WSR 15-15-108

PROPOSED RULES

[Order 15-01—Filed July 16, 2015, 10:32 a.m.]

Preproposal statement of inquiry was filed as WSR 15-07-014.

Title of Rule and Other Identifying Information: Ecology is proposing to revise chapter 173-351 WAC, Criteria for municipal solid waste landfills, by adding two hazardous organic constituents to Appendix III of WAC 173-351-990: 2,3,7,8-Tetrachlorodibenzo- p-dioxin - (CAS 1746-01-6) and alpha, alpha-Dimethylphenethylamine (CAS 122-09-8).

Hearing Location(s): Washington State Department of Ecology, 300 Desmond Drive S.E., Lacey, WA 98503, on August 27, 2015, at 3:00 p.m.

Date of Intended Adoption: September 22, 2015.

Submit Written Comments to: Kyle Dorsey, P.O. Box 47600, Olympia, WA 98504, e-mail kyle.dorsey@ecy.wa.gov, fax (360)407-6102, by September 8, 2015.

Assistance for Persons with Disabilities: Contact the waste 2 resources program by August 25, 2015, TTY (877) 833-6341 or (360) 407-6900. Persons with impaired hearing may call Washington relay service at 711.

Purpose of the Proposal and Its Anticipated Effects, Including Any Changes in Existing Rules: Revising chapter 173-351 WAC will clarify requirements for landfill operators, and enable ecology to obtain full approval of our municipal solid waste rules from the United States Environmental Protection Agency (EPA).

This revision is necessary to be consistent with federal rules in 40 C.F.R. Part 258. Operators of municipal solid waste landfills must meet federal program requirements. Revising our rule eliminates possible noncompliance for facilities that inadvertently omit the two additional constituents required by federal rules. It also clarifies monitoring requirements for local jurisdictional health authorities that have the lead for issuing and enforcing solid waste permits.

Ecology's municipal solid waste landfill program operates under partial approval from EPA. The addition of these two constituents will allow EPA to make a determination of full program adequacy. In turn, EPA will be able to approve the Research, Development and Demonstration (RD&D) element that is part of our current state program.

Reasons Supporting Proposal: EPA specifies criteria for municipal solid waste landfills under 40 C.F.R. Part 258. The state program is currently partially approved by EPA under 40 C.F.R. Part 239. The only identified barrier to full program approval of the state program is the lack of the two constituents identified in this rule proposal. EPA has said they will move forward with full program approval if ecology shows a commitment to make the changes in state rules proposed under this rule making. We have been coordinating with EPA, and legal counsel for both agencies have been involved. Local jurisdictional health authorities issue solid waste permits subject to ecology review. Local permits must at least meet state program requirements. Ecology has a communication strategy for this rule making that includes outreach to all municipal solid waste landfill operators, health jurisdictions, and impacted and interested parties.

Statutory Authority for Adoption: RCW 70.95.020 and 70.95.060.

Statute Being Implemented: Chapter 70.95 RCW.

Rule is necessary because of federal law, 40 C.F.R. Part 258 - Criteria for Municipal Solid Waste Landfills.

Agency Comments or Recommendations, if any, as to Statutory Language, Implementation, Enforcement, and Fiscal Matters: Chapter 173-351 WAC establishes state requirements for the design and operation of municipal solid waste landfills. Applicable requirements are implemented through permits issued by local jurisdictional health authorities who serve as the first and primary agencies to implement and enforce the rules. The department of ecology provides technical assistance and reviews permits issued by local health authorities.

Name of Proponent: Washington state department of ecology, governmental.

Name of Agency Personnel Responsible for Drafting: Kyle Dorsey, Lacey, Washington, (360) 407-6559; Implementation: Wayne Krafft, Spokane, Washington, (509) 329-3438; and Enforcement: Laurie G. Davies, Lacey, Washington, (360) 407-6103.

Executive Summary: Based on research and analysis required by the Regulatory Fairness Act (RFA), RCW 19.85.070, ecology has determined that the proposed rule, criteria for municipal solid waste landfills (chapter 173-351 WAC) does not have disproportionate impacts on small businesses. The RFA directs ecology to determine if there is likely to be disproportionate impact, and if legal and feasible, reduce this disproportionate impact.

The small business economic impact statement (SBEIS) is intended to be read with the associated cost-benefit analysis (Ecology publication # 15-07-027), which contains more in-depth discussion of the analysis.

The proposed rule amendments add two chemicals to the Appendix III list in WAC 173-351-990. These chemicals are 2,3,7,8 TCDD (2,3,7,8-Tetrachlorodibenzo-p-dioxin, CAS 1746-01-6) and Phentermine (alpha,alpha-Dimethylphenethylamine, CAS 122-09-8). No other changes are proposed.

When the operator of a municipal solid waste landfill finds a statistically significant increase in a contaminant listed in Appendix I of WAC 173-351-990, during routine detection monitoring, the landfill must then perform additional assessment monitoring for the expanded list of chemicals in Appendix III.

Most municipal solid waste landfills (MSWLF) are owned and operated by government entities (cities, counties, federal government), but five are owned and operated by private businesses, and one of these is a small business. The small business is not currently in assessment monitoring. This means that the proposed rule does not impose costs on small businesses, as they currently exist and operate.

The proposed rule does not impose disproportionately large costs on small businesses. Ecology is therefore not required to include cost-mitigating elements in the proposed rule.

We estimated that there would be relatively little net change in jobs, statewide over twenty years. This is because the majority of compliance costs are a transfer to the testing laboratory industry. The precise number estimated by the model is between a gain of 0.33 and a loss of nearly four full-time employees (FTE) for the duration of the analysis. This likely small impact is due to the proposed rule's direct compliance costs, based on the total present-value costs to landfills, and the transfer of some payments to laboratories. This includes direct job impacts in the landfill industry, as well as indirect impacts to all other private industry in the state.

Section 1: Background and Introduction:

1.1 Introduction: Based on research and analysis required by RFA, RCW 19.85.070, ecology has determined that the proposed rule, criteria for MSWLFs (chapter 173-351 WAC) does not have disproportionate impacts on small businesses. The RFA directs ecology to determine if there is likely to be disproportionate impact, and if legal and feasible, reduce this disproportionate impact.

The SBEIS is intended to be read with the associated cost-benefit analysis (Ecology publication # 15-07-027), which contains more in-depth discussion of the analysis.

1.2 Description of the proposed rule amendments: The proposed rule amendments add two chemicals to the Appendix III list in WAC 173-351-990. These chemicals are 2,3,7,8 TCDD (2,3,7,8-Tetrachlorodibenzo-p-dioxin, CAS 1746-01-6) and Phentermine (alpha,alpha-Dimethylphenethylamine, CAS 122-09-8). No other changes are proposed.

When the operator of a MSWLF finds a statistically significant increase in a contaminant listed in Appendix I of WAC 173-351-990, during routine detection monitoring, the landfill must then perform additional assessment monitoring for the expanded list of chemicals in Appendix III.

1.3 Reasons for the proposed rule amendments: Ecology previously amended chapter 173-351 WAC, Criteria for municipal solid waste landfills, in 2012, but omitted two potential pollutants listed in the equivalent federal rules (40 C.F.R. Part 258). Due to this omission:

Ecology is therefore proposing rule amendments that would bring the rule in line with the federal rule, and allow for full federal approval of the state program, as well as appropriate monitoring at sites that trigger broader assessment monitoring.

Section 2: Analysis of Compliance Costs for Washington Businesses:

2.1 Introduction: We analyzed the impacts of the proposed rule relative to the baseline of the existing rule, within the context of all existing requirements (federal and state laws and rules). This context for comparison is called the baseline, and reflects the most likely regulatory circumstances that MSWLFs would face if the proposed rule were not adopted. It is discussed in detail in Section 2.2, below.

2.2 Baseline: The baseline for our analyses generally consists of existing rules and laws, and their requirements. For economic analyses, the baseline also includes the implementation of those regulations, including any guidelines and policies that result in behavior changes and real impacts. This is what allows us to make a consistent comparison between the state of the world with or without the proposed rule amendments. In this case we will assume that landfills required to perform assessment monitoring have already incurred an obligation from the federal rules to perform an annual monitoring event, and semi-annual monitoring for any constituents identified in the annual event. Therefore the increment resulting from proposed changes in state program rules will be two analytical events as the state requires quarterly instead of semi-annual monitoring. For this rule making, we discuss the baseline below, including the:

2.3 Proposed rule amendments: The proposed rule amendments are intended to make the list of contaminants that MSWLFs must evaluate under assessment monitoring (if they trigger it) consistent with the list in the federal rule. Specifically, the proposed rule would add 2,3,7,8-Tetrachlorodibenzo-p-dioxin (CAS 1746-01-6) and alpha,alpha-Dimethylphenethylamine (CAS 122-09-8) to the Appendix III list of contaminants.

Only one requirement of the proposed and existing state rules differs from the federal rule: Quarterly rather than twice-yearly assessment monitoring. The proposed amendments mean that a landfill which triggers assessment monitoring and finds one or both contaminants in its initial assessment or during an annual assessment thereafter, would have to analyze for them twice more per year than the minimum under the federal rules. Landfills that do not find these potential pollutants in their preliminary or annual assessment monitoring are not required to analyze for them quarterly during the rest of the year. All of the other requirements of the proposed rule are the same as those in the existing rule, and we do not expect any additional changes in behavior to result from the proposed rule.

2.4 Monitoring costs: There are twenty-five landfills operating in Washington state that might be, or are, presently subject to groundwater assessment monitoring under the baseline. These landfills are open and accepting municipal solid waste, or were closed under the baseline rule and are subject to postclosure care requirements that include groundwater monitoring. Of these, twelve landfills are currently performing assessment monitoring.

As discussed in Chapter 2, the proposed rule will potentially generate only one change in behavior: An increase in monitoring of two events per year (four quarterly rather than two annual) for the two chemicals ecology is proposing to add to Appendix III of the rule language.

2.4.1 Number of wells: Table 1 summarizes the numbers and circumstances of wells for this analysis.

2.4.2 Testing costs: We contacted six labs requesting typical retail costs for analysis of 2,3,7,8-TCDD and Phentermine. Only two labs provided costs, consistent with one another and ecology's general expectation from professional experience. The estimated incremental costs were:

If we assume that all facilities currently performing assessment monitoring will find dioxin in annual assessment monitoring events, then an additional one hundred sixty wells would be included at an additional $500 cost twice per year. Ecology looks at a twenty year timeframe in its analysis (to include short- and long-term impacts), and this additional $160 thousand annual cost translates to approximately $2.8 million in present value cost over twenty years (2016 through 2035), at a real discount rate of 1.21 percent.1

There are seventy-five remaining wells at facilities that are not currently performing assessment monitoring. While ecology believes it is unlikely that these additional wells will all enter assessment monitoring in the future, an additional seventy-five wells would increase costs proportionally by forty-seven percent, or $1.3 million in present value testing costs over twenty years. For illustration, each additional well entering assessment monitoring would increase costs by less than one percent.

2.4.3 Labor costs: Monitoring requires additional professional and administrative effort as well, including:

Sampling costs: We assumed that a professional engineer or environmental technician [needs] between fifteen and thirty minutes per well to take samples. As additional monitoring would only be necessary at landfills that are already performing assessment monitoring, we did not include costs such as travel to the landfill, as they would already be incurred under the baseline. It is important to note that only 2,3,7,8-TCDD monitoring would require additional sampling, as sampling for Phentermine testing would already be covered by existing sampling for semi-volatile contaminants under the baseline.

The median wage for environmental engineers is currently $43.36 per hour, and is $31.74 per hour for environmental technicians.2 As this activity is likely to be performed as part of regular internal job duties, we did not include an overhead premium.

Total sampling costs for one hundred sixty wells at the wages and times above lead to an estimated annual cost of approximately $2.500 [$2,500] to $6,900 per year. Ecology looks at a twenty year timeframe in its analysis (to include short- and long-term impacts), and this additional annual cost translates to an approximate $45 thousand to $123 thousand in present value cost over twenty years (2016 through 2035), at a real discount rate of 1.21 percent.3

There are seventy-five remaining wells at facilities that are not currently performing assessment monitoring. While ecology believes it is unlikely that these additional wells will all enter assessment monitoring in the future, an additional seventy-five wells would increase costs proportionally by forty-seven percent, or $21 thousand to $57 thousand in present value sampling costs over twenty years. For illustration, each additional well entering assessment monitoring would increase costs by less than one percent.

Analytical costs: Analytic labor costs for this analysis were assumed to be included in lab costs, discussed above in section 3.2.2. The lab would perform all necessary analytic work for the landfill.

Reporting and recordkeeping costs: We conservatively assumed an environmental technician or professional engineer would require an additional thirty minutes to one hour, per well, per additional monitoring event, for recordkeeping and reporting.

The median wage for environmental engineers is currently $43.36 per hour, and is $31.74 per hour for environmental technicians.4 As this activity is likely to be performed as part of regular internal job duties, we did not include an overhead premium.

Total recordkeeping and reporting costs for one hundred sixty wells at the wages and times above lead to an estimated annual cost of approximately $5,100 to $13,900 per year. Ecology looks at a twenty year timeframe in its analysis (to include short- and long-term impacts), and this additional annual cost translates to an approximate $90 thousand to $245 thousand in present value cost over twenty years (2016 through 2035), at a real discount rate of 1.21 percent.5

There are seventy-five remaining wells at facilities that are not currently performing assessment monitoring. While ecology believes it is unlikely that these additional wells will all enter assessment monitoring in the future, an additional seventy-five wells would increase costs proportionally by forty-seven percent, or $42 thousand to [$]115 thousand in present value reporting and recordkeeping costs over twenty years. For illustration, each additional well entering assessment monitoring would increase costs by less than one percent.

2.5 Summary of the likely compliance costs of the proposed rule amendments: We estimated the costs of requiring an additional two samples per year under assessment monitoring for the two pollutants proposed to be added to the state rule. There are two important assumptions here. First, we did not speculate on landfills that might be required to monitor in the future. While this may under predict costs, we also did not account for landfills that would complete assessment monitoring and drop out of the calculation. Further, it seems unlikely that all facilities will eventually be required to perform assessment monitoring, and even if so, certainly not for dioxin in every case. Secondly, for those landfills currently performing assessment monitoring, we assumed that all wells not currently analyzed for dioxin would have to be analyzed an additional two times per year. Ecology expects few to find dioxin. Therefore, the estimates below are very conservative (high end costs). Table 2 summarizes those costs of the proposed rule.

Section 3: Quantification of Cost Ratios:

3.1 Introduction: This analysis would normally estimate and compare the compliance costs per employee at small versus large (the largest ten percent) businesses. The proposed rule does not, however, impose new costs on small businesses. We describe, in this section, the affected and unaffected businesses, and make the required comparison of costs per employee at large businesses, to the zero new compliance cost to small businesses under the proposed rule.

3.2 Affected businesses: Most MSWLFs are owned and operated by government entities (cities, counties, federal government), but five are owned and operated by private businesses, and one of these is a small business. The small business is not currently in assessment monitoring. This means that the proposed rule does not impose costs on small businesses, as they currently exist and operate.

3.3 Cost-to-employee ratios: Ecology found constant ranges of compliance costs, based on the total number of wells sampled (see Section 2). The number of wells actually affected at a large facility is difficult to determine, due to different types of well[s], as well as multiple-use wells. Consequently, we estimated costs across all twenty-five facilities, based on the total number of wells.

The proposed rule does not impose disproportionately large costs on existing small businesses in an industry.

Section 4: Actions Taken to Reduce the Impact of the Rule on Small Businesses: The proposed rule does not impose disproportionately large costs on small businesses. Ecology is therefore not required to include cost-mitigating elements in the proposed rule.

Section 5: The Involvement of Small Businesses and Local Government in the Development of the Proposed Rule: Ecology involved landfill owners and operators in the development of this limited rule making. A list of affected facilities is provided in the table below. Ecology also notified more than two hundred members of a listserv specifically maintained for those interested in revisions to chapter 173-351 WAC.

Section 6: The SIC Codes of Impacted Industries: The SIC (Standard Industry Classification) system has long been replaced by the North American Industry Classification System (NAICS). The proposed rule specifically applies to landfills, NAICS code 5622.

Section 7: Impacts on Jobs: We used the Washington state office of financial management's 2002 Washington input-output model (OFM-IO) to estimate the proposed rule's first-round impact on jobs across the state. This methodology estimates the impact as reductions or increases in spending in certain sectors of the state economy flow through to purchases, suppliers, and demand for other goods. Compliance costs incurred by an industry are entered in the OFM-IO model as a decrease in spending and investment. If that money is spent in another industry (in this case, it is in part spent on laboratory analysis), it is entered in the model as an increase in production.

We estimated that there would be relatively little net change in jobs, statewide over twenty years. This is because the majority of compliance costs are a transfer to the testing laboratory industry. The precise number estimated by the model is between a gain of 0.33 and a loss of nearly four FTEs for the duration of the analysis. This likely small impact is due to the proposed rule's direct compliance costs, based on the total present-value costs to landfills, and the transfer of some payments to laboratories. This includes direct job impacts in the landfill industry, as well as indirect impacts to all other private industry in the state.

As with transfers of funds across industries, while there is likely to be a job loss of fewer than four FTEs statewide, the model also estimates primarily losses of between twenty-four and twenty-six FTEs in waste management jobs, and gains of nineteen laboratory services-related jobs, as well as their employment spending on retail goods, healthcare, and food good[s] and services adding to approximately five jobs across multiple industries.

A copy of the statement may be obtained by contacting Kirsten Miller, Washington State Department of Ecology, Waste 2 Resources Program, P.O. Box 47600, Olympia, WA 98504-7600, phone (360) 407-6707, fax (360) 407-6102, e-mail kirsten.miller@ecy.wa.gov.

A cost-benefit analysis is required under RCW 34.05.328. A preliminary cost-benefit analysis may be obtained by contacting Kirsten Miller, Washington State Department of Ecology, Waste 2 Resources Program, P.O. Box 47600, Olympia, WA 98504-7600, phone (360) 407-6707, fax (360) 407-6102, e-mail kirsten.miller@ecy.wa.gov.

July 15, 2015

Polly Zehm

Deputy Director

COMMON NAME 1		CAS RN 2
Inorganic Constituents
1)	Antimony. . . .(Total)
2)	Arsenic. . . .(Total)
3)	Barium. . . .(Total)
4)	Beryllium. . . .(Total)
5)	Cadmium. . . .(Total)
6)	Chromium. . . .(Total)
7)	Cobalt. . . .(Total)
8)	Copper. . . .(Total)
9)	Lead. . . .(Total)
10)	Nickel. . . .(Total)
11)	Selenium. . . .(Total)
12)	Silver. . . .(Total)
13)	Thallium. . . .(Total)
14)	Vanadium. . . .(Total)
15)	Zinc. . . .(Total)
16)	Nitrate. . . .
Organic Constituents
17)	Acetone. . . .67-64-1
18)	Acrylonitrile. . . .107-13-1
19)	Benzene. . . .71-43-2
20)	Bromochloromethane. . . .74-97-5
21)	Bromodichloromethane. . . .75-27-4
22)	Bromoform; Tribromomethane. . . .75-25-2
23)	Carbon disulfide. . . .75-15-0
24)	Carbon tetrachloride. . . .56-23-5
25)	Chlorobenzene. . . .108-90-7
26)	Chloroethane; Ethyl chloride. . . .75-00-3
27)	Chloroform; Trichloromethane. . . .67-66-3
28)	Dibromochloromethane; Chlorodibromomethane. . . .124-48-1
29)	1,2-Dibromo-3-chloropropane; DBCP. . . .96-12-8
30)	1,2-Dibromoethane; Ethylene dibromide; EDB. . . .106-93-4
31)	o-Dichlorobenzene; 1,2-Dichlorobenzene. . . .95-50-1
32)	p-Dichlorobenzene; 1,4-Dichlorobenzene. . . .106-46-7
33)	trans-1,4-Dichloro-2-butene. . . .110-57-6
34)	1,1-Dichloroethane; Ethylidene chloride. . . .75-34-3
35)	1,2-Dichloroethane; Ethylene dichloride. . . .107-06-2
36)	1,1-Dichloroethylene; 1,1-Dichloroethene; Vinylidene chloride. . . .75-35-4
37)	cis-1,2-Dichloroethylene; cis-1,2-Dichloroethene. . . .156-59-2
38)	trans-1,2-Dichloroethylene; trans-1,2-Dichloroethene. . . .156-60-5
39)	1,2-Dichloropropane; Propylene dichloride. . . .78-87-5
40)	cis-1,3-Dichloropropene. . . .10061-01-5
41)	trans-1,3-Dichloropropene. . . .10061-02-6
42)	Ethylbenzene. . . .100-41-4
43)	2-Hexanone; Methyl butyl ketone. . . .591-78-6
44)	Methyl bromide; Bromomethane. . . .74-83-9
45)	Methyl chloride; Chloromethane. . . .74-87-3
46)	Methylene bromide; Dibromomethane. . . .74-95-3
47)	Methylene chloride; Dichloromethane. . . .75-09-2
48)	Methyl ethyl ketone; MEK; 2-Butanone. . . .78-93-3
49)	Methyl iodide; lodomethane. . . .74-88-4
50)	4-Methyl-2-pentanone; Methyl isobutyl ketone. . . .108-10-1
51)	Styrene. . . .100-42-5
52)	1,1,1,2-Tetrachloroethane. . . .630-20-6
53)	1,1,2,2-Tetrachloroethane. . . .79-34-5
54)	Tetrachloroethylene; Tetrachloroethene; Perchloroethylene. . . .127-18-4
55)	Toluene. . . .108-88-3
56)	1,1,1-Trichloroethane; Methyl chloroform. . . .71-55-6
57)	1,1,2-Trichloroethane. . . .79-00-5
58)	Trichloroethylene; Trichloroethene. . . .79-01-6
59)	Trichlorofluoromethane; CFC-11. . . .75-69-4
60)	1,2,3-Trichloropropane. . . .96-18-4
61)	Vinyl acetate. . . .108-05-4
62)	vinyl chloride. . . .75-01-4
63)	Xylenes. . . .1330-20-7

Field Parameters
pH
specific conductance
temperature
static water level
Geochemical Indicator Parameters
Calcium (Ca)	Sodium (Na)
Bicarbonate (HCO3)	Chloride (Cl)
Magnesium (Mg)	Potassium (K)
Sulfate (SO4)	Alkalinity (as Ca CO3)
Total suspended solids (TSS)	Iron (Fe) (Dissolved)
	Manganese (Mn) (Dissolved)
Leachate Indicators
Ammonia (NH3-N)
Total Organic Carbon (TOC)
Total Dissolved Solids (TDS)

Common Name1	CAS RN2	Chemical abstracts service index name3
Acenaphthene	83-32-9	Acenaphthylene, 1,2-dihydro-
Acenaphthylene	208-96-8	Acenaphthylene
Acetone	67-64-1	2-Propanone
Acetonitrile; Methyl cyanide	75-05-8	Acetonitrile
Acetophenone	98-86-2	Ethanone, 1-phenyl-
2-Acetylaminofluorene; 2-AAF	53-96-3	Acetamide, N-9H-fluoren-2-yl-
Acrolein	107-02-8	2-Propenal
Acrylonitrile	107-13-1	2-Propenenitrile
Aldrin	309-00-2	1,4:5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexachloro-1,4,4a,5,8,8a-hexahydro- (1α,4α,4aβ,5α,8α,8aβ)-
Allyl chloride	107-05-1	1-Propene, 3-chloro-
4-Aminobiphenyl	92-67-1	[1,1 1 -Biphenyl]-4-amine
Anthracene	120-12-7	Anthracene
Antimony	(Total)	Antimony
Arsenic	(Total)	Arsenic
Barium	(Total)	Barium
Benzene	71-43-2	Benzene
Benzo[a]anthracene; Benzanthracene	56-55-3	Benz[a]anthracene
Benzo[b]fluoranthene	205-99-2	Benz[e]acephenanthrylene
Benzo[k]fluoranthene	207-08-9	Benzo[k]fluoranthene
Benzo[ghi]perylene	191-24-2	Benzo[ghi]perylene
Benzo[a]pyrene	50-32-8	Benzo[a]pyrene
Benzyl alcohol	100-51-6	Benzenemethanol
Beryllium	(Total)	Beryllium
alpha-BHC	319-84-6	Cyclohexane, 1,2,3,4,5,6-hexachloro-, (1α,2α,3β,4α,5β,6β)-
beta-BHC	319-85-7	Cyclohexane, 1,2,3,4,5,6-hexachloro-, (1α,2β,3α,4β,5α,6β)-
delta-BHC	319-86-8	Cyclohexane, 1,2,3,4,5,6-hexachloro-, (1α,2α,3α,4β,5α,6β)-
gamma-BHC; Lindane	58-89-9	Cyclohexane, 1,2,3,4,5,6-hexachloro-, (1α,2α,3β,4α,5α,6β)-
Bis(2-chloroethoxy)methane	111-91-1	Ethane, 1,1 1 -[methylenebis(oxy)]bis[2-chloro-
Bis(2-chloroethyl) ether; Dichloroethyl ether	111-44-4	Ethane, 1,1 1 -oxybis[2-chloro-
Bis-(2-chloro-1-methylethyl) ether; 2,2 1 -	108-60-1	Propane, 2,2 1 -oxybis[1-chloro-
Dichlorodiisopropyl ether;
DCIP, See note 4
Bis(2-ethylhexyl) phthalate	117-81-7	1,2-Benzenedicarboxylic acid, bis(2-ethylhexyl) ester
Bromochloromethane; Chlorobromomethane	74-97-5	Methane, bromochloro-
Bromodichloromethane; Dibromochloromethane	75-27-4	Methane, bromodichloro-
Bromoform; Tribromomethane	75-25-2	Methane, tribromo-
4-Bromophenyl phenyl ether	101-55-3	Benzene, 1-bromo-4-phenoxy-
Butyl benzyl phthalate; Benzyl butyl phthalate	85-68-7	1,2-Benzenedicarboxylic acid, butyl phenylmethyl ester
Cadmium	(Total)	Cadmium
Carbon disulfide	75-15-0	Carbon disulfide
Carbon tetrachloride	56-23-5	Methane, tetrachloro-
Chlordane	See Note 5	4,7-Methano-1H-indene, 1,2,4,5, 6,7,8,8-octachloro-2,3,3a,4,7, 7a-hexahydro-
p-Chloroaniline	106-47-8	Benzenamine, 4-chloro-
Chlorobenzene	108-90-7	Benzene, chloro-
Chlorobenzilate	510-15-6	Benzeneacetic acid, 4-chloro-α-(4-chlorophenyl)-α-hydroxy-, ethyl ester
p-Chloro-m-cresol; 4-Chloro-3-methylphenol	59-50-7	Phenol, 4-chloro-3-methyl-
Chloroethane; Ethyl chloride	75-00-3	Ethane, chloro-
Chloroform; Trichloromethane	67-66-3	Methane, trichloro-
2-Chloronaphthalene	91-58-7	Naphthalene, 2-chloro-
2-Chlorophenol	95-57-8	Phenol, 2-chloro-
4-Chlorophenyl phenyl ether	7005-72-3	Benzene, 1-chloro-4-phenoxy-
Chloroprene	126-99-8	1,3-Butadiene, 2-chloro-
Chromium	(Total)	Chromium
Chrysene	218-01-9	Chrysene
Cobalt	(Total)	Cobalt
Copper	(Total)	Copper
m-Cresol; 3-methylphenol	108-39-4	Phenol, 3-methyl-
o-Cresol; 2-methylphenol	95-48-7	Phenol, 2-methyl-
p-Cresol; 4-methylphenol	106-44-5	Phenol, 4-methyl-
Cyanide	57-12-5	Cyanide
2,4-D; 2,4-Dichlorophenoxyacetic acid	94-75-7	Acetic acid, (2,4-dichlorophenoxy)-
4,4'-DDD	72-54-8	Benzene 1,1 1 -(2,2-dichloroethylidene)bis[4-chloro-
4,4'-DDE	72-55-9	Benzene, 1,1 1 -(dichloroethyenylidene)bis[4-chloro-
4,4'-DDT	50-29-3	Benzene, 1,1 1 -(2,2,2-trichloroethylidene)bis[4-chloro-
Diallate	2303-16-4	Carbamothioic acid, bis(1-methylethyl)-,S-(2,3-dichloro-2-propenyl) ester
Dibenz[a,h]anthracene	53-70-3	Dibenz[a,h]anthracene
Dibenzofuran	132-64-9	Dibenzofuran
Dibromochloromethane; Chlorodibromomethane	124-48-1	Methane, dibromochloro-
1,2-Dibromo-3-chloropropane; DBCP	96-12-8	Propane, 1,2-dibrome-3-chloro-
1,2-Dibromoethane; Ethylene dribromide; EDB	106-93-4	Ethane, 1,2-dibromo-
Di-n-butyl phthalate	84-74-2	1,2-Benzenedicarboxylic acid, dibutyl ester
o-Dichlorobenzene; 1,2-Dichlorobenzene	95-50-1	Benzene, 1,2-dichloro-
m-Dichlorobenzene; 1,3-Dichlorobenzene	541-73-1	Benzene, 1,3-Dichloro-
p-Dichlorobenzene; 1,4-Dichlorobenzene	106-46-7	Benzene, 1,4-dichloro-
3,3'-Dichlorobenzidine	91-94-1	[1,1 1 -Biphenyl]-4,4 1 -diamine, 3,3 1 -dichloro-
trans-1,4-Dichloro-2-butene	110-57-6	2-Butene, 1,4-dichloro-, (E)-
Dichlorodifluoromethane; CFC 12;	75-71-8	Methane, dichlorodifluoro-
1,1-Dichloroethane; Ethyldidene chloride	75-34-3	Ethane, 1,1-dichloro-
1,2-Dichloroethane; Ethylene dichloride	107-06-2	Ethane, 1,1-dichloro-
1,1-Dichloroethylene; 1,1-Dichloroethene; Vinylidene chloride	75-35-4	Ethene, 1,1-dichloro-
cis-1,2-Dichloroethylene; cis-1,2-Dichloroethene	156-59-2	Ethene, 1,2-dichloro-, (Z)-
trans-1,2-Dichloroethylene; trans-1,2-Dichloroethene	156-60-5	Ethene, 1,2-dichloro-, (E)-
2,4-Dichlorophenol	120-83-2	Phenol, 2,4-dichloro-
2,6-Dichlorophenol	87-65-0	Phenol, 2,6-dichloro-
1,2-Dichloropropane; Propylene dichloride	78-87-5	Propane, 1,2-dichloro-
1,3-Dichloropropane; Trimethylene dichloride	142-28-9	Propane, 1,3-dichloro-
2,2-Dichloropropane; Isopropylidene chloride	594-20-7	Propane, 2,2-dichloro-
1,1-Dichloropropene	563-58-6	1-Propene, 1,1-dichloro-
cis-1,3-Dichloropropene	10061-01-5	1-Propene, 1,3-dichloro-, (Z)-
trans-1,3-Dichloropropene	10061-02-6	1-Propene, 1,3-dichloro-, (E)-
Dieldrin	60-57-1	2,7:3,6-Dimethanonaphth[2,3-b]oxirene, 3,4,5,6,9,9-hexa, chloro-1a,2,2a,3,6,6a,7,7a-octahydro-, (1aα,2β,2aα,3β,6β, 6aα,7β,7aα)-
Diethyl phthalate	84-66-2	1,2-Benzenedicarboxylic acid, diethyl ester
0,0-Diethyl 0-2-pyrazinyl phosphorothioate; Thionazin	297-97-2	Phosphorothioic acid, 0,0-diethyl 0-pyrazinyl ester
Dimethoate	60-51-5	Phosphorodithioic acid, 0,0-dimethyl S-[2-(methylamino)-2-oxoethyl] ester
p-(Dimethylamino)azobenzene	60-11-7	Benzenamine, N,N-dimethyl-4-(phenylazo)-
7,12-Dimethylbenz[a]anthracene	57-97-6	Benz[a]anthracene, 7,12-dimethyl-
3,3'-Dimethylbenzidine	119-93-7	[1,1 1 -Biphenyl]-4,4 1 -diamine, 3,3 1 -dimethyl-
alpha, alpha-Dimethylphenethylamine	122-09-8	Benzeneethanamine, α,α-dimethyl-
2,4-Dimethylphenol; m-Xylenol	105-67-9	Phenol, 2,4-dimethyl-
Dimethyl phthalate	131-11-3	1,2-Benzenedicarboxylic acid, dimethyl ester
m-Dinitrobenzene	99-65-0	Benzene, 1,3-dinitro-
4,6-Dinitro-o-cresol 4,6-Dinitro-2-methylphenol	534-52-1	Phenol, 2-methyl-4,6-dinitro
2,4-Dinitrophenol;	51-28-5	Phenol, 2,4-dinitro-
2,4-Dinitrotoluene	121-14-2	Benzene, 1-methyl-2,4-dinitro-
2,6-Dinitrotoluene	606-20-2	Benzene, 2-methyl-1,3-dinitro-
Dinoseb; DNBP; 2-sec-Butyl-4,6-dinitrophenol	88-85-7	Phenol, 2-(1-methylpropyl)-4,6-dinitro-
Di-n-octyl phthalate	117-84-0	1,2-Benzenedicarboxylic acid, dioctyl ester
Diphenylamine	122-39-4	Benzenamine, N-phenyl-
Disulfoton	298-04-4	Phosphorodithioic acid, 0,0-diethyl S-[2-(ethylthio)ethyl] ester
Endosulfan I	959-98-8	6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10,10-hexa-chloro-1,5,5a,6,9,9a-hexahydro-, 3-oxide,
Endosulfan II	33213-65-9	6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10, 10-hexa- chloro-1,5,5a,6,9,9a-hexahydro-, 3-oxide, (3α,5aα, 6β,9β,9aα)-
Endosulfan sulfate	1031-07-8	6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10, 10-hexa- chloro-1,5,5a,6,9,9a-hexahydro-,3-3-dioxide
Endrin	72-20-8	2,7:3,6-Dimethanonaphth[2,3-b]oxirene, 3,4,5,6,9,9-hexachloro-1a,2,2a,3,6,6a,7,7a-octahydro-, (1aα, 2β,2aβ,3α,6α, 6aβ,7β,7aα)-
Endrin aldehyde	7421-93-4	1,2,4-Methenocyclopenta[cd]pentalene-5-carboxaldehyde, 2,2a,3,3,4,7-hexachlorodecahydro-, (1α,2β, 2aβ,4β,4aβ,5β,6aβ,6bβ,7R*)-
Ethylbenzene	100-41-4	Benzene, ethyl-
Ethyl methacrylate	97-63-2	2-Propenoic acid, 2-methyl-, ethyl ester
Ethyl methanesulfonate	62-50-0	Methanesulfonic acid, ethyl ester
Famphur	52-85-7	Phosphorothioic acid, 0-[4-[(dimethylamino)sulfonyl]pheny l] 0,0-dimethyl ester
Fluoranthene	206-44-0	Fluoranthene
Fluorene	86-73-7	9H-Fluorene
Heptachlor	76-44-8	4,7-Methano-1H-indene, 1,4,5,6, 7,8,8-heptachloro-3a,4,7,7a-tetrahydro-
Heptachlor epoxide	1024-57-3	2,5-Methano-2H-indeno[1,2-b]oxirene, 2,3,4,5,6,7,7-heptachloro-1a,1b,5,5a,6,6a-hexahydro-, (1aα, 1bβ, 2α, 5α, 5aβ, 6β, 6aα)
Hexachlorobenzene	118-74-1	Benzene, hexachloro-
Hexachlorobutadiene	87-68-3	1,3-Butadiene, 1,1,2,3,4,4-hexachloro-
Hexachlorocyclopentadiene	77-47-4	1,3-Cyclopentadiene, 1,2,3,4,5, 5-hexachloro-
Hexachloroethane	67-72-1	Ethane, hexachloro-
Hexachloropropene	1888-71-7	1-Propene, 1,1,2,3,3,3-hexachloro-
2-Hexanone; Methyl butyl ketone	591-78-6	2-Hexanone
Indeno(1,2,3-cd)pyrene	193-39-5	Indeno(1,2,3-cd)pyrene
Isobutyl alcohol	78-83-1	1-Propanol, 2-methyl-
Isodrin	465-73-6	1,4,5,8-Dimethanonaphthalene,1, 2,3,4,10,10- hexachloro-1,4,4a, 5,8,8a hexahydro- (1α,4α,4aβ, 5β,8β,8aβ)-
Isophorone	78-59-1	2-Cyclohexen-1-one, 3,5,5-trimethyl-
Isosafrole	120-58-1	1,3-Benzodioxole, 5-(1-propenyl)-
Kepone	143-50-0	1,3,4-Metheno-2H-cyclobuta[cd]pentalen-2-one, 1, 1a,3,3a,4,5,5,5a,5b,6-decachlorooctahydro-
Lead	(Total)	Lead
Mercury	(Total)	Mercury
Methacrylonitrile	126-98-7	2-Propenenitrile, 2-methyl-
Methapyrilene	91-80-5	1,2-Ethanediamine, N.N-dimethyl-N 1 -2-pyridinyl-N1/2-thienylmethyl)-
Methoxychlor	72-43-5	Benzene,1,1 1 -(2,2,2, trichloroethylidene)bis[4-methoxy-
Methyl bromide; Bromomethane	74-83-9	Methane, bromo-
Methyl chloride; Chloromethane	74-87-3	Methane, chloro-
3-Methylcholanthrene	56-49-5	Benz[j]aceanthrylene, 1,2-dihydro-3-methyl-
Methyl ethyl ketone; MEK; 2-Butanone	78-93-3	2-Butanone
Methyl iodide; Iodomethane	74-88-4	Methane, iodo-
Methyl methacrylate	80-62-6	2-Propenoic acid, 2-methyl-, methyl ester
Methyl methanesulfonate	66-27-3	Methanesulfonic acid, methyl ester
2-Methylnaphthalene	91-57-6	Naphthalene, 2-methyl-
Methyl parathion; Parathion methyl	298-00-0	Phosphorothioic acid, 0,0-dimethyl
4-Methyl-2-pentanone; Methyl isobutyl ketone	108-10-1	2-Pentanone, 4-methyl-
Methylene bromide; Dibromomethane	74-95-3	Methane, dibromo-
Methylene chloride; Dichloromethane	75-09-2	Methane, dichloro-
Naphthalene	91-20-3	Naphthalene
1,4-Naphthoquinone	130-15-4	1,4-Naphthalenedione
1-Naphthylamine	134-32-7	1-Naphthalenamine
2-Naphthylamine	91-59-8	2-Naphthalenamine
Nickel	(Total)	Nickel
o-Nitroaniline; 2-Nitroaniline	88-74-4	Benzenamine, 2-nitro-
m-Nitroaniline; 3-Nitroanile	99-09-2	Benzenamine, 3-nitro-
p-Nitroaniline; 4-Nitroaniline	100-01-6	Benzenamine, 4-nitro
Nitrobenzene	98-95-3	Benzene, nitro-
o-Nitrophenol; 2-Nitrophenol	88-75-5	Phenol, 2-nitro-
p-Nitrophenol; 4-Nitrophenol	100-02-7	Phenol, 4-nitro-
N-Nitrosodi-n-butylamine	924-16-3	1-Butanamine, N-butyl-N-nitroso-
N-Nitrosodiethylamine	55-18-5	Ethanamine, N-ethyl-N-nitroso-
N-Nitrosodimethylamine	62-75-9	Methanamine, N-methyl-N-nitroso-
N-Nitrosodiphenylamine	86-30-6	Benzenamine, N-nitroso-N-phenyl-
N-Nitrosodipropylamine; N-Nitroso-N-dipropylamine; Di-n-propylnitrosamine	621-64-7	1-Propanamine, N-nitroso-N-propyl-
N-Nitrosomethylethalamine	10595-95-6	Ethanamine, N-methyl-N-nitroso-
N-Nitrosopiperidine	100-75-4	Piperidine, 1-nitroso-
N-Nitrosopyrrolidine	930-55-2	Pyrrolidine, 1-nitroso-
5-Nitro-o-toluidine	99-55-8	Benzenamine, 2-methyl-5-nitro-
Parathion	56-38-2	Phosphorothioic acid, 0,0-diethyl 0-(4-nitrophenyl) ester
Pentachlorobenzene	608-93-5	Benzene, pentachloro-
Pentachloronitrobenzene	82-68-8	Benzene, pentachloronitro-
Pentachlorophenol	87-86-5	Phenol, pentachloro-
Phenacetin	62-44-2	Acetamide, N-(4-ethoxyphenl)
Phenanthrene	85-01-8	Phenanthrene
Phenol	108-95-2	Phenol
p-Phenylenediamine	106-50-3	1,4-Benzenediamine
Phorate	298-02-2	Phosphorodithioic acid, 0,0-diethyl S-[(ethylthio)methyl] ester
Polychlorinated biphenyls; PCBs; Aroclors	See Note 6	1,1'-Biphenyl, chloro derivatives
Pronamide	23950-58-5	Benzamide, 3,5-dichloro-N-(1,1-dimethyl-2-propynyl)-
Propionitrile; Ethyl cyanide	107-12-0	Propanenitrile
Pyrene	129-00-0	Pyrene
Safrole	94-59-7	1,3-Benzodioxole, 5-(2-propenyl)-
Selenium	(Total)	Selenium
Silver	(Total)	Silver
Silvex; 2,4,5-TP	93-72-1	Propanoic acid, 2-(2,4,5-trichlorophenoxy)-
Styrene	100-42-5	Benzene, ethenyl-
Sulfide	18496-25-8	Sulfide
2,4,5-T; 2,4,5-Trichlorophenoxyacetic acid	93-76-5	Acetic acid, (2,4,5-trichlorophenoxy)-
2,3,7,8-TCDD; 2,3,7,8-Tetrachlorodibenzo-p-dioxin	1746-01-6	Dibenzo[b,e][1,4]dioxin, 2,3,7,8-tetrachloro-
1,2,4,5-Tetrachlorobenzene	95-94-3	Benzene, 1,2,4,5-tetrachloro-
1,1,1,2-Tetrachloroethane	630-20-6	Ethane, 1,1,1,2-tetrachloro-
1,1,2,2-Tetrachloroethane	79-34-5	Ethane, 1,1,2,2-tetrachloro-
Tetrachloroethylene; Tetrachloroethene; Perchloroethylene	127-18-4	Ethene, tetrachloro-
2,3,4,6-Tetrachlorophenol	58-90-2	Phenol, 2,3,4,6-tetrachloro-
Thallium	(Total)	Thallium
Tin	(Total)	Tin
Toluene	108-88-3	Benzene, methyl-
o-Toluidine	95-53-4	Benzenamine, 2-methyl-
Toxaphene	See Note 7	Toxaphene
1,2,4-Trichlorobenzene	120-82-1	Benzene, 1,2,4-trichloro-
1,1,1-Trichloroethane; Methylchloroform	71-55-6	Ethane, 1,1,1-trichloro-
1,1,2-Trichloroethane	79-00-5	Ethane, 1,1,2-trichloro-
Trichloroethylene; Trichloroethene	79-01-6	Ethene, trichloro-
Trichlorofluoromethane; CFC-11	75-69-4	Methane, trichlorofluoro-
2,4,5-Trichlorophenol	95-95-4	Phenol, 2,4,5-trichloro-
2,4,6-Trichlorophenol	88-06-2	Phenol, 2,4,6-trichloro-
1,2,3-Trichloropropane	96-18-4	Propane, 1,2,3-trichloro-
0,0,0-Triethyl phosphorothioate	126-68-1	Phosphorothioic acid, 0,0,0-triethylester
sym-Trinitrobenzene	99-35-4	Benzene, 1,3,5-trinitro-
Vanadium	(Total)	Vanadium
Vinyl acetate	108-05-4	Acetic acid, ethenyl ester
Vinyl chloride; Chloroethene	75-01-4	Ethene, chloro-
Xylene (total)	See Note 8	Benzene, dimethyl-
Zinc	(Total)	Zinc