'United States   ' i
Environmental Protection
: Agency       j
Off ice of Toxic
SubstancesL (TS-779)
Washington, D.C. 2Q460
Revised'January 1991
 EPA 560/4-91-008
Toxic Chemical Release Inventory
Magnetic Media Submission
Instructions           !
Revised 1990 Version
Section |313
of the Emefg^ncy Planning dnd
Community pight-to-Kn|ow Act
! (Title III of tl|e Superfund Amendments
sand Reauthbrization Act of 1986)
• •»..••    ' i • - •  • .   ,      it

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                 MAGNETIC MEDIA REPORT SPECIFICATIONS FOR THE
                    TOXIC RELEASE,INVENTORY SYSTEM  (TRIS)


    This  document provides basic  specifications  for  the use  of magnetic media
to submit EPA Form R reports required by section 313 of the Emergency Planning
and Community Right-to-Know Act (Title III of the Superfund Amendments and
Reauthorization Act of 1986), Public Law 99-499.  The use of magnetic media
can be a convenient and timesaving way to submit required information.  The
specifications and requirements presented in this document supplement the
reporting requirements presented in the section 313 final rule (40 CFR Part
372).   Submission of magnetic media reports does not relieve the submitter
from any of the regulatory requirements of the section 313 final rule.

    Special Note  -- Availability  of  Commercial Software Packages.
       Several independent software firms are marketing computer systems
    to  assist  facilities  in  meeting  their  reporting  requirements under
    section 313.  Their software  products  may be designed to produce
    reports on magnetic media in  the format specified in  this document.
    EPA's Office of Toxic Substances,  Information Management Division will
    validate magnetic  media  formats  produced by  software  packages  upon the
    request of the vendors.   Facilities  should be cautious and select a
    software package that will produce a valid format.    To  obtain up to
    date  information concerning the  software packages which  EPA recognizes
    as  preparing valid magnetic media formats, contact the Emergency
    Planning and Community Right-to-Know Information Hotline, U.S. EPA, at
    (800) 535-0202 or  (703)  920-9877.

    A  complete Form R  report contains information on the  release of one toxic
chemical or chemical category listed in the section 313 final rule.   There is
no maximum or minimum number of reports that may be submitted on magnetic
media for each reporting facility.

    In many cases, magnetic  media can be submitted in lieu of the  hard copy
Form R.  While the rule allows the specific identity of chemicals to be
claimed  trade -secret,  however, you may not use magnetic media for submissions
in which chemical identity is claimed trade secret.   In addition,  reporting of
corrections to previously submitted section 313 data may not be made through
magnetic media.

    For detailed  instructions concerning reporting requirements, calculation
of thresholds and releases,  and assembly of required data,  see the Toxic
Chemical Release Inventory Reporting Form R and Instructions, document number
EPA 560/4-91-007, revised January 1991.   The instruction document is also
contained in the Toxic Chemical Release Inventory Reporting Package,  document
number EPA 560/4-91-001.   For more information on section 313,  contact the
Emergency Planning and Community Right-to-Know Information Hotline,  U.S.  EPA,
at  (800) 535-0202 or  (703)  920-9877.

    States are not required  to accept reports submitted on magnetic media.
Reporting of section 313 information to state agencies on magnetic media must
be discussed with,  and authorized by, the state involved.  For more
information consult the appropriate state contact listed in an appendix of the
Toxic Chemical Release Inventory Reporting Form R and Instructions.

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                                      -2-

    Note that these instructions do not apply to the Title III  reporting
requirements under sections 311 and 312.

    Please note that written instructions  for completing Form R must be
complied with and that the instructions for filing the Form R electronically
do not supersede the instructions  for completing a hardcopy form.  This is
particularly true when it comes to reporting "NA" where there is no
information to report.  Specific changes in the magnetic media format since
the January 1990 version of this document (for 1989 reporting)  are shown
below:

    •   Total Release Reporting Range codes (A, B, C, or NA) remain the same
       but their meaning changes.

       A for 1-10 pounds
       B for 11-499 pounds
       C for 500-999 pounds

    •   Waste minimization "R" codes (Rl R2 R3 R4 R5) remain the same but their
       meaning changes.

       Rl  Regulatory Requirement  for  the  Waste
       R2  Reduction of  Treatment/Disposal Costs
       R3  Other Process  Cost Reduction
       R4  Discontinuation of Product
       R5  Other (e.g.,  occupational safety concerns,  etc.)

       In addition, a responder may attach an explanation to Form R
       elaborating on "other reasons."

    •   Three fields are added to Record Type TR (Trailer), contained in
       Diskette File TRITR and on  tape.
Sequence
Number
Record
1
2

3
4
5

Field Name Start
Type TR (Trailer), contained
Record type
Number of Submissions

Vendor
Version
Report Year

End
in Diskette
1
3

8
38
41

2
7

37
40
44

Length
Type
Format Notes

File TRITR.
2
5

30
3
4

Char
Mum

Char
Char
Char

Enter tr

Total number of submissions
on diskette package
Package vendor
Package version
Reporting year for which
package was developed





    •   The end position for the TRI Facility I.D. number in file TRI02 was
       listed as column 355 but has been changed to 354.

    •   The start position for the POTW zip code in file TRIOS was listed as
       column 181 but has been changed to 182.

    •   Numeric fields are right justified with leading zeros.  A 'NA'  entry in
       a numeric field is left justified.

    •   All alphabetic fields are left justified.

    •   Numeric linking codes (i.e., POTW code,  Offsite code) are right
       justified with leading zeros.

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                                      -3-

    •   Alphabetic linking codes (i.e., Stream codes) are left justified and
       upper case.

    •   Format notes change from "Y, N, or NA" to "Y or N" for Diskette file
       TRI02 Records 8-20, Diskette file TRI09 Record 13, and Diskette file
       TRI14 Records 6 and 8.

    Note:  This  document reflects  only the  changes  in  the reporting
requirements that affect the submission of reports on magnetic media.  Review
the instructions to Form R to identify additional changes in the reporting
requirements that do not directly affect the format of magnetic media
submissions (e.g., chemicals being delisted).

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                                      -4-

1.  CONTENT OF MAGNETIC MEDIA REPORTS - GENERAL SPECIFICATIONS

    Reports may be made to EPA using  either  9  track magnetic tape or
microcomputer diskettes formatted in DOS 2.1 or higher from an IBM PC/XT/AT or
compatible microcomputer.  File format specifications are substantially
different for these two types of media.  Data structures and magnetic media
must conform to the formats specified in Part 3 of this document.

    EPA will make  every effort to process  the  magnetic media received.  If  the
media cannot be read, the tapes or diskettes will be returned to the
submitter, who will be held responsible for providing readable media within 30
days.  A facility that has not provided readable media before the July 1
deadline will be considered in non-compliance status until EPA receives either
readable media or complete Form R reports.  EPA strongly encourages facilities
to read the information that is contained on the tapes or diskettes before
they are submitted to assure data accessibility and avoid non-compliance.
Non-readable media will be returned via the required return packaging and pre-
paid postage provided by the submitter.  All readable media received will
become the property of EPA.

    Any number  of  multiple reports from a  single  facility  or reports  from
multiple facilities may be included on a single tape or diskette.   However,
individual reports for a facility should be completely contained on a single
tape.  Diskette files should be completely contained on a single diskette.

    Reporting on magnetic  media  is in lieu, of  reporting on the hard copy Form
R, however, this does not affect the requirement to maintain a record of  all
information used to complete the reports.   This information must be maintained
in a form available for review by EPA or state officials for a period of  three
years from the date of submission.

    Exhibit 1,  on  the  following  page,  is a checklist  for submission of
magnetic media reports.

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                                       -5-

— Exhibit 1.  MAGNETIC MEDIA PACKAGE CHECKLIST FOR SUBMITTING MEDIA TO EPA ==

     A magnetic media package is complete only after you perform the following
steps.  Use this checklist as an aid to preparing your magnetic media package.
D
     1.  Prepare a cover  letter which  includes  all  the  required information as
        well as an original  signature for  each facility reporting on the
        magnetic media.   (See Part  2.1 of  this document.)
D
     2.  Prepare an  additional  cover page  listing  all  facilities in the order in
        which  they  appear  on the magnetic media,  if your package includes
      ,  reports from multiple  facilities.   (See Part  2.2 of this document.)
     3.  Verify  that  the  data have been formatted and transferred to magnetic
        media as  specified in  this  document.   (See  Parts  3 and 4 of this
        document.)
D
     4.  Confirm  there  are  no  reports  for  a chemical whose identity is claimed as
        a  trade  secret.  No trade  secret  information may be submitted on
        magnetic media.
 D
     5. Confirm that your reports  contain all  required  information.   (See the
        Toxic  Chemical  Release  Inventory  Reporting  Form R and Instructions,
        available  from  EPA.)
 n
     6. Verify  that  all  the  reported information is  correct to the best of your
        knowledge.
     7.  Perform a  data dump  or otherwise  access  the  data contained on the
         magnetic media to  confirm that  the  data  is readable from the copy which
         is  to be sent  to EPA.
 n
     8.  Label  the  media properly.   (See  Part  5.1  of  this document.)
     9.   Package  the media safely and include  return packaging and postage, the
         cover  letter(s),  and cover  page  (if applicable)  in the package with the
         magnetic media.   (See Part  5.2 of  this  document.)  Return packaging and
         postage  allow EPA to return unreadable  media.
    10. Mail the package  to EPCRA Reporting Center.
        For  general  mailing:
        P.O. Box 23779
        Washington,  D.C.   20026-3779
        Attn:   Toxic Chemical Release  Inventory
                Magnetic Media Submission
For certified mail:
470 L'Enfant Plaza East
Suite 7103,  SW
Washington,  DC  20024
Attn:  Toxic Chemical
       Release Inventory
      • Magnetic Media Sub.

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                                      -6-

2.  COVER LETTER AND CERTIFICATION

    2.1  Single Facility Packages

    Each, facility that  provides  reports  on magnetic  media must enclose  a  cover
letter containing the following information:

    1.  Full name and address of the submitting facility;

    2.  TRI Facility Identification Number;

    3.  Number of tapes or diskettes enclosed;

    4.  List of chemical (or chemical category) names and CAS numbers covered
       by the report;

    5.  Name and phone number of a data processing contact person who is
       available to provide clarification;

    6.  A statement that the information that you are submitting does not
       contain any trade secret data.

    7.  Certification statement identical to the certification statement from
       EPA Form R.  (See example in Exhibit 1 of this document.)  As required
       by the regulation, this certification statement must be signed by the
       owner or operator or a senior management official, not the data
       processing contact.  The signed name must also be typed, followed by
       the official title of the signee.  The date on which the statement was
       signed must also be on the letter.

    8.  Specification of the page number of the cover letter in the following
       format:  "Page 1 of N Pages."

    The certification provided in  the  cover  letter is  the same certification
statement contained on reporting Form R.  The certification will apply to all
reports provided by the facility which are identified by chemical name in the
cover letter.  The name of the owner/operator or senior management official
contained on the cover letter must match the name provided in the data field
for Section 2 of Part I of the form (Certification Name and Official Title) in
each of the facility's reports contained on the magnetic media.

    Exhibit  2  is  a sample  cover  letter that  includes each of the  required
elements.

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                                              -7-
Exhibit  2.   SAMPLE  COVER  LETTER ACCOMPANYING  A MAGNETIC MEDIA  PACKAGE
                                                              Page 1 of 1 Pages.

                                                              Pirx-Lewis, Incorporated
                                                              Battery Products  Division
                                                              10545 Cerillas  Road
                                                              Albuquerque,  N.M.  81103-0420
                                                              TRI Fac. ID #81103PRXLWCERIL
                                                              May 2, 1991
      EPCRA Reporting Center
      P.O.  Box 23779
      Washington,  D.C.   20026-3779
      Attn:  Toxic Chemical Release Inventory
             Magnetic Media Submission

      To Whom It May  Concern:

        Enclosed please find  two  (2) microcomputer diskettes  (numbers 1 and 2) containing
      toxic chemical  release  reporting information for  Pirx-Lewis, Inc., Battery Products
      Division, as required under section 313,  Title III of the Superfund Amendments and
      Reauthorization Act of  1986.

        A total of two (2)  reports are included from our  facility, concerning the following
      chemicals:
                                   Report
               Chemical Name        Number        CAS Number
               Lead compounds       00001        NA
               Zinc                 00002        7440-66-6
        Our data processing contact is Jeffrey Mills,  who can be reached at (505) 752-5369.
      Mr.  Mills is available should any questions or problems arise in your processing of
      these diskettes.

        I hereby certify that  I have reviewed the attached documents and that, to the best of
      my knowledge and belief, the submitted information  is true and complete and that the
      amounts and values in this report are accurate based on reasonable estimates using  data
      available to the preparers of this report.
                                                              Sincerely yours,
                                                              Stanley L.  Pirx,  III
                                                              Vice President
                                                              Battery Products  Division
                                                              Pirx-Lewis,  Incorporated
      Enclosures

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                                             -8-
    2.2  Multiple Facility Packages
    When multiple facilities provide  reports on a single  magnetic media,  each
facility must  prepare a separate  cover  letter containing each of the  required
elements noted in  Section 2.1 of  this document.   An additional cover  page must
also be  enclosed which  lists  the  names  of the facilities in the  order in which.
they appear on the media.   Pages  should be  numbered sequentially starting with
the  cover page and continuing through all of the  cover letters.

    A  sample of  a multiple  facility cover page  is included as  Exhibit 3.
              Exhibit 3.   SAMPLE COVER PAGE FOR MULTIPLE FACILITIES  =====
                    REPORTING IN A SINGLE  MAGNETIC MEDIA  PACKAGE

                                                            Page 1 of 3 Pages.

                                                            American Manufacturing, Inc.
                                                            Corporate Headquarters
                                                            2625 McDowell Road
                                                            Phoenix, AZ  85008
                                                            IRI Fac. ID #85008MRCNMMCDOW
                                                            May 8, 1991

          EPCRA Reporting Center
          P.O. Box 23779
          Washington, D.C.  20026-3779
          Attn:  Toxic Chemical Release Inventory
                Magnetic Media Submission

          To Whom It May Concern:

            Enclosed please find a total of  two (2)  3.5 inch microcomputer diskettes containing
          toxic chemical release reporting information required under section 313, Title III of
          the Superfund Amendments and Reauthorization Act of 1986.

            Please also find attached a total of two (2) cover letters, one for each of our
          subsidiaries that is reporting.  The letters include certification statements from each
          of these facilities and the signatures of  senior management officials responsible for
          reporting. The report data is arranged on the two diskettes in the following order:

            1.     Pirx-Lewis Incorporated,  Battery  Products Division ,(2 reports)
            2.     Larson Plastics (1 report)

            Our data processing contact is John Berg, who can be reached  at (602) 258-1234.
          Mr. Barg is available should any questions or problems arise in your processing of these
          diskettes.

                                                            Sincerely,
                                                            Michael J. Noonan
                                                            Vice President, Operations
                                                            American Manufacturing, Inc.
          Enclosures

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                                      -9-

3.  FORMAT OF MAGNETIC TAPE REPORTS

    3. 1  Technical  Specifications and  Structural Records

    The  following technical  requirements apply  for magnetic  tape  reports:

       •   Density and recording technique:  9-Track, 1600 BPI, odd parity.

       •   Logical record length (for all record types):   500 Bytes.

       •   Blocksize:       2000 Bytes.

       •   Record format:   Fixed Blocked (FB).

       •   Character Type:  7 Bit ASCII.

       •   Label Type:      No Label (NL)  with no leading tape mark.

       .   File Name:       TRIDATA.DAT.

    As previously described  in this  document, a Form  R report  contains
information,on releases of one chemical or chemical category.   All reports for
all the facilities reporting on any one tape must be in a single data file
that is entirely contained on that tape.   The data file must not span multiple
tapes.  If several facilities are reporting on separate tapes which are
included in a single package, each facility's reports should be numbered
sequentially on their respective tapes,  beginning with report number one.

    The  file  itself is made  up of records,  some of which  contain  Form R
information (described in Part 3.2 of this document)  and others which contain
information on the data (structural records).   Each record has a fixed length
of 500 bytes, some of which are used by the current data fields and some
reserved for future use.  All data are to exist as unquoted, fixed field ASCII
format,  and should not include commas, control characters, or other
delimiters.

    Structural  records contain specific data on the number of  records,
reports, and facilities contained on the tape.   There are four types of
structural records required in tape reporting,  as follows:

    1.  Header (type hh) is the first record.of the data file TRIDATA.DAT.

    2.  Report start  (type ss). which is located at beginning of each report.

    3.  Report end  (type se). which is located at the end of each report.

    4.  Trailer (type tr) is the last record of the data file TRIDATA.DAT.

The field layout for these four record types is shown in Table 1.  All four
record types are required for magnetic tapes,  regardless of the number of
facilities reporting on the tape.   All information on the tape should be in a
single file named TRIDATA.DAT.

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                                                        -10-

                                                        Table 1

                            STRUCTURAL RECORD SPECIFICATIONS FOR FORM R DATA REPORTS OH TAKE
Sequence
Number     Field Name
Record Typo EH (Header Record)
                                                Byte
                                                Position
                                                            Total
Start   End  Length  Type   Format Notes
    1       Record Type
    2       BLANK
  122      Char  Enter hh
  375      Char  Leave blank
Record Type SS (Report Start)
            Record Type
            Report Number
  122      Char  Enter se
  3     7      5      Hum   Sequential report number, right justified
                           with leading zeros
Record Typo SE (Roport End)
    1       Record Type
    2       Report Number

    3       Number of Records
  122      Char  Enter ss
  3     7      5      Hum   Sequential report .number,  right  justified
                           with leading zeros
  8    12      5      Num   Total number of type  01-14 records  in
                           report,  right justified with  leading zeros
Record Typo TR (Trailer)
    1       Record Type
    2       Number of Submissions

    3       Vendor
    4       Version
    S       Report Year
  122      Char  Enter tr
  3     7      5      Hum   Total number of submissions  on  tape, right
                           justified with leading  zeros
  8    37     30      Char  Package vendor
 38    40      3      Char  Package version
 41    44      4      Char  Reporting year for which package  was
                           developed

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                                     -11-

    3.2  Structure of Data Records for Tapes

  ,  Table  3  specifies the data  structure  of each  of  the  data  record types  and
relates to the information requested in the individual sections and blanks of
EPA Form R.   Each data element is contained in a data record of a predefined
record type (numbered 01 through 14).   The record type is identified by the
first two byte positions of the record.   The report number is a sequential
number assigned by the submitting facility to each report contained on the
magnetic media and is used to cross  reference the records of a report.  [Note:
Reports from multiple facilities on a single media must be numbered
sequentially and uniquely throughout the media.  Therefore, no two reports on
the same tape will have the same report number, whether the reports originate
from the same or different facilities.]

    The  start  byte,  end byte, and total length  of each data field  has  been
defined as shown in Table 3.   Blank data fields will be represented by blank
bytes on the report media and should not be considered to be the same as data
fields filled by NA, which is used to designate data not applicable to the
submitting facility.  (See the Form R instructions for further clarification.)

    Table  3  also  provides information on  data formats  including  the right  or
left justification and the pre-defined placement of decimal points (e.g.,  a
left justified 3 will be read as 300,000,000 in a 9 byte field).  Percent data
should be reported to the nearest whole number.  For example, 05300 will be
read as 53 percent,  and although 00053 would be read as 0.53 percent,  1
percent (i.e., 00100) should be reported).

    Exhibit  4  presents  a  sample data structure  for a magnetic tape record
prepared by a facility which conforms to the data structure specified in Table
3.  Exhibit 5 illustrates how the four structural records described in Part
3.1 of this document and the records which contain Form R data should be
ordered on the tape package.
        -Exhibit 4. EXAMPLE DATA STRUCTURE FOR MAGNETIC TAPE REPORTS=
    Bell  Products  is  completing Record  Type  10  for  its  first  report.  Bell has
two receiving streams for this report,  and so will have two Type 10 records.
The following format is used for Bell's data:
Data Stream
lOOOOOlab
nam 10000
lOOOOOlbnaOOOOOOOOlSOo 05100
            Explanation
Type 10 record for a release to water; 10 is
the record type; 00001 is the report number;
"a" is the alphabetical index assigned to the
receiving stream; "b" is the range code; "na"
is the estimate; "m" is the basis of estimate
code for monitoring data; 10000 corresponds to
a stormwater percentage of 100%

A second type 10 record, for a second
receiving stream (assigned index "b") which is
estimated to receive 150 pounds 'of the
chemical with stormwater percentage 51%.

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                                     -12-
            =Exhibit 5.  EXAMPLE OF RECORD ORDER FOR TAPE REPORTS=
    Gates Photographic Supply is reporting for two of its facilities on one
tape.  Gates has two reports for its first facility and one report for its
second facility.  All of this information should be contained in a single file
named "TRIDATA.DAT".  Gates should structure  its data stream as shown below:
Record Type

hh

ss


01 to 14
se
ss
01 to 14
se
ss
01 to 14

se

tr
Explanation
Header record for tape.

Report start record for report 1 in facility 1;  this report
is assigned report number 00001.

Record types 01 through 14 for report 1 go here.   They
contain Form R data for the first report as defined in Table
3

Report end record for report 1.  This record contains a
field which indicates the number of Form R type records in
the first report.  (The number can vary, depending on the
number of multiple records in the report; see above example)

Report start record for report 2 in facility 1;  this report
is assigned report number 00002.

Record types 01 through 14 for report 2.

Report end record for report 2.  This record contains a
field which indicates the number of Form R type records in
the second report.

Report start record for the first report from facility 2.
Because this is the third report on the tape, it is assigned
report number 00003,  to avoid its confusion with the first
report from facility 1.

Record types 01 through 14 for this report.

Report end record for this report.

Trailer record for this tape. .This record has a field which
indicates the total number of submissions from all
facilities on the. tape.

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                                     -13-

4.  MICROCOMPUTER DISKETTE REPORTS

    4.1  Technical  Specifications and Special Files

    Diskettes  may be either 5.25 inch or 3.5 inch in size and either double
density or high density in data capacity.  They must be formatted using DOS
2.1 or higher, on an IBM PC/XT/AT or compatible, as follows:
       Size
       5.25"
       3.5"
Double density
  360 Kbytes
  720 Kbytes
High density
 1.2 Mbytes
 1.4 Mbytes
All diskettes contained in a single package must be of a single type and
format, and must be properly labeled with the format used.

    For diskette submissions,  records of different types  must be  contained in
separate files.  These files are named with a combination of the letters  "TRI"
and the record type (e.g., type 08 records will be in the file "TRIOS.")•
Multiple records of the same type which are part of a single report, as well
as all records of the same type provided for all other reports in the package,
must be contained in a single file.  Files containing records of a type should
be completely contained on a single floppy diskette which has been properly
labeled to identify the files it holds.

    Two additional  files  must be created to  contain information on  the numbers
of records and reports provided in the diskette package.  They are:

    1.  Report end records (typese). created to identify the number of records
       in each report that is Included in the diskette package.  These are
       placed in a data file named "TRISE.".

    2.  Trailer___records (type tr) . created to identify the total number of
       submissions being provided by all facilities which are reporting on the
       diskettes.  These are placed in a data file named "TRITR.".

The structure for these record types is shown in Table 2 on the following
page.

    It  is  very important  that each report have  a unique  report number  used
throughout the records pertaining to that report.  Report numbers may be
assigned in any order, so long as no two reports share the same number.

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r
             Sequence
             Number     Field Name
                                                                      44-
                                                                    Table 2
                                      STRUCTURAL RECORD SPECIFICATIONS FOR FORM R DATA REPORTS ON DISKETTE
 Byte
 Position    Total
                                     i
Start   End  Length  Type  Format Notes
             Record Typo SE (Report End),  contained in Diskette File TRISE.
                 1      Record Type
                 2      Report Number

                 3      Number of Records
  122      Char  Enter se
  375      Hum   Sequential report number,  right justified
                           with leading zeros
  3    12      5      Hum   Total number of type 01-14 records in
                           report, right justified with leading zeros
             Record Type TR (Trailer),  contained in Diskette File TRITR.
                 I      Record Type
                 2      Number of Submissions

                 3      Vandor
                 4      Version
                 S      Roport Year
  122      Char  Enter tr
  375      Hum   Total number of submissions on diskette
                           package, right justified with leading zeros
  8    37     30      Char  Package vendor
 38    40      3      Char  Package version
 41    44      4      Char  Reporting year for which package was
                           developed

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                                     -15-

    4.2   Structure of Form R Data Records for  Diskettes

    Each record has a fixed length of 500 bytes,  some of which are used by  the
current data fields, some reserved for future use, and some reserved for a
carriage return and line feed (positions 499 and 500 respectively) .   All data
are to exist as unquoted, fixed field ASCII format, and should not include
commas,  control characters, or other delimiters.

    Table 3  specifies the data structure  of each  of these records and relates
the data to the individual sections and blanks of EPA Form R.  Each data
element is contained in a record of a predefined record type (numbered 01
through 14).  The record type is identified by the first two byte positions of
the record.  The report number is a sequential number assigned by the
submitting facility to each report contained on the magnetic media and is used
to cross reference the records of a report.  Multiple entries of facility data
(e.g., SIC code, NPDES permit numbers) should be contained in multiple records
of the type that is appropriate for that data.  For'example, a facility with
two SIC codes would have two records of type 03.    [Note:   Reports from all
facilities on a single media must be numbered sequentially and uniquely
throughout the media.  Therefore, no two reports on the same diskette will
have the same report number, whether the reports originate from the same or
different facilities.]

    The  start byte,  end byte,  and total length of each data  field has been
defined as shown in Table 3.  Blank data fields will be represented by blank
bytes on the report media and should not be considered to be the same as data
fields filled by NA, which is used to designate data not applicable to the
submitting facility.   (See the instructions for completing Form R for further
clarification.)

    Table 3  also provides information on  data  formats including  the  right or
left justification and the pre-defined placement of decimal points  (e.g.,  a
left justified 3 will be read as 300,000,000 in a 9 byte field).  Percent data
should be reported to the nearest whole number.  For example, 05300 will be
read as 53 percent, and although 00053 would be read as 0.53 percent,  1
percent  (i.e.,  00100) should be reported).

    An example  of how a company might prepare  diskette files  for Form R
reporting is contained in Exhibit 6.

-------
                                       -16-

	 Exhibit 6. EXAMPLE FILE AND DATA STRUCTURE FOR DISKETTE REPORTING =====

     American Manufacturing is preparing reports for two of its facilities and
submitting reports on diskettes.  The facilities are assigned facility numbers
00001 and 00002.  There are a total of three reports from the two facilities
combined.  American Manufacturing assigns report numbers 00001 and 00002 to the
two reports from the first facility, and report number OOOQ3 to the second
facility's report, so that each report will have a unique report number.

     After consulting the Toxic, Chemical Release Inventory Reporting Form R and
Instructions to assemble the information it needs, American Manufacturing can
proceed to Table 3 to determine how this information should be entered on the
diskettes.

     The first diskette contains files TRIOS and TRI07,  both containing Form R
data, and files TRISE and TRITR.  Facility 1 has an SIC code of 3691, and
facility 2 has an SIC code of 4567.  Table 3 of this document describes the data
structure of rec'ord type 03.  The record's first two byte positions contain the
record type, the next 5 byte positions contain the report number, and the last
four contain the facility SIC code.  American Manufacturing must prepare three
records for this file, one record for each report it is completing, and store
all three in file TRIOS.  File TRIOS contains the following formatted data:

     03000013691
     03000023691
     03000034567

     To prepare file TRI07 American Manufacturing must determine how many
receiving streams each report names.  The first report names two receiving
streams, and the other two reports name one receiving stream each; American
Manufacturing must report a total of four receiving streams.  After determining
the structure of record type 07 from Table 3 of this report, American
Manufacturing stores the following information in file TRI07 [Note:  For report
number 00001, with two receiving streams named, the first, "tijeros arroyo", is
assigned alphabetical stream code "A", and the second, "rio grande", is assigned
stream code "B".  The other reports (00002 and 00003), assign stream code "A" to
the only stream that they contain.]:

     0700001Atijeros arroyo
     0700001Brio grande
     0700002Ario grande
     0700003Asanta cruz river

     After completing the other records for the reports,  American Manufacturing
finds a total of 18 records for report 00001, 21 records for report 00002, and
14 records for report 00003.  [Note: • The count of records includes record types
01 to 14 only.  It does not include the number of records of types se or tr.]
File TRISE contains the following end of report records:

     se0000100018
     se0000200021
     se0000300014

     Record type tr contains the number of submissions in the diskette package,
therefore file TRITR contains the following formatted data:

     trOOOOS

-------
                                                          -17-

                                                          Table 3

                                   DATA RECORD STRUCTURAL  SPECIFICATIONS FOR FORM R DATA
               Reference to
Sequence     Reporting Form R
Number    Page Sect.  Title/Topic

Record Type 01 (Diskette file TRIO!)
    1                  Record type
    2                  Report number
 Byte
 Position
             Total
Start   End  Length  Type  Format Notes
3
4
5
6
7 •
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
.1
.2
.3



.1
.1
.1
.1
.1
.1
.1
.1
.2
.3
.3
.4
.4
.6
.6
.11
.11
.1
.2
                       Trade secret
                       Sanitized copy
                       Reporting year
                       Certification name
                       Certification title
                       Certification date
                       Facility name (1st part)  111
                       Facility name (2nd part)  141
                       Facility st.  (1st part)   171
                       Facility st.  (2nd part)   201
                       Facility city
                       Facility county
                       Facility state
                       Facility zip
                       Entire/part facility
                       Technical contact name
                       Technical contact phone   338
                       Public contact name
                       Public contact phone
                       Facility latitude
                       Facility longitude
                       1st UIC ident. number
                       2nd UIC ident. number
                       Parent company name
                       Parent company D&B num.   486
1
3
8
9
11
15
60
105
111
141
171
201
231
256
281
283
292
293
338
348
393
403
410
417
429
441
486
2
7
8
10
14
59
104
110
140
170
200
230
255
280
282
291
292
337
347
392
402
409
416
428
440
485
494
2
5
1
2
4 '
45
45
6.
30
30
30
30
25
25
2
9
1
45
10
45
10
7
7
12
12
45
9
Char
Num
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
                           Enter 01
                           Sequential number, right justified, leading
                           zeros
                           Enter N*
                           Enter NAa
                           Enter reporting year (e.g., 1990)
                           Left justified
                           Left justified
                           Date format bf!DDYYb
                           Left justified0
                           Left justified0
                           Left justified0
                           Left justified0
                           Left justified
                           Left justified
                           Left justified
                           Left justified, no dashes
                           Enter A (entire) or B (part)
                           Left justified
                           Includes area cods'*
                           Left justified
                           Includes area coded
                           Format DDDMMSS8
                           Format DDDMUSS6
                           Right justified with leading zeros
                           Right justified with leading zeros
                           Left justified
                           Right just., no dashes, leading zeros
     a  This is the only acceptable value for the field,  because no trade secret data may be  submitted on magnetic media.

     b  e.g., March 17, 1991, would be entered as "031791".

     c  Two fields are provided to allow ample room to report this, information.

     d  Do not include parentheses or dashes, e.g., (202) 555-1212 would'be entered as "2025551212".

     e  e.g., 91 degrees,  15 minutes, 5 seconds would be  entered as "0911505".   North latitude  and west longitude are
        assumed.

-------
                                                      ,-18-

                     Table 3:   DATA RECORD STRUCTURAL SPECIFICATIONS FOR FORM R DATA (Cont'd)
Sequence
Huraber
Reference to
Reportins Form R
Page Sect.
Title/Topic
Racozd Type 02 (Diskette file TRI02)
1 Record type
2
3
4
5
6

7
8
9
10
11
12
13
14
IS
16
17
18
19
20
21
22

23

24
25
26

27
28
29

30
31
32
33
34
35
36
37
38
39

3
3
3
3

3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3

3

3
3
3

3
3
3

3
•4
4
4
4
4
4
4
4
1

1
1
1
1

2
3
3
3
3
3
3
3
3
3
3
3
3
3
4
5

5

5
5
5

5
5
5

5
8
8
8
8
8
8
8
8
3

.1
.2
.3
.4


.1
.1
.1
.1
.1
.1
.2
.2
.2
.2
.3
.3
.3

.1

.1

.1
.2
.2

.2
.4
.4

.4
.A
.B
.B
.B
.B
.C
.C
.D
.1
Report number
RESERVED
CAS number
Chemical/category name
Generic name

Mixture component name
M:(a) Produce
M:(b) Import
M:(c) On-site use
M:(d) Sale/distrib.
M:(e) Byproduct
M:(f) Impurity
P:(a) Reactant
P:(b) Formulatn. comp.
P:(c) Article comp.
P:(d) Repackaging only
OU: (a) Chem. process
OU: (b) Manufact. aid
OU: (c) Ancillary/Other
Maximum amount on site
F/Air: Range code

F/Air: Release est.

F/Air: Basis of est.
S/Air: Range code
S/Air: Release est.

S/Air: Basis of est.
UI: Range code
UI: Release estimate

UI: Basis of estimate
Waste min. code
•Current yr. chem. qty.
Prior year chem. qty.
Percentage change
Percent change sign
Index
Index sign
Reason for action code
TRI Facility I.D. num.
Byte
Position
Start End
1
3
8
9
18
88

158
228
230
232
234
236
238
240
242
244
246
2i8
250
252
254
256

258

269
271
273

284
286
288

299
301
303
316
329
334
335
337
338
340
2
7
8
17
87
157

227
229
231
233
235
237
239
241
243
245
247
249
251
253
255
257

268

270
272
283

285
287
298

300
302
315
328
333
334
336
337
339
354
Total

Length Type
2
5
1
9
70
70

70
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

11

2
2
11

2
2
11

2
2
13
13
5
1
2
1
2
15
Char
Num
Char
Char^
Char
Char

Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char

Char

Char
Char
Char

Char
Char
Char

Char
Char
Char
Char
Char
Char
Char
Char
Char
Char

Format Notes
Enter 02



Sequential number, right just., leading zeros
Leave Blank
Right justified with leading zeros*, or NAd
Left justify or NA
Hot applicable for non-trade secret reports,
left justified
Left justify or NA
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter Y or N, left justified
Enter amount range code (01 through 11)
Enter range code (A through C)b or HA, left
just.
Right justify num. (no decimal places) with
leading zeros or NAd
Basis code (M, C, E, or 0) or NA, left just.

























Range code (A through C)b or NA, left justified
Right justify num. (no decimal places) with
leading zeros or NAd
Basis code (M, C, E, or O) or .NA, left just.



Range code (A through C)b or NA, left justified
Right justify num. (no decimal places) with
leading zeros or NAd
Basis code (M, C, E, or" 0) or NA, left just.
Type of modification code (Ml through M8) or
Right justify num. with leading zeros or NAd'
Right justify num. with leading zeros or NAd.
Right just, percent (no decimal point)0 or NA
Enter P (positive) or N (negative)



NA


d

Right just., no decimal point (99=9.9), or NAd
Enter P (positive) or N (negative)
Action code (Rl through R5)
Left justified, no dashese



*  a.8.. CAS number 1336-36-3 would be entered as "001336363".


b  "A" should be entered for 1-10 pounds, "B" for 11-499 pounds,  or "C"  for 500-999 pounds.


c  Enter percent without a decimal point, but with two trailing zeros (e.g., 23 percent would be entered as "02300").
   Do not include fractions of a percent (i.e.,  report 23 rather  than 23.15).


d  "NA" entry in numeric field should be left justified.


*  TRI Facility Identification Number is a" new data item for 1989 reports  and  is  assigned by EPA.

-------
                                                          -19-
                         Table 3:  DATA RECORD STRUCTURAL SPECIFICATIONS FOR FORM R DATA (Confd)
               Reference to
Sequence     Reporting Form'R
Number    Page Sect.  Title/Topic
Record Type 03 (Diskette file TRI03)
    1                  Record type
    2                  Report number
    3       1   3.5     SIC  code

Record Type 04 (Diskette file TRI04)
    1                  Record type
    2                  Report number
    3       1   3.7     D&B  Number

Record Type 05 (Diskette file TRIOS)
    1                  Record type
    2                  Report number
    3       1   3.8     EPA  ID Number

Record Type 06 (Diskette file TRI06)
    1                  Record type
    2                  Report number
    3       1   3.9.    NPDES Permit  Number

Record Type 07 (Diskette file TRI07)
    1                  Record type
    2                  Report number
    3       1   3.10    Receiving Stream Code
    4       1   3.10    Receiving Stream Name

Record Type 08 (Diskette file TRI08)
                       Record type
                       Report number
                       POIW Code
                       FOTW Name (1st part)
                       PQTW Name (2nd part)
                       POTW Street (1st part)
                       POTW Street (2nd part)
                       POTW City
                       POTW County
                       POIW State
                       POTW Zip
1
2
3
4
5
6
7
8
9
io
11


2
2
2
2
2
2
2
2
2


1
1
1
1
1
1
1
1
1
Byte

Position
Start
1
3
8
1
3
8
.1
3
8
1
3
8
1
3
8
9
1
3
8
10
40
70
100
130
155
180
182
End
2
7
11
2
7
. 16
2
7
19
2
7
16
2
7
8
78
2
7
9
39
69
99
129
ISA
179
.181
190

Total
Length
2
5
4
2
5
9
2
5
12
2
5
9
2
5
1
70
2
5
2
30
30
30
30
25
25
2
9


Type
Char
Hum
Char
Char
Hum
Char
Char
Num
Char
Char
Num
Char
Char
Num
Char
Char
Char
Num
Char
Char
Char
Char
Char
Char
Char
Char
Char
      Sequential number, right just.,  leading zaros
      SIC code
      Enter 04
      Sequential number, right just.,  leading zeros
      Right justify, use leading zeros, no dashes
      Enter 05
      Sequential number, right just., leading zeros
      Right justify, use leading zeros, no dashes
      Enter 06
      Sequential number, right just., leading zeros
Char  Right justify with leading zeros
      Enter 07
      Sequential number, right just., leading zeros
Char  Sequential alphabetic character3
      Left justify
      Enter 08
      Sequential number, right just., leading zeros
      Sequential numeric character15
      Left justifyc
      Left justify0
      Left justify0
      Left justify0
      Left'justify
      Left justify
      Left justify
      Left justify, no dashes
        Each distinct receiving stream must be  assigned a  distinct  alphaoetic  code  (a, b,  c,  etc.).   The  code must  also be
        entered in. the corresponding  location in record type  10  to  allow  release  estimate  data  to  be  matched to  the
        receiving location's descriptive  information.   Left justified  and upper case.

        POTWs should be assigned distinct sequential numeric  codes  (1,  2, 3, etc.).  The code must also be  entered  in  the
        corresponding location in record  type 12 to allow  release estimate  data to  be matched to the  POTWs descriptive
        information.  Right justified with leading zeros.
        Two fields are provided to allow ample room to report this information.

-------
                                                           -20-
                         Table 3:  DATA RECORD STRUCTURAL  SPECIFICATIONS FOR FORM R DATA (Cont'd)
Sequence
Number
     Reference to
   Reporting Form R
Page Sect.  Title/Topic
Record Typo 09 (Diskette file TRI09)
    1                  Record type
    2                  Report number
3
4
5
6
7
8
9
10
11
12
13
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

2
2
2
2
2
                       Off Site Code
                       RCRA ID Number
                       Off Site Name (1st part)
                       Off Site Name (2nd part)
                       Off Site St. (1st part)
                       Off Site St. (2nd part)
                      •Off Site City
                       Off Site County
                       Off Site State
                       Off Site Zip
                       Off Site Control Ind.
                                                  Byte
                                                 Position
                                                             Total
Start   End  Length  Type  Format Notes
                                                          Char
                                                          Num
8
10
22
52
82
112
142
167
192
194
203
9
21 '
51
81
111
141
'166
191
193
202
204
2
12
30
30
30
30
25
25
2
9
2
Char
Char
Char
Char
Char.
Char
Char
Char
Char
Char
Char
                           Enter 09
                           Sequential number, right justified,  leading
                           zeros
                           Sequential numeric character9
                           Right justify with leading zeros
                           Left justify6
                           Left justify15
                           Left justify6
                           Left justify15
                           Left justify
                           Left justify
                           Left justify
                           Left justify
                           Enter Y or N, left justified
Record Typo 10 (Diskette file TRI10)
                       Record type                1
                       Report number              3

            3/5 5.3    Hater: Stream code         8
            3/5 5.3    Hater: Range code          9

            3/5 5.3    Hater: Release estimate   11

            3/5 5.3    Hater: Basis of estimate  22

            3/5 5.3    Hater: Stormwater percent 24
                                              2     2     Char   Enter  10
                                              7     5     Num   Sequential number, right justified, leading
                                                                 zeros.
                                              8     1     Char   Matches Record  Type 07, alphabetic character0
                                             10     2     Char   Range  code (A through C)d or NA, left
                                                                 justified
                                             21    11     Char   Right  justify num. (no decimal places) with
                                                                 leading zeros or NAf
                                             23     2     Char   Basis  code (M,  C, E, or 0) or NA, left
                                                                 justified
                                             28     5     Char   Right  justify percent (no decimal point)6 or
     *  Off-sita transfer points must be assigned distinct numeric codes.  The code must also be entered in the
        corresponding location in record type 13.  Right justified with leading zeros.

     b  Two fields are provided to allow ample room to report this information.

     c  The code entered must be, an alphabetical character code that matches the code used in record type 07 for the
        receiving stream.  Each receiving stream should have a distinct record type 10.   Left justified and upper case.

     d  "A" should be entered for 1-10 pounds, "B" for 11-499 pounds, or "C" for 500-999 pounds.

     •  Enter percent without a decimal point, but with two trailing zeros  (e.g.,  23  percent would be entered as "02300").
        Do not include fractions of a percent (i.e., report 23 rather than 23.15).

        "NA" entry in numeric field should be left justified.

-------
                                                   -21-

                 Table 3:  DATA BECOBD STRUCTURAL SPECIFICATIONS KK FOBM R DATA (Conf d)
Reference
Seouence Reoortinj? Form R
Number
Record
1
2 ,
3
4

5
6
7

8
9
10

11
12
13

14
Record
1
2
3
4
5

6
Record
'I
2
3
4
5

6
7
Page
Type 11


3/5
3/5

3/5
3/5
3/5

3/5
3/5
3/5

3/5
. 3/5
3/5

3/5
Type 12


4/5
4/5
4/5

4/5
Type 13


4/5
4/5
4/5

4/5
4/5
Sect.
Title/Topic
Byte

Position
Start
End

Total
Length


Type


Format Notes






(Diskette file TRI11)


5
5

5
5
5

5
5
5

5
5
5

5


.5
.5

.5
.5
.5

.5
.5
.5

.5
.5
.5

.5
Record type
Report number
On-site landfill: Range
On-site landfill:Release

On-site landfill: Basis
Land treat: Range code
Land treat: Release est.

Land treat: Basis of est
Surf. Imp: Range code
Surf. Imp: Release est.

Surf. Imp: Basis of est.
Other land: Range code
Other land: Release est.

Other land: Basis of est
1
3
8
10

21
23
25

36
38
40

51
53
55

66
2
7
9
20

22 .
24
35

37
39
50

52
54
65

67
2
5
Z
11

2
2
11.

2
2
11

2
2
11

2
Char
Hum
Char
Char

Char
Char
Char

Char
Char
Char

Char
Char
Char

Char
Enter 11

Sequential number, right just.,
Range code (A
Right justify
leading zeros
Basis code (M,
Range code (A
Right justify
leading zeros
Basis code (M,
Range code (A
Right justify
leading zeros
Basis code (M,
Range code (A
Right justify
leading zeros
Basis code (M,

leading zeros
through C)a or NA, left just.
num. (no decimal
or NAC
places) with

C, E, or 0) or NA, left just.
through C)a or NA
num. (no decimal
or NAC
, left justified
places) with

C, E, or 0) or NA, left just.
through C)a or NA
num. (no decimal
or NAC
, left justified
places) with

C, E, or 0) or NA, left just.
through C)a or NA
num. (no decimal
or NAC
, left justified
places) with

C, E, or 0) or NA, left just.
(Diskette file TRI12)


6
6
6

6


.1
.1
.1

.r
Record type
Report number
POTW Code
POTW Range code
POTW Release estimate .

POTW Basis of estimate
1
3
8
10
12

23
2
7
9
11
22

24
2
5
2
2
11

2
Char
Hum
Char
Char
Char

Char
Enter 12

Sequential number, right just.,
Matches Record Type 08, numeric
Range code (A
Right justify
leading zeros
Basis code (M,
through C)a or NA
num. (no decimal
or NAC

leading zeros
character13
, left justified
places) with

C, E, or 0) or NA, left just.
(Diskette file TRI13)


6
6
6

6
6


._
._
._

._

Record type
Report number
Off site: Code
Off site: Range code
Off site: Release est.

Off site: Basis of est.
Off site: Treatment type
1
3
8
10
12

23
25
2
7
9
11
22

24
27
2
5
2
2
11

2
3
Char
Hum
Char
Char
Char

Char
Char
Enter 13

Sequential number, right just. ,
Matches Record Type 09, numeric
Range code (A
Right justify
leading zeros
Basis code (M,
through C)a or NA
num. (no decimal
or NAC '

leading zeros
character*5
, left just.
places) with

C, E, or 0) or NA, left just.
Offsite Treatment code, left justified
"A" should be entered for 1-10 pounds, "B" for 11-499 pounds,  or  "C"  for  500-999 pounds.


The code entered must match the numeric code in record type 08 for  the  corresponding POTW or  record  type  09  for
the corresponding off-site transfer point.  Record types 12 and 13  contain  data for the amounts of toxic  chemical
transferred to each POTW or off-site location; this code cross-references with other records  containing
descriptive information.  Right justified with leading zeros.


"NA" entry in numeric field should be left justified.

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                                                           -22-
                         Table 3:  DATA RECORD STRUCTURAL SPECIFICATIONS FOR FORM R DATA (Cont'd)
               Reference to
             Reporting Form R
Huutbar    Poga Soct.  Title/Topic
                                                        Byte
                                                Position    Total
Rtcord Typo 14 (Diskette file TRIM)
    1
    2
    3
    «
    5
    6
    7
                                               Start   End  Length  Type  Format Notes
                      Record type
                      Report number
            4/5 7._a  WTME:  Wastestream
            4/5 7._b  WTME:  Treatment
            4/5 7._o  WTME:  Influent oono.  rng.
            4/5 7._d  WTME:  Sea;,  treatment
            4/5 7._e  WTME:  Efficiency est.

            4/5 7._f  WTME:  Based on data
 1
 3
 8
 9
12
14
16

21
 2
 7
 8
11
13
15
20

22
Char
Hum
Char
Char
Char
Char
Num

Char
Enter 14
Sequential number, right just.,  leading zeros
Wastestream code
Treatment code, left justified
Range code (1 through 5)a or NA
Y or N, left justified
Right justify percent (no decimal point),b or
NAC
Y or N, left justified                   '    '
     *  "1" should be entered for > .1 percent,  "2"  for 0.01 percent to  1  percent,  "3"  for  1 ppm to  100 ppm,  "4"  for  1 ppb
        to 1 ppm,  or "5" for < 1 ppb.

     b  Entor percent without a decimal point but with two trailing zeros (e.g., 23  percent would be  entered as  "02300").
        Do not include fractions of a percent (i.e.,  report 23 rather than 23.15).
        "HA" entry in numeric field should be left justified.

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                                     -23-
5.  LABELING AND PACKAGING REQUIREMENTS

    5.1   Labeling Requirements

    A  label must be  attached  to  each  tape  reel  (not  tape band)  and  diskette
(not jacket) which conforms to the following format:

                                A.  Name of the submitting facility (or for
                                   multiple facility packages the name of the
                                   company which prepared the reports).
                                B.  Date the tape or diskette was created.
                                C.  Floppy diskette, format density.  -Use HD for
                                   high density or DD for double density.
                                   (Applicable only to diskettes.)
                                D.  Year for which the data are reported.
                                E.  Number of this diskette or tape.
                                F.  Total number of diskettes or tapes in the
                                   package.
                                G.  Name and phone number of a facility
                                   computer contact person.
                                H.  File name or names on the tape or diskette.
THIS Report
(A)
Date
(B)
Report Yr.
Contact
Files


(D)
Density
Num. 
(G)

(C)
Of(F)

(H)

    Labels may be  typed or  legibly handwritten.  Any media  submitted without  a
proper label attached will not be processed and will be returned to the
submitter.   Exhibit 7 contains a sample diskette label.
                                   EXHIBIT  7
                                   At left is a sample diskette label for
                               American Manufacturing, which ,has  two  double
                               density  diskettes  in its  package.   The package
                               contains information on two  of  American's
                               facilities, but  the  labels should  only list
                               the  parent company,  American Manufacturing,
                               and  the  data  processing contact at American.
                               Diskette 1 contains  the files TRIOS, TRI07,
                               TRISE, and TRITR.

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                                     -24-

    5.2  Packaging and Shipping Requirements

    The type of packaging and method of shipment used for magnetic media are
left to the discretion of the submitting facility.  EPA accepts no
responsibility for packages lost or damaged during transit.  It is recommended
that the package be marked with the words "Magnetic Media - - Do Not X-Ray".

    All magnetic media packages must include self-addressed, postage paid
return packaging sufficient to allow EPA to return unreadable media to the
facility.

    Send complete magnetic media (properly  labeled)  along with  a cover letter
(containing an original certification signature from each submitting
facility), and cover page (if necessary) to:

       EPCRA Reporting Center
       P.O. Box 23779
       Washington, B.C.  20026-3779
       Attn:  Toxic Chemical Release Inventory
              Magnetic Media Submission

    Certified mail and hand-delivered submissions only should be addressed to:

       EPCRA Reporting Center
       470 L'Enfant Plaza East
       Suite 7103, SW
       Washington, DC  20024
       Attn:  Toxic Chemical Release Inventory
               Magnetic Media Submission

    Reports to the appropriate State agency must be  made in accordance with'
the instructions for completing Form R (see page 1 of this  document) .   A State
contact list is provided in the instructions document.  However,  a State may
not have the capability to accept magnetic media as specified in this
document.  In these cases, you must send copies of Form R to the State.
Alternatively, the State may have established a computer database but  have
different specifications for submission of section 313 data on magnetic media,
in which case you should contact the State representative listed in the Toxic
Chemical Release Inventory Reporting Package (EPA560/4-91-001)  for details.

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