Apcol Cercla PDF
Apcol Cercla PDF
Apcol Cercla PDF
Notice
This document has been developed to assist in conducting environmental audits. The use of this document should
be restricted to environmental audits only. For example, areas such as safety, transportation, occupational health,
and fire protection are mentioned solely for clarification purposes. It is a summary of environmental regulations
under CERCLA, but it is not a substitute for a comprehensive knowledge of the regulations themselves. Any
variation between applicable regulations and the summaries contained in this guidance document are unintentional,
and, in the case of such variations, the requirements of the regulations govern.
This document is intended solely as guidance to explain performance objectives for environmental auditors.
Following the steps set forth in this guidance generally should result in compliance with those aspects of the
regulations that it covers. The U.S. Environmental Protection Agency (EPA) does not make any guarantee or
assume any liability with respect to the use of any information or recommendations contained in this document.
Regulated entities requiring additional information or advice should consult a qualified professional.
This guidance does not constitute rulemaking by the EPA and may not be relied on to create a substantive or
procedural right or benefit enforceable, at law or in equity, by any person. EPA may take action at variance with
this guidance and its internal procedures.
Acknowledgments
EPA would like to gratefully acknowledge the support of the U.S. Army Corps of Engineers Construction
Engineering Research Laboratories (CERL) for their assistance in providing suggestions for the overall format of
this document.
Table of Contents
Section I: Introduction
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
Federal Legislation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Appendices
Appendix A: Consolidated List of Hazardous Substances and Reportable Quantities Under CERCLA
and EPCRA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A1
Section I:
Introduction
Background
The Environmental Protection Agency (EPA) is responsible for ensuring that businesses and organizations comply with
federal laws that protect the public health and the environment. Recently, EPA has begun combining traditional
enforcement activities with more innovative compliance approaches. In its Strategic Plan, the Agency recognizes the
need to assist the regulated community by providing compliance assistance and guidance that will promote improved
compliance and overall environmental performance (see Exhibit 1). EPA encourages regulated entities to recognize
compliance as the floor, rather than the ceiling, of environmental performance by internalizing and implementing sound
environmental practices. As part of that effort, EPA is encouraging the development of self-assessment programs at
individual facilities. Voluntary audit programs play an important role in helping companies meet their obligation to
comply with environmental requirements. Such assessments can be a critical link, not only to improved compliance,
but also to improvements in other aspects of an organization’s performance. For example, environmental audits may
identify pollution prevention opportunities that can substantially reduce an organization’s operating costs.
Over the years, EPA has encouraged regulated entities to initiate environmental audit programs that support and
document compliance with environmental regulations. EPA has developed this audit protocol to provide regulated
entities with specific guidance in periodically evaluating their compliance with federal environmental requirements.
In 1986, in an effort to encourage the use of environmental auditing, EPA published its "Environmental Auditing Policy
Statement" (see 51 FR 25004). The 1986 audit policy states that "it is EPA policy to encourage the use of
environmental auditing by regulated industries to help achieve and maintain compliance with environmental laws and
regulation, as well as to help identify and correct unregulated environmental hazards." In addition, EPA defined
environmental auditing as “a systematic, documented, periodic, and objective review of facility operations and practices
related to meeting environmental requirements.” The policy also identified several objectives for environmental audits:
< assessing risks from regulated and unregulated materials and practices.
Under the final Audit/Self Policing Policy, EPA will not seek gravity-based penalties and will not recommend
criminal prosecutions for companies that meet the requirements of the Policy. Gravity-based penalties represent
the “seriousness” or punitive portion of penalties over and above the portion representing the economic gain from
non-compliance. The policy requires companies:
C to promptly disclose and correct violations,
C to prevent recurrence of the violation, and
C to remedy environmental harm
Corporations remain criminally liable for violations resulting from conscious disregard of their legal duties, and
individuals remain liable for criminal wrongdoing. EPA retains discretion to recover the economic benefit gained
as a result of noncompliance, so that companies will not be able to obtain an economic advantage over their
competitors by delaying investment in compliance. Where violations are discovered by means other than
environmental audits or due diligence efforts, but are promptly disclosed and expeditiously corrected, EPA will
reduce gravity-based penalties by 75% provided that all of the other conditions of the policy are met.
As a result of EPA’s new audit policy, through March 1998, 247 companies have disclosed environmental
violations at more than 760 facilities and EPA has reduced or waived penalties for 89 companies and 433 facilities.
The final Audit/Self-Policing Policy was published in the Federal Register on December 22, 1995 (60 FR 66706).
It took effect on January 22, 1996. For further information, contact the Audit Policy Docket at (202) 260-7548 or
call (202) 564-4187.
In 1995, EPA published "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations"
which both reaffirmed and expanded its 1986 audit policy. The 1995 audit policy offers major incentives for entities to
discover, disclose and correct environmental violations. Under the 1995 policy, EPA will not seek gravity-based
penalties or recommend criminal charges be brought for violations that are discovered through an “environmental
audit” (as defined in the 1986 audit policy) or a management system reflecting “due diligence” and that are promptly
disclosed and corrected, provided that other important safeguards are met (see Exhibit 2). These safeguards protect
health and the environment by precluding policy relief for violations that cause serious environmental harm or may
have presented an imminent and substantial endangerment, for example.
This protocol, which is part of a set containing other area or statutory specific audit protocols, is a tool to assist you in
conducting environmental audits, which should inform you whether your facility is in compliance with federal
regulations. EPA has developed these audit protocols to assist and encourage businesses and organizations to perform
environmental audits and disclose violations in accordance with EPA's audit policy. The audit protocols are intended to
promote consistency among regulated entities when conducting environmental audits and to ensure that audits are
conducted in a thorough and comprehensive manner.
Each protocol provides guidance on key requirements, defines regulatory terms, and gives an overview of the federal
laws affecting a particular environmental management area. It also includes a checklist containing detailed procedures
for conducting a review of facility conditions. In order to use these documents effectively, you should be familiar with
basic environmental auditing practices and the relevant environmental regulations under Title 40 of the Code of Federal
Regulations (CFR). The audit protocols are not intended to be exclusive or limiting with respect to procedures that may
be followed. EPA recognizes that other audit approaches and techniques may be effective in identifying and evaluating
a facility’s environmental status and in formulating recommendations to correct observed deficiencies.
These protocols can be used as a basis to implement, upgrade, or benchmark environmental management activities.
The protocols are a management tool for measuring and improving environmental performance by correcting
deficiencies uncovered by the audit (see Exhibit 3). This process is perhaps the key element to a high quality
environmental management program and will function best when an organization identifies the "root causes" of each
audit finding. Root causes are those breakdowns in management oversight, information exchange, and evaluation that
allow environmental problems to recur. Thus, while an organization may have developed an excellent record of dealing
with a symptom, such as spill response, the underlying problem or "root cause" has not been addressed. Furthermore,
identifying the root cause of an audit finding can mean identifying not only the failures that require correction but also
the successes. In each case a root cause analysis should uncover the failures while promoting the successes so that an
organization can make continual progress toward environmental excellence.
Analyze
Identify Exceptions for
Audit Problems Cause/Effect
To conduct effective compliance audits, the auditor or audit team needs to possess sound working knowledge of the
operations and processes to be reviewed, the relevant regulations that apply to a given facility, and of acceptable
auditing practices. The audit protocol should be used as a planning tool to assist the auditor in understanding the
requirements for conducting a comprehensive audit. This document will provide the user with a generic audit approach
to identify regulatory issues that may require closer examination. Once the general issues are identified through the use
of this protocol, the auditor should perform a more detailed investigation to determine the specific area of
noncompliance to be corrected. The auditor should review federal, state and local environmental requirements and
annotate the protocol, as required, to include other applicable requirements not included in the protocol.
The auditor also should determine which regulatory agency has authority for implementing an environmental program
so that the proper set of regulations is consulted. State programs that implement federally mandated programs may
contain more stringent requirements. This protocol should not be used as a substitute for the applicable regulations.
The collective set of the audit protocols developed by EPA is designed to support a wide range of environmental
auditing needs; therefore several of the protocols in this set or sections of an individual protocol may not be applicable
to a particular facility. Each protocol is not intended to be an exhaustive set of procedures; rather it is meant to inform
the auditor, about the degree and quality of evaluation essential to a thorough environmental audit. EPA is aware that
other audit approaches may provide an effective means of identifying and assessing facility environmental status and in
! Applicability - provides guidance on the major activities and operations included in the protocol and a brief
The checklist delineates what should be evaluated during an audit. The left column states either a requirement
mandated by regulation or a good management practice that exceeds the requirements of the federal regulations. Good
management practices are distinguished from regulatory requirements in the checklist by the acronym (MP) and are
printed in italics. The regulatory citation is given in parentheses after the requirement. The right column gives
instructions to help conduct the evaluation. These instructions are performance objectives that should be accomplished
by the auditor. Some of the performance objectives may be simple documentation checks that take only a few minutes;
others may require a time-intensive physical inspection of a facility.
EPA is presently in the process of developing a series of audit protocol application guides to serve as companion
documents to the set of protocols. The application guides will provide the auditor with a matrix which identifies and
cross references certain site-specific activities or unit operations with particular environmental aspects of that activity.
For example, managing hazardous waste containers is a site-specific activity with environmental concerns, such as
possible releases to air, and water, that may require additional review through auditing. By using the application guide
the user can identify facility specific practices that require more in-depth review. In addition, the application guides
will also direct the user to specific protocols and sections (e.g., checklist items) of the protocol to determine areas that
are regulated and require auditing.
List of Acronyms
FS Feasibility study
MP Management practice
PA Preliminary assessment
PL Public law
RA Remedial action
RD Remedial design
RI Remedial investigation
SI Site inspection
Section II:
Audit Protocol
Applicability
This protocol addresses facilities where hazardous substances were released or pose a substantial threat of release. This
document does not include protocols for determining compliance with the Emergency Planning and Community Right-
to-Know Act (EPCRA). These requirements are contained in a separate EPA document, Protocol for Conducting
Compliance Audits under the Emergency Planning and Community Right-to-Know Act (EPA-305-B-98-007). Specific
state regulations are not included in this protocol.
There are numerous environmental regulatory requirements administered by federal, state, and local governments.
Each level of government may have a major impact on areas at the facility that are subject to the audit. Therefore,
auditors are advised to review federal, state, and local regulations in order to perform a comprehensive audit.
Federal Legislation
In addition to the federal requirements mentioned in this document, many states have (or are in the process of
establishing) release reporting requirements and clean-up requirements that place additional responsibilities on facility
owners and operators and other potentially responsible parties. States and localities or states and municipalities may
establish release reporting requirements and other related legal obligations that are more stringent than those under
CERCLA. Therefore, regulated entities that are not subject to the requirements of CERCLA may be subject to state or
local regulations regarding release reporting and site evaluation and clean-up.
Site Evaluation
If a release has, may have occurred, or could potentially occur, the first requirement is a site evaluation, the goal of
which is to collect data and evaluate releases of hazardous substances, pollutants, or contaminants to determine the
extent of the release and the release’s impact to public health and the environment. Tthe regulations which outline the
requirements for a site evaluation are found in 40 CFR 300.420. A site evaluation consists of the following three
components:
C A preliminary assessment (PA), which is a review of existing site information and an off-site reconnaissance, if
If it is determined that the site will need remediation actions, then the lead agency is required to conduct a remedial
investigation/feasibility study (or equivalent investigation, e.g., engineering evaluation/cost analysis (EE/CA)), unless
the release ?may present an imminent and substantial danger to public health, welfare or the environment,” in which
case the lead agency must mitigate the threat through a removal action, or oversee implementation of the removal action
by the potentially responsible party (PRP).
to the extent necessary to select a site remedy. The regulations promulgated under CERCLA that apply to RI/FSs are in
40 CFR 300.430(a)-(e) and require that an RI/FS consist of the following four steps:
C Project scoping, which is a plan developed by the lead agency or PRP for conducting an RI/FS such that the detail
of analysis is appropriate to the complexity of the release site problems being addressed;
C A remedial investigation, which is the collection of the necessary field data to adequately characterize the release
site in order to assist in developing and evaluating remedial alternatives;
C A risk assessment which, as a component of the RI, characterizes potential threats to human health and the
environment that may be posed by site contaminants in the absence of site remediation; and
C A feasibility study, which is a study of potential remedial alternatives to address site risks.
Following the completion of the RI/FS, a report is prepared by the lead agency or PRP and a public comment period is
held on the proposed remedy (discussed further in <Community Relations’). Then the lead agency selects a remedy and
the design process commences.
Removal Actions
If at any point during the remediation process, a determination has been made that there is an imminent threat to public
health welfare, or the environment, the lead agency is required by CERCLA to take an appropriate removal action to
abate, prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release. When the determination has
been made that a removal action is appropriate, 40 CFR 300.410 requires that the following steps be undertaken as
promptly as possible:
C A removal preliminary assessment which includes the collection or review of readily available information such as
site management practices, information from waste generator, document review, and facility interviews;
C A removal site inspection, if necessary, to gather information that was not obtained during the removal preliminary
assessment; and
C A removal action which is performed in response to a specific release.
The lead agency will have the latitude to respond as necessary to ensure the minimization of harm to public health,
welfare, or the environment.
Community Involvement
Section 117 of CERCLA requires (through 40 CFR 300.430 and 300.435) that the lead agency conduct various
community involvement activities throughout the inactive waste site evaluation process. The intention is to promote
active communication between communities affected by the release site and the PRP’s response for implementing
remedial actions. Community involvement activities must be undertaken in the RI/FS, RD/RA, and removal actions
processes and may include interviewing community interest groups and developing a Community Relations Plan
(CRP). The CRP is designed to ensure that the public has been provided the appropriate opportunity to become
involved in site-related decision making, to identify the appropriate activities for ensuring such public involvement, and
to provide the appropriate opportunity for the community to learn about the release site.
Administrative Record
Section 133(k) of CERCLA requires the establishment and maintenance of an administrative record which contains all
documents pertaining to information used or potentially relied upon to select response actions, information on the
RI/FS and RD/RA processes, the ROD and all public comments received. There are specific requirements in CERCLA
that are promulgated at 40 CFR 300.800-300.805 which require the administrative record to be maintained at a central
location near the release site and that it must be easily accessible to community interest groups.
For further information regarding the CERCLA regulations, contact U.S. EPA’s Superfund, RCRA/UST, and
EPCRA Hotline at 800-424-9346 (or 703-412-9810 in the D.C. area) from 9 a.m. to 6 p.m., Monday through
Friday.
This EPA hotline provides up-to-date information on regulations developed under CERCLA (Superfund),
RCRA and the Oil Pollution Act. The hotline can assist with Section 112(r) of the Clean Air Act (CAA) and
Spill Prevention, Control and Countermeasures (SPCC) regulations. The hotline also responds to requests for
relevant documents and can direct the caller to additional tools that provide a more detailed discussion of
specific regulatory requirements.
Environment
As defined by section 101(8) of CERCLA, environment means the navigable waters, the waters of the contiguous zone,
and the ocean waters of which the natural resources are under the exclusive management authority of the United States
under the Magnuson Fishery Conservation and Management Act; and any other surface water, ground water, drinking
water supply, land surface or subsurface strata, or ambient air within the United States or under the jurisdiction of the
United States (40 CFR 300.5).
Facility
As defined by section 101(9) of CERCLA, facility means any building, structure, installation, equipment, pipe or
pipeline (including any pipe into a sewer or publicly owned treatment works), well, pit, pond, lagoon, impoundment,
ditch, landfill, storage container, motor vehicle, rolling stock, aircraft, or any site or area, where a hazardous substance
has been deposited, stored, disposed of, placed, or otherwise come to be located; but does not include any consumer
product in consumer use or any vessel (40 CFR 300.5).
Hazardous Substance
As defined by section 101(4) of CERCLA, any substance designated pursuant to section 311(b)(2)(A) of the Clean
Water Act (CWA); any element, compound mixture, solution, or substance designated pursuant to section 102 of
CERCLA; any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the
Solid Waste Disposal Act (but not including any waste the regulation of which under the Solid Waste Disposal Act has
been suspended by Act of Congress); any toxic pollutant listed under section 307(a) of the CWA; any hazardous air
pollutant listed under section 112 of the Clean Air Act; and any imminently hazardous chemical substance or mixture
with respect to which the EPA Administrator has taken action pursuant to section 7 of the Toxic Substances Control
Act. The term does not include petroleum, including crude oil or any fraction thereof which is not otherwise
specifically listed or designated as a hazardous substance in the first sentence of this paragraph, and the term does not
include natural gas, natural gas liquids, liquefied natural gas, or synthetic gas usable for fuel (or mixtures of natural gas
and such synthetic gas (40 CFR 300.5).
Lead Agency
The federal or state agency that provides the On-Scene Coordinator (OSC) or the responsible official for a CERCLA
response action.
Person
An individual, firm, corporation, association, partnership, consortium, joint venture, commercial entity, United States
government, state, municipality, commission, political subdivision of a state, or any interstate body (40 CFR 300.5 and
302.3).
Pollutant or Contaminant
As defined by section 101(33) of CERCLA, pollutant or contaminant includes, but is not limited to, any element,
substance, compound, or mixture, including disease-causing agents, which after release into the environment and upon
exposure, ingestion, inhalation, or assimilation into any organism, either directly from the environment or indirectly by
ingestion through food chains, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities,
cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction) or physical
deformations, in such organisms or their offspring. The term does not include petroleum, including crude oil or any
fraction thereof which is not otherwise specifically listed or designated as a hazardous substance under section
101(4)(A) through (F) of CERCLA, nor does it include natural gas of pipeline quality (or mixtures of natural gas and
such synthetic gas). For purposes of the NCP, the term pollutant or contaminant means any pollutant or contaminant
that may present an imminent and substantial danger to public health or welfare (40 CFR 300.5).
Release
As defined by section 101(22) of CERCLA, release means any spilling, leaking, pumping, pouring, emitting, emptying,
discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or
discarding of barrels, containers, and other closed receptacles containing any hazardous substance or pollutant or
contaminant). It excludes any release which results in exposure to persons solely within a workplace, with respect to a
claim which such persons may assert against the employer of such persons; emissions from the engine exhaust of a
motor vehicle, rolling stock, aircraft, vessel, or pipeline pumping station engine; release of source byproduct, or special
nuclear material from a nuclear incident, as those terms are defined in the Atomic Energy Act of 1954, if such release is
subject to requirements with respect to financial protection established by the Nuclear Regulatory Commission under
section 170 of such Act, or, for the purposes of section 104 of CERCLA or any other response action, any release of
source, byproduct, or special nuclear materials from any processing site designated under section 102(a)(1) or 302(a) of
the Uranium Mill Tailings Radiation Control Act of 1978; and the normal application of fertilizer. For purposes of the
NCP, release also means threat of release (40 CFR 300.5 and 302.3).
Remove or Removal
As defined by section 311(a)(8) of the CWA, refers to removal of oil or hazardous substances from the water and
shorelines or the taking of such other actions as may be necessary to minimize or mitigate damage to the public health
or welfare or to the environment. As defined by section 101(23) of CERCLA, removal of released hazardous
substances from the environment; such actions as may be necessary taken in the event of the threat of release of
hazardous substances into the environment; such actions as may be necessary to monitor, assess, and evaluate the
release or threat of release of hazardous substances; the disposal of removed material; or the taking of such other
actions as may be necessary to prevent, minimize, or mitigate damage to the public health or welfare or the
environment, which may otherwise result from a release or threat of release. The term includes, in addition, without
being limited to, security fencing or other measures to limit access, provision of alternative water supplies, temporary
evacuation and housing of threatened individuals not otherwise provided for, action taken under section 104(b) of
CERCLA, post-removal site control, where appropriate, and any emergency assistance which may be provided under
the Disaster Relief Act of 1974. For the purpose of the NCP, the term also includes enforcement activities related
thereto (40 CFR 300.5).
Reportable Quantity
That quantity, as set forth in 40 CFR 302, the release of which requires notification pursuant to 40 CFR 302 (40 CFR
302.3).
C Spill/release records
C Soil sample and groundwater monitoring data related to areas targeted for removal and cleanup
C Cleanup sites
C Disposal sites
C Contaminated areas
Refer To
Checklist
Compliance Category:
CERCLA/SARA
All Facilities
C.1 The current status of any Determine if noncompliance issues have been resolved by reviewing a copy of the
ongoing or unresolved Consent previous report, Consent Orders, Compliance Agreements, NOVs, or equivalent state
Orders, Compliance enforcement actions.
Agreements, Notices of
Violation (NOVs), or equivalent For those open items, indicate what corrective action is planned and milestones
state enforcement actions established to correct problems.
should be examined.
Determine how many dockets, if any, your facility has.
C.2 Facilities are required to Determine if any new regulations have been issued since the finalization of the guide.
comply with all applicable If so, annotate checklist to include new standards.
federal regulatory requirements
not contained in this checklist. Determine if the facility has activities or facilities which are federally regulated, but not
addressed in this checklist.
Verify that the facility is in compliance with all applicable and newly issued regulations.
C.3 Facilities are required to Verify that the facility is abiding by state and local requirements.
abide by state and local
regulations concerning Verify that the facility is operating according to permits issued by the state or local
hazardous materials. agencies.
C.4. Facilities that are Verify that the facility has procedures in place to identify areas where hazardous
determined: 1) to own or substances are or may have been stored, treated, or released at the facility.
operate, or 2) who at the time
owned or operated, or 3) who Confirm that the facility maintains an inventory of potential inactive waste sites and
accepted hazardous substances determine whether the inventory contains the following information for each site:
for transport and selected a - The site location.
facility at which hazardous - The site history (i.e., types of waste or hazardous substance that may have been
substances are or have been released).
stored, treated, or disposed of,
- Facility responses to environmental problems.
are required to notify the EPA
unless such facility has been
properly permitted under RCRA
(40 CFR 302).
Compliance Category:
CERCLA/SARA
C.5. Facilities are required to Confirm through interviewing facility personnel and reviewing facility release reporting
notify EPA of the existence of procedures that the facility has performed the following:
hazardous waste sites - If any hazardous substances are found to have been stored, treated, or disposed of
(CERCLA s.103, 40 CFR at the facility, the EPA is notified of the existence of the site(s) unless the site(s)
300.405(b), 300.135(j), has been issued a valid RCRA permit.
300.120(b)). - Notified the EPA if the facility accepted hazardous substances for transport and
selected a facility where hazardous substances are or have been stored, treated, or
disposed of without a valid RCRA permit.
- Notified the National Response Center (NRC) when a hazardous substance release
exceeded a CERCLA Reportable Quantity.
- Promptly notified trustees for natural resources of hazardous substance releases
that are injuring or may injure natural resources under their jurisdiction.
C.6. Releases in excess of or Verify that spills in excess of the reportable quantities listed in Appendix A have been
equal to reportable quantities of reported. (Also, refer to 40 CFR 302, Table 302.4.)
hazardous substances shall be
reported to the NRC Verify that a procedure is in place for the notification of the NRC immediately after
immediately (40 CFR 302.1 becoming aware of the release.
through 302.6).
Verify that if mixtures or solutions of hazardous substances are released, except for
radionuclides, it is reported when either of the following occur:
- The quantity of all hazardous constituents of the mixture or solution is known and a
reportable quantity or more of any hazardous constituent is released.
- The quantity of one or more of the hazardous constituents of the mixture or solution
is unknown and the total amount of the mixture or solution released equals or
exceeds the reportable quantity for the hazardous constituent with the lowest
reportable quantity.
(NOTE: Notification requirements for radionuclide releases are not included in this
guide.)
C.7. Facilities with releases Determine if the facility has any releases that are continuous and stable in quantity
that are continuous and stable and rate.
in quantity and rate are required
to meet limited notification Verify that the following notifications have been given:
requirements (40 CFR 302.8). - Initial telephone notification
- Initial written notification within 30 days of the initial telephone notification
- Follow-up notification within 30 days of the first anniversary date of the initial written
notification
- Notification of changes in:
-- the composition or source of the release
-- information submitted in the initial written notification
-- the follow-up notification required on the first anniversary date of the initial
written notification
- Notification of when there is an increase in the quantity of the hazardous
substances in any 24-hour period that represents a statistically significant increase.
(NOTE: Instead of the initial written report or follow-up report, the facility may submit a
copy of the Toxic Release Inventory (TRI) form submitted under SARA Title III section
313 for the previous July 1, provided that conditions are met as described in 40 CFR
302.8(j).)
Compliance Category:
CERCLA/SARA
Site Evaluation
C.8. When a facility Verify that for all potential inactive waste sites, a preliminary assessment (PA) is
experiences a hazardous conducted that contains at least the following:
substance release to the - A review of existing information about the release such as:
environment, an evaluation of -- information on the pathways of exposure;
the release site must be -- exposure targets; and
performed to determine the -- source and nature of release.
extent of the release and the
- On-site reconnaissance.
release’s impact to public health
and the environment. A site - Off-site reconnaissance.
evaluation typically contains the
following three components (40 When the facility performs a remedial PA, confirm that the facility completes the EPA
CFR 300.420): Preliminary Assessment form or its equivalent and that it includes the following
information:
a. A preliminary assessment - A description of the release
(PA) which is a review of - A description of the probable nature of the release
existing site information and - A recommendation on whether further action is warranted, which lead agency
an off-site reconnaissance, should conduct further action, and whether a site investigation (SI) or removal
if appropriate, to determine action, or both, should be undertaken.
if a release may require
further investigations or Where the facility has received an interim or final RCRA facility permit, determine
removal actions. Typically, whether the facility has completed a RCRA Facility Assessment (RFA).
when performing a PA,
facility documents are For facility SIs verify that, prior to conducting any field sampling, the facility has
reviewed and field sampling developed sampling and analysis plans which consist of the following:
is not conducted. - A field sampling plan.
- A Quality Assurance Project Plan (QAPP).
b. A site inspection (SI) which
is an on-site investigation to
Determine whether the facility has included the following information when preparing
determine whether a
an SI:
release has occurred and to
identify the preliminary - A description/history/nature of waste handling
public health and - A description of known contaminants
environmental threats - A description of pathways of migration of contaminants
associated with the release. - An identification and description of human and environmental targets
The SI typically builds upon - A recommendation on whether further action is warranted.
the information collected
during the PA. Determine if the facility determined whether a removal action is appropriate based
Furthermore, the SI upon the information collected during the PA/SI. If so, confirm that the facility initiated
involves, as appropriate, a removal PA pursuant to C.12.
both on- and off-site field
sampling and analysis.
Compliance Category:
CERCLA/SARA
C.9. Sites that meet a certain Confirm that the facility has assisted federal and state agencies in evaluating whether
criteria may be eligible for release sites have met one of the following criteria:
placement on the National - The release scores sufficiently high pursuant to the Hazard Ranking System.
Priorities List (NPL) (40 CFR (NOTE: The Hazard Ranking System is the method used by EPA to evaluate the
300.425(c), (d)). relative potential of hazardous substance releases to cause health or safety
problems, ecological damage, or environmental damage.)
- The state has designated a release as its highest priority (a state may have only
one highest priority).
- The release satisfies all of the following criteria:
-- the Agency for Toxic Substances and Disease Registry has issued a health
advisory that recommends dissociation of individuals from the release;
-- the EPA determines that the release poses a significant threat to public health;
-- the EPA anticipates that it will be more cost-effective to use its remedial
authority than to use removal authority to respond to the release.
If the facility determines that a release is eligible for placement on the NPL, verify that
the facility has submitted the release score (using HRS model) and has provided the
appropriate backup documentation.
Compliance Category:
CERCLA/SARA
C.10. The purpose of the RI/FS Determine whether the facility has initiated coordination with regulatory agencies to
is to assess site conditions and ensure that both parties have discussed and identified the appropriate sequence
evaluate remedial alternatives to actions necessary to address the release site problems.
the extent necessary to select a
site remedy. Developing and Verify that the facility has conducted project scoping to identify the optimal set and
implementing an RI/FS sequence of actions necessary to address the release site problems. Specifically, the
generally includes the following following should be incorporated into the project scope:
(40 CFR 300.430): - The assembly and evaluation of existing data for the release site, including the
results of any removal actions and PA/SI data.
a. Project Scoping - The - The identification of likely response scenarios, potentially applicable technologies,
facility should have and operable units that may address site problems.
developed a plan for - The identification of the type, quality, and quantity of the data that will be collected
conducting an RI/FS such during the RI/FS.
that the detail of analysis is - The preparation of site-specific health and safety plans that specify, at a minimum,
appropriate to the employee training and protective equipment, medical surveillance requirements,
complexity of the release standard operating procedures, and contingency plan that conforms with 29 CFR
site problems being 1910.120(l)(1)and (l)(2).
addressed.
- The development of a sampling and analysis plan that meets the requirements
outlined in C.8.
b. Remedial Investigation - - The identification of potential federal and state Applicable or Relevant and
The purpose of an RI is to Appropriate Requirements (ARARs).
collect the necessary field
data to adequately
characterize the release site Determine whether the facility has assessed the following factors when conducting an
in order to assist in RI:
developing and evaluating - The physical characteristics of the site (i.e., soils, sediments, geology,
remedial alternatives. Site hydrogeology, meteorology, and ecology).
characterization may be - Characteristics of air, surface water, and ground water.
conducted in one or more - The general characteristics of the waste, including quantities, physical state,
phases to focus sampling concentration, toxicity, ability to bioaccumulate, and mobility.
efforts and to better define - The extent to which the source can be adequately identified and characterized (i.e.,
the potential threat to evaluation of the vertical and horizontal extent of contamination).
human health or the - Actual and potential exposure routes (i.e., inhalation through air transport and
environment. ingestion through groundwater or bioaccumulation).
- Actual and potential exposure pathways through environmental media.
Verify that the facility, in conjunction with regulatory agencies, has identified the
potential ARARs for the release site.
For each release site undergoing an RI, confirm that the facility has conducted a
baseline risk assessment which contains the following:
- A characterization of the current and potential threats to human health and the
environment that may be posed by site contaminants migrating through
environmental media.
- The establishment of acceptable exposure levels for use in developing remedial
alternatives.
Compliance Category:
CERCLA/SARA
C.10. (continued) Where the facility has received an interim or final RCRA facility permit, determine
whether the facility has completed the following:
c. Risk Assessment - As a - A RCRA Facility Investigation (RFI) to evaluate whether releases of hazardous
component of the RI, the substances may have occurred from Solid Waste Management Units (SWMUs).
risk assessment should
characterize the current and Verify that as a part of the FS, the facility has established remedial action objectives
potential threats to human (i.e., acceptable exposure levels that are protective of human health and the
health and the environment environment) which have been developed by using the following:
that may be posed by - ARARs under federal or state environmental laws.
contact to environmental - Maximum contaminant level goals (MCLGs), established under the Safe Drinking
media in the absence of site Water Act, or if the MCLG is determined not to be relevant, the corresponding
remediation. Typically, the maximum contaminant level (MCL).
risk assessment results will - Water quality criteria established under sections 303 or 304 of the CWA.
assist in establishing
- An alternative concentration limit (ACL) established according to CERCLA section
acceptable exposure levels
121(d)(2)(B)(ii).
for use in developing
remedial alternatives in the
FS. For source control actions, confirm that the facility has developed alternatives tailored
to the release site conditions that employ the following, as appropriate:
d. Feasibility Study - The - Treatment techniques that reduce toxicity, mobility, or volume of the release site to
purpose of the FS is to the maximum extent feasible, eliminating or minimizing the need for long-term
ensure that appropriate management.
remedial alternatives are - One or more alternatives that involve little or no treatment, but provide protection of
developed and evaluated. human health and the environment primarily by preventing or controlling exposure
The development and to the release site.
evaluation of alternatives - For groundwater response actions, remedial alternatives which attain site-specific
should reflect the scope and remediation levels within different time periods and using one or more different
complexity of the remedial technologies.
action under consideration
and the release site Confirm that, as a part of an FS, the facility has developed the following:
problems being addressed. - One or more innovative treatment technologies for further consideration.
- A no-action alternative or a no further action alternative, if some removal or
remedial action has already occurred at the release site.
Verify that, to the extent possible, the facility has considered the short- and long-term
aspects of the following criteria to guide the development and screening of remedial
alternatives:
- Effectiveness (i.e., minimization of residual risks and short-term impacts, long-term
protection, quickness of protection).
- Implementability (i.e., technical feasibility and availability).
- Cost (i.e., construction, operation, and maintenance).
Compliance Category:
CERCLA/SARA
C.10. (continued) Determine whether the facility has performed an analysis of a limited number of
remedial alternatives, which have been considered a viable approach to remedial
action, based on the following:
- Overall protection of human health and the environment.
- Compliance with ARARs.
- Long-term effectiveness and permanence.
- Reduction of toxicity, mobility, or volume.
- Short-term effectiveness.
- Implementability.
- Cost.
- State acceptance.
- Community acceptance.
(NOTE: For facilities with an interim or final RCRA facility permit, federal and state
authorities will request that a Corrective Measures Study (CMS) be performed as part
of a Corrective Action Order (CERCLA Sect. 3008(h)) or corrective action requirement
outlined in a permit application and/or permit (CERCLA Sect. 3004(u) and (v)).)
Compliance Category:
CERCLA/SARA
C.11. Upon the completion of When the facility has, in conjunction with the regulatory agency, identified a preferred
the RI/FS, the lead agency proposed remedial action alternative, verify that the proposed plan has been
selects a preferred proposed presented to the public for comment.
alternative for remediation which
can be presented to the public Determine whether the proposed plan presented to the public contains the following:
(and state) for their review and - A brief summary of the alternatives.
comment. The public comments - The rationale used to develop the preferred alternative.
must be considered before the - A summary of comments received from regulatory agencies.
facility can issue a final remedial - A summary of any proposed waiver from an ARAR.
design/remedial action (RD/RA).
Upon receiving new information Verify that the facility conducts the following community relations activities to support
from the public or regulatory the selection of the remedy:
- Publishes a notice of availability and a brief analysis of the proposed plan in a
agencies, the lead agency
major local newspaper.
should reassess its initial
- Makes the proposed plan and supporting information available in the Administrative
remedial alternative Record.
determination. The public - Provides for a public comment period of not less than 30 days.
comments may prompt the lead - Provides for a public meeting at or near the facility during the public comment
agency to modify aspects of period.
their preferred alternative or - Keeps a transcript of the meeting and makes the transcript available to the public.
cause the lead agency to select - Prepares a written summary of significant comments and new information received
a different alternative. The lead during the public comment period.
agency and the lead regulatory
agency will make the final Verify that the facility has developed an RD/RA that is consistent with the selected and
remedy selection decision and implemented remedy as set forth in the ROD.
they will document that decision
in the Record of Decision (ROD) Confirm that Operations and Maintenance (O&M) measures have been initiated after
(40 CFR 300.430(f), 300.435(b), the remedial action objectives/goals outlined in the ROD have been achieved.
(c), (f)).
Compliance Category:
CERCLA/SARA
Removal Action
C.12. At any release site, Confirm that the following information has been considered by the facility when
regardless of whether the site performing a removal preliminary assessment:
has been included on the NPL, - Identification of the source and nature of the release or threat of release.
where the facility has made the - Evaluation by the Agency for Toxic Substances and Disease Registry or by other
determination that there is a sources (e.g., state public health agencies) of the threat to public health.
threat to public health, welfare, - Evaluation of the magnitude of the threat.
or the environment, the facility - Evaluation of factors necessary to make the determination of whether a removal is
may take an appropriate necessary.
removal action to abate,
prevent, minimize, stabilize,
Determine whether a removal site inspection has been performed.
mitigate, or eliminate the
release or threat of release.
When the facility has Verify that the facility has documented the results obtained from a removal site
determined that a removal evaluation.
action is appropriate, the facility
should undertake the action as Verify that the facility evaluated the following factors prior to initiating a removal action
promptly as possible. The action to determine whether or not the action was appropriate:
typically consists of the following - Actual or potential exposure of contaminants to nearby human populations,
three stages (40 CFR 300.410, animals, or the food chain.
300.415): - Actual or potential contamination of drinking water supplies or sensitive
ecosystems.
a. A removal preliminary - Hazardous substances or contaminants stored at the facility that may pose a threat
assessment which includes of release.
the collection or review of - High levels of hazardous substances or contaminants in surface soils that may
readily available information migrate.
such as site management - Weather conditions that may cause hazardous substances or contaminants to be
practices, information from released.
waste generator, document - Threat of fire or explosion.
review, and facility - The availability of appropriate release response mechanisms.
interviews.
If the removal action requires a planning period of greater than six months, verify that
b. A removal site inspection, if
the facility has developed the following:
necessary, to gather
- An Engineering Evaluation/Cost Analysis (EE/CA) on the removal alternatives for
information that was not
the site.
obtained during the removal
preliminary assessment. - A sampling and analysis plan that has been reviewed and approved by the EPA.
c. A removal action which is If removal actions have been implemented, determine whether the selected action, to
performed in response to a the extent practicable, has contributed to the anticipated long-term remedial action for
specific release. the release site.
Appendix A:
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
The list includes chemicals under the four following federal statutory provisions:
1. EPCRA Section 302 Extremely Hazardous Substances - The presence of extremely hazardous substances (EHSs) in
sufficient quantities requires certain emergency planning activities to be conducted. Releases of these substances are also
subject to reporting under Section 304 of EPCRA. The final rule listing the extremely hazardous substances and their
threshold planning quantities (TPQs), is found in 40 CFR 355.
2. CERCLA Hazardous Substances - Releases of CERCLA hazardous substances are subject to reporting under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) of 1980. Such
releases are also subject to reporting under Section 304 of EPCRA. CERCLA hazardous substances and their reportable
quantities (RQs) are listed in 40 CFR 302, Table 302.4.
3. EPCRA Section 313 Toxic Chemicals - Emissions or releases of EPCRA Section 313 toxic chemicals must be reported
annually as part of EPCRA’s community right-to-know provisions. A list of these toxic chemicals is found in 40 CFR
372.65.
4. RCRA Hazardous Wastes - The consolidated list includes specific chemicals from the RCRA P and U lists only (40 CFR
261.33). RCRA hazardous wastes from the “F” and “K” lists are not included here; such waste streams are also CERCLA
hazardous substances. This listing is provided as an indicator that you may already have data on a specific chemical that
can be used for EPCRA reporting.
There are four columns in the consolidated list corresponding to these four statutory provisions. If a chemical is listed as an
extremely hazardous substance under Section 302, its TPQ is given in the extremely hazardous substance column. Similarly,
the RQ is given for those chemicals that are listed as CERCLA hazardous substances. A key to the symbols used in the
Section 302 and CERCLA columns precedes the list. An “X” in the column for Section 313 indicates that the chemical is
subject to reporting under Section 313.
The letter-and-digit code in the column for 40 CFR 261.33 is the chemical’s RCRA hazardous waste code. A blank in any of
these columns indicates that the chemical is not subject to the corresponding statutory authorities.
The Chemical Abstract Service (CAS) registry number is provided for each chemical on the list.
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
* Indicates carbamate wastes under RCRA; statutory one pound RQ applies until RQs are adjusted.
# Indicates diisocyanates.
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
This is an alphabetical listing of the consolidated list of chemicals. Numbered chemicals are listed first.
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
1-Amino-2-methylanthraquinone x 82-28-0
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
1,2-Dichloroethylene x 540-59-0
1,3-Butadiene 10 x 106-99-0
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
2-Aminoanthraquinone x 117-79-3
2-Methoxyethanol x 109-86-4
2-Phenylphenol x 90-43-7
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
2,3,4-Trichlorophenol 10 15950-66-0
2,3,4,6-Tetrachlorophenol 10 58-90-2
2,3,5-Trichlorophenol 10 933-78-8
2,3,6-Trichlorophenol 10 933-75-5
2,4-Diaminotoluene 10 x 95-80-7
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
2,4,5-Trichlorophenol 10 x 95-95-4
2,4,6-Trichlorophenol 10 x 88-06-2
2,5-Dinitrophenol 10 329-71-5
2,6-Dinitrophenol 10 573-56-8
2,6-Xylidine x 87-62-7
3,4-Dinitrotoluene 10 610-39-9
3,4,5-Trichlorophenol 10 609-19-8
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
4-Aminoazobenzene x 60-09-3
4-Aminobiphenyl 1 x 92-67-1
4-Nitrobiphenyl 10 x 92-93-3
4,4'-Isopropylidenediphenol x 80-05-7
4,4'-Methylenedianiline 10 x 101-77-9
5-Nitro-o-anisidine x 99-59-2
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
alpha-Endosulfan 1 959-98-8
alpha-BHC 10 x 319-84-6
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Arsenic 1 x 7440-38-2
Asbestos 1 x 1332-21-4
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Benzamide x 55-21-0
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Benzo[b]fluoranthene 1 x+ 205-99-2
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
beta-Endosyulfan 1 33213-65-9
beta-BHC 1 319-85-7
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Butyraldehyde x 123-72-8
Cadmium 10 x 7440-43-9
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Captan 10 x 133-06-2
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Chlorotetrafluoroethane x 63938-10-3
Chlorothalonil x 1897-45-6
Chlorpyrifos 1 2921-88-2
Cobalt x 7440-48-4
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Cupferron x 135-20-6
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
DDE 1 72-55-9
Delta-BHC 1 319-86-8
Diazinon 1 x 333-41-5
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Dichlone 1 117-80-6
Dichloro-1,1,2-trifluoroethane x 90454-18-5
Dichlorotrifluoroethane x 34077-87-7
Dicofol 10 x 115-32-2
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Dinitrophenol 10 25550-58-7
Diphenylamine x 122-39-4
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Ethylene x 74-85-1
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Fluometuron x 2164-17-2
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Hexachloronaphthalene x 1335-87-1
Hexamethylphosphoramide 1 x 680-31-9
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Isobutyraldehyde x 78-84-2
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Lead 10 x 7439-92-1
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Lewisite 10 541-25-3
Maneb x 12427-38-2
Manganese x 7439-96-5
Mechlorethamine 10 x 51-75-2
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
N-Nitrosomorpholine 1 x 59-89-2
N-Nitrosonornicotine x 16543-55-8
Naled 10 x 300-76-5
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Nitrofen x 1836-75-5
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Octachloronaphthalene x 2234-13-1
p-Anisidine x 104-94-9
p-Cresidine x 120-71-8
p-Nitrosodiphenylamine x 156-10-5
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Pentachlorophenol 10 x 87-86-5
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Propargite 10 x 2312-35-8
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Pyrethrins 1 121-21-1
Pyrethrins 1 121-29-9
Pyrethrins 1 8003-34-7
Sarin 10 107-44-8
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Simazine x 122-34-9
Sodium 10 7440-23-5
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Tabun 10 77-81-6
Tetrachlorvinphos x 961-11-5
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Triaziquone x 68-76-8
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Trichlorophenol 10 25167-82-2
Trifluralin 10 x 1582-09-8
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
(NOTE: This list is constantly changing; consult the Federal Register for the most up-to-date information.)
Extremely Hazardous
Hazardous Toxic
Hazardous Materials
Substances Chemicals 40
Chemical Name Substances which are CAS No.
40 CFR 302.4 CFR
40 CFR 355 RCRA
(RQ, lbs.) 372.65(a)
(TPQ, lbs.) wastes
Zineb x 12122-67-7