Monthly US EPA RCRA / Superfund Hotline Report for January 2000

Hotline Questions and Answers

RCRA

1. Retroactivity of Land Disposal Restrictions (LDR) Recordkeeping Requirements


Under the RCRA land disposal restrictions (LDR), generators are
required to retain a copy of all notices, certifications, waste analysis
data, and other documentation produced pursuant to the LDR requirements
(40 CFR Section 268.7(a)(8)). The Phase IV LDR final rule changed the
required record retention time for such documents from five years to
three years (62 FR 26004; May 12, 1997). Does this new three-year
recordkeeping requirement apply retroactively, such that LDR records
generated during the period of the five-year record retention must only
be retained for three years?


EPA intended for the new recordkeeping requirement to apply
retroactively. Records generated during the five-year record retention
period only need to be retained for three years as of August 11, 1997,
the effective date of the record retention portion of the LDR Phase IV
rule. Thus, if a facility began retaining records pursuant to LDR
requirements on August 11, 1994, the facility would have fulfilled the
record retention requirement on August 11, 1997. If a facility began
retaining LDR records on August 11, 1996, the facility would be required
to retain those records for two years after the effective date of the
Phase IV rule, and would fulfill the record retention requirement on
August 11, 1999 (Section 268.7(a)(8)). The rule changed the record
retention period in Section 268.7(a)(8) in order to make the
requirements more consistent with other RCRA recordkeeping requirements,
specifically the record retention requirements for the manifest system
in Section 262.40(a) (62 FR 26004, 26021; May 12, 1997).


UST


2. UST Financial Responsibility Commonly Asked Questions


Must financial responsibility be demonstrated on an owner and operator
basis or on a facility basis?


Financial responsibility must be demonstrated on an owner and operator
basis. Any person who owns or operates petroleum underground storage
tanks (USTs) must demonstrate financial responsibility in accordance
with 40 CFR Part 280, Subpart H. However, financial responsibility need
only be demonstrated once per owner or operator, not for each facility
owned. The number of facilities under one owner or operator is
important only in determining the extent of financial responsibility
required for annual aggregate coverage. Owners and operators should
contact their state UST regulatory agency, as states may require
additional coverage for in-state tanks.


What constitutes an occurrence?


The term �occurrence� is defined in Section 280.92 as an �accident,
including continuous or repeated exposure to conditions, which results
in a release from an underground storage tank.� EPA notes in Section
280.92 that this definition is not intended to limit the meaning of the
term �occurrence� in a way that conflicts with standard insurance
industry usage. EPA further clarifies that, consistent with the
insurance industry�s use of the term, an occurrence does not have to
relate to a release from a single tank, but that one occurrence can be
associated with multiple tank releases discovered during an
investigation (Letter; Ng to Naylor, October 15, 1990, FR-1).


What is annual throughput?


Annual throughput is the total amount of product removed or dispensed
from USTs at a facility over the course of the previous calendar year.
Annual throughput is a factor used in determining annual aggregate
coverage for non-marketers.


What mechanisms can I use to demonstrate financial responsibility?


Owners and operators can use a variety of mechanisms to demonstrate
financial responsibility. Allowable mechanisms may include: financial
test of self-insurance, guarantee, insurance or risk retention group
coverage, surety bond, letter of credit, trust fund, or state fund. The
allowable mechanisms are listed in Sections 280.95 through 280.107.


Can I combine financial responsibility mechanisms?


Owners and operators may use any one or combination of the mechanisms
listed in Sections 280.95 through 280.107. If an owner or operator uses
separate mechanisms or combinations of mechanisms to demonstrate
financial responsibility for different petroleum USTs, the annual
aggregate must be based on the number of tanks covered by each separate
mechanism or combination of mechanisms.



NEW PUBLICATIONS


How to order...


NTIS Publications are available by calling (800) 553-6847 or (703)
605-6000, or writing NTIS, 5285 Port Royal Road, Springfield, VA
22161. Use the NTIS Order Number listed under the document.


EPA Publications are available through the Hotline. Use the EPA Order
Number listed under the document.


RCRA, Superfund, and EPCRA National Toll-Free No.: (800) 424-9346
Local: (703) 412-9810 TDD National Toll-Free No.: (800) 553-7672


EPA's Fax-on-Demand service distributes selected publications noted by a
"Fax-on-Demand" number. To order these documents, from your fax machine
dial (202) 651-2060 (for OSW documents), (202) 651-2098 (for OUST
documents), (202) 651-2061 (for CEPPO documents), and (202) 651-2062
(for OERR documents), and follow the instructions provided by the voice
prompt, using the Fax-on-Demand number noted. Please call the Hotline
for detailed instructions on using the Fax-on-Demand service.


EPA Publications Available on the Internet
You may access certain documents electronically by using this server:
WWW: http://www.epa.gov
Documents on the WWW server may be located by using the on-line search
functions.


RCRA


TITLE: Screening Level Ecological Risk Assessment Protocol for Hazardous
Waste Combustion Facilities, Volume One - Peer Review Draft
PUBLICATION DATE: August 1999
AVAILABILITY: Internet only
EPA ORDER NO.: EPA530-D-99-001A
URL: http://www.epa.gov/epaoswer/hazwaste/combust/ecorisk.htm


The draft three volume set details the recommended approach for
conducting ecological risk assessments in support of permitting RCRA
hazardous waste combustion facilities. Volume I explains the basis of
the user-friendly procedures used to perform the risk assessments.


TITLE: Screening Level Ecological Risk Assessment Protocol for Hazardous
Waste Combustion Facilities, Volume Two - Peer Review Draft
PUBLICATION DATE: August 1999
AVAILABILITY: Internet only
EPA ORDER NO.: EPA530-D-99-001B
URL: http://www.epa.gov/epaoswer/hazwaste/combust/ecorisk.htm


The draft three-volume set details the recommended approach for
conducting ecological risk assessments in support of permitting RCRA
hazardous waste combustion facilities. Volume II presents
compound-specific information necessary to complete the risk assessment.


TITLE: Screening Level Ecological Risk Assessment Protocol for Hazardous
Waste Combustion Facilities, Volume Three - Peer Review Draft
PUBLICATION DATE: August 1999
AVAILABILITY: Internet only
EPA ORDER NO.: EPA530-D-99-001C
URL: http://www.epa.gov/epaoswer/hazwaste/combust/ecorisk.htm


The draft three volume set details the recommended approach for
conducting ecological risk assessments in support of permitting RCRA
hazardous waste combustion facilities. Volume III contains data related
to the risk assessment procedures, including equations for calculating
media concentrations, chemical and media-specific bioconcentration
factors, and toxicity reference values.


TITLE: Catalog of Hazardous and Solid Waste Publications, Twelfth
Edition
PUBLICATION DATE: September 1999
AVAILABILITY: Internet only
EPA ORDER NO.: EPA530-B-99-001
URL: http://www.epa.gov/epaoswer/osw/catalog.htm


This catalog is a directory of EPA documents relevant to RCRA. The
catalog is divided into sections which organize the documents by
subject, title, and document order number. Summaries of the documents
and their publication dates are also included for documents published as
of July 1999.


TITLE: Planet Protectors Create Less Waste in the First Place! Poster
PUBLICATION DATE: September 1999
AVAILABILITY: Internet only
EPA ORDER NO.: EPA530-H-99-001
URL: http://www.epa.gov/epaoswer/osw/kids.htm


This poster emphasizes the importance of waste prevention by reducing,
reusing and recycling. Poster summarizes the ways to reuse an old jelly
jar.


TITLE: Planet Protectors Create Less Waste in the First Place!
PUBLICATION DATE: September 1999
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: EPA530-K-99-006
URL: http://www.epa.gov/epaoswer/osw/kids.htm


This coloring book emphasizes the importance of waste prevention by
reducing, reusing and recycling. The booklet suggests several ways to
reuse an old jelly jar.


TITLE: A Collection of Solid Waste Resources - Fall 1999 Edition
PUBLICATION DATE: November 1999
AVAILABILITY: Hotline
EPA ORDER NO.: EPA530-C-99-002


This CD-ROM contains a number of OSW documents in their entirety,
including the Municipal Solid Waste Factbook. These documents provide
information on how to reduce, reuse, and recycle trash, and properly
manage different forms of solid and hazardous waste.


TITLE: RCRA Helps Turn Brownfields Green
PUBLICATION DATE: December 1999
AVAILABILITY: Internet only
EPA ORDER NO.: EPA530-F-99-048
URL: http://www.epa.gov/epaoswer/hazwaste/ca/index.htm


This brochure shows how RCRA corrective action returns brownfield sites
to beneficial use. It also provides two brownfields success stories.


UST


TITLE: Underground Storage Tank Program: Regional and State Contacts
PUBLICATION DATE: January 2000
AVAILABILITY: Hotline
EPA ORDER NO.: EPA510-F-00-001


This document is a listing of regional and state UST and LUST program
contacts; it includes Internet addresses for state UST/LUST offices.


CERCLA


TITLE: Closeout Procedures for National Priorities List Sites
PUBLICATION DATE: January 2000
EPA ORDER NO.: EPA540-R-98-016, OSWER 9320.2-09A-P, PB98-963 223
AVAILABILITY: Internet only
URL: http://www.epa.gov/superfund/resources/closeout/index.htm


This document is designed primarily for Remedial Project Managers. It
describes the process for accomplishing remedial action completion,
construction completion, site completion, and site deletion. The
guidance applies only to those sites that are or were on the final
National Priorities List.


TITLE: Presumptive Remedy for Metals-in-Soil Sites
PUBLICATION DATE: September 1999
EPA ORDER NO.: EPA540-F-98-054, PB99-963 301, OSWER 9355.0-72FS
AVAILABILITY: Internet
URL: http://www.epa.gov/superfund/resources/presump/index.htm


This directive identifies a presumptive remedy for metals-in-soil sites,
and summarizes technical factors that should be considered when
selecting a presumptive remedy for these sites. This presumptive remedy
is intended for use at sites where metal contamination in soils is a
primary problem, including areas where metals may be co-located with
other contaminants.


TITLE: Interim Final Guidance Institutional Controls and Transfer of
Real Property under CERCLA Section 120(h)(3)(A)(B) or (C)
PUBLICATION DATE: January 2000
AVAILABILITY: SDC/Internet
URL: http://www.epa.gov/swerffrr/guide.htm


EPA�s evaluation of federal property transfers is contingent on the
receipt of information establishing that the institutional controls will
be effective in preventing human or environmental exposure to hazardous
substances that remain on site above levels which allow unrestricted
use. This guidance requires that the transferring federal agency
demonstrate prior to transfer that certain procedures are in place, or
will be put in place, that will provide EPA with sufficient basis for
determining that the institutional controls will perform as expected in
the future.


EPCRA


TITLE: Chemicals in Your Community: A Guide to the Emergency Planning
and Community Right-to-Know Act
PUBLICATION DATE: December 1999
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: EPA550-K-99-001
URL: http://www.epa.gov/ceppo/p-gen.htm


This pamphlet provides a summary of the types of information that can be
obtained under the EPCRA and the Clean Air Act (CAA). The pamphlet
provides a discussion on how the various types of public information can
be used by groups such as fire departments, health care professionals,
citizens, and other industries to improve the safety of the surrounding
community.


TITLE: Joint United States-Mexico Contingency Plan
PUBLICATION DATE: June 1999
AVAILABILITY: Hotline/Internet
EPA ORDER NO.: EPA550-R-99-006
URL: http://www.epa.gov/ceppo/p-gen.htm


The Joint U.S./Mexico Contingency Plan provides a structure for
cooperation between the United States and Mexico in response to a
polluting incident. Such incidents could potentially threaten both
parties or could affect one party to such a degree that warning the
other party or asking for assistance from the other party would be
necessary. This Plan offers guidance on subjects such as response
operations, organization, preparedness, and notification procedures.


ALL PROGRAMS


TITLE: FY 1998 Audited Financial Statements
PUBLICATION DATE: September 1999
ORDER NO.: N/A
AVAILABILITY: Internet
URL: http://www.epa.gov/ocfopage/finstatement/finstatement.htm


This document contains EPA�s annual financial statements for fiscal year
1998. This document summarizes EPA�s financial activities, and
highlights the successes achieved by the Agency�s programs during FY
1998.



FEDERAL REGISTERS


Federal Register Availability


You may order copies of all major RCRA, Superfund, and EPCRA Federal
Registers by calling the Hotline.


RCRA, Superfund, and EPCRA National Toll-Free No.: (800) 424-9346
Local: (703) 412-9810 TDD National Toll-Free No.: (800) 553-7672


Electronic Availability
Federal Registers from October 1994 to the present related to the
Hotline�s program areas are accessible via
EPA�s Public Access Servers. The servers are accessible at:
WWW: http://www.epa.gov
FTP: ftp.epa.gov


EPA Federal Registers are organized by date on the WWW (starting from
October 1994).


Go to: http://www.epa.gov/fedrgstr


For RCRA/UST and selected CERCLA Federal Registers, choose: EPA - Waste.


For selected EPCRA Federal Registers, choose: EPA - TRI.
For CAA Section 112(r) Federal Registers, choose: EPA - Air.



FINAL RULES


RCRA


�Adequacy of State Permit Programs Under RCRA Subtitle D�
January 12, 2000 (65 FR 1814)


EPA streamlined the approval process for specific state permit programs
for solid waste disposal facilities other than municipal solid waste
landfills (MSWLF) that receive conditionally exempt small quantity
generator (CESQG) hazardous waste. This rule is effective April 11,
2000, unless the Agency receives adverse comments.


�Hazardous Waste Management System; Identification and Listing of
Hazardous Wastes; Final Exclusion�
January 14, 2000 (65 FR 2337)


EPA granted a petition submitted by BWX Technologies, Inc., to exclude
from hazardous waste control a certain solid waste generated at
Lynchburg, Virginia, facility when disposed in Subtitle D landfills.
The final authorization will become effective on January 14, 2000.


�North Dakota: Final Authorization of State Hazardous Waste Management
Program�
January 19, 2000 (65 FR 2897)


EPA authorized revisions to North Dakota�s hazardous waste program.
The final authorization will become effective on March 20, 2000, unless
adverse comments are received.


�Comprehensive Guideline for Procurement of Products Containing
Recovered Materials; Recovered Materials Advisory Notice; Final Rule�
January 19, 2000 (65 FR 3070)


EPA amended the May 1, 1995 Comprehensive Procurement Guidelines (CPG)
by designating 18 new items that are or can be made with recovered
materials. These items are: carpet cushion, flowable fill, railroad
grade crossing surfaces, park benches and picnic tables, playground
equipment, food waste compost, plastic lumber landscaping timbers and
posts, solid plastic binders, plastic clipboards, plastic file folders,
plastic clip portfolios, plastic presentation folders, sorbents,
industrial drums, awards and plaques, mats, signage, and manual-grade
stripping. This final rule will become effective on January 19, 2001.


CERCLA


�National Priorities List; PAB Oil and Chemical Services, Inc. Superfund
Site�
January 3, 2000 (65 FR 19)


Notice of Deletion.


�National Priorities List; D.L. Mud, Inc. Superfund Site�
January 7, 2000 (65 FR 1070)


Notice of Deletion.


�National Priorities List; Renora, Inc. Superfund Site�
January 19, 2000 (65 FR 2903)


Notice of Deletion.


�National Priorities List; Katonah Municipal Well Site�
January 19, 2000 (65 FR 2905)


Notice of Deletion.


PROPOSED RULES


RCRA


�Adequacy of State Permit Programs Under RCRA Subtitle D�
January 12, 2000 (65 FR 1842)


EPA proposed to streamline the approval process for specific state
permit programs for solid waste disposal facilities other than municipal
solid waste landfills (MSWLF) that receive conditionally exempt small
quantity generator (CESQG) hazardous waste. Comments must be received
by February 11, 2000.


�North Dakota: Final Authorization of State Hazardous Waste Management
Program�
January 19, 2000 (65 FR 2925)


EPA proposed to grant final authorization to the hazardous waste
program revisions submitted by the North Dakota Department of Health.
Comments must be received on or before February 18, 2000.


CERCLA


�National Priorities List; D.L. Mud, Inc. Superfund Site�
January 7, 2000 (65 FR 1081)


Proposal to Delete.


�National Priorities List; Renora, Inc. Superfund Site�
January 19, 2000 (65 FR 2925)


Proposal to Delete.


�National Priorities List; Katonah Municipal Well Site�
January 19, 2000 (65 FR 2926)


Proposal to Delete.


NOTICES


RCRA


�Alaska: Tentative Determination and Final Determination of Full Program
Adequacy of the State of Alaska�s Municipal Solid Waste Landfill Permit
Program�
January 5, 1999 (65 FR 453)


EPA published its tentative and final actions to streamline the
approval process of Alaska�s Department of Environmental Conservation�s
municipal solid waste landfill permit program. All comments must be
received by March 6, 2000.


�Agency Information Collection Activities: Submission for OMB Review;
Comment Request; Part B Permit Application, Permit Modifications, and
Special Permits�
January 14, 2000 (65 FR 2388)


EPA planned to submit the following ICR to OMB: Part B Permit
Application, Permit Modifications, and Special Permits, OMB Number
2050-0009, which expires on
March 31, 2000. The ICR describes the nature of the information
collection and its expected cost and burden; where appropriate it
includes the actual data collection instrument. Comments must be
submitted on or before February 14, 2000.


�Recovered Materials Advisory Notice III�
January 19, 2000 (65 FR 3082)


EPA provided notice of the availability of the final Recovered
Materials Advisory Notice III and supporting materials which contains
EPA�s recommendations for purchasing 18 items designated in the final
Comprehensive Procurement Guidelines III, which were published on the
same day. The recommendations for purchasing these items are effective
January 19, 2001.


�Proposed Exclusion From the Definition of Solid Waste; Hazardous Waste
Management System; Identification and Listing of Hazardous Waste�
January 20, 2000 (65 FR 3188)


EPA extended the public comment period regarding a variance from EPA�s
hazardous waste management requirements for certain materials reclaimed
by the World Resources Company from metal-bearing sludges. The original
proposal was published on
December 9, 1999. The comment period has been extended to March 8,
2000.


�Access to Confidential Business Information by HAZMED�
January 26, 2000 (65 FR 4245)


EPA authorized its contractor HAZMED to access confidential business
information (CBI) which has been submitted to EPA under authority of all
sections of RCRA. Access to this data will occur no sooner than
February 7, 2000.


CERCLA


�Announcement and Publication of a Standard Letter To Be Sent to Parties
Requesting a Prospective Purchaser Agreement (PPA); a Checklist of
Information Generally Required Before a PPA Can Be Negotiated; and a
Revised Model PPA Announced by EPA on October 1, 1999�
January 10, 2000 (65 FR 1381)


To further promote the reuse of CERCLA sites, EPA is streamlining the
process for evaluating and negotiating Prospective Purchaser Agreements
(PPAs). On October 1, 1999, EPA issued a standard letter to be sent to
parties requesting PPAs (Attachment A); a proposed checklist of
information needed by EPA to evaluate requests (Attachment
B); and a revised Model PPA (Attachment C).


CONSENT DECREES AND SETTLEMENTS


�Proposed Administrative Settlement; WICO Superfund Site�
January 6, 2000 (65 FR 773)


�Proposed Administrative Settlement; Industri-Plex Superfund Site�
January 10, 2000 (65 FR 1386)


�Proposed Prospective Purchaser Agreement; Oronogo-Duenweg Mining Belt
Superfund Site�
January 19, 2000 (65 FR 2953)


�Consent Decree; United States and State of Idaho v. Union Pacific
Railroad Co., and Coeur d�Alene Tribe v. Union Pacific Railroad Co.�
January 20, 2000 (65 FR 3249)


�Proposed Administrative Settlement; Bates Mill Superfund Site�
January 20, 2000 (65 FR 3233)


�Proposed Administrative Settlement; Uniroyal Hill Street Superfund
Site�
January 24, 2000 (65 FR 3709)


�Consent Decree; United States v. Ambroid Company, Inc.�
January 24, 2000 (65 FR 3738)


�Consent Decree; United States v. Amity Product Carriers, Inc.�
January 24, 2000 (65 FR 3738)


�Consent Decree; United States v. Robert Odabashian, et al.�
January 24, 2000 (65 FR 3739)

CALL ANALYSES


This month, the Hotline responded to a total of 13,854 questions and
document requests.


Caller Profile


RCRA/UST Hotline


Regulated Community 2,412
Citizens 165
State & Local Government 102
Native Americans 3
Federal Agencies 19
Educational Institutions 61
EPA 72
Media 3
Interest Groups 58
Congress 3
International 2
Other 20
Referrals* 135
Transfers to EPCRA/Superfund Hotline* 109
Document Retrieval Line* 11
Message Retrieval Line* 237
Mailed Document Requests* 28


TOTAL NUMBER OF CALLERS 3,440


Emergency Planning and Community Right-to-Know Act/ Superfund Hotline


Regulated Community/Industry 1,654
Consultants/Engineers 685
Attorneys 57
Citizens 75
Public Interest Groups 32
Educational Institutions 26
EPA 24
Federal Agencies 26
GOCOs 1
Congress 5
State Officials/SERC 11
Local Officials/LEPCs 21
Fire Departments 0
Hospitals/Laboratories 1
Trade Associations 0
Media/Press 0
International 8
Other 8
Referrals* 101
Transfers to RCRA/UST Hotline* 118
Document Retrieval Line* 0
Message Retrieval Line* 99


TOTAL NUMBER OF CALLERS 2,952
*No caller profile data available.


HOTLINE TOPICS


RCRA


RCRA GENERAL 517
SUBTITLE C
Hazardous Waste Id. - General 713
Characteristics 395(1)
Listings 409
Mixture Rule 59(1)
Derived-From 40(1)
Contained-In Policy 127
Sampling 23
Solid and Hazardous Waste Exclusions 213
Radioactive Mixed Waste 28
Delisting Petitions 8
Definition of Solid Waste/Hazardous
Waste Recycling 431(1)
Large Quantity Generators 755(1)
Small Quantity Generators 148
CESQGs 107
Transporters 86
Exports/Imports 36
TSDFs
General Facility Standards 131
Unit Standards 205
Air Emissions 56
Combustion - General 38
BIFs 26
Incinerators 11
Draft Strategy 3
Waste Minimization 45
LDR
Applicability 167
Notifications/Certification 39
Treatment Standards 205
Permits and Permitting 158
State Programs 97
Financial Assurance 56
Closure/Post-Closure 79
Corrective Action 191(1)
Enforcement (cleanup) 48
Enforcement (operation) 62
Hazardous Waste Data 64
Test Methods 42
Indian Lands 0
Used Oil Standards 233
Military Munitions 21
OTHER WASTES
Ash 7
Bevill Amendment (Mining Waste) 22
Medical Wastes 109
Oil and Gas 4
SUBTITLE D
Household Hazardous Wastes 76
Subtitle D - General 121
Technical Standards 10
Industrial Wastes 25
Municipal Wastes 50
Indian Lands 2
Financial Assurance 2
Solid Waste Recycling/Markets -
General 155
Aluminum 0
Batteries 11
Glass 0
Paper 0
Plastics 5
Tires 6
Used Oil 6
Composting 9
Procurement 36
Source Reduction/Pollution Prevention 116
Grants and Financing 1
TOTAL QUESTIONS 6,845*
* Includes 2,343 RCRA document requests.


UST


General/Misc. 62
Applicability/Definitions 79(1)
Regulated Substances 23
Closure 17
Previously Abandoned Tanks 7
1998 Deadline 15
Standards for New Tank Systems 9
Upgrading 7
Release Detection 34
Reporting Requirements 7
Operating Requirements 6
Financing/Grants/Loans 4
Private Sector Initiative 5
AST Interface 0
Corrective Action 19
Financial Responsibility 18
Enforcement (cleanup) 5
Enforcement (operational) 6
State Programs 17
Indian Lands 0
MTBE 41(1)
RBCA 0
Technologies 0
Solvency/Cost Controls 0
Trust Fund 1
Pay for Performance 0
UST Fields 0
Lender Liability 0
TOTAL QUESTIONS 382*
* Includes 133 UST document requests.


EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW


General:
General Title III Questions 292
Trade Secrets 5
Training 0
Chemical-Specific Information 15
Federal Facilities Executive Order 2


Emergency Planning (Sections 301-303):
General 55
Notification Requirements 28
SERC/LEPC Issues 20
EHSs/TPQs 36(1)
Risk Communication/
Hazards Analysis 2
Exemptions 2
Enforcement 9
Emergency Release Notification (Section 304):
General 53
Notification Requirements 72
Reportable Quantities 62
CERCLA Section 103 vs. SARA Section 304 30
ARIP/AHEDB/ERNS 4
Exemptions 22
Enforcement 14
Hazardous Chemical Reporting
(Sections 311-312)
General 297
MSDS Reporting Requirements 88
Tier I/II Requirements 570(1)
Thresholds 173(1)
Hazard Categories 6
Mixtures Reporting 32
Exemptions 91(1)
Enforcement 27
Toxic Chemical Release Inventory (Section 313):
General 300
AFR 23
Reporting Requirements 327
Thresholds 255
Form R Completion 192
Supplier Notification 32
NOTEs/NOSEs/NONs 6
Voluntary Revisions 30
Pollution Prevention 33/50 5
Public Access to Data 18
TRI Database 15
Petitions 1
TRI Expansion 33
Exemptions 44
Enforcement 32
CAA (Section 112(r)):
General Duty 45
RMP General 489
Regulated Substances/Thresholds 240(1)
Exemptions 111
Process Identification 35
Program Levels 6
Offsite Consequence Analysis 181(1)
Accident History 3
Prevention Program 3
Emergency Response Program 4
Management Program 0
RMP Submission 127
Access to RMP Data 124(1)
Risk Communication 157
State Implementation 12
RMP Enforcement 24


TOTAL QUESTIONS 4,881
*Includes 875 Emergency Planning and Community Right-to-Know document
requests.



SUPERFUND


General/Misc. 264
Administrative Improvements:
General 17
Environmental Justice/Brownfields 87
Presumptive Remedies 5
SACM
Soil Screening Levels 13
Administrative Record 3
ARARs 38
CERCLIS 49
Claims Against Fund 6
Clean-Up Costs 18
Clean-Up Standards 42
Community Involvement 18
Contract Lab Program (CLP) 11
Contracts 1
Definitions 12
Enforcement 42
Access & Information Gathering 16
Citizen Suits 1
Liability 52
PRPs 15
Settlements 30(1)
Federal Facilities 25
Hazardous Substances 68
Natural Resource Damages 2
NCP 25
NPL 49(1)
Off Site Rule 10(1)
Reauthorization 0
Release Notification 132(1)
Response Process 31
HRS 2
PA/SI 5
RD/RA 11
Removal 0
RI/FS 33
Risk Assess./Health Effects 64
RODs 19
RQ 82
State/Tribal 7
Taxes 2
Special Topics
Oil Pollution Act 5
SPCC General 104
SPCC Applicability 113(1)
Definitions 63
SPCC Plan Requirements 51(1)
SPCC Regulatory Revisions 15
SPCC Secondary Containment 42(1)
SPCC Other 4
FRP 12
Oil Spill Liability 2
Oil Spill Enforcement/Penalties 2
Oil Spill Notification 17
Oil Spill Info./ERNS 5
Oil Spill Response 4
NCP Product Schedule 0
Oil Spill Response Technologies 0


TOTAL QUESTIONS 1,746*
*Includes 501 Superfund document requests.


TOTAL HOTLINE QUESTIONS AND DOCUMENT REQUESTS: 13,854


(1) Hot topics for this month
Topics are calculated as the summation of all questions received by the
Hotline. A single call may result in multiple questions.