec. 302(o))
A-26
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"DEMONSTRATION"
1. means the initial exhibition of a new technology process or practice or a
significantly new combination or use of technologies, processes or
practices, subsequent to the development stage, for the purpose of
proving technological feasibility and cost effectiveness.
(RCRA - Sec. 1004(2A))
"DESIGNED FOR EMISSION CCMTROL"
1. as used in the preceding sentence means a catalytic converter, thermal
reactor, or other component installed on or in a vehicle for the sole or
primary purpose of reducing vehicle emissions (not including those
vehicle components which were in general use prior to model year 19^8 and
the primary function of which is not related to emission control) .
(CAA - Sec. 207(a)(3),, Sentence Specific, Sec. 207(a)(3) 1st Sentence)
"DISCHARGE"
1. includes, but is not limited to, any spilling, leaking, punping, pouring,
emitting, emptying or dumping, but excludes (A) discharges in compliance
with a permit under section 402 olTthis A:t,
(B) discharges resulting from circunstances Identified and reviewed and
made a part of the public record with respect to a permit issued or
modified under section 402 of this Act, and subject to a condition in
such permit, and
(C) continuous or anticipated intermittent discharges from a point
source, identified in a permit or permit application under section 402 of
this Act, which are caused by events occuring within the scope of
relevant operating or treatment systems.
(CWA - Sec. 311(a)(2), SS 311)
A-27
-------
2. includes, but is not limited to, any spilling, leaking, punping, pouring,
emitting, emptying or dunping.
(CWA - Sec. 312(a) (9), SS 312)
3. when used without qualification includes a discharge of a pollutant, and
a discharge of pollutants.
(CWA - Sec. 502(16)) ,Except as provided
"DISCHARGE OF A POLLUTANT" or "DISCHARGE OF POLLUTAM'S"
1. each means (A) any addition of any pollutant to navigable waters from any
point source, (B) any addition of any pollutant to the water of the
contiguous aone or the ocean from any point source other than a vessel or
other floating craft.
(OTA - Sec. 502(12)) ,Except as provided
"DISPERSION TECHNIQUE"
1. includes any intermittent or supplemental control of air pollutants
varying with atmospheric conditions.
(CAA - Sec. 123(b) , SS 123)
"DISPOSAL"
1. shall have the meaning provided in section 1004 of the Solid fcfcste
Disposal Pet.
(CERCLA - Sec. 101(29))
A-?§
-------
2. means the discharge, deposit, injection, dunping, spilling, leaking, or
placing of any solid waste or hazardous wastes into or on any land or
water so that such solid waste into or on any land or water so that such
solid waste or hazardous waste or any constituent thereof may enter the
environment or be emitted into the air or discharged into any waters,
including ground waters.
(RCRA - Sec. 1004(3))
"DISTRIBUTE IN COMMERCE" and "DISTRIBUTION IN CCMMERCE"
1. when used to describe an action taken with respect to a chemical
substance or mixture or article containing a substance or mixture mean to"
sell, or the sale of, the substance, mixture, or article in commerce; to
introduce or deliver for introduction into commerce, or the introduction
or delivery for introduction into commerce of, the substance, mixture, or
article; or to hold, or the holding of, the substance, mixture, or
article after its introduction into coronerce.
(TSCA -Title II, Subtitle A, Chapter 38, Subchapter A, Sec. 3(4))
"DOMESTIC CRUDE OIL"
1. means any cyude oil produced from a well located in the united States.
(CEKCLA - Sec. 4612(a)(2), CS 38A)
"DRINKING WATER SUPPLY"
1. means any raw or finished water source that is or may be "used by a public
water system (as defined in the Safe Drinking Wbter tet) or as drinking
water by one or more individuals.
(CERCLA - Sec. 101(7))
tf 29
-------
"EFFECTS ON WELFARE"
1. includes, but is not limited to, effects on soils, water, crops,
vegetation, manmade materials, animals, wildlife, v^ather, visibility,
and climate, damage to and deterioration of property, and hazards to
transportation, as well as effects on economic values and on personal
comfort and well-being.
(CM - Sec. 302(h))
"EFFLUENT LIMITATIONS"
1. means any restriction established by a State or the administration on
quantities, rates, and concentrations of chemical, physical, biological,
and other constituents which are discharged from point sources into
navigable waters, the waters of the contiguous zone, or the ocean,
including schedules of compliance.
(CWA - Sec. 502(11)), Except as provided
"EFFLUENT STANDARD OR LIMITATION UNDER THIS ACT'
1. means (1) effective July 1, 1973, an unlawful act under subsection (a) of
section 301 of this Act;
(2) an effluent limitation or other limitation under section 301 or 302
of this ?ct;
(3) standard of performance under section 305 of this Act;
(4) prohibition, effluent standard or pretreatment standards under
section 307 of this Act;
(5) certification under section 401 of this Act; or
(6) a permit or condition thereof issued under section 402 of this fit:t,
which is in effect under this Act (including a requirement applicable by
reason of section 313 of this Act).
(CWA - Sec. 505(f) , SS 505)
A-30
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ELIGIBLE TREATMENT WORKS"
1. means those treatment works in each State which meet the requirements of
section 201(g) (5) of this Pet and diich can be fully funded from funds
available for such purpose in such State in the fiscal years ending
September 30, 1979, September 30, 1980, and September 30, 1981. Such
term does not include collector sewers, interceptors, storm or sanitary
severs or the separation thereof, or major sewer rehabilitation.
(CWA - Sec. 202(a) (4), SS 202)
EMISSION STANDARD OR LIMITATION"
1. means (1) a schedule or timetable of compliance, emission limitation,
standard of performance or emission standard.
(2) a control or prohibition respecting a motor vehicle fuel or fuel
additive, which is in effect under this £ct (including a requirement
applicable by reason of section 118) or under an applicable
implementation plan, or
(3) any condition or requirement of a permit and part C of title I
(relating to nonattairment), any condition or requirement of section
113(d) (relating to certain enforcement orders), 119 (relating to primary
nonferrous -smelter orders), any condition or requirement under an
applicable implementation plan relating to transportation control
measures, air quality maintenance plans, vehicle inspection and
maintenance programs, or vapor recovery requirements, section 211(e)- and
(f) (relating to fuels and fuel additives) # section 1*9A (relating to
visibility protection), any condition or requirement under part B of
title I (relating to oaone protection), or any requirement under section
111 or 112 without regard to Whether such requirement is expressed as an
emission standard or otherwise.
(CAA - Sec. 304(f), SS 304)
2* "HMISSI0N LIMITATION* —means a requirement established by the State or
the Administrator which limits the quantity* rate, or concentration of
emissions of air pollutants on a continuous basis including any
requirement relating to the operation or maintenance of a source to
assure continuous emission reduction.
(CAA-Sec. 302(k))
-------
3. "EMISSION STANDARD" means a requirement established by the State or
the Administrator viiich limits the quantity, rate, or conentration of
emissions of air pollutants on a continuous basis including any
requirement relating to the operation or maintenance of a source to
assure continuous emission reduction.
(CAA - Sec. 302(k))
"ENyiRQWEWT"
1. means (A) the navigable waters, the waters of the contiguous aone, arx3
the ocean waters of which the natural resources are under the exclusive
management authority of the United States under the Fishery Conservation
and Management Act of 1976, and (B) any other surface water, ground
water, drinking water supply, land surface or subsurface strata, or
ambient air within the United States or inder the jurisdiction of the
United States.
(CERCLA - Sec. 101(8))
2. includes water, air, and land and the interrelationship which exists
among and between tveter, air, and larxJ and all living things.
(TSCA - Sec- 3(5))
"EVIDENCE"
1. as used in clause (i) the term means any matter in the rulemaking record.
(TSCA - Sec. 19(c) (1) (B) (iii) , SS 19(c) (1) (3) (i))
"EXISTING SOURCE"
1. means any stationary source other than a new source.
(CAA - Sec. 111(a)(5), SS 111)
2. shall have the same meaning as such terms have under section 111(a).
(CAA - Sec. 112(a) (3), SS 112)
A-32
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"EXISTING VESSEL"
1. includes every description of watercraft or other artifical contrivance
used, or capable of being used, as a means of transportation on the
navigable waters, the construction of which is initiated before
promulgation of standards and regulations under this section.
(CWA - Sec. 312(a)(2), SS 312)
"FACILITY"
1. means (A) any building, structure, installation, equipnent, 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, or aircraft, or (B) any site or
area where a hazardous substance has been deposited, stored, disposed of,
or placed, or otherwise come to be located; but does not include any
consumer product in consuner use or any vessel.
(CERCIA - Sec. 101(9))
"FEDERAL AGENCY"
1. means any department, agency, or other instrumentality of the Federal
Government, any independent agency or establishment of the Federal
Government including any Government corporation, and the Government
Printing Office.
(RCRA - Sec. 1004(4))
"FEDERAL GOVERNMENT"
1. includes the legislative, executive, and judicial branches of the
Government of the Uhited States, and the government of the District of
Colunbia.
(CAA - Sec. 212(a) (2), SS 212)
"FEDERAL LAND MANAGER"
I, means with respect to any lands in the United States the secretary of the
department with authority over such land.
(CAA - Sec. 302(i))
A-35
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"FEDERALLY PERMITTED RELEASE"
1. means (A) discharges in compliance with a permit under section 402 of the
Federal Wkter Pollution Control Act,
(B) discharges resulting from circumstances identified and reviewed and
made part of the public record with respect to a perait issued or
modified under section 402 of the Federal V&ter Pollution Control Act and
subject to a condition of such permit,
(O continuous or anticipated intermittent discharges from a point
source, identified in a permit or permit application under section 402 of
the Federal Water Pollution Control Act, fcfaich are caused by events
occuring within the scope of relevant operating or treatment systems,
(D) discharges in compliance with a legally enforceable permit under
section 404 of the Federal W&ter Pollution Control Act,
(E) releases in compliance with legally enforceable final permit issued
pursuant to section 3005(a) through (d) of the Solid Waste Disposal Act
from a hazardous waste treatment, storage, or disposal facility vhen such
permit specifically identifies the hazardous substances and makes such
substances subject to a standard of practice, control procedure or
bioassay Imitation or condition, or other control on the hazardous
substances in such releases,
(F) any release in compliance with a legally enforceable permit issued
under section 102 of section 103 of the Marine Protection, Research, and
Sanctuaries A2t of 1972,
(G) any injection of fluids authorized under Federal undergound injection
control programs or State programs submitted fcr Federal approval (an not
disapproved by the administrator of the Bivirormental Protection Agency)
pursuant to part C of the Safe Drinking W&ter Act,
(H) any emission into the air subject to a permit or control regulation
under section 111, section 112, title I part C, title I part D, or State
implementation plans submitted in accordance with section 110 of the
Clean Air Act (and not disapproved by the Administrator of the
Environmental Protection Agency) , including any schedule or waiver
granted, promulgated, or approved under these sections,
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(I) any injection of fluids or other materials authorized under
applicable State law (i) for the purpose of stimulating or treating wells
for the production of crude oil, natural gas, or water, (ii) for the
purpose of secondary, tertiary, or other enhanced recovery of crude oil
or natural gas, or (iii) which are brought to the surface in conjunction
with the production of crude oil or natural gas and Uiich are reinjected,
(J) the introduction of any pollutant into a publicly owied treatment
works v«ihen such pollutant is specified in and in compliance with
applicable pretreatment standards of section 307 (b) or (c) of the Clean
Wfcter Act and enforceable requirements in a pretreatment program
submitted by a State or municipality for Federal approval under section
402 of such Act, and
(K) any release of source, special nuclear, or byproduct material, as
those terms are defined in the Atomic Ehergy Act of 1954, in compliance
with a legally enforceable license, permit, regulation, or order issued
pursuant to the Atomic Ehergy Act of 1954.
(CERCLA - Sec. 101(10))
"FOOD"
1. as used in clause (vi) of this subparagraph includes poultry and poultry
products (as devined in sections 4(e) and 4(f) of the Poultry Products
Inspection Act), meat and meat food products (as defined in section 1
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"FRACTIONAL PART OF TON"
1. In the case of a fraction of a ton, the tax imposed by section 4*561 shall
be the same fraction of the amount of such tax imposed on a whole ton.
(CERCLA - Title II, Subtitle A, Chapter 38, Subchapter B,
Sec. 4**2(a)(5), CS 38B)
"FUEL ECONOMY IMPROVEMENT STANDARD"
1. means a requirement of a percentage increase in the number of miles of
transportation provided by a manufacturer's entire annual production of
new motor vehicles per unit of fuel consuned, as determined for each
manufacturer in accordance with test procedures established by the
Administrator pursuant to this Act. Such term shall not include any
requirement for any design standard or any other requirement specifying
or otherwise limiting the manufacturer's discretion in deciding how to
comply with the fuel economy improvement standard by any lawful means.
(CAA - Sec. 213(a) (2), SS 213)
"FUND" or "TRUST FUND"
1. means the Hazardous Substance Response Fund established by section 221 of
this Ast or, in the case of a hazardous waste disposal facility for which
liability has been transferred under section 107(k) of this Art, the
Post-closure Liability EUnd established by section 232 of this Ast.
(CERCLA - Sec. 101(11))
"GASOLINE"
1. has the meaning provided under regulations of the Mministrator
promulgated inder this section.
(CAA - Sec. 211(g) (1) (A), SS 211(g))
"GRAVWATER"
1. means galley, bath, and shower water.
(CWA - Sec. 312(a)(11), SS 312)
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"GROUND WATER"
1. means water in a saturated 2one or stratun beneath the surface of land or
water.
(CERCIA - Sec. 101(12))
"GUARANTOR"
1. means any person, other than the owner or operator, vtoo provides evidence
of financial responsibility for an owner or operator under this fict.
(CERCIA - Sec. 101(13))
"HALOCARBON"
1. means the chemical compounds CFCL3 and CF-Cl- and such other halogenated
compounds as the Administrator determines rrtay reasonably be anticipated
to contribute to reductions in the concentration of ozone in the
stratosphere.
(CAA - Sec. 152(1), TS 1(B))
"HAZARDOUS AIR FOLLUTA^'
1. means an air pollutant to which no anbient air quality standard is
applicable and which in the judgment of the Aflministrator causes, or
contributes to, air pollution which may reasonably be anticipated to
result in an increase in mortality or an increase in serious
irreversible, or incapacitating reversible, illness.
(CAA - Sec. 112(a)(1), SS 112)
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"HAZARDOUS SUBSTANCE"
1. means (A) any substance designated pursuant to section 311(b)(2)(A) of
the Federal Water Pollution Control Pet,
(B) any elenent, compound, mixture, solution, or substance designated
pursuant to section 102 of this Pet,
(Q any hazardous waste having the characteristics identified under or
listed pursuant to section 3001 of the Solid Waste Disposal Pet (but not
including any waste the regulation of which under the Solid V&ste
Disposal Act has been suspended by the Act of Congress) ,
(D) any toxic pollutant listed under section 307(a) of the Federal W&ter
Pollution Control Pet,
(E) any hazardous air pollutant listed tnder section 112 of the Clean Air
Act, and
(F) any imminently hazardous chemical substance or mixture with respect
to which the Administrator has taken action pursuant to section 7 of the
Toxic Substances Oontrol Pet.
The terra does not include petroleun, including crude oil or any fraction
thereof which Ts not otherwise specifically listed or designated as a
hazardous substance under subparagraphs (A) through (F) of this
paragraph, and the tenn 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) .
(CERCLA - Sec. 101(14))
2. means any substance designated pursuant to subsection (b) (2) of this
section.
(CWA - Sec. 311(a) (14), SS 311)
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"HAZARDOUS WASTE"
X. shall have the meaning provided in section 1004 of the Solid W&ste
Disposal Act.
(CERCIA - Sec. 101(29))
2. means any waste (A) having the characteristics identified isider section
3001 of the Solid Whste Disposal Act, as in effect on the date of the
enactment of this Pet (other than waste the regulation of which under
such Art has been suspended by the Act of Congress on that date), or (B)
subject to the reporting or recordkeeping requirements of sections 3002
and 3004 of such Ast, as so in effect.
(CERCIA - Title II, Subtitle C, Chapter 38, Subchapter C,
Sec. 4682(a) (1), CS 38C)
3. means a solid waste, or combination of solid wastes, which because of its
quantity, concentration, or physical, chemical, or infectious
characteristics may—
(A) cause, or significantly contribute to an increase in mortality or an
increase in serious irreversible, or incapaciting reversible, illness;
or
(B) pose a substantial present or potential hazard to human health or the
environment when improperly treated, stored, transported, or disposed of, *
or otherwise managed.
(RCRA - Sec. 1004(5))
"HAZARDOUS WASTE GENERATION"
1. means the act or process of producing hazardous waste.
(RCRA - Sec. 1004(5))
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"HAZARDOUS WASTE MANAGEMENT"
1. means the systematic control of the collection, source separation,
storage, transportation, processing, treatment, recovery, and disposal of
hazardous wastes.
(RCRA - Sec. 1004(7))
"HEALTH AND SAFETY STUDY"
1. means any study of any effect of a chemical substance or mixture on
health or the environment or on both, including underlying data and
epidemiological studies, studies of occupational exposure to a chemical
substance or mixture, toxicological, clinical, and ecological studies of
a chemical substance or mixture, and any test performed pursuant to this
£ct.
(TSCA - Sec. 3(*))
"HEAVY DUTY VEHICLE"
1. means a truck, bus, or other vehicle manufactured primarily for use on
the public streets, roads, and highways (not including any vehicle
operated exclusively on a rail or rails) which has a gross vehicle weight
(as determined under regulations promulgated by the ASminstrator) in
excess of six thousand pounds. Such term includes any such vehicle which
has special features enabling off-street or off-highway operation and
use.
(CAA - Sec. 202(b) (3) (C) , PSD)
"HIGH TERRAIN AREA"
1, means with respect to any facility, any area having an elevation of 900
feet or more above the base of the stack of such facility.
(CAA - Sec. 165(d) (2) (D) (iv) , SS 1*5(d) (2) (D) (iii))
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w IMMINENTLY HAZARDOUS CHEMICAL SUBSTANCE OR MIXTURE"
1. means a chemical substance or mixture which presents an imminent and
unreasonable risk of serious or widespread injury to health or the
environment. Such a risk to health or the environment shall be
considered imminent if it is shown that the manufacture, processing,
distribution in commerce, use, or disposal of the chemical substance or
mixture, or that any combination of such activities, is likely to result
in such injury to health or the environment before a final rule under
section 6 can protect against such risk.
(TSCA - Sec. 7(f) , SS 7(b))
w IMPLEMENTATION"
1. does not include the acquisition, leasing, construction, or modification
of facilities or equipment or the acquisition, leasing or improvement of
land. (Pot purposes of Federal financial assistance other than rural
commuiities assistance.)
(RCRA - Sec. 1004(8))
"IMPORTER"
1. means the person entering the taxable chemical for consumption, use, or
warehousing.
(CERCLA - Title II, Subtitle A, Chapter 38, Subchapter B,
Sec. 4662(a) (3), CS 38B)
" INDIRECT SOURCE"
1. means a facility, building, structure, installation, real property, road,
or highway which attracts, or may attract, mobile sources of pollution.
Such term includes parking lots, parking garages, and other facilities
subject to any measure for management of parking supply (within the
meaning of section 110(c)(2)(D) (ii)), inclining regulation of existing
off-street parking but such term does not include new or existing
on-street parking. Direct emissions sources or facilities at, within, or
associated with, any indirect source shall not be deemed indirect sources
for the purpose of this paragraph.
(CAA - Sec. 5110(a) (5) (O r SS110(a) (5) (Q )
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"INDIRECT SOURCE REVIEW PROGRAM"
1. means the facility-by-facility review of indirect sources of air
pollution, including such measures as are necessary to assure, or assist
in assuring, that a new or modified indirect source will not attract
mobile sources of air pollution, the emissions from which would cause or
contribute to air pollution concentrations-(i) exceeding -any national
primary ambient air quality standard for a mobile source-related air
pollutant after the primary standard attainment date, or (ii) preventing
maintenance of any such standard after such date.
(CAA - Sec. 110(a) (5) (0), SS 110)
"INDUSTRIAL USER"
1. means those industries identified in the Standard Industrial
Classification Manual, Bureau of the Budget, 19*57, as amended and
supplemented, under the category "Division D - Manufacturing" and such
other classes of significant waste products as, by regulation, the
Administrator deems appropriate.
(CWA - Sec. 502(18)) , Except as provided
"INLAND OIL BARGE"
1. means a non-self-propelled vessel carryirvg oil in bulk as cargo and
certificated to operate only in the inland waters of the united States,
while operating in such waters.
(CWA - Sec. 311(a) (15), SS 311)
"INLAND WATERS TOE UNITED STATES"
1. means those waters of the Uhited States lying inside the baseline from
which the territorial sea is measured and those waters outside such
baseline which are a part of the Gulf Intracoastal W&terway.
(CWA - Sec. 311(a) (16), SS 311)
"INTERMUNICIPAL AGENCY"
1. means an agency established by two or more municipalities with
responsibility for planning or administration of solid waste.
(FCRA - Sec. 1004(9))
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"INSTITUTION OF HIGHER EDUCATION"
1. means an educational institution described in the first sentence of
section 1201 of the Higher Education Pet of 1965 (Other than an
institution of any agency of the united States) fchich is accredited by a
nationally recognized accrediting agency of association approved by the
Administrator for this purpose.
(CWA - Sec. 112(a), SS 109-112)
"INTERSTATE AGENCY"
1. means an agency of two or more states established by or pursuant to an
agreement of compact approved by the Cbngress, or any other agency of tvo
or more. States, having substantial powers or duties pertaining to the
control of pollution as determined and approved by the Administrator.
(CWA - Sec. 502(2)), Bccept as provided
2. means an agency of tvo or more municipalities in different States, or an
agency established by two or more States, with authority to provide for
the management of solid wastes and serving tvo or more municipalities
located in different States.
(RCRA - Sec. 1004(10))
"INTERSTATE AIR POLLUTION CONTROL AGENCY"
1. means (1) an air pollution control agency established- by tvo or more
States, or (2) an air pollution control agency of two or more
municipalities located in different States.
(CAA - Sec.302 (c))
"OTHERWISE SUBJECT TO THE JURISDICTION OF TOE UNITED STATES"
1. means subject to the jurisdiction of the Uhited States by virtue of
United States citizenship, united states vessel documentation or
numbering, or as provided by international agreement to which the United
States is a party.
(CEEOA - Sec. 101(19))
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2. means subject to the jurisdiction of the united States by virtue of
United States citizenship, tjhited States vessel docunentation or
numbering, or as provided for by international agreement to which the
United States is a party.
(CWA - Sec. 311(a) (17), SS 311)
"LIABLE" CR "LIABILITY"
1. under this title shall be construed to be the standard of liability vtaich
obtains under section 311 of the Federal Vfeter Pollution Control Act.
(CERCLA - Sec. 101(32))
"LIGHT DOTY VEHICLES AND ENGINES"
1. means new duty motor vehicles and new light duty motor vehicle engines,
as determined under regulations of the administrator.
(CAA - Sec. 202(b) (3) (B) , PSD)
"LONG-TERM CONTRACT"
1. means, when used in relation to solid waste supply, a contract of
sufficient duration to assure the viability of a resource recovery
facility (to the extent that such viability depends upon solid waste
supply).
(RGRA - Sec. 1004(11))
"LOW TERRAIN AREA"
1. means any area other than a high terrain area.
(CAA - Sec. 165(d)(2)(D)(iv), SS 165(d)(2)(D)(iii))
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"LOW-EMISSION VEHICLE"
1. means any motor vehicle which (A) emits any air pollutant in amounts
significantly below new motor vehicle standards applicable under section
202 at the time of procurement to that type of vehicle; and (B) with
respect to all other air pollutants meets the new motor vehicle standards
applicable under section 202 at the tirae of procurement to that type of
vehicle.
(CM - Sec. 212(a) (4), SS 212)
"LOWEST ACHIEVABLE EMISSION RATE"
1. means for any source that rate of emissions which reflects (A) the most
stringent emission limitation which is contained in the impleraenttion
plan of an State for such class or category of source, unless the owner
or operator of the proposed source demonstrates that such limitations are
not achievable, or
(B) the most stringent emission limitation which is achieved in practice
by such class or category of source, vtaichever is more stringent. In no
event shall the application of this term permit a proposed new or
modified source to emit any pollutant in excess of the amount allowable
under applicable new source standards of performance.
(CAA - 110(a)(2)(I)(3), Sec. 171(3), PS-C)
"LUBRICATING OIL"
1. means the fraction of crude oil which is sold for purposes of reducing
friction in any industrial^ or mechanical device. -Such term includes
re-refined oil.
(RCRA - Sec. 1004(38))
"MAJOR EMITTING FACILITY"
1. means any of the following stationary soL-rces of air pollutants -which
emit, or have the potential to mlt, one hundred tons per year or more of
any air pollutant from the following types of stationary sources:
fossil-fuel fired steam electric plants of more than two hundred and
fifty million British thermal units per hour heat input, coal cleaning
plants (thermal dryers), kraft pulp mills, Portland Oment plants,
primary zinc smelters, iron and steel mill plants, primary alum in un ora
A-45
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reduction plants, primary copper smelters, municipal incinerators capable
of charging more than two hundred and fifty tons of refuse per day,
hydrofluoric, sulfuric, and nitric acid plants, petroleum refineries,
lime plants, phosphate rock processing plants, coke oven batteries,
sulfur recovery plants, carbon black plants (furnace process), primary
lead smelters, fuel conversion plants, sintering plants, secondary metal
production facilities, chemical process plants, fossil-fuel boilers of
more than two hundred and fifty million British thermal units per hour
heat input, petroleum storage and transfer facilities with a capacity
exceeding three hundred thousand barrels, taconite ore processing
facilities, glass fiber processing plants, charcoal production
facilities. Such term also includes any other source with the potential
to emit two hundred and fifty tons per year or more of any air pollutant.
This term shall not include new or modified facilities vfoich are
nonprofit health or education institutions which have been exempted by
the State.
(CAA - Sec. 169 (1), PSC)
2. means any stationary facility or source of air pollutants which directly
emits, or has the potential to emit, one hundred tons per year or more of
any air pollutant (including any major emitting facility or source of
fugitive emissions of any such pollutant, as determined by rule by the
Administrator) .
(CAA - Sec. 302(j))
"MAJOR STATIONARY SOURCE"
1. means the following types of stationary sources with the potential to
emit 250 tons or more of any pollutant; fossil-fuel fired steam electric
plants of more then 250 million British thermal units per hour heat
input, coal cleaning plants (thermal dryers), draft pulp mills, Portland
Cement plants, primary zinc anelters, iron and steel mill plants, primary
aluminum ore reduction plants, primary copper anelters, municipal
incinerators capable of charging more than 250 tons of refuse per day,
hydrofluoric, sulfuric, and nitric acid plants, petroleum refineries,
lime plants, phosphate rock processing plants, coke oven batteries,
sulfur - recovery plants, carbon black plants (furnace process), primary
lead smelters, fuel conversion plants, sintering plants, secondary metal
production facilities, chemical process plants, fossil-fuel boilers of
more than 250 million British thermal units per hour heat input,
petroleum storage and transfer facilities with a capacity exceeding
300,000 barrels, taconite ore processing facilities, glass fiber
processing plants, charcoal production facilities.
(CAA - Sec. 169A(g) (7), SS 169A)
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2. means any stationary facility or source of air pollutants vtaich directly
emits, or has the potential to emit, one hundred tons per year or more of
any air pollutant (including any major emitting facility or source of
fugitive emissions of any such pollutant, as determined by rule by the
Administrator) .
(CAA - Sec. 302(j))
"MANAGEMENT OF PARKING SUPPLY"
1. shall include any requirement providing that any new facility containing
a given number of parking spaces shall receive a permit or other prior
approval, issuance of which is to be conditioned on air quality
considerations.
(CAA - Sec. 110(c) (1) (D) (ii) , SS 110(c) (1) (D))
"MANDATORY CLASS I FEDERAL AREAS"
1. means Federal areas vhich may not be designated as other than class I
under this part.
(CAA - Sec. 169A(g) (5), SS 1S9A)
"MANIFEST"
1. means the form used for identifying the quantity, composition, and the
origin, routing, and destination of hazardous- waste during its
transportation from the point of generation to the point of disposal,
treatment, or storage.
(RCRA - Sec. 1004(12))
"MAWADE AIR POLLUTION"
1. means air pollution vhich results directly or indirectly from human
activities.
(CAA - Sec, 169Mg) (3), SS 169A)
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"MANUFACTURE"
1. means any person engaged in the manufacturing, assembling, or importation
of marine sanitation devices or of vessels subject to standards and
regulations promulgated under this section.
(CWA - Sec. 312(a) (7), SS 312)
2. means manufacturing or processing for commercial purposes.
(TSCA - Sec. 5(i) , SS 5)
"MANUFACTURER"
1. means to import into the customs territory of the United States (as
defined in general headnote 2 of the Tariff Schedules of the united
States), produce, or manufacture.
(TSCA - Sec. 3(7))
2. as used in sections 202, 203, 206, 207, and 208 means any person engaged
in the manufacturing or assembling of new motor vehicles or new motor
vehicle engines, or importing such vehicles or engines for resale, or who
acts for and is under the control of any such person in connection with
the distribution of new motor vehicles or new motor vehicle engines, but
shall not include any dealer with respect to new motor vehicles or new
motor vehicle engines received by him in commerce.
(CAA - Sec. 216(1), SS 202/203,206,207,208)
*MANUFACTURER PARTS"
1. means, with respect to a motor vehicle engine, parts produced or sold by
the manufacturer of the motor vehicle or motor vehicle engine.
(CAA - Sec. 203(a) (4) (D), Sentence Specific Sec. 203(a) (4) (D), 3rd
Sentence)
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"MARINE SANITATION DEVICE"
1. includes any equipment for installation on board a vessel which is
designed to receive, retain, treat, or discharge sewage, and any process
to treat such sewage.
(CWA - Sec. 312(a)(5), SS 312)
"MEANS OF EMISSION LIMITATION"
1. means a system of continuous emission reduction (including the use of
specific technology or fuels with specified pollution characteristics).
(CAA - Sec. 302(m))
"MIXTURE"
1. means any combination of two or more chemical substances if the
combination does not occur in nature and is not, in whole or in part, the
result of a chemical reaction; except that such term does include any
combination which occurs, in whole or in part, as a result of a chemical
reaction if none of the chemical substances comprising the combination is
a new chemical substance and if the combination could have been
manufactured for commercial purposes without a chemical reaction at the
time the chemical substances comprising the combination were combined.
(TSCA - Sec. 3(8))
"MODEL YEAR"
1. with reference to any specific calendar year means the manufacturers
annual production period {as determined by the Administrator) which
includes January 1 of such calendar year. If the manufacturer has no
annual production period, the term 'model year' shall mean the calendar
year.
(CAA - Sec. 202(b) (3) (A) (i), PSD)
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"MODIFICATION"
1. means any physical change in, or change in the method of operation of, a
stationary source which increases the amount of any air pollutant emitted
by such source or which results in the emission of any air pollutant not
previously emitted.
(CAA - Sec. 111(a)(4), SS 111)
2. shall have the same meaning as such terms have under section 111(a).
(CAA - Sec. 112(a)(3), SS 112)
3. means the sane as the term 'modification' as used in section 111(a)(4) of
this Pet,
(CAA - 110(a) (2) (I) (4), Sec. 171(4),PS-D)
"MODIFIED"
1. means the same as the term 'modification' as used in section 111(a)(4) of
this Pet,
(CAA - 110(a)(2) (I) (4), Sec. 171(4),PS-D))
"MOTOR VEHICLE"
1. means any self-propelled vehicle designed for use in the united States on
the highways, other than a vehicle designed or used for military field at
training, combat, or tactical purposes.
(CAA - Sec. 212(a) (3), SS 212)
2. means any self-propelled vehicle designed for transporting persons or
property on a street or highway.
(CAA - Sec. 216(2), TS II)
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"MUNICIPALITY"
1. means a city, tovri, borough, county, parish, district, association, or
other public body created by or pursuant to State law and having
jurisdiction over disposal of sewage, industrial wastes, or other wastes,
or an Indian tribe or an authorized Indian tribal organization, or a
designated and approved management agency under section 208' of this Act.
(CWA - Sec. 502(4)}, Except as provided
2. means a city, town, borough, county, parish, district, or other public
body created by or pursuant to State law.
(CM - Sec. 302(f))
3. (A) means a city, tovn, borough, county, parish, district, or other
pitolic body created by or pursuant to State law, with responsibility for
the planning or administration of solid waste management, or an Indian
tribe or authorized tribal organization or Alaska Native village or
organization, and
(B) includes any rural community or unincorporated town or village or any *
other public entity for which an application for assistance is made by a
State or politcal subdivision thereof.
(RCRA - Sec. 1004(13))
"NATIONAL CONTINGENCY PLAN"
1. means the national contingency plan published under section 311(c) of the
Federal Vtater Pollution Control Act or revised pursuant to section 105 of
this /tot.
(CERCLA - Sec. 101(31))
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"NATURAL RESOURCES"
1. means land, fish, wildlife, biota, air, water, ground water, drinking
water supplies, and other such resources belonging to, managed by, held
in trust by, appertaining to, or otherwise controlled by the Uhited
States (including the resources of the fishery conservation zone
established by the Fishery Conservation and Management Pet of 1976), any
State or local government, or any foreign government.
(CERCIA - Sec. 101(16))
"NAVIGABLE WATERS"
1. means the waters of the Uhited States, including the territorial seas.
(CWA - Sec. 502(7)), Except as provided
2. Navigable W&ters" or "Navigable frfeters of the Uhited States means the
waters of the Uhited States, including the territorial seas.
(CERCIA - Sec. 101(15))
"NECESSARY FRECONSTRUCTION APPROVALS OR PERMITS'
1. means those-permits or approvals, required by the permitting authority as
a precondition to undertaking any activity under clauses (i) or (ii) of
subparagraph (A) of this paragraph.
(CAA - 169(2) (B) , PSC)
"NEW CHEMICAL SUBSTANCE"
1. means any chemical substance which is not included in the chemical
substance list compiled and published under section 8(b).
(TSCA - Sec. 3(9))
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"NEW MOTOR VEHICLE"
1. means a motor vehicle the equitable or legal title to which has never
been transferred to an ultimate purchaser.
(CAA - Sec. 216(2), TS II)
"MEW MOTOR VEHICLE ENGINE"
1. means an engine in a new motor vehicle or a motor vehicle engine the
equitable or legal title to which has never been transferred to the
ultimate purchaser; and with respect to imported vehicles or engines,
such terms mean a motor vehicle and engine, respectively, manufactured
after the effective date of a regulation issued under section 202 vriiich
is applicable to such vehicle or engine (or which vould be applicable to
such vehicle or engine had it been manufactured for importation into the
United states).
(CAA - Sec. 215(3), TS II)
"NEW SOURCE"
1. means any source, the construction of which is commenced after the
publication of proposed regulations prescribing a standard of performance
under this section which will be applicable to such source, if such
standard is thereafter promulgated in accordance with this section.
(CWA - Sec. 30*(a)(2), SS 306)
2. means any stationary source, the construction or modification of which is
commenced after the publication of regulations (or, is earlier, proposed
regulations) prescribing a standard of performance under this section
vfcich will be applicable to such source.
(CAA - Sec. ill(a)(2), SS 111)
3. means a stationary source, the construction or modification of which is
commenced after the Administrator proposes regulations under this section
establishing an emission standard which will be applicable to such
source.
(CAA - Sec. 112,(a)(2), SS 112)
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"NEW VESSEL"
1. includes every description of watercraft or other artifical contrivance
used, or capable of being used, as a means of transportation on the
navigable waters, the construction of which is initiated after
promulgation of standards and regulation under this section.
(CWA - Sec. 312(a) (1), SS 312)
"NONATTAIWIENT AREA"
1. means for any air pollutant an area which is shown by monitored data or
which is calculated by air quality modeling (or other methods determined
by the Administrator to be reliable) to exceed any national ambinet air
quality standard for such pollutant. Such term includes any area
identified under paragraphs (A) through (C) of section 107(d)(1).
(CAA - 110(a) (2) (I) (2), Sec. 171(2), PS-D)
"NOT FEASIBLE TO PRESCRIBE OR ENFORCE AN EMISSION STANDARD"
1. means any situation in which the Administrator determines that (A) a
hazardous pollutant or pollutants cannot be emitted through a conveyance
designed and constructed to emit or capture such pollutant, or that any
requirement for, or use of, such a conveyance would be inconsitent with
any Federal, State, or local law, or
(B) the application of measurement methodology to a particular class of
sources is not practicable due to technological or economic limitations.
(CAA - Sec. 112(e) (2), SS 112(e))
"NOT FEASIBLE TO FRESCRIBE OR ENFORCE A STANDARD OF PERFORMANCE"
1. means any situation in which the Administrator determines that (A) a
pollutant or pollutants cannot be emitted through a conveyance designed
and constructed to emit or capture such pollutant, or that any
requirement for, or use of, such a conveyance would be inconsistent with
any Federal, State, or lccal law, or
(B) the application of measurement methodology to a particular class of
sources is not practicable due to technological or economic limitations.
(CAA - Sec. 111(b)(2), SS 111)
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"OCEAN"
1. means any portion of the high seas beyond the contiguous aone.
(CWA - Sec. 502(10)), accept as provided
"OFFSHORE FACILITY"
1. means any facility of any kind located in, on, or under, any of the
navigable waters of the Uhited States, and any facility of any kind which
is subject to the jurisdiction of the Uhited States and is located in,
on, or under any other waters, other than a vessel or a public vessel.
(CERCIA - Sec. 101(17))
2. means any facility of any kind located in, on, or under, any of the
navigable waters of the United States, and any facility of any kind which
is subject to the jurisdiction of the Uhited States and is located in,
on, or under any other waters, other than a vessel ot a public vessel.
(CWA - Sec. 311(a) (11), SS 311)
"OIL"
1. means oil of any kind or in any form, including, but not limited to
petroleum, fuel oil, sludge, oil refuse, arxi oil mixed with wastes other
than dredged spoil.
(CWA - Sec. 311(a) (1), SS 311)
"ONSHORE FACILITY"
1. means any facility (including, but not limited to, motor vehicles arid
rolling stock) of any kind located in, on, or under, any land or
nonnavigable waters within the Uhited States.
(CERCIA - Sec. 101(18))
2. means any facility (including, but not limited to, motor vehicles and
rolling stock) of any kind located in, on, or under, any lard within the
Uhited States other than submerged land.
(CWA - Sec. 311(a) (10), SS 311)
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"OPEN DLMP"
1. means any facility or site where solid waste is disposed of which is not
a sanitary landfill which meets the criteria promulgated under section
4004 artf which is not a facility for disposal of hazardous waste.
(RCRA - Sec. 1004(14))
* OPERATOR"
1. shall have the same meaning as such terms have under section 111(a).
(CAA - Sec. 112(a)(3), SS 112)
" ORGANIZATION*
1. means a legal entity other than a government# established or organized
for any purpose, and such teem includes a corporation, company,
association, firm, partnership, joint stock company, foundation,
institution, trust, society, union or any other association of persons.
(RCRA - Sec. 3008 (f) (5))
"OWNER"
1. shall have the same meaning as such terms have under section 111(a).
(CAA - Sec. 112(a)(3), SS 112)
"OWNER or OPERATOR"
1. means (A) (i) in the case of a vessel, any person owing, operating, or
charterir*g by demise, such vessel, (ii) in the case of an onshore
facility or an offshore facility, any person owning or operating such
facility, and (iii) in the case of any abandoned facility, any person who
owned, operated, or otherwise controlled activities at such facility
immediately prior to such abandonment. Such torn does not include a
person, who, without participating in the management of a vessel or
facility, holds indicia of ownership primarily to protect his security
interest in the vessel or facility.
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(B) in the case of a hazardous substance which has been accepted for
transportation by a common or contract carrier and except as provided in
section 107(a) (3) or (4) of this Act, (i) the term "ovner or operator"
shall mean such common carrier or other bona fide for hire carrier acting
as an independent contractor during such transportation, (ii) the shipper
of such hazardous substance shall not be considered to have caused or
contributed to any release during such transportation which resulted
solely from circunstances or conditions beysnd his control?
(C) in the case of a hazardous sitostance which has been delivered by a
common or contract carrier to a disposal or treatment facility and except
as provided in section 107(a) (3) or (4) (i) the term "owner or opera tor"
shall not include such common or contract carrier, and (ii) such common
or contract carrier shall not be considered to have caused or contributed
to any release at such disposal or treatment facility resulting from
circunstances or conditions beyond its control.
(CERCLA - Sec. 101(20))
2. means any person vho owns, leases, operates, controls, or supervises a
source.
(CWA - Sec. 306(a) (4), SS 306)
3. means (A) in the case of a vessel, any person owning, operating, or
chartering .by demise, such vessel, and (B) in the case of an onshore
facility, and an offshore facility, any person owning or operating such
onshore facility or offshore facility, and (O in the case of any
abandoned offshore facility, the person who owned or operated such
facility immediately prior to such abandonment.
(CWA - Sec. 311(a) (S), SS 311)
4. means any person who owns, leases, operates, controls, or supervises a
stationary source.
(CPA - Sec. 111(a) (5), SS 111)
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PARKING SURCHARGE REGULATION"
1. means a regulation Imposing or requiring the imposition of any tax,
surcharge, fee, or other charge on parking spaces, or any other area used
for the temporary storage of motor vehicles.
(CAA - Sec. 110(c) (1) (D) (i), SS 110(c) (1) (D))
"PERSON"
1. means 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.
(CERCLA - Sec. 101(21))
2. shall mean, in addition to the definition contained in section 50?.(5) of
this Act, any responsible corporate officer.
(CWA - Sec. 309(c) (3), SS 309(c))
3. includes an individual, firm, corporation, association, and a
partnership.
(CWA - Sec. 311(a) (7), SS 311)
4. means an individual, partnership, firm, corporation, or association, but
does not include an individual on board a public vessel.
(CWA - Sec. 312(a)(8), SS 312)
5. shall mean, in addition to the definition contained in section 502(5) of
this Pet, any responsible corporate officer.
(CWA - Sec. 404(S) (4) (B) , SS 404(s) (4) (A)
6. means an individual, corporation, partnership, association, State,
municipality, ccanmission, or political subdivision of a State, or any
interstate body.
(CWA - Sec. 502(5)), Except as provided
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7. includes, in addition to the entities referred to in section 302(e), any
responsible corporate officer.
(CAA - Sec. 113(c) (3), SS 113(c))
8. includes an individual, corporation, partnership, association, State,
municipality, political subdivision of a State, and any agency,
department, or instrunentality of the United State municipality, politcal
subdivision of a State, and any agency, department, or instrunental ity of
the Uhited States and any officer, agent, or employee thereof.
(CAA - Sec. 302(e))
9. means an individual, trust, firm, joint stock company, corporation
(including a government corporation), partnership, association, State,
municipality, commission, political subdivision of a State, or any
interstate body.
(RCRA - Sec. 1004(15))
"PETROLEUM PRODUCT"
1. includes crude oil.
(CERCIA - Title II, Subtitle A, Chapter 38, Subchapter A,
Sec. 4612(a) (3), CS 38A)
"POINT SOURCE*
1. means any discernible, confined and discrete conveyance, including but
not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete
fissure, container, rolling stock, concentrated animal feeding operation,
or vessel or other floating craft, from which pollutants are or may be
discharged. This term does not include return flows from irrigated
agriculture.
(CWA - Sec. 502(14)), Except as provided
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"POLLUTANT"
1. means dredged spoil, solid waste, incinerator residue, sewage, garbage,
sewage sludge, munitions, chemical wastes, biological materials,
radioactive materials, heat, wrecked or discarded equipment, rock, sand,
cellar dirt and industrial, municipal, and agricultural waste discharged
into water.
This tern does not mean (A) "sewage from vessels" within the meaning of
section 312 of this Act; or (B) water, gas, or other material vfoich is
injected into a well to facilitate production of oil or gas, or water
derived in association with oil or gas production and disposed of in a
well, if the well used either to facilitate production or for disposal
purposes is approved by authority of the State in which the well is
located, and if such State determines that such injection or disposal
will not result in the degradation of ground or surface water resources.
(CWA - Sec. 502(fi)), Except as provided
2. shall include, but not be 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 organisns or their offspring.
The term does not include petroleum, including crude oil and any fraction
thereof vfaich is not otherwise specifically listed or designated as
hazardous substances under section 101(14) (A) through (F) of this title,
nor does it include natural gas, liquefied natural gas, or synthetic gas
of pipeline quality (or mixtures of natural gas and such synthetic gas).
(CERCLA - Sec. 104(a) (?.), SS 104)
"POLLUTION*
1. means the man-made or man-induced alteration of the chemical, physical,
biological and radiological integrity of water.
(CWA - Sec. 502(19)), Except as provided
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"PREFERENTIAL BUS/CARPOOL LANE"
1. shall include any requirement for the setting aside of one or more lanes
of a street or highway on a permanent or temporary basis for the
exclusive use of buses or carpools, or both.
(CAA - Sec. 110(A) (1) (0) (iii) , SS 110(c) (1)
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"PROCESS"
1. means the preparation of a chemical substance or mixture, after its
manufacture, for distribution in commerce (A) in the same form or
physical state as, or in a different form or physical state from, that in
which it was received by the person so preparing such substance or
mixture, or (B) as part of an article containing the chemical substance
or mixture.
(TSCA - Sec. 3(10))
2. means manufacturing or processing for commercial purposes.
(TSCA - Sec. 5(i) , SS 5)
"PROCESSOR"
1. means any person who processes a chemical substance or mixture.
(TSCA - Sec. 3(11))
"PUBLIC VESSEL"
1. means a vessel owned or bareboat-chartered and operated by the united
States, or by a State or political subdivision thereof, or by a foreign
nation, except when such vessel is engaged in commerce.
(CWA - Sec. 311(a)(4), SS 311)
2. means a vessel owned or bareboat-chartered and operated by the United
States, by a State or political subdivision thereof, or by a foreign
nation, except when such vessel is engaged in commerce.
(CWA - Sec. 312(a) (3), SS 312)
"QUALIFIED HAZARDOUS WASTE DISPOSAL FACILITY"
1. means any facili-y vhich has received a permit or is accorded interim
status under section 3005 of the Solid Wsste Disposal Act.
(CERCLA - Title II, Subtitle C,Chapter 38,Subchapter C,
Sec. 4682(a) (2), CS 38C)
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"QUALIFIED SUBSTANCE"
1. means any substance (i) used in a qualified use by the manufacturer,
producer, or importer, (ii) sold for use by the purchaser in a qualified
use, or (iii) sold for resale by the purchaser to a second purchaser for
use by such second purchaser in a qualified use.
(CERCLA - Title II, Subtitle A, Chapter 38, Subchapter B,
Sec. 46*2(b) (2) (B) , SS 4662(b))
"QUALIFIED USE"
1. means any use in the manufacture or production of a fertilizer.
(CERCLA - Title II, Subtitle A, Chapter 38, Subchapter B,
Sec. 4662(b) (2) (Q , SS 4662(b))
"REASONABLE FURTHER FROGRESS"
1, means annual incremental reductions in emissions of the applicable air
pollutant (including substantial reductions in the early years following
approval or promulgation of plan provisions under this part and section
110(a)(2)(I) and regular reductions thereafter) which are sufficient in
the judgment of the Administrator, to provide for attainment of the
applicable -national ambient air quality standard by the date required in
section 172 (a).
(CAA - 110(a) (2) (T) (1), Sec. 171(1), PS-©)
"RECOVERABLE*
1. refers to the capability and likelihood of being recovered from solid
waste for a commercial or industrial use.
(RCRA - Sec. 1004(18))
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"RECOVERED MATERIAL"
1. means waste material and by products v^iich have been recovered or
diverted from solid waste, but such terms does not include those
materials arvd byproducts generated from, and commonly reused within, an
original manufacturing process.
(RCRA - Sec. 1004(19))
"RECOVERED RESOURCES"
1. means material or energy recovered from solid waste.
(RCRA - Sec. 1004(20))
"RECYCLED OIL"
1. means any used oil which is reused, following its original use, for any
purpose (including the purpose for vhich the oil was originally used).
Such term includes oil vhich is re-refined, reclaimed, burned, or
reprocessed.
(RCRA - Sec. 1004(37))
"REFINER"
1. shall not include any refiner those total refinery capacity (including
the refinery capacity of any person who controls, is controlled by, or is
under common control with, such refiner) does not exceed <>5,000 barrels
per day.
(CAA - Sec. 325(c)(2), SS 325)
"REFINERIES WHICH FRODUCE NATURAL CASOLINE"
1. In the case of the United States refinery which produces natural gasoline
from natural gas, the gasoline so produced shall be treated as received
at such refinery at the time so produced.
(CERCIA - Title II, Subtitle A, Chapter 3R, Subchapter A,
Sec. 4512(a) (S), CS 38A)
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"REFINERY"
1. has the meaning provided under regulations of the Mministrator
promulgated under this section.
(CAA - Sec. 211(g) (1) (A), SS 211(g))
"REGIONAL AUTHORITY"
1. means the authority established or designated under section 4005.
(RCRA - Sec. 1004(25))
"RELEASE"
1. means any spilling, leaking, pumping, pouring, emitting, emptying,
discharging, injecting, escaping, leaching, dumping, or disposing into
the environment, but excludes (A) 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,
(B) emissions frcm the engine exhaust of a motor vehicle, rolling stock,
aircraft, vessel, or pipeline pumping station engine,
(O release of source byproduct, or special nuclear material from a
nuclear incident, as those terms are defined in the Atomic Qiergy 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 Pet, or, for the purposes of section 104 of
this title or any other response action, any release of source byproduct,
or special nuclear material from any processing site designated under
section 102(a)(1) or 302(a) of the Uraniun Mill Tailings Radiation
Control Act of 1978, and
(D) the normal application of fertilizer.
(CERCIA - Sec. 101(22))
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"REMEDY" or "REMEDIAL ACTION"
1. means 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 no 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 or contaminated materials, recycling or reuse,
diversion, destruction segregation of reactive wastes, dredging or
excavations, repair or replacement of leaking containers, collection of
leachate and runoff, onsite treatment or incinceration, provision of
alternative water supplies, and any monitoring reasonably required to
assure that such actions protect the public health and welfare and the
environment.
The term includes the costs of permanent relocation of residents and
businesses and community facilities vdiere the President 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 dispostion
offsite of hazardous substances, or may otherwise by necessary to protect
the public health or welfare.
The term does not include offsite transport of hazardous substances, or
the storage, treatment, destruction, or secure disposition offsite of
such hazardous substances or contaminated materials unless the President
determines that such actions
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(A) are more cost-effective than other remedial actions,
(B) will create new capacity to manage, in compliance with subtitle C of
the Solid Wbste Disposal Act, hazardous substances in addition to those
located at the affected facility, or
(C) are necessary to protect public health or welfare or the environment
from a present or potential risk vhich may be created by further exposure
to the continued presence of such substances or materials.
(CERCLA - Sec. 101(24))
"REMOVE OR REMOVAL"
1. means the cleanup or removal or released hazardous substances from the
environment, such actions as may be necesary 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 danage to the public health or velfare or
to the environment, vhich may otherwise result from a release or threat
of release.
The term ingludes, in addition, without being limited to, security
fencing or other measures to limit access, provision of alternative vater
supplies, temporary evacuation and housing of threatened individuals not
otherwise provided for, action taken under section 104(b) of this Act,
and any emergency assistance which may be provided under the Disaster
Relief Act of 1974.
(CERCLA - Sec. 101(23))
2. refers to removal of the 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, including,
but not limited to, fish, shellfish, wildlife, and public and private
property, shorelines, and beaches.
(CWA - Sec. 311(a) (8), SS 311)
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"REPLACEMENT"
1. means those expenditures for obtaining and installing equipment,
accessories, or appurtenances during the useful life of the treatment
works necessary to maintain the capacity and performance for v^iich such
works are designed and constructed.
(CWA - Sec. 212(3), TS II)
"RE-REFINED OIL"
1. means used oil from vhich the physical and chemical contaminants acquired
through previous use have been removed through a refining process.
(RCRA Sec. 1004(43))
"RESOURCE CONSERVATION"
1. means reduction of the amounts of solid waste that are generated,
reduction of overall resource consumption, and utilization of recovered
sources.
(RCRA Sec. 1004(23))
"RESOURCE RECOVERY"
1. means the recovery of material or energy from solid waste.
(RCRA - Sec. 1004(22))
"RESOURCE RECOVERY SYSTEM"
1. means a solid waste management system which provides for collection,
separation, recycling, and recovery of solid wastes, including disposal
of nonrecoverable waste residues.
(RCRA - Sec. 1004(23))
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"RESOURCE RECOVERY FACILITY"
1. means any facility at which solid waste is processed for the purpose of
extracting, converting to energy, or otherwise separating and preparing
solid waste for reuse.
(RCRA - Sec. 1004(24))
"RESPOND" or "RESPONSE"
1. means remove, removal, remedy, and remedial action.
(CERCLA - Sec. 101(25))
"RETAIL PRICE"
1. means (A) the maximun statutory price applicable to any class or model of
motor vehicle; or (B) in any case vdiere there is no applicable maximum
statutory price, the most recent procurement price paid for any class or
model of motor vehicle.
(CAA - Sec. 212(a)(5), SS 212)
"SANITARY LANDFILL"
1. means a facility for the disposal of solid waste which meets the criteria
published inder section 4004.
(RCRA - Sec. 1004(26))
"SANITATION SERVICES"
1. shall mean water supply, sewage disposal, solid waste disposal and other
services necessary to maintain generally accepted standards of personal
h^qiene and public health.
(CWA -Sec. 113(g), SS 113)
"SCHEDULE AND TIMETABLE OF COMPLIANCE"
1. means a schedule of remedial measures including an enforceable sequence
of actions or operations leading to compliance with an emission
limitation, other limitation, prohibition, or standard.
(CAA - Sec. 302 (p))
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"SCHEDULE OF COMPLIANCE"
1. means a schedule of remedial measures including an enforceable sequence
of actions or operations leading to compliance with an effluent
limitation, other limitation, prohibition, or standard.
(CWA - Sec. 502(17)), Except as provided
"SECRETARY"
I. as used in this section means the Secretary of the Army, acting through
the Chief of Engineers.
(CWA - Sec. 404(d) , SS 404)
"SERIOUS BODILY INJURY"
1. means (A) bodily injury which involves a substantial risk of death;
(B) unconsciousness;
(C) extreme.physical pain;
(D) protracted and obvious disfigurement; or
(E) protracted loss or impairment of the function of a bodily member,
organ, or mental faculty.
(RCRA - Sec. 3008 (f) (6))
"SEWSE"
1. means hunan body wastes and the wastes from toilets and other receptacles
intended to receive or retain body wastes except that, with respect to
commercial vessels on the Great Lakes such term shall include graywater.
(CWA - Sec. 312(a) (<5) , SS 312)
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"SLUDGE"
1. means any solid, semisolid or liquid waste generated from a municipal,
commercial, or industrial wastewater treatment plant, water supply
treatment plant, or air pollution control facility or any other such
waste having similar characteristics and effects.
(RCRA - Sec.1004nfiA))
"SMALL REFINERY"
1. means a refinery or a portion of a refinery producing gasoline (i) the
gasoline producing capacity of v^iich was in operation or under
construction at any time during the orie-year period immediately preceding
October 1, 1975, and (ii) vhich has a crude oil or bona fide feed stock
capacity (as determined by the Administrator) of 50,000 barrels per day
or less, and (iii) vftich is owied or controlled by a refiner with a total
combined crude oil or bona fide feed stock capacity (as determined by the
Administrator) of 137,500 barrels per day or less.
(CM - Sec. 211(g) (1) (B) , SS 211(g))
"SOLID WASTE"
1. means any garbage, refuse, sludge from a waste treatment plant, water
supply treatment plant, or air pollution control facility and other
discarded material, including solid, liquid, semisolid, or contained
gaseous material resulting from industrial, commercial, mining, and
agricultural operations, and from community activities, but does not
include solid or dissolved material in domestic sewage, or solid or
dissolved materials in irrigation return flows or industrial discharges
vrtiich are point sources subject to permits under section 402 of the
Federal W&ter dilution Control Act, as amended (85 Stat. 880) , or
source, special nuclear, or byproduct material as defined by the Atomic
Energy Pet of 1954, as amended (58 Stat. 973).
(RCRA - Sec.1004(27))
"SOLID WASTE MANAGEMENT"
1. means the systematic administration of activities v-hich provide for the
collection, source separation, storage, transportation, transfer,
processing, treatment, and disposal of solid waste.
(RCRA - Sec. 1004(28))
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"SOLID WASTE MANAGEMENT FACILITY"
1. includes (A) any resource recovery system or component thereof,
(B) any system, program, or facility for resource conservation, and
(C) any facility for the collection, source separation, storage,
transportation, transfer, processing, treatment of disposal of solid
vrastes including hazardous wastes, whether such facility is associated
with facilities generating such wastes or otherwise.
(RCRA - Sec. 1004(29))
"SOLID WASTE PLANNING"
1. include planning or management respecting resource recovery and resource
conservation.
(RCRA - Sec. 1004(30))
"SOLID WASTE MANAGEMENT"
1. include plarjning or management respecting resource recovery and resource
conservation.
(RCRA - Sec. 1004(30))
"SOURCE"
1. means any building, structure, facility, or installation from which there
is or may be the discharge of pollutants.
(CWA - Sec. 30*? (a) (3), SS 30^)
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"STANDARD OF PERFORMANCE"
1. means a standard for the control of the discharge of pollutants which
reflects the greatest degree of effluent reduction which the
Administrator determines to be achievable through application of the best
available demonstrated control technology, processes, operating methods,
or other alternatives, including, where practicable, ' a standard
permitting no discharge of pollutants.
(CWA - Sec. 305(a)(1), SS 306)
2. means a requirement of continuous emission reduction, including any
requirement relating to the operation or maintenance of a source to
assure continuous emission reduction.
(CPA - Sec. 302(1))
"STANDARDS FOR THE DEVELOPMENT OF TEST DATA"
1. means a prescription of (A) the (i) health and environmental effects, and
(ii) information relating to toxicity, persistence, and other
characteristics fchich affect health and the environment, for vhich test
data for a chemical substance or mixture are to be developed and any
analysis that is to be performed on such data, and
(B) to the extent necessary to assure that data respecting such effects
and characteristics are reliable and adequate (i) the manner in vhich
such data are to be developed, (ii) the specification of any test
protocol or methodology to be employed in the development of such data,
and (iii) such other requirements as are necessary to provide such
assurance.
(TSCA - Sec. 3(12))
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"STATE"
1. means any of the several States, the District of Columbia, the
Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa,
and the Gommonwealth of the Northern Mariana Islands.
(RCRA - Sec. 1004(31))
2. means a state, the District of Columbia, the Commonwealth of Puerto Rico,
the Virgin Islands, Guam, American Samoa, and the Trust Territory of the
Pacific Islands.
(CWA - Sec. 502(3)), Except as provided
3. means any State of the United States, the District of Columbia, the
Commonwealth of Puerto Rico, the Virgin Islands, Guam, the Canal Zone,
American Samoa, the Northern Mariana Islands, or any other territory or
possession of the United States.
(TSCA - Sec. 3(13))
4. means a State, the District of Columbia, the Commonwealth of Puerto Rico,
the Virgin Islands, Guam, and American Samoa and includes the
Commonwealth of the Northern Mariana Islands.
(CAA - Sec. 302(d)
"STATE AUTHORITY"
1. means the agency established or designated under section 4007.
(RCRA - Sec. 1004(32))
"STATE WATER POLLUTION CONTROL AGENCY"
1. means the State agency designated by the Governor having responsibility
for enforcing State laws relating to the abatement of pollution.
(CWA - Sec. 502(1)), Except as provided
A-7 4
-------
"STATIONARY SOURCE"
1. means any building, structure, facility, or installation which emits or
may emit any air pollutant.
(CAA - Sec. 111(a)(3), SS 111)
2. shall have the same meaning as such terms have under section 111(a) .
(CAA - Sac. 112(a)(3), SS 112)
"STORAGE"
1. when used in connection with hazardous waste, means the containment of
hazardous Vvaste, either on a temporary basis or for a period of years, in
such a manner as not to constitute disposal of such hazardous waste.
(RCRA - Sec. 1004(33))
"STRATOSPHERE"
1. means that part of the atmosphere above the tropopause.
(CAA - Sec. 152 (2) , TS 1(B))
"SUSTAINED-USE MOTOR VEHICLE"
1. means any diesel or gasoline fueled motor vehicle (vhether light or heavy
duty) which, as determined by the Administrator (in conjunction with the
Secretary), is normally used and occupied for a sustained, continuous, or
extensive period of time, including buses, taxicabs, and police vehicles.
(CAA - Sec. 22^(b), SS 226)
A-75
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"TAXABLE CHEMICAL"
1. *means any substance (A) which is listed in the table under
section 4661(b) , and (B) vhich is manufactured or produced in the United
States or entered into the United States for consumption, use, or
warehousing.
(CERCLA -Title II, Subtitle A, Chapter "58, Subchapter B,
Sec. 4662(a)(1), CS 3PB)
2. shall not include any substance to the extent derived from coal.
(CERCLA -Title II, Subtitle A, Chapter 18, Subchapter B,
Sec. 4662(b) (4) , CS 38B)
"TECHNOLOGICAL SYSTEMS OF CONTINUOUS EMISSION REDUCTION"
1. means (A) a technological process for production or operation by any
source which is inherently lowpolluting or nonpolluting, or
(B) a technological system for continuous reduction of the pollution
generated by a source before such pollution is emnitted into the ambient
air, including precombustion cleaning or treatment of fuels.
(CAA - Sec. 111(a)(7), SS 111)
"TERRITORIAL SEA"
1. shall have the meaning provided in section 502 of the Federal Vfcter
Pollution Control Ast.
(CERCLA - Sec. 101(30))
Except as provided in Sec. 4662(b)
A-76
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TAX ON CERTAIN CHEMICALS
(Table referred to under section 4551 (b) .)
In the case of: The tax is the following
amount per ton
Acetylene
$4.8-7
Benzene
4.87
Butane
4.87
Butylene
4.87
Butad iene
4.87
Ethylene
4.87
Methane
3.44
Napthalene
4.87
Propylene
4.87
Toluene
4.87
Xylene
4.87
Ammonia
2.54
Antimony
4.45
Antimony trioxide
3.75
Arsenic
4.45
Arsenic trioxide
3.41
Bariun sulfide
2.30
Bromine
4.45
Cadmium
4.45
Chlorine
2.70
Chramiim
4.45
Chromite
1.52
Potassium dichrcmate
1. 59
Sodiun dichramate
1.87
Cobal t
4.45
Cupric sulfate
1.87
Cupric oxide
3.59
Cuprous oxide
3.97
Hydrochloric acid
0.29
Hydrogen fluoride
4.23
Lead oxide
4.14
Mercury
4.45
Nickel
4.45
Phosphorous
4.45
Stannous chloride
2.85
Stannic chloride
2.12
Zinc chloride
2.22
Zinc sulfate
1.90
Potassium hydroxide
0.22
Sodium hydroxide
0.28
Sulfuric acid
0.25
Nitric acid
0.24
A-77
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"TERRITORIAL SEAS"
1. means the belt of the seas measured from the line of ordinary low water
along that portion of the coast which is in direct contact \/ith the open
sea and the line marking the seaward limit of inland waters, and
extending seaward a distance of three miles.
(CWA - Sec. 502(8)), Except as provided
"TON"
1. means 2,000 pounds. In the case of any taxable chemical which is a gas,
the term 'ton' means the amount of such gas in cubic feet which is the
equivalent of 2,000 pounds on a molecular weight basis.
(CERCLA -Title II, Subtitle A, Chapter 38, Subchapter B,
Sec. 4^62(a)(4), CS 38B)
"TOTALLY ENCLOSED MANNER"
1. means any manner which will ensure that any exposure of hunan beings or
the environment to a polychlorinated biphenyl will be insignificant as
determined by the Administrator by rule.
(TSCA - Sec. 5(e) (?.) (C) , SS 5(e) (?) (B) )
"TOXIC POLLUTANT"
1. means those pollutants, or combinations of pollutants, including
disease-causing agents, which after discharge and upon exposure,
ingestion, inhalation or assimilation into any organism, either directly
from the environment or indirectly by ingestion through food chains,
will, on the basis of information available to the Administrator, cause
death, disease, behavioral abnormalities, cancer, genetic mutations,
physiological nonfunctions (including malfunctions in reproduction) or
physical deformations, in such organisms or their offspring.
(CWA - See. 502(13)) , Except as provided
A-78
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"TRANSPORT" or "TRANSPORTATION"
1. means the movement of a hazardous substance by any mode, including
pipeline (as defined in the Pipeline Safety A=t) , and in the case of a
hazardous substance which has been accepted for transportation by a
common or contract carrier, the term "transport" or "transportation"
shall include any stoppage in transit which is temporary, incidental to
the transportation movement, and at the ordinary operating convenience of
a common or contract carrier, and any such stoppage shall be considered
as a continuity of movement and not as the storage of a hazardous
substance.
(CERCLA - Sec. 101(26))
" TREATMENT"
1. shall have the meaning provided in section 1004 of the Solid W&ste
Disposal Act.
(CERCLA - SEC. 101(29))
2. when used in connection with hazardous waste, means any method,
technique, or process, including neutralization, designed to change the
physical, chemical, or biological character or composition of any
hazardous waste so as to neutralize such waste or so as to render such
vaste nonhazardous, safer for transport, amenable for recovery, amenable
for storage, or reduced in volume. Such term includes any activity or
processing designed to change the physical form or chemical composition
of hazardous waste so as to render it nonhazardous.
(RCRA - Sec. 1004(34))
A-79
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"TREATMENT WORKS"
1. means (A) any devices and systems used in the storage, treatment,
recycling, and reclanation of municipal sewage or industrial wastes of a
liquid nature to implement section 201 of this act, or necessary to
recycle or reuse water at the most economical cost over the estimated
life of the works, including intercepting sewers, outfall sewsrs, sewage
collection systems, punping, powsr and other equipment, and their
appurtenances; extensions, improvements, remodeling, additions, and
alterations thereof; elements essential to provide a reliable recycled
supply such as standby treatment units and clear well facilities; and
any works, including site acquisition of the land that will be an
integral part of the treatment process (including land use for the
storage of treated wastewater in land treatment systems prior to land
application) or is used for ultimate disposal of residues resulting from
such treatment.
(CWA - Sec.212(2)(A), TS II)
2. means any other method or system for preventing, abating, reducing,
storing, treating, separating, or disposing of municipal waste, including
storm water runoff, or industrial waste, including waste in combined
storm water and sanitary sewer systems. (In addition to meaning of
definition cited on Sec. 212(2) (A).)
(CWA - Sec. 212(2) (B) ,TS II)
"ULTIMATE PlJRCHAgER"
1. means, with respect to any new motor vehicle or new motor vehicle engine,
the first person vho in good faith purchases such new motor vehicle or
new engine for purposes other than resale.
(CAA - Sec. 216(5), TS II)
"UNITED STATES"
1. include the several States of the United States, the District of
Columbia, the Commonwealth of Puerto Rico, Guam, American Samoa, the
United States virgin Islands, the Commonwealth of the Northern Marianas,
and any other territory or possession over which the United States has
jurisdiction.
(CERCIA - Sec. 101(27))
A-80
-------
2. (A) means, in general, the 50 States, the District of Gblunbia, the
Commonwealth of Puerto Rico, any possession of the United States, the
Common veal th of the Northern Mariana Islands, and the Trust Territory of
the Pacific Islands;
(B) United states includes continental shelf areas. The principles of
section 638 shall apply for purposes of the term 'United States';
(C) United States includes foreign trade zones. The term 'United States'
includes any foreign trade zone of the United States.
(CERCIA - Title II, Subtitle A, Chapter 38, Subchapter A,
Sec. 4612(a) (4), CS 38A)
3. has the meaning given such term by section 4612(a)(4).
(CERCIA - Title II, Subtitle A, Chapter 38, Subchapter B,
Sec. 4662(a) (2) , CS 38B)
4. means the States, the District of Colunbia, the Common>vealth of Puerto
Rico, the Canal Zone, Guam, American Samoa, the Virgin Islands, and the
Trust Territory of the Pacific Islands.
(CWA - Sec.'311 (a) (5), SS 311)
5. includes the States, the District of Colunbia, the Commonwealth of Puerto
Rico, the Virgin Islands, Guam, American Samoa, the Canal Zone, and the
Trust Territory of the Pacific Islands.
(CWA - Sec. 312(a) (4), SS 312)
6. when used in the geographic sense, means all of the States.
(TSCA - Sec. 3(14))
"UNITED STATES REFINERY"
1. means any facility in the united States at vtaich cruie oil is refined.
(CERCLA - Title II, Subtitle A, Chapter 38, Subchapter A,
Sec. 4612(a) (5), CS 38A)
A-81
-------
"USED OIL"
1. means any oil v*faich has been —
(A) refined from crude oil,
(B) used, and
(C) as a result of such use, contaminated by physical or chemical
impurities.
(RCRA - Sec. 1004(36))
"VESSEL"
1. means every description of v*atercraft or other artifical contrivance
used, or capable of being used, as a means of transportation on vaster.
(CERCLA - Sec. 101(IB))
2. means every description of water craft or other artificial contrivance
used, or capable of being used, as a means of transportation on vater
other than a public vessel.
(CWA - Sec. 311(a) (3), SS 311)
"VILLAGE"
1. shall mean an incorporated or unincorporated community with a population
of ten to six hundred people living within a two-mile radius.
(CWA - Sec. 113(g) , SS 113)
"VIRGIN MATERIAL"
1. means a raw material, including previously unused copper, alirunun, lead,
zinc, iron, or other metal or metal ore, any undeveloped resource that
is, or with new technology will become, a source of raw materials.
(RCRA - Sec. 1004(35))
A-82
-------
"VISIBILITY IMPAIRMENT" or "IMPAIRMENT
1. shall include reduction in visual
(CAA - Sec. lS9A(g)(5), SS 1G9A)
OF VISIBILITY"
range and atmospheric discoloration.
A-83
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APPENDIX B
LIST OF HAZARDOUS SUBSTANCES FROM PRIOR REGULATIONS
To show the act under which regulatory action has been taken, an "x"
has been placed in the appropriate column(s) opposite the chemical name, ex-
cept in the case of RCRA entries. Under RCRA, entries are coded to correspond
to the original regulatory designation (40CFR261), as follows:
P = Acute hazardous waste
U = Toxic waste
8 = Hazardous constituent (Appendix VIII)
B-l
-------
LIST OF HAZARDOUS SUBSTANCES FROM PRIOR REGULATIONS
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
208968
83329
75070
107200
75876
640197
62442
591082
53963
2545597
61792072
1928478
93765
93798
1319728
3813147
2008460
6369966
6369977
25168154
Acenaphthylene x
Acenaphthylene, 1,2-dihydro x
Acetaldehyde x
Acetaldehyde, chloro
Acetaldehyde, trichloro
Acetamide, 2-fluoro
Acetamide, N-(4-ethoxyphenyl)
Acetamide, N-(aminothioxomethyl)
Acetamide, N-9H-fluoren-2-yl
Acetic acid, (2,3,5-trichlorophenoxy)-, 2-butoxyethyl
ester x
Acetic acid, (2,4,5-trichlorophenoxy)-, 1-methyl
propyl ester x
Acetic acid, (2,4,5-trichlorophenoxy)-,
2-ethylhexyl ester x
Acetic acid, (2,4,5-trichlorophenoxy)- x
Acetic acid, (2,4,5-trichlorophenoxy)-,
butyl ester x
Acetic acid, (2,4,5-trichlorophenoxy)- compd,
with l-amino-2-propanol (1:1) x
Acetic acid, (2,4,5-trichlorophenoxy)-, compd, with
d,2', 211-nitrilotris (ethanol) (1:1) x
Acetic acid, (2,4,5-trichlorophenoxy)-, compd,
with N,N-diethylethanamine (1:1) x
Acetic acid, (2,4,5-trichlorophenoxy)-, compd,
with N,N-dimethylmethanamine (1:1) x
Acetic acid, (2,4,5-trichlorophenoxy)-, compd,
with N-methylmethanamine (1:1) x
Acetic acid, (2,4,5-trichlorophenoxy)-,
isooctyl ester x
U,8
P,8
U
P »8
U ,8
P,8
U ,8
U,8
-------
CAS #
Substance
13560991 Acetic acid, (2,4,5-trichlorophenoxyl)-, sodium salt
94111 Acetic acid, (2,4-dichlorophenoxy)-, 1-methylethyl
ester
1929733 Acetic acid, (2,4-dichloropheoxy)-, 2-butoxyethyl
ester
2971382 Acetic acid, (2,4-dichlorophenoxy)-, 4-chloro-2-
butenyl ester
94757 Acetic acid, (2,4-dichlorophenoxy)-
94804 Acetic acid, (2,4-dichlorophenoxy)-,
butyl ester
1320189 Acetic acid, (2,4-dichlorophenoxy)-, ester with
1,2-propanediol monobutyl ether
25168267 Acetic acid, (2,4-dichlorophenoxy)-, isooctyl
ester
1928387 Acetic acid, (2,4-dichlorophenoxy)-, methyl ester
1928616 Acetic acid, (2,4-dichlorophenoxy)-, propyl
ester
94791 Acetic acid, (2,4-dichlorophenoxy)-, sec-butyl ester
110190 Acetic acid, 2-methylpropyl ester
64197 Acetic acid
631618 Acetic acid, ammonium salt
108247 Acetic acid, anhydride
123864 Acetic acid, butyl ester
543908 Acetic acid, cadmium salt
1066304 Acetic acid, chromium (3+) salt
142712 Acetic acid, copper (2+) salt
108054 Acetic acid, ethenyl
CWA RCRA FIFRA SDWA CAA TSCA
x
x
X
X
x U,P,8
x
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
CAS #
Substance
141786 Acetic acid, ethyl ester
62748 Acetic acid, fluoro-, sodium sal
301042 Acetic acid, lead (2+) salt
628637 Acetic acid, pentyl ester
563688 Acetic acid, thallium (1+) salt
557346 Acetic acid, zinc salt
75058 Acetonitrile
506967 Acetyl bromide
75365 Acetyl chloride
1162658 Aflatoxin B1
1165395 Aflatoxin G1
1402682 Aflatoxin
6795239 Aflatoxin Ml
6885570 Aflatoxin M2
7220817 Aflatoxin B2
7241987 Aflatoxin G2
17878545 Aflatoxin B2a
20421107 Aflatoxin G2a
29611038 Aflatoxin RO
32215024 Aflatoxin PI
52819962 Aflatoxin Q1
20859738 Aluminum phosphide (A1P)
7664417 Ammonia
12125029 Ammonium chloride
CWA RCRA FIFRA SDWA CAA TSCA
x
x
U
P ,8
U,8
U,8
x
x
l),8
U ,8
8
8
8
8
8
8
8
8
8
8
8
8
P ,8
x
-------
CAS i
Substance
12125018 Ammonium fluoride
1341497 Ammonium fluoride ((NH4)(HF2))
1336216 Ammonium hydroxide
12135761 Ammonium sulfide ((NH4)2S)
52628258 Ammonium zinc chloride
120127 Anthracene
28300745 Antimonate(2-), bis (mu-(2,3-dihydroxybutanedioato(4
-0(1),0(2):0(3).0(4)) di-, dipotassium trihydrate,
stereoisomer
7440360 Antimony
7647189 Antimony chloride (SbCl5)
1309644 Antimony oxide (Sb203)
506616 Argentate (l-)» bis (cyano-C)-, potassium
7784465 Arsenenous acid, sodium salt
7440382 Arsenic
7778394 Arsenic acid (H3As04)
10103614 Arsenic acid (H3As04), copper salt
7784410 Arsenic acid (H3As04), monopotassium salt
7778441 Arsenic acid (H3As04), calcium salt (2:3)
7784409 Arsenic acid (H3As04), lead (2+) salt (1:1)
3687318 Arsenic acid (H3As04), lead (2+) salt (2:3)
10102484 Arsenic acid (H3As04), lead (4+) salt (3:2)
7645252 Arsenic acid (H3As04), lead salt
7631892 Arsenic acid (H3As04), sodium salt
1327533 Arsenic oxide (As203)
1303282 Arsenic oxide (As205)
CWA RCRA FIFRA SDWA CAA TSCA
x
x
x
x
X
X
X
X
X
X
P,8
8
P ,8
x
x
x
x
x
x
x
x
X
P.8
P ,8
-------
CAS §
Substance
1303328 Arsenic sulfide (As2S2)
7784341 Arsenous trichloride
692422 Arsine, diethyl
75605 Arsinic acid, dimethyl
52740166 Arsonic acid, calcium salt (1:1)
98055 Arsonic acid, phenyl
10124502 Arsonic acid, potassium salt
696286 Arsonous dichloride, phenyl
1332214 Asbestos
52244 Aziridine, 1,1',1''-phosphinothioylidynetris
75558 Aziridine, 2-methyl
151564 Aziridine
50077 Azirino(2',3':3,4)pyrrolo(l,2-a)indole-4,7-dione,
6-amino-8-[(aminocarbonyl)oxy]methyl)-l,1A,2,8,8A,
8B-hexahydro-8A-methoxy-5-methyl-,[1AR-(la alpha ,8
beta,8a alpha,8b alpha)]
7440393 Barium
542621 Barium cyanide
57976 Benz(a)anthracene, 7,12-dimethyl
56553 Benz(a)anthracene
56495 Benz(j)aceanthrylene, 1,2-dihydro-3-methyl
23950585 Benzamide, 3,5-dichloro-n-(l,1-dimethyl-2-propynyl)
225514 Benz(c)acridine
205992 Benz(e)acephenanthrylene
99558 Benzenamine, 2-methyl-5-nitro
636215 Benzenamine, 2-methyl-, hydrochloride
CWA RCRA FIFRA SDWA CAA TSCA
x
x
P,8
U
x
8
x
P,8
U x
8
P,8
P,8
U,8
8
P >8
U ,8
U,8
U,8
U,8
U,8
8
U,8
U,8
-------
CAS #
Substance
CD
I
492808 Benzenamine, 4,4'-carbonimidoylbis(N,N-dimethyl
101144 Benzenamine, 4,4'-methylenebis(2-chloro
106478 Benzenamine, 4-chloro
3165933 Benzenamine, 4-chloro-2-methyl-.hydrochloride
100016 Benzenamine, 4-nitro
62533 Benzenamine
60117 Benzenamine, N,N-dimethyl-4-(phenylazo)
86306 Benzenamine, N-nitroso-N-phenyl
1300738 Benzenamine, AR, AR-dimethyl
50293 Benzene, 1,1'-(2,2,2-trichloroethylidene)bis
(4-chloro)
72435 Benzene, 1,1'-(2,2,2-trichloroethylidene)bis
(4-methoxy)
72548 Benzene, 1,1'-(2,2-dichloroethylidene)bis(4-chloro)
72560 Benzene, 1,1'-(2,2-dichloroethylidene)bis
(4-ethyl)
72559 Benzene, 1 ,l'-(dichloroethenylidene)bis(4-chloro)
87616 Benzene, 1,2,3-trichloro
95943 Benzene, 1,2,4,5-tetrachloro
120821 Benzene, 1,2,4-trichloro
95501 Benzene, 1,2-dichloro-
95476 Benzene, 1,2-dimethyl
528290 Benzene, 1,2-dinitro
108703 Benzene, 1,3,5-trichloro
108678 Benzene, 1,3,5-trinitro
CWA RCRA FIFRA SDWA CAA TSCA
x
x
11,8
U,8
P,8
U
P,8
U
U,8
P.8
U,8
U
U,8
x
x
x
x
x
x
x
U,8
8
U,8
U,8
8
U,8
x
x
-------
CAS #
Substance
CUA
RCRA FIFRA SDWA CAA TSCA
541731
Benzene,
1,3-dichloro
U,8
26471625
Benzene,
1,3-diisocyanatomethyl
U,8
108383
Benzene,
1,3-dimethyl
X
U ,8
99650
Benzene,
1,3-dinitro
X
8
106467
uenzene,
1,4-dichloro
X
U,8
106423
Benzene,
1,4-dimethyl
X
U,8
100254
Benzene,
1,4-dinitro
X
101553
Benzene,
l-bromo-4-phenoxy
11,8
95498
Benzene,
l-chloro-2-methyl
8
106434
Benzene,
1-chloro-4-methyl
8
7005723
Benzene,
l-chloro-4-phenoxy
X
121142
Benzene,
1-methyl-2,4-dinitro
X
U
88722
Benzene,
1-methyl-2-nitro
X
99081
Benzene,
1-methyl-3-nitro
X
99990
Benzene,
1-methyl-4-nitro
X
98828
Benzene,
(1-methyl ethyl)-
U
606202
Benzene,
2-methyl-1,3-dinitro
X
u
610390
Benzene,
4-methyl-l ,2-dinitro
X
71432
Benzene
X
cz
*
00
X
510156
Benzeneacetic acid, 4-chloro-alpha-(4-chlorophenyl)-
alpha-hydroxy-, ethyl ester
U x
305033
Benzenebutanoic acid, 4-(bis(2-chloroethyl) amino)
11,8
108907
Benzene,
chloro
X
U ,8
100447
Benzene,
(chloromethyl)
X
P,8
823405
1,3-Benzenediamine, 2-methyl
U,8
-------
CAS I
Substance
CWA RCRA FIFRA SDWA CAA TSCA
2687254
1,2-Benzenediamine, 3-methyl
U,8
496720
1,2-Benzenediamine, 4-methyl
U,8
95807
1,3-Benzenediamine, 4-methyl
U,8
25376458
Benzenediamine, AR-methyl
U,8
117817
1,2-Benzenedicarboxylic acid, bis(2-ethylhexylJester
U,8
85687
1,2-Benzenedicarboxylic acid, butyl phenylmethyl ester
8
84742
1,2-Benzenedicarboxylic acid, dibutyl ester
U,8
84662
1,2-Benzenedicarboxylic acid, diethyl ester
x
11,8
131113
1,2-Benzenedicarboxylic acid, diethyl ester
U,8
117840
1,2-Benzenedicarboxylic acid, dioctyl ester
U,8
25321226
Benzene, dichloro
X
11,8
98873
Benzene, (di chloromethyl)
U
1330207
Benzene, dimethyl
X
U,8
25154545
Benzene, dinitro
X
51434
1,2-Benzenediol, 4-[l-hydroxy-2-(methyl-anrino)
ethyl]-, (R)-
P,8
108463
1,3-Benzenediol
U,8
122098
Benzenethanamine, alpha, alpha-dimethyl
P,8
100425
Benzene, ethenyl
X
100414
Benzene, ethyl-
X
118741
Benzene, hexachloro
U,8
115322
Benzene,ethanol, 4-chloro-alpha-(4-chlorophenyl)-
alpha-(trichloromethyl)-
X
108883
Benzene, methyl
X
U,8
25321146
Benzene, methyldinitro
X
-------
CAS #
Substance
1321126 Benzene, methylnitro
98953 Benzene, nitro
608935 Benzene, pentachloro
82688 Benzene, pentachloronitro
127822 Benzensulfonic acid, 4-hydroxy-, zinc salt (2:1)
27176870 Benzenesulfonic acid, dodecyl-
68411325 Benzenesulfonic acid, dodecyl-, branched
26264062 Benzenesulfonic acid, dodecyl-, calcium salt
42504461 Benzenesulfonic acid, dodecyl-, compd, with 1-amino
2-propanol (1:1)
27323417 Benzenesulfonic acid, dodecyl-, compd, with 2,2',2'
nitrilotris(ethanol) (1:1)
25155300 Benzenesulfonic acid, dodecyl-, sodium salt
98099 Benzenesulfonyl chloride
108985 Benzenethiol
98077 Benzene, (trichloromethyl)
12002481 Benzene, trichloro-
123024 Benzene, tridecyl
3816765 1H-Benzimidazole-1-ethanamine,2-[(4-chlorophenyl)
methyl]-N,N-diethyl-5-nitro
81072 1,2-Benzisothiazol-3(2H)-one, 1,1-dioxide
50328 Benzo(a)pyrene
120581 1,3-Benzodioxole, 5-(l-propenyl)
94597 1,3-Benzodioxole, 5-(2-propenyl)-
94586 1,3-Benzodioxole, 5-propyl
1563662 7-Benzofuranol, 2,3-dihydro-2,3-dimethyl-,
methyl carbamate
CWA RCRA FIFRA SDWA CAA TSCA
x
x U,8
x U,8
U,8
x
x
x
x
x
x
x
U
P,8
U,8
x
x
U,8
U,8
U ,8
U ,8
U,8
x
x
x
x
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
191242
Benzo(gh i)pery1ene
X
50317
Benzoic acid, 2,3,6-trichloro
1918009
Benzoic acid, 3,6-dichloro-2-methoxy
x
65850
Benzoic acid
X
1863634
Benzoic acid, ammonium salt
X
205823
Renzo(j)f1uoroanthene
8
207089
Benzo(k)f1uorathene
X
1194656
Benzonitrile, 2,6-dichloro
X
100470
Benzonitrile
X
81812
2H-l-Benzopyran-2-one, 4-hydroxy-3-
(3-oxo-l-phenyl butyl)
P,8
129066
2H-1-Benzopyran-2-one, 4-hydroxy-3-
(3-oxo-l-phenylbutyl)-, sodium salt
P,8
189559
Benzo(rst)pentaphene
U,8
98884
Benzoyl chloride
X
7440417
Beryl1i um
X
P,8
7787475
Beryllium chloride
X
7787497
Beryllium fluoride
X
1464535
2,2'-Bioxirane
U,8
298180
2,2'-Bioxirane, (R*,R*)-(+-)-
U,8
564001
2,2'-Bioxirane, (R*,S*)-
U,8
91941
(1,1 '-Biphenyl)-4,4'-diamine, 3,3'-dichloro
X
U,8
84684
(1,1'-Biphenyl)-4,4'-diamine, 2,2'-dichloro
X
1331471
(1,1'-Biphenyl)-4,4'-diamine, dichloro
X
119904
(1,1'-Biphenyl)-4,4'-diamine, 3,3'-dimethoxy
11,8
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
119937 (1,1'-Biphenyl)-4,4'-diamine, 3,3'-dimethyl
92875 (1,11-Biphenyl)-4,4'-diamine
92671 (1,1'-Biphenyl)-4-amine
1336363 1 ,11-Biphenyl, chloro-derivs, (see footnote)
4685147 4,4'-Bipyridinium, 1,1'-dimethyl
13826830 Borate(l-), tetrafluoro-, ammonium
13814965 Borate(l-), tetrafluoro-, lead(2+) (2:1)
U,8
11,8
8
8
x
x
X
X
NOTE: This entry identifies the polychlorinated biphenyls (PCBs). However, while it is the sole entry
on this list for this particular class of compounds, it is not meant to exclude other individual chlor-
inated biphenyls that can be identified by other unique CAS registry numbers. Such registry numbers may
include:
2050671
2050682
2974927
11096825
11097691
11100144
11104282
11120299
11141165
12672296
12737870
13029088
16605917
25323686
25429292
26914330
27323188
34883391
34883415
34883437
37317412
37324235
37324246
37353632
53469219
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
1332076 Boric acid, zinc salt x
87683 1,3-Butadiene, 1,1,2,3,4,4-hexachloro U,8
78795 1,3-Butadiene, 2-methyl x
109739 1-Butanamine x
13952846 2-Butanamine x
924163 1-Butanamine, N-butyl-N-nitroso U,8
513495 2-Butanamine, (S) x
14307438 Butanedioic acid, 2,3-dihydroxy- (R-R*,R*))-,
atrmonium salt x
815827 Butanedioic acid, 2,3-dihydroxy- (R-(R*,R*))-,
copper(2+) salt (1:1) x
3164292 Butanedioic acid, 2,3-dihydroxy- (R-{R*,R*))-,
diammonium salt x
121755 Butanedioic acid, ((dimethoxyphosphinothioyl)thio)-,
diethyl ester x
107926 Butanoic acid x
624419 1-Butanol, 2-methyl-, acetate x
123922 1-Butanol, 3-methyl-, acetate x
71363 1-Butanol x U
39196184 2-Butanone, 3,3-dimethyl-l-(methylthio)-,
0-[(methylamino)carbonyl]oxime P,8
78933 2-Butanone U,8
1338234 2-Butanone, peroxide U,P,8
4170303 2-Butenal x U,8
764410 2-Butene, 1,4-dichloro U
31423924 Butene, 1,4-dichloro U
110576 2-Butene, 1,4-dichloro-, (E) U
-------
CAS #
Substance
1476115 2-Butene, 1,4-dichloro-,(Z)
110178 2-Butenedioic acid (E)
110167 2-Butenedioic acid (Z)
303344 2-Butenoic acid, 2-methyl-,7-[[2,3-dihydroxy-2-
(1-methoxyethyl)-3-methyl-1-oxobutoxy]methyl]
-2,3,5,7a-tetrahydro-lH-pyrrolizin-l-yl ester,
[1S-(1 alpha(Z), 7(2s*,3R*),7a alpha)]
7786347 2-Butenoic acid, 3-((dimethoxyphosphinyl)oxy)-,
methyl ester
7440439 Cadmium
7789426 Cadmium bromide
10108642 Cadmium chloride
75207 Calcium carbide (CaC2)
592018 Calcium cyanide
51796 Carbamic acid, ethyl ester
615532 Carbamic acid, methylnitroso-, ethyl ester
1111780 Carbamic acid, monoammonium salt
79447 Carbamic chloride, dimethyl
111546 Carbamodithioic acid, 1,2-ethanediylbis-
2303164 Carbamothioic acid, bis(1-methylethyl)-, S-(2,3
dichloro-2-propenyl) ester
75150 Carbon disulfide
506876 Carbonic acid, diammonium salt
6533739 Carbonic acid, dithal1ium(1 +) salt
1066337 Carbonic acid, monoammonium salt
3486359 Carbonic acid, zinc salt (1:1)
CWA RCRA F1FRA SDWA CAA TSCA
U
x
x
U,8
x
x
X
X
P,8
11,8
U,8
x
x
x
x
x
U,8
U,8
U,8
P ,8
U,8
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
75445
Carbonic dichloride
X
P,8
353504
Carbonic difluoride
U
630080
Carbon monoxide
79221
Carbonochloridic acid, methyl ester
U
12789036
Chlordane
U,8
7782505
Chlorine
X
7790945
Chlorosulfuric acid
X
11115745
Chromic acid
X
7789095
Chromic acid (H2Cr207), diammonium salt
X
10588019
Chromic acid (H2Cr207), disodium salt
X
13765190
Chromic acid (H2Cr04), calcium salt
X
U,8
7788989
Chromic acid (H2Cr04), diammonium salt
X
7789006
Chromic acid (H2Cr04), dipotassium salt
X
7778509
Chromic acid (H2Cr207), dipotassium salt
X
7738945
Chromic acid (H2Cr04)
X
14307358
Chromic acid (H2Cr04), dilithium salt
X
7775113
Chromic acid (H2Cr04), disodium salt
X
7789062
Chromic acid (H2Cr04), strontium salt (1
:1)
X
7440473
Chromi um
8
10049055
Chromium chloride (CrC12)
X
218019
Chrysene
U,8
7789437
Cobalt bromide (CoBr2)
X
12002038
Color Index Pigment Green 21 (Cupric acetoarsenite)
X
10380297
Copper(2+), tetraammine-, sulfate (1:1),
monohydrate
X
7440508
Copper
X
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
7447394 Copper chloride (CuC12) x
544923 Copper cyanide P,8
8021394 Creosote 11,8
57125 Cyanide x P,8
506683 Cyanogen bromide U,P,8
506774 Cyanogen chloride x P,8
118752 2,5-cyclohexadiene-l,4-dione, 2,3,5,6-tetrachloro-
106514 2,5-Cyclohexadiene-l ,4-dione U
608371 Cyclohexane, 1,2,3,4,5,6-hexachloro x U,8
319857 Cyclohexane, 1,2,3,4,5,6-hexachloro-,(lalpha,
2beta,3alpha,4beta,5alpha,6beta)- x U,8
319846 Cyclohexane, 1,2,3,4,5,6-hexachloro-,(lalpha,
2alpha,3beta,4alpha,5beta,6beta) x U,8
58899 Cyclohexane, 1,2,3,4,5,6-hexachloro-,(lalpha,
2alpha,3beta,4alpha,5alpha,6beta) x U,8
6108107 Cyclohexane, 1,2,3,4,5,6-hexachloro-,(lalpha,
2alpha,3alpha,4beta,5beta,6beta) x U,8
319868 Cyclohexane, 1,2,3,4,5,6-hexachloro-,(lalpha,
2alpha,3alpha,4beta,5alpha,6beta) x U,8
110827 Cyclohexane x U
108941 Cyclohexanone U
77474 1,3-Cyclopentadiene, 1,2,3,4,5,5-hexachloro x U,8
121211 Cyclopropanecarboxylic acid, 2,2-dimethyl-3-(2-
methyl-l-propenyl)-, 2-methyl-4-oxo-3-(2,4-pentadienyl)-
2-cyclopenten-l-yi ester (lalpha(lalpha(8*(Z)),3beta)) x
121299 Cyclopropanecarboxylic acid, 3-(3-methoxy-3-methyl-
3-oxo-l-propenyl)-2,2-dimethyl-,2-methyl-4-oxo-3-
(2,4-pentadienyl)-2-cyclopenten-l-yl ester,
{1R-(1alpha(8*(Z)),3beta(E)))- x
-------
CAS f
Substance
CD
I
226368 Dibenz(a,h)acridine
53703 Dibenz(a,h)anthracene
224420 Dibenz(a,j)acridine
189640 Dibenzo(b,def)chrysene
1746016 Dibenzo(b,e)(l,4)dioxin, 2,3,7,8-tetrachloro
194592 7H-Dibenzo(c,g)carbazole
72208 2,7:3,6-Dimethanonaphth(2,3-b)oxirene, 3,4,5,6,9,9-
hexachloro-la,2,2a,3,6,6a,7,7a-octahydro~, (la alpha,
2 beta,2a beta, 3 alpha, 6 alpha, 6a beta, 7 beta,
7a alpha)
60571 2,7:3,6-Dimethanonaphth(2,3-b)oxirene, 3,4,5,6,9,9-
hexachloro-la,2,2a,3,6,6a,7,7a-octahydro-, (la alpha,
2 beta, 2a alpha, 3 beta, 6 beta, 6a alpha, 7 beta,
7a alpha)
465736 1,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-
hexachloro-1,4,4a,5,8,8a-hexahydro-,(1 alpha, 4 alpha,
4a beta, 5 beta, 8 beta, 8a beta)
309002 1,4:5,8-Dimethanonaphthalene, 12,3,4,10,10-
hexachloro-1,4,4a,5,8,8a-hexahydro-,(l alpha, 4 alpha,
4a beta, 5 alpha, 8 alpha, 8a beta)
123911 1,4-Dioxane
152169 Diphosphoramide, octamethyl
107493 Diphosphoric acid, tetraethyl ester
2764729 Dipyrido(l,2-a:2',1'-c)pyrazinediium,
6,7-dihydro-
85007 Dipyrido(l,2-a:2',1'-c)pyrazinediium,
6,7-dihydro-, dibromide
7779864 Dithionous acid, zinc salt (1:1)
CWA RCRA FIFRA SDWA CAA TSCA
8
U,8
8
x 8
x 8
8
x P,8 x x
x P,8 x x
P,8
x P,8 x
U,8
P,8 x
x P,8 x
x
x
x
-------
CAS #
Substance
51752 Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl
55867 Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl,
hydrochloride
126852 Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl,
N-oxide
302705 Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl,
N-oxide, hydrochloride
75047 Ethanamine
109897 Ethanamine, N-ethyl
121448 Ethanamine, N,N-diethyl
55185 Ethanamine, N-ethyl-N-nitroso
10595456 Ethanamine, N-methyl, N-nitroso
111911 Ethane, 1,1'-[methylenebis(oxy)]bis(2-chloro
111444 Ethane, 1,1'-oxybis(2-chloro
60297 Ethane, l,l'-oxybis
630206 Ethane, 1,1,1,2-tetrachloro
71556 Ethane, 1,1,1-trichloro
79345 Ethane, 1,1,2,2-tetrachloro
79005 Ethane, 1,1,2-trichloro
75343 Ethane, 1,1-dichloro
106934 Ethane, 1,2-dibromo
107062 Ethane, 1,2-dichloro
75003 Ethane, chloro
107153 1,2-Ethanediamine
91805 1,2-Ethanediamine, N,N-dimethyl-N'-2-pyridinyl-
N'-(2-thienylmethyl)
CWA RCRA FIFRA SDWA CAA TSCA
x
x
x
x
x
x
x
8
8
8
U,8
8
U,8
U,8
U
U,8
U,8
U,8
U,8
U,8
U,8
U,8
P,8
U,8
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
460195
Ethanedinitrile
P,8
2944674
Ethanedioic acid, ammonium iron(3+) salt (3:3:1)
X
55488874
Ethanedioic acid, ammonium iron salt
X
14258492
Ethanedioic acid, ammonium salt
X
5893663
Ethanedioic acid, copper(2+) salt (1:1) hemihydrate
X
6009707
Ethanedioic acid, diammonium salt, monohydrate
X
5972736
Ethanedioic acid, monoammonium salt, monohydrate
X
67721
Ethane, hexachloro
U,8
76017
Ethane, pentachloro
U,8
25322207
Ethane, tetrachloro
X
8
62555
Ethanethioamide
U,8
25323891
Ethane, trichloro
X
23135220
Ethanimidothioic acid, 2-(dimethylamino)-N-
[[(methylamino)-carbonyl]oxy]-2-oxo-, methyl ester
16752775
Ethanimidothioic acid, N-((methylamino)carbonyl)oxy)-,
methyl ester
P»8
1116547
Ethanol, 2,2'-(nitrosoimino)bis
U,8
98862
Ethanone, 1-phenyl
U
75354
Ethene, 1,1-di chloro
X
U,8
156592
Ethene, 1,2-dichloro-, (Z)
X
8
540590
Ethene, 1,2-dichloro
X
8
156605
Ethene, 1,2-dichloro-, (E)
X
U
110758
Ethene, (2-chloroethoxy)
U,8
75014
Ethene, chloro
X
U,8
127184
Ethene, tetrachloro
U,8
79016
Ethene, trichloro
X
U,8
14433933
Ferric cyanide (ferric ferrocyanide)
8
-------
CAS «
Substance
206440 Fluoranthene
86737 9H-Fluorene
7782414 Fluorine
50000 Formaldehyde
64186 Formic acid
544183 Formic acid, cobalt (2+) salt
557415 Formic acid, zinc salt
110009 Furan
98011 2-Furancarboxaldehyde
108316 2,5-Furandione
109999 Furan, tetrahydro
14901087 beta-D-Glucopyranoside, (methyl-0NN-azoxy)methyl
18883664 D-Glucose, 2-deoxy-2[[methylnitrosoamino)
carbonyl]amino]
60004 Glycine, N,N'-1,2-ethanediylbis(N-carboxymethyl)
13256229 Glycine, N-methyl-N-nitroso
70257 Guanidine, N-methyl-N'-nitro-N-nitroso
124049 Hexanedioic acid
57147 Hydrazine, 1,1-dimethyl
1615801 hydrazine, 1,2-diethyl
540738 Hydrazine, 1,2-dimethyl
122667 Hydrazine, 1,2-diphenyl
302012 Hydrazine
79196 Hydrazinecarbothioamide
CWA RCRA FIFRA SDWA CAA TSCA
U,8
x
P.8
x U,8
x U
x
X
U
x U
x U,8
U
8
U,8
x
8
0,8
x
U,8
U,8
U,8
U,8
U ,8
P,8
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
60344 Hydrazine, methyl P,8
7647010 Hydrochloric acid x
74908 Hydrocyanic acid x P,8 x
7664393 Hydrofluoric acid x U
7783064 Hydrogen sulfide (H2S) x U,8
80159 Hydroperoxide, 1-methyl-1-phenyl ethyl U
7778543 Hypochlorous acid, calcium salt x
7681529 Hypochlorous acid, sodium salt x
10022705 Hypochlorous acid, sodium salt, pentahydrate x
96457 2-Imidazolidinethione U,8
193395 Indeno(l,2,3-cd)pyrene U,8
53861 IH-Indole-3-acetic acid, l-(4-chlorobenzoyl )-5-
methoxy-2-methyl P ,8
7758943 Iron chloride (FeC12) x
7705080 Iron chloride (FeC13) x
10025771 Iron chloride (FeC13), hexahydrate x
9004664 Iron dextran U
7783508 Iron fluoride (FeF3) x
85449 1,3-Isobenzofurandione U,8
133062 lH-Isoindole-1,3(2H)-dione, 3a,4,7,7a-tetrahydro-2-
((trichloromethyl)thio) x
2763964 3(2H)-isoxazolone, 5-(aminomethyl) P,8
7439921 Lead 8 x
1335326 Lead,. bis(acetato-0)tetrahydroxytri U,8
7758954 Lead chloride (PbC12) x
7783462 Lead fluoride (PbF2) x
-------
CAS #
Substance
10101630
Lead iodide (PbI2)
1314870
Lead sulfide (PbS)
7439976
Mercury
62384
Mercury,(acetato-o)phenyl-
592041
Mercury cyanide (Hg(CN)2)
628864
Mercury fulminate
7785844
Metaphosphoric acid (H3P309), trisodium salt
10124568
Metaphosphoric acid (H6P6018), hexasodium salt
74895
Methanamine
75503
Methanamine, N,N-dimethyl
124403
Methanamine, N-methyl
62759
Methanamine, N-methyl-n-nitroso
74839
Methane,
bromo
75-27-4
Methane,
bromodichloro
74873
Methane,
chloro
107302
Methane,
chloromethoxy
74953
Methane,
dibromo
124481
Methane,
dibromochloro
75092
Methane,
dichloro
75718
Methane,
dichlorodifluoro
74884
Methane,
iodo
624839
Methane,
isocyanato
542881
Methane,
oxybis(chloro)
62500
Methanesulfonic acid, ethyl ester
CWA RCRA FIFRA SDWA CAA TSCA
x
x
X
X
U,8
P,8
x
X
X
X
X
U
U,P,8
U,8
x
x
U,8
U,8
U,8
U
U,8
U
U,8
P,8
P,8
11,8
-------
CAS #
Substance
66273 Methanesulfonic acid, methyl ester
56235 Methane, tetrachloro
509148 Methane, tetranitro
74931 Methanethiol
75707 Methanethiol, trichloro
75252 Methane, tribromo
67663 Methane, trichloro
75694 Methane, trichlorofluoro
33089611 Methanimidamide, N'-(2,4-dimethylphenyl)-N-((2,4-
dimethylphenyl)imino)methyl)-N-methyl-
57749 4,7-Methano-lH-indene, 1,2,4,5,6,7,8,8-octachloro-
2,3,3a,4,7,7a-hexahydro
76448 4,7-Methano-lH-indene, 1,4,5,6,7,8,8-heptachloro-
3a,4,7,7a-tetrahydro
1031078 6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10,10-
hexachlor-1,5,5a,6,9,9a-hexahydro-, 3,3-dioxide
33213659 6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10,10-
hexachlor-1,5,5a,6,9,9a-hexahydro-,3-oxi de,(3alpha,
5a alpha, 6 beta, 9 beta, 9a alpha)
115297 6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10,10-
hexachlor-1,5,5a,6,9,9a-hexahydro-,3-oxide
959988 6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10,1-
hexachloro-1,5,5a,6,9,9a-hexahydro-,3-oxide,
(3 alpha, 5a beta, 6 alpha, 9 alpha, 9a beta)
1024573 2,5-Methano-2H-indeno(l,2-b)oxirene, 2,3,4,5,6,7,8-
heptachloro-1a,1b,5,5a,6,6a-hexahydro
67561 Methanol
CWA RCRA FIFRA SDWA CAA TSCA
x
X
8
U,8
P
U
P,8
U,8
U,8
U
P,8
P,8
8
U
-------
CAS #
Substance
124414 Methanol, sodium salt
2385855 1,3,4-Metheno-lH-cyclobuta(cd)pentalene,l,1a,2,2,
3,3a,4,5,5,5a,5b,6-dodecachloroocta hydro
143500 1,3,4-Metheno-2H-cyclobuta(cd)pentalen-2-one, 1,1a,
3,3a,4,5,5a,5b,6-decachlorooctahydro-
59892 Morpholine, 4-nitroso-
20830813 5,12-Naphthacenedione, 8-acetyl-10[(3-amino-2,3,6-
trideoxy-alpha-L-lyxo-hexapyranosyl)oxy]-7,8,9,10-
tetrahydro-6,8,11-tri hydroxy-1-methoxy-,(8S-c i s)
91598 2-Naphthalenamine
134327 1-Naphthalenamine
494031, Naphthalenamine, N,N'-bis(2-chloroethyl)
90131 Naphthalene, 1-chloro
1825305 Naphthalene, 1,5-dichloro
1825316 Naphthalene, 1,4-dichloro
2050693 Naphthalene, 1,2-dichloro
2050728 Naphthalene, 1,6-dichloro
2050739 Naphthalene, 1,7-dichloro
2050740 naphthalene, 1,8-dichloro
2050751 Naphthalene, 2,3-dichloro
2065705 Naphthalene, 2,6-dichloro
2198756 Naphthalene, 1,3-dichloro
2198778 Naphthalene, 2,7-dichloro
28699889 Naphthalene, dichloro-
91587 Naphthalene, 2-chloro
91203 Naphthalene
CWA RCRA FIFRA SDWA CAA TSCA
x
x U,8 x
8
U,8
U,8
U,8
U,8
x 8
x 8
x 8
x 8
x 8
x 8
x 8
x 8
x 8
x 8
x 8
x 8
x U,8
x U,8
-------
CAS #
Substance
130154 1,4-Naphthalenedione
117806 1,4-Naphthalenedione, 2,3-dichloro
72571 2,7-Naphthalenedisulfonic acid, 3,3'-[(3,3'-
dimethyl(1,11-biphenyl)-4,4'-diyl)bis(azoj]
bis(5-amino-4-hydroxy-, tetrasodium salt
2234131 Naphthalene, octachloro
6358538 2-Naphthalenol, l-[(2,5-dimethoxyphenyl)azo]
63252 1-Naphtha!enol, methyl carbamate
192654 Naphtho(l,2,3,4-def)chrysene
1338245 Naphthenic acid
13463393 Nickel carbonyl, (t-4)-
37211055 Nickel chloride
7718549 Nickel chloride (NiC12)
557197 Nickel cyanide
12054487 Nickel hydroxide (Ni(0H)2)
7440020 Nickel
14797558 Nitrate
7697372 Nitric acid
7787555 Nitric acid, beryllium salt, trihydrate
18256989 Nitric acid, lead salt
7761888 Nitric acid, silver (1+) salt
13597994 Nitric acid, beryllium salt
10421484 Nitric acid, iron(3+) salt
10099748 Nitric acid, lead(2+) salt
10415755 Nitric acid, mercury(l+) salt
7782867 Nitric acid, mercury(l+) salt, monohydrate
CWA RCRA FIFRA SDWA CAA TSCA
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
U,8
U,8
8
8
8
P.8
P,8
x
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
10045940
Nitric acid, mercury(2+) salt
X
13138459
Nitric acid, nickel(2+) salt
X
14216752
Nitric acid, nickel salt
X
10102451
Nitric acid, thallium (1+) salt
U,8
7779886
Nitric acid, zinc salt
X
13746899
Nitric acid, zirconium(4+) salt
X
10544726
Nitrogen oxide (N204)
P ,8
10102440
Nitrogen oxide (N02)
X
P,8
10102439
Nitrogen oxide (NO)
P.8
7632000
Nitrous acid, sodium salt
X
16543558
Nornicotine, N-nitroso-
8
1072351
Octadecanoic acid, lead(2+) salt
X
7428480
Octadecanoic acid, lead salt
X
20816120
Oxmium oxide (0S04)(T-4)
P,8
145733
7-0xabicyclo(2.2.1)heptane-2,3-dicarboxylic acid
P >8
1120714
1,2-0xathiolane, 2,2-dioxide
U,8
50180
2H-1,3,2-0xazaphosphorin-2-amine,N,N-bis(2-chloroethyl)
tetrahydro-,2-ox i de
U,8
7530054
Oxirane, 2-chloromethyl-3-methyl
8
75218
Oxirane
U
765344
Ox i ranecarboxaldehyde
U,8
106898
Oxirane, (chloromethyl)
X
U,8
75569
Oxirane, methyl
X
10028156
Ozone
-------
CAS #
Substance
30525894
Paraformaldehyde
504609
1,3-Pentadiene
620111
3-Pentanol, acetate
626380
2-Pentanol, acetate
108101
2-Pentanone, 4-methyl
7722647
Permanganic acid (HMn04), potassium salt
85018
Phenanthrene
578949
Phenarsazine, 10-chloro-5,10-dihydro
88857
Phenol, 2-(1-methylpropyl)-4,6-dinitro
70304
Phenol, 2,2'-methylenebis(3,4,6-trichloro)
97187
Phenol, 2,2'-thiobis(4,6-dichloro)
4901513
Phenol, 2,3,4,5-tetrachloro
58902
Phenol, 2,3,4,6-tetrachloro
64006
Phenol, 2,3,4,6-tetrachloro
933755
Phenol, 2,3,6-trichloro
526750
Phenol, 2,3-dimethyl
95954
Phenol, 2,4,5-trichloro
88062
Phenol, 2,4,6-trichloro
131748
Phenol, 2,4,6-trinitro-, ammonium salt
120832
Phenol, 2,4-dichloro
105679
Phenol, 2,4-dimethyl
51285
Phenol, 2,4-dinitro
583788
Phenol, 2,5-dichloro
CWA RCRA FIFRA SDWA CAA TSCA
x
U
x
X
U
X
X
X
P,8
U,8
x
x 8
x U,8
x 8
x 8
x
x U,8
x U,8
P
x U
U,8
x U,P,8
x 8
-------
CAS #
Substance
329715
Phenol, 2,5-dinitro
87650
Phenol, 2,6-dichloro
573568
Phenol, 2,6-dinitro
95578
Phenol, 2-chloro
131895
Phenol, 2-cyclohexyl-4,6-dinitro
534521
Phenol, 2-methyl-4,6-dinitro
95487
Phenol, 2-methyl
88755
Phenol, 2-nitro
2032657
Phenol, 3,5-dimethyl-4-(methylthio)-, methyl-
carbamate
108689
Phenol, 3,5-dimethyl
108394
Phenol, 3-methyl
558847
Phenol, 3-nitro
56531
Phenol, 4,4*-(1,2-ethendyl)bis-,(E)
59507
Phenol, 4-chloro-3-methyl
315184
Phenol, 4-(dimethylamino)-3,5-dimethyl-,
methyl carbamate (ester)
609938
Phenol, 4-methyl-2,6-dinitro
106445
Phenol, 4-methyl
100027
Phenol, 4-nitro
108952
Phenol
25167800
Phenol, chloro
25167811
Phenol, dichloro
1300716
Phenol, dimethyl
1319773
Phenol, methyl
CWA RCRA FIFRA SDWA CAA TSCA
x
x U,8
x
U,8
P,8
P,8
x U
x
X
X
x U
X
U,8
U,8
x
X
x U
x U,8
x U,8
x 8
x 8
x
U
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
25154556 Phenol, nitro x
87865 Phenol, pentachloro x U,P,8
25167833 Phenol, tetrachloro x 8
25167822 Phenol, trichloro x 8
58366 lOH-Phenoxarsine, 10,10'-oxybis x
148823 L-Phenylalanine, 4-(bis(2-chloroethyl)amino) U,8
7803512 Phosphine P,8
52686 Phosphonic acid, (2,2,2-trichloro-l-hydroxyethyl)-,
dimethyl ester x
944229 Phosphonodithiocic acid, ethyl-, 0-ethyl 5-phenyl
ester x
22224926 Phosphoramidic acid, (1-methylethyl)-, ethyl
3-methyl-4-(methylthio)phenyl ester x
300765 Phosphoric acid, 1,2-dibromo-2,2-dichloroethyl
dimethyl ester x
62737 Phosphoric acid, 2,2-dichloroethenyl dimethyl ester x
470906 Phosphoric acid, 2-chloro-l-(2,4-dichlorophenyl)
ethenyl diethyl ester x
13171216 Phosphoric acid, 2-chloro-3-(diethylamino)-1-methyl-3-
oxo-1-propenyl dimethyl ester x
7664382 Phosphoric acid x
311455 Phosphoric acid, diethyl 4-nitrophenyl ester P,8
6923224 Phosphoric acid dimethyl l-methyl-3-(methylaminoJ-
3-oxo-l-propenyl ester, (E) x
7558794 Phosphoric acid, disodium salt x
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
03
CO
o
10028247 Phosphoric acid, disodium salt, dihydrate x
10039324 Phosphoric acid, disodium salt, dodecahydrate x
10140655 Phosphoric acid, disodium salt, hydrate x
7446277 Phosphoric acid, lead(2+) salt (2:3) U,8
7601549 Phosphoric acid, trisodium salt x
10361894 rnosphoric acid, trisodium salt, decahydrate x
10101890 Phosphoric acid, trisodium salt, dodecahydrate x
13194484 Phosphorodithioic acid, 0-ethyl S,S dipropyl ester
298022 Phosphorodithioic acid, 0,0-diethyl S-[(ethylthio)
methyl) ester P
3288582 Phosphorodithioic acid, 0,0-diethyl ester, S-methyl ester U,8
60515 Phosphorodithioic acid, 0,0-dimethyl S-(2-(methylamino)
-2-oxoethyl) ester P,8
86500 Phosphorodithioic acidi 0,0-dimethyl S-((4-oxo-l,2,3-
benzotriazin-3(4H)-yl)methyl) ester x
563122 Phosphorodithioic acid, S,S'-methylene 0,0,0r,0'-
tetraethyl ester x
298044 Phosphorodithioic acid, 0,0-diethyl S-(2-(ethylthio)
ethyl) ester x P,8
55914 Phosphorofluoridic acid, bis(l-methylethyl) ester P,8
56724 Phosphorothioic acid, 0-(3-chloro-4-methyl-2-
oxo-2H-l-benzopyran-7-yl) 0,0-diethyl ester x
126750 Phosphorothioic acid, 0,0-diethyl S-(2-(ethylthio)
ethyl) ester
-------
CAS #
Substance
CVIA RCRA FIFRA SDWA CAA TSCA
2921882 Phosphorothioic acid, 0,0-diethyl 0-(3,5,6-trichloro-
2-pyridinyl) ester x
115902 Phosphorothioic acid, 0-0-diethyl 0-[4-(methylsulfinyl)
phenyl] ester x
56382 Phosphorothioic acid, 0,0-diethyl 0-(4-nitrophenyl)
ester x P,8
333415 Phosphorothioic acid, 0,0-diethyl 0-(6-methyl-2-(l-
methylethyl)-4-pyrimidinyl) ester x
297972 Phosphorothioic acid, 0,0-diethyl 0-pyrazinyl ester P,8
298000 Phosphorothioic acid, 0,0-dimethyl 0-(4-nitrophenyl)
ester x P,8
52857 Phosphorothioic acid, 0-[4-[(dimethylamine)
sulfonyl]phenyl]0,0-dimethyl ester P,8
126681 Phosphorothioic acid, 0,0,0-triethyl ester 8
7719122 Phosphorous trichloride x
7723140 Phosphorus x
12185103 Phosphorus, mol. (P4) x
1314803 Phosphorus sulfide (P2S5) x U
10025873 Phosphoryl chloride x
78342 Phosphorodithioic acid, S,S'-1,4-dioxane-2,3-
diyl 0,0,0',0'-tetraethyl ester
100754 Piperidine, 1-nitroso U,8
78002 Plumbane, tetraethyl x P,8
9004982 Poly(oxy-l,2-ethanediyl), alpha,-9-octadecenyl-,
omega,-hydroxy-, (Z) P,8
-------
CAS #
Substance
53467111
Poly[oxy(methyl-1,2-ethanediyl)], alpha
-(2,4-di-chlorophenoxy)acetyl-omega-butoxy
151508
Potassium cyanide
1310583
Potassium hydroxide
116063
Propanal, 2-methyl-2-(methylthio)-o-
((methyl amino)carbonyl)oxime
75649
2-Propanamine, 2-methyl
78819
1-Propanamine,2-methyl
107108
1-Propanamine
621647
1-Propanamine, N-nitroso-n-propy1
142847
1-Propanamine, N-propyl
78999
Propane, 1,1-dichloro
96184
Propane, 1,2,3-trichloro
96128
Propane, 1,2-dibromo-3-chloro-
78875
Propane, 1,2-dichloro
142289
Propane, 1,3-dichloro
108601
Propane, 2,2'-oxybis(l-chloro-
39638329
Propane, 2,2'-oxybis(2-chloro-
79469
Propane, 2-nitro
26638197
Propane, dichloro
109773
Propanedinitrile
57556
1,2-Propanediol
CWA RCRA FIFRA SDWA CAA TSCA
x
x
x
P,8
x
x
X
X
P.8
U
U,8
U
8
8
U,8
U,8
8
8
U,8
U
U,8
11,8
P >8
-------
CAS #
Substance
CWA RCRA FIFRA SOMA CAA TSCA
107120
Propanenitrile
P,8
75865
Propaneni tri1e» 2-hydroxy-2-methyl
X
P,8
126987
2-Propanenitrile, 2-methyl
U
542767
Propanenitrile, 3-chloro
P,8
1185575
1,2,3-Propanetricarboxylic acid, 2-hydroxy-,
ammonium iron(3+) salt
X
3012655
1,2,3-Propanetricarboxylic acid, 2-hydroxy-,
diammonium salt
X
55630
1,2,3-Propanetriol, trinitrate
P,8
93721
Propanoic acid, 2-(2,4,5-trichlorophenoxy)
X
U,8
32534955
i
Propanoic acid, 2-(2,4,5-trichlorophenoxy)-,
isooctyl ester
X
75990
Propanoic acid, 2,2-dichloro
X
79312
Propanoic acid, 2-methyl
X
79094
Propanoic acid
X
123626
Propanoic acid, anhydride
X
126727
1-Propanol, 2,3-dibromo-, phosphate (3:1)
U,8
75650
2-Propanol, 2-methyl
X
78831
1-Propanol, 2-methyl
U
598312
2-Propanone, 1-bromo
P,8
67641
2-Propanone
U
107186
2-Propen-l-ol
X"
P,8
107028
2-Propenal
X
P,8
-------
CAS #
Substance
00
1
OJ
4*
79061 2-Propenamide
1888717 1-Propene, 1,1,2,3,3,3-hexachloro
542756. 1-Propene, 1,3-dichloro
8003198 1-Propene, 1,3-dichloro-, mixt with
dichloropropane
78886 1-Propene, 2,3-dichloro
107051 1-Propene, 3-chloro
26952238 1-Propene, dichloro
107131 2-Propenenitrile
97632 2-Propenoic acid, 2-methyl-, ethyl ester
80626 2-Propenoic acid, 2-methyl-, methyl ester
79107 2-Propenoic acid
140885 2-Propenoic acid, ethyl ester
107197 2-Propyn-l-ol
129000 Pyrene
123331 3,6-Pyridazinedione, 1,2-dihydro
504245 4-Pyridinamine
109068 Pyridine, 2-methyl
54115 Pyridine, 3-(1-methyl-2-pyrrolidinyl)-,(S)
65316 Pyridine, 3-(1-methyl-2-pyrrolidinyl)-,(S)
2,3-dihydroxybutanedioate (1:2)
65305 Pyridine, 3-(1-methyl-2-pyrrolidinyl)-,(S)
sulfate (2:1)
CWA RCRA FIFRA SDWA CAA TSCA
U,8
U,P,8
x U,8
x
x 8
x
X
x U,8 x
U
x U,8
U
U
P»8
x
U
P,8
U
P,8
R*))
P,8
P,8
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
2820511
Pyridine, 3-(1-methyl-2-pyrrolidinyl)-, hydrochloride,
(S)
P,8
110861
Pyridine
11,8
1918021
2-Pyridinecarboxylic acid, 4-amino-3,5,6-
trichloro
66751
2,4-(lH,3H)-Pyrimidinedione,5-[bis(2-chloroethyl)
amino]
11,8
56042
4(1H)-Pyrimidinone, 2,3-dihydro-6-methy1-2-thioxo
U,8
51525
4(lH)-Pyrimidinone, 2,3-dihydro-6-propyl-2-thioxo
8
930552
Pyrrolidine, 1-nitroso
U,8
56575
Quinoline, 4-nitro, 1-oxide
8
91225
Quinoline
x
7446222
Selenic acid (H2Se04), dithallium(l+) salt
x
7783008
Selenious acid
U,8
10102188
Selenious acid (H2Se03), disodium salt
X
7782823
Selenious acid (H2Se03), monosodium salt
X
7782492
Selenium
8
7446084
Selenium oxide (Se02)
X
7446346
Selenium sulfide (SeS)
U,8
7488564
Selenium sulfide (SeS2)
X
630104
Selenourea
P,8
115026
L-Serine, diazpacetate (ester)
U,8
16919190
Silicate(2-), hexafluoro-, diammonium
X
16871719
Silicate(2-), hexafluoro-, zinc (1:1)
X
-------
CAS #
Substance
7440224
Silver
506649
Silver cyanide (Ag(CN))
7440235
Sodium
26628228
Sodium azide
143339
Sodium cyanide
7681494
Sodium fluoride
1333831
Sodium fluoride (Na(HF2))
1210732
Sodium hydroxide
16721805
Sodium sulfide (Na(SH))
7789619
Stibine, tribromo
10025919
Stibine, trichloro
7783564
Stibine, trifluoro
8001501
Strobane
1314961
Strontium sulfide
357573
Strychnidin-10-one, 2,3-dimethoxy
57249
Strychni di n-10-one
60413
Strychnidin-10-one, sulfate (2:1)
14017415
Sulfamic acid, cobalt(2+) salt (2:1)
7773060
Sulfamic acid, monoammonium salt
12771083
Sulfur chloride
10025679
Sulfur chloride (S2C12)
CWA RCRA FIFRA SDWA CAA TSCA
8
P,8
x
x
X
X
X
X
X
X
p
P,8
X
X
X
X
X
'X-
P »8
P.8
P.8
P>8
-------
CAS #
Substance
7446095 Sulfur dioxide
7664939 Sulfuric acid
10043013 Sulfuric acid, aluminum salt (3:2)
10045893 Sulfuric acid, ammonium iron (2+) salt (2:2:1)
7783859 Sulfuric acid, ammonium iron(2+) salt (2:2:1),
hexahydrate
15699180 Sulfuric acid, ammonium nickel(2+) salt (2:2:1)
10101538 Sulfuric acid, chromium(3+) salt (3:2)
7758987 Sulfuric acid copper(2+) salt (1:1)
7758998 Sulfuric acid, copper(2+) salt (1:1), pentahydrate
77781 , Sulfuric acid, dimethyl ester
7446186 Sulfuric acid, ditha11ium(1+) salt
7720787 Sulfuric acid, iron(2+) salt (1:1)
7782630 Sulfuric acid, iron(2+) salt (1:1), heptahydrate
10028225 Sulfuric acid, iron(3+) salt (3:2)
7446142 Sulfuric acid, lead(2+) salt (1:1)
15739807 Sulfuric acid, lead salt
7783359 Sulfuric acid, mercury(2+) salt (1:1)
7786814 Sulfuric acid, nickel (2+) salt (1:1)
10031591 Sulfuric acid, thallium salt
7733020 Sulfuric acid, zinc salt (1:1)
14644612 Sulfuric acid, zirconium(4+) salt (2:1)
CWA RCRA FIFRA SDWA CAA TSCA
x
x
x
x
x
x
X
X
U,8
X
X
X
X
X
X
X
X
X P,8
?<,
X
X
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
7446313
Sulfuric acid, zirconium(4+) salt (2:1), tetrahydrate
X
2312358
Sulfurous acid, 2-(4-(l,1-dimethylethyl)phenoxy)
cyclohexyl 2-propynyl ester
X
140578
Sulfurous acid, 2-chloroethyl 2-(4-(l,1-dimethylethyl)
phenoxy)-l-methyl ethyl ester
8
10196040
Sulfurous acid, diammonium salt
X
10192300
Sulfurous acid, monoammonium salt
X
7631905
Sulfurous acid, monosodium salt
X
61788338
Terphenyl, chlorinated
61788338
Terphenyl, chlorinated
757584
i
Tetraphosphoric acid, hexaethyl ester
P»8
7440280
Thallium
X
8
7791120
Thallium chloride (T1C1)
11,8
1314325
Thallium oxide (T103)
P.8
12039520
Thallium selenide (TISe)
P»8
1762954
Thiocyanic acid, ammonium salt
X
592870
Thiocyanic acid, lead (2+) salt
X
592858
Thiocyanic acid, mercury (2+) salt
X
3689245
Thiodiphosphoric acid ((H0)2P(S)20), tetraethyl
ester
P,8
541537
Thioimidodicarbonic diamide
P.8
137268
Thioperoxydicarbonic diamide (((H2N)C(S))2S2),tetramethyl•
U,P,8
7783188
Thiosulfuric acid (H2S203), diammonium salt
X
-------
CAS #
Substance
CWA RCRA FIFRA SDWA CAA TSCA
5344821
Thiourea, (2-chlorophenyl)
P.8
97994
Thiourea, 1-naphthalenyl
P,8
62566
Thiourea
U,8
103855
Thiourea, phenyl
P,8
8001352
Toxaphene
x
U,8
61825
1H-1,2,4-Triazol-3-amine
U,8
123637
1,3,5-Trioxane, 2,4,6-trimethyl
U
7758294
Triphosphoric acid, pentasodium salt
x
541093
Uranium, bis(acetato-0)dioxo-
X
10102064
Uranium, bis(nitrato-O) dioxo-
X
36478769
Uranium, bis(nitrato-0,0,)dioxo-, (OC-6-11)
X
330541
Urea, N'-(3,4-dichloropheny1)-N,N-dimethy1
X
150685
Urea, N'-(4-chloropheny1)-N-N-dimethyl
759739
Urea, N-ethyl-n-nitroso
U,8
684935
Urea, N-methyl-n-ni troso
U,8
7803556
Vanadic acid (HV03), ammonium salt
P.8
1314621
Vanadium oxide (V205)
X
P,8
27774136
Vanadium, oxo(sulfato(2-)-0)
X
4549400
Vinylamine, N-methyl-N-nitroso
Pj8
50555
Yohimban-16-carboxylic acid, 11,17-dimethoxy-18-
((3,4,5-trimethoxybenzoyl)oxy)-, methyl ester,
(3 beta, 16 beta, 17 alpha, 18 beta, 20 alphaj-
U
-------
CAS I
Substance
14639975 Zincate(2-), tetrachloro-, diammonium, (T-
14639986 Zincate(3-), pentachloro-, triammonium
7699458 Zinc bromide
7646857 Zinc chloride
557211 Zinc cyanide
7783495 Zinc fluoride
1314847 Zinc phosphide (Zn3P2)
7440666 Zinc
10026116 Zirconium chloride (ZrC14)
62010100 Zirconium oxide sulfate
CWA RCRA FIFRA SOWA CAA TSCA
x
x
x
X
x P,8
X
x P,8
X
X
-------
RCRA Hazardous Substances from Prior Regulations
Industry and EPA
Hazardous Waste No. Hazardous Waste
Generic:
F001 The spent halogenated solvents used in degreasing, tetrachloroethylene, trichloroethylene,
methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and the chlorinated
fluorocarbons; and sludges from the recovery of these solvents in degreasing operations
F002 The spent halogenated solvents, tetrachloroethylene, methylene chloride, trichloroethylene,
1,2,2-trifluoroethane, o-dichlorobenzene, trichlorofluoromethane and the still bottoms
from the recovery of these solvents
F003 The spent nonhalogenated solvents, xylene, acetone, ethyl acetate, ethyl benzene, ethyl
ether, n-butyl alcohol, cyclohexanone, and the still bottoms from the recovery of
these solvents
F004 The spent nonhalogenated solvents, cresols and cresylic acid, nitrobenzene, and the still
bottoms from the recovery of these solvents
F005 The spent nonhalogenated solvents, methanol, toluene, methyl ethyl ketone, methyl iso-
butyl ketone, carbon disulfide, isobutanol, pyridine and the still bottoms from the
recovery of these solvents
F006 Wastewater treatment sludges from electroplating operations
F007 Spent plating bath solutions from electroplating operations
F008 Plating bath sludges from the bottom of plating baths from electroplating operations
F009 Spent stripping and cleaning bath solutions from electroplating operations
F010 Quenching bath sludge from oil baths from metal heat treating operations
F011 Spent solutions from salt bath pot cleaning from metal heat treating operations
-------
Industry and EPA
Hazardous Waste No.
Hazardous Waste
F012 Quenching wastewater treatment sludges from metal heat treating operations
F013 Flotation tailings from selective flotation from mineral metals recovery operations
F014 Cyanidation wastewater treatment tailing pond sediment from mineral metals recovery
operations
F015 Spent cyanide bath solutions from mineral metals recovery operations
F016 Dewatered air pollution control scrubber sludges from coke ovens and blast furnaces
RCRA Hazardous Waste From Specific Sources
Wood Preservation:
K001 Bottom sediment sludge from the treatment of wastewaters from wood processes that use
cresote and/or pentachlorophenol
Inorganic Pigments:
K002 Wastewater treatment sludge from the production of chrome yellow and orange pigments
K003 Wastewater treatment sludge from the production of molybdate orange pigments
K004 Wastewater treatment sludge from the production of zinc yellow pigments
K005 Wastewater treatment sludge from the production of chrome green pigments
K006 Wastewater treatment sludge from the production of chrome oxide green pigments
(anhydrous and hydrated)
K007 Wastewater treatment sludge from the production of iron blue pigments
K008 Oven residue from the production of chrome oxide green pigments
-------
Industry and EPA
Hazardous Waste No.
Hazardous Maste
Organic Chemicals:
K009 Distillation bottoms from the production of acetaldehyde from ethylene
K010 Distillation side cuts from the production of acetaldehyde from ethylene
K011 Bottom stream from the wastewater stripper in the production of acrylonitrile
K012 Still bottoms from the final purification of acrylonitrile in the production
of acrylonitrile
K013 Bottom stream from the acetonitrile column in the production of acrylonitrile
K014 Bottoms from the acetronitrile purification column in the productidon of acrylonitrile
KOI5 Still bottoms from the distillation of benzyl chloride
KOI6 Heavy ends or distillation residues from the production of carbon tetrachloride
K017 Heavy ends (still bottoms) from the purification column in the production of
epichlorohydrin
K018 Heavy ends from fractionation in ethyl chloride production
K019 Heavy ends from the distillation of ethylene dichloride in ethylene dichloride
production
K020 Heavy ends from the distillation of vinyl chloride in vinyl chloride monomer production
K021 Aqueous spent antimony catalyst waste from fluoromethanes production
K022 Distillation bottom tars from the production of phenol/acetone from cumene
K023 Distillation light ends from the production of phthalic anhydride from naphthalene
-------
Industry and EPA
Hazardous Waste No.
Hazardous Waste
K024 Distillation bottoms from the production of phthalic anhydride from naphthalene
K025 Distillation bottoms from the production of nitrobenzene by the nitration of benzene
K026 Stripping still tails from the production of methyl ethyl pyridines
K027 Centrifuge residue from toluene diisocyanate production
K028 Spent catalyst from the hydrochlorinator reactor in the production of 1,1,1-trichloroethane
KQ29 Waste from the product stream stripper in the production of 1,1,1-trichloroethane
K030 Column bottoms or heavy ends from the combined production of trichloroethylene and
perchloroethylene
Pesticides:
K031 Byproducts salts generated in the production of MSMA and cacodylic acid
K032 Wastewater treatment sludge from the production of chlordane
K033 Wastewater and scrub water from the chlorination of cyclopentadiene in the production
of chlordane
K034 Filter solids from the filtration of hexachlorocyclopentadiene in the production of
chlordane
K035 Wastewater treatment sludges generated in the production of creosote
K036 Still bottoms from toluene reclamation distillation in the production of disulfoton
K037 Wastewater treatment sludges from the production of disulfoton
K038 Wastewater from the washing and stripping of phorate production
-------
Industry and EPA
Hazardous Waste No.
Hazardous Waste
K039 Filter cake from the filtration of diethylphosphorodithoric acid in the production of
phorate
K040 Wastewater treatment sludge from the production of phorate
K041 Wastewater treatment sludge from the production of toxaphene
K042 Heavy ends or distillation residues from the distillation of tetrachlorobenzene in the
production of 2,4,5-T
K043 2,6-Dichlorophenol waste from the production of 2,4-D
Explosives:
K044 Wastewater treatment sludges from the manufacturing and processing of explosives
K045 Spent carbon from the treatment of wastewater containing explosives
K046 Wastewater treatment sludges from the manufacturing, formulation and loading of lead-
based initiating compounds
K047 Pink/red water from TNT operations
Petroleum REfining:
K048 Dissolved air flotation (DAF) float from the petroleum refining industry
K049 Slop oil emulsion solids from the petroleum refining industry
K050 Heat exchanger bundle cleaning sludge from the petroleum refining industry
K051 API separator sludge from the petroleum refining industry
K052 Tank bottoms (leaded) from the petroleum refining industry
-------
Industry and EPA
Hazardous Waste No.
Hazardous Waste
Leather Tanning Finishing:
K053 Chrome (blue) trimmings generated by the following subcategories of the leather tanning
and finishing industry: hair pulp/chrome tan/retan/wet finish; hair save/chrome tan/
retan/wet finish; retan/wet finish; no beamhouse; through-the-blue; and shearling
K054 Chrome (blue) shavings generated by the following subcategory the leather tanning
and finishing industry: hair pulp/chrome tan/retan/wet finibu, nair save/chrome tan/
retan/wet finish; retan/wet finish; no beamhouse; through-the-blue; and shearing
K055 Buffing dust generated by the following subcategories of the leather tanning and finish-
ing industry: hair pulp/chrome tan/retan/wet finish; hair save/chrome tan/retan/wet
finish; retan/wet finish; no beamhouse; and through-the-blue
K056 Sewer screenings generated by the following subcategories of the leather tanning and
finishing industry: hair pulp/chrome tan/retan/wet finish; hair save/chrome tan/retan/
wet finish; retan/wet finish; no beamhouse; through-the-blue; and shearing
K057 Wastewater treatment sludges generated by the following subcategories of the leather tan-
ning and finishing industry: hair pulp/chrome tan/retan/wet finish/ hair save/chrome
tan/retan/wet finish; retan/wet finish; no beamhouse; through-the-blue and shearing
K058 Wastewater treatment sludges generated by the following subcategories of the leather tan-
ning and finishing industry: hair pulp/chrome tan/retan/wet finish; hair save/chrome
tan/retan/wet finish; and through-the-blue
K059 Wastewater treatment sludges generated by the following subcategory of the leather tan-
ning and finishing industry: hair save/non-chrome tan/retan/wet finish
Iron and Steel:
K060 Ammonia still lime sludge from coking operations
K061 Emission control dust/sludge from the electric furnace production of steel
K062 Spent pickle liquor from steel finishing operations
-------
Industry and EPA
Hazardous Waste No. Hazardous Waste
K063 Sludge from lime treatment of spent pickle liquor from steel finishing operations
Primary Copper:
K064 Acid plant blowdown slurry/sludge resulting from the thickening of blowdown slurry from
primary copper production
Primary Lead:
K065 Surface impoundment solids contained in and dredged from surface impoundments at primary
lead smelting facilities
Primary Zinc:
K066 Sludge from treatment of process wastewater and/or acid plant blowdown from primary zinc
production
K067 Electrolytic anode slimes/sludges from primary zinc production
K068 Cadmium plant leach residue (iron oxide) from primary zinc production
Secondary Lead:
K069 Emission control dust/sludge from secondary lead smelting
-------
APPENDIX C
CANDIDATE LIST OF HAZARDOUS SUBSTANCES,
PRIORITY 1
Designation codes are as follows:
Co a Corrosive
F = Flammable
Fs = Flammable Solid
H = Health Hazard
H/W 3 Hazardous When Wet
X * Oxidizer or Explosive
Py = Pyrophoric
C-l
-------
HAZARDOUS SUBSTANCE CANDIDATE LIST, PRIORITY 1
CAS # Substance Designation Criteria
79027 Acetaldehyde, dichloro H
127195 Acetamide, N,N-dimethyl H
108214 Acetic acid, 1-methylethyl ester F
79118 Acetic acid, chloro- Co
541888 Acetic acid, chloro-, anhydride Co
79141 Acetic acid, hydroxy Co
79209 Acetic acid, methyl ester F
109604 Acetic acid, propyl ester F
7327608 Acetonitrile, 2,2', 2''-nitrilotris H
79049 Acetyl chloride, chloro Co
7446700 Aluminum chloride Co
7784181 Aluminun fluoride Co
97938 Aluminum, triethyl- Py
1726654 Aluminum, trihexadecyl Py
1116730 Aluminum, trihexyl Py
1070004 Aluminum, trioctyl Py
1726665 Aluminum, tridecyl Py
68279549 9,10-Anthracenediol, 6-ethyl-l,2,3,4-tetrahydro H
67923880 9,10-Anthracenediol, ethyl-9,10-dihydro H
15547178 9,10-Anthracenedione, 6-ethyl-l,2,3,4-tetrahydro H
101848 Benzene, l,l'-oxybis H
95636 Benzene, 1,2,4-trimethyl H
13414545 Benzene, l-[(2-methyl-2-propenyl)oxy]-2-nitro H
91087 Benzene, 1,3-diisocyanato-2-methyl H
100185 Benzene, 1,4-bi s(1-methyl ethyl) H
88733 Benzene, l-chloro-2-nitro H
100005 Benzene, l-chloro-4-nitro H
5216251 Benzene, l-chloro-4-(trichloromethyl) H
98566 Benzene, l-chloro-4-(trifluoromethyl) H
C-2
-------
CAS #
Substance
Designation Criteria
98839 Benzene, (1-methylethenyl) H
584849 Benzene, 2,4-diisocyanato-l-methyl H
103639 Benzene, (2-bromoethyl) H
25321099 Benzene, bis(1-methylethyl) H
719324 1,4-Benzenedicarbonyl dichloride, 2,3,5,6-
tetrachloro H
100210 1,4-Benzenedicarboxylic acid Co
25724587 1,2-Benzenedicarboxylic acid, decyl hexyl ester H
26761400 1,2-Benzenedicarboxylic acid, diisodecyl ester
3648202 1,2-Benzenedicarboxylic acid, diundecyl ester H
25340174 Benzene, diethyl
123319 1,4-Benzenediol H
123013 Benzene, dodecyl H
25550145 Benzene, ethyl methyl H
103651 Benzene, propyl H
98113 Benzenesulfonic acid Co
104154 Benzenesulfonic acid, 4-methyl H
50854949 Benzenesulfonic acid, undecyl H
1459105 Benzene, tetradecyl H
6742547 Benzene, undecyl H
13414556 Benzofuran, 2,3-dihydro-2,2-dimethyl-7-nitro H
68298464 7-Benzofuranamine, 2,3-dihydro-2,2-dimethyl-,
sulfate (2:1) H
1563388 7-Benzofuranol, 2,3-dihydro-2,2-dimethyl H
118489 2H-3,l-Benzoaz1ne-2,4(lH)-dione H
12161829 BertrandIte (BE4(0H)20(Si03)2) H
32741927 [1,1'-Biphenyl3-2,4', 5-tricarboxylic acid,
trimethyl ester H
92524 l,l'-Biphenyl H
7726956 Bromine Co
106990 1,3-Butadiene F
106978 Butane F
107891 Butanal, 3-hydroxy F
123728 Butanal F
C-3
-------
CAS #
Substance
Designation Criteria
78784 Butane, 2-methyl F
17773410 Butanenitrile, 2-hydroxy-4-(methylthio) H
583915 Butanoic acid, 2-hydroxy-4-(methylthio) H
106310 Butanoic acid, anhydride
106989 1-Butene
107017 2-Butene
25167673 Butene
2431507 1-Butene, 2,3,4-trichloro
513359 2-Butene, 2-methyl
563462 1-Butene, 2-methyl
760236 1-Butene, 3,4-dichloro
563451 1-Butene, 3-methyl
624646 2-Butene, (E)
590181 2-Butene, (Z)
26760645 Butene, methyl
16529569 3-Butenenitrile 2-methyl H
110656 2-Butyne-l,4-diol H
126998 1,3-Butadiene, 2-chloro H
7789755 Calcium fluoride Co
1305620 Calcium hydroxide Co
1305788 Calcium oxide Co
1305799 Calcium peroxide Co
40861298 Carbonic acid, ammonium zinc salt (2:1:2) H
2941642 Carbonochloridothioic acid, S-ethyl ester H
140932 Carbonodithioic acid, 0-(1-methylethyl) ester,
sodium salt H
9004700 Cellulose, nitrate X
10049044 Chlorine oxide (CI02) X
1333820 Chromium oxide (Cr03) H
57455375 Color Index Pigment Blue 29 H
1344372 Color Index Pigment Yellow 34 H
51274001 Color Index Pigment Yellow 42 H
C-4
-------
CAS #
Substance
Designation Criteria
12013159 Copper hydroxide sulfate H
22205454 Copper sulfide (Cu2S) H
108918 Cyclohexanamine
94600 1,4-Cyclohexanedicarboxylic acid, dimethyl ester
108930 Cyclohexanol
100641 Cyclohexanone, oxime
96377 Cyclopentane, methyl
75194 Cyclopropane
124185 Decane
112312 Decanal
872059 1-Decene
7775146 Dithionous acid, disodium salt H
67481 Ethanaminium, 2-hydroxy-N,N,N-trimethyl-,chloride H
1325877 Ethanaminium, n-[4-[[4-(diethylamino)pheny1][4-
(ethyl ami no)-1-naphtha!enyl]methyleneJ-2,5-
cyclohexadien-1-ylidene]-N-ethyl-, molybdate-
tungstatephosphate H
505602
Ethane, 1,1'-thiobis(2-chloro
H
74840
Ethane
F
111400
1,2-Ethanediamine, N-(2-aminoethyl)
H
144627
Ethanedioic acid
H
63494597
Ethanesulfonamide, 2-(ethyl(3-methyl-
4-n1trosophenyl)amino)-N-methyl
H
102716
Ethanol, 2,2',2''-nitrilotris
H
111422
Ethanol, 2,2'-iminobis
H
141435
Ethanol, 2-amino
H
107073
Ethanol, 2-chloro
H
110805
Ethanol, 2-ethoxy
F
111159
Ethanol, 2-ethoxy-, acetate
F
109864
Ethanol, 2-methoxy
F
64175
Ethanol
F
C-5
-------
CAS #
Substance
540498
Ethene, 1,2-dibromo
74851
Ethene
116143
Ethene, tetrafluoro
74862
Ethyne
8049170
Ferrosilicon
7789211
Fluorosulfuric acid
68122
Formamide, N,N-dimethyl
109944
Formic acid, ethyl ester
107313
Formic acid, methyl ester
98000
2-Furanmethanol
96480
2(3H)-Furanone, dihydro
142825
Heptane
592767
1-Heptene
25339564
Heptene
110543
Hexane
124094
1,6-Hexanediamine
111693
Hexanedinitrile
1772254
1,3,6-Hexanetri carbon i tri1e
111273
1-Hexanol
104767
1-Hexanol, 2-ethyl
110123
2-Hexanone, 5-methyl
645625
2-Hexenal, 2-ethyl
592416
1-Hexene
1119853
3-Hexenedinitrile
13042029
2-Hexenedinitrile
10035106
Hydrobromic acid
1333740
Hydrogen
7722841
Hydrogen peroxide
3071327
Hydroperoxide, 1-phenylethyl
10039540
Hydroxy!amine, sulfate (2:1)
7790923
Hypochlorous acid
Designation Criteria
X
X
H
Co
C-6
-------
CAS #
Substance
Designation Criteria
1854268 2-Imidazolidinone, 4,5-dihydroxy-l,3-
bi s(hydroxymethyl) H
68797397 lH-Imidazolium, 1(or 3)-(carboxymethyl)-4,
5-di hydro-1-(2-hydroxyethy1)-2-undecyl-,
salt with alpha-sulfo-omega-(tridecyloxy)
poly(oxy-l,2-ethanediyl), monosodium salt H
108190 Imidodicarbonic diamide H
7553562 Iodine H
1310436 Iron phosphide (Fe2P) H
1317379 Iron sulfide (FeS) H
31394544 Isoheptane F
1314416 Lead oxide (Pb304) H
1317368 Lead oxide (PbO) H
7439954 Magnesium FS
1313139 Manganese oxide (Mn02) H
593817 Methanamine, N,N-dimethyl-, hydrochloride H
115106 Methane, oxybis F
594423 Methanesulfenyl chloride, trichloro Co
77736 4,7-Methano-lH-indene, 3a,4,7,7a-tetrahydro H
3085356 Methanol, butoxy F
4461523 Methanol, methoxy F
1313275 Molybdenum oxide (Mo03) H
2027170 Naphthalene, 2-(1-methylethyl) H
38640629 Naphthalene, bis(1-methylethyl) H
1937377 2,7-Naphthalenedisulfonic acid, 4-amino-3-
C(4'-[(2,4-diaminophenyl)azo][l,11-bi phenyl]-
4-yl]azo]-5-hydroxy-6-(phenylazo)-,disodium salt H
12035722 Nickel sulfide H
13780115 Nitric acid, ammonium calcium salt (3:1:1) X
6484522 Nitric acid ammonium salt X
10124375 Nitric acid, calcium salt X
7757791 Nitric acid, potassium salt X
7631994 Nitric acid sodium salt X
10042769 Nitric acid, strontium salt X
C-7
-------
CAS #
Substance
Designation Criteria
10024972 Nitrogen oxide (N20)
7782776 Nitrous acid
123966 2-0ctanol
111875 l-0ctanol
111660 l-0ctene
674828 2-0xetanone, 4-methylene
107835 Pentane, 2-methyl
109660 Pentane
4553622 Pentanedinitrile, 2-methyl
123422 2-Pentanone, 4-hydroxy-4-methyl
25377724 Pentene
141797 3-Penten-2-one, 4-methyl
107391 1-Pentene, 2,4,4-trimethyl
107404 2-Pentene, 2,4,4-trimethyl
109671 1-Pentene
646048 2-Pentene, (E)
4635874 3-Pentenenitrile
7632044 Perboric acid, sodium salt
7790989 Perchloric acid, ammonium salt
7601890 Perchloric acid, sodium salt
7727540 Peroxydisulfuric acid [((H0)S(0)2)202],
diammonium salt
25168063 Phenol, (1-methyl ethyl)
13414589 Phenol, 2-(2-methylallyl)-6-nitro
90051 Phenol, 2-methoxy
98544 Phenol, 4-(l,1-dimethylethyl)
80057 Phenol, 4,4'-(1-methylethylidene)bis
1121706 Phenol, 4-methyl-, sodium salt
27193868 Phenol, dodecyl
251,54523 Phenol, nonyl
13847171 Phosphoric acid, cadmium salt
X
X
X
X
H
H
H
H
H
H
H
H
H
C-8
-------
CAS #
Substance
Designation Criteria
2524030 Phosphorochloridothioic acid,
0,0-dimethyl ester H
756809 Phosphorodithioic acid, 0,0-dimethyl
ester H
121459 Phosphorous acid, trimethyl ester H
101020 Phosphorous acid, triphenyl ester H
25586429 Phosphorous acid, tris(methylphenyl)
ester H
1314563 Phosphorus oxide (P205) Co
1762272 Plumbane, diethyl dimethyl H
1762283 Plumbane, triethylmethyl H
7789233 Potassium fluoride H
78842 Propanal, 2-methyl F
597319 Propanal, 3-hydroxy-2,2-dimethyl F
3268493 Propanal, 3-(methylthio) H
123386 Propanal F
919302 1-Propanamine, 3-(triethoxysilyl) H
108203 Propane, 2,2'-oxybis- F
75285 Propane, 2-methyl F
74986 Propane F
598787 Propanoic acid, 2-chloro H
97858 Propanoic acid, 2-methyl-, 2-methylpropyl
ester F
110974 2-Propanol, 1,1'-iminobis H
76084 2-Propanol, 1,1,l-tribromo-2-methyl H
78897 1-Propanol, 2-chloro H
67630 2-Propanol F
71238 1-Propanol F
26545733 Propanol, dichloro H
115117 1-Propene, 2-methyl F
563473 1-Propene, 3-chloro-2-methyl H
115071 1-Propene F
C-9
-------
CAS # Substance Designation Criteria
103117
2-Propenoic acid, 2-ethylhexyl ester
F
79414
2-Propenoic acid, 2-methyl-
Co
141322
2-Propenoic acid, butyl ester
F
96333
2-Propenoic acid, methyl ester
F
74997
1-Propyne
F
872504
2-Pyrrolidinone, 1-methyl
H
10026047
Si lane, tetrachloro
Co
10025782
Silane, trichloro
Co
16925396
Silicate(2-), hexafluoro-, calcium (1:1)
Co
16961834
Silicate(2-), hexafluoro-, dihydrogen
Co
16893859
Silicate(2-), hexafluoro-, disodium
Co
56802994
Sodium hypochlorite phosphate
X
1313822
Sodium sulfide (Na2S)
H
5329146
Sulfamic acid
Co
10545990
Sulfur chloride (SCI2)
Co
7785877
Sulfuric acid, manganese(2+) salt (1:1)
H
8014957
Sulfuric acid, mixt with sulfur trioxide
Co
7681381
Sulfuric acid, monosodium salt
Co
7782992
Sulfurous acid
Co
7446119
Sulfur trioxide
Co
7791255
Sulfuryl chloride
Co
8007452
Tar, coal
H
100970
1,3,5,7-Tetraazatricyclo(3.3.1.13,7)decane
H
7719097
Thionyl chloride
Co
3982910
Thiophosphoryl chloride
Co
7440326
Titanium
FS
7550450
Titanium chloride (TiC14), (T-4)
Co
108805
1,3,5-Triazine-2,4,6(lH,3H,5H)-trione
H
2782572
1,3,5-Triazine-2,4,6(lH,3H,5H)-trione
1,3-dichloro
X
2893789
1,3,5-Triazine-2,4,6(lH,3H,5H)-trione,
1,3-dichloro-, sodium salt
X
C-10
-------
CAS #
Substance
Designation
Criteria
36452218
1,3,5-Triazine-2,4,6(lH,3H,5H)~trione,
disodium salt
H
108770
1,3,5-Triazine, 2,4,6-trichloro
H
121824
1,3,5-Triazine, hexahydro-1,3,5-trinitro
X
110883
1,3,5-Trioxane
H
10380082
Triphosphoric acid
Co
8006642
Turpentine
H
1120214
Undecane
F
1314132
Zinc oxide
H
51810709
Zinc phosphide
H
62010100
Zirconium oxide sulfate
H
C-ll
-------
APPENDIX D
CANDIDATE LIST OF HAZARDOUS SUBSTANCES,
PRIORITY 2
Designation
codes are as follows:
Co
=
Corrosive
F
s
Flammable
FS
s
Flammable Solid
H
s
Health Hazard
H/W
a
Hazardous When Wet
X
9
Oxidizer or Explosive
Py
S
Pyrophoric
D-l
-------
CANDIDATE LIST OF HAZARDOUS SUBSTANCES, PRIORITY 2
CAS # Substance Designation Criteria
93710 Acetamide, 2-chloro-N,N-di-2-propenyl H
40137608 Acetic acid, chloro-, l-methyl-2-
(2-methylpropoxy) ethyl ester H
5330176 Acetic acid, chloro-, 2-butoxyethyl ester H
590023 Acetic acid, chloro-, butyl ester H
96344 Acetic acid, chloro-, methyl ester H
3926623 Acetic acid, chloro-, sodium salt H
25103097 Acetic acid, mercapto-, isooctyl ester H
298124 Acetic acid, oxo Co
76039 Acetic acid, trichloro Co
79367 Acetyl chloride, dichloro Co
14484696 Aluminate (1-), tetrafluoro-, potassium, (T-4) H
64147473 Aluminate (2-), difluoro (phosphato
(3-)-01-, sodium hydrogen H
7784216 Aluminum hydride Py
60304361 Aluminum potassium fluoride H
1116707 Aluminum, tributyl Py
12124979 Ammonium bromide H
6219665 1,2-Anthracenedicarboxylic acid,
7-acetyl-6-ethyl-9, 10-dihydro-3,5,8-
trihydroxy-9,10-dioxo H
68310496 lH-Azepine-l-carboxamide, N,N', N1'-
[(2,4,6-trioxo-l,3,5-triazine-l ,3,5
(2H ,4H,6H)-triyl) tri s(methyl-3,1-phenylene)]
tris(hexahydro-2-oxo H
111499 lH-Azepine, hexahydro H
10302155 Aziridine, 1-(phenylsulfonyl) H
10361372 Barium chloride H
11138117 Barium iron oxide H
90028 Benzaldehyde, 2-hydroxy H
100527 Benzaldehyde H
D-2
-------
CAS #
Substance
Designation Criteria
1334787 Benzaldehyde, methyl H
88686 Benzamide, 2-amino H
25834804 Benzenamine, 2,4-bis[(4-aminophenyl)methyl] H
95534 Benzenamine, 2-methyl- H
88744 Benzenamine, 2-nitro H
569619 Benzenamine, 4-[(4-aminophenyl)(4-imino-
2,5-cyclo-hexadi en-1-yli dene)methyl)-
monohydrochloride H
768525 Benzenamine, N-(1-methylethyl) H
121697 Benzenamine, N,N-dimethyl H
122394 Benzenamine, N-phenyl H
588590 Benzene, 1,1'-(1,2-ethenediyl)bis H
1163195 Benzene, 1,11-oxybis(2,3,4,5,6-pentabromo) H
98511 Benzene, 1 -(1,1-dimethyl ethyl)-4-methyl H
98066 Benzene, (1,1-dimethylethyl) H
634662 Benzene, 1,2,3,4-tetrachloro H
99627 Benzene, 1,3-bis(l-methylethyl) H
68360 Benzene, 1,4-bis(trichloromethyl) H
105055 Benzene, 1,4-diethyl H
121733 Benzene, l-chloro-3-nitro H
104121 Benzene, l-chloro-4-isocyanato H
100298 Benzene, l-ethoxy-4-nitro H
104938 Benzene, 1-methoxy-4-methyl H
602017 Benzene, 1-methyl-2,3-dinitro X
6144043 Benzene, (1-methylethenyl)-, dimer H
393759 Benzene, 2-chloro-l,3-dinitro-5-
(trifluoromethyl) H
118967 Benzene, 2-methyl-l,3,5-trinitro X
619158 Benzene, 2-methyl-l,4-dinitro X
610399 Benzene, 4-methyl-l,2-dinitro X
13005362 Benzeneacetic acid, potassium salt H
114705 Benzeneacetic acid, sodium salt H
614459 Benzenecarboperoxoic acid, 1,l-d1methylethyl
ester H
D-3
-------
CAS #
Substance
Designation Criteria
25168052 Benzene, chloromethyl H
793248 1,4-Benzenediamine, N-0,3-dimethylbutyl)-
N'-phenyl H
91156 1,2-Benzenedicarbonitrile H
626175 1,3-Benzenedicarbonitrile H
100209 1,4-Benzenedicarbonyl dichloride H
85701 1,2-Benzenedicarboxylic acid, 2-butoxy-
2-oxoethyl butyl ester H
6422862 1,4-Benzenedicarboxylic acid, bis (2-
ethylhexyl) ester H
117828 1,2-Benzenedicarboxylic acid, bis(2-
methoxyethyl)ester H
84695 1,2-Benzenedicarboxylic acid, bis(2-
methylpropyl)ester H
85698 1,2-Benzenedicarboxylic acid, butyl
2-ethylhexyl ester H
119073 1,2-Benzenedicarboxylic acid, decyl
octyl ester H
131179 1,2-Benzenedicarboxylic acid, di-2-
propenyl ester H
84617 1,2-Benzenedicarboxylic acid, dicyclohexyl
ester H
84775 1,2-Benzenedicarboxylic acid, didecyl
ester H
131113 1,2-Benzenedicarboxylic acid, dimethyl
ester H
1459934 1,3-Benzenedicarboxylic acid, dimethyl
ester H
119062 1,2-Benzenedicarboxylic acid, ditridecyl
ester H
58353632 Benzene, dodecylnitro H
60128 Benzeneethanol H
64800835 Benzene, ethyl(phenylethyl) H
56939 Benzenemethanaminium, N,N,N-trimethyl-
chloride H
D-4
-------
CAS #
Substance
Designation Criteria
2650182 Benzenemethanaminium, N-ethyl-N-[4-[[4-
(ethyl [(3-sulfophenyl)methyl]amino]
phenyl](2-sulfophenyl)methylene)-2,5-
cyclohexadien-l-ylidene]-3-sulfo-, hydroxide,
inner salt, diammonium salt H
467629 Benzenemethanol, 4-amino-, alpha, alpha,
-bis(4-aminophenyl) H
2131182 Benzene, pentadecyl H
38888981 Benzene, (phenyl ethyl) H
6683198 Benzenepropanoic acid, 3,5-bis(l,1-dimethy-
lethyl)-4-hydroxy-, 2,2-bis[(3-[3,5-bis
(1,1-dimethyl ethyl)-4-hydroxyphenyl]-l-
oxopropoxy]methyl]-l,3-propanediyl ester H
6386385 Benzenepropanoic acid, 3,5-bis(1,l-
dimethylethyl)-4-hydroxy-, methyl ester H
2082793 Benzenepropanoic acid, 3,5-bis(l,l-
dimethylethyl)-4-hydroxy-, octadecyl ester H
88197 Benzenesulfonamide, 2-methyl H
70553 Benzenesulfonamide, 4-methyl H
1077561 Benzenesulfonamide, N-ethyl-2-methyl H
28348530 Benzenesulfonic acid, (1-methylethyl)-,
sodium salt H
13863315 Benzenesulfonic acid, 2,2'-(l,2-ethenediyl)
bis[[4-[(2-hvdroxyethyl)methylamino]-6-
(phenyl ami noj-1»3,5-tri azln-2-y1]ami no!-,
disodium salt H
16090021 Benzenesulfonic acid, 2,2'-(1,2-ethenediyl)
bis(4-morpholinyl)-6-(phenylamino)-l ,3,5-
tr1azin-2-yl]am1no]-» disodium salt H
16470249 Benzenesulfonic acid, 2,2'-(l,2-ethened1yl)
bis[5-[[4-[bis(2-hydroxyethyl)amino]-6-
[(4-sulfophenyl)amino]-1,3,5-triazin-2-yl]
amino]-, tetrasodlum salt H
68155680 Benzenesulfonic acid, 2,2'-(1,2-ethenediyl)
bis[5-[[4-chloro-6-[4-sulfophenyl)amino]-
1,3,5-tr1az1n-2-yl]am1no]-, dipotassium
disodium salt H
81118 Benzenesulfonic acid, 2,2'-(l,2-ethened1yl)
b1s(5-amino) H
D-5
-------
CAS #
Substance
Designation Criteria
7336201 Benzenesulfonic acid, 2,2'-0 .2-ethenediyl)
bis(5-amino)-, disodium salt H
128427 Benzenesulfonic acid, 2,2'-(l,2-ethenediyl)
bis(5-nitro) H
15883597 Benzenesulfonic acid, 2,2'-(l ,2-ethenediyl)
bis(5-nitro)-, sodium salt H
88539 Benzenesulfonic acid, 2-amino-5-chloro-
4-methyl H
121039 Benzenesulfonic acid, 2-methyl-5-nitro H
127684 Benzenesulfonic acid, 3-nitro-, sodium salt H
18777543 Benzenesulfonic acid, 4-(l-ethyldecyl) H
16066356 Benzenesulfonic acid, 4-(1-methylethyl) H
54322315 Benzenesulfonic acid, 4-(2-bromoethyl) H
80513 Benzenesulfonic acid, 4,4'-oxybis-,
dihydrazide H
1324761 Benzenesulfonic acid, [[4-[[4-(phenylamino)
phenyl [4-(phenylimino)-2,5-cyclohexadien-1-
yliden]methyl]phenyl(amino] H
140603 Benzenesulfonic acid, 4-decyl H
2627067 Benzenesulfonic acid, 4-decyl-, sodium salt H
98691 Benzenesulfonic acid, 4-ethyl H
14995381 Benzenesulfonic acid, 4-ethyl-, sodium salt H
5160021 Benzenesulfonic acid, 5-chloro-2-[(2-hydroxy-
1-naphthalenyl)azo]-4-methyl-, barium salt (2:1) H
6973133 Benzenesulfonic acid, 5-chloro-4-methyl-2-nitro H
25321419 Benzenesulfonic acid, dimethyl H
28519020 Benzenesulfonic acid, dodecyl (sulfophenoxy)-,
disodium salt H
27457289 Benzenesulfonic acid, ethenyl-, sodium salt H
57352348 Benzenesulfonic acid, ethyl H
30995654 Benzenesulfonic acid, ethyl-, sodium salt H
12068030 Benzenesulfonic acid, methyl-, sodium salt H
25496019 Benzenesulfonic acid, tridecyl H
26248248 Benzenesulfonic acid, tridecyl-, sodium salt H
133595 Benzenesulfonyl chloride, 2-methyl H
D-6
-------
CAS #
Substance
Designation Criteria
121631
Benzenesulfonyl chloride, 4,4'-oxybis
H
98599
Benzenesulfonyl chloride, 4-methyl
H
930698
Benzenethiol, sodium salt
H
68186312
1,2,4-benzenetricarboxylic acid, 2-ethylhexyl
ester
H
132672
Benzoic acid, 2-[(l-naphthalenylamino)
carbonyl-, monosodium salt
H
34408258
Benzoic acid, 2,5-dichloro-3-n1tro-,
methyl ester
H
2905693
Benzoic acid, 2,5-dichloro-, methyl ester
H
134203
Benzoic acid, 2-amino-, methyl ester
H
40188838
Benzoic acid, 3,6-dichloro-2-nitro-, methyl
ester
H
98737
Benzoic acid, 4-(l,1-dimethylethyl)
H
1571080
Benzoic acid, 4-formyl-, methyl ester
H
99752
Benzoic acid, 4-methyl-, methyl ester
H
68540409
Benzoic acid, 5-hexadecyl-2-hydroxy-,
calcium salt (2:1)
H
25567106
Benzoic acid, methyl
H
91645
2H-1-Benzopyran-2-one
H
95329
Benzothiazole, 2-(4-morpholiny 1dithio)
H
2492264
2(3H)-Benzothiazolethione, sodium salt
H
90164
1,2,3-Benzotriazin-4(lH)-one
H
24310416
1,2,3-Benzotriazin-4(3H)-one, 3-
(chloromethyl)
H
2905604
Benzoyl chloride, 2,3-dichloro
Co
2905615
Benzoyl chloride, 2,5-dichloro
Co
2905615
Benzoyl chloride, 2,5-dichloro
Co
13327327
Beryllium hydroxide
H
80568
B1cyclo(3,1,1)hept-2-ene,2,6,6-trimethyl
F
25640782
1,1'-Biphenyl, (1-methylethyl)
H
90437
[1,1'-BiphenylJ-2-ol
H
612839
(1,1'-Biphenyl)-4,4'-diamine, 3,3'-dichloro-,
dihydrochloride
H
28652724
1 ,T-Biphenyl, methyl
H
D-7
-------
CAS #
Substance
Designation Criteria
121437 Boric acid, trimethyl ester F
590192 1,2-Butadiene F
67755979 Butanal, 2-hydroxy-3-methyl H
541355 Butanamide H
6358856 Butanamide, 2,2'-[(3,3'-dichloro(l,1'-
biphenyl) -4,4'-diyl)bis(azo)]bis
(3-oxo-N-phenyl H
102012 Butanamide, 3-oxo-n-phenyl H
616217 Butane, 1,2-dichloro H
6863587 Butane, 2,2'-oxybis F
75832 Butane, 2,2-dimethyl F
79298 Butane, 2,3-dimethyl F
6865970 Butane, 2-chloro-3-nitroso-, dimer H
17611824 Butanedinitrile, ethyl H
106650 Butanedioic acid, dimethyl ester F
577117 Butanedioic acid, sulfo-, 1,4-bis(2-ethyl-
hexylJester, sodium salt H
1639663 Butanedioic acid, sulfo-, 1,4-dioctyl ester,
sodium salt H
13419595 Butanedioic acid, sulfo-, trisodium salt H
109740 Butanenitrile H
141979 Butanoic acid, 3-oxo-, ethyl ester F
105453 Butanoic acid, 3-oxo-, methyl ester F
14481608 Butanoic acid, 4-(octadecylamino)-4-oxo-
2-sulfo-, disodium salt H
52871188 Butanoic acid, 4-(octadecylamino)-4-oxosulfo-,
disodium salt H
14287048 Butanoic acid, ammonium salt H
97950 1-Butanol, 2-ethyl F
75854 2-Butanol, 2-methyl F
3085301 1-Butanol, aluminum salt FS
1320667 Butanol, chloro H
2372454 1-Butanol, sodium salt FS
75978 2-Butanone, 3,3-dimethyl F
689974 l-Buten-3-yne F
D-8
-------
CAS #
Substance
Designation Criteria
503606
2-Butene, l-chloro-3-methyl
F
30574971
2-Butenenitrile, 2-methyl-, (E)
H
20068024
2-Butenenitrile, 2-methyl-, (Z)
H
3724650
2-Butenoic acid
Co
1306190
Cadmium oxide
H
7440702
Calcium
FS
9007130
Calcium resinate
FS
65105002
Carbamic acid, (3-isocyanatomethylphenyl)-,
1-methyl-1,3-propanediyl ester
H
68413832
Carbamic acid, bis(hydroxymethyl)-, 2-(l-methyl-
ethoxy)ethyl ester
H
52304173
Carbamic acid, bis(hydroxymethyl)-,2-methyl-
propyl ester
H
67953326
Carbamic acid, (hydroxymethyl)-, 2-methylpropyl
ester
H
3566107
Carbamodithioc acid, 1,2-ethanediylbis-,
diammonium salt
H
51821
Carbamodithioic acid, dimethyl-,
(dimethylamino)methyl ester
H
105588
Carbonic acid, diethyl ester
F
3333673
Carbonic acid, nickel(2+) salt (1:1)
H
108236
Carbonochloridic acid, 1-methylethyl ester
H
106752
Carbonochloridlc acid, oxydi-2, 1-ethanediyl
ester
H
109615
Carbonochloridlc acid, propyl ester
H
13889924
Carbonochlorldothioic acid, S-propyl ester
H
25306756
Carbonodithioic acid, 0-(2-methylpropyl)
ester, sodium salt
H
151019
Carbonodithioic acid, 0-ethyl ester
H
35200023
Carbonodithioic acid, S-methyl 0-
(1-methylethyl)ester
H
2231574
Carbonothioic dlhydrazlde
H
463581
Carbon oxide sulfide
H
7791211
Chlorine oxide (C120)
X
D-9
-------
CAS #
Substance
Designation Criteria
3021316 Chlorosulfurous acid, 2-(p-tert-butyl-
phenoxy)cyclohexyl ester H
13530659 Chromic acid (H2CR04), zinc salt (1:1) H
7758976 Chromic acid, lead(2+) salt (1:1) H
1308141 Chromium hydroxide H
12336957 Chromium hydroxide sulfate H
1308389 Chromium oxide (Cr203) H
11118573 Chromium oxide H
7440484 Cobalt H
1325377 Color Index Direct Yellow 11 H
12656858 Color Index Pigment Red 104 H
8007189 Color Index Pigment Yellow 53 H
68389468 Color Index Solvent Blue 3, leuco base H
147148 Copper, [29H,31H-phthalocyaninato(2-)~
N29,N30,N31,N32]-, (SP-4-1) H
7758896 Copper chloride H
1317391 Copper oxide H
1317404 Copper sulfide H
5124301 Cyclohexane, 1,V-methylenebis(4-
isocyanato) H
87843 Cyclohexane, 1,2,3,4,5-pentabromo-6-chloro H
3322938 Cyclohexane, 1,2-dibromo-4-(l,2-dibromoethyl) H
99821 Cyclohexane, 1-methyl-4-(1-methyl ethyl) F
26762925 Cyclohexane, 1-methyl-4-(1-methylethyl)-,
monohydroperoxy derivative F
4098719 Cyclohexane, 5-isocyanato-l-(isocyanatomethyl)
-1,3,3-trimethyl F
542187 Cyclohexane, chloro F
694837 1,2-Cyclohexanediamine F
1942718 Cyclohexanol, 2-(p-tert-buty1phenoxy) F
31198762 2-Cyclohexen-l-one, 2-methyl-5-
(l-methy1ethenyl)-,oxime F
D-10
-------
CAS #
Substance
Designation Criteria
2622211 Cyclohexene, 1-ethyenyl
138863 Cyclohexene, 1-methyl-4-{1-methylethenyl)
5989275 Cyclohexene, 1-methyl-4-(1-methylethenyl)-,(R)
100403 Cyclohexene, 4-ethenyl F
111784 1,5-Cyclooctadiene F
542927 1,3-Cyclopentadiene F
5500210 Cyclopropanecarbonitrile H
26389606 Cyclopropanemethanamine, N-propyl H
280579 1,4-Diazabicyclo(2,2,2)octane H
126158 4a(4H)-Di benzofurancarboxaldehyde,
1,5a,6,9,9a,9b-hexahydro H
13560899 1,4:7,10-Dimethanodibenzo(a,e)cyclooctene,
1,2,3,4,7,8,9,10,13,13,14,14-dodecachloro-
1,4,4a,5,6,6a,7,10,10a,11,12,12a-dodecahydro H
646060 1,3-Dioxolane F
107460 Disiloxane, hexamethyl F
142789 Dodecanamide, N-(2-hydroxyethyl) H
869249 Ethanamine, 2-chloro-n,n-diethyl-,
hydrochloride H
79276 Ethane, 1,1,2,2-tetrabromo H
534156 Ethane, 1,1-dimethoxy H
693072 Ethane, l-chloro-2-(ethylthio) H
107222 Ethanedial H
628966 1,2-Ethanediol, dinitrate X
79210 Ethaneperoxoic acid X
1562001 Ethanesulfonic acid, 2-hydroxy-,
monosodium salt H
75081 Ethanethiol H
4439207 Ethanol, 2,2'-(1,2-ethanediyldiimino)b1s H
14806725 Ethanol, 2,2',2''-nitrilotris-, acetate
(salt) H
14426212 Ethanol, 2,2'-iminobis-, hydrochloride H
111411 Ethanol, 2-((2-aminoethyl)amino) H
78513 Ethanol, 2-butoxy-, phosphate (3:1) H
D-ll
-------
CAS #
Substance
Designation Criteria
52663577
Ethanol, 2-butoxy-, sodium salt
FS
140089
Ethanol, 2-chloro-, phosphite (3:1)
H
100378
Ethanol, 2-(di ethyl ami no)
H
110770
Ethanol, 2-(ethylthio)
H
60242
Ethanol, 2-mercapto
H
122996
Ethanol, 2-phenoxy
H
141526
Ethanol, sodium salt
FS
64147484
Ferrate(2-), difluoro[phosphato(3-)-0]-,
sodium hydrogen
H
13746662
Ferrate(3-), hexakis(cyano-C)-,tripotassium,
(0C-6-11)
H
75127
Formamide
H
590294
Formic acid, potassium salt
H
616024
2,5-Furandione, 3-methyl
F
97994
2-Furanmethanol, tetrahydro
F
64028
Glycine, N,N1-1,2-ethanediylbis[n-
(carboxymethyl)-, tetrasodium salt
H
140012
Glycine, N,N-bis(2-(bis(carboxymethyl)
amino)ethyl)-, pentasodium salt
H
19525598
Glycine, N-phenyl-, monopotassium salt
H
10265697
Glycine, N-phenyl-, monosodium salt
H
506934
Guanidine, mononitrate
X
556887
Guanidine, nitro
X
111148
Heptanoic acid
Co
110430
2-Heptanone
F
108838
4-Heptanone, 2,6-dimethyl
F
822060
Hexane, 1,6-diisocyanato
H
143237
1,6-Hexanediamine, N-(6-aminohexyl)
H
68052493
1,6-Hexanediaminium, N,N,N',N'-
tetrabutyl-N, N'-diethyl-, bis(ethyl sulfate)
H
2432748
Hexanenltrile, 6-amino
H
0-12
-------
CAS #
Substance
Designation Criteria
136527 Hexanoic acid, 2-ethyl-, cobalt (2+) salt H
591786 2-Hexanone F
25264931 Hexene F
30951952 3-Hexene, 3,4-dimethyl F
20469710 Hydrazinecarbodithioic acid, compd, with
hydrazine (1:1) H
110214 1,2-Hydrazinenedicarboxamide H
7778667 Hypochlorous acid, potassium salt X
13253446 2,4-Imidazolidinedione, 5-[2-(methylthio)
ethyl] F
68647449 Imidazolium, l-(carboxymethyl)-4,5-dihydro-l
(or 3)-2-hydroxyethyl)-2-undecyl-, hydroxide,
monosodium salt F
4035896 Imidodicarbonic diamide, N,N',2-tris
(6-i socyanatohexy1) F
95136 lH-Indene H
496117 lH-Indene, 2,3-dihydro H
1203174 lH-Indene, 2,3-dihydro-l,1,2,3,3-pentamethyl H
85438 1,3-Isobenzofurand1one, 3a,4,7,7a-tetrahydro H
117088 1,3-Isobenzofurandione, 4,5,6,7-tetrachloro H
67874355 Isodecanediamine H
25103542 Isodecanol, hydrogen phosphorodithioate,
zinc salt H
133073 IH-Isoindole-l,3(2H)-dione, 2-((trichloro-
methyl)thio) H
85405 lH-Iso1ndole-l,3(2H)-dione, 3a,4,7,7a-
tetrahydro H
1319466 Lead, bis[(carbonato(2-)]dihydroxytri H
39390006 Lead chloride silicate H
1309600 Lead oxide (Pb02) H
12065906 Lead oxide sulfate (Pb504(S04)) H
67711868 Lead silicate sulfate (Pb2(S103)(S04)) H
7783406 Magnesium fluoride H
74975 Methane, bromochloro H
D-13
-------
CAS #
Substance
Designation Criteria
109875
Methane, dimethoxy
F
27159906
Methanesulfonamide, N-(2-(ethyl(3-methyl-
phenyl)amino)ethyl)-, sodium salt
H
75752
Methanesulfonic acid
Co
870724
Methanesulfonic acid, hydroxy-, monosodium
salt
Co
10278714
Methan imi dami de, N,N-dimethyl-N1 -(2-methyl-
phenyl)
H
18858434
Molybdenum oxide (Mo02)
H
11098843
Molybdic acid, ammonium salt
H
27546072
Molybdic acid, diammonium salt
H
6158458
Naphthalene, 1-(1-methyl ethyl)
H
90120
Naphthalene, 1-methyl
H
91576
Naphthalene, 2-methyl
H
92706
2-Naphthalenecarboxylic acid, 3-hydroxy
H
1321944
Naphthalene, methyl
H
81163
1-Naphthalenesulfonic acid, 2-amino
H
68540410
1-Naphthalenesulfonic acid, 2-amino-,
monoammonium salt
H
25417203
Naphthalenesulfonic acid, dibutyl-,
sodium salt
H
12607704
Nickel, (carbonato(2-))tetrahydroxytri
H
13473900
Nitric acid, aluminum salt
X
10022318
Nitric acid, barium salt
X
10377603
Nitric acid, magnesium salt
X
68201843
9,12-Octadecadienoic acid, 12-sulfo-, (?,Z)-
H
110305
Octadecanamide, N,N'-1,2-ethanediylbis-
H
557051
Octadecanoic acid, zinc salt
H
2717159
9-0ctadecenoic acid (Z)-, compd, with
2,2',2'' nitrilotris(ethanol) (1:1)
H
111659
Octane
F
111853
Octane, 1-chloro
H
7795951
1-Octanesulfonyl chloride
Co
40630635
1-Octanesulfonyl fluoride
Co
D-14
-------
CAS # Substance Designation Criteria
307357
l-Octanesulfonyl fluoride, 1,1,2,2,3,3,
4,4,5,5,6,6,7,7,8,8,8-helptadecafluoro-
Co
111137
2-0ctanone
F
3083258
Oxirane, (2,2,2-trichloroethyl)
2426086
Oxirane, (butoxymethyl)
F
106887
Oxirane, ethyl
F
540841
Pentane, 2,2,4-trimethyl
F
96140
Pentane, 3-methyl
F
96220
3-Pentanone
F
25167708
Pentene, 2,4,4-trimethyl
F
3404679
1-Pentene, 2-ethyl-3-methyl
F
598969
2-Pentene, 3,4,4-trimethyl
F
627203
2-Pentene, (Z)
F
123546
2,4-Pentenedione
F
592518
4-Pentenenitrile
H
25899507
2-Pentenenitrile, (Z)
H
7778747
Perchloric acid, potassium salt
X
110054
Peroxide, bis(1,1-dimethylethyl)
X
80433
Peroxide, bis(1-methyl-1-phenylethyl)
X
94360
Peroxide, dibenzoyl
X
7727211
Peroxydisulfuric acid, dlpotassium salt
X
7775271
Peroxydlsulfuric acid, disodium salt
X
7722863
Peroxymonosulfuric acid
X
1333137
Phenol, (1,1-dimethyl ethyl)-3-methyl
H
25567402
Phenol, (1,1-dimethylethyl)-4-methyl
H
27576869
Phenol, (1-methyl-1-phenylethyl)
H
88608
Phenol, 2-(1,1-dimethyl ethyl)-5-methyl
H
68527628
Phenol, 2,2'-methyleneb1s(4-(l,1,3,3-
tetramethylbutyl)-, calcium salt
H
2416946
Phenol, 2,3,6-trimethyl
H
136323
Phenol, 2,4,5-trichloro-, sodium salt
H
497392
Phenol, 2,4-bis(l,1-dimethylethyl)-5-methyl
H
50884305
Phenol, 2,4-dichloro-, potassium salt
H
D-15
-------
CAS #
Substance
Designation Criteria
137995 Phenol, 2,4-dinonyl H
95874 Phenol, 2,5-dimethyl H
128370 Phenol, 2,6-bis(1,1-dimethyl ethyl)-4-methyl H
576261 Phenol, 2,6-dimethyl H
90006 Phenol, 2-ethyl H
28983268 Phenol, 2-isononyl-4-methyl H
123079 Phenol, 4-ethyl H
19277919 Phenol, 4-ethyl-, sodium salt H
104405 Phenol, 4-nonyl H
1806264 Phenol, 4-octyl H
28987179 Phenol, nonyl-, barium salt H
26523784 Phenol, nonyl-, phosphite (3:1) H
2819865 Phenol, pentamethyl H
139026 Phenol, sodium salt H
13598362 Phosphonic acid (H303P) H
2809214 Phosphonic acid, (1-hydroxyethylidene)bis H
2781115 Phosphonic acid, ((bis(2-hydroxyethyl)amino)
methyl)-, diethyl ester H
1809194 Phosphonic acid, dibutyl ester H
2235430 Phosphonic acid, (nitrilotris(methylene))
tris-, pentasodium salt H
55566308 Phosphonium, tetrakis(hydroxymethyl)-, sulfate
(2:1) (salt) H
1497683 Phosphonuchloridothioic acid, ethyl-,
0-ethyl ester H
5075138 Phosphonochloridothioic acid, phenyl-,
0-ethyl ester H
3497005 Phosphonothioic dichloride, phenyl H
644973 Phosphonous dichloride, phenyl H
17321470 Phosphoramidothioic acid, 0,0-dimethyl ester H
33125869 Phosphoric acid, 1,2-ethanediyl tet*akis
(2-chloroethyl) ester H
1241947 Phosphoric acid, 2-ethylhexyl diphenyl ester H
D-16
-------
CAS #
Substance
Designation Criteria
68460037 Phosphoric acid, bis(2-chloro-l-
(chloromethyl)ethyl 2,3-dichloropropyl
ester H
29761215 Phosphoric acid, isodecyl diphenyl ester H
126738 Phosphoric acid tributyl ester H
78400 Phosphoric acid, triethyl ester H
115866 Phosphoric acid, triphenyl ester H
7778532 Phosphoric acid, tripotassium salt H
13598373 Phosphoric acid, zinc salt (2:1) H
7779900 Phosphoric acid, zinc salt (2:3) H
2524041 Phosphorochloridothioic acid, 0,0-diethyl ester H
10043911 Phosphorodiamidic acid H
1498517 Phosphorodichloridic acid, ethyl ester H
107562 Phosphorodithioic acid, 0,0-bis(l-methylethyl)
ester H
298066 Phosphorodithioic acid, 0,0-diethyl ester H
3338247 Phosphorodithioic acid, 0,0-diethyl ester,
sodium salt H
28631449 Phosphorodithioic acid, 0,0-diisodecyl
ester H
26999291 Phosphorodithioic acid, 0,0-diisoctyl ester H
28629665 Phosphorodithioic acid, 0,0-diisooctyl ester,
zinc salt H
26377297 Phosphorodithioic acid, 0,0-dimethyl ester,
sodium salt H
3070153 Phosphorothioic acid, 0,0-diethyl
0-[4-methylsulfinyl)phenyl]ester H
1254780 Phosphorous acid, didecyl phenyl ester H
54771301 Phosphorous acid, dinonylphenyl bis
(nonylphenyl) ester H
26544230 Phosphorous acid, isodecyl diphenyl ester H
122521 Phosphorous acid, triethyl ester H
16883833 Phthalic acid, benzyl 3-hydroxy-l-isopropyl-2,
2-dimethylpropyl ester isobutyrate H
D-17
-------
CAS # Substance Designation Criteria
H0850 Piperazine H
6531380 1,4-Piperazinediethanamine H
31295542 1,4-Piperazinediethanamine, N-(2-aminoethyl) H
140318 1-Piperazineethanamine H
1762261 Plumbane, ethyltrimethyl H
75741 Plumbane, tetramethyl H
12034309 Plumbate, disodium H
7681110 Potassium iodide H
1310618 Potassium sulfide H
463490 1,2-Propadiene F
1646759 Propanal, 2-methyl-2-(methylthio)-, oxime H
24948810 2-Propanamine, N-chloro-N-0-methylethyl) H
3327228 1-Propanaminium, 3-chloro-2-hydroxy-N,N,N-
trimethyl-, chloride H
540545 Propane, 1-chloro H
75296 Propane, 2-chloro H
1634044 Propane, 2-methoxy-2-methyl F
109557 1,3-Propanediamine, N,N-dimethyl F
3296900 1,3-Propanediol, 2,2-bis(bromomethyl) F
93141 1,2-Propanediol, 3-(2-methoxyphenoxy) F
6423434 1,2-Propanediol, dinitrate X
78671 Propanenitrile, 2,2'-azobis(2-methyl- H
19355692 Propanenitrile, 2-amino-2-methyl H
78977 Propanenitrile, 2-hydroxy- H
111944 Propanenitrile, 3,3'-iminobis- H
1738256 Propanenitrile, 3-(dimethylamino) H
126830 1-Propanesulfonic acid, 3-chloro-2-hydroxy-,
monosodium salt H
75661 2-Propanethiol, 2-methyl- H
3938952 Propanoic acid, 2,3-dimethyl-, ethyl ester F
67969817 Propanoic acid, 2-chloro-, 1-methyl-2-(2-
methylpropoxy)ethyl ester F
D-18
-------
CAS #
Substance
Designation Criteria
547648
Propanoic acid, 2-hydroxy-, methyl ester
F
97723
Propanoic acid, 2-methyl-, anhydride
Co
2935902
Propanoic acid, 3-mercapto-, methyl ester
F
105373
Propanoic acid, ethyl ester
F
554121
Propanoic acid, methyl ester
F
116370
2-Propanol, 1,1'-[(l-methylethylidene)bis
(4,1-phenyleneoxy)jbis-
H
107982
2-Propanol, 1-methoxy
F
107119
2-Propen-l-amine
H
124027
2-Propen-l-amine, N-2-propenyl
H
7398698
2-Propen-1-ami n i um,N,N-di methyl-N-2-propeny1-
chloride
H
2210255
2-Propenamide, N-(1-methyl ethyl)
H
924425
2-Propenamide, N-(hydroxymethyl)
H
590216
1-Propene, 1-chloro
H
557982
1-Propene, 2-chloro
H
103753
2H-Pyran, 2-ethoxy-3,4-dihydro
F
108894
Pyridine, 4-methyl
H
59676
3-Pyridinecarboxylic acid
Co
1333411
Pyridine, methyl
H
37439342
2(1H)-Pyridinone, 3,5,6-trichloro-,
sodium salt
H
75774
Silane, chlorotrimethyl
Co
98124
Si lane, trichlorocyclohexyl
Co
75796
Silane, trichloromethyl
Co
16871902
Silicate(2-), hexafluoro-, d1potassium
H
12650281
Silicic acid, barium salt
H
11113705
Silicic acid, chromium lead salt
H
10099760
Silicic acid, lead(2+) salt (1:1)
H
11120222
Silicic acid, lead salt
H
D-19
-------
CAS #
Substance
Designation Criteria
23606328
Silver(l+), diammine-, nitrate
X
7785231
Silver bromide
F
7782925
Sodium amide
FS
1313606
Sodium peroxide
X
7646788
Stannane, tetrachloro
Co
9056386
Starch nitrate
X
1005352
Sulfonium, (4-hydroxyphenyl)dimethy1-,
chloride
H
2551624
Sulfur fluoride (SF6), (OC-6-11)
H
13814874
Sulfuric acid, ammonium zinc salt (2:2:1)
H
64675
Sulfuric acid, diethyl ester
H
151417
Sulfuric acid, monododecyl ester
H
2235543
Sulfuric acid, monododecyl ester,
ammonium salt
H
139968
Sulfuric acid, monododecyl ester, compd, with
2,2',2''-nitrilotris(ethanol) (1:1)
H
16924008
Tantalate(2-), heptafluoro-, dipotassium
H
2691410
1,3,5,7-Tetrazocine, octahydro-1,3,5,7-
tetranitro
H
13776846
Thioantimonic acid, trisodium salt
H
5930712
Thioperoxydiphosphoric acid, tetramethyl
ester
H
77792
Thiophene, 2,5-dihydro-, 1,1-dioxide
H
126330
Thiophene, tetrahydro-, 1,1-dioxide
H
16919270
Titanate(2-), hexafluoro-, dipotassium, (OC-6-11) H
12047277
Titanate (Ti03(2-)) barium (1:1)
H
87901
1,3,5-Triazine-2,4,6(lH,3H,5H)-trione,
1,3,5-trichloro-,
H
839907
1,3,5-Triazine-2,4,6(1H,3H,5H)-trione,
1,3,5-tris(2-hydroxyethyl)
H
3047334
1,3,5-Triazine-2,4,6(lH,3H,5H)-trione,
trisodium salt
H
68568467
l,3,5-Triazine-2,4,6-triamine, tris
(methoxymethyl)tris((octadecyloxy)methyl)
H
D-20
-------
CAS #
Substance
Designation Criteria
5915413
1,3,5-Triazine-2,4-diamine, 6-chloro-N-
(1,1-dimethyl ethyl)-N'-ethyl
H
91769
1,3,5-Triazine-2,4-diamine, 6-phenyl
H
11120255
Tungstic acid, decaammonium salt
H
689112
Urea, (1-methyl propyl)
H
1746812
Urea, N'-(4-chlorophenyl)-N-methoxy-n-methyl
H
101202
Urea, N-(4-chlorophenyl)-N'-(3,4-dichlorophenyl)
H
141071
Urea, N,N'-bis(methoxymethyl)
H
68510996
Vanadic acid, (H4V6017) disodium salt
H
13718268
Vanadic acid (HV03) sodium salt
H
7440622
Vanadium
H
1314347
Vanadium oxide
H
14324551
Zinc, bis(diethylcarbamodithioato-S,S')-,
(T-4)-
H
20427581
Zinc hydroxide
H
1314983
Zinc sulfide
H
7440677
Zirconium
FS
D-21
-------
APPENDIX E
HAZARD INDEX
E-l
-------
The Hazard Index is a scoring system designed to assess the relative
potential threat to human health and to the environment of chemical substances
released to the air, water, and soil. The system consists of various rating
factors used to examine the types of hazards that may result, and to the
extent possible, the degree of hazard. Each rating factor has a defined
rating scale by which chemicals receive numerical scores based on known data.
The rating factors are combined in an equation to arrive at a single unitless
number that is used to rank a chemical relative to other chemicals processed
through the same equation.
DEVELOPMENT OF THE HAZARD INDEX
The rating of hazardous substances can be accomplished in a number of
ways and by the use of any number of criteria. However, the depth of an
analysis that can be applied is limited by the availability and quality of
data needed for each substance to arrive at a defensible rating. The primary
complications are: (1) human effects data limitations; (2) ecological impact
data limitations; and (3) uncertainty in the effects of continuous exposures
to low-level concentrations of hazardous substances. Such limitations of the
data base confine the rater to make certain choices about how the "degree of
hazard" can be described.
From a practical point of view and in consideration of the state of
knowledge concerning hazardous substances and related effects, it is better to
limit the evaluation criteria to those for which appropriate evaluation data
are available. The approach taken during this study was to select criteria
for evaluation of hazardous substances in such a way that the most important
health and environmental effects were included for consideration.
E-2
-------
Basically, five steps were followed in developing the hazard index: (1)
determine the technical criteria; (2) derive alternative equations, with and
without weighting factors; (3) establish appropriate rating scales for the
criteria; (4) test each equation on a selected list of 27 hazardous
substances; and finally (5) provide a final ranking list.
Four alternative HI equations which have been derived for rating haz-
ardous substances are summarized in Table El and are discussed in more detail
in the following sections. These alternative equations differ in logic and in
the number of potential health and environmental effects parameters consid-
ered. Included is a discussion of alternative rating scales available for
certain parameters. Finally, a brief review of related models which are cur-
rently available for rating hazardous waste sites and a summary of other
models available for rating hazardous chemicals for other purposes is pre-
sented.
Hazard Index Criteria
The criteria which have been considered to a greater or lesser extent in
development of each of the four alternative HI equations fall into four gen-
eral categories as outlined below:
A. Health Effects
o Carcinogenicity
o Mutagenicity
o Teratogenicity
o Toxicity (Human and Mammalian)
B. Welfare Effects
o Flammability
o Explosivity
o Corrosivity
o Reactivity
o Aquatic Toxicity
E-3
-------
TABLE E-l. ALTERNATIVE HI EQUATIONS AND RATING FACTORS
EQUATION 1
HI = (Carcinogenicity} + (Mutagenicity) ~ (Terattigioiclty) + (Hunan Toxicity) + (Hawaiian Toxicity)
HI = (Health Effects)
. Carcinogenicity
. Mutagenicity
. Teratogenicity
. Hunan Toxicity
. Manna) Ian Toxicity
EQUATION 2
(Welfare Effects) * (Aggravating Effects)
Flaamabfllty
Explosivity
Corrosivity
Reactivity
Persistence
BioaccuMulation
Toxic Combust ion
Products
(Mitigating Effects)
. Innocuous Trans-
foration Products
. Evaporation Potential
HI « [(Health Effects)
. Carcinogenicity
. Hunan Toxicity
. Hamalian Toxicity
EQUATION 3
x I Aggravating Health) * (Welfare Effects)]
V Flrlnn '
Factors
Bioaccumulation
Persistence
Flaanabtl ity
Explosivity
Corrosivity
Reactivity
/Aggravating/Mitigating |
' Transformation Products'
. Mitigating (Innocuous
Products)
. Aggravating
(Hazardous Products)
HI = (Health Effects)
. Carcinogenicity
. Mutagenicity
. Teratogenicity
. Toxicity
- Inhalation
- Ingestion
- Oenul
EQUATION 4
(Welfare Effects)
. Ignitability
. Reactivity
. Aquatic Toxicity
{ Environmental\ * (
1 Mobility ' *
. Volatility
. Solubility
Aggravating \
Characteristics'
Bioaccumulation
Persistence
-------
C. Aggravating Characteristics
o Persistence
o Bioaccumulation
o Toxic Combustion Products
D. Biological and Physical Transformation Characteristics
o Hydrolysis
o Photolysis
o Oxidation
o Biolysis
E. Environmental Mobility
o Volatility
o Solubility
The primary information sources which have been used for evaluating each
of these criteria for the twenty-seven selected substances have been the SANSS,
OHMTADS, and RTECS data files in the CIS data base. Details of the CIS data
base are given in Section 8. In cases where data were not available for the
twenty-seven hazardous substances, information was obtained to the extent
possible by hand searching various secondary data references.
First Alternative Equation
The first alternative equation was deliberately formulated to rank chemi-
cals entirely on major potential health effects. It is a simple additive
equation comprised of five components:
HI = (Carcinogenicity) + (Mutagenicity) + (Teratogenicity) +
(Human Toxicity) + (Mammalian Toxicity)
The rating scales for each of these components are summarized in Table E-2.
Carcinogenicity, mutagenicity, and teratogenicity are rated on a simple scale
of 0 to 3 according to the following:
E-5
-------
TABLE E-2. RATING FACTORS AND SCALES FOR FIRST ALTERNATIVE HI EQUATION
CARCINOGENICITY
MUTAGENICITY
TERATOGENICITY
TOXICITY*
(HUMAN AND MAMMALIAN)
0 = Negative
0 =
negative
0
= negative
0 = >10,000 ppm
1 = not tested/no data
1 =
not tested/no data
1
= not tested/no data
1 = 1000 - 10,000
2 = suspected/potential
2 =
suspected/potential
2
= suspected/potential
2 = 100 - 1000
3 = positive
3 =
positive
3
= positive
3 = 10 - 100
4 = <10
* The toxicity rating scale may have to be revised if a cutoff value of 500 ppm is used in the designation
step.
-------
0 = Negative correlation (animal or human)
1 = No data or not tested
2 = Suspected or potential (animal or human)
3 = Positive correlation (animal or human)
The choice of this particular rating scale is based on data reported in
the OHMTADS file and in the NIOSH RTECS toxicity file. Known or suspected
carcinogens, mutagens, and teratogens are not ranked in terms of their relative
potency for two reasons: First, it is extremely difficult to determine the
potency of these chemicals and to determine no-effect levels. Secondly, the
fact that a chemical has been classified as a suspected animal, known human, or
animal positive carcinogen, mutagen, or teratogen is often a measure of the
extent to which the chemical has been tested rather than its potency.
Alternative rating scales used in other rating systems for these same
criteria are summarized in Tables E-3 through E-5. The extent to which they
differ from the proposed rating scale is either in the relative weighting of
the scales (i.e., 0 to 3, 0 to 5, 0 to 7) or in the specific data requirements
which further define the status of testing. It is our opinion that a more
definitive rating scale is not justified at the present time because of a lack
of data.
Human and mammalian toxicity are rated as follows:
0 = >10,000 ppm
1 = 1000-10,000
2 = 100-1000
3 = 10-100
4 = <10
E-7
-------
TABLE E-3
ALTERNATIVE RATING SCALES FOR CARCINOGENICITY
1. Category
Score
Known or suspected human carcinogen
5
Known mammalian carcinogen
4
Suspected mammalian carcinogen or known
mammalian mutagen
3
Ames test positive
2
Precursor or carcinogen
1
Source: Margler, L.W., M.B. Rogozen, R.A. Zlskind, and
R. Reynolds. 1979. Rapid Screening and Identification
of Airborne Carcinogens of Greatest Concern in California.
J. Air Poll lit Control Assoc. 29(11) 7 1153-1157.
Category Score
Human positive, potential human, animal positive 7
Potential animal 3
Carcinogenic by a route other than oral or dermal, 2
strongly suspect carcinogen by accepted mutagenicity
screening tests
Suspect carcinogen by accepted mutagenicity screening tests 1
Not carcinogenic 0
Insufficient Information *
Source: Michigan Department of Natural Resources. 1979. Critical
Materials Register 1979. Publication Number 4833-5323. Lansing,
Michigan. 71 pp.
Effects Noted Score
or Status
Carcinogenic
Produces Neoplasm
Under Test
Not Tested
Negative
Source: Fuller, B., J. Hushon, M. Kornreich, R. Quelette, L. Thomas,
and P. Walker. 1976. Preliminary Scoring of Selected Organic Air
Pollutants. EPA-450/3-77-008a, PB 264 442. Mitre Corp., McLean,
Virginia. 104 pp.
E-8
5
4
3
0
0
-------
aJiiis £
TABLE E-4
ALTERNATIVE RATING SCALES FOR MUTAGENICITY
1.
Status
Score
2.
Mutagenic
Not Tested
Negative
5
0
0
Source: Fuller, B., J. Hushon, M. Kornreich, R. Quelette,
L. Thomas, and P. Walker. 1976. Preliminary Scoring of
Selected Organic Air Pollutants. EPA-450/3-77-008a, PB
264 442. Mitre Corp., McLean, Virginia. 104 pp.
Category
Score
Confi rmed 7
Potential (multicellular organisms) 4
Potential (microorganisms) 2
Mot a hereditary mutagen 0
Insufficient Information *
Source: Michigan Department of Natural Resources. 1979.
Critical Materials Register 1979. Publication Number 4833-5323.
Lansing, Michigan. 71 pp.
Criteria Score
Evidence of mutagenicity in one or more whole 9
mammalian tests
Evidence of 1n-vitro mutagenicity in more than one 6
test systerni-orHn-one test-system and interacts
specifically with gemrinal-cell DNA in vivo
Evidence of 1n-vitro mutagenicity 1n one test 4
system, but no evidence of germinal-cell DNA
interaction-!
No data, but suspect mutagen based on professional 3
judgment using such parameters as structure/
activity relationships
No data, but considered a suspect mutagen based on 1
professional judgment
Adequate ev-i*len€e-vnegat4-vfr test-results) of no 0
mutagenicity
Source: Modified from Toxic Substances Control Act - Inter
agency Testing Committee Workshop, 1979, Table 3, p. 17.
E-9
-------
umf
TABLE E-5. ALTERNATIVE RATING SCALES FOR TERATOGENICITY
1. Category Score
Confirmed 7
Potential 3
Not Teratogenic 0
Insufficient Information *
Source: Michigan Department of Natural Resources. 1979.
Critical Materials Register 1979. Publication Number 4833-5323.
Lansing, Michigan. 71 pp.
2. Status Score
Teratogenic 5
Not Tested 0
Negative 0
Source: Fuller, B., J. Hushon, M. Kornreich, R. Quelette,
L. Thomas, and P. Walker. 1976. Preliminary Scoring of
Selected Organic Air Pollutants. EPA-450/3-77-008a,
PB 264 442. Mitre Corp., McLean, Virginia. 104 pp.
3. Teratogenicity Scores for Toxic Substances Control Act -- Interagency
Testing Committee Scoring System
Category - Score
CunMfflsd teratogen ih MUmans or in two appropriate 3
animal species
Confirmed teratogen in one animal species 2
Insufficient or inadequate experimental data for definite 1
conclusions, but either (a) no experimental or structural
reason for suspicion, or (b) low biological activity
Adequately tested in two suitable animal species with 0
negative findings for teratogenic activity
Source: Federal Register (1979), p. 55073,
E-10
-------
These scales are similar to those used by Hann and Jensen (1977), the
Michigan Department of Natural Resources (State of Michigan, 1980), and Loomis
(1974). These are based on LD^q values and LD1q values. In cases where these
data were not available, the following relationships were used to estimate
values from LC-|0, LC^g, and TLV data.
Human Toxicity
Oral LD-jQ (mg/Kg) or inhalation LC-jQ (ppm) (in order of preference)
where:
-3
LD^0 - 5.85 x 10 x molecular weight (gm) x LC-]0 (ppm) (1)
Calculated LD-|0 expressed in terms of mg/Kg/day
Mammalian Toxicity (in order of preference)
Oral-rat LDg0 (mg/Kg) or
O
TLV (mg/m or ppm) where
Calculated LD^q expressed in terms of mg/Kg/day
Alternative rating scales used in other rating systems for acute toxicity
data are summarized in Table E6.
Equations (1) and (2) adopted from Handy and Schindler, 1976. Equation (3)
Dacre, et al., 1980.
LD50 =34.5 TLV (mg/m3)
(2)
Calculated LDgg expressed in terms of mg/Kg or
LC50 (mg/1) where
LD50 = LC50 fa'1) x V35
(3)
E-ll
-------
TA3LE E-6
ALTERNATIVE RATING SCALES FOR ACUTE TOXICITY DATA
LD5Q in mg/Kg
Range
Score
<
50
5
>
50 to <250
4
_>
250 to • <1000
3
J>
1000 to <5000
2
_>
5000 to <10000
1
2
10000
0
1.
LC5q in ppm
2.
Range
Score
< 100
2 100 to <200
± 200 to <1000
± 1000 to <'3000
2 3000 to <.5000
_> 5000
5
4
3
2
1
source: t-uiier, u., j. Husnon, M. Kornreich, R. quelette,
L. Thomas, and P. Walker. 1976. Preliminary Scoring of
Selected Organic Air Pollutants. EPA-450/3-77-008a, PB 264 442.
Mitre Corp., McLean, Virginia. 104 pp.
Oral LD
mg/Kg
50
Dermal LD
mg/Kg
50
Aquatic 96-H LCcn
mg/L b0
Score
5
5-50
50-500
500-5000
5000
<
>
>
>
>
5
5-200
200-500
500-5000
5000
1
1-10
10-100
100-1000
1000
Insufficient Information
7
3
2
1
0
~
Source: Michigan Department of Natural Resources. 1979. Cri
tical Materials Register 1979. Publication Number 4833-5323.
Lansing, Michigan. 71 pp.
E-12
-------
<4
TABLE E-6
ALTERNATIVE RATING SCALES FOR ACUTE TOXICITY DATA
(CONTINUED)
Hazard LD,-n
4. Description Grade
Insignificant Above 5000 0
Slight 500-5000 1
Moderate 50-500 2
High 5-50 3
Extreme Below 5 4
Source: Beckman, R.B., 1974. System for Evaluation of the Hazards of
Bulk Water TransDortation of Industrial Chemicals. National
Academy of Sciences, Washington, D.C.
E-13
-------
Table E-7 lists the possible maximum and minimum rating values for
each criterion and summarizes the maximum and minimum HI rating which a
substance can receive using this equation.
Second Alternative Equation
The second alternative equation which was developed is slightly more
sophisticated in that, in addition to potential health effects, it permits
evaluation of other adverse effects that may occur (fire, explosion, reaction)
and aggravating characteristics (persistence and bioaccumulation). In addition,
this particular equation allows evaluation of certain mitigating effects. The
basic form of the equation is additive and consists of the following simplified
terms:
/Health \ / Welfare \ /Aggravating\ /Mitigating\
HI = \ Effects / \ Effects ) \ Effects j ' \ Effects /
The individual rating factors which comprise each of the four terms are
outlined below and the rating scales are summarized in Table E-8.
Health Effects
Carcinogenicity
Mutagenicity
Teratogenicity
Human Toxicity
Mammalian Toxicity
Welfare Effects
Flammability
Explosivity
Corrosivity
Reactivity
E-14
-------
TABLE E-7
MINIMUM AND MAXIMUM POTENTIAL HI RATING/FIRST EOUATION
Rating Factor
Minimum Value
Maximum Value
Carcinogenicity
0
3
Mutagenicity
0
3
Teratogenicity
0
3
Human Toxicity
0
4
Mammalian Toxicity
0
4
TOTAL
0
17
E-15
-------
TABLE E-8
RATING FACTORS AND SCALES FOR SECOND ALTERNATIVE AI EQUATION
HEALTH EFFECTS
Carcinogenicity
Mutagenicity
Teratogenicity ( Same scales as specified in
Toxicity (Human, Mammalian) I Table E-2
WELFARE EFFECTS
1. Flammability
Based on the NFPA classification of Table E-9
2. Explosivity
0 = Nonexplosive/Unknown
4 * Explosive
3. Corrosivity
0 = Noncorrosive/Unknown
4 = Corrosive
4. Reactivity
Based on the NFPA classification of Table E-10
E-16
-------
.*pv „
/f-j M r&
TABLE E-8
RATING FACTORS AND SCALES FOR SECOND ALTERNATIVE HI EQUATION
(CONTINUED)
AGGRAVATING EFFECTS
1. Persistence
0 = Nonpersistent
1 = Unknown
2 a Persistent
2. Bioaccumulation
0 = Nonbioaccumulative
1 = Unknown
2 ¦ Bioaccumulative
3. Toxic Combustion Products
0 = None
1 3 Slight
2 * Moderate
3 s Severe
MITIGATING EFFECTS
1. Innocuous Transformation Products
0 a None
3 ¦ Positive Evidence
2. Evaporation Potential
0 * None (B.P. >100°C)
3 * BP <100°C and substance satisfies all of the following:
Nontoxic via inhalation
Nonflammable
Nonexplosive
Unreactive In Air
E-17
-------
Aggravating Effects
Persistence
Bi©accumulation
Toxic Combustion Products
Mitigating Effects
Innocuous Transformation Products
Evaporation Potential
The rating scales for the health effects criteria remain the same as for
the first equation. In the category of welfare effects, flammable substances
are rated on a simple scale of 0 to 4 based on the flammability classification
of the National Fire Protection Association (NFPA) as defined in Table E-9.
Flash point data is used as an additional rating guide for flammable liquids
in the following manner:
NFPA Level 0
NFPA Level 1 Flash Point >200°F
NFPA Level 2 Flash Point 100-200°F
NFPA Level 3 Flash Point <100°F
NFPA Level 4 Flash Point <100°F
(The distinction between Level 3 and Level 4 is that
Level 4 must have a vapor pressure >78 mm Hg.)
These flash point ranges were selected based on the Department of Transportation's
(DOT) definition of combustible and flammable materials in 49CFR173.115.
Reactivity is also assigned a value of 0 to 4 based on the classification
system of the National Fire Protection Association (NFPA) as shown in Table E-10.
For explosivity» it is difficult to rate the degree of hazard. A simple rating
of YES (4) and NO (0) is proposed, as determined from the NFPA classification
to ensure equal weighting between criteria. Similarly, the degree of corrosive-
ness for a given chemical substance cannot be determined from the data base.
A rating of YES (4) and NO (0) is proposed based on information in the OHMTADS
E-18
-------
TABLE E-9
FLAMMABILITY RATING
Assigned
Value
N.F.P.A. Level
4 Very flammable gases, very volatile
flammable liquids, and materials
that in the form of dusts or mists
readily form explosive mixtures
when dispersed in air.
3 Liquids which can be ignited under
all normal temperature conditions.
Any material that ignites spontan-
eously at normal temperatures in
air.
2 Liquids which must be moderately
heated before ignition will occur
and solids that readily give off
flammable vapors.
1 Materials that must be preheated
before ignition can occur. Most
combustible solids have a flam-
mability rating^of 1.
0 Materials that will not burn.
E-19
-------
TABLE E-10
REACTIVITY RATING
muzr
Assigned
Value N.F.P.A. Level
4 Materials which in themselves are readily capable
of detonation or of explosive decomposition or
explosive reaction at normal temperatures and
pressures. Includes materials which are sensitive
to mechanical or localized thermal shock.
3 Materials which in themselves are capable of detona-
tion or of explosive decomposition or of explosive
reaction but which require a strong initiating
source or which must be heated under confinement before
initiation. Includes materials which are sensitive
to thermal or mechanical shock at elevated tempera-
tures and pressures or which react explosively with
water without requiring heat or confinement.
2 Materials which in themselves are normally unstable
and readily undergo violent chemical change but do
not detonate. Includes materials which can undergo
chemical change with rapid release of energy at
normal temperatures and pressures or which can
undergo violent chemical change at elevated tempera-
tures and pressures. Also includes those materials
which may react violently with water or which may
form potentially explosive mixtures with water.
1 Materials which in themselves are normally stable
but which may become unstable at elevated tempera-
tures and pressures or which may react with water
with some release of energy but not violently.
0 Materials which are normally stable even under fire
exposure conditions and which are not reactive with
water.
E-20
-------
file describing possible corrosive action to materials commonly used for
packaging, or equipment that might be required at a spill site.
Aggravating characteristics such as persistence, bioaccumulation, and the
potential to form toxic combustion products are considered a necessary element
of a comprehensive hazard index. However, because there are no standardized
procedures for measuring these and the availability of data is limited, it is
difficult to estimate degrees of hazard for one chemical relative to another.
Tables E-11 and E-12 summarize some of the available rating schemes for per-
sistence and bioaccumulation.
The persistence of chemicals is often measured by half-lives. However,
degradative half-lives for many of the compounds are not available in the data
base or the literature, and serious limitations exist in the usefulness of
experimentally derived half-lives. This is because there are no standardized
test procedures, and the methods and conditions for conducting rate studies
vary widely. A rating scheme based on chemical structure has been proposed
by Abrams (1975). However, for this equation we have decided to rate the
persistence of substances on a YES/NO basis. A rating of 0 is assigned if a
substance is nonpersistent, and a rating of 1 if its persistence is unknown, and
a rating of 2 if it is known to persist.
A similar problem exists for measuring the bioaccumulation potential of
chemicals. One measure is the bioconcentration factor (BCF) which is defined
as the concentration of a chemical in an organism divided by the concentration
in water. BCF values reported in the literature vary considerably for a
single compound depending upon the surface area of the test organism, the lipid
content, and the ability of the organism to metabolize the compound. Further-
more, the laboratory data represent experiments performed on different biological
E-21
-------
TABLE E-11
ALTERNATIVE RATING SCALES FOR PERSISTENCE
Score
Category
+3
+2
+1
0
-1
-2
Infinite
Up to 1 Year
1 to 8 Weeks
Up to 1 Week
Suspected Low; No Data
Suspected High; No Data
Source:
TSCA-ITC Workshop (1979), Table 4, p. 60.
Score
Category
0
1
2
3
Easily Biodegradable
Straight Chain Hydrocarbons
Substituted and Other Ring Compounds
Metals, Polycyclic Compounds, and Halogenated
Hydrocarbons
Source: Abrams, E.F., et al. Identification of Organic
Compounds in Effluents from Industrial Sources.
EPA-560/3-75-002. April 1975.
Score
Category Half-Life in Weeks
(Soil or Water)
4
3
2
1
0
*
Very persistent >52
Persistent 40-52
Slowly degradable 27-39
Moderately degradable 14-26
Readily degradable 0-13
Insufficient Information
Source: Michigan Department of Natural Resources. 1979.
Critical Materials Register 1979. Publication Number
4833-5323. Lansing, Michigan. 71 pp.
E-22
-------
TABLE E-12
ALTERNATIVE RATING SCALE FOR BIOACCUMULATION
Score
Bioaccumulation Log P
7
3
2
1
0
*
>4000 >6.00
1000-3999 5.00-5.99
700-999 4.50-4.99
300-699 4.00-4.49
< 300 <4.00
Insufficient Information
Source: Michigan Department of Natural Resources. 1979.
Critical Materials Register 1979. Publication Number
4833-5323. Lansing, Michigan. 71 pp.
Score
Potential
+3
+2
+1
0
-1
-2
High
Appreciable
Low
Negligible
Suspected Low; No Data
Suspected High; No Data
Note:
Bioaccumulation potential based on the n-octanol/water
partition coefficient.
Source:
TSCA-ITC Workshop (1979), Table 4. p. 60.
E-23
-------
species, each with potentially different abilities to bioconcentrate the test
materials. Consequently, BCF values are of limited use for rating relative
chemical hazard unless test conditions are similar for the various compounds
being compared,
A second measure of bioaccumulation potential is based on the n-octanol/
water partition coefficient (P) which is a measure of the distribution of a
chemical between the two immiscible solvents, octanol and water. The Log P has
been found to correlate with solubility and bioconcentration (Kenaga and
Goring, 1978). Although Log P is a useful measure, experimental values are not
always available. Several methods are available for estimating Log P from
solubility, but errors in excess of 75% are common. For these reasons, we have
decided to rate the bioaccumulation potential of substances in this report on a
YES/NO basis. A substance is assigned a rating of 0 if it is known that it does
not bioaccumulate, a rating of 1 if its bioaccumulation potential is unknown and
a rating of 2 if the substance is known to bioaccumulate.
The degree of hazard for potential toxic combustion products which may be
released when a substance of concern is burned or heated to decomposition is
estimated from information in the OHMTADS file. A rating of 0 to 3
(0 = none, 1 = slight, 2 = moderate, 3 = severe) is assigned based on the
nature of the toxic combustion products generated and the severity of the
inhalation toxicity of such products.
Finally, it was felt that if certain mitigating characteristics of the
hazardous substances could be assessed, then these should serve to reduce the
overall hazard index score. Such mitigating characteristics are defined as
transformation by physical, chemical, or biological processes into innocuous
products, or evaporation of a substance into a nontoxic, nonflammable, non-
explosive and unreactive vapor.
E-24
-------
Table E-13 lists the possible maximum and minimum rating values for each
criterion and summarizes the maximum and minimum HI rating which a substance
can receive using the second HI equation. The maximum HI rating would be 40,
the sum of the health effects, welfare effects, and aggravating effects terms.
This value could be reduced if there were appropriate mitigating factors involved.
In combination with the rating of hazardous substances according to the
specific criteria already discussed, weighting factors can be applied to each of
the criteria to denote the relative importance of each in the final hazard index
score. Table E-14 lists weighting factors which were assigned to the various
rating factors included in the second equation. The comparison of results
(with and without the weighting factors) can be found in Table E-20. It is
apparent from these results that the rater must be very careful in his assign-
ment of weighting factors so as not to overrate certain criteria, in this case
toxicity, and therefore, swamp out the measurement of other important criteria,
(i.e., welfare effects).
Third Alternative Equation
The third alternative equation is an extension of the second. It is com-
prised of essentially the same rating factors; however, the mathematical logic
is different. Rather than being strictly additive, it incorporates multi-
plicative arrangements to arrive at a final rating. This third equation has
the following form:
HI
/ Health \ / Aggravating \ /welfare \ /Aggravating/Mitigating \
\Effects/ x ( Health I + \Effects/ x (Transformation Properties/
\ Factors / J
The individual rating factors which comprise each of the terms are outlined
below.
E-25
-------
TABLE E-13. MINIMUM AND MAXIMUM POTENTIAL HI RATINGS/SECOND EQUATION
Rating Factor Minimum Value Maximum Value
1. Health Effects
Carcinogenicity 0 3
Mutagenicity 0 3
Teratogenicity 0 3
Human Toxicity 0 4
Mammalian Toxicity _0_ 4
TOTAL 0 17
2. Welfare Effects
Flammability 0 4
Explosivity 0 4
Corrosivity 0 4
Reactivity _0_ 4
TOTAL 0 16
3. Aggravating Effects
Persistence 0 2
Bioaccumulation 0 2
Toxic Combustion Prod. 0 3
TOTAL Q L
GRAND TOTAL 0 40
4. Mitigating Effects
Innocuous Transfor- 0 3
mation Products
Evaporation 0 3
TOTAL 0 6
E-26
-------
TABLE E-14. SUMMARY OF WEIGHTING FACTORS APPLIED
TO THE SECOND ALTERNATIVE HI EQUATION
Min
Weighting
Max Factor Min
Max
Human Health Effects
Carcinogenicity
0
3
X
6
S
0
18
Mutagenicity
0
3
X
6
S
0
18
Teratogenicity
0
3
X
6
a
0
18
Human Toxicity
0
4
X
12
3
0
48
(LD or TLV or LC)
Mammalian Toxicity
0
4
X
6
S
0
24
TOTAL
0
126
Welfare Effects
Flammability
0
4
X
1
S
0
4
Explosiveness
0
4
X
1
=
0
4
Corrosiveness
0
4
X
1
s
0
4
Reactivity
0
4
X
1
s
0
4
TOTAL
0
16
Aggravating Effects
Persistence
0
2
X
3
0
6
Bioaccumulation Potential
0
2
X
3
s
0
6
Toxic Combustion Products
0
3
X
3
38
0_
9
TOTAL
n
?l
GRAND TOTAL
0
163
Mitigating Effects
Innocuous Transformation
0
3
X
2
c
0
6
Products
Evaporation Potential
0
3
X
1
*
0
3
TOTAL
0
3
E-27
-------
Health Effects
Carcinogenicity
Human Toxicity
Mammalian Toxicity
The rating scores for each of the health effects factors are summed.
Aggravating Health Factors
Bioaccumulation
Persistence
The rating scores for bioaccumulation and persistence are multiplied together.
Welfare Effects
Flammability
Explosivity
Corrosivity
Reactivity
The rating scores for each of the welfare effects factors are summed.
Aggravating/Mitigating Transformation Properties
Mitigating (Innocuous Products)
Aggravating (Hazardous Products)
The major changes reflected in this third alternative are the following:
1. Bioaccumulation and persistence, both of which are aggravating
characteristics related primarily to health effects, are
multiplied against the sum of the rating values for health
effects.
2. Transformation of a substance by physical, chemical, or bio-
logical processes can result in either mitigating or
aggravating products for Health Effects as well as Welfare
Effects. The rating score for transformation is therefore
multiplied against the sum of both these terms.
E-28
-------
Table E-15 presents modified rating scales for bioaccumulation, persistence,
and mitigating and aggravating transformation properties only. The rating scales
for all other factors remain the same as previously defined. The choice in
rating values for bioaccumulation, persistence, and mitigating and aggravating
transformation properties was made to accommodate the multiplicative arrangement
of terms. A rating value of 1 is assigned if the potential for bioaccumulation
and persistence is negative or unknown and if the aggravating or mitigating
transformation properties of a substance have no effect or are unknown. A rating
value of 0 in this case would wipe out the other terms in the equation. A
rating of 1.5 is assigned for positive evidence of bioaccumulation, 1.25 for
positive evidence of persistence, 0.5 for mitigating transformation properties,
and 1.5 for aggravating transformation properties. These particular values were
selected as multipliers so as not to overemphasize the effects they are measuring
relative to the other rating factors in the equation. Table E-16 presents the
minimum and maximum HI ratings which can be obtained with the third algorithm.
Fourth Alternative Equation
The fourth alternative equation is similar in concept to the second in
that it evaluates major health effects (carcinogenicity, mutagenicity, tera-
togenicity), welfare effects (ignitability, reactivity) and aggravating
characteristics, in an additive manner. It differs, however, in the following:
1. It does not consider mitigating characteristics such as innocuous
transformation products.
2. It Incorproates media specific toxicity measurements for air
(inhalation toxicity) and water (ingestion toxicity), as well
as toxicity via direct contact (dermal toxicity).
3. The rating scale for persistence is based on a chemical structure/
classification scheme proposed by Abrams, et al. (See Table E-ll.)
E-29
-------
AGGRAVATING HEALTH FACTORS
TABLE E-15
1. Bioaccumulation
1,0 s Unknown or None
1.5= Positive
2. Persistence
1.0 = Unknown or None
1.25 = Positive
AGGRAVATING/MITIGATING TRANSFORMATION PROPERTIES
1. Mitigating (innocuous products) « 0.5
2. No Effect/Unknown ¦ 1.0
3. Aggravating (Hazardous Products) = 1.5
E-30
-------
TABLE E-16
MINIMUM AND MAXIMUM POTENTIAL HI RATINGS/THIRD EQUATION
Rating Factor Minimum Value Maximum Value
1. Health Effects
Carcinogenicity 0 3
Human Toxicity 0 4
Mammalian Toxicity 0 4
TOTAL 0 11
2. Aggravating Health Factors
Bioaccumulation 1 1.50
Persistence _J__ 1.25
TOTAL 1 1.875
3. Welfare Effects
4-
4
4
4
Subtotal 0 36.62
t
4. Aggravating/Mitigating Transformation Properties
Mitigating — 0.5
No Effect/Unknown — 1.0
Aggravating — 1.5
GRAND TOTAL 0 55
Flammability 0
Explosivity 0
Corrosivity 0
Reactivity _0_
total o
E-31
-------
4. In the category of welfare effects, specific ratings for explosivity
and corrosivity have been deleted and are included in the definitions
of ignitability and reactivity, which are based on the NFPA scheme.
5. The concept of environmental mobility has been introduced using
solubility and volatility as criteria.
6. Aquatic toxicity is included in the general welfare category because
it is a measure of lethal effects on specified freshwater and marine
fauna resources.
The form of the fourth equation is as follows:
/Health \ /-Welfare \ /Environmental^ / Aggravating \
HI = \ Effects/ + \ Effects / + \ Mobility / + \Characteristics/
The individual rating factors which comprise each of the four terms
are outlined below.
Health Effects
o Carcinogenicity
o Mutagenicity
o Teratogenicity
o Inhalation Toxicity (human or mammal i an—LC-|0, LC^q)
o Ingestion Toxicity (human or mammalian—LD^Q, LD^q)
o Dermal Toxicity (human or mammalian—LD^)
Welfare Effects
o Ignitability
o Reactivity
o Aquatic Toxicity
Environmental Mobility
o Volatility
o Solubility
E-32
-------
Aggravating Characteristics
o Bioaccumulation
o Persistence
The rating scales for each of these components are summarized in Tables
E-17 through E-18.
This fourth equation also departs from the previous three hazard index
formulas in that any available data regarding mammalian toxicity was considered
pertinent. If human or rat toxicity data was unavailable, mouse, rabbit, or
guinea pig toxicity information was used. This departure avoids reliance on
sometimes scarce human toxicity data.
Inhalation toxicity values are scaled as before, where parts per million
represents the concentration in the air. Ingestion and dermal toxicity values
are also scaled as before, where parts per million represents mg of dose per
Kg of animal weight. Carbon disulfide and trinitrotoluene are both known to
enter the body via skin absorption. Since skin toxicity data was not available
for these two compounds, subcutaneous toxicity data was utilized. Table E-19
presents a matrix of the unavailable toxicity data as it pertains to Equation 4.
Table E-20 presents for each of the 27 test substances (arranged alpha-
betically) the HI values calculated using each of the alternative equations.
Column I lists the values obtained from the first equation. Column Ila lists
the values obtained from the second, without using weighting factors, and
Column lib lists the values obtained from the second using various weighting
factors. Columns III and IV list the HI values obtained from the third and
fourth alternative equations respectively. The larger the HI value, the more
hazardous a substance is.
For the purpose of comparison, Table E-21 presents the relative rankings
of the 27 hazardous substances according to the alternative equations, using
E-33
-------
TABLE E-17
RATING SCALES FOR FOURTH ALTERNATIVE HI EQUATION
HEALTH EFFECTS
Carcinogenicity
Mutagenicity Same rating scales as in Table E-2.
Teratogenicity
Toxicity (Inhalation, Ingestion, Dermal)
WELFARE EFFECTS
Ignitability (Same as Table E-9)
Reactivity (Same as Table E-10)
Aquatic Toxicity (Same as Table E-2)
E-34
-------
TABLE E-18
if
ENVIRONMENTAL MOBILITY
Volatility
Vapor Pressure (1st Choice)
Boilinq Point (2nd Choice)
0
VP <0.1 mm Hg
B.P. > 200°C
1
VP 0.1 - 25 mm Hg
B.P. W0-200°C
2
VP 25 - 78 mm Hg
B.P. 25-100°C
3
VP ' > 78 ran Hg
B.P. < 25°C
Solubility CRC Handbook Code (1st Choice)
0 * Insoluble I .
1 • Slightly Soluble S/S1
2 - Soluble S
3 a Very Soluble V
Infinitely Soluble
Solubility Data (2nd Choice)
100 mg/1
100-1000 mg/1
1000-10,000 mg/1
10,000 mg/1
AGGRAVATING CHARACTERISTICS
Bioaccumulation
0 » Nonbioaccumlative
1 * Unknown
2 « Bioaccumulative
Persistence*
0 ¦ Easily Biodegradable
1 * Straight Chain Hydrocarbons
2 3 Substituted and Other Ring Compounds
3 s Metals, Polycyclic Compounds, and Halogenated Hydrocarbons
~Source: Abrams, E.F., et a!., Identification of Organic Compounds
in Effluents from Industrial Sources, EPA-560/3-75-002,
April, 1976.
E-35
-------
TABLE E-19
UNAVAILABLE MAMMALIAN TOXICITY DATA PER ROUTE OF ENTRY
FOR EQUATION 4
Inhalation
Ingestion
Dermal
Toxicity
Toxicity
Toxicity
Acetyl Bromide
X
X
X
.Acetylene
X
X
Acrolein
Acrylonitrile
Ammonium Bichromate
X
X
Benzene
Benzidine
X
X
Benzo(a)pyrene
X
X
X
Bis(2-ethylhexyl)phthalate
X
Carbon Oisulfide
Carbon Tetrachloride
Chloroform
X
DDT
X
Heptachlor Epoxide
X
X
Methyl Chloride
X
Nitric Acid
X
N-Nitrosodimethylamine
X
PCB's
X
Phenol
X
Phosgene
X
Phosphorus (White)
X
X
Potassium Permanganate
X
X
Sodium Amide
X
X
X
Sodium Dichromate
X
2,4,6-TNT
X
Vinyl Chloride
X
Vinylidene Chloride
X
NOTE: X denotes unavailable data
E-36
-------
TABLE E-20
HAZARD INDEX SCORES DETERMINED FROM THE ALTERNATIVE EQUATIONS
I
I la
lib
III
IV
Acetyl Bromide
3
24
49
26
14
Acetylene
3
14
29
18
16
Acrolein
10
25
109
28
27
Acrylonitrile
8
23
69
26
30
Ammonium Bichromate
7
16
61
17
20
Benzene
7
18
63
20
18
Benzidine
9
13
74
10
18
Benzo(a)pyrene
7
9
48
3
12
Bis(2-ethylhexyl)phthalate
7
8
44
2
16
Carbon Disulfide
11
26
105
27
29
Carbon Tetrachloride
9
22
93
26
26
Chloroform
11
24
105
29
24
DDT
8
15
79
18
19
Heptachlor Epoxide
9
11
60
6
13
Methyl Chloride
4
21
47
24
17
Nitric Acid
8
18
74
21
20
N-Nitrosodiroethylamine
12
19
121
12
18
PCB's
5
14
58
10
14
Phenol
6
18
68
18
18
Phosgene
8
19
79
20
14
Phosphorus (White)
11
31
122
41
20
Potassium Permanganate
4
10
30
12
16
Sodium Amide
3
18
35
28
9
Sodium Dichromate
9
17
74
20
22
2,4,6-TNT
2
14
32
15
12
Vinyl Chloride
8
23
67
26
26
Vinylidene Chloride
8
20
66
21
23
RANGE OF VALUES
Low
2
8
29
2
9
High
12
31
122
41
30
E-37
-------
TABLE E-21
RELATIVE RANKINGS OF HAZARDOUS SUBSTANCES
Hazardous Substance
I
Ha
lib
III
IV
Acetyl Bromide
24
4
20
6
21
Acetylene
24
20
27
16
18
Acrolein
5
3
3
3
3
Acrylonitrile
10
6
12
6
1
Ammonium Bichromate
16
18
17
19
9
Benzene
16
13
16
13
13
Benzidine
6
23
9
23
13
Benzo(a)pyrene
16
26
21
26
25
Bis(2-ethylhexyl)phthalate
16
27
23
27
18
Carbon Disulfide
2
2
4
5
2
Carbon Tetrachloride
6
8
6
6
4
Chloroform
2
4
4
2
6
DDT
10
19
7
16
12
Heptachlor Epoxide
6
24
18
25
24
Methyl Chloride
22
9
22
10
17
Nitric Acid
10
13
9
11
9
N-Ni trosodimethy1 ami ne
1
11
2
21
13
PCB's
21
20
19
23
21
Phenol
20
13
13
16
13
Phosgene
10
11
7
13
21
Phosphorus (White)
2
1
1
1
9
Potassium Permanganate
22
25
26
21
18
Sodium Amide
24
13
24
3
27
Sodium Dichromate
6
17
9
13
8
2,4,6-TNT
27
20
25
20
25
Vinyl Chloride
10
6
14
6
4
Vinylidene Chloride
10
10
15
11
7
E-38
-------
the same column assignments. The substances are ranked from 1 (most hazardous)
to 27 (least hazardous) in the following manner.
For each equation, the substance with the highest HI value is taken to be
the most hazardous and therefore is assigned a relative rank of 1. The substance
with the next highest HI value is assigned a relative rank of 2, and so on. If
two or more substances share the same HI value, then each receives an identical
ranking. In such cases the next relative rank assigned will be equal to the
last relative rank assigned, plus the number of identical rankings. The
following from Equation 1 should serve as an example.
Hazardous Substance
HI Value
Relative Rank
N-Nitrosodimethylamine
12
1
Carbon Disulfide
11
2
Chloroform
11
2
Phosphorus (White)
n
2
Acrolein
10
5
Figure E-l presents graphically the range and the variance in the relative
rankings for each hazardous substance. The equation from which each data point
was taken is denoted. The range of differences in the relative rankings
obtained by the various alternative equations can be quite large. However, in
several cases, the relative rankings fall fairly close together (i.e., acrolein,
benzene, carbon disulfide, carbon tetrachloride, chloroform, nitric acid,
and PCB's). It is clear from this figure that the relative ranking of chemicals
depends very much on the number of selected criteria and the emphasis placed on
these criteria in each equation.
E-39
-------
FIGURE E-l. VARIANCE IN THE RELATIVE RANKINGS OF SELECTED HAZARDOUS SUBSTANCES
79
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Finally, Table E-22 denotes the various data which were unavailable for
rating the selected 27 hazardous substances.
Certain conclusions about the hazard index system in general can be made:
1. The hazard index does not measure degree of hazard where data are
missing. For this reason it relies on what is known about a
substance.
2. Because of limitations in the available data base, the hazard index
does not measure chronic toxicity. This is most apparent in the
rating results obtained for PCB's.
3. In addition, the hazard index does not measure difficulty of cleanup
(i.e., PCB's again), nor the public perception of hazard, exposure,
and distribution, or other considerations that may be pertinent in
specific spill or exposure situations.
REVIEW OF OTHER AVAILABLE MODELS
Several models have been developed for rating the relative potential
hazard to public health and the environment posed by releases of hazardous
substances as well as for hazardous waste disposal facilities. The charac-
teristics of these models and their relevance to development of a hazard index
for assignment of Reportable Quantities are outlined in the following sec-
tions. Aspects of these systems which were used in the development of the
four alternative equations presented in this report will be indicated.
Models for Rating Hazardous Waste Facilities
A number of models have been developed to evaluate and rank the hazard
»
potential of specific waste disposal sites and uncontrolled hazardous waste
facilities, for the purpose of determining remedial action priorities. These
include the LeGrand (1980a, b) model, the Rating Methodology Model (Kufs,
1980), and the Site Ranking Model (S. Chang, et al., 1981).
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TABLE E-22
SUMMARY OF UNAVAILABLE DATA
r - —
CARCINOGENICITY
MUTAGENICITY
TERATOGENICITY
HUMAN TOXICITY
i
MAMMALIAN TOXICITY
IGNITABILITY
EXPLOSIVENESS
jcORROSIVENESS
REACTIVITY
TRANSFORMATION
PROPERTIES
Acetyl Bromide
X
X
X
X
X
Acetylene
X
X
X
X
X
Acrolein
X
«
Acrylonitrile
X
X
Ammonium Bichromate
X
X
X
X
Benzene
X
Benzidine
X
X
X
X
Benzo(a)pyrene
X
X
X
X
X
X
X
Bis(2-ethylhexyl)phthalate
X
X
X
Carbon Disulfide
X
Carbon Tetrachloride
Chloroform
X
DDT
X
Heptachlor Epoxide
X
X
X
X
X
X
X
Methyl Chloride
X
X
X
X
Nitric Acid
X
X
X
N-Nitrosodimethylamine
X
X
X
X
X
PCB's
X
X
X
X
Phenol
X
X
Phosgene
X
X
X
Phosphorus (White)
X
X
X
Potassium Permanganate
X
X
X
X
Sodium Amide
X
X
X
X
X
Sodium Dichromate
X
X
2,4,6-TNT
x"
X
Vinyl Chloride
X
X
X
Vinylidene Chloride
X
X
X
NOTE: X denotes unavailable data E-42
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The LeGrand Model describes the potential for groundwater contamination
(primarily wells). The Rating Methodology Model addresses both ground and
surface water contamination. The Site Ranking Model, which is an extension of
the Rating Methodology Model, is the most advanced and comprehensive of these.
It is designed to address five routes of contamination: ground water, surface
water, air, fire and explosion, and direct contact.
Application of each of these models requires, to a lesser or greater
extent, knowledge of site specific physical attributes data used to estimate
the relative potential hazard of a facility. Data requirements include:
Horizontal distance between the waste and the nearest ground
well
Depth of the water table below the waste
Ground water use
Water flow gradients
Permeability of the unsaturated zone
Soil type
Net precipitation
Transmissivity of the aquifler
Surface water use
Land use/zoning
Distance to the nearest population
Critical environments
Site slope
Flood potential
Ignition sources
Distance to nearest buildings
Waste management designs and procedures
Total waste quantity
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Evidence of releases
Measured levels of contamination
The final rating obtained in both the Rating Methodology Model and
the Site Ranking Methodology reflects to some extent the intrinsic potential
hazard of the wastes present at each site. Wastes are characterized for
toxicity, persistence, ignitabi1ity, reactivity, and volatility. The toxicity
rating system is oversimplified and represents the most serious flaw. It is
based only on Hazardous Properties of Industrial Materials (Sax) and the
National Fire Protection Associations Guide on Hazardous Materials.
Summary of Other Available Chemical Rating Systems—
The concept of ranking and screening chemicals based on their potential
health and environmental risk has been the subject of several reports and
papers. Each of these differs in purpose, selection of criteria, and form of
the rating system. It is not the intent to review each of these here but
rather to summarize the available references. The first of these,
Chemical Scoring System Development (Ross and Lu, 1981} represents work
performed for the Assessment Division of the EPA Office of Pesticides and
Toxic Substances, which is responsible for the first phases of evaluating
chemicals under the Toxic Substances Control Act (TSCA). In addition to
proposing a scoring system, this report reviews in some detail the other 16
rating systems referenced at the end of this section. Certain aspects of
these systems were considered in the development of the four alternative
algorithms presented in this report. For the most part, however, these other
models were either too limited in scope for our purposes, did not provide
sufficient procedural detail, or incorporated subjective judgment in
differing degrees.
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BIBLIOGRAPHY OF EXISTING RATING SYSTEMS
Astill, B. D., H. B. Lockhart, Jr., J. B. Moses, A.N.M. Nasr, R. L. Raleigh,
and C. J. Terhaar, 1980: Sequential Testing for Chemical Risk Assessment.
Paper presented at the Second International Congress on Toxicology, Brussels,
Belgium, July6-11 , 1980. 38 pp.
Becker, D. S., 1978: Algorithmic Ranking of Consumer Chemicals by Health
Hazard: Prepared for U.S. Consumer Product Safety Commission. ITT Research
Institute, Chicago, Illinois. 35 pp.
Beckmann, R. B., 1974; System for Evaluation of the Hazards of Bulk Water
Transportion of Industrial Chemicals: National Academy of Sciences, Washington,
D.C. 42 pp.
Cramer, G. M., R. A. Ford, and R. L. Hall; 1978; Estimation of Toxic Hazard—
A Decision Tree Approach: Food Cosmet., Toxicol. 16:255276.
Fuller, B., J. Hushon, M. Kornreich, R. Quelette, L. Thomas, and P. Walker.
1976. Preliminary Scoring of Selected Organic Air Pollutants. EPA450/ 3-77-
008a, PB 264 442. Mitre Corp., McLean, VA 104 pp.
Gori, G. B. 1977. Ranking of Environmental Contaminants for Bioassay Prior-
ity. In: Air Pollution and Cancer in Man. U. Mohr, D. Schmahl, L. Tomatis,
and W. Davis, eds. IARC Publication No. 16. International Agency for
Research on Cancer, Lyon, pp. 99111.
Griesemer, R. A., and C. Cueto, Jr. 1980. Toward a Classification Scheme for
Degrees of Experimental Evidence for the Carcinogenicity of Chemicals for
Animals. In: Molecular and Cellular Aspect of Carcinogen Screening Tests.
R. Montesano, H. Bartsch, and L. Tomatis, eds. IARC Scientific Publication
No. 27. International Agency for Research on Cancer, Lyon, France, pp. 259-
281.
Margler, L. W., M, B. Rogozen, R. A. Ziskind, and R. Reynolds. 1979. Rapid
Screening and Identification of Airborne Carcinogens of Greatest Concern in
California. J. Air Pollut. Control Assoc. 29(11):11531157.
Michigan Department of Natural Resources. 1979. Critical Materials Register
1979. Publication Number 4833-5323. Lansing, MI. 71 pp.
Nees, P.O. 1979. Assessment on Oncogenic Potential—A Scoring Matrix to
Determine Oncogenic Potential Proposed for Application in Risk Assessment.
In: Toxic Substances Control. Vol. 3, Implementing the Regulatory Program.
M.L. Miller, ed. Government Institutes, Inc., Washington, DC, pp. 168-182.
Ross, R.H. and J. Welch. 1980. Proceedings of the EPA Workshop on the
Environmental Scoring of Chemicals. EPA-560/11-80-010. ORNL/EIS-158. Oak
Ridge National Laboratory, Oak Ridge, TN. 38 pp.
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Stanford Research Institute. 1978. Systems for Rapid Ranking of Environ-
mental Pollutants. EFA-600/5-78-012. Menlo Park, CA. 294 pp.
Stepheneson, M.E. 1977. An Approach to the Identification of Organic Com-
pounds Hazardous to the Environment and Human Health. Ecotoxicol. Environ.
Safety 1:39-48.
Toxic Substances Control Act Interagency Testing Committee. 1977. Initial
Report to the Administrator, U.S. Environmental Protection Agency. Fed.
Regist. 42(197):550 6-55080.
U.S. Environmental Protection Agency. 1979. Conceptual Development of an
Action Alert System for Priority Pollutants (Draft). Washington, DC, 96 pp.
Venezian, Emilio C. 1977. Prescreening for Environmental Hazards—A System
for Selecting and Prioritizing Chemicals. EPA-560/1-77-002. NTIS PB 267 093.
Arthur D. Little, Inc., Cambridge, MA. 117 pp.
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REFERENCES
Chang, S., K. Barrett, S. Haus, and A. Piatt, 1981; Site Ranking Model for
Determining Remedial Action Priorities Among Uncontrolled Hazardous Substances
Facilities: The Mitre Corporation.
Cleland, J. G. & Kingsbury, J. L., 1977; Multimedia Environmental Goals for
Environmental Assessment, Vol. 1: U.S. EPA Report No. 600/7-77-136a.
Dacre, J. C., Rosenblatt, D. H., and Cogley, D. R., 1980; Preliminary Pollu-
tant Limit Values for Human Health Effects: Environmental Science & Technol-
ogy, Vol. 14, No. 7, pp. 778-788.
Doll R. and R. Peto, The Causes of Cancer: Quantitative Estimates of Avoid-
able Risks of Cancer in the United States Today: J. National Cancer Institute
1981, summarized in Chemical & Engineering News, August 17, 1981, pp. 32-34.
Handy, R. and Schindler, A., 1976; Estimation of Permissible Concentrations of
Pollutants for Continuous Exposure: EPA Report No. 600/12-76-155, p. 61.
Hann and Jensen, 1977; Water Quality Characteristics of Hazardous Materials:
Texas A & M University.
Institute of Medicine, 1981; Costs of Environment-Related Health Effects: A
Plan for Continuing Study; National Academy Press, Washington D.C., p. 9.
Kanaga, E. E. & Goring, C.A.I., 1978; Relationship Between Water Solubility,
Soil Sorption, Octanol-Water Partitioning & Bioconcentration of Chemicals in
Biota: American Society of Testing Materials, 3rd Aquatic Toxicology Sympo-
sium, New Orleans, Louisiana.
Karickoff, S. W., Brown, D. S., & Scott, T. A., 1978; Sorption of Hydrophobic
Pollutants on Natural Sediments: EPA Internal Report, Environmental Research
Laboratory, Athens, Georgia.
Kufs, C., et al., 1980, Methodology for Rating the Hazard Potential of
Waste Disposal Sites: JRB Associates, Inc., May 5.
LeGrand, H. E., and H. S. Brown, 1980, Evaluation of Ground Water Contamina-
tion Potential from Waste Disposal Sources.
LeGrand, H. E., 1980; A Standardized System for Evaluating Waste Disposal
Sites, National Well Water Association.
Leo, A., Hansch, C., and El kins, D.f 1971; Partition Coefficients and Their
Uses: Chemical Reviews, Vol. 71, No. 6, pp. 525-555.
Loomis, T., 1974; Essentials of Toxicology; Lea & Febiger, Philadelphia.
Murphy, S. D., 1978; Toxicological Dynamics: In: Dynamics, Exposure and
Hazard Assessment of Toxic Chemicals: R. Hague, editor. Ann Arbor Science
Publishers, Ann Arbor, Michigan, 496 pp.
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National Fire Protection Association (NFPA), National Fire Codes, Vol. 13,
No. 49, 1977.
Reif, A. E., 1981; The Causes of Cancer: American Scientist, Vol. 69, 438-
447.
Ross, Robert H., and Paul Lu, 1981; Chemical Scoring System Development: U.S.
Environmental Protection Agency, Chemical Scoring System Development (Draft)
Washington, D.C., Interagency Agreement No. 790X0856.
Sax, N. I., Dangerous Properties of Industrial Materials, 5th Ed., 1979.
State of Michigan Department of Natural Resources; 1980; Critical Materials
Register. Environmental Protection Bureau. Pub. 48335324.
Stoll, D. R., 1970; 4th Symposium on Loss Prevention, Vol. 4, p. 16.
U.S. Coast Guard, 1973; Evaluation of the Hazard of Bulk Water Transportation
of Industrial Chemicals; Report No. AD 775756.
Walsh, P. J., Killough, G. G., 4 Rohwer, P. S., 1978; Composite Hazard Index
for Assessing Limiting Exposures to Environmental Pollutants: Formulations
and Derivation: Environmental Science 4 Technology, Vol. 12, No. 7, pp. 799-
807.
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