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-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
Hay 1992
Dear Facility Compliance Manager:
OFFICE OF
PESTICIDES AND TOXIC
SUBSTANCES
This document contains complete instructions for preparing and
submitting your Toxic Chemical Release Inventory Form R reports for
1991, including new information as required by the Pollution
Prevention Act of 1990. You must use this version of Form R for
your 1991 submissions and not submit previous form versions.
Because of delays in finalizing and distributing the OMB-
approved 1991 Form R report and accompanying guidance, facilities
subject to EPCRA reporting may not have sufficient time to prepare
and submit their reports by July 1, 1992. EPA is aware that delay
in the distribution of the reporting package is creating concern
regarding potential enforcement actions, including civil penalties,
for those facilities reporting after the July 1, 1992 deadline.
In recognition of legitimate concerns and the importance to
the public that facilities submit complete and accurate Form R
reports, EPA will not initiate enforcement proceedings against
facilities that file accurate Form R reports between July 1, 1992
and September 1, 1992. Reports for the 1991 reporting year that
are filed after September 1, 1992 and/or contain inaccurate or
missing information, including errors or omissions, may be subject
to enforcement action, including, but not limited to, civil
penalties.
This determination applies only to violations of the EPCRA
§313 reporting obligations for Form R reports due on July 1, 1992,
covering calendar year 1991. Nothing in this determination shall
be construed to apply to any 'Other EPCRA reporting obligations of
facilities for Form R reports due for past or future reporting
years.
This action does not represent an administrative suspension of
the statutory deadline established by Congress. Rather, this
decision recognizes the inability of the government to provide
approved Form R reporting forms and the Administrator's discretion
to determine the appropriate enforcement response for violations of
EPCRA §313.
Sincerely,
Linda J. Fisher
Assistant Administrator
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Important Changes in the Section 313
Requirements for Reporting Year 1991
Reporting requirements for calendar year 1991 (reports (4)
due July 1,1992) differ from previous years:
(1) The following chemicals have been specifically
delisted and are not covered for the 1991 report-
ing year:
Chemical Name CAS Number
Terephthalic acid 100-21-0
Melamine 108-78-1
*C.I. Pigment Blue 15 147-14-8
Sodium hydroxide (solution) 1310-73-2 (5)
•*CI. Pigment Green 7 1328-53-6
Aluminum oxide (non-fibrous forms) 1344-28-1
C.I. Acid Blue 9 diammonium salt 2650-18-2
C.I. Acid Blue 9 disodium salt 3844-45-9
Sodium sulfate (solution) 7757-82-6
Titanium dioxide 13463-67-7
*C.I. Pigment Green 36 14302-13-7
These substances were delisted from the "Copper Com-
pounds" category.
(2) The following chemicals have been added to the
toxic chemical list and are covered for the 1991 (6)
reporting year:
Chemical Name
CAS Number
Bromotrifluoromethane (Halon 1301) 75-63-8
Trichlorofluoromethane (CFC-11) 75-69-4
Dichlorodifluoromethane (CFC-12) 75-71-8
Dichlorotetrafluoroethane (CFC-114) 76-14-2
Monochloropentafluoroethane (CFC-115) 76-15-3
Dibromotetrafluoroethane (Halon 2402) 124-73-2
Bromochlorodifluoromethane (Halon 1211) 353-59-3
(3) Reporting in Part H, Section S, "Source Reduc-
tion and Recycling Activities," is now manda-
tory under the Pollution Prevention Act of 1990.
All facilities required to file Form R are now
required to report any source reduction and
recycling activity engaged in during the report-
ing year. See the instructions for Part II, Section
8 for information about the new requirements.
(7)
Toxic chemicals that are used for energy recov-
erypurposesnowhaveaseparatereportingdata
element. If the reported toxic chemical is actu-
ally used for energy recovery and has a signifi-
cant heat of combustion value, that activity will
be reported as energy recovery. If the toxic
chemical is incinerated with no recovery of en-
ergy, or if the heat of combustion value of the
toxic chemical is too low to contribute signifi-
cantly to energy recovery, the activity will be
considered waste treatment.
The de minimis exemption has been revised;
beneficiation activities are no longer excluded
from this exemption. Under any circumstances,
toxic chemicals received in mixtures or trade
name products under the de minimis value of
one percent, or 0.1 percent if carcinogenic, are
exempted from threshold determinations and
release calculations.
QiceaUstedtoxiccherrdcalexceedsitsdeminimis
level, however, all releases occurring after that
point are subject to reporting.
A TRI facility identification number has been
assigned to each facility mat previously submit-
ted Form R reports. This identification number
is designed to simplify locating facility reports.
All facilities which submitted a Form R previ-
ously will receive a section 313 compliance pack-
age that includes a self-adhesive mailing label
with the TRI facility identification number. If
this package does not contain a mailing label or
you have misplaced it, contact the Emergency
Planning and Community Right-to-Know Infor-
mation Hotline for help in determining your TRI
facility identification number.
The toll-free telephone number for the Emer-
gency Planning and Community Right-to-Know
Information Hotline, 1-800-535-0202, is now ac-
cessible throughout the U.S., including Wash-
ington, D.C., and Alaska. The toll telephone
number has been changed to 703-920-9877.
Toxic Release Inventory Reporting Form R and Instructions
-------
Important Changes to Form R for 1991
The Form R for reporting year 1991 contains many •
changes. The changes were made to consolidate related
data elements and clarify reporting requirements. The
followingchangeshavebeenmadeforthel991reporting
year (reports due on or before July 1,1992): 9
• TheformatofFormRhasbeenchangedtomake
the data readable by the Optical Character Rec-
ognition (OCR) Scanner.
• Part n, Section 8 of Form R, "Source Reduction
and Recycling Activities," contains data elements
mandated by the Pollution Prevention Act of •
1990 (PPA).
• Form R now consists of two parts:
Part I. Facility Identification Informa-
tion (pages 1-2); and
Part n. Chemical-Specific Information •
(pages 3-9).
Par tn of previous FormRs, "Off-Site Locations
to which Toxic Chemicals are Transferred in
Wastes/' has been incorporated into Part n,
Section 6 of this year's form, "Transfers of the
ToxicChemical in Wastes to Off-Site Locations."
This change allows location information and
transferarnountstobereportedtogether. Partni •
of previous Form Rs, "Chemical-Specific Infor-
mation/'isnow Part II. PartlY of previous From
Rs, "Supplemental Information," has been elimi-
nated.
• A space was added to page 1 for indicating if the
form being submitted is a revision.
• Space has been made available to enter me toxic
chemical name and TRI facility identification
number on every page of Form R (minimum of 9
pages per FormR). These spaces are designed to
help ensure correct reporting by facilities and
correctdataenbybyEPA. Theyarenotrequired
data elements.
On page 1, Part I, Section 4.1, space has been
added for including the reporting facility's mail-
ing address if it differs from the street address.
The data elements for entering the names of
receiving streams and water bodies have been
incorporated into Part n, Section 5, "Releases of
the Toxic Chemical to the Environment On-
Site." As a result, the amount released will
appear next to the name of the receiving stream
or water body.
InPartlLSectionS/'Releasesof the ToxicChemi-
cal to the Environment On-Site," and Part n,
Section 6, "Transfers of the Toxic Chemical in
Wastes to Off-Site Locations," the range report-
ing columns havebeen removed. Space has been
added to enter either an estimate or a code
representing one of the three reporting ranges.
Information on off-site transfers for recycling
and energy recovery is included in Part II, Sec-
tion 6, "Transfers of the Toxic Chemical in Wastes
to Off-Site Locations." Section 6 has been modi-
fied to allow for more than one operation code
(i.e., waste treatment, disposal, recycling, or
energy recovery) and more than one amount to
be entered per location.
Section 6.1, 'Discharges to Publicly Owned Treat-
ment Works" now contains two parts: 6.1 .A,
'Total QuantityTransferred to POTWsand Basis
of Estimate," and 6.1.B, "POTW Name and Loca-
tion Information." If you transfer a toxic chemi-
cal in wastes to more than one POTW, enter the
total transfers to all POTWs in section 6.1.A.1,
and in section 6.1.A.2 enter the basis of estimate
for the total amount transferred. In section
6.1 .B., list the name and location of all POTWs
that received the toxic chemical in wastes.
ii Toxic Release Inventory Reporting Form R and Instructions
-------
if additional space is needed for completing
Sections5.3, "Discharges to Receiving Stream or
Water Body" and Section 6, "Transfers of the
Toxic Chemical in Wastes to Off-Site Locations,"
pages 5 and 6 should be photocopied, and the
extra pages submitted.
Part n, Section 7 A, "On-Site Waste Treatment
Methods and Efficiency," has been expanded
and now is the only data element on page 7 of
FormR. If additional space is needed for Section
7A (On-Site Waste Treatment Methods and Effi-
ciency), this page may be photocopied, and the
extra pages submitted. Page 8 contains two new
required data elements: Section 7B, "On-Site
Energy Recovery Processes," and Section 7C,
"On-Site Recycling Processes."
Page 9 consists of the required PPA data ele-
ments. Section 8, "Source Reduction and Recy-
cling Activities," is now a required section of
Form R. See Part H, Section 8 for the data
elements.
Toxic Release Inventory Reporting Form R and Instructions iii
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Toxic Release Inventory Reporting Form R and Instructions
Table of Contents
Page
A. General Information
A.I How to Assemble a Complete Report 1
A.2 Trade Secret Claims •• 1
A.3 Recordkeeping 2
A.4 When the Report Must Be Submitted 2
A.5 Where to Send the Form R 3
A.6 How to Obtain Forms and Other Information 3
A.7 Who Must Submit This Form 4
B. How to Determine if Your Facility Must Submit EPA Form R
B.I Full-Time Employee Determination 5
B.2 Primary SIC Code Determination • 5
B.2.a Multi-Establishment Facilities 5
B.2.b Auxiliary Facilities 7
B.2.C Facility-Related Exemptions 7
B.3 Activity Determination 8
B.3.a Definitions of "Manufacture," "Process," and "Otherwise Use" 8
B3.b Activity Exemptions ~ 9
B.3.C Activity Qualifiers = • 10
B.4 Threshold Determination H
B.4.a How to Determine If Thresholds Are Exceeded 11
B.4.b Mixtures and Trade Name Products 13
C Instructions for Completing EPA Form R
Parti. Facility Identification Information
Data Element
1. Reporting Year
2.1 Are You Claiming the Toxic Chemical Identity on Page 3 Trade Secret?.
2.2 If "Yes" in 1.1, Is This Copy Sanitized or Unsanitized?
3. Certification
4.1 Facility Name and Location
4.2 Full or Partial Facility Indication .
4.3 Technical Contact
4.4 Public Contact
4.5 Standard Industrial Classification (SIC) Code
4.6 Latitude and Longitude •
4.7 Facility, Dun and Bradstreet Number(s)
4.8 EPA Identification Number(s) •
4.9 NPDES Permit Number(s)
4.10 Underground Injection Well Code (UIC) Identification Number
5.1 Name of Parent Company
5.2 Parent Company's Dun and Bradstreet Number
.17
.17
.17
.17
.18
.18
,18
.18
.19
.19
.19
.19
.19
.19
.20
.20
iv Toxic Release Inventory Reporting Form Rand Instructions
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Toxic Release Inventory Reporting Form R and Instructions
Table of Contents
Part II. Chemical-Specific Information
Data Element
Page
1.1 CAS Number 21
1.2 Toxic Chemical or Chemical Category Name 21
1.3 Generic Chemical Name 21
2. Mixture Component Identity '. 22
2.1 Generic Chemical Name Provided by Supplier 22
3. Activities and Uses of the Toxic Chemical at the Facility 22
3.1 Manufacture of the Toxic Chemical 22
3.2 Process the Toxic Chemical 23
3.3 Otherwise Use the Toxic Chemical 23
4 Maximum Amount of the Toxic Chemical On-Site
at Any Time During the Calendar Year 25
5 Releases of the Toxic Chemical to the Environment On-Site 25
5.1 Fugitive or Non-Point Air Emissions 25
5.2 Stack or Point Air Emissions 26
5.3 Discharges to Receiving Streams or Water Bodies 26
5.4 Underground Injection On-Site 26
5.5 Releases to Land On-Site 26
5.5.1 Landfill „ 26
5.5.2 Land Treatment/Application Farming 26
5.5.3 Surface Impoundment .'. 26
5.5.4 Other Disposal 27
5.A Total Release 27
5.B Basis of Estimate 28
5.C Percent From Stormwater 30
6. Transfers of the Toxic Chemical in Wastes to Off-Site Locations 31
6.1 Discharges to Publicly Owned Treatment Works (POTW) 32
6.1.A.1 Total Transfers 32
6.1.A.2 Basis of Estimate 33
6.2 Transfer to Other Off-Site Locations .' 33
6.2A Total Transfers 34
6.2B Basis of Estimate 34
6.2C Type of Waste Treatment/Disposal/Recyding/Energy Recovery 34
7A On-Site Waste Treatment Methods and Efficiency 36
7A.a General Waste Stream 36
7A.b Waste Treatment Method(s) Sequence 37
7A.c Range of Influent Concentration <.. 39
7A.d Waste Treatment Efficiency Estimate '. 40
7A.e Based on Operating Data? 40
7B On-Site Energy Recovery Processes 40
7C On-Site Recycling Processes 41
8 Source Reduction and Recycling Activities 42
Toxic Release Inventory Reporting Form R and Instructions v
-------
Toxic Release Inventory Reporting Form R and Instructions
Table of Contents
Page
Table I SIC Codes 20-39 [[[ l~l
Table II Section 313 Toxic Chemical List for Reporting Year 1991 ........................................ II-l
TableHI State Abbreviations [[[ m~l
Appendix A Toxic Chemical Release Inventory Reporting Form R .............................................. A-l
Appendix B Reporting Codes for EPA Form R [[[ B'1
Appendix C Common Errors in Completing Form R Reports [[[ C-l
Appendix D Supplier Notification Requirements .............................. ..»•• .................................... ...D-l
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Reporting Form R Submission Checklist
1. Complete a separate Form R for each toxic
chemical or chemical category you are report-
ing.
Q l.a Enter CAS number and toxic chemical
name in Part II, Sections 1.1 and 1.2 (or
the toxic chemical category name and
category code in the CAS number sec-
tion);
Ul l.b Enter the toxic chemical, chemical cat-
egory, or generic chemical name and the
TRI facility identification number in the
appropriate space on every page of Form
R (optional); and
Ui l.c Enter information that applies only to
the toxic chemical or chemical category
being reported.
2. Complete the report with information from the
previous calendar year.
Ul 2.a Complete all sections, if applicable, or
enter NA;
Ul 2.b Include both Parts I and II (minimum of
9 pages); and
Q 2.c Sign the report certification (Part I, Sec-
tion 3).
3. Submit by July 1,1992, to:
Q 3.a EPA Headquarters (original signature
on Part I, Section 3 is required for each
form submitted to EPA) at the following
address:
EPCRA Reporting Center
P.O. Box 23779
Washington, D.C. 20026-3779
Attn: Toxic Chemical Release Inventory
and
4. Keep a copy of each Form Rand all supporting
, documentation for your files. (All such infor-
mation must be kept for three years.)
Additional requirements if claiming a toxic chemical
identity a trade secret (see Section A.2: Trade Secret
Claims):
1. Submit two complete Form R reports (mini-
mum of 9 pages);
Q l.a One that identifies the toxic chemical
("unsanitized");
Ul l.b One that provides a generic chemical
identity ("sanitized"); and
Ul l.c Certify both with an original signature
and date.
2. Provide two complete trade secret substantia-
tion forms:
Ul 2.a One that identifies the toxic chemical
("unsanitized");
Ul 2.b One that provides a generic chemical
identity ("sanitized"); and
Ul 2.c Certify both with an original signature
and date.
3. Check that the sanitized and unsanitized ver-
; sions are correctly identified in Part I, Section
2.2.
4. Originals of bothFormRsandboth trade secret
substantiation forms should be submitted to
EPA Headquarters (see address above).
5. Verify if submissionrequirements inyour state
differ from EPA's by contacting your state-
designated section 313 contact (see Appendix
F), and submit the correct version(s).
Ul 3.b State-designated section313 contact (see
Appendix F) or the designated official of
an Indian tribe.
Toxic Release Inventory Reporting Form R and Instructions vii
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A. General Information
Submission of EPA Form R, the Toxic Chemical Release
Inventory (TRI) Reporting Form, is required by section
313 of the Emergency Planning and Community Right-
to-Know Act (EPCRA, or Title IE of the Superfund
Amendments and Reauthorization Act of 1986), Public
Law 99-499. The information contained in Form R
constitutes a "report," and the submission of a report to
the appropriate authorities constitutes "reporting."
Reporting is required to provide the public with informa-
tion on the releases of listed toxic chemicals, in their
communities and to provide EPA with release informa-
tion to assist the Agency in determining the need for
future regulations. Facilities must report the quantities
of both routine and accidental releases of listed toxic
chemicals, as well as the maximum amount of the listed
toxic chemical on-site during the calendar year and the
amount contained in wastes transferred off-site.
ThePollutionPreventionAct, passed into lawin October,
1990 (Pub. L. 10,1-508), added reporting requirements to
Form R. These new requirements will affect all facilities
required to submit Form R under section 313 of EPCRA.
The new data, which is described in the preceding sec-
tion, "Important Changes to Form R for 1991," will be
required beginning with reports for calendar year 1991
(first reports due to EPA and States by July 1,1992).
A completed Form R must be submitted for each toxic
chemical manufactured, processed, or otherwise used at
each covered facility as described in the reporting rule in
40 CFR Part 372 (originally published February 16,1988,
in the Federal Register). These instructions supplement
and elaborate on the requirements in the reporting rule.
Together with the reporting rule, they constitute the
reporting requirements. All references in these instruc-
tions are to sections in the reportingrule unless otherwise
indicated.
A. 1 How to Assemble a Complete
Report
The Toxic Chemical Release Reporting Form, EPA Form
R, consists of two parts:
• Part I, Facility Identification Information (pages
1 and 2); and
• Part n, Chemical-Specific Information (pages
3-9).
Most of the information required in Part I of Form R can
be completed, photocopied, and attached to each chemi-
cal-specific report. However, Part I of each Form R
submitted musthave an original signature on the certifi-
cation statement and the trade secret designation mustbe
entered as appropriate. Part II must be completed
separately for each toxic chemical or chemical category.
Because a complete Form R consists of at least 9 unique
pages, any submissions containing less than 9 unique
pages is not a valid submission.
A complete reportfor any listed toxic chemical that is not
claimed as a trade secret consists of the following com-
pleted parts:
• Part I with aboriginal signature on the certifica-
tion statement (Section 2); and
• Part II (Section 8 is now mandatory).
Staple all 9 pages of each report together. If you check yes
on Part n, Section 8.12, you may attach additional infor-
mation on pollution prevention activities at your facility.
A.2 Trade Secret Claims
For any toxic chemical whose identity is claimed as a
trade secret, you must submit to EPA two versions of the
substantiation form as prescribed in 40 CFR Part 350,
published July 29,1988, in the Federal Register (53 FR
28772) as well as two versions of Form R. One set of
forms, the "unsanitized" version, should provide the
actual identity of the toxic chemical. The other set of
forms, the "sanitized" version, should provide only a
generic identity of the toxic chemical. If EPA deems the
trade secret substantiation form valid, only the sanitized
set of forms will be made available to the public.
Use the order form in this document to obtain copies of
the rule and substantiation form. Further explanation of
the trade secret provisions is provided in Parti, Sections
2.1 and 2.2, and Part H, Section 1.3, of the instructions.
In summary, a complete report to EPA for a toxic chemi-
cal claimed as a trade secret must include all of the
following:
• A completed "unsanitized" version of a Form R
report including the toxic chemical identity
(staple the pages together);
Toxic Release Inventory Reporting Form R and Instructions 1
-------
• A "sanitized" version of a completed Form R
reportin which the toxic chemical identity items
(Partn,Sections 1.1 and 1.2) have beenleftblank
but in which a generic chemical name has been
supplied (Part II, Section 1.3) (staple the pages
together);
• A completed "unsanitized" version of a trade
secret substantiation form (staple the pages to-
gether); and
• A "sanitized" version of a completed trade se-
cret substantiation form (staple the pages to-
gether).
Securely fasten all four reports together.
Some states also require submission of both sanitized
and unsanitized reports for toxic chemicals whose iden-
tity is claimed as a trade secret Others require only a
sanitized version. Facilities may jeopardize the trade
secret status of a toxic chemical by submitting an
unsanitized version of Form R to a state agency or Indian
tribe that does not require unsanitized forms. You may
identify an individual State's submission requirements
by contacting the appropriate state-designated Section
313 contact (see Appendix F).
A.3 Recordkeeping
Sound recordkeepingpractices are essential for accurate
and efficient TRI reporting. It is in the facility's interest,
as well as EPA's, to maintain records properly.
Facilities mustkeepacopy of eachFormR report filed for
at least three years from the date of submission. These
reports will be of use in subsequentyears when complet-
ing future Form R reports.
Facilities must also maintain those documents, calcula-
tions, worksheets, and other forms upon which they
relied to gather informationfor prior Form R reports. In
the event of a problem with data elements on a facility's
Form R, EPA may request documentation from the
facility that supports the information reported. In the
future, EPA may conduct data quality reviews of past
.Form R submissions. An essential component of this
process would be to review a facility's records for accu-
racy and reliability.
A partial list of records, organized by year, that a facility
should maintain include:
Previous years' Form Rs;
Section 313 Reporting Threshold Worksheets;
Engineering calculations and other notes;
Purchase records from suppliers;
Inventory data;
EPA (NPDES) permits;
EPCRA Section 312, Tier H Reports;
Monitoring records;
Flowmeter data;
RCRA Hazardous Waste Generator's Report;
Pretreatmentreports filed by the facility with the
local government;
Invoices from waste management companies;
Manufacturer's estimates of treatment efficien-
cies;
RCRA Manifests; and
Process diagrams that indicate emissions and
releases.
A.4 When the Report Must be
Submitted
Thereportfor any calendar year mustbe submitted on or
before July 1 of the following year (e.g., the report for
calendar year 1991, January-December, must be submit-
ted on or before July 1,1992).
Voluntary Revision of a Previous. Submission
Voluntary revisions must be submitted on a Form R
identical to the version originally submitted to EPA for
that reporting year. The Emergency Planning and Com-
munity Right-to-KhowlhfonnationHotlinecanhelp you
identify the version of Form R used for each reporting
year.
For the 1991 reporting year only, enter "X" in the space
marked "Enter 'X' here if this is a revision" on page 1 of
the form if you are making a voluntary revision to a
previous Form R submission. If you have obtained the
Document Control Numbeir (DCM) of the original sub-
mission from EPA, enter that number in red ink in any
available space on page 1 of the form. Enter the revised
datatotheFormRandcircleallchanges fromtheoriginal
submission in red ink. Sign the certification statement
and provide a current date.
2 Toxic Release Inventory Reporting Form Rand Instructions
-------
For reporting years prior to 1991, there are two options
for making voluntary revisions. The first is to submit a
photocopy of the original Form R submission (fromyour
file), with corrections made in red ink. Write the words
"VOLUNTARYREVKION", and the DocumentControl
Number (DCN), if available, on page 1 of the Form R, and
re-sign and re-date the certification statement on page 1.
The second is to obtain a blank Form R for the reporting
year affected by the correction(s). Complete all data
elements on this Form, but circle with red ink those data
elements that you have changed. A cover letter should
be included to clarify exactly which voluntary revisions
you have made.
Send the entire completed or revised Form R report to
EPA and the appropriate state agency (or the designated
official of an Indian tribe). Submissions for the next
calendar year are not considered revisions of a previous
year's data.
A.5 Where to Send the Form R
Form R submissions must be sent to both EPA and the
State (or the designated official of an Indian tribe). If a
Form R is not received by both EPA and the State (or the
designated official of an Indian tribe), the submitter is
considered out of compliance and subject to enforcement
action.
Send reports to EPA by mail to:
EPCRA Reporting Center
P.O. Box 23779
Washington, D.C. 20026-3779
Attn: Toxic Chemical Release Inventory
To submit a Form R via hand delivery or certified mail,
please call the Emergency Planning and Community
Right-to-Know Information Hotline to obtain the street
address of the EPCRA Reporting Center.
In addition, you must also send a copy of the report to the
State in which the facility is located. ("State" also in-
cludes: the District of Columbia, the Commonwealth of
Puerto Rico, Guam, American Samoa, the U.S. Virgin
Islands, the Northern Mariana Islands, and any other
territory or possession over which the U.S. has jurisdic-
tion.) Refer to Appendix F for the appropriate State
submission addresses.
Facilities located on Indian land should send a copy to the
Chief Executive Officer of the applicable Indian tribe.
Some tribes have entered into a cooperative agreement
with States; in this case, Form R submissions should be
sent to the entity designated in the cooperative agree-
ment.
Submission of section313 reports in magnetic media and
computer-generated facsimileformats has beenapproved
by EPA. EPA has developed a package called the "Toxic
Chemical Release Inventory Reporting System." The
easy-to-use diskette comes with complete instructions
for its use. Italso provides prompts and messages to help
you report according to EPA instructions. For copies of
the diskette you may call the EPCRA Hotline.
Many firms are offering computer software to assist
facilities in producing magnetic media submissions or
computer-generated facsimiles of Form R reports. To
ensure accuracy, EPA will only accept magnetic media
submissions and computer-generated facsimiles thatmeet
basic specifications established by EPA. To determine if
software offered by a firm meets these specifications,
EPA reviews ;and approves all software upon request.
Call the Emergency Planning and Community Right-to-
Know Information Hotline to identify the software that
has been approved by EPA for the current reporting year.
It should be noted, however, that some States may accept
only hard copies of Form R. If this is the case, a magnetic
media or computer-generated facsimile may be unac-
ceptable.
A.6 How to Obtain Forms and Other
Information
A copy of Form R is included in this booklet. Remove this
form and produce as many photocopies as needed.
Related guidance documents may be obtained from:
Section 313 Document Distribution Center
P.O. Box 12505
Cincinnati, OH 45212
See Appendix I for the document request form and
more information on available documents.
Questions about completing Form R may be directed to
the Emergency Planning and Community Right-to-Know
Information Hotline at the following address or tele-
phone numbers.
Toxic Release Inventory Reporting Form R and Instructions 3
-------
Emergency Planning and Community
Right-to-Know Information Hotline
U.S. Environmental Protection Agency
401M Street, S.W. (OS-120)
Washington, DC 20460
(800) 535-0202 or (703) 920-9877
from 830 am - 7:30 pm Eastern Time
(Mon-Fri, except Federal Holidays.)
EPA Regional Staff may also be of assistance. Refer to
Appendix G for a list of EPA Regional Offices.
A.7 Who Must Submit this Form
Section 313 of EPCRA requires that reports be filed by
owners and operators of facilities that meet all three of
the following criteria:
• The facility has 10 or more full-time employees;
and
• The facility is included in Standard Industrial
Classification (SIC) Codes 20 through 39; and
• The facility manufactures (defined to include
importing), processes, or otherwise uses any
listed toxic chemical in quantities equal to or
greater than the established threshold in the
course of a calendar year.
4 Toxic Release Inventory Reporting Form R and Instructions
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B. How to Determine if Your Facility Must Submit
EPA Form R
(See Figure 1 for more information.)
B.I Full-Time Employee
Determination
A "full-time employee," for purposes of section 313
reporting, is defined as 2,000 work hours per year. This
definition is dependent only upon the number of hours
worked by all employees for the facility during the
calendar year and not the number of persons working.
To determine the number of full-time employees work-
ing for your facility, add up the hours worked by all
employees during the calendar year, including contract
employees and sales and support staff working for the
facility, and divide the total by 2,000 hours. In other
words, if the total number of hours worked by all em-
ployees is 20,000 hours or more, your facility meets the
ten employee threshold.
Examples include:
• A facility consists of 11 employees who each
worked 1500 hours for the facility in a calendar
year. Consequently, the total number of hours
worked by all employees for the facility during
the calendar year is 16,500hours. Thenumberof
full-time employees for this facility is equal to
16,500hours divided by2,000hours per full-time
employee, or 8.3 full-time employees. Therefore,
even though 11 persons worked for this facility
during the calendar year, the number of hours
worked is equivalent to 8.3 full-time employees.
This facility does not meet the employee criteria
and is not subject to section 313 reporting.
• Another facility consists of 6 workers and 3 sales
staff. The 6 workers each worked 2,000 hours for
the facility in the calendar year. The sales staff
also each worked 2,000 hours in the calendar
year although they may have been on the road
. half of the year. In addition, 5 contract employ-
ees were hired for a period during which each
worked 400 hours for the facility. The total
number of hours is equal to the time worked by
theworkersatthefacility(12/000hours),plusthe
time worked by the sales staff for the facility
(6,000 hours), plus the time worked by the con-
tract employees at me facility (2,000 hours), or
20,000 hours. Dividing the 20,000 hours by 2,000
yields 10 full-time employees. This facility has
met the full-time employee criteria and may be
subject to reporting if the other criteria are met.
B.2 Primary SIC Code Determination
Standard Industrial Classification (SIC) codes 20-39 are
covered by the rule and are listed in Table I. The first two
digits of a 4-digit SIC code define a major business sector,
while the last two digits denote a facility's specialty
within the major sector. If you are not familiar with the
SIC codes that apply to your facility, contact your trade
association, Chamber of Commerce, or legal counsel. For
a detailed description of 4-digit SIC codes, refer to the
"Standard Industrial Classification Manual 1987."
Clothbound editions are available in most major libraries
or may be ordered through the National Technical Infor-
mation Service, 5285 Port Royal Road, Springfield, VA,
22161, (703) 487-4650. The access number for the
dothbound manual is PB87-100012, and the price is
$30.00.
Section 313 requires that reports be filed by "facilities,"
which are defined as "all buildings, equipment, struc-
tures, and other stationary items which are located on a
single site or on contiguous or adjacent sites and which
are owned or operated by the same person." The SIC
code system, however, classifies businesses not as "facili-
ties," but as "establishments," which are defined as
"distinct and separate economic activities [that] are per-
formed at a single physical location."
Guidelines for using these definitions to determine pri-
mary SIC codes for facilities are presented in the follow-
ing subsections.
B.2.a Multi-Establishment Faculties
Your facility may include multiple establishments that
have different SIC codes. If so, calculate the value of the
products produced or shipped from each establishment
within the facility and then use the following rule to
determine if your facility meets the SIC code criterion:
• Ifthetotalvalueoftheproductsshippedfromor
produced at establishments with primary SIC
codes between 20 and 39 is greater man 50
percent of the value of the entire facility's prod-
ucts and services, the entire facility meets the SIC
code criterion.
Toxic Release Inventory Reporting Form R and Instructions 5
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Figure 1
Determining Applicability of Section 313 Requirements
Does your facility have 10
or more full-time
employees?
(sea definition In these
Instructions)
Yes V
A/o
Is your facility classified
under SIC codes
20 through 39?
(see Table I In these
Instructions)
.t.
No
Does your facility
manufacture, process, or
otherwise use any listed
chemical or chemical
category?
(see Table II In these
Instructions)
Yes
Manufacture or Process
No
Reporting is not required
for any chemical at the
facility for this year.
""A
I
I
I
yes
Otherwise Use
Did your facility
otherwise use more thain
10,000 pounds of
the chemical in
the calendar year?
yes
Did your facility
manufacture or process
more than 25,000 pounds
of the chemical
in the calendar year?
Report must be filed
for this chemical
for this year.
No
yes
Report must be filed
for this chemical
for this year.
Reporting not required ,
for this chemical
for this year. I
-------
© IfanyoneestablishmentwithaprimarySICcode
between 20 and 39 produces or ships products
whose value exceeds the value of products and
services produced or shipped by any other es-
tablishment within the facility, the facility also
meets the SIC code criterion.
The value of production attributable to a particular
establishmentmaybeisolated by subtracting the value of
products obtained from other establishments within the
same facility that are incorporated into its final products.
This procedure eliminates the potential for "double count-
ing" production in situations where establishments are
engaged in sequential production activities at a single
facility.
Examples include:
• One establishment in a gold mining facility is
engaged primarily in the exploration of gold
deposits, developing mines, and mining gold.
This establishment deploys several means to
mine the gold, including crushing, grinding,
gravity concentration, froth flotation, amalgam-
ation, cyanidation, and the production of bullion
at the mine and mill sites (these processes are
classified under SIC code 1041). All of the ore
discovered through this establishment is deliv-
ered to a second establishment which is prima-
rily engaged in rolling, drawing, and extruding
the gold for sale and distribution. The smeltering
establishment in the facility is classified under
SIC code 3339. The facility could calculate the
value of production for each establishment sepa-
rately (both SIC code 1041 and 3339 having
separate values). Alternatively, the facility could
determine the value of the smelter operation by
subtracting the value of the ore produced from
the value of entire facility's production (Gross
value of facility - SIC code 1041 value=Value for
SIC code 3999). e
• A food processing establishment in a facility
processes crops grown atthe facility inaseparate
establishment. The facility could base the value
of the products of each establishment on the total
production value of each establishment. Alter-
natively, the facility could first determine the
value of the crops grown at the agricultural
establishment, and then calculate the contribu-
tion of the food processing establishment by
subtracting the crop value from the total value of
the product shipped from the processing estab-
lishment. (Value of product shipped from pro-
cessing - crop value = value of prpcessing
establishment) ' •
A covered multi-establishment facility must make toxic
chemical threshold determinations and,ifrequked,must
report all relevant information about releases, source
reduction, recycling, and waste treatment associated
with a listed toxic chemical for the entire facility, even
from establishments that are not in SIC codes 20-39. EPA
realizes, however, that certain establishments in a multi-
establishment facility can be, for all practical purposes,
separate business units. Therefore, individual establish-
ments may report releases separately, provided that the
total releases for the whole facility is represented by the
sum of releases reported by the separate establishments.
B.2.b Auxiliary Facilities
An auxiliary facility is one that supports another facility's
activities (e.g., research and development laboratories,
warehouses, storage facilities, and waste-treatment fa-
cilities). An auxiliary facility can assume the SIC code of
another covered facility if its primary function is to
service that other covered facility's operations. Thus, a
separate warehouse facility (i.e., one not located within
the physical boundaries of a covered facility) may be-
come a covered facility because it services a facility in SIC
codes 20-39. Auxiliary facilities that are in SIC codes 20-
39 are required to report if they meet the employee
criterion and reporting thresholds for manufacture, pro-
cess, or otherwise use. Auxiliary establishments that are
part of a multi-establishment facility must be factored
into threshold determinations for the facility as a whole.
B.2.c Facility-Related Exemptions
Laboratories: Listed toxic chemicals that are manufac-
tured, processed, or otherwise used in laboratory activi-
ties at a covered facility under the direct supervision of
a technically qualified individual do not have to be
considered for threshold and release calculations. How-
ever, pilot plant scale and specialty chemical production
do not qualify for this laboratory activities exemption.
Property Owners: You are not required to report if you
merely own real estate on which a facility covered by this
rule is located; fhatis, you haveno other business interest
in the operation of that facility (e.g., your company owns
an industrial park). The operator of that facility, how-
ever, is subject to reporting requirements.
Toxic Release Inventory Reporting Form Rand Instructions 7
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B.3 Activity Determination
B.S.a Definitions of "Manufacture,"
"Process," and "Otherwise Use"
Manufacture: The term "manufacture" means to pro-
duce, prepare/compound/orimportalisted toxic chemi-
cal. (See Part II, Section 3.1 of these instructions for
further clarification.)
Import is defined as causing the toxic chemical to be
imported into the customs territory of the United States.
If you order a listed toxic chemical (or a mixture contain-
ing the chemical) from a foreign supplier, then you have
imported the chemical when that shipment arrives at
your facility directly from a source outside of the United
States. By ordering the chemical, you have "caused it to
beimported/' even thoughyoumay have used animport
brokerage firm as an agent to obtain the toxic chemical.
The term manufacture also includes coincidental pro-
duction of a toxic chemical (e.g., as a byproduct or
impurity) as a result of the manufacture, processing,
otherwiseuse,ortreatmentof other chemical substances.
In the case of coincidental production of an impurity (i.e.,
a toxic chemical that remains in the product that is
distributed in commerce), the de minimis limitation,
discussed in Section B.4.b of these instructions, applies.
The de minimis limitation does not apply to byproducts
(e.g., a toxic chemical that is separated from a process
stream and further processed or disposed). Certain
listed toxic chemicals may be manufactured as a result of
wastewater treatment or other treatment processes. For
example, neutralization of acid wastewater can result in
the coincidental manufacture of ammonium nitrate (so-
lution).
Example 1: Coincidental Manufacture
Your company, a nitric acid manufacturer, uses am-
monia in a waste treatment system to neutralize an
acidic wastewater stream containing nitric acid. The
reaction of the ammonia and nitric acid produces an
ammoniumnitrate solution. Ammoniumnitrate solu-
tion is a listed toxic chemical, as £ire nitric acid and
ammonia. Your facility thus otherwise uses ammonia
as a reactant and manufactures ammonium nitrate
solution as a byproduct. If the ammonium nitrate
solution is produced in a quantity that exceeds the
threshold (e.g., 25,000 pounds for the reporting year),
the facility must report for the ammonium nitrate
solution. If more than 10,000 pounds of ammonia is
added to the wastewater treatment system, then the
facility must report for ammonia.
Process: The term "process" means the preparation of
a listed toxic chemical, after its manufacture, for distribu-
tion in commerce. Processing is usually the intentional
incorporation of a toxic chemical into a product (see Part
n, Section 3.2 of these instructions for further clarifica-
tion). Processing includes preparation of the toxic chemi-
cal in the same physical state or chemical form as fhat
received by your facility, or preparation that produces a
change in physical state or chemical form. The term also
applies to the processing of a mixture or other trade name
product (see Section B.4.b of these instructions) that
contains a listed toxic chemical as one component.
Otherwise Use: Theterm "otherwise use" encompasses
any activity involving a listed toxic chemical at a facility
that does not fall under the definitions of "manufacture"
or "process." A chemical that is otherwise used by a
y
Example 2: Typical Process and Manufacture Activities
Your company receives toluene, a listed toxic chemical, from another facility, and reac ts the toluene with
air to form benzoic acid. Your company processes toluene and manufactures benzole acid. Benzoic acid,
however, is not a listed toxic chemical and thus does not trigger reporting requirements.
Your facility combines toluene purchased from a supplier with various materials to form paint. Your
facility processes toluene.
Your company receives a nickel compound (nickel compound is a listed toxic chemical category) as a
bulk solid and performs various size-reduction operations (e.g., grinding) before packaging the
compound in 50 pound bags. Your company processes the nickel compound.
Your company receives a prepared mixture of resin and chopped fiber to be used in the injection molding
of plastic products. The resin contains a listed toxic chemical that becomes incorporated into the plastic.
Your facility processes the toxic chemical.
8 To&I&easelmwitoryReportingFprmRandlnsirticHoris
-------
Example 3: Otherwise Use
When your facility cleans equipment with toluene,
you are otherwise using toluene. Your facility also
separates two components of a mixture by dissolving
one component in toluene, and subsequently recovers
the toluene from the process for reuse or disposal.
Your facility otherwise uses toluene.
facility is not intentionally incorporated into a product
distributed in commerce (see Part II, Section 3.3 of these
Instructions for further clarification).
B.3.b Activity Exemptions
*
Use Exemptions. Certain uses of listed toxic chemicals
are specifically exempted:
• use as a structural component of the facility;
• use in routine janitorial or facility grounds main-
tenance;
• personal uses by employees or other persons;
• use of products containing toxic chemicals for
thepurposeofmaintainingmotor vehicles oper-
ated by the facility; or
• use of toxic chemicals contained in intake water
(used for processing or non-contact cooling) or
in intake air (used either as compressed air or for
combustion).
Article Exemptions. Quantities of alisted toxic chemical
contained in an article do not have to be factored into
threshold or release determinations when that article is
processed or otherwise used at your facility. An article
is defined as a manufactured item that is formed to a
specific shape or design during manufacture, that has
end-use functions dependent in whole or in part upon its
shape or design duringend-use, and that does notrelease
a toxic chemical under normal conditions of the process-
ing or otherwise use of that item at the facility.
If the processing or otherwise use of similar articles
results in a total release of less than 0.5 pounds of a toxic
chemical in a calendar year to any environmental media,
EPA will allow this release quantity to be rounded to
zero, and the manufactured items remain exempt as
articles. EPA requires facilities to round off and report all
estimates to the nearest whole number. The 0.5-pound
limitdoesnotapply to each individual article,butapplies
to the sum of all releases from processing or otherwise
use of like articles.
The article exemptionapplies to thenormal processing or
otherwise use of an article. It does not apply to the
manufacture of an article. Toxic chemicals processed
into articles produced at a facility must be factored into
threshold and release determinations.
A closed item containing toxic chemicals (e.g., a trans-
former containing PCBs) that does not release the toxic
chemicals during normal use is considered an article if a
facility uses the item as intended and the toxic chemicals
are not released. If a facility services the dosed item (e.g.,
a transformer) by replacing the toxic chemicals, the toxic
chemicals added during the reporting year must be
counted in threshold and release calculations.
Example 4: Article Exemption
Lead that is incorporated into a lead acid battery is processed to manufacture the battery, and therefore
mustbe counted toward threshold and release determinations. However, the use of thelead acid battery
elsewhere in the facility does not have to be counted. Disposal of the battery after its use does not
constitute a "release"; thus, the battery remains an article.
Metal rods that are extruded into wire are not articles because their form changes during processing.
If an item used in the facility is fragmented, the item is still an article if those fragments being discarded
remain identifiable as the article (e.g., recognizable pieces of a cylinder, pieces of wire). For instance,
an 8-foot piece of wire is broken into two 4-foot pieces of wire, without releasing any toxic chemicals.
Each 4-foot piece is identifiable as a piece of wire; therefore, the article status for these pieces of wire
remains intact.
Toxic chemicals received in the form of pellets are not articles because the pellet form is simply a
convenient form for further processing of the material.
Toxic Release Inventory Reporting Form R and Instructions 9
-------
When the processing or otherwise use of an item gener-
ates fumes, dust, filings, or grindings, the article exemp-
tion is not applicable. The toxic chemical(s) in the item
must be counted toward the appropriate threshold de-
termination, and the fumes, dust, filings, and grindings
must be reported as releases or wastes. Scrap pieces that
are recognizable as an article do not constitute a release.
B.S.c Activity Qualifiers
Tablell contains thelistof individual toxic chemicals and
categories of chemicals subject to 1991 calendar year
reporting. Some of the toxic chemicals listed in Table II
have parenthetic qualifiers listed next to them. A toxic
chemical that is listed without a qualifier is subject to
reporting in all forms in which it is manufactured, pro-
cessed, and otherwise used.
Fume or dust. Three of the metals on the list (aluminum,
vanadium, and zinc) contain the qualifier "fume or
dust." Fume or dust refers to dry forms of these metals
but does not refer to "wet" forms such as solutions or
slurries. As explained in Section B.3a of these instruc-
tions, the term manufacture includes the generation of a
toxic chemical as abyproductor impurity. In such cases,
a facility should determine if, for example, it generated
more than 25,000 pounds of aluminum fume or dust in
1991 as a result of its activities. If so, the facility must
report that it manufactures "aluminum (fume or dust)."
Similarly, there maybe certain technologies in which one
of these metals is processed in the form of a fume or dust
to make other toxic chemicals or other products for
distribution in commerce* In reporting releases, the
facility would only report releases of the fume or dust.
EPA considers dusts to consist of solid particles gener-
atedbyanymechanicalprocessingof materials including
crushing, grinding, rapid impact, handling, detonation,
and decrepitation of organic and inorganic materials
such as rock, ore, and metal. Dusts do not tend to
flocculate, excep tunder electrostatic forces. A fume is an
airborne dispersion consisting of small solid particles
created by condensation from a gaseous state, in distinc-
tion to a gas or vapor. Fumes arise from the heating of
solids such as lead. The condensation is often accompa-
nied by a chemical reaction, such as oxidation. Fumes
flocculate and sometimes coalesce.
Manufacturing qualifiers. Two of the entries to the
section 313 toxic chemical list contain a qualifier relating
to manufacture. For isopropyl alcohol, the qualifier is
"manufacturing — strong acid process." For saccharin,
the qualifier simply is "manufacturing." For isopropyl
alcohol, the qualifier means that only facilities manufac-
turing isopropyl alcohol by the strong acid process are
required to report. In the case of saccharin, only manu-
facturers of the toxic chemical are subject to the reporting
requirements. A facility that processes or otherwise uses
either toxic chemical would not be required to report for
those toxic chemicals. In both cases, supplier notification
does not apply because only manufacturers, not users, of
the toxic chemical must report.
Solutions. Two substances on the list, ammonium ni-
trate and ammonium sulfate, are qualified by the term
"solution," which refers to the physical state of these
toxic chemicals. Solid, molten, and pelletized forms of
these toxic chemicals are exempt from threshold and
release determinations. Only facilities thatmanufacture,
process, or otherwise use these toxic chemicals in the
form of a solution are required to report. Supplier
notification applies only if the toxic chemical is distrib-
uted as a solution.
Phosphorus (yellow or white). The listing for phospho-
rus is qualified by the term "yellow or white." This
means mat only manufacturing, processing, or otherwise
use of phosphorus in the yellow or white chemical form
triggers reporting.. Conversely, manufacturing, process-
ing, or otherwise use of "black" or "red" phosphorus
does not trigger reporting. Supplier notification also
applies only to distribution of yellow or white phospho-
rus.
Asbestos (friable). Thelistingfor asbestos is qualified by
the term "friable," referring to the physical characteristic
of being able to be crumbled, pulverized, or reducible to
a powder with hand pressure. Only manufacturing,
processing, or otherwise use of asbestos in the friable
form triggers reporting. Supplier notification applies
only to distribution of mixtures or trade name products
containing friable asbestos.
Aluminum Oxide (fibrous forms). The listing for alumi-
num oxide is qualified by the term "fibrous forms."
Fibrous refers to a man-made form of aluminum oxide
that is processed to produce strands or filaments which
can be cut to various lengths depending on the applica-
tion. Only manufacturing, processing, or otherwise use
of aluminum oxide in the fibrous form triggers reporting.
Supplier notification applies only to distribution of mix-
tures or trade name products containing fibrous forms of
aluminum oxide.
10 TotfcRdeaselnventoryReporHngFmmRandltKtructions
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B.4 Threshold Determination
Section 313 reporting is required if threshold quantities
are exceeded. Separate thresholds apply to the amount of
the toxic chemical that is manufactured, processed, or
otherwise used.
You must submit a report for any listed toxic chemical
that is manufactured Or processed at your facility in
excess of the following threshold:
• 25,000 pounds during the course of a calendar
year.
You must submit a report if the quantity of a listed toxic
chemical that is otherwise used at your facility exceeds:
• 10,000 pounds during the course of a calendar
year.
B.4.a How to Determine If Tour Facility Has
Exceeded Thresholds
To determine whether your facility has exceeded a sec-
tion313reportingthreshold,comparequantities of listed
toxic chemicals that you manufacture, process, or other-
wise use to the respective thresholds for those activities.
A worksheet is provided in Figure 2 to assist facilities in
determining whether they exceed any of the reporting
thresholds. This worksheet also provides a format for
maintaining reporting facility records. Use of this
worksheetisnotrequired and the completed worksheets)
should not accompany Form R reports submitted to EPA
and the State.
Completeaseparateworksheetfor each section313 toxic
chemical or chemical category. Base your threshold
determination for listed toxic chemicals with qualifiers
only on the quantity of the toxic chemical satisfying the
qualifier.
Use of the worksheet is divided into three steps:
Step 1 allows you to record the gross amount of the toxic
chemical or chemical category involved in activities
throughoutthe facility. Pureformsaswell as the amounts
of the toxic chemical or chemical category present in
mixtures or trade name products must be considered.
The types of activity (i.e., manufacturing, processing, or
otherwise using) for which the toxic chemical is used
must be identified because separate thresholds apply to
each of these activities. A record of the information
source(s) used should be kept. Possible information
sources include purchase records, inventory data, and
calculations by a process engineer. The data collected in
Step 1 will be totalled for each activity to identify the
overall amount of the toxic chemical or chemical cat-
egory manufactured (indudingimported), processed, or
otherwise used.
Step 2 allows you to identify uses of the toxic chemical or
chemical category that were included in Step 1 but are
exempt under section 313. Do not include in Step 2
exempt forms of the toxic chemical not included in the
calculations in Step 1. For example, if freon contained in
the building's air conditioners was not reported in Step
1, you would not include the amount as exempt in Step
2. Step 2 is intended for use when one form or use of the
toxic chemical is exempt while other forms require re-
porting. Note the type of exemption for future reference.
Also identify, if applicable, the fraction or percentage of
the toxic chemical present that is exempt. Add the
amounts in each activity to obtain a subtotal for ex-
empted amounts of the toxic chemical or chemical cat-
egories at the facility.
Step 3 involves subtracting the result of Step 2 from the
results of Step 1 for each activity. Compare this net sum
to the applicable activity threshold. If the threshold is
met or exceeded for any of the three activities, a facility
must submit a Form R for that toxic chemical or chemical
category. This worksheet should be retained in either
case todocumentyourdeterminationfor reporting ornot
reporting, but should not be submitted with the report.
Do not sum quantities of the toxic chemical that are
manufactured, processed, and otherwise used at your
facility, because each of these activities requires a sepa-
rate threshold determination. For example, if in a calen-
dar year you processed 20,000 pounds of a chemical and
you otherwise used 6,000 pounds of that same toxic
chemical, your facility has not met or exceeded any
applicable thresholdand thus isnotrequired to reportfor
that chemical.
You must submit a report if you exceed any threshold
for any listed toxic chemical or chemical category. For
example, if your facility processes 22,000 pounds of a
listed toxic chemical and also otherwise uses 16,000
pounds of that same toxic chemical, it has exceeded the
otherwise used threshold (10,000 pounds) and your
facility must report even though it did not exceed the
process threshold. However, in preparing your reports,
you must consider all non-exempted activities and all
releases of the toxic chemical from your facility, not just
releases from the otherwise use activity.
Toxic Release Inventory Reporting Form R and Instructions 11
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Also note that threshold determinations are based upon
the actual amounts of a toxic chemical manufactured,
processed, or otherwise used over the course of the
calendar year. The threshold determination may not
relate to the amount of a toxic chemical brought on-site
during the calendar year. For example, if a stockpile of
100,000 pounds of a toxic chemical is present on-site but
only20^00poundsisappliedtoaprocess/onlythe20,000
pounds processed is counted toward a threshold deter-
mination, not the entire 100,000 pounds of the stockpile.
Threshold Determinations for On-Site Reuse/Recycle
Operations.
Threshold determinations of listed toxic chemicals that
are recycled or reused at the facility are based only on the
amount of the toxic chemical that is added during the
year, not the total volume in the system. For example, a
facility operates a refrigeration unit that contains 15,000
pounds of ammonia at the beginning of the year. The
system is charged with 2,000 pounds of ammonia during
theyear. Thefacilityhas therefore "otherwiseused" only
2,000 pounds of the covered toxic chemical and is not
required to report (unless there are other "otherwise use"
activities of ammonia which, when taken together, ex-
ceed the reporting threshold). If, however, the whole
refrigeration unit was recharged with 15,000 pounds of
ammonia during the year, the facility would exceed the
otherwise use threshold, and be required to report.
This exemption does not apply to toxic chemicals "re-
cycled" off-site and returned to a facility. Such toxic
chemicals returned to a facility are treated as the equiva-
lent of newly purchased material for purposes of section
313 threshold determinations.
Threshold Determinations for Chemical Categories.
A number of chemical compound categories are subject
to reporting. See Table n for a listing of these toxic
chemical categories. When reporting for one of these
toxic chemical categories, all individual members of a
category that are manufactured, processed, or otherwise
used must be counted. However, threshold determina-
tions must be made separately for each of the three
activities. Do not include in these threshold determina-
tions for a category any chemicals that are also specifi-
cally listed section 313 toxic chemicals (see Table II) or
specific toxic chemicals that have been deleted from the
category (e.g., three compounds deleted from copper
compound category -- see the introduction to these
instructions). Specifically listed toxic chemicals are sub-
ject to their own, individual threshold determination.
Threshold determinations for metal-containing com-
pounds present a special case. If, for example, your
facility processes several differentlead compounds, base
your threshold determination on the total weight of all
lead compounds processed. However, if your facility
processes both the "parent" metal (lead) as well as one or
more lead compounds, you must make threshold deter-
minations for both because they are separately listed
toxic chemicals. If your facility exceeds thresholds for
both the parentmetal and compounds of thatsamemetal,
FJ*A allows you to file one combined report (e.g., one
report for lead compounds, including lead) because the
release information you will report in connection with
metal compounds will be the total pounds of the parent
metal released.
One other case involving metal compounds should be
noted. Some metal compounds may contain more than
one listed metal. For example, lead chromate is both a
lead compound and a chromium compound. In such
cases, if applicable thresholds are exceeded, you are
required to file two separate reports, one for lead com-
pounds and one for chromium compounds. Apply the
total weight of the lead chromate to the threshold deter-
minations for both lead compounds and chromium com-
pounds. However, only the amount of each parentmetal
released (not the amount of the compound) would be
reported on the appropriate sections of both Form Rs.
B.4.b Mixtures and Trade Name Products
Toxic chemicals contained in mixtures and trade name
products must be factored into threshold and release
determinations.
If your facility processed or otherwise used mixtures or
trade name products during the calendar year, you are
required to use the best information available to deter-
mine whether the components of a mixture are above the
de minimis concentration and, therefore, must be in-
cluded in threshold and release determinations. If you
know that a mixture or trade name product contains a
specific toxic chemical, combine the amount of the toxic
chemical in the mixture or trade name product with other
amounts of the same toxic chemical processed or other-
wise used at your facility for threshold and release
determinations. If you know that a mixture contains a
toxic chemical but no concentration information is pro-
vided by the supplier, you do not have to consider the
amount of the toxic chemical present in that mixture for
purposes of threshold and release determinations.
Toxic Release Inventory Reporting Form R and Instructions 13
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Example 5: Mixture and Trade Name Products
Scenario #1: Your facility uses 12,000 pounds of an industrial solvent (Solvent X) for equipment cleaning. The
Material Safety Data Sheet (MSDS) for the solvent indicates that it contains at least 50 percent methyl ethyl ketone
(MEK), a listed toxic chemical; however, it also states that the solvent contains 20 percent non-hazardous
surfactants. This is the only MEK-containing chemical used at the facility.
Follow these steps to determine if the quantity of the toxic chemical insolvent x exceeds the threshold for otherwise
use.
1) Determine a reasonable maximum concentration for the toxic chemical by subtracting out the non-
hazardous surfactants (i.e., 100%-20% = 80%).
2) Determine the midpoint between the known minimum (50%) and the reasonable maximum calculated
above (i.ev (80%-50%)/2+50 = 65%).
3) Multiply total weight of Solvent X otherwise used by 65 percent.
12,000 pounds x 0.65 = 7,800 pounds
4) Because the total amount of MEK otherwise used at the facility was less than the 10,000 pound otherwise
use threshold, the facility is not required to file a Form R for MEK.
Scenario #2: Your facility otherwise used 15,000 pounds of Solvent Y to clean printed circuit boards. The MSDS
for the solvent lists only that Solvent Y contains at least 80% of a listed toxic chemical which is only identified as
chlorinated hydrocarbons.
Follow these steps to determine if the quantity of the toxic chemical in solvent exceeds the threshold for otherwise
use.
1) Because the specific chemical is unknown, the Form R will be filed for "chlorinated hydrocarbons." This
name will be entered into Part n, Section 2.1, "Mixture Component Identity." (Note: Because your
supplier is claiming the toxic chemical identity a trade secret, you do nothave to file substantiation forms.)
2) The upper bound limit is assumed to be 100 percent and the lower bound limit is known to be 80 percent.
Using this information, the specific concentrationis estimated to be 90 percent (i.e., the mid-point between
upper and lower limits).
(1.0 + 0.80)72 = 0.90
3) The total weight of Solvent Y is multiplied by 90 percent when calculating for thresholds.
«
15,000 x 0.90 = 13,500
4) Because the total amount of chlorinated hydrocarbons exceeds the 10,000 pound otherwise used
threshold, you must file a Form R for this chemical.
14 ToxicReleaselrioeti^RepmtingFarmRandlristnictiotis
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Observe the following guidelines in estimating concen-
trations of toxic chemicals in mixtures when only limited
information is available:
• If you know the lower and upper bound concen-
trations of a toxic chemical in a mixture, use the
midpoint of these two concentrations for thresh-
old determinations.
• If you know only the lower bound concentration,
you should subtract out the percentages of any
other known components to determine a reason-
able upper bound concentration, and then deter-
mine a midpoint.
• If you have no information other than the lower
bound concentration, calculate a midpoint as-
suming an upper bound concentration of 100%.
• If you only know the upper bound concentra-
tion, you must use it for threshold determina-
tions.
• In cases where you only have a concentration
range available, you should use the midpoint of
the range extremes.
De Minimis Exemption. A listed toxic chemical does not
have to be considered if it is present in a mixture at a
concentration below a specified deminimis level. Thede
minimis level is 1.0%, or 0.1% if the toxic chemical meets
the OSHA carcinogen standard. See Table n for the de
minimis value associated with each listed toxic chemical.
For mixtures that contain more than one member of a
listed toxic chemical category, the de minimis level
applies to the aggregate concentration of all such mem-
bers and not to each individually. EPA included the de
minimis exemption in the rule as a burden-reducing step,
primarily because facilities are not likely to have informa-
tion on the presence of a toxic chemical in a mixture or
tradename product beyond that available in the product's
MSDS. The de minimis levels are consistent with OSllA
requirements for development of MSDS information
concerning composition.
For threshold determinations, the de minimis exemption
applies to:
• A listed toxic chemical in a mixture or trade
name product received by the facility.
• A listed toxic chemical manufactured during a
process where the toxic chemical remains in a
mixture or trade name product distributed by
the facility.
The de minimis exemption does not apply to:
• A toxic chemical manufactured at the facility
that does not remain in a product distributed by
the facility. A threshold determination must be
made on the annual quantity of the toxic chemi-
cal manufactured regardless of the concentra-
tion. For example, quantities of formaldehyde
created as a result of waste treatment must be
applied toward the threshold for "manufacture"
of this toxic chemical, regardless of the concen-
tration of this toxic chemical in the waste.
In general, when the de minimis exemption applies to
threshold determinations and the concentration of the
toxic chemical in the mixture is below the de minimis
limitation, then you are not required to report releases
associated with the processing or otherwise use of the
toxic chemical in that mixture. Note that it is possible to
meet the threshold for a toxic chemical on a facility-wide
basis, but not be required to calculate releases from a
particular process because that process involves only
mixtures containing the toxic chemical below the de
minimis level.
Application of the de minimis exemption to process
streams must also be reviewed. Mixtures containing
toxic chemicals can be added to a process or generated
within a process. A facility is required to consider and
report releases from the process once the de minimis
concentrationlevelhas been exceeded. Allreleases of the
toxic chemical from the process which occur after the de
minimis exemptionhas been exceeded are then subject to
reporting, regardless of whether or not the toxic chemical
concentration later falls to a level below the de minimis
exemption.
Supplier Notification. Beginning in 1989, suppliers of
facilities in SIC codes 20-39 are required to develop and
distribute a notice if the mixtures or trade name products
they manufacture or process, and subsequently distrib-
ute, contain listed toxic chemicals. These notices are
distributed to other companies in SIC codes 20-39 or to
companies that sell or otherwise distribute the product to
facilities in SIC codes 20-39. If a MSDS isnotrequired for
Toxic Release Inventory Reporting Form R and Instructions 15
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the mixture or trade name product, the notification must
be in writtenform (i.ev letter). Otherwise, thenotice must
be incorporated into or attached to the MSDS for that
product. The supplier notification requirement began
with the first shipment of a product in 1989 and must
accompany the first shipment each year thereafter. In
addition, a new or revised notice must be sent if a change
occurs in the product which affects the weight percent of
alistedtoxicchemicalorifitis discovered thataprevious
notice did notproperly identify the toxic chemicals or the
percentage by weight. For more information on supplier
notification, see Appendix D.
If listed toxic chemical concentrations are equal to or
above die de minimis cut-off level, your supplier must
identify the specific components as they appear in Table
n and provide their percentage com position by weight in
the mixture or product. If your supplier maintains that
the identity of a toxic chemical is a trade secret, a generic
identity that is structurally descriptive must be supplied
on the notice. A maximum concentration level must be
providedif your supplier contends fhatchemical compo-
sition information is a trade secret. In either case, you do
not need to make a trade secret claim on behalf of your
supplier (unless you consider your use of the proprietary
mixture a trade secret). On Form R, identify the toxic
chemical you are reporting according to its generic name
provided in the notification. (See the instructions for Part
n, Section 2 for more information.) If the listed toxic
chemical is present below the de minimis level, no noti-
fication is required.
16 ToxicRekaselnvenloryReportingFormRandlnstructions
-------
C. Instructions for Completing EPA Form R
The following are specific instructions for completing
eachpartofEPAFormR. Thenumberdesignationsofthe
parts and sections of these instructions correspond to
those in Form R unless otherwise indicated.
For all parts of Form R:
1. Typeorprintinformationontheformihtheunits
and format requested. Use black ink. (Using
blue ink for the certification signature is sug-
gested as a means of indicating its originality.)
2. All information on Form R is required.
3. Do not leave items in Parts I and II on Form R
blank unless specifically directed to do so; if an
item does not apply to you, enter not applicable,
NA, in the space provided. If your information
does not fill all the spaces provided for a type of
information, enter NA,inthenextblankspacein
the sequence.
4. Report releases, off-site transfers, and recycling
activities to the nearest pound. Do not report
fractions of pounds.
5. Do not submit an incomplete form. The certifi-
cation statement (Part I) specifies that the report
is complete as submitted. See page 1 of these
instructions for the definition of a complete sub-
mission.
6. When completing additional pages for Part n of
the form, number the additional information
sequentially from the prior sections of the form.
7. Indicateyour TRI Facility Identification Number
and the toxic chemical, toxic chemical category,
or generically named toxic chemical on which
you are reporting in the space provided in the top
right corner of eachpageofFormR. Completion
of this non-mandatory data element will greatly
aid your internal recordkeeping and the quality
of EPA's data entry process.
Part I. Facility Identification
Information
Section 1. Reporting Year
This is the calendar year to which the reported informa-
tion applies, not the year in which you are submitting the
report. Information for the 1991 reporting year must be
submitted on or before July 1,1992.
Section 2. Trade Secret Information
2.1 Are you claiming the chemical identity on
page 3 trade secret?
Answer this question only after you have completed the
rest of the report. The specific identity of the toxic
chemical being reported in Part II, Section 1, may be
designated as a trade secret. If you are making a trade
secret claim, mark "yes" and proceed to Section2.2. Only
check "yes" if it is your manufacturing, processing, or
otherwise use of the toxic chemical whose identity is a
trade secret. (See page 1 of these instructions for specific
information on trade secrecy claims.) If you checked
"no," proceed to Section 3; do not answer Section 2.2.
2.2 If "yes" in 2.1, is this copy sanitized or
unsanitized?
Answer this question only after you have completed the
rest of the report. Check "sanitized" if this copy of the
report is the public version which does not contain the
toxic chemical identity but does contain a generic name
in its place, and you have claimed the toxic chemical
identity trade secret in Part I, Section 2.1. Otherwise,
check "unsanitized."
Section 3.
Certification
The certification statement must be signed by the owner
or operator or a senior official with management respon-
sibility for the person (or persons) completing the form.
The owner, operator, or official must certify the accuracy
and completeness of the information reported on the
form by signing and dating the certification statement.
Each report must contain an original signature. Print or
type in the space provided the name and tide of the
person who signs the statement. This certification state-
ment applies to all the information supplied on the form
and should be signed only after the form has been
completed.
Toxic Release Inventory Reporting Form R and Instructions 17
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Section 4. Facility Identification
4.1 Facility Name and Location
Enter the name of your facility (plant site name or
appropriate facility designation), street address, mailing
address/ city, county, state, and zip code in the space
provided. Do not use a post office box number as the
street address. The street address provided should be
thelocation where the toxic chemicals are manufactured,
processed, or otherwise used. If your mailing address
and street address are the same, enter NA in the space for
the mailing address.
If you have submitted a Form R for previous reporting
years, a TRI Facility Identification Number has been
assigned to your facility. The TRI Facility Identification
Number appears (with other facility-specific informa-
tion) on the peel-off mailing label on the cover of this
Toxic Chemical Release Inventory Instructions for 1991
(EPA 700-K-92-002). Remove the mailing label from the
back of this document and apply it to the space marked
"place label here" in Part I, Section 4.1 of the blank Form
R.
If your mailing label is missing information required on
Form R, insert that information in the appropriate box in
Part I, Section 4.1. For example, if your label contains
your street address and not your mailing address, enter
your mailing address in the space provided.
If you do not have a mailing label or cannot locate your
TRI Facility Identification Number, please contact the
Emergency Planning and Community Right-to-Know
Information Hotline.
Enter"NA"inthespacefortheTRIFacilityIdentificatibn
numbej: if this is your first submission of a Form R.
4.2 Full or Partial Facility Indication
A covered facility must report all releases and source
reduction and recycling activities of a listed toxic chemi-
cal if it meets a reporting threshold for that toxic chemi-
cal. However, if the facility is composed of several
distinct establishments, EPAallows these establishments
to submit separate reports for the toxic chemical as long
as all releases of the toxic chemical from the entire facility
are accounted for. Indicate in Section 4.2 whether your
report is for the entire covered facility as a whole or for
part of a covered facility. Check box (a) if the toxic
chemical information applies to the entire covered facil-
ity. Check box (b) if the toxic chemical information
applies only to part of a covered facility.
Section 313 requires reports by "facilities," which are
defined as "all buildings, equipment, structures, and
other stationary items which are located on a single site
or on contiguous or adjacent sites and which are owned
or operated by the same person."
The SIC code system defines business "establishments"
as "distinct and separate economic activities [that] are
performed at a single physical location." Under section
372.30(c) of the reporting rule, you may submit a separate
Form R for each establishment, or for groups of establish-
ments in your facility, provided all releases and source
reduction and recycling activities involving the toxic
chemical from the entire facility are reported. This allows
you the option of reporting separately on the activities
involving a toxic chemical at each establishment, or
group of establishments (e.g., part of a covered facility),
rather than submitting a single Form R for that toxic
chemical for the entire facility. However, if an establish-
ment or group of establishments does not manufacture,
process, or otherwise use or release a toxic chemical, you
do not have to submit a report for that establishment or
group of establishments. (See also Section B.2.a of these
instructions.)
4.3
Technical Contact
Enter the name and telephone number (including area
code) of a technical representative whom EPA or State
officials may contact for clarification of the information
reported on Form R. This contact person does not have
to be the same person who prepares the report or signs
the certification statement and does not necessarily need
to be someone at the location of the reporting facility;
however, this person must be familiar with the details of
the report so that he or she can answer questions about
the information provided.
4.4
Public Contact
Enter the name and telephone number (including area
code) of a person who can respond to questions from the
public about the report. If you choose to designate the
same person as both the technical and the public contact,
you may enter "Same as Section 4.3" in this space. This
contact person does not have to be the same person who
prepares the report or signs the certification statement
18 Toxic Release Inventory Reporting Form R and Instructions
-------
and does not necessarily need to be someone at the
location of the reporting facility. If this space is leftblank,
the technical contact will be listed as the public contact in
the TRI database.
4.5 Standard Industrial Classification (SIC)
Code
Enter the appropriate 4-digit primary Standard Indus-
trial Classification (SIC) code for your facility (Table I
lists the SIC codes within the 20-39 range). If the report
covers more than one establishment, enter the primary 4-
digit SIC code for each establishment starting with the
primary SIC code for the entire facility. You are required
to enter SIC codes only for those establishments within
the facility that fall within SIC codes 20 to 39. If you do
not know your SIC code, check with your financial office
or contact your local Chamber of Commerce or State
Department of Labor.
4.6 Latitude and Longitude
Enter the latitudinal and longitudinal coordinates of
your facility. Sources of these data include EPA permits
(e.g., NPDES permits), county property records, facility
blueprints, and site plans. Instructions on how to deter-
mine these coordinates can be found in Appendix E.
Enter only numerical data. Do not preface numbers with
letters such as N or W to denote the hemisphere.
Latitude and longitude coordinates of your facility are
very important for pinpointing the location of reporting
facilities and are required elements on the Form R. EPA
encourages facilities to make the best possible measure-
ments when determining latitude and longitude. As
with any other data field, missing, suspect, or incorrect
data may generate a Notice of Technical Error to be
issued to the facility. (See Appendix C: Common Errors
in Completing Form R Reports).
4.7
Dun and Bradstreet Number
7748 (8:30 am to 8:00 pm, Eastern Time). If none of your
establishments has been assigned a D & B number, enter
not applicable, NA, in box (a). If only some of your
establishments have been assigned Dun and Bradstreet
numbers, enter those numbers in Part I, Section 4.7.
4.8 EPA Identification Number
The EPA I.D. Number is a 12-character number assigned
to facilities covered by hazardous waste regulations
under the Resource Conservation and Recovery Act
(RCRA). Facilities not covered by RCRA are not likely to
have an assigned I.D. Number. If your facility is not
required to have an I.D. Number, enter not applicable,
NA, in box (a). If your facility has been assigned EPA
Identification Numbers, you must enter those numbers
in the spaces provided in Section 4.8.
Enter the9-digit number assigned by Dun and Bradstreet
(D & B) for your facility or each establishment within
your facility. These numbers code the facility for finan-
cial purposes. This number maybe available from your
facility's treasurer or financial officer. You can also
obtain the numbers from your local Dun and Bradstreet
office (check the telephonebook White Pages). If a facility
does not subscribe to the D & B service, a "support
number" can be obtained from the Dun & Bradstreet
center located in Allentown, Pennsylvania, at (215) 882-
4.9
NPDES Permit Number
Enter the numbers of any permits your facility, holds
under the National Pollutant Discharge Elimination Sys-
tem (NPDES) even if the permit(s) do not pertain to the
toxic chemical being reported. This 9-character permit
number is assigned to your facility by EPA or the State
under the authority of the Clean Water Act If your
facility does not have a permit, enter not applicable, NA,
in Section 4.9a.
4.10 Underground Injection Well Code (UIC)
Identification Number
If your facility has a permit to inject a waste containing
the toxic chemical into Class 1 deep wells, enter the 12-
digit Underground Injection Well Code (UIC) identifica-
tion number assigned by EPA or by the State under the
authority of the Safe Drinking Water Act. If your facility
does not hold such a permit(s), enter not applicable, N A,
in Section 4.10a. You are only required to provide the
UIC number for wells that receive the toxic chemical
being reported.
Section 5. Parent Company Information
You must provide information on your parent company.
For purposes of Form R, a parent company is defined as
the highest level company, located in the United States,
that directly owns at least 50 percent of the voting stock
of your company. If your facility is owned by a foreign
entity, enter not applicable, NA, in this space. Corporate'
names should be treated as parent company names for
companies with multiple facility sites. For example, the
Toxic Release Inventory Reporting Form R and Instructions 19
-------
Bestchem Corporation is not owned or controlled by any
other corporation but has sites throughout the country
whosenames begin with Bestchem. In this case, Bestchem
Corporation would be listed as the "parent" company.
5.1 Name of Parent Company
Enter thenameof thecorporationor other business entity
that is your ultimate US parent company. If your facility
has no parent company, check the NA box.
5.2 Parent Company's Dun & Bradstreet Number
Enter the Dun and Bradstreet Number for your ultimate
US parent company, if applicable. The number may be
obtained from the treasurer or financial officer of the
company. If your parent company does not have a Dun
and Bradstreet number, check the NA box.
20 Toxic Release Inventory Reporting Form R and Instructions
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Part n Chemical Specific
Information
In Part II, you are to report on:
€> The toxic chemical being reported;
• The general uses and activities involving the
toxic chemical at your facility;
• Releases of the toxic chemical from the facility to
air, water, and land;
• Quantities of the toxic chemical transferred to
off-site locations;
• Information for on-site and off-site waste treat-
ment, energy recovery, disposal, and recycling
of the toxic chemical; and
• Source reduction activities.
Section 1. Toxic Chemical Identity
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS) registry
number in Section 1.1 exactly as it appears in Table II for
the chemical being reported. CAS numbers are cross-
referenced with an alphabetical list of chemical names in
Table II of these instructions. If you are reporting one of
the toxic chemical categories in Table II (e.g., chromium
compounds), enter the applicable category code in the
CAS number space. Toxic chemical category codes are
listed below and can also be found, in Table II.
Toxic Chemical Category Codes
N010 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Berylium compounds
N078 Cadmium compounds
N084 Clorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N230 Glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N575 Polybrominated biphenyls (PBBs)
N725 Selenium compounds
N740 Silver compounds
N760 Thallium compounds
N982 Zinc compounds
If you are making a trade secret claim, you must report
the CAS number or category code on your unsanitized
Form R and unsanitized substantiation form. Do not
include the CAS number or category code on your
sanitized Form R or sanitized substantiation form.
1.2 Toxic Chemical or Chemical Category Name
Enter the name of the toxic chemical or chemical category
exactly as itappears in Table II. If the toxicchemical name
is followed by a synonym in parentheses, report the
chemical by the name that directly follows the CAS
number (i.e., not the synonym). If the listed toxic chemi-
cal identity is actuallyaproducttradename(e.g.,dicofol)/
the 9th Collective Indexname is listed below it in brackets.
You may report either name in this case.
Do not list the name of a chemical that does not appear
in Table II, such as individual members of a reportable
toxic chemical category. For example, if you use silver
nitrate, do not report silver nitrate with its CAS number.
Report this chemical as "silver compounds" with its
category code, N740.
If you are making a trade secret claim, you must report
the specific toxic chemical identity on your unsanitized
Form R and unsanitized substantiation form. Do not
report the name of the toxic chemical on your sanitized
Form R or sanitized substantiation form. Include a ge-
neric name in Part II, Section 1.3 of your sanitized Form
R report.
EPA requests that the toxic chemical, chemical category,
orgenericnamealsobeplaced in theboxmarked "Chemi-
cal, Category, or Generic Name" in the upper right-hand
corner on all pages of Form R. While this space is not a
required data element, providing this information will
help you in preparing a complete Form R report.
1.3
Generic Chemical Name
Complete Section 1.3 only if you are claiming the specific
toxic chemical identity of the toxic chemical as a trade
secret and have marked the trade secret block in Part I,
Section 2.1 on page 1 of Form R. Enter a generic chemical
name that is descriptive of the chemical structure. You
must limit the generic name to seventy characters (e.g.,
numbers, letters, spaces, punctuation) or less. Do not
enter mixture names in Section 1.3; see Section 2 below.
Toxic Release Inventory Reporting Form R and Instructions 21
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In-house plant codes and other substitute names that are
not structurally descriptive of the toxic chemical identity
being withheld as a trade secret are not acceptable as a
generic name. The generic name must appear on both
sanitized and unsanitized Form R's, and the name must.
be the same as that used on your substantiation forms.
Section 2. Mixture Component Identity
Do not complete this section if you have completed
Section 1 of Part II. Report the generic name provided to
you by your supplier in this section if your supplier is
claiming the chemical identity proprietary or trade se-
cret. Do not answer "yes" in Part I, Section 2.1 on page
1 of the formif you complete this section. You do notneed
to supply trade secret substantiation forms for this toxic
chemical because it is your supplier who is claiming the
chemical identity a trade secret.
2.1 Generic Chemical Name Provided by
Supplier
Enter the generic chemicabaameinihis section only if the
following three conditions apply:
1. You determine that the mixture contains a listed
toxic chemical but the only identity you have for
that chemical is a generic name;
2. You know either the specific concentration of
that toxic chemical component or a maximum or
average concentration level; and
3. You multiply the concentration level by the total
annual amount of the whole mixture processed
or otherwise used and determine that you meet
the process or otherwise use threshold for that
single, generically identified mixture compo-
nent.
Example 6: Mixture Containing Unidentified
Toxic Chemical
Your facility uses 20/000 pounds of asolventthatyour
supplier has told you contains 80 percent "chlori-
nated aromatic/' their genericname for a toxic chemi-
cal subject to reporting under section 313. You
therefore know that you have used 16,000 pounds of
some listed toxic chemical which exceeds the "other-
wise use" threshold. You would file a Form R and
enter the name "chlorinated aromatic" in the space
provided in Part II, Section 2.
Section 3. Activities and Uses of the Toxic
Chemical at the Facility
Indicate whether the toxic chemical is manufactured
(including imported), processed, or otherwise used at
the facility and the general nature of such activities and
uses at the facility during the calendar year. Report
activities that take place only at your facility, not activi-
ties that take place at other facilities involving your
products. You mustcheckall the boxes in this section that
apply. If you are a manufacturer of the toxic chemical,
you must check (a) and /or (b), and at least one of (c), (d),
(e), or (f) in Section 3.1. Refer to the definitions of
"manufacture," "process," and "otherwise use" in the
general information section of these instructions or Part
40, Section 372.3 of the Code of Federal Regulations for
additional explanations.
3.1
Manufacture the Toxic Chemical
Persons who manufacture (including import) the toxic
chemical must check at least one of the following:
a. Produce - the toxic chemical is produced at the
facility.
b. Import - the toxic chemical is imported by the
facility into the Customs Territory of the United
States. (See Section B.3.a of these instructions for
further clarification of import.)
And check at least one of the following:
c. For on-site use/processing - the toxic chemical is
produced or imported and then further pro-
cessed or otherwise used at the same facility. If
you check this block, you must also check at least
one item in Part II, Section 3.2 or 3.3.
d. For sale/distribution - the toxic chemical is pro-
duced or imported specifically for sale or distri-
bution outside the manufacturing facility.
e. As a byproduct - the toxic chemical is produced
coincidentally during the production, process-
ing, otherwise use, or disposal of another chemi-
cal substance or mixture and, following its
production, is separated from that other chemi-
cal substance or mixture. Toxic chemicals pro-
duced and released as a result of waste treatment
or disposal are also considered byproducts.
22 Toxic Release Inventory Reporting Form R and Instructions
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f. As an impurity - the toxic chemical is produced
coincidentally as a result of the manufacture,
processing, or otherwiseuse of another chemical
but is not separated and remains primarily in the
mixture or product with that other chemical.
3.2 Process the Toxic Chemical (incorporative
activities)
a. As a reactant - A natural or synthetic toxic chemi-
cal used in chemical reactions for the manufac-
tureof another chemical substanceorofaproduct.
Includes, but is not limited to, feedstocks, raw
materials, intermediates, and initiators.
b. As a formulation component - A toxic chemical
added to a product (or product mixture) prior to
further distribution of the product that acts as a
performance enhancer during use of the prod-
uct. Examples of toxic chemicals used in this
capacity include, but are not limited to, addi-
tives, dyes, reaction diluents, initiators, solvents,
inhibitors, emulsifiers, surfactants, lubricants,
flame retardants, and rheological modifiers.
c. As an article component - A toxic chemical that
becomes an integral component of an article
distributed for industrial, trade, or consumer
use. One example is the pigment components of
paint applied to a chair that is sold.
d. Repscfaigzwg-Processingorpreparationofatoxic
chemical (or product mixture) for distribution in
commerce in a different form, state, or quantity.
This includes, but is not limited to, the transfer of
material from a bulk container, such as a tank
truck to smaller containers such as cans or bottles.
3.3 Otherwise Use the Toxic Chemical (non-
incorporative activities)
a. As a chemicalprocessingaid-A toxic chemical that
is added to a reaction mixture to aid in the
manufacture or synthesis of another chemical
substance but is not intended to remain in or
become part of the product or product mixture.
Examples of such toxic chemicals include, but
are not limited to, process solvents, catalysts,
inhibitors, initiators, reaction terminators, and
solution buffers.
b. As a manufacturingaid - A toxic chemical that aids
the manufacturing process but does not become
part of the resulting product and is not added to
the reaction mixture during the manufacture or
synthesis of another chemical substance. Ex-
amples include, but are not limited to, process
lubricants, metalworking fluids, coolants, re-
frigerants, and hydraulic fluids.
c. Ancillary or other use - A toxic chemical that is
used at a facility for purposes other than aiding
chemical processing or manufacturing as de-
scribed above. Examples include, but are not
limited to, cleaners, degreasers, lubricants, fuels,
and toxic chemicals used for treating wastes.
Example 7: Activities and Uses of Toxic Chemicals
In the example below, it is assumed that the threshold quantities for manufacture, process, or otherwise use
(25,000 pounds, 25,000 pounds, and 10,000pounds, respectively, for calendar year 1991) have been exceeded and
the reporting of listed toxic chemicals is therefore required.
Your facility manufactures sulfuric acid. Fifty percent is sold as a product. The remaining 50 percent is reacted
with naphthalene, forming phthalic acid and also producing sulfur dioxide fumes.
• Your company manufactures sulfuric acid, a listed toxic chemical, both for sale/distribution as a
commercial product and for on-site use/processing as a feedstock in the phthalic acid production
process. Because the sulfuric acid is a reactant, it is also processed. See Figure 3 for how this information
would be reported in Part n, Section 3 of Form R.
• Your facility also processes naphthalene, as a reactant to produce phthalic acid, a chemical not on the
section 313 list.
323-732 - 92 - 2 QL 3
Toxic Release Inventory Reporting Form R and Instructions 23
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Figure 3
ccr*TtnM -i Tovir» r*MPMlCAl mPMTirv (Important: DO NOT complete this
SECTION 1. TOXIC, CHEMICAL IDENTITY section If you complete Section 2 below.)
'm.
•"%S; ••':-,
•'^&'.;
DAS Number (lmportanu:Enteronly one number ^^exa^asftappiaisfln^SecflonSIS faL.!:Entef categoiycote If repofOng adtemisal category.)
7
-------
Section 4. Maximum Amount of the Toxic
Chemical On-Site at Any Time
During the Calendar Year
For data element 4.1 of Part II, insert the code (see below)
that indicates the maximum quantity of the toxic chemi-
cal (e.g., in storage tanks, process vessels, on-site ship-
ping containers) at your facility at any time during the
calendaryear. If the toxic chemical was presentatseveral
locations within your facility, use the maximum total
amount present at the entire facility at any one time.
Weight Range in Pounds
Range Code From...
To....
01
02
03
04
05
06
07
08
09
10
11
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
If the toxic chemical present at your facility was part of
a mixture or trade name product, determine the maxi-
mum quantity of the toxic chemical present at the facility
by calculating the weight percent of the toxic chemical
only.
Do not include the weight of the entire mixture or trade
name product. This data may be found in the Tier II form
your facility may have prepared under Section 312 of
EPCRA. See Part 40, Section 372.30(b) of the Code of
Federal Regulations for further information on how to
calculate the weight of the toxic chemical in the mixture
or trade name product. For toxic chemical categories
(e.g.,nickelcompounds),includeallchemical compounds
in the category when calculating the maximum amount,
using the entire weight of each compound.
Section 5. Releases of the Toxic Chemical to the
Environment On-Site
In Section 5, you must account for the total aggregate
releases of the toxic chemical to the environment from
your facility for the calendar year.
Do not enter the values in Section 5 in gallons, tons, liters,
or any measure other than pounds. You must also enter
the values as whole numbers. Numbers following a
decimal point are not acceptable.
Releases to the environment include emissions to the air,
discharges to surface waters, and on-site releases to land
and underground injection wells. If youhave no releases
to a particular media (e.g., stack air), you must check the
"NA" box or enter zero; do not leave any part of Section
5 blank. Check the box on the las t line of this section if you
use the additional space for Section 5.3 on page 5 of the
Form.
You are not required to count, as a release, quantities of
a toxic chemical that are lost due to natural weathering or
corrosion, normal/natural degradation of a product, or
normal migration of a toxic chemical from a product. For
example, amounts of a listed toxic chemical that migrate
from plastic products in storage do not have to be
counted in estimates of releases of that toxic chemical
from the facility. Also, amounts of listed metal com-
pounds (e.g., copper compounds) that are lost due to
normal corrosion of process equipment do nothave to be
considered as releases of copper compounds from the
facility.
All releases of the toxic chemical to the air must be
classified as either a point or non-point emission, and
included in the total quantity reported for these releases
inSectionsS.l and 5.2. Instructions for columns A, B, and
C follow the discussions of Sections 5.1 through 5.5.
5.1 Fugitive or Non-Point Air Emissions
Report the total of all releases of the toxic chemical to the
air that are not released through stacks, vents, ducts,
pipes, or any other confined air stream. You mu st include
(1) fugitive equipment leaks from valves, pump seals,
flanges, compressors, sampling connections, open-ended
lines, etc.; (2) evaporative losses from surface impound-
ments and spills; (3) releases from building ventilation
systems; and (4) any other fugitive or non-point air
emissions. Engineering estimates and mass balance
calculations (using purchase records, inventories, engi-
neering knowledge or process specifications of the quan-
tity of die toxic chemical entering product, hazardous
waste manifests, or monitoring records) may be useful in
estimating fugitive emissions.
Toxic Release Inventory Reporting Form R and Instructions 25
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5.2
Stack or Point Air Emissions
Report the total of all releases of the toxic chemical to the
air that occur through stacks, vents, ducts, pipes, or other
confined air streams. You must include storage tank
emissions. Air releases from air pollution control equip-
ment would generally fall in mis category. Monitoring
data, engineering estimates, and mass balance calcula-
tions may help you to complete this section.
5.3 Discharges to Receiving Streams or Water
Bodies
In Sections^ you are to enter thename(s) of the stream(s)
or water body(ies) to which your facility directly dis-
charges the toxic chemical on which you are reporting. A
to talofthreespacesareprovided;however,other streams
or water bodies to which the toxic chemical is discharged
can be reported in the additional spaces for Section 5.3
found on page 5 of Form R. Enter the name of each
receivingstreamorsurface water body to which the toxic
chemical being reported is directly discharged. Report
the name of the receiving stream or water body as it
appears on the NPDES permit for the facility. If the
stream is not covered by a permit, enter the name of the
off-site stream or water body by which it is publicly
known. Do not lista series of streams through which the
toxic chemical flows. Be sure to include the receiving
stream(s) or water body(ies) that receive stormwater
runoff from your facility. Do not enter names of streams
to which off-site treatmentplants discharge. Enter "NA"
in Section 5.3.1. if you do not discharge the listed toxic
chemical to surface water bodies.
Enter the total annual amount of the toxic chemical
released from all discharge points at the facility to each
receivingstream or water body. Include process outfalls
such as pipes and open trenches, releases from on-site
wastewatertreatmentsystems,andthecontributionfrom
stormwater runoff, if applicable (see instructions for
column C below). Do not include discharges to a POTW
or other off-site wastewater treatment facilities in this
section. These off-site transfers must be reported in Part
H, Section 6 of Form R.
Wastewater analyses and flowmeter data may provide
the quantities you will need to complete this section.
Discharges of listed acids (e.g., hydrogen fluoride; hy-
drogen chloride; nitric acid; phosphoric acid; and sulfu-
ric acid) may be reported as zero if the discharges have
beenneutralizedtopH6orabove. If wastewater contain-
ing a listed mineral acid is discharged below pH 6, then
releases of the mineral acid must be reported. In this case,
pH measurements may be used to estimate the amount
of mineral acid released.
If you must report more than three discharges to receiv-
ing streams or water bodies, check the box at the bottom
of page 4 and enter the additional information on the
followifigpage, in Section5.3, Additional Information on
Releases of the Toxic Chemical to the Environment On-
Site. In Section5.3 on page5, blanks in the data elements
are provided so you may continue the numeration you
began on page 4.
5.4 Underground Injection On-Site
Enter the total annual amount of the toxic chemical that
was injected into all wells, including Class I wells, at the
facility. Chemical analyses, injection rate meters, and
RCRA Hazardous Waste Generators Reports are good
sources for obtaining data that will be useful in complet-
ing this section. Check the Not Applicable "NA" box in
Section5.4 if you do notinject the reported toxic chemical
into underground wells.
5.5
Releases to Land On-Site
Four predefined subcategories for reporting quantities
released to land within the boundaries of the facility are
provided. Do not report land disposal at off-site loca-
tions in this section. Accident histories and spill records
may be useful (e.g., release notification reports required
under Section 304 of EPCRA and accident histories
required under Section 112(r)(7)(B)(ii) of the Clean Air
Act).
5.5.1 Landfill—Typically, the ultimate disposal method
for solid wastes is landfilling. Leaks from landfills need
not be reported as a release because the amount of the
toxic chemical in the landfill has already beenreported as
a release.
5.5.2 Land treatment/application f arming—Land treat-
ment is a disposal method in which a waste containing a
listed toxic chemical is applied onto or incorporated into
soil. While this disposal method is considered a release
to land, any volatilization of listed toxic chemicals into
me air occurring during the disposal operation must be
included in the total fugitive air releases reported in Part
H, Section 5.1 of Form R.
5.5.3 Surface impoundment—A surface impoundment
is a natural topographic depression, man-made excava-
tion, or diked area formed primarily of earthen materials
26 Toxic Release Inventory Reporting Form R and Instructions
-------
(although some may be lined with man-made materials),
which is designed to hold an accumulation of liquid
wastes or wastes containing free liquids. Examples of
surface impoundments are holding, settling, storage,
and elevation pits; ponds; and lagoons. If the pit, pond,
or lagoon is intended for storage or holding without
discharge, it would be considered to be a surface im-
poundment used as a final disposal method.
Quantities of the toxic chemical released to surface im-
poundments fhatare usedmerelyas part of a wastewater
treatment process generally must not be reported in this
section. However, if the impoundment accumulates
sludges containing the toxic chemical, you must include
an estimate in this section unless thesludges are removed
and otherwise disposed (in which case they should be
reported under the appropriate section of the form). For
the purposes of this reporting, storage tanks are not
considered to be a type of disposal and are not to be
reported in this section of Form R.
5.5.4 Other disposal — Includes any amount of a listed
toxic chemical released to land that does not fit the
categories of landfills, land treatment, or surface im-
poundment. This other disposal would include any
spills or leaks of listed toxic chemicals to land. For
example, 2,000 pounds of benzene leaks from a under-
ground pipeline into the land at a facility. Because the
pipe was only a few feet from the surface at the erupt
point, 30 percent of the benzene evaporates into the air.
The 600 pounds released to the air would be reported as
a fugitive air release (Part II, Section 5.1) and the remain-
ing 1,400 pounds would be reported as a release to land,
other disposal (Part II, Section 5.5.4).
S.Column A Total Release
Only on-site releases of the toxic chemical to the environ-
ment for the calendar year are to be reported in this
sectionofFormR. The totalreleases from your facility do
not include transfers or shipments of the toxic chemical
fromy our facility for sale or distribution in commerce, or
of wastes to other facilities for waste treatment, recy-
cling, disposal, or energy recovery (see Part n, Section 6
of these Instructions). Both routine releases, such as
fugitive air emissions, and accidental or non-routine
releases, suchas chemical spills, mustbe included in your
estimate of the quantity released. EPA requires no more
than two significant digits when reporting releases (e.g.,
7,521 pounds would be reported as 7,500 pounds).
Releases of Less Than 1,000 Pounds. For total annual
releases or off-site transfers of a toxic chemical from the
facility of less than 1,000 pounds, the amount may be
reported either as an estimate or by using the range codes
that have been developed. The reporting range codes to
be used are:
Code
A
B
C
Range (pounds)
1-10
11-499
500-999
Do not enter a range code and an estimate in the same box
in column A. Total annual releases or off-site transfers of
a toxic chemical from the facility of less than 1 pound may
be reported in one of several ways. You should round the
value to the nearest pound. If the estimate is 0.5 pounds
or greater, you should either enter the range code "A" for
"1-10" or enter "\" in column A. If the release is less than
0.5 pounds, you may round to zero and enter "0" in
column A.
Note that total annual releases of less than 0.5 pounds
from the processing or otherwise use of an article main-
tain the article status of that item. Thus, if the only
releases you have are from processing an article, and
such releases are less than 0.5 pounds per year, you are
not required to submit a report for that toxic chemical.
The 0.5-pound release determination does not apply to
just a single article. It applies to the cumulative releases
from the processing or otherwise use of the same type of
article (e.g., sheet metal or plastic film) that occurs over
the course of the calendar year.
Zero Releases. If you have no releases of a toxic chemical
to a particular medium, report either NA, not applicable,
or 0, as appropriate. Report NA only when there is no
possibility a release could have occurred to a specific
media or off-site location. If a release to a specific media
or off-site location could have occurred, but either did
not occur or the annual aggregate release was less than
0.5 pounds, report zero. However, if you report zero
releases, a basis of estimate must be provided in column
B.
For example, if hydrochloric acid is involved in the
facility's processing activities but the facility neutralizes
the wastes to a pH of 6 or above, then the facility reports
a 0 release for the toxic chemical. If the facility has no
underground injection well, "NA" would be written in
Part I, Section 4.10 and checked in Part n, Section 5.4 of
Form R. Also, if the facility does not landfill the acidic
waste, NA would be checked in Part n, Section 5.5.1 of
Form R.
Toxic Release Inventory Reporting Form R and Instructions 27
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Releases of 1,000 Pounds or More. For releases to any
medium that amount to 1,000 pounds or more for the
year, you must provide an estimate in pounds per year in
column A. Any estimate provided in column A should
be reported to no more than two significantfigures. This
estimate should be in whole numbers. Do not use
decimal points.
Calculating Releases. To provide the release informa-
tion required in column A in this section, you must use
all readily available data (including relevant monitoring
data and emissions measurements) collected at your
facility to meet other regulatory requirements or as part
of routine plant operations, to the extent you have such
data for the toxic chemical.
When relevant monitoring data or emission measure-
ments are not readily available, reasonable estimates of
the amounts released must be made using published
emission factors, material balance calculations, or engi-
neering calculations. You may not use emission factors
or calculations to estimate releases if more accurate data
are available.
No additional monitoring or measurement of the quan-
tities or concentrations of any toxic chemical released
into the environment or of the frequency of such re-
leases, beyond that which is required under other provi-
sions of law or regulation or as part of routine plant
operations, is required for the purpose of completing
Form R.
You mustestimate, as accurately as possible, the quantity
(in pounds) of the toxic chemical or chemical category
that is released annually to each environmental medium.
Include only the quantity of the toxic chemical in this
estimate. If thetoxicchemicalpresentatyour facility was
part of a mixture or trade name product, calculate only
the releases of the toxic chemical, not the other compo-
nents of the mixture or trade name product. If you are
only able to estimate the releases of the mixture or trade
name product as a whole, you must assume that the
release of the toxic chemical is proportional to its concen-
tration in the mixture or tradename product. See Part 40,
Section 372.30(b) of the Code of Federal Regulations for
further information on how to calculate the concentra-
tion and weight of the toxic chemical in the mixture or
trade name product
If you are reporting a toxic chemical category listed in
Table n of these instructions rather than a specific toxic
chemical, you must combine the release data for all
chemicals in the listed toxic chemical category (e.g., all
glycol ethers or all chlorophenols) and report the aggre-
gate amount for that toxic chemical category. Do not
report releases of each individual toxic chemical in thai-
category separately. For example, if your facility releases
3,000 pounds per year of 2-chlorophenol, 4,000 pounds
per year of 3-chlorophenol, and 4,000 pounds per year of
4-chlorophenol to air as fugitive emissions, you should
report that your facility releases 11,000 pounds per year
of chlorophenols to air as fugitive emissions in Part II,
Section 5.1.
For listed toxic chemicals with the qualifier "solution,"
such as ammoniumnitrate, at concentrations of 1 percent
(or 0.1 percent in the case of a carcinogen) or greater, the
chemical concentrations must be factored into threshold
and release calculations because threshold and release
amounts relate to the amount of toxic chemical in solu-
tion, not the amount of solution.
For metal compound categories (e.g., chromium com-
pounds), report releases of only the parent metal. For
example, a user of various inorganic chromium salts
would report the total chromium released regardless of
the chemical form (e.g., as the original salts, chromium
ion, oxide) and exclude any contribution to mass made
by other species in the molecule.
S.Column 6 Basis of Estimate
For each release estimate, you are required to indicate the
principal method used to determine the amount of re-
lease reported. You will enter a letter code that identifies
the method that applies to the largest portion of the total
estimated release quantity.
The codes are as follows:
M- Estimate is based on monitoring data or mea-
surements for the toxic chemical as transferred
to an off-site facility.
C- Estimate is.based on mass balance calculations,
such as calculation of the amount of the toxic
chemical in wastes entering and leaving process
equipment.
E- Estimate is based on published emission factors,
suchas those relatingreleasequantity to through-
put or equipment type (e.g., air emission fac-
tors).
28 Toxic Release Inventory Reporting Form R and Instructions
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Example 8: Calculating Releases and Transfers
Your facility disposes of 14,000 pounds of lead chromate (PbCrO4.PbO) in an on-site landfill and transfers 16,000
pounds of lead selenite (PbSeO4) to an off-site land disposal facility. You would therefore be submitting three
separate reports on the following: lead compounds, selenium compounds, and chromium compounds. However,
the quantities you would be reporting would be the pounds of "parent" metal being released or transferred off-
site. All quantities are based on mass balance calculations (See Section 5.B for information on Basis of Estimate
and Section 6.C for waste treatment or disposal codes and information on transfers of toxic chemicals in wastes).
You would calculate releases of lead, chromium, and selenium by first determining the percentage by weight of
these metals in the materials you use as follows:
Lead Chromate (PbCrO4.PbO) -
Lead 2Pb-
Chromium 1 Cr -
Lead chromate is therefore (% by weight)
Molecular weight
Molecular weight
Molecular weight
546.37
207.2x2 = 414.4
51.996
(414.4/546.37) = 75.85% lead and
(51.996/546.37) = 9.52% chromium
Lead Selenite (PbSeO4)
Lead 1 Pb
Selenium 1 Se
Lead selenite is therefore (% by weight)
Molecular weight = 350.17
Molecular weight = 207.2
Molecular weight = 78.96
(207.2/350.17) = 59,17% lead and
(78.96/350.17) = 22,55% selenium.
The total pounds of lead, chromium, and selenium released or transferred from your facility are as follows:
Lead
Release: 0.7585 x 14,000 = 10,619 pounds from lead chromate (round to 11,000 pounds)
Transfer: 0.5917 x 16,000 = 9,467 pounds from lead selenite (round to 9,500 pounds)
Chromium
Release: 0.0952 x 14,000 = 1,333 pounds from lead chromate (round to 1,300 pounds)
Selenium
Transfer: 0.2255 x 16,000 = 3,608 pounds of selenium from lead round to 3,600 pounds)
Toxic Release Inventory Reporting Form R and Instructions 29
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O- Estimate is based on other approaches such as
engineering calculations (e.gv estimating vola-
tilization using published mathematical formu-
las) or best engineering judgment. This would
indudeapplyingan estimated removal efficiency
to a treatment, even if the composition of the
waste before treatment was fully identified
through monitoring data.
For example, if 40 percent of stack emissions of the
reported toxic chemical were derived using monitoring
data/ 30 percent by mass balance, and 30 percent by
emission factors, you would enter the code letter "M" for
monitoring.
If the monitoring data, mass balance, or emission factor
used to estimate the release is not specific to the toxic
chemical being reported, the form should identify the
estimate as based on engineering calculations or best
engineering judgment.
If a mass balance calculation yields the flow rate of a
waste, but the quantity of reported toxic chemical in the
waste is based on solubility data, report "O" because
"engineering calculations" were used as the basis of
estimateofthequantityofthetoxicchemicalinthewaste.
If the concentration of the toxic chemical in the waste was
measured by monitoring equipment and the flow rate of
the waste was determined by mass balance, then the
primary basis of the estimate is "monitoring" (M). Even
though a mass balance calculationalso contributed to the
estimate, "monitoring" should be indicated because
monitoring data was used to estimate the concentration
of the waste.
Mass balance (C) should only be indicated if it is directly
used to calculate the mass (weight) of toxic chemical
released. Monitoring data should be indicated as the
basis of estimate only if the toxic chemical concentration
is measured in the waste being released into the environ-
ment Monitoring data should not be indicated, for
example/if themonitoringdatarelatestoaconcentration
of the toxic chemical in other process streams within the
facility.
Itisimportantto realize thattheaccuracy and proficiency
of release estimation will improve over time. However,
submitters are not required to use new emission factors
or estimation techniques to revise previous Form R
submissions.
B.Column C Percent From Stonnwater
This column relates only to Section 5.3 — discharges to
receiving streams or water bodies. If your facility has
monitoring data on the amount of the toxic chemical in
stormwater runoff (including unchanneled runoff), you
must include that quantity of the toxic chemical in your
water release in column A and indicate the percentage of
the total quantity (by weight) of the toxic chemical
contributed by stormwater in column C (Section 5.3C).
If your facility has monitoring data on the toxic chemical
and an estimate of flow rate, you must use this data to
determine the percent stormwater.
If you have monitored stormwater but did not detect the
toxic chemical, enter zero (0) in column C. If your facility
has no stormwater monitoring data for the chemical,
enter not applicable, "NA," in this space on the form.
If your facility does not have periodic measurements of
stormwater releases of the toxic chemical, but has sub-
mitted chemical-specific monitoring data in permit ap-
plications, then these data must be used to calculate the
percent contribution from stormwaier. Rates of flow can
be estimated by multiplying the annual amount of rain-
fall by the land area of the facility and then multiplying
that figure by the runoff coefficient. The runoff coeffi-
cientrepresents the fraction of rainfall that does not seep
into the ground but runs off as storrnwater. The runoff
coefficient is directly related to how the land in the
drainage area is used. (See table below.)
Description of Land Area Runoff Coefficient
Business
Downtown areas
Neighborhood areas
Industrial
Light areas
Heavy areas
Railroad yard areas
Unimproved areas
Streets
Asphaltic
Concrete
Brick
Drives and walks
Roofs
Lawns: Sandy Soil
Flat, 2%
Average, 2-7%
Steep, 7%
0.70-0.95
0.50-0.70
0.50-0.80
0.60-0.90
0.20-0.40
0.10-0.30
0.70-0.95
0.80-0.95
0.70-0.85
0.70-0.85
0.75-0.95
0.05-0.10
0.10-0.15
0.15-0.20
30 Toxic Release Inventory Reporting Form R and Instructions
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Example 9: Releases from Stormwater
Your stormwater monitoring data shows that the average concentration of zinc in the stormwater runoff from
your facility from a biocide containing a zinc compound is 1.4 milligrams per liter, and the total annual stormwater
discharge from the facility is 7.527 million gallons. The total amount of zinc discharged to surface water through
the plant wastewater discharge (non-stormwater) is 250 pounds per year. The total amount of zinc discharged
with stormwater is:
(7,527,000 gallons stormwater) x (3.785 liters/gallon) = 28,489,695 liters stormwater
(28,489,695 liters stormwater) x (1.4 mg. zinc/liter) =. 39,885.6 grams zinc = 88 pounds zinc
The total amount of zinc discharged from all sources of your facility is:
250 pounds zinc from wastewater discharge
+ 88 pounds zinc from stormwater runoff
338 pounds zinc total water discharge
Round to 340 pounds of zinc on Form R.
The percentage of zinc discharged through stormwater is:
88/338x100 = 26%
Lawns: Heavy Soil
Flat, 2%
Average, 2-7%
Steep, 7%
0.13-0.17
0.18-0.22
0.25-0.35
Choose the most appropriate runoff coefficient for your
site or calculate a weighted-average coefficient, which
takes into account different types of land use at your
facility:
Weighted-average runoff coefficient =
(Area 1 % of total)(Cl) + (Area 2 % of total)(C2) +
(Area 3 % of total)(C3) + ... + (Area i % of total)(Ci)
where Ci = runoff coefficient for a specific
land use of Area i.
Section 6 Transfers of the Toxic Chemical in
Wastes to Off-Site Locations
You must report in this section the total annual quantity
of the toxic chemical in wastes sent to any off-site facility
for the purposes of waste treatment, disposal, recycling,
or energy recovery. Note that beginning with reporting
year 1991, off-site transfers for the purposes of recy-
cling and energy recovery are required to be reported.
Report the total amount of the toxic chemical transferred
off-site after any on-site waste treatment, recycling, or
removal is completed. Do not report transfers of listed
mineral acids if they have been neutralized to a pH of 6
or above prior to discharge to a Publicly Owned Treat-
mentWorks (POTW).
If you do not discharge wastewater containing the re-
ported toxic chemical to a POTW, enter not applicable,
NA, in the box for the POTW's name in Section 6.1 .B._. If
you do not ship or transfer wastes containing the re-
ported toxic chemical to other off-site locations, enter not
applicable, NA, in the box for the off-site location's EPA
Identification Number in Section 6.2._.
Important: Beginning with the 1991 reporting year, you
must number the boxes for reporting the information for
each POTW or other off-site location in Sections 6.1 and
6.2. In the upper left hand corner of each box, the section
number is either 6.1.B._ or 6.2._.
If you report a transfer of the listed toxic chemical to one
or more POTW, number the boxes in Section 6.1.B as
6.1.B.1,6.1.B.2/ etc. If you transfer the listed toxic chemi-
cal to more than two POTWs, photocopy page 5 of Form
Ras many times as necessary and then number the boxes
consecutively for each POTW. At the bottom of page 5
you will find instructions for indicating the total number
of page 5s that you are submitting as part of Form R, as
well as indicating the sequence of those pages. For
Toxic Release Inventory Reporting Form R and Instructions 31
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Example 10: Stormwater Runoff
Your facility is located in a semi-arid region of the United States which has an annual precipitation (including
snowfall) of 12 inches of rain. (Snowfall should be converted to the equivalent inches of rain; assume one foot
of snow is equivalent to one inch of rain.) The total area covered by your facility is 42 acres (about 170,000 square
meters or 1,829/520 square feet). The area of your facility is 50 percent unimproved area, 10 percent asphaltic
streets, and 40 percent concrete pavement.
The total stormwater runoff from your facility is therefore calculated as follows:
Land Use
Unimproved area
Asphaltic streets
Concrete pavement
Runoff
%JCoiaLArea Coefficient
50
10
40
0.20
0.85
0.90
Weighted-average runoff coefficient = (50%) x (0.20) + (10%) x (0.85) + (40%) x (0.90) = 0.545
(Rainfall) x (land area) x (conversion factor) x (runoff coefficient) = stormwater runoff
(1 foot) x (1,829,520 ffa) x (7.48 gal/fb) x (0545) = 7,458,221 gallons/year
Total stormwater runoff = 7.45 million gallons/year
example, your facility transfers the reported toxic chemi-
cal in wastewaters to three POTWs. You would photo-
copy page 5 once, indicate at the bottom of each page 5
that there are a total of two page 5s and then indicate the
first and second page5. The boxes for the two POTWs on
the first page 5 would be numbered 6.1.B.1 and 6.1.B.2,
while the box for the third POTW on the second page 5
would be numbered 6.1.B.2-
If you report a transfer of the listed toxic chemical to one
or more other off-site locations, number the boxes in
Section 6.2 as 6.2.1,6.2.2, etc. If you transfer the listed
toxic chemical to more than two other off-site locations,
photocopy page 6 of Form R as many times as necessary
and thennumbertheboxesconsecutivelyfor each off-site
location. At the bottom of page 6 you will find instruc-
tions for indicating the total number of page 6s that you
are submittingas partof Form R as well as indicating the
sequence of those pages. For example, your facility
transfers the reported toxic chemical to three other off-
site locations. You would photocopy page 6 once, indi-
cate at the bottom of each page 6 that mere are a total of
two page 6s and then indicate the first and second page
6.Theboxesforthetwooff-sitelocationsonthefirstpage
6 would be numbered 6.2.1 and 6.2.2, while the box for
the third off-site location on the second page 6 would be
numbered 6.2.3.
6.1 Discharges to Publicly Owned Treatment
Works (POTW)
In Section 6.1.A, estimate me quantity of the reported
toxic chemical transferred to all POTWs and the basis
upon which the estimate was made. In Section 6.1.B,
enter fhename and address for each POTW to which your
facility discharges wastewater containing the reported
toxic chemical.
If you do not discharge wastewater containing the re-
ported toxic chemical to a POTW, enter not applicable,
NA, in the box for the POTWs name in Section 6.1.B._.
6.1.A.1 Total Transfers
s
Enter the total amount, in pounds, of the reported toxic
chemical that is contained in the wastewaters transferred
to all POTWs. Do not enter the total poundage of the
wastewaters. If the total amount transferred is less than
1,000 pounds, you may report a range by entering the
appropriate range code. The following reporting range
codes are to be used:
32 Toxic Release Inventory Reporting Form R and Instructions
-------
Code Reporting Range (in pounds)
A 1-10
B 11-499
C 500-99
6.1.A.2 Basis of Estimate
You must identify the basis for your estimate of the total
quantity of the reported toxic chemical in the wastewa-
ters transferred to all POTWs. Enter one of the following
letter codes that applies to the method by which the
largest percentage of the estimate was derived.
M- Estimate is based on monitoring data or mea-
surements for the toxic chemical as transferred
to an off-site facility.
C - Estimate is based on mass balance calculations,
such as calculation of the amount of the toxic
chemical in streams entering and leaving pro-
cess equipment.
E- Estimate is based on published emission factors,
such as those relatingreleasequantity to through-
put or equipment type (e.g., air emission fac-
tors).
O - Estimate is based on other approaches such as
engineering calculations (e.g., estimating vola-
tilization using published mathematical formu-
las) or best engineering judgment. This would
include applyinganestimated removal efficiency
to a waste stream, even if the composition of the
stream before treatment was fully identified
through monitoring data.
If you transfer a toxic chemical to more than one POTW,
you should report the basis of estimate that was used to
determine the largest percentage of the toxic chemical
that was transferred.
6.2
Transfers to Other Off-Site Locations
In Section 6.2, enter the EPA Identification Number,
name, and address for each off-site location to which
your facility ships or transfers wastes containing the
reported toxic chemical for the purposes of waste treat-
ment, disposal, recycling, or energy recovery. Also
estimate the quantity of the reported toxic chemical
transferred and the basis upon which the estimate was
made. If appropriate, youmustreportmultiple activities
(up to four) for each off-site location. For example, if your
facility sends a reported toxic chemical in wastes to an
off-site location where some of the toxic chemical is to be
recycled while the remainder of the quantity transferred
is to be treated, you mustreport both the waste treatment
and recycle activities, along with the quantity associated
with each activity.
If you do not ship or transfer wastes containing the
reported toxic chemical to other off-site locations, enter
not applicable, NA, in the box for the off7site location's
EPA Identification Number in Section 6.2._. The EPA
Identification Number (defined in 40 CFR 260.10 and
therefore commonly referred to as the RCRA ID Num-
ber) may be found on the Uniform Hazardous Waste
Manifest, which is required by RCRA regulations. If you
ship pr transfer wastes containing a toxic chemical and
the off-site location does not have an EPA Identification
Number (e.g., itdoesnot acceptRCRAhazardous wastes
or the wastes in question arenotclassified as hazardous),
enter NA in the box for the off-site location EPA Identi-
fication Number. If you ship or transfer the reported
toxic chemical in wastes to another country, enter the
Federal Information Processing Standards (PIPS) code
for that country in the county field of the address for the
off-site facility. The most commonly used FIPS codes are
listed below.
The following is an abridged list of countires to which a
U.S. facility might ship a listed toxic chemical. For a
complete listing of FIPS codes, consult your local library.
Country
Argentina
Belgium
Bolivia
Brazil
Canada
Chile
Columbia
Costa Rica
Cuba
Ecuador
El Salvador
France
Guatemala
Honduras
Ireland
Italy
Mexico
Nicaragua
Panama
Paraguay
Peru
Code
AR
BE
BL
BR
CA
CI
CO
CS
CU
EC
ES
FR
GT
HO
El
IT
MX
NU
PM
PA
PE
Toxic Release Inventory Reporting Form R and Instructions 33
-------
Country Code
Portugal PO
Spain SP
Switzerland SZ
United Kingdom UK
Uruguay UY
Venezuela VE
You must distinguish between incineration, which is
always considered waste treatment, and combustion
where energy is actually recovered. When the reported
toxic chemical has a significantheat of combustion value,
and is transferred to an off-site location for combustion
in an industrial kiln, furnace, or boiler, report the quan-
tity as used for the purposes of energy recovery. How-
ever, toxic chemicals with little or no heat of combustion
value (e.g., metals, chlorofluorocarbons) must be re-
ported as treated.
6.2 column A Total Transfers
For each off-site location, enter the total amount, in
pounds, of the toxic chemical that is contained in the
waste transferred to that location. Do not enter the total
poundage of the waste. If the total amount transferred is
less man 1,000 pounds, you may report a range by
entering the appropriate range code. The following
reporting range codes are to be used:
Cude
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999 .
If you transfer the toxic chemical in wastes to an off-site
facility for distinct and multiple purposes, you must
report those activities (up to four) for each off-site loca-
tion, along with the quantity of the reported toxic chemi-
cal associated with each activity. For example, your
facility transfers a total of 15,000 pounds of toluene to an
off-site location that will use 5,000 pounds for the pur-
poses of energy recovery, enter 7,500 pounds into a
recovery process, and dispose of the remaining 2,500
pounds. These quantities and the associated activity
codes must be reported separately in Section 6.2. (See
Figure 4 for a hypothetical Section 6.2 completed for two
off-site locations, one of which receives the transfer of
15,000 pounds of toluene as detailed.) If more than four
activities are performed on distinct quantities at the off-
site location, list the predominant four activities but still
report all quantities sent to the off-site location.
Do not doubleor multiple countamounts transferred off-
site. For example, when a reported toxic chemical is sent
to an off-site facility for sequential activities and the
specific quantities associated with each activity are un-
known, report only a single quantity (the total quantity
transferred to the off-site location) along with a single
activity code. In such a case, report the activity applied
to the majority of the reported toxic chemical sent off-site,
not the ultimate disposition of the toxic chemical. For
example, when a toxic chemical is first treated and then
recovered with the majority of the toxic chemical being
treated and only a fraction subsequently recovered,
report the appropriate waste treatment activity along
with the quantity.
6.2 column B Basis of Estimate
You must identify the basis for your estimates of the
quantities of the reported toxic chemical in wastes trans-
ferred to each off-site location. Enter one of the following
letter codes that applies to the method by which the
largest percentage of the estimate was derived.
M - Estimate is based on monitoring data or mea-
surements for the toxic chemical as transferred
to an off-site facility.
C - Estimate is based on mass balance calculations,
such as calculation of the amount of the toxic
chemical in wastes entering and leaving process
equipment.
E - Estimate is based on published emission factors,
suchas those relatingreleasequantity to through-
put or equipment type (e.g., air emission fac-
tors).
O - Estimate is based on other approaches such as
engineering calculations (e.g., estimating vola-
tilization using published mathematical formu-
las) or best engineering judgment. This would
include applyingan estimated removal efficiency
to a treatment, even if the composition of the
waste before treatment was fully identified
through monitoring data.
6.2 column C Type of Waste Treatment/Disposal/
Recycling/Energy Recovery
Enter one of the following codes to identify the type of
waste treatment, disposal, recycling or energy recovery
methods used by the off-site location for the reported
toxic chemical. You must use more than one line and
34 Toxic Release Inventory Reporting Form R and Instructions
-------
Figure 4
Hypothetical Section 6.2 Completed for Two Off-site Locations
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
• Off^iteEPAIdentificationNuniberfRCRAlDNo.)! * ,-,,{, -7 fit I
6-2--L (10 0 £b>if>\lf2.yLffl
Off-Site Location Name | \
m^we
Street.Address j -,_ »A ,
o riufi
Wojsie- S^v'ic.^s
1 , i . . County | i i . i\
— ' Kelease-viU-e, Hill
State^ 1 A A Zip Coda:,! -y,.,ii \ Is location under control of reporting i — i 1—7 1
' CO SOHUM - facility or parent company? | | Yes |X| No
A. Total Transfers (pounds/year) > , , ^,f,,
• (enter ranga code or estimala) •' / -,
1. v5,000
2. 7500
3. 2,500
4. Mk
B, Basis of Estimate
(enter code} . '
1. 0
C- •
3. 0
4.
C. Type ol Waste Treatment/Disposal/
Becycling/Energy flecoveiy (enter code)
1. M 5lf>
2. w20
3. M ~72L
4. M
This off-site location receives a transfer of 15,000 pounds of toluene (as discussed earlier) and will combust 5,000
pounds for the purposes of energy recovery, enter 7,500 pounds into a recovery process, and dispose of the remaining
2,500 pounds.
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
:6.2jl
OffcsitftEPAIderltJticationNumbs^CRCfW^BNaJj- /\A/X ,i-i-,^«_.,^,
• Off-Site Location Name::;
L,UU
Qombu.st.icm,, _Lr\c,
StreetAddresssBM ,-, ,— -v~ • \'.J_ , T3--J ,
* )t
, xV{«itBtrangeeod»w«sliraat9) ,xf' - ~k? ' ^
1. 12,500
2. Wr\
3.
4.
IV^UMC^-
CountEijtj -^
ourns
Is location under control of reporting r— i r^i
facility or parent company? | | "°* -I2SJ
& Ba$!saf Esffmate -,^ l/'c 5- -,' ' ' s>x'
-' ,-v
1. C
2.
3.
4.
&Typ»ofWaste'TrealmenVOisposair
•' Recydirtg/Enefgy Recovery (enter code) ,
1. M5"H
2. M
3. M
4. M
This off-site location receives a transfer of 12,500 pounds of tetrachloroethylene (perchloroethylene) that is part of
a waste that is combusted for the purposes of energy recovery in an industrial furnace. Note that the perchloroeth-
ylene is reported using code M54 to indicate that it is combusted in an energy recovery unit but it does not contribute
to the heating value of the waste.
Toxic Release Inventory Reporting Form R and Instructions 35
-------
code for a single location when distinct quantities of the
reported toxic chemical are subject to different waste
treatment disposal, recycling, or energy recovery meth-
ods. You may have this information in your copy of EPA
Form SO, Item S of the Annual/Biennial Hazardous
Waste Treatment, Storage, and Disposal Report (RCRA),
or in your invoices from the waste service(s) or broker(s)
receiving your wastes for the purposes of waste treat-
ment) disposal, recycling, or energy recovery.
You must distinguish between incineration, which is
waste treatment and legitimate energy recovery, In
order for you to claim mat a reported toxic chemical sent
off-site is used for the purposes of energy recovery and
not for waste treatment, the toxic chemical must have a
heating value high enough to sustain combustion and
mustbe combusted in an energy recovery unit such as an
industrial boiler, furnace, or kiln. Ina situation where the
reported toxicchemicalisinawaste thatis combusted in
an energy recovery unit, but the toxic chemical does not
have a heating value high enough to sustain combustion,
use code M54, Incineration/Insignificant Fuel Value, to
indicate tHat the toxic chemical was incinerated in an
energyrecoveryunitbutdidnotcontributetotheheating
value of the waste (see Figure 4 for an example).
Applicable codes for Part n, Section 6.2, column C are:
Disposal
M10 Storage Only
M71 Underground Injection
M72 Landfill/Disposal Surface Impoundment
M73 Land Treatment
M79 Other Land Disposal
M94 Transfer to Waste Broker—Disposal
Recycling
M20 Solvents/Organics Recovery
M24 Metals Recovery
M26 Other Reuse or Recovery
M28 Acid Regeneration
M93 Transfer to Waste Broker—Recycling
Waste Treatment
M40 Solidification/Stabilization
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M61 Wastewater Treatment (Excluding POTW)
M69 Other Waste Treatment
M95 Transfer to Waste Broker—Waste Treatment
Energy Recovery
M56 Energy Recovery
M92 Transfer to Waste Broker—Energy Recovery
Section 7 On-Site Waste Treatment, Energy
Recovery and Recycling Methods
You must report in this section the methods of waste
treatment, energy recovery, and recycling applied to the
reported toxic chemical in wastes on-site. There are three
separate sections for reporting such activities.
Section 7A On-Site Waste Treatment Methods
and Efficiency
In Section 7A, you must provide the following informa-
tion if you treat the reported toxic chemical on-site:
(a) the general waste stream types containing the
toxic chemical being reported;
(b) the waste treatment method (s) or sequence used
on all waste streams containing the toxic chemi-
cal;
(c) the range of concentration of the toxic chemical
in the influent to the waste treatment method;
(d) theefficiency of each waste treatmentmethod or
waste treatment sequence in removing the toxic
chemical; and
(e) whether the waste treatment efficiency figure
was based on actual operating data.
Use a separate line in Section 7A for each general waste
stream type. Report only information about treatment of
waste streams at your facility, not information about off-
site waste treatment.
If you do not perform on-site treatment of waste streams
containing the reported toxic chemical, check the Not
Applicable (NA) box at the top of Section 7A.
7A column a General Waste Stream
For each waste treatment method, indicate the type of
waste stream containing the toxic chemical that is treated.
Enter the letter code that corresponds to the general
waste stream type:
A Gaseous (gases, vapors, airborne particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and
slurries)
36 Toxic Release Inventory Reporting Form R and Instructions
-------
If a waste is a mixture of water and organic liquid and the
organic content is less than 50 percent, report it as a
wastewater (W). Slurries and sludges containing water
must be reported as solid waste if they contain appre-
ciable amounts of dissolved solids, or solids that may
settle, such that the viscosity or density of the waste is
considerably different from that of process wastewater.
7A column b Waste Treatment Method(s)
Sequence
Enter the appropriate code from the list below for each
on-site waste treatment method used on a waste stream
containing the toxic chemical, regardless of whether the
waste treatment method actually removes the specific
toxicchemicalbeingreported. Waste treatmentmeihods
must be reported for each type of waste stream being
treated (i.e., gaseous waste streams, aqueous waste
streams, liquid non-aqueous waste streams, and solids).
Except for the air emission treatment codes, the waste
treatment codes are not restricted to any medium.
Waste streams containing the toxic chemical may have a
single source or may be aggregates of many sources. For
example, process water from several pieces of equipment
at your facility may be combined prior to waste treat-
ment. Report waste treatment methods that apply to the
aggregate waste stream, as well as waste treatment
methods that apply to individual waste streams. If your
facility treats various wastewater streams containing the
toxic chemical in different ways, the different waste
treatment methods must be listed separately.
If your facility has several pieces of equipment perform-
ing a similar service in a waste treatment sequence, you
may combine the reporting for such equipment. It is not
necessary to enter four codes to cover four scrubber
units, for example, if all four are treating waste streams
of similar character (e.g., sulfuric acid mist emissions),
have similar influent concentrations, and have similar
removal efficiencies. If, however, any of these param-
eters differs from one unit to the next, each scrubber must
be listed separately.
If your facility performs more than eightsequential waste
treatment methods on a single general waste stream,
continuelistingthemethods in thenextrowand renumber
appropriately those waste treatment method code boxes
you used to continue the sequence. For example, if the
general waste stream in box 7A.la had nine treatment
methods applied to it, the ninth method would be indi-
cated in the first method box for row 7A.2&. The numeral
"1" would be crossed out, and a "9" would be inserted.
Treatment applied to any other general waste stream
types would then be listed in the next empty row. In the
scenario above, for instance, the second general waste
stream would be reported in row 7A.3a. See Figure 5
below for an example of a hypothetical Section 7A com-
pleted for a nine-step waste treatment process and a
single waste treatment method.
If you need additional space to report under Section 7A,
photocopy page 7 of Form R as many times as necessary.
At the bottom of page 7 you will find instructions for
indicating the total number of page 7s that you are
submitting as part of Form R, as well as instructions for
indicating the sequence of those pages.
Waste Treatment Codes
Air Emissions Treatment (applicable to gaseous
waste streams only)
A01 Flare
A02 Condenser
A03 Scrubber
A04 , Absorber
A05 : Electrostatic Precipitator
A06 Mechanical Separation
A07 . Other Air Emission Treatment
Biological Treatment
Bll Biological Treatment — Aerobic
B21 : Biological Treatment — Anaerobic
B31 Biological Treatment — Facultative
B99 ; Biological Treatment — Other
Chemical Treatment
C01 Chemical Precipitation — Lime or Sodium
Hydroxide
C02 Chemical Precipitation — Sulfide
C09 Chemical Precipitation — Other
Cll Neutralization
C21 : Chromium Reduction
C31 Complexed Metals Treatment (other than pH
Adjustment)
C41 Cyanide Oxidation — Alkaline Chlorination
C42 : Cyanide Oxidation — Electrochemical
C43 , Cyanide Oxidation —Other
C44 General Oxidation (including Disinfection) —
Chlorination
C45 General Oxidation (including Disinfection) —
Ozonation
Toxic Release Inventory Reporting Form R and Instructions 37
-------
Figure 5
Hypothetical Section 7A
38 Toxic Release Inventory Reporting Form R and Instructions
-------
C46 General Oxidation (including Disinfection)
Other
C99 Other Chemical Treatment
Incineration/Thermal Treatment
F01 Liquid Injection
Fl 1 Rotary Kiln with Liquid Injection Unit
F19 Other Rotary Kiln
F31 Two Stage
F41 Fixed Hearth
F42 Multiple Hearth
F51 FluidizedBed
F61 Infra-Red
F71 Fume/Vapor
F81 Pyrolytic Destructor
F82 Wet Air Oxidation
F83 Thermal Drying/Dewatering
F99 Other Incineration/Thermal Treatment
Physical Treatment
P01 Equalization
P09 Other Blending
Pll Settling/Clarification
P12 Filtration
P13 Sludge Dewaterihg (non-thermal)
P14 Air Flotation
P15 Oil Skimming
P16 Emulsion Breaking — Thermal
P17 Emulsion Breaking—Chemical
P18 Emulsion Breaking — Other
P19 Other Liquid Phase Separation
P21 Adsorption — Carbon
P22 Adsorption — Ion Exchange (other than for
recovery/reuse)
P23 Adsorption — Resin
P29 Adsorption — Other
P31 Reverse Osmosis (other than for recovery/
reuse)
P41 Stripping — Air
P42 Stripping —Steam
P49 Stripping —Other
P51 Acid Leaching (other than for recovery/reuse)
P61 Solvent Extraction (other than recovery/reuse)
P99 Other Physical Treatment
Solidification/Stabilization
G01 Cement Processes (including Silicates)
G09 Other Pozzolonic Processes (including
Silicates)
Gil Asphaltic Processes
G21, Thermoplastic Techniques
G99 Other Solidification Processes
7A column c Range of Influent Concentration
The form requires an indication of the range of concentra-
tion of the toxic chemical in the waste stream (i.e., the
influent) as ittypically enters the waste treatment step or
sequence. The concentration is bashed on the amount or
mass of the toxic chemical in the waste stream as comr
pared to the total amount or mass of the waste stream.
Enter in the space provided one of the following code
numbers corresponding to the concentration of the toxic
chemical in the influent:
1 = Greater than 1 percent
2 = 100 parts per million (0.01 percent) to 1 percent
(10,000 parts per million)
3 = 1 part per million to 100 parts per million
4 = 1 part per billion to 1 part per million
5 = Less than 1 part per billion
Note: Parts per million (ppm) is:
o milligrams/kilogram(mass/mass)forsolidsand
liquids;
o cubiccentimeters/cubicmeter(volume/volume)
for gases;
o milligrams/liter for solutions or dispersions of
the chemical in water; and
o milligrams of chemical/kilogram of air for par-
ticulates in air.
If you have particulate concentrations (at standard tem-
perature and pressure) as grains/cubic foot of air, mul-
tiply by 1766.6 to convert to parts per million; if in
milligrams/cubic meter, multiply by 0.773 to obtain
parts per million: These conversion factors are for stan-
dard conditions of 0°C (32°F) and 760 mmHg atmo-
spheric pressure.
Toxic Release Inventory Reporting Form R and Instructions 39
-------
7A column d Waste Treatment Efficiency Estimate
In the space provided/ enter the number indicating the
percentage of the toxic chemical removed from the waste
stream through destruction, biological degradation,
chemical conversion, or physical removal. The waste
treatment efficiency (expressed as percent removal) rep-
resents the percentage of the toxic chemical destroyed or
removed (based on amountormass),notmerely changes
in volume or concentration of the toxic chemical in the
waste stream. The efficiency, which can reflect the
overall removal from sequential treatment methods ap-
plied to the general waste stream, refers only to the
percentdestraction, degradation, conversion, or removal
ofthelisted toxicchemicalfromtfrewastestream,notthe
percent conversion or removal of other constituents in
the waste stream. The efficiency also does not refer to the
general efficiency of the treatmentmethod for any waste
stream. For some waste treatment methods, the percent
removal will represent removal by several mechanisms,
as in an aeration basin, where a toxic chemical may
evaporate, be biodegraded, or be physically removed
from the sludge.
Percent removal can be calculated as follows:
(1-E) x 100, where
I
I = amount of the toxic chemical in the influent waste
stream (enteringthe waste treatmentstep or sequence)
and
E = amount of the toxic chemical in the effluent waste
stream (exiting the waste treatment step or sequence).
Calculate the amount of the toxic chemical in the influent
wastestreambymultiplyingtheconcentration(byweight)
of the toxic chemical in the waste stream by the total
amount or weight of the waste stream. In most cases, the
percent removal compares the treated effluent to the
influent for the particular type of waste stream. For
solidification of wastewater, the waste treatment effi-
ciency can be reported as 100 percent if no volatile toxic
chemicals were removed with the water or evaporated
into the air. Percent removal does not apply to incinera-
tion because the waste stream, such as wastewater or
liquids, may not exist in a comparable form after waste
treatment and the purpose of incineration as a waste
treatment is to destroy the toxic chemical by converting
it to carbon dioxide and water. In cases where the toxic
chemical is incinerated, the percent efficiency must be
based on the amount of the toxic chemical destroyed or
combusted, except for metals or metal compounds. In
the cases where a metal or metal compound is inciner-
ated, the efficiency is always zero for the parent metal.
Similarly, an efficiency of zero must be reported for any
waste treatment method(s) (e.g., evaporation) that does
not destroy, chemically convert, or physically remove
the toxic chemical from the waste stream.
For metal compounds, the calculation of the reportable
concentration and waste treatment efficiency must be
based on the weight of the parent me tal, not on the weight
of the metal compounds. Metals are not destroyed, only
physically removed or chemically converted from one
form into another. The waste treatment efficiency re-
ported must represent only physical removal of the
parent metal from the waste stream (except for incinera-
tion), not the percent chemical conversion of the metal
compound. If a listed waste treatment method converts
but does not remove a metal (e.g., cliromiurn reduction),
the method must be reported with a waste treatment
efficiency of zero.
Listed toxic chemicals that are strong mineral acids
neutralized to a pH of 6 or above are considered treated
at a 100 percent efficiency.
All data available at your facility must be used to calcu-
late waste treatment efficiency and influent toxic chemi-
cal concentration. If data are lacking, estimates must be
made usingbest engineeringjudgment or other methods.
7A column e Based on Operating Data?
This column requires you to indicate "Yes" or "No" to
whether the waste treatment efficiency estimate is based
on actual operating data. For example, you would check
"Yes" if the estimate is based on monitoring of influent
and effluent wastes under typical operating conditions.
If the efficiency estimate is based on published data for
similar processes or on equipment supplier's literature,
or if you otherwise estimated either the influent or
effluent waste comparison or the flow rate, check "No."
Section 7B On-Site Energy Recovery Processes
In Section 7B, you must indicate the on-site energy
recovery methods used on the reported toxic chemical. If
you do not perform on-site energy recovery for the
reported toxic chemical, check the Not Applicable (NA)
box at the top of Section 7B.
40 Toxic Release Inventory Reporting Form R and Instructions
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Example 11: Reporting On-Site Energy Recovery
One waste stream generated byyour facility contains,
among other chemicals, toluene and cadmium.
Threshold quantities are exceeded for both of these
toxic chemicals, and you would, therefore, submit
two separate Form R reports. This waste stream is
sent to an on-site industrial furnace which uses the
heat generated in a thermal hydrocarbon cracking
process atyour facility. Because toluene has a signifi-
cant heat value (17,440 BTU/pound) and the energy
is recovered in an industrial furnace, the code "U02"
would be reported in Section 7B for the Form R
submitted for toluene.
However, as cadmium is a non-combustible metal
and therefore does not contribute any heat value for
energy recovery purposes, the combustion of cad-
mium in the industrial furnace is considered waste
treatment, not energy recovery. You would report
cadmium as entering a waste treatment step (i.e.,
incineration), in Section 7A, column b.
Only listed toxic chemicals that have a significant heating
value and are combusted in an energy recovery unit such
as an industrial furnace, kiln, or boiler, can be reported as
combusted for energy recovery in this section. If a
reported toxic chemical is incinerated on-site but does
not contribute energy to the process (e.g., metals and
chlorofluorocarbons),itmustbeconsidered waste treated
on-site and reported in Section 7A. Energy recovery may
take place only in one of the types of energy recovery
equipment listed below.
Energy Recovery Codes
U01 . Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
U09 Other Energy Recovery Methods
If your facility uses more than one on-site energy recov-
ery method for the reported toxic chemical, list the
methods used in descending order (greatest to least)
based on the amount of the toxic chemical entering such
methods.
Section 7C On-Site Recycling Processes
In Section 7C, you must report the recycling methods
used on the listed toxic chemical. If you do not conduct
any on-site recycling of the reported toxic chemical,
check the Not Applicable (NA) box at the top of Section
7C.
In this section, use the codes below to report only the
recycling methods in place at your facility that are ap-
plied to the listed toxic chemical. Do not list any off-site
recycling activities (Information about off-site recycling
must be reported in Part II, Section 6, "Transfers of the
Toxic Chemical in Wastes to Off-Site Locations,").
On-Site Recycling Codes
Rl 1 Solvents/Organics Recovery — Batch Still
Distillation
R12 Solvents/Organics Recovery — Thin-Film
Evaporation
R13 Solvents /Organics Recovery — Fractionation
R14 Solvents/Organics Recovery — Solvent •>
Extraction
R19 Solvents/Organics Recovery — Other
R21 Metals Recovery — Electrolytic
R22 Metals Recovery — Ion Exchange
R23 Metals Recovery —Acid Leaching
R24 Metals Recovery — Reverse Osmosis
R26 Metals Recovery — Solvent Extraction
R27 Metals Recovery — High Temperature
R28 Metals Recovery — Retorting
R29 Metals Recovery — Secondary Smelting
R30 Metals Recovery — Other
R40; Acid Regeneration '
R99' Other Reuse or Recovery
If your facility uses more than one on-site recycling
method fora toxic chemical, enter the codes in the space
provided in descending order (greatest to least) of the
volume of the reported toxic chemical recovered by each
process. If your facility uses more than ten separate
methods for recycling the reported toxic chemical on-
site, men list the ten activities that recover the greatest
amount of the toxic chemical (again, in descending or-
der):
Toxic Release Inventory Reporting Form R and Instructions 41
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Section 8 Source Reduction and Recycling
Activities
This Section includes the new data elements mandated
by section 6607 of the Pollution Prevention Act of 1990
(PPA). Section 8 is now a required section of Form R and
must be completed. This is the first reporting year these
data are being collected. They are included in the Form
R for reports due on or before July 1, 1992, covering
source reductionand recyclingactivities in calendar year
1991. You are not required to amend previous year's
submissions to include this information.
In Sections/ you must provide information about source
reduction and recycling activities related to the toxic
chemical for which releases are being reported. For all
appropriate questions, report only the quantity, in
pounds, of the reported toxic chemical. Do not include
the weight of water, soil, or other waste constituents.
When reporting on a metal compound, report only the
amount of the parent metal as you do when estimating
release amounts. All amounts must be reported in whole
numbers and up to two significant figures can be pro-
vided.
Section 8.1 through 8.9 must be completed for each toxic
chemical. SectionS.lOmustbe completed onlyifasource
reduction activity was newly implemented specifically
(in whole or in part) for the reported toxic chemical
during the reporting year. Section 8.11 allows you to
indicate if you have attached additional optional infor-
mation on source reduction, recycling, or pollution con-
trol activities implemented at any time at your facility.
Sections 8.1 through 8.7 require reporting of quantities
for the current reporting year, the prior year, and-quan-
tities anticipated in both the first year immediately fol-
lowing the reporting year and the second year following
the reporting year (future estimates).
Column A: 1990 (Prior Year)
Quantities for Sections 8.1 through 8.7 must be reported
for the year immediately preceding the reporting year in
column A. For reports due July 1,1992, the prior year is
1990. Information available at the facility that may be
used to estimate the prior year's quantities include the
prior year's FormR submission, supporting documenta-
tion, and recycling, energy recovery, or treatment oper-
ating logs or invoices.
EPA believes that such data should be available, espe-
cially in those cases where the facility has filed a Form R
for the reported toxic chemical in the prior year. How-
ever, for the first year of reporting these data elements,
1991, prior year quantities are required only to the extent
such information is available. In the event that sufficient
data are not available, enter not applicable, "NA."
Column B: 1991 (Reporting Year)
Quantities for Sections 8.1 through 8.7 must be reported
for the current reporting year in column B.
Columns C and D: 1992 and 1993 (Folio wing Year and
Second Year)
Quantities for Sections 8.1 through 8.7 must be estimated
for 1992 and 1993. EPA expects reasonable future quan-
tity estimates using a logical basis. Information available
at the facility to estimate quantities of the chemical
expected during these years include planned source
reduction activities, market projections, expected con-
n-acts, anticipated new product lines, company growth
projections, and production capacity figures. Not appli-
cable, "NA", may noibe entered for these data elements.
Respondents should take into account protections avail-
able for trade secrets as provided in EPCRA Section 322
(42 USC11042).
Example 12: Reporting Future Estimates
A pharmaceutical manufacturing facility uses a listed
toxic chemical in the manufacture of a prescription
drug. During the reporting year (1991), the company
received approval from the Food and Drug Adminis-
tration to begin marketing their product as an over-
the-counter drug beginning in 1992. This approval is
publicly known and does not constitute confidential
business information. As a result of this expanded
market, the company estimates that sales and subse-
quent production of this drug will increase their use of
the reported toxic chemical by 30 percent per year for
the twoyearsfollowingthereportingyear. The facility
treats the toxic chemical on-site and the quantity
treated is directly proportional to production activity.
The facility thus estimates the total quantity of the
reported toxic chemical treated for the following year
(1992) by adding 30 percent to the amount in column
B (the amount for the current reporting year). The
second year (1993) figure can be calculated by adding
an additional 30 percent to the amount reported in
Column C (the amount for the following year (1992)
projection).
42
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Relationship to Other Laws
The reporting categories for quantities recycled, treated,
used for energy recovery, and disposed apply to com-
pleting Section 8 of Form R as well as to the rest of Form
R. These categories are to be used only for TRI reporting.
They are not intended for use in determining, under the
Resource Conservation and Recovery Act (RCRA) Sub-
title C regulations, whether a secondary material is a
waste whenrecycled. These definitions also donotapply
to the information that may be submitted in the Biennial
Report required under RCRA. In addition, these defini-
tions do not imply any future redefinition of RCRA terms
and do not affect EPA's RCRA authority or authority
under any other statute administered by EPA.
Differences in terminology and reporting requirements
for toxic chemicals reported on Form R and for hazard-
ous wastes regulated under RCRA occur because EPCRA
and the PPA focus on specific chemicals, while the RCRA
regulations and the Biennial Report focus on wastes,
including mixtures. For example, a RCRA hazardous
waste containing a section 313 toxic chemical is recycled
to recover certain constituents of that waste, but not the
toxic chemical reported under EPCRA section 313. The
toxic chemical simply passes through the recycling pro-
cess and remains in the residual from the recycling
process. While the waste may be considered recycled
under RCRA, the toxic chemical constituent would be
considered to be treated for TRI purposes.
Quantities Reportable in Sections 8.1 - 8.7
8.1 ReportreleasespursuanttoEPCRASection329(8)
including "any spilling, leaking, pumping, pouring,
emitting, emptying, discharging, injecting, escaping,
leaching, dumping, or disposing [on-site or off-site]
into the environment (including the abandonment of
barrels, containers, and other dosed receptacles)." Do
not include any quantity treated on-site or off-site.
8.2 - 8.3 A toxic chemical or a mixture containing a
toxic chemical that is used for energy recovery on-site
or is sent off-site for energy recovery, unless it is a
commercially available fuel. For the purposes of
reporting on Form R, reportable on-site and off-site
energy recovery is the combustion of a residual mate-
rial containing a TRI toxic chemical when:
(b) The toxic chemical is combustible and
has a heating value high enough to sus-
tain combustion.
8.4 - 8.5 A toxic chemical or a mixture containing a
toxic chemical that is recycled on-site or is sent off-site
for recycling.
i
8.6 - 8.7 A toxic chemical or a mixture containing a
toxic chemical that is treated on-site or is sent to a
POTW or other off-site location for waste treatment.
A toxic chemical or a toxic chemical in a mixture that is
a waste under RCRA must be reported in Sections 8.1
through 8.7.
Avoid Double-Counting in Sections 8.1 Through 8.8
Section 8 of Form R uses data collected to complete Part
n, Sections 5 through 7. For this reason, Section 8 should
be completed last.
Do not double- or multiple-count quantities in Sections
8.1 through 8.7. The quantities reported in each of those
sections must be mutually exclusive. Do not multiple-
count quantities entering sequential reportable activi-
ties. For example, 5,000 pounds of toxic chemical enters
a treatment operation. Three thousand pounds of the
toxic chemical exits the treatment operation and then
enters a recycling operation. Five hundred pounds of the
toxic chemical is in residues from the recycling operation
which is subsequently sent off-site for disposal. These
quantities would be reported as follows in Section 8:
(a) The combustion unit is integrated into
an energy recovery system (i.e., indus-
trial furnaces, industrial kilns, and boil-
ers); and
Section 8.1: 500 pounds disposed
Section 8.4: 2,500 pounds recycled
Section 8.6: 2,000 pounds treated (5,000 that
initially entered - 3,000 that sub-
sequently entered recycling)
To report that 5,000 pounds were treated, 3,000 pounds were
recycled, and that 500 pounds were sent off-site for disposal
would result in over-counting the quantities of toxic chemical
recycled, treated, and disposed by 3,500 pounds.
Do not include in Sections 8.1 through 8.7 any quantities
of the toxic chemical released into the environment due
to remedial actions; catastrophic events such as earth-
quakes, fires, or floods; or unanticipated one-time events
not associated with the production process such as tank
ruptures or reactor explosions. These quantities should
be reported in Section 8.8 only. For example, 10,000
pounds of diaminoanisole sulfate is released due to a
catastrophic event and is subsequently treated off-site.
Toxic Release Inventory Reporting Form R and Instructions 43
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The 10,000 pounds is reported in Section 8.8, but the
amount subsequently treated off-site is not reported in
Section 8.7.
8.8 Quantity Released to the Environment as a
Result of Remedial Actions, Catastrophic
Events, or One-Time Events Not Associated
with Production Processes.
In Section 8.8, enter the total quantity of toxic chemical
released directly into the environment or sent off-site for
recycling, waste treatment, energy recovery, or disposal
during the reporting year due to any of the following
events:
(1) remedial actions,
(2) catastrophic events such as earthquakes,
fires, or floods; or
(3) one-timeeventsnotassociatedwithnor-
mal or routine production processes.
These quantities should not be included in Sections 8.1
through 8.7. The amount of toxic chemical released into
the environment during remediation or transferred off-
site is to be reported in Part II, Sections 5 and 6 as
appropriate.
The purpose of this section is to separate quantities
recycled, used for energy recovery, treated, or disposed
that are associated with normal or routine production
Operations from those that are not. While all quantities
released, recycled, treated, or disposed may ultimately
be preventable, this section separates the quantities that
are more likely to be reduced or eliminated by process-
oriented source reduction activities from those releases
that are largely unpredictable and are less amenable to
such source reduction activities. For example, spills that
occur as a routine part of production operations and
could be reduced or eliminated by improved handling,
loading, or unloading procedures are included in the
quantities reported in Section 8.1 through 8.7 as appro-
priate. A total loss of containment resulting from a tank
rupture caused by a tornado would be included in the
quantity reported in Section 8.8.
Similarly, the amount of a toxic chemical spilled or
cleaned up from normal operations during the reporting
year would be included in the quantities reported in
Sections 8.1 through 8.7. However, the quantity of the
reported toxic chemical generated from a remedial ac-
tion (e.g., RCRA corrective action) to clean up the envi-
ronmental contamination resulting from past practices
should be reported in Section 8.8 because they cannot
currently be addressed by source reduction methods. A
remedial action for purposes of Section 8.8 is a waste
cleanup (including RCRA and CERCLA operations)
within the facility boundary. Most remedial activities
involve collecting and treating contaminated material.
Also, releases caused by catastrophic events are to be
incorporated into the quantity reported in Section 8.8.
Such releases may be caused by natural disasters (e.g.,
hurricanes and earthquakes) or by large scale accidents
(e.g., fires and explosions). These amounts are not in-
cluded in the quantity reported in Sections 8.1 through
8.7 because such releases are generally unanticipated and
Example 13: Quantity Released to the Environment as a Result of Remedial Actions, Catastrophic Events,
or One-Time Events Not Associated with Production Processes.
A chemical manufacturer produces a toxic chemical in a reactor that operates at low pressure. The reactants and
the toxic chemical product are piped in and out of the reactor at monitored and controlled temperatures. During
normal operations, small amounts of fugitive emissions occur from the valves and flanges in the pipelines.
Due to a malfunction in the control panel (which is state-of-the-art and undergoes routine inspection and
maintenance), the temperature and pressure in the reactor increase, the reactor ruptures, and the toxic chemical
is released. Because the malfunction could not be anticipated and, therefore, could not be reasonably addressed
by specific source reduction activities, the amount released is included in Section 8.8. In this case, much of the
toxicchemicalisreleasedasaliquidandpools on theground.Itis estimated that 1,000 pounds of the toxicchemical
pooled on the ground and was subsequently collected and sent off-site for treatment. In addition, it is estimated
that another 200 pounds of the toxic chemical vaporized directly to the air from the rupture. The total amount
reported in Section 8.8 is the 1,000 pounds that pooled on the ground (and subsequently sent off-site), plus the
200 pounds that vaporized into the air, a total of 1,200 pounds. The quantity sent off-site must also be reported
in Section 6 (but not in Section 8.7) and the quantity that vaporized must be reported as a fugitive emission in
Section 5 (but not in Section 8.1). _„______-_—.
44 ToxicReleaseltwmton/ReportingFormRandlnstnictions
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cannot be addressed by routine process-oriented acci-
dent prevention techniques.
By checking your documentation for calculating esti-
mates made for Part n, Section 5, "Releases of the Toxic
Chemical to the Environment/' you may be able to
identify release amounts from me above sources. Emer-
gency notifications under CERCLA and EPCRA as well
as accident histories required under the Clean Air Act
may provide useful information. You should also check
facility incident reports and maintenance records to
identify one-time or catastrophic events.
Note that while the information reported in Section 8.8
representsonly remedial, catastrophic, or one-time events
not associated with production processes, Section 5 of
Form R (releases to the environment) and Section 6 (off-
site transfers), must include all releases and transfers as
appropriate, regardless of whether they arise from cata-
strophic, remedial, or routine process operations.
8.9 Production Ratio or Activity Index
ForSection8.9,youmustprovidearatioofreportingyear
production to prior year production, or provide an
"activity index" based on a variable other than produc-
tion that is the primary influence on the quantity of (he
reported toxic chemical recycled, used for energy recov-
ery, treated, or disposed. The ratio or index must be
reported to the nearest tenths or hundredths place (e.g.,
one or two digits to the right of the decimal point). If the
manufacture or use of the reported toxic chemical began
during the current reporting year, enter not applicable,
"NA," as the production ratio or activity index.
It is important to realize that if your facility reports more
than one reported toxic chemical, the production ratio or
activity index may vary for different chemicals. For
facilities that manufacture reported toxic chemicals, the
quantities of the toxic chemical(s) produced in the cur-
rent and prior years provide a good basis for the ratio
because that is the primary business activity associated
with the reported toxic chemical(s). In most cases, the
productionratioor activity index mustbe based on some
variable of production or activity rather than on toxic
Example 14: Determining a Production Ratio
Your facility's only use of toluene is as a paint carrier
for a painting operation. You painted 12,000 refrig-
erators in the currentreportingyear and 10,000 refrig-
erators during the preceding year. The production
ratio for toluene in this case is 1.2 (12,000/10,000)
because the number of refrigerators produced is the
primary factor determining the quantity of toluene to
be reported in Sections 8.1 through 8.7.
A facility manufactures inorganic pigments, includ-
ing titanium dioxide. Hydrochloric acid is produced
as a! waste byproduct during the production process.
An appropriate production ratio for hydrochloric
acid is the annual titanium dioxide production, not
the amount of byproduct generated. If the facility
produced 20,000 pounds of titanium dioxide during
the reportingyear and 26,000 pounds in the preceding
year, the production ratio would be 0.77 (20,000/
26,000).
chemical or material usage. Indices based on toxic
chemical or material usage may reflectthe effectof source
reductionactivities rather than changes in businessactiv-
ity. Toxic chemical or material usage is therefore not a
basis to be used for the production ratio or activity index
where the toxic chemical is "otherwise-used" (i.e., non-
incorporative activities such as extraction solvents, metal
degreasers, etc.).
While several methods are available to the facility for
determining this data element, the production ratio or
activity index must be based on the variable that most
directly affects the quantities of the toxic chemical re-
cycled, used for energy recovery, treated, or disposed.
Examples of methods available include:
(1) Amount of toxic chemical manufactured in 1991
divided by the amount of toxic chemical manu-
factured in 1990; or
(2) Amount of productproduced in 1991 divided by
the amount of product produced in 1990.
Toxic Release Inventory Reporting Form R and Instructions 45
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Example 15: Determining an Activity Index
Your facility manufactures organic dyes in a batch process. Different colors of dyes are manufactured, and
between colord»anges,aUequipmentmustbethorougWy cleaned withsolventcontainingglycolethers to reduce
color carryover. During the preceding year, the facility produced 2,000 pounds of yellow dye in January, 9,000
pounds of green dye for February through September, 2,000 pounds of red dye in November, and another 2,000
pounds of yellow dye inDecember. This adds up to a total of 15,000 pounds and four color changeovers. During
the reportingyear, the facility produced 10,000 pounds of green dye during the first half of the year and 10,000
pounds of red dye in the second half. If your facility uses glycol ethers in this cleaning process only, an activity
indexofO.5 (based on twocolor changeovers forthereportingyeardividedby four changeovers for thepreceding
year) is more appropriate than a production ratio of 1.33 (based on20,000 pounds of dye produced in the current
year divided by 15,000 pounds in the preceding year). In this case, an activity index, rather than a production
ratio, better reflects the factors that influence the amount of solvent recycled, used for energy recovery, treated,
or disposed.
A facility that manufactures thermoplastic composite parts for aircraft uses acetone as a wipe solvent to clean
molds. The solvent is stored in 55-gallon drums and is transferred to 1-gallon dispensers. The molds are cleaned
on an as-needed basis that is not necessarily a function of the parts production rate. Operators cleaned 5,200
molds during the reporting year, but only cleaned 2,000 molds in the previous year. An activity index of 2.6
(5^00/2,000)representstheactivitiesinvolvingacetoneusageinthefacility. If the molds were cleaned after 1,000
parts were manufactured, a productionratio would equal the activity index and either could be used as the basis
for the index.
A facility manufactures surgical instruments and cleans the metal parts with 1,1,1-trichloroethane in a vapor
degreaser. The degreasing unit is operated in a batch mode and the metal parts are cleaned according to an
irregular schedule. The activity index can be based upon the total time the metal parts are in the degreasing
operation. If the degreasing unit operated 3,900 hours during the reporting year and 3,000 hours the prior year,
the activity index is 1.3 (3,900/3,000).
A pharmaceutical plant uses hydrochloric acid to regenerate deionization units that supply deionized water to
several operations in the facility. During the reportingyear, the facility noted that the units were recharged once
per week. Records for the prior year indicate that the units were recharged four times per week. Provided that
the reduction in recharges per week is not part of a planned source reduction program, an index of 0.25 (1/4)
represents the activities that were the primary influence on the amount of hydrochloric acid recycled, used for
energy recovery, treated, or disposed.
Example 16: "NA" is Entered as the Production
Ratio or Activity Index
Your facility began production of a microwidget during this reporting year. Perchloroethylene is used as a
cleaning solvent for this operation and this is the only use of the toxic chemical in your facility. You would enter
not applicable, "NA," in Section 8.9 because you have no basis of comparison in the prior year for the purposes
of developing the activity index.
46 To&Rete^bnmtcnyReportmgFcmiRandlnstructians
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Example 17: Determining the Production Ratio Based on a Weighted Average
At many facilities, a reported toxic chemical is used in more than one production process. In these cases, a
production ratio or activity index can be estimated by weighting the production ratio for each process based on
the respective contribution of each process to the quantity of the reported toxic chemical recycled, used for energy
recovery, treated, or disposed.
Your facility paints bicycles with paint containing toluene. Sixteen thousand bicycles were produced in the
reporting year and 14,500 were produced in the prior year. There were no significant design modifications that
changed the total surface area to be painted for each bike. The bicycle production ratio is 1.1 (16,000/14,5000).
You estimate 12,500 pounds of toluene treated, recycled, used for energy recovery, or disposed as a result of
bicycle production. Your facility also uses toluene as a solvent in a glue that is used to make components and
add-on equipment for the bicycles. Thirteen thousand components were manufactured in the reporting year
as compared to 15,000 during the prior year. The production ratio for the components using toluene is 0.87
(13,000/15,000). You estimate 1,000 pounds of toluene treated, recycled, used for energy recovery, or disposed
as a result of components production. A production ratio can be calculated by weighting each of the production
ratios based on the relative contribution each has to the quantities of toluene treated, recycled, used for energy
recovery, or disposed during the reporting year (13,500 pounds). The production ratio is calculated as follows:
Production ratio = (12,500/13,500 x 1.1) + (1,000/13,500x0.87)= 1.08
8.10 Did Your Facility Engage in any Source
Reduction Activities for this Chemical
during the Reporting Year?
Jf-your facility engaged in any source reduction activity
for the reported toxic chemical during the reportingyear,
report the activity that was implemented and the method
used to identify the opportunity for the activity imple-
mented. If your facility did not engage in any source
reduction activity for the reported toxic chemical, enter
not applicable, "NA," in Section 8.10.1 and answer Sec-
tion 8.11.
Source reduction means any practice which:
• Reduces the amount of any hazardous substance,
pollutant, or contaminant entering any waste
stream or otherwise released into the environ-
ment (including fugitive emissions) prior to re-
cycling, treatment, or disposal; and
• Reduces the hazards to public health and the
environment associated with the release of such
substances, pollutants, or contaminants.
The term includes equipment or technology modifica-
tions, process or procedure modifications, reformulation
or redesign of products, substitution of raw materials,
and improvements in housekeeping, maintenance, train-
ing, or inventory control.
The term source reduction does not include any practice
which alters the physical, chemical, or biological charac-
teristics or the volume of a hazardous substance, pollut-
ant, or contaminant through a process or activity which
itself is not integral to and necessary for the production
of a product or the providing of a service.
Source reduction activities do not include recycling,
treating, using for energy recovery, or disposing of a
toxic chemical. Report in this section only the source
reduction activities implemented to reduce or eliminate
the quantities reported in Sections 8.1 through 8.7—the
focus of the section is only those activities that are applied
to reduce routine or reasonably anticipated releases and
quantities of thereported toxic chemical recycled, treated,
used for energy recovery, or disposed. Do not report in
this section any activities taken to reduce or eliminate the
quantities reported in Section 8.8.
Toxic Release Inventory Reporting Form R and Instructions 47
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Example 18: Source Reduction
A facility assembles and paints furniture. Both the glue used to assemble the furniture and «he paints containlisted
toxic chemicals. By examining the gluing process, the facility discovered that a new drum of glue is opened at
the beginning of each shift, whether fhe old drum is empty or not. By adding a mechanism that prevents the drum
from being changed before it is empty, the need for disposal of the glue is eliminated at the source. As a result,
this activity is considered source reduction. The painting process at this facility generates a solvent waste which
is collected and recovered. The recovered solvent is used to clean the painting equipment. The recycling activity
does no t reduce the amount of toxic chemical recycled, and therefore is not considered a sour ce reduction activity.
Source Reduction Activities
You must enter in the first column of Section 8.10,
"Source Reduction Activities," the appropriate code(s)
indicating the type of actions taken to reduce the amount
of the reported toxic chemical released (as reported in
Section 8.1), used for energy recovery (as reported in
Section 8.2), recycled (as reported in Section 8.4-8.5), or
treated (as reported in Section 8.6-8.7). The list of codes
below includes many, but not all, of the codes provided
in the RCRA biennial report. Remember that source
reduction activities include only those actions or tech-
niques that reduce or eliminate the amounts of the toxic
chemical reported in Section 8.1 through 8.7. Actions
taken to recycle, treat, or dispose of the toxic chemical are
not considered source reduction activities.
Source Reduction Activity Codes:
Good Opera ting Practices
W13 Improved maintenance scheduling,
recordkeeping, or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W19 Other changes in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials
do not stay in inventory beyond shelf-life
W22 Began to test outdated material — continue to
use if still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labelling procedures
W25 Instituted clearinghouse to exchange materials
that would otherwise be discarded
W29 Other changes in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading, unloading,
and transfer operations
W33 Installed overflow alarms or automatic shut-
off valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring
program of potential spill or leak sources
W39 Other spill and leak prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications
Process Modifications
W51 Instituted recirculation within a process
W52 Modified equipment, layout, or piping
W53 Use of a different process catalyst
W54 Instituted better controls on operating bulk
containers to minimize discarding of empty
. containers
W55 Changed from small volume containers to
bulk containers to minimize discarding of
empty containers
W58 Other process modifications
Cleaning and Degreasing
W59 Modified stripping/cleaning equipment
W60 Changed to mechanical stripping/cleaning
devices (from solvents or other materials)
W61 Changed to aqueous cleaners (from solvents
or other materials)
48 To^cMef^IttoentoryRepottingFormRandlnstnicHons
-------
W63
W64
W65
W66
W67
W68
W71
Modified containment procedures for cleaning
units
Improved draining procedures
Redesigned parts racks to reduce dragout
Modified or installed rinse systems
Improved rinse equipment design
Improved rinse equipment operation
Other cleaning and degreasing modifications
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications
Product Modifications
W81 Changed product specifications.
W82 Modified design or composition of product.
W83 Modified packaging
W89 Other product modifications
In columns a through c of Section 8.10, the "Methods to
Identify Activity", you must enter one or more of the
following code(s) that correspond to those internal and
external method(s) or information sources you used to
identify the possibility for a source reduction activity
implementation at your facility. If more than three
methods were used to identify the source reduction
activity, enter only the three codes that contributed most
to the decision to implement the activity.
Methods to Identify Activity
T01
T02
T03
T04
T05
T06
T07
T08
T09
T10
Til
8.11
Internal pollution prevention opportunity
audit(s)
.External pollution prevention opportunity
audit(s) -
Materials balance audits
Participative team management
Employee recommendation (independent of a
formal company program)
Employee recommendation (under a formal
company program)
State government technical assistance program
Federal government technical assistance
program
Trade association/industry technical
assistance program
Vendor assistance
Other '.!
Is Additional Information on Source
! Reduction, Recycling, or Pollution Control
Activities Included with this Report?
Check "Yes" for this data element if you have attached to
this report any additional ogpHonal information onsource
reduction, recycling, or pollution control activities you
have implemented in the reporting year or in prior years
for the reported toxic chemical. If you are not including
additional information, check "No."
If you submit additional optional information, try to limit
this information to one page that summarizes the source
reduction, recycling, or pollution control activities. If
there is a contact person at the facility, other than the
technical or public contact provided in Part I, Section 4,
the summary page should include that person's name
and telephone number for individuals who wish to
obtain further information about those activities. Also
submit a copy of this additional information to the
appropriate state agency as part of the Form R submitted
to thatagency.
Toxic Release Inventory Reporting Form R and Instructions 49
-------
-------
TABLE I. SIC CODES 2O-39
20 Food and Kindred Products
2011 Meat packing plants
2013 Sausages and other prepared meat products
2015 Poultry slaughtering and processing
2021 Creamery butter
2022 Natural, processed, and imitation cheese
2023 Dry, condensed, and evaporated dairy •
products
2024 Ice cream and frozen desserts
2026 Fluid milk ,
2032 Canned specialties
2033 Canned fruits, vegetables, preserves, jams,
and jellies
2034 Dried and dehydrated fruits, vegetables, and
soup mixes ;
2035 Pickled fruits and vegetables, vegetable sauces
and seasonings, and salad dressings if;
2037 Frozen fruits, fruit juices, and vegetables
2038 Frozen specialties, n.e.c.*
2041 Flour and other grain mill products
2043 Cereal breakfast foods
2044 Rice milling
2045 Prepared flour mixes and doughs M
2046 Wet corn milling
2047 Dog and cat food
2048 Prepared feeds and feed ingredients for
animals and fowls, except dogs and cats
2051 Bread and other bakery products, except
cookies and crackers
2052 Cookies and crackers
2053 Frozen bakery products, except bread
2061 Cane sugar> except refining
2062 Cane sugar refining
2063 Beet sugar
2064 Candy and other confectionery products
2066 Chocolate and cocoa products
2067 Chewing gum
2068 Salted and roasted nuts and seeds
2074 Cottonseed oil mills
2075 Soybean oil mills
2076 Vegetable oil mills, n.e.c.*
2077 Animal and marine fats and oils
2079 Shortening, table oils, margarine, and other
edible fats and oils, n.e.c.*
2082 Malt beverages
2083 Malt
2084 Wines, brandy, and brandy spirits
2085 Distilled and blended liquors
2086 Bottled and canned soft drinks and
carbonated waters
2087 Flavoring extracts and flavoring syrups, n.e.c.'
2091 Canned and cured fish and seafoods
2092 Prepared fresh or frozen fish and seafoods
2095 Roasted coffee
2096 Potato chips, corn chips, and similar snacks
2097 Manufactured ice
2098 Macaroni, spaghetti, vermicelli, and noodles
2099 Food preparations, n.e.c.*
21 Tobacco Products
2111 Cigarettes
2121 Cigars
2131 Chewing and smoking tobacco and snuff
2141 Tobacco stemming and redrying
22 Textile Mill Products
2211 Broadwoven fabric mills, cotton
2221 Broadwoven fabric mills, manmade fiber, and
silk
2231 Broadwoven fabric mills, wool (including
dyeing and finishing)
2241 Narrow fabric and other smallwares mills:
. cotton, wool, silk, and manmade fiber
2251 Women's full length and knee length hosiery,
except socks
2252 Hosiery, n.e.c.*
2253 Knit outerwear mills
2254 Knit underwear and nightwear mills
2257 Weft knit fabric nulls
2258 Lace and warp knit fabric mills
2259 Knitting mills, n.e.c *
2261 Finishers of broadwoven fabrics of cotton
2262 Finishers of broadwoven fabrics of manmade
fiber and silk
2269 Finishers of textiles, n.e.c*
2273 Carpets and rugs
2281 Yarn spinning mills
2282 Yarn texturizing, throwing, twisting, and
winding mills
2284 Thread mills
2295 Coated fabrics, not rubberized
2296 Tire cord and fabrics
2297: Nonwoven fabrics
2298 Cordage and twine
2299 Textile goods, n.e.c.*
*"Not elsewhere classified" indicated by "n.ex."
Table I 1-1
-------
23 Apparel and Other Finished Products made
from Fabrics and Other Similar Materials
2311 Men's and boys' suits, coats, and overcoats
2321 Men's and boys' shirts, except work shirts
2322 Men's and boys' underwear and nightwear
2323 Men's and boys' neckwear
2325 Men's and boys' separate trousers and slacks
2326 Men's and boys' work clothing
2329 Men's and boys' clothing, n.e.c *
2331 Women's, misses', and juniors' blouses and
shirts
2335 Women's, misses', and juniors' dresses
2337 Women's, misses', and juniors' suits, skirts,
and coats
2339 Women's, misses', and juniors', outerwear,
n.e.c.*
2341 Women's, misses', children's, and infants'
underwear and nightwear
2342 Brassieres, girdles, and allied garments
2353 Hats, caps, and millinery
2361 Girls', children's and infants' dresses, blouses,
and shirts
2369 Girls', children's and infants' outerwear,
n.e.c.*
2371 Fur goods
2381 Dress and work gloves, except knit and all
leather
2384 Robes and dressing gowns
2385 Waterproof outerwear
2386 Leather and sheep lined clothing
2387 Apparel belts
2389 Apparel and accessories, n.e.c.*
2391 Curtains and draperies
2392 Housefurnishings, except curtains and
draperies
2393 Textile bags
2394 Canvas and related products
2395 Pleating, decorative and novelty stitching, and
tucking for the trade
2396 Automotive trimmings, apparel findings, and
related products
2397 Schiffli machine embroideries
2399 Fabricated textile products, n.e.c.*
24 Lumber and Wood Products, Except
Furniture
2411 Logging
2421 Sawmills and planing mills, general
2426 Hardwood dimension and flooring mills
2429 Special product sawmills, n.e.c.*
2431 Millwork
2434 Wood kitchen cabinets
1-2 Table I
2435 Hardwood veneer and plywood
2436 Softwood veneer and plywood
2439 Structural wood members, n.e.c.*
2441 Nailed and lock corner wood boxes and shook
2448 Wood pallets and skids
2449 Wood containers, n.e.c.*
2451 Mobile homes
2452 Prefabricated wood buildings and components
2491 Wood preserving
2493 Reconstituted wood products
2499 Wood products, n.e.c.*
25 Furniture and Fixtures
2511 Wood household furniture, except
upholstered
2512 Wood household furniture, upholstered
2514 Metal household furniture
2515 Mattresses, foundations, and convertible beds
2517 Wood television, radio, phonograph, and
sewing machine cabinets
2519 Household furniture, n.e.c.*
2521 Wood office furniture
2522 Office furniture, except wood
2531 Public building and related furniture
2541 Wood office and store fixtures, partitions,
shelving, and lockers
2542 Office and store fixtures, partitions, shelving,
and lockers, except wood
2591 Drapery hardware and window blinds and
shades
2599 Furniture and fixtures, n.e.c.*
26 Paper and Allied Products
2611 Pulp mills
2621 Paper mills
2631 Paperboard mills
2652 Setup paperboard boxes
2653 Corrugated and solid fiber boxes
2655 Fiber cans, tubes, drums, and similar products
2656 Sanitary food containers, except folding
2657 Folding paperboard boxes, including sanitary
2671 Packaging paper and plastics film, coated and
laminated
2672 Coated and laminated paper, n.e.c.*
2673 Plastics, foil, and coated paper bags
2674 Uncoated paper and multiwall bags
2675 Die-cut paper and paperboard and cardboard
2676 Sanitary paper products
2677 Fjivelopes
2678 Stationery tablets, and related products
2679 Converted paper and paperboard products,
n.e.c.*
*"Not elsewhere classified" indicated as "n.e.c."
-------
Printing, Publishing, and Allied Indus!
t-
2711 Newspapers: publishing, or publishing and
printing j
2721 Periodicals: publishing, or publishing and
printing
2731 Books: publishing, or publishing and printing
2732 Book printing " "
2741 Miscellaneous publishing
2752 Commercial printing, lithographic _: -
2754 Commercial printing, gravure
2759 Commercial printing, n.e.c.*
2761 Manifold business forms
2771 Greeting cards
2782 Blankbooks, looseleaf binders and devices
2789 Bookbinding and related work
2791 Typesetting
2796 Platemaking and related services
28 Chemicals and Allied Products
2812 Alkalies and chlorine
2813 Industrial gases
2816 Inorganic pigments
2819 Industrial inorganic chemicals, n.e.c,*
2821 Plastics materials, synthetic resins, and
non-vulcanizable elastomers
2822 Synthetic rubber (vulcanizable elastomers)
2823 Cellulosic manmade fibers
2824 Manmade organic fibers, except cellulosic
2833 Medicinal chemicals and botanical products
2834 Pharmaceutical preparations
2835 In vitro and in vivo diagnostic substances
2836 Biological products, except diagnostic
substances
2841 Soap and other detergents, except specialty
cleaners
2842 Specialty cleaning, polishing, and sanitation
preparations
2843 Surface active agents, finishing agents,
sulfonated oils, and assistants
2844 Perfumes, cosmetics, and other toilet
preparations - :
2851 Paints, varnishes, lacquers, enamels, and allied
products
2861 Gum and wood chemicals
2865 Cyclic organic crudes and intermediates, and
organic dyes and pigments
2869 Industrial organic chemicals, n.e.c.?
2873 Nitrogenous fertilizers
2874 Phosphatic fertilizers
2875 Fertilizers, mixing only
2879 Pesticides and agricultural chemicals, n.e.c.*
2891 Adhesives and sealants
2892 Explosives
2893 Printing ink
2895 Carbon black
2899 Chemicals and chemical preparations, n.e.c.*
29 Petroleum Refining and Related Industries
2911 Petroleum refining
2951 Asphalt paving mixtures and blocks
2952 Asphalt felts and coatings
2992 Lubricating oils and greases
2999 Products of petroleum and coal, n.e.c.*
30 Rubber and Miscellaneous Plastics Products
3011 Tires and inner tubes
3021 Rubber and plastics footwear
3052 Rubber and plastics hose and belting
3053 Gaskets, packing, and sealing devices
3061 Molded, extruded, and lathecut mechanical
, rubber products
3069 Fabricated rubber products, n.e.c.*
3081 Unsupported plastics film and sheet
3082 Unsupported plastics profile shapes
3083, Laminated plastics plate, sheet, and profile
shapes
3084 Plastics pipe
3085 Plastics bottles
3086 Plastics foam products
3087 Custom compounding of purchased plastics
resins
3088 Plastics plumbing fixtures
3089 Plastics products, n.e.c.*
31 Leather and Leather Products
3111, Leathertanning and finishing
3131 Boot and shoe cut stock and findings
3142; House slippers
3143 Men's footwear, except athletic
3144 Women's footwear, except athletic
3149: Footwear, except rubber, n.e.c.*
3151 Leather gloves and mittens
3161 Luggage
3171 Women's handbags and purses
3172: Personal leather goods, except women's
handbags and purses
3199 'Leather goods, n.e.c *
*"Not elsewhere classified" indicated by "n,e.c."
Table I 1-3
-------
32 Stone, Clay, Glass and Concrete Products
3211 Flat glass
3221 Glass containers
3229 Pressed and blown glass and glassware/ n.e.c.*
3231 Glass products, made of purchased glass
3241 Cement, hydraulic
3251 Brick and structural clay tile
3253 Ceramic wall and floor tile
3255 Clay refractories
3259 Structural clay products, n.e.c.*
3261 Vitreous china plumbing fixtures and china
and earthenware fittings and bathroom
accessories
3262 Vitreous china table and kitchen articles
3263 Fine earthenware (whiteware) table and
kitchen articles
3264 Porcelain electrical supplies
3269 Pottery products, n.e.c.*
3271 Concrete block and brick
3272 Concrete products, except block and brick
3273 Ready mixed concrete
3274 Lime
3275 Gypsum products
3281 Cut stone and stone products
3291 Abrasive products
3292 Asbestos products
3295 Minerals and earths, ground or otherwise
treated
3296 Mineral wool
3297 Nonclay refractories
3299 Nonmetallic mineral products, n.e.c.*
33 Primary Metal Industries
3312 Steel works, blast furnaces (including coke
ovens), and rolling mills
3313 Electrometallurgical products, except steel
3315 Steel wiredrawing and steel nails and spikes
3316 Cold-rolled steel sheet, strip, and bars
3317 Steel pipe and tubes
3321 Gray and ductile iron foundries
3322 Malleable iron foundries
3324 Steel investment foundries
3325 Steel foundries, n.e.c.*
3331 Primary smelting and refining of copper
3334 Primary production of aluminum
3339 Primary smelting and refining of nonferrous
metals, except copper and aluminum
3341 Secondary smelting and refining of nonferrous
metals
3351 Rolling, drawing, and extruding of copper
3353 Aluminum sheet, plate, and foil
^ff1**'" -:
335,4 Aluminum extruded products
3355 Aluminum rolling and drawing, n.e.c.*
3356 Rolling, drawing, and extruding of nonferrous
metals, except copper and aluminum
3357 Drawing and insulating of nonferrous wire
3363 Aluminum die-castings
3364 Nonferrous die-castings, except aluminum
3365 Aluminum foundries
3366 Copper foundries
3369 Nonferrous foundries, except aluminum and
copper
3398 Metal heat treating
3399 Primary metal products, n.e.c.*
34 Fabricated Metal Products, except Machinery
and Transportation Equipment
3411 Metal cans
3412 Metal shipping barrels, drums, kegs, and pails
3421 Cutlery
3423 Hand and edge tools, except machine tools
and handsaws
3425 Handsaws and saw blades
3429 Hardware, n.e.c.*
3431 Fjnameled iron and metal sanitary ware
3432 Plumbing fixture fittings and trim
3433 Heating equipment, except electric and warm
air furnaces
3441 Fabricated structural metal
3442 Metal doors, sash, frames, molding, and trim
3443 Fabricated plate work (boiler shops)
3444 Sheet metal work
3446 Architectural and ornamental metal work
3448 Prefabricated metal buildings and components
3449 Miscellaneous structural metal work
3451 Screw machine products
3452 Bolts, nuts, screws, rivets, and washers
3462 Iron and steel forgings
3463 Nonferrous forgings
3465 Automotive stampings
3468 Crowns and closures
3469 Metal stampings, n.e.c.*
3471 FJectroplating, plating, polishing, anodizing,
and coloring
3479 Coating, engraving and allied services, n.e.c.*
3482 Small arms ammunition
3483 Ammunition, except for small arms
3484 Small arms
3489 Ordnance and accessories, n.e.c.*
3491 Industrial valves
3492 Fluid power valves and hose fittings
3493 Steel springs, except wire
3494 Valves and pipe fittings, n.e.c.*
1-4 Table I
*"Not elsewhere classified" indicated as "n.e.c."
-------
3-rv
3495, Wire springs
3496, Miscellaneous fabricated wire products
34955 Metal foil and leaf
3498. Fabricated pipe and pipe fittings
3499 Fabricated rnetal products, n.e.c.*
35 Industrial and Commercial Machinery and
Computer Equipment
3511 Steam, gas and hydraulic turbines, and turbine
generator set units
3519 Internal combustion engines, n.e.c.*
3523 Farm machinery and equipment
3524 Lawn and garden tractors and home lawn and
garden equipment
3531 Construction machinery and equipment
• 3532 Mining machinery and equipment, except oil
and gas field machinery and equipment
3533 Oil and gas field machinery and equipment
3534 Elevators and moving stairways
3535 Conveyors and conveying equipment
3536 Overhead traveling cranes, hoists, and
monorail systems
3537 Industrial trucks, tractors, trailers, and
stackers
3541 Machine tools, metal cutting types
3542 Machine tools, metal forming types
3543 Industrial patterns
3544 Special dies and tools, die sets, jigs and
fixtures, and industrial molds
3545 Cutting tools, machine tool accessories, and
machinists' measuring devices
3546 Power driven handtools
3547 Rolling mill machinery and equipment
3548 Electric and gas welding and soldering
equipment
3549 Metalworking machinery, n.e.c.*
3552 Textile machinery
3553 Woodworking machinery
3554 Papgr industries machinery
3555 Printing trades machinery and equipment
3556 Food products machinery
3559 Special industry machinery, n.e.c.*
3561 Pumps and pumping equipment
3562 Ball and roller bearings
3563 Air and gas compressors
3564 Industrial and commercial fans and blowers
and air purification equipment
3565 Packaging equipment
3566 Speed changers, industrial high speed drives,
:' and gears
3567 Industrial process furnaces and ovens
3568 Mechanical power transmission equipment,
n.e.c.*
*"Not elsewhere classified" indicated by "n.e.c."
3569 General industrial machinery and equipment,
' n.e.c.* • .,'.
3571 Electronic computers
3572 Computer storage devices
3575 Computer terminals
3577 Computer peripheral equipment, n.e.c.*
3578 Calculating and accounting machines, except
electronic computers
3579 Office machines, n.e.c.*
3581 Automatic vending machines
3582 Commercial laundry, drycleaning, and
pressing machines
3585 Air conditioning and warm air heating
equipment and commercial and industrial
refrigeration equipment
3586 Measuring arid dispensing pumps
3589 Service industry machinery, n.e.c.*
3592 Carburetors, pistons, piston rings, and valves
3593 Fluid power cylinders and actuators
3594 Fluid power pumps and motors
3596 Scales and balances, except laboratory
3599 Industrial and Commercial machinery and
'. equipment, n.e.c*
36 , Electronic and Other Electrical Equipment
and Components, Except Computer
Equipment
3612 Power, distribution, and specialty
; transformers
3613; Switchgear and switchboard apparatus
3621 Motors and generators
3624 Carbon and graphite products
3625 Relays and industrial controls
3629 Electrical industrial appliances, n.e.c.*
3631 Household cooking equipment
3632 Household refrigerators and home and farm
freezers
3633 Household laundry equipment
3634 Electrical housewares and fans
3635 Household vacuum cleaners
36391 Household appliances, n.e.c.*
3641 'Electric lampbulbs and tubes
3643 Current carrying wiring devices
3644 Noncurrent carrying wiring devices
3645 jResidential electric lighting fixtures
3646 Commercial, industrial, and institutional
electric lighting fixtures
3647 Vehicular lighting equipment
3648 Lighting equipment, n.e.c.*
3651 Household audio and video equipment
3652 Phonograph records and pre-recorded audio
tapes arid disks
A Table I 1-5
-------
re?
3661 Telephone and telegraph apparatus
3663 Radio and television broadcasting and
communications equipment
3669 Communications equipment, n.e.c.*
3671 Electron tubes
3672 Printed circuit boards
3674 Semiconductors and related devices
3675 Electronic capacitors * •."•'•
3676 Electronic resistors
3677 Electronic coils, transformers, and other
inductors ' • '-' ' •
3678 Electronic connectors
3679 Electronic components, n.e.c.*
3691 Storage batteries
3692 Primary batteries, dry and wet
3694 Electric equipment for internal combustion
engines *'
3695 Magnetic and optical recording media
3699 Electrical machinery, equipment, and supplies,
n.e.c.*
37 Transportation Equipment
3711 Motor vehicles and passenger car bodies
3713 Truck and bus bodies
3714 Motor vehicle parts and accessories
3715 Truck trailers
3716 Motor homes
3721 Aircraft
3724 Aircraft engines and engine parts
3728 Aircraft parts and auxiliary equipment, n.e.c.*
3731 Ship building and repairing
3732 Boat building and repairing
3743 Railroad equipment
3751 Motorcycles, bicycles and parts
3761 Guided missiles and space vehicles
3764 Guided missile and space vehicle propulsion
units and propulsion unit parts
3769 Guided missile and space vehicle parts and
auxiliary equipment, n.e.c.*
3792 Travel trailers and campers
3795 Tanks and tank components
3799 Transportation equipment, n.e.c.*
38 Measuring, Analyzing, and Controlling
Instruments; Photographic, Medical and
Optical Goods; Watches and Clocks
3812 Search, detection, navigation, guidance,
aeronautical, and nautical systems and
instruments
3821 Laboratory apparatus and furniture
3822 Automatic controls for regulating residential
"and commercial environments and appliances"
3823 Industrial instruments for measurement?™' :' •
display, and control of process variablels^aTSd
related products ( ^.^
3824 Totalizing fluid meters and counting devices'-;
3825 Instruments for measuring and testing of f ';;:
' ••' electricity and electrical signals ldIDS,Cf E!
3826 Laboratory-analytical instruments am b?
3827 Optical instruments and lenses
3829 Measuring and controlling devices, n.e.c.*
3841 Surgical and medical instruments and
apparatus "
3842 Orthopedic, prosthetic, and surgical
appliances and supplies fMuJ •"'"
3843 Dental equipment and supplies
3844 X-ray apparatus and tubes and related^omr '•
irradiation apparatus
3845 Electromedical and electrothefapeutic -1
apparatus
3851 Ophthalmic goods ' • s
3861 Photographic equipment and supplies
3873 Watches, docks, clockwork operated ifevlcls!;-•
, . . bnF 'ano'r!.
and parts
~»fof 3ncr: :
39 Miscellaneous Manufacturing Industries
, • , • r} ffiSm:'i"', :"':''.•
3911 Jewelry, precious metal
3914 Silverware, plated ware, and stainless steel
. - • ;,uz
ware
3915 Jewelers' findings and materials, and lapidary^
work
3931 Musical instruments f
3942 Dolls and stuffed toys
3944 Games, toys and children's vehicles; except
dolls and bicycles ..
3949 Sporting and athletic goods, n.e.c.* >jOt/U
3951 Pens, mechanical pencils, and parts )fl
3952 Lead pencils, crayons, and artists' materials >~itt
3953 Marking devices
3955 Carbon paper and inked ribbons
3961 Costume jewelry and costume novelties,
except precious metal
3965 Fasteners, buttons, needles, and pins
3991 Brooms and brushes
3993 Signs and advertising specialties
3995 Burial caskets
3996 Linoleum, asphalted-felt-base, and other hard
surface floor coverings, n.e.c.*
3999 Manufacturing industries, n.e.c.*
1-6 Table I
.
*"Not elsewhere classified" indicated as "n.e.c."
-------
TABLE II. SECTION 313 TOXIC CHEMICAL LIST
FOR REPORTING YEAR 1991 (including
ff^ Toxic Chemical Categories)
Spec^g.toxie chemicals with CAS Number are listed in alphabetical order on this page. A list of the same
chemicals in CAS Number order begins at the end of the alphabetical list of toxic chemicals. Covered toxic
chemical-categories follow. ''
i
xic chemicals listed in Table II have parenthetic "qualifiers." These qualifiers indicate that these toxic
chemicals are subject to the section 313 reporting requirements if manufactured, processed, or otherwise used in
a specific form. The following chemicals are reportable only if they are manufactured, processed, or otherwise
used in the specific form(s) listecj^low:
Chemical
!
Aluminum (fume or dust)
Aluminum oxide (fibrous forms)
Ammonium nitrate (solution)
Ammonium sulfate (solution)
Asbestos (friable)
Isojgrpgyl alcohol (manufacturing -
strong acid process, no supplier
notification)
••. . •
Phosphorus (yellow or white)
Saccharin (manufacturing, no
supplier notification).
Vanadium (fume or dust)
Zinc (fume or dust)
CAS Number
7429-90-5
1344-28-1
6484-52-2
7783-20-2 , ,
1332-21-4
67-63-0
7723-14-0
81-07-2
7440-62-2
7440-66-6
Qualifier
Only if it is in a fume or dust form.
Only if it is a fibrous form.
'i
Only if it is in a solution.
Only if it is in a solution.
f Only if it is a friable form.
Only if it is being manufactured by the
!• strong acid process.
Only, if it is a yellow or white form.
Only if it is being manufactured.
Only if it is in a fume or dust form.
Only if it is in a fume or dust form.
[Note: Chemicals may be added to or deleted from the list. The Emergency Planning and Community Rieht-to-
Know Information Hotline, (800) 535-0202 or (703) 920-9877, will provide up-to-date information on
-------
a. Alphabetical Chemical List
De Minimis
CAS Number Toxic Chemical Name Concentration
De Minimis
Toxic Chemical Name Concentration
75-07-0 Acetaldehyde
60-35-5 Acetamide
67-64-1 Acetone
75-05-8 Acetonitrile
53-96-3 2-Acetylaminofluprene
107-02-8 Acrolein ,
79-06-1 Acrylamide
79-10-7 Acrylic acid
107-13-1 Acrylonitrile
309-00-2 Aldrin
{l,4:5^-Dimethanonaphthalene,
l^AlO/lO-hexachloro-l/Ma,
5,8,8a-hexahydro"-(l.alpha.,
4.alpha.,4a.beta.,5.alpha.,
8.alpha.,8a.beta.)-}
107-18-6 Allyl alcohol r
107-05-1 Allyl chloride ,
7429-90-5 Aluminum (fume or dust)
1344-28-1 Aluminum oxide
(fibrous forms)
\17-79-3 2-Aminoanthraquinone
, s60-09-3 4-Aminoazobenzene
92-67-1 4-Aminobiphenyl
82-28-0 l-Amino-2-
methylanthraquinone
7664-41-7 Ammonia
6484-52-2 Ammonium nitrate (solution)
7783-20-2 Ammonium sulfate (solution)
62-53-3 Aniline
90-04-0 o-Anisidine
104-94-9 p-Anisidine
134-29-2 o-Anisidine hydrochloride
120-12-7 Anthracene
7440-36-0 Antimony
7440-38-2 Arsenic
1332-21-4 Asbestos (friable)
7440-39-3 Barium
98-87-3 Benzal chloride
55-21-0 Benzamide
71-43-2 Benzene
92-87-5 Benzidine
98-07-7 Benzoic trichloride
{Benzotrichloride}
98-88-4 Benzoyl chloride
94-36-0 Benzoyl peroxide
100-44-7 Benzyl chloride
7440-41-7 Beryllium
0.1
0.1
1.0
1.6
.0.1
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
0.1
0.1
1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0
0.1
CAS Number
92-52-4 Biphenyl
111-44-4 Bis(2-chloroethyl) ether
542-88-1 Bis(chloromethyl) ether
0.1108-60-1 Bis(2-chloro-l-methylethyl)
' ' ether
103-23-1 '". Bis(2-ethylhexyl) adipate
353-59-3 BrorfJSchlorodifluoromethane
{Halonmi}
7S-25-2 , Bromoform
{Tribromomethane}
74-83-9 Bromomethane
{Methyl bromide},
75-63-8 Bromotrifluoromethane
{Halon 1301}
106-99-0 1,3-Butadiene
141-32-2 Butyl acrylate
71-36-3 n-Butyl alcohol
78-92-2 sec-Butyl alcohol
75-65-0 tert-Butyl alcohol
85-68-7 Butyl benzyl phthalate
106-88-7 1,2-Butylene oxide
123-72-8 Bufyraldehycle
4680-78-8 C.I. Acid Green 3* _,-G;
'569-64-2 C.I. Basic Green 4* B^,
989-38-8 C.I. Basic Red 1*
1937-37-7 C.I. Direct Black 38*
2602-46-2 C.I. Direct Blue 6*
16071-86-6 C.I. Direct Brown 95*
2832-40-8 C.I. Disperse Yellow 3*
3761-53-3 C.I. Food Red 5*
81-88-9 C.I. Food Red 15*
' 3118-97-6 C.I. Solvent Orange 7*
97-56-3 C.I. Solvent Yellow 3*
842-07-9 C.I. Solvent Yellow 14*
492-80-8 C.I. Solvent Yellow 34*
{Aurimine}
128-66-5 C.I. Vat Yellow 4* H-?_
7440-43-9 Cadmium
' 156-62-7 Calcium cyanamide
133-06-2 Captan
{lH-Isoindole-l,3(2H)-dione,
3a,4,7,7a-tetrahydro-
2-[(trichloromethyl)thio]-Kg \
63-25-2 Carbaryl
{1-Naphthalenol,
methylcarbamate} :?
'; 75-15-0 Carbon disulfide
56-23-5 Carbon tetraehloride
463-58-1 Carbonyl sulfide
060
1.0
:-TO
1.0
1.0
1.0
1.0
Jlc
0.1
1.0
1.0
-,. 1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
0.1
1.0
0.1
0.1
1.0
-0.1
0.1
0.1
1.0
,,0.1
1.0
1.0
1.0
1.0
0.1
1.0
II-2 Table II
*Q|>means "Colpr Index"
-------
,JCAS Number Toxic Chemical Name
De Minimis
Concentration
CASNumber Toxic Chemical Name
De Minimis
Concentration
120-80-9
133-90-4
57-74-9
7782-50-5
10049-04-4
79-11-8
532-27-4
108-90-7
510-15-6
75-00-3
67-66-3
74-87-3
107-30-2
126-99-8
1897-45-6
7440-47-3
7440-48-4
7440-50-8
8001-58-9
120-71-8
1319-77-3
108-39-4
95-48-7
106-44-5
98-82-8
80-15-9
135-20-6
110-82-7
94-75-7
1163-19-5
2303-16-4
Catechol
Chloramben
{Benzoic acid, 3-amino-
2,5-dichloro-}
Chlordane
{4,7-Methanoindan, 1,2,4,5,6,7,
7,7a-hexahydro-}
Chlorine
Chlorine dioxide
Chloroacetic acid
2-Chloroacetophenone
Chlorobenzene
Chlorobenzilate
(Benzeneacetic acid,4-chlor o-
.alpha.-(4-chlorophenyl)-
.alpha.-hydroxy-,eihyl ester}
Chloroethane
{Ethyl chloride}
Chloroform
Chloromethane
{Methyl chloride}
Chloromethyl methyl ether
Chloroprene
Chlorothalonil
{1,3-Benzenedicarbonitrile,
2,4,5,6-tetrachloro-}
Chromium
Cobalt
Copper
Creosote .
p-Cresidine
Cresol (mixed isomers)
m-Cresol
o-Cresol
p-Cresol
Cumene
Cumene hydroperoxide
Cupferron
{Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt}
Cydohexane
2,4-D
{Acetic acid,
(2,4-dichlorophenoxy)-}
Decabromodiphenyl oxide
Diallate
{Carbamothioic acid,
bis(l-methylethyl)-, S-(2,3-
dichloro-2-propenyl) ester}
1,0
1.0
1.0
1.0
1.0
1.0
1.0
1-0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
1-0
1-0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
615-05-4 2,4-Diaminoanisole 0.1
39156-41-7 2,4-Diaminoanisole sulfate 0.1
1Q1-80-4 4,4'-piaminodiphenyl ether 0.1
25376-45-8 Diaminotoluene . .... 0.1
(mixed isomers)
95-80-7 2,4-Diaminotoluene
334-88-3 Diazomethane
132-64-9 Dibenzofuran
96-12-8 l^-Dibromo-S-chloropropane
{DBCP}
106-93-4 1,2-Dibromoethane
{Ethylene dibromide}
124-73-2 Dibromotetrafluoroethane
; {Halon2402}
84-74-2 Dibutyl phthalate
25321-22-6 Dichlorobenzene (mixed
isomers)
95-50-1 1,2-Dichlorobenzene
541-73-1 1^-Dichlorobenzene
IQ6-46-7 1,4-Dichlorobenzene
91-94-1 S^'-Dichlorobenzidine
75-27-4 Dichlorobromomethane
75-71-8 Dichlorodifluoromethane
. : •';/. (CFC-12)
107-06-2 1,2-Dichloroethane
{Ethylene dichloride}
540-59-0 1,2-Dichloroethylene
75-09-2 Dichloromethane
; .! {Methylene chloride}
120-83-2 2,4-Dichlorophenol
78-87-5 1,2-Dichloropropane
78-88-6 2^-Dichloropropene
542-75-6 1,3-Dichloropropylene
76-14-2 Dichlorotetrafluoroethane
(CFC-114)
62-73-7 Dichlorvos
{Phosphoric acid, 2,2-
•',-'. dichloroethenyl dimethyl ester}
115-32-2 Dicofol
{Benzenemethanol, 4-chloro-
.alpha.-(4-chlorophenyl)-
'• .alpha.- (trichloromethyl)-}
1464-53-5 Diepoxybutane
111-42-2 piethanolamine T
177-81-7 Di-(2-ethylhexyl) phthalate
{DEHP}
84-66-2 Diethyl phtitialate
64-67-5 Diemyl sulfate
119-90-4 33'-Dimethoxybenzidine
60-11-7 4-Dimethylaminoazobenzene
0.1
1.0
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
b.i
1.0
o.i
i.o
i.o
i.o
o.i
1.0
i.o
1.0
o.i
1.0
0.1
1.0
0.1
0.1
0.1
*C.I. means "Color Index"
Table II H-3
-------
CAS Number Toxic Chemical Name
De Minimis
Concentration
CAS Number Toxic Chemical Name
De Minimis
Concentration
119-93-7 3,3'-Dimethylbenzidine 0.1
{o-Tolidine}
79-44-7 Dimethylcarbamyl chloride 0.1
57-14-7 1,1-Dimethyl hydrazine 0.1
105-67-9 2,4-Dimethylphenol 1.0
131-11-3 Dimethyl phthalate . 1.0
77-78-1 Dimethyl sulfate 0.1
99-65-0 m-Dinitrobenzene 1.0
528-29-0 o-Dinitrobenzene 1.0
100-25-4 p-Dinitrobenzene 1.0
534-52-1 4,6-Dinitro-o-cresol 1.0
51-28-5 2,4-Dinitrophenol 1.0
121-14-2 2,4-Dinitrotoluene " , 1.0
606-20-2 2,6-DinitrotoIuene 1.0
25321-14-6 Dinitrotoluene 1.0
(mixed isomers)
117-84-0 n-Diocfyl phthalate 1.0
123-91-1 1,4-Dioxane 0.1
122-66-7 1,2-Diphenylhydrazine 0.1
{Hydrazobenzene} .
106-89-8 Epichlorohydrin 0.1
110-80-5 2-Ethoxyethanol 1.0
140-88-5 Ethyl acrylate 0.1
100-41-4 Ethylbenzene 1.0
541-41-3 Ethyl chloroformate 1.0
74-85-1 Ethylene 1.0
107-21-1 Ethylene glycol 1.0
151-56-4 Ethyleneimine 0.1
{Aziridine}
75-21-8 Ethylene oxide 0.1
96-45-7 Ethylene thiourea 0.1
2164-17-2 Fluometuron 1.0
{Urea, HN-dimethyl-N'-
[3-{trifluoromethyl)phenyl]-}
50-00-0 Formaldehyde 0.1
76-13-1 FreonllS 1.0
{Ethane, l/l^-trichloro-l^^-
trifluoro-}
76-44-8 Heptachlor 1.0
{1,4,5,6,7,8,8-Heptachloro-
3a,4,7,7a-tetrahydro-
4,7-methano-lH-indene}
118-74-1 Hexachlorobenzene 0.1
87-68-3 Hexachloro-l,3-butadiene 1.0
77-47-4 Hexachlorocydopentadiene 1.0
67-72-1 Hexachloroethane 1.0
1335-87-1 Hexachloronaphihalene 1.0
680-31-9 Hexamethylphosphoramide 0.1
302-01-2 Hydrazine 0.1
10034-93-2 Hydrazine sulfate 0.1
-305
>r?
7647-01-0 Hydrochloric acid 1.0
74-90-8 Hydrogen cyanide 1.0
7664-39-3 Hydrogen fluoride 1.0
123-31-9 Hydroquinone 1.0
78-84-2 Isobutyraldehyde 1.0
67-63-0 Isopropyl alcohol 0.1;
(manufacturing-strong acid '
process, no supplier notification) '"
80-05-7 4,4'-Isopropylidenediphenol 1.0
120-58-1 Isosafrole . 1.0s
7439-92-1 Lead 0.1
58-89-9 Lindane 0.1
{Cyclohexane,!^/*^^-
hexachloro-,(l .alpha.,2.alphav
3.beta.,4.alpha.^.alpha.,6.beta.)-}
108-31-6 Maleic anhydride 1.0
12427-38-2 Maneb 1.0
{Carbamodithioic acid, 1,2-
ethanediylbis-,manganese 'jd
complex} "^
7439-96-5 Manganese
7439-97-6 Mercury 1.6*"'^
67-56-1 Methanol 1 JO "'
72-43-5 Methoxychlor 'l:d
{Benzene, 1,1X2,2,2- ^ >r f
trichloroefhylidene)bis
[4-methoxy-]}
109-86-4 2-Methoxyethanol 1.0
96-33-3 Methyl acrylate 1.0
1634-04-4 Methyl tert-butyl ether 1.0
101-14-4 4,4'-Methylenebis (2- 0:1
chloroaniline)
{MBOCA} • --'-«
101-61-1 4,4'-Methylenebis 0.1 ''
(N,N-dimethyl)
benzenaimine
101-68-8 Methylenebis '1.0
(phenylisocyanate) {MBI} •' -
74-95-3 Methylene bromide 1.0
101-77-9 4,4'-Methylenedianiline 0.1
78-93-3 Methyl ethyl ketone |:08-\8
60-34-4 Methyl hydrazine is:(F"OV
74-88-4 Methyl iodide %'rl/'
108-10-1 Methyl isoburyl ketone 'W;-';'~
624-83-9 Methyl isocyanate |:^f-'
80-62-6 Methyl methacrylate 1."$"
90-94-8 Michler's ketone " b'.l
1313-27-5 Molybdenum trioxide >J"1.0
76-15-3 (Mono)chloropentafluoroethanel.O
{CFC-115} 'i:sf
II-4 TaUe II
*C.I. means "Color Index"
-------
«c.
CAS Number
505-60-2
91-20-3
134-32-7
91-59-8
7440-02-0
7697-37-2
139-13-9
99-59-2
98-95-3
92-93-3
1836-75-5
51-75-2
55-63-0
88-75-5
100-02-7
79-46-9
156-10-5
121-69-7
924-16-3
55-18-5
62-75-9
86-30-6
621-64-7
4549-40-0
59-89-2
759-73-9
684-93-5
16543-55-8
100-75-4
2234-13-1
20816-12-0
56-38-2
87-86-5
79-21^6
108-95-2
106-50f3
90-4|
75-44r5
7664-38-2
7723-14-0
85-44-9 4,
88-89-1
DeMinimis
Toxic Chemical Name Concentration
Mustard gas 0.1
{Ethane, I7l'-thiobis[2-chloro-]}
Naphthalene 1.0
alpha-Naphthylamine 0.1
beta-Naphthylamine 0.1
Nickel luiDbv., 0.1
Nitric acid ',- 1.0
Nitrilotriacetic acid 0.1
5-Nitro-o-anisidine 0.1
Nitrobenzene 1.0
4-Nitrobiphenyl , 0.1
Nitrofen 0.1
{Benzene, 2,4-dichloro-l-
(4-nitrophenoxy)-}
Nitrogen mustard 0.1
{2-Chloro-N-(2-chloroethyl)-N-
methylethanamine}
Nitroglycerin 1.0
2-Nitrophenol 1.0
4-Nitrophenol 1.0
2-Nitropropane 0.1
p-Nitrosodiphenylamine 0.1
N,N-Dimethylaniline 1.0
N-Nitrosodi-n-butylamine 0.1
N-Nitrosodiethylamine 0.1
N-Nitrosodimethylamine 0.1
N-Nitrosodiphenylamine 1.0
N-Nitrosodi-n-propylamine 0.1
N-Nitrosomethylvinylamine 0.1
N-Nitrosomorpholine 0.1
N-Nitroso-N-ethylurea 0.1
N-Nitroso-N-methylurea 0.1
N-Nitrosonornicotine 0.1
N-Nitrosopiperidine 0.1
Octachloronaphthalene 1.0
Osmium tetroxide 1.0
Parathion 1.0
{Phosphorothioic acid, O, O-
diethyl-O-(4-nitrpphenyl) ester}
Pentachlorophenol {PCP} 1.0
Peracetic acid 1.0
Phenol 1.0
p-Phenylenediamine 1.0
2-Phenylphenol 1.0
Phosgene 1.0
Phosphoric acid 1.0
Phosphorus (yellow or white) 1.0
Phthalic anhydride 1.0
Picric acid 1.0
CAS Number Toxic Chemical Name
DeMinimis
Concentration
1336-36-3 Polychlorinated biphenyls 0.1
{PCBs}
1120-71-4 Propane sultone 0.1
57-57-8 beta-Propiolactone 0.1
123-38-6 Propionaldehyde 1.0
114-26-1 Propoxur 1.0 ^
{Phenol, ^-(l-methylethoxy)-,
methylcarbamate}
115-07-1 Propylene 1.0 v
; {Propene}
75-55-8 Propyleneimine 0.1
75-56-9 Propylene oxide 0.1
110-86-1 Pyridine 1.0
91-22-5 Quinoline 1.0
106-51-4 Quinone 1.0
82-68-8 Quintozene 1.0
{Pentachloronitrobenzene}
81-07-2 Saccharin (manufacturing, no 0.1
supplier notification)
{l,2-Benzisothiazol-3(2H)-one, '••.-'•••>.
1,1-dioxide} '•.••'=-; .'.'<
94-59-7 Safrole -Oil,
7782-49-2 Selenium 1!.0
7440-22-4 Silver 1:.0:.
100-42-5 Styrene 0;1:' •#•'
96-09-3 Styrene oxide 0.1
7664-93-9 Sulfuricacid M.O-,*;-.
79-34-5 1,1,2,2-Tetochloroethane 0.1
127-18-4 Tetrachloroethylene 0.1
{Perchloroethylene}
961-11-5 Tetrachlorvinphos 1.0 !
{Phosphoric acid, 2-chloro-l-
(2,4,5-Mchlorophenyl) ethenyl
dimethyl ester}
7440-28-0 Thallium 1.0
62-55-5 Thioacetamide 0.1
139-65-1 4,4'-Thiodianiline 0.1
62-56-6 Thiourea 0.1
1314-20-1 Thorium dioxide 1.0
7550-45-0 Titanium tetrachloride 1.0
108-88-3 Toluene 1.0
584-84-9 Toluene-2,4-diisocyanate 0:1
91-08-7 Toluene-2,6-diisocyanate 0.1 '
26471-62-5 Toluenediisocyanate 0.1
(mixed isomers)
95-53-4 o-Toluidine 0.1 . ,,
636-21-5 o-Toluidine hydrochloride Oil
8001-35-2 Toxaphene 0.1 j)£
*C.I. means "Color Index"
Table II II-5
-------
CAS Number Toxic Chemical Name
De Minimis
Concentration
68-76-8 Triaziquone 0.1
{2/5-Cydohexadiene-l,4-dione/
2/3/5-tris(l-aziridinyl)-}
52-68-6 Trichlorfon 1.0
{Phosphonic add,(2A2-trichloro-
l-hydroxyethyl)-,dirrieth.yl ester} ,
120-82-1 1,2,4-Trichlorobenzene 1.0
7I-55-6" 1,1,1-Trichloroethane ,. 1.0
{Methyl chloroform} ••
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 1.0
75-69-4 Trichlorofluoromethane 1.0
{CFC-11}
95-95-4 2,4^-Trichlorophenol , l.Q
88-06-2 2,4,6-Trichlorophenol 0.1
1582-09-8 Trifluralin 1.0
{Benzenamine, 2,6-dinitro-N,N-
dipropyl-4-(trifluoromethyl)-l}
95-63-6 l^^Trimethylbenzene 1.0
CAS Number
126-72-7
51-79-6
7440-62-2
108^05-4
593-60-2
75-01-4
75-35-4
1330-20-7
108-38-3
95-47-6
106-42-3
87-62-7
7440-66-6
12122-67-7
De
Minimis
Toxic Chemical Name Concentration
Tris (2,3-dibromopropyl)
phosphate
Urethane
{Ethyl carbamate}
Vanadium (fume or dust)
Vinyl.acetate
Vinyl:brbS?ide
Vinyl chloride
Vinylidene chloride
Xylene (mixed isomers)
m-Xylene
o-Xylene
p-Xylene
2,6-Xylidine
Zinc (fume or dust)
Zineb
{Carbamodithioic acid, 1,2-
ethanediylbis-, zinc complex}
0.1
o.i
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
; *•'•£
II-6 TaUe II
*C.I. means "Color Index"
-------
b. List By CAS Number
CAS Number
50-00-0
51-28-5
51-75-2
51-79-6
52-68-6
53-96-3
55-18-5
55-21-0
55-63-0
56-23-5
56-38-2
57-14-7
57-57-8
57-74-9
58-89-9
De Minimis
Toxic Chemical Name Concentration
Formaldehyde 0.1
2,4-Dinitrophenol 1.0
Nitrogen mustard 0.1
{2-Chloro-N-(2-chloroethyl)-N-
methylethanamine}
Urethane 0.1
{Ethyl carbamate}
Trichlorfon 1.0
{Phosphonic acid,(2,2,2-trichloro-
1-hydroxyethyl)-, dimethyl ester}
2-Acetylaminofluorene
N-Nitrosodiethylamine
Benzamide
Nitroglycerin
Carbon tetrachloride
Parathion
{Phosphorothioic acid, O,O-
diethyl-O-(4-nitrophenyl)ester}
1,1-Dimethylhydrazine
beta-Propiolactone
Chlordane
{4/7-Methanoindan,l/2,4/5/6,7,
0.1
0.1
1.0
1.0
0.1
1.0
0.1
0.1
1.0
hexahydro-}
Lindane 0.1
{Cyclohexane,l,2,3,4,5,6-
hexachloro-,(l .alphav2.alpha.,
S.beta., 4.alpha.,5.alpha.,6.beta.)-}
59-89-2 N-Nitrosomorpholine 0.1
60-09-3 4-Aminoazobenzene 0.1
60-11-7 4-Dimethylaminoazobenzene 0.1
60-34-4 Methyl hydrazine 1.0
60-35-5 Acetamide 0.1
62-53-3 Aniline 1.0
62-55-5 Thioacetamide 0.1
62-56-6 Thiourea 0.1
62-73-7 Dichlorvos 1.0
{Phosphoric acid, 2,2-
dichloroethenyl dimethyl ester}
62-75-9 N-Nitrosodimethylamine 0.1
63-25-2 Carbaryl 1.0
{1-Naphthalenol,
methylcarbamate}
64-67-5 Diethyl sulfate 0.1
67-56-1 Methanol 1.0
67-63-0 Isopropyl alcohol 0.1
(manufacturing-strong acid
process, no supplier notification)
De Minimis
CAS Number Toxic Chemical Name Concentration
67-64-1 Acetone 1.0
67-66-3 Chloroform 0.1
67-72-1 Hexachloroethane 1.0
68-76-8 Triaziquone 0.1
{2,5-Cyclohexadiene-l,4-dione,
2,3,5-tris(l-aziridinyl)-}
71-36-3 n-Butyl alcohol 1.0
71-43-2 Benzene 0.1
71-55-6 1,1,1-Trichloroethane 1.0
{Methyl chloroform}
72-43-5 Methoxychlor 1.0
{Benzene, l,l'-(2,2,2-
trichloroethylidene)bis
[4-methoxy-]}
74-83-9 Bromomethane 1.0
{Methyl bromide}
74-85-1 Ethylene 1.0
74-87-3 Chloromethane . 1.0
{Methyl chloride}
74-88-4 Methyl iodide 0.1
74-90-8 Hydrogen cyanide 1.0
74-95-3 Methylene bromide 1.0
75-00-3 Chloroethane 1.0
{Ethyl chloride}
75-01-4 Vinyl chloride 0.1
75-05-8 Acetonitrile 1.0
75-07-0 Acetaldehyde 0.1
75-09-2 Dichloromethane 0.1
{Methylene chloride}
75-15-0 Carbon disulfide 1.0
75-21-8 Ethylene oxide 0.1
75-25-2 Bromoform 1.0
{Tribromomethane}
75-27-4 Dichlorobromomethane 1.0
75-35-4 Vinylidene chloride 1.0
75-44-5 Phosgene 1.0
75-55-8 Propyleneimine 0.1
75-56-9 Propylene oxide 0.1
75-63-8 Bromotrifluoromethane 1.0
i {Halon 1301}
75-65-0 tert-Butyl alcohol 1.0
75-69-4 Trichlorofluoromethane 1.0
i {CFC-11}
75-71-8 Dichlorodifluoromethane 1.0
{CFC-12}
76-14-2 Dichlorotetrafluoroethane 1.0
{CFC-114}
76-15-3 Monochloropentafluoroethane 1.0
'. {CFC-115}
*C.I. means "Color Index"
323-732 - 92 - 6 QL 3
Table II H-7
-------
CAS Number Toxic Chemical Name
De Minimis
Concentration
76-44-8 Heptachlor 1.0
{1,4,5,6,7,8,8-Heptachloro-
SaA^a-tetrahydro-
4,7-methano-lH-indene}
77-13-1 FreonllS 1.0
{Ethane, l^^-trichloro-l^^-
trifluoro-}
77.47.4 Hexachlorocydopentadiene 1.0
77-78-1 Dimethyl sulfate 0.1
78-84-2 Isobutyraldehyde 1.0
78-87-5 1,2-Dichloropropane 1.6
78-88-6 2,3-Dichloropropene 1.0
78-92-2 sec-Butyl alcohol 1.0
78-93-3 Methyl ethyl ketone 1.0
79-00-5 1,1^-Trichloroethane 1.0
79-01-6 Trichloroethylene 1.0
79-06-1 Acrylamide 0.1
79-10-7 Acrylic acid 1.0
79-11-8 Chloroaceticacid 1.0
79-21-0 Peraeetic acid 1.0
79-34-5 1,1/2,2-Tetrachloroethane 0.1
79-44-7 Dimethylcarbamyl chloride 0.1
79-46-9 2-Nitropropane 0.1
80-05-7 4/t'-Isopropylidenediphenol 1.0
80-15-9 Cumene hydroperoxide 1.0
80-62-6 Methyl methacrylate 1.0
81-07-2 Saccharin (manufacturing, no 0.1
supplier notification)
{i;Z-Benzisothiazol-3(2H)-one,
1,1-dioxide}
81-88-9 CI. Food Red 15* 0.1
82-28-0 l-Amino-2-methyl- 0.1
anthraquinone
82-68-8 Quintozene 1.0
{Pentachloronitrobenzene}
84-66-2 Diethylphthalate 1.0
84-74-2 Dibutylphthalate 1.0
85-44-9 Phthalic anhydride 1.0
85-68-7 Butyl benzyl phthalate 1.0
86-30-6 N-Nitrosodiphenylamine 1.0
87-62-7 2,6-Xylidine 1.0
87-68-3 Hexachloro-l^-butadiene 1.0
87-86-5 Pentachlorophenol 1.0
{PCP}
88-06-2 2,4,6-Triclilorophenol 0.1
88-75-5 2-Nitrophenol 1.0
88-89-1 Picric acid 1.0
90-04-0 o-Anisidine 0.1
90-43-7 2-Phenylphenol 1.0
90-94-8 Michler's Ketone 0.1
De Minimis
CAS Number Toxic Chemical Name Concentration
91-08-7
91-20-3
91-22-5
91-59-8
91-94-1
92-52-4
92-67-1
92-87-5
92-93-3
94-36-0
94-59-7
94-75-7
95-47-6
95-48-7
95-50-1
95-53-4
95-63-6
95-80-7
95-95-4
96-09-3
96-12-8
96-33-3
96-45-7
97-56-3
98-07-7
98-82-8
98-87-3
98-88-4
98-95-3
99-59-2
99-65-0
100-02-7
100-25-4
100-41-4
100-42-5
100-44-7
100-75-4
101-14-4
101-61-1
101-68-8
101-77-9
Toluene-2,6-
Diisocyanate
Naphthalene
Quinoline
beta-Napthylamine
3,3'-Dichlorobenzidine
Biphenyl
4-Aminobiphenyl
Benzidine
4-Nitrobiphenyl
Benzoyl Peroxide
Safrole
2,4-D
{Acetic acid,
(2,4 dichlorophenoxy)-}
o-Xylene
o-Cresol
1,2 Dichlorobenzene
o-Toluidine
1,2,4 Trimethylbenzene
2,4-Diaminotoluene
2,4,5-Trichlorophenol
Styrene oxide
l,2-Dibromo-3-chloropropane
{DBCP}
Methyl acrylate
Ethylene thiourea
C.I. Solvent Yellow 3*
Benzoic trichloride
{Benzotrichloride}
Cumene
Benzal chloride
Benzoyl chloride
Nitrobenzene
5-Nitro-o-anisidine
m-Dinitrobenzene
4-Nitrophenol
p-Dinitrobenzene
Ethylbenzene
Siyrene
Benzyl chloride
N-Nitrosopiperidine
4,4'-Methylenebis (2-
chloroaniline)
{MBOCA}
4,4'-Methylenebis(N,N-
dimethyl) benzenamine
Methylenebis
(phenylisocyanate) {MBI}
4,4'-Methylenedianiline
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
0.1
1.0
0.1
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
0.1
0.1
1.0
0.1
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
1.0
0.1
0.1
0.1
1.0
0.1
H-8 Table II
*C.I. means "Color Index"
-------
CAS Number
101-80-4
103-23-1
104-94-9
105-67-9
106-42-3
106-44-5
106-46-7
106-50-3
106-51-4
106-88-7
106-89-8
106-93-4
106-99-0
107-02-8
107-05-1
107-06-2
107-13-1
107-18-6
107-21-1
107-30-2
108-05-4
108-10-1
108-31-6
108-38-3
108-39-4
108-60-1
108-88-3
108-90-7
108-95-2
109-86-4
110-80-5
110-82-7
110-86-1
111-42-2
111-44-4
114-26-1
DC Minimis
Toxic Chemical Name Concentration
CAS Number Toxic Chemical Name
De Minimis
Concentration
115-07-1
115-32-2
117-79-3
117-81-7
4/4'-Diaminodiphenyl ether 0.1
Bis(2-ethylhexyl) adipate 1.0
p-Anisidine 1.0
2,4-Dimethylphenol 1.0
p-Xylene 1.0
p-Cresol 1.0
1,4-Dichlorobenzene 0.1
p-Phenylenediamine 1.0
Quinone 1.0
1,2-Butylene oxide 1.0
Epichlorohydrin 0.1
1,2-Dibromoethane 0.1
{Ethylene dibrornide}
1,3-Butadiene 0.1
Acrolein 1.0
Allyl chloride 1.0
1,2-Dichloroethane 0.1
{Ethylene dichloride}
Acrylonitrile 0.1
., Allyl alcohol 1.0
Ethylene-glycol 1.0
Chloromethyl methyl ether -04
Vinyl acetate 1.0
Methyl isobutyl ketone 1.0
Maleic anhydride 1.0
m-Xylene 1.0
m-Cresol 1.0
Bis(2-chloro-l-methylethyl) 1.0
ether
Toluene 1.0
Chlorobenzene 1.0
Phenol 1.0
2-Methoxyethanol 1.0
2-Ethoxyethanol 1.0
Cydohexane 1.0
Pyridine 1.0
Diethanolamine 1.0
Bis(2-chloroethyl) ether 1.0
Propoxur l.Q
{Phenol, 2-(l-meihylethoxy)-/
methylcarbamate}
Propylene (Propene) 1.0
Dicofol 1.0
{Benzenemethanol, 4-chloro-
.alpha.-(4-chlorophenyl)-
.alpha.-(trichloromethyl)-}
2-Aminoanthraquinone 0.1
Di(2-ethylhexyl) phthalate 0.1
{DEHP}
117-84-0 n-Diocryl phthalate 1.0
118-74-1 Hexachlorobenzene 0.1
119-90-4 3,3'-Dimethoxybenzidine 0.1
119-93-7 3^'-Dimethylbenzidine 0.1
{o-Tolidine}
120-12-7 Anthracene 1.0
120r58-l Isosafrole 1.0
120-71-8 p-Cresidine 0.1
120-80-9 Catechol 1.0
120-82-1 1,2,4-Trichlorobenzene i-0
120^-83-2 2,4-Dichlorophenol 1.0
121-14-2 2,4-Dinitrotoluene 1.0
121-69-7 N,N-Dimethylaniline 1.0
122-66-7 1,2-Diphenylhydrazine 0.1
{Hydrazobenzene}
123-31-9 Hydroquinone 1.0
123-38-6 Propionaldehyde 1.0
123-72-8 Butyraldehyde 1.0
123-91-1 1,4-Dioxane 0.1
124-73-2 Dibromotetrafluoroethane 1.0
; {Halon2402}
126-72-7 Tris(2,3-dibromopropyl) 0.1
phosphate
126-99-8 Chloroprene 1.0
127-18-4 Tetrachloroethylene 0.1
! {Perchloroethylene}
128-66-5 C.I. Vat Yellow 4* 1.0
131-11-3 Dimethyl phthalate 1.0
132-64-9 Dibenzofuran 1.0
133-06-2 Captan " 1.0
{lH-Isoindole-l,3(2H)-dione,
3a,4,7,7a-tetrahydro-
2-[(hichloromethyl)thio]-}
133-90-4 Chloramben 1.0
{Benzoic acid, 3-amino-
2,5-dichloro-}
134-29-2 o-Anisidine hydrochloride 0.1
134-32-7 alpha-Naphthylamine 0.1
135-20-6 Cupferron 0.1
{Benzeneamine, N-hydroxy-
N-nitroso,ammonium salt}
139-13-9 NitrUotriacetic acid 0.1
139-65-1 4,4'-Thiodianiline 0.1
140-88-5 Ethyl acrylate 0.1
141-32-2 Butyl acrylate 1.0
151-56-4 Ethyleneimine (Aziridine) 0.1
156-10-5 p-Nitrosodiphenylamine 0.1
156-62-7 Calcium cyanamide 1.0
302-01-2 Hydrazine 0.1
*C.I. means "Color mdex"
Table II H-9
-------
CAS Number Toxic Chemical Name
DeMinimis
Concentration
CAS Number Toxic Chemical Name
De Minimis
Concentration
309-00-2
334-88-3
353-59-3
463-58-1
492-80-8
505-60-2
510-15-6
528-29-0
532-27-4
534-52-1
540-59-0
541-41-3
541-73-1
542-75-6
542-88-1
569-64-2
584-84-9
593-60-2
606-20-2
615-05-4
621-64-7
624-83-9
636-21-5
680-31-9
684-93-5
759-73-9
842-07-9
924-16-3
961-11-5
989-38-8
1120-71-4
1163-19-5
1313-27-5
1314-20-1
1319-77-3
1330-20-7
Aldrin 1.0
{l/4:5,8-Dimemanonaphthalene,
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
0.1
0.1
1.0
0.1
0.1
1.0
0.1
0.1
0.1
0.1
0.1
0.1
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
5,8,8a-hexahydro-(l.alpha.,
4.alpha./4a.beta./5.alpha.,
8-alpha.,8a.beta.)-}
Diazomethane
Bromochlorodifluoromethane
{Halonl211}
Carbonylsulfide
C.I. Solvent Yellow 34*
{Aurimine}
Mustard gas
{Ethane,l,l'-truobis[2-chloro-}
Chlorobenzilate
{Benzeneacetic acid,4-chloro-
.alpha.-(4-chlorophenyl)-
.alpha.-hydroxy-,ethyl ester}
o-Dinitrobenzene
2-Chloroacetophenone
4,6-Diriitro-o-cresol
1,2-Dichloroemylene
Ethyl chloroformate
1,3-Dichlorobenzene
1,3-Dichloropropylene
Bis(chloromethyl) ether
C.I. Basic Green 4*
Toluene-2,4-diisocyanate
Vinyl bromide
2,6-Dinitrotoluene
2,4-Diaminoanisole
N-Nitrosodi-n-propylamine
Methyl isocyanate
o-Toluidinehydrochloride
Hexamethylphosphoramide
N-Nitroso-N-methylurea
N-Nitroso-N-ethylurea
C.I. Solvent Yellow 14*
N-Nitrosodi-n-butylamine
Tetrachlorvinphos
{Phosphoric acid, 2-chloro-l-
(2,4^-trichlorophenyl)ethenyl
dimethyl ester}
C.I. Basic Red 1*
Propane sultone
Decabromodiphenyl oxide
Molybdenum trioxide
Thorium dioxide
Cresol (mixed isomers)
Xylene (mixed isomers)
1332-21-4 Asbestos (friable)
1335-87-1 Hexachloronaphthalene
1336-36-3 Polychlorinated biphenyls
{PCBs}
1344-28-1 Aluminum oxide
(fibrous forms)
1464-53-5 Diepoxybutane
1582-09-8 Trifluralin
{Benzenamine, 2,6- dinitro-N,N
dipropyl-4-(trifluoromethyl)-}
1634-04-4 Methyl tert-butyl ether
1836-75-5 Nitrofen
{Benzene, 2,4-dichloro-l-
(4-nitrophenoxyH
1897-45-6 Chlorothalonil
{1,3-Benzenedicarbonitrile,
2,4,5,6-tetrachloro-}
1937-37-7 C.I. Direct Black 38*
2164-17-2 Fluometuron
{Urea, N,N-dimethyl-N'-
[3-(trifluoromethyl)phenyl]-}
2234-13-1 Octachloronaphthalene
2303-16-4 Diallate
{Carbamothioic acid,
bis (1-methylethyl)-, S-(2,3-
dichloro-2-propenyl) ester}
2602-46-2 C.I. Direct Blue 6*
2832-40-8 C.I. Disperse Yellow 3*
3118-97-6 C.I. Solvent Orange 7*
3761-53-3 C.I. Food Red 5*
4549-40-0 N-Nitrosomethylvinylamine
4680-78-8 C.I. Acid Green 3*
6484-52-2 Ammonium nitrate (solution)
7429-90-5 Aluminum (fume or dust)
7439-92-1 Lead
7439-96-5 Manganese
7439-97-6 Mercury
7440-02-0 Nickel
7440-22-4 Silver
7440-28-0 Thallium
7440-36-0 Antimony
7440-38-2 Arsenic
7440-39-3 Barium
7440-41-7 Beryllium
7440-43-9 Cadmium
7440-47-3 Chromium
7440-48-4 Cobalt
7440-50-8 Copper
7440-62-2 Vanadium (fume or dust)
7440-66-6 Zinc (fume or dust)
0.1
1.0
0.1
0.1
0.1
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
1.0
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
0.1
1.0
1.0
1.0
1.0
II-10 Table II
*C.I. means "Color Index"
-------
De Minimis
CAS Number Toxic Chemical Name Concentration
7550-45-0 Titanium tetrachloride 1.0
7647-01-0 Hydrochloric acid 1.0
7664-38-2 Phosphoric acid 1.0
7664-39-3 Hydrogen fluoride 1.0
7664-41-7 Ammonia 1.0
7664-93-9 Sulfuric acid 1.0
7697-37-2 Nitric acid 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
7782-49-2 Selenium 1.0
7782-50-5 Chlorine 1.0
7783-20-2 Ammonium sulfate (solution) 1.0
8001-35-2 Toxaphene 0.1
8001-58-9 Creosote 0.1
10034-93-2 Hydrazine sulfate 0.1
10049-04-4 Chlorine dioxide 1.0
12122-67-7 Zineb 1.0
{Carbamodithioic acid, 1,2-
ethanediylbis-,zinc complex}
12427-38-2 Maneb 1.0
{Carbamodithioic acid, 1,2-
ethanediylbis-,manganese
complex}
16071-86-6 C.I. Direct Brown 95* 0.1
16543-55-8 N-Nitrosonornicotine 0.1
20816-12-0 Osmium tetroxide 1.0
25321-14-6 Dinitrotoluene (mixed isomers) 1.0
25321-22-6 Dichlorobenzene (mixed 0.1
isomers)
25376-45-8 Diaminotoluene 0.1
(mixed isomers)
26471-62-5 Toluenediisocyanate 0.1
(mixed isomers)
39156-41-7 2,4-Diaminoanisole sulfate 0.1
SECTION 313 TOXIC CHEMICAL CATEGORIES
Section 313 requires reporting on the toxic chemical
categories listed below, in addition to the specific toxic
chemicals listed above.
The metal compounds listed below, unless otherwise
specified, are defined as including any unique chemical
substance that contains the named metal (i.e., antimony,
copper, etc.) as part of that chemical's structure.
Toxic chemical categories are subject to the 1 percent de
minimis concentration unless the substance involved
meets the definition of an OSH A carcinogen, which are
subject to the 0.1 percent de minimis concentration. The
de minimis concentration for each compound is pro-
vided in paranthesis.
Antimony Compounds - (Category Code N010) -
Includes any unique chemical substance that contains
antimony as part of that chemical's infrastructure. (1.0)
Arsenic Compounds - (Category Code N020) -
Includes any unique chemical substance that contains
arsenic as part of that chemical's infrastructure.
(Inorganic compounds: 0.1; organic compounds: 1.0)
Barium Compounds - (Category Code N040) -
Includes any unique chemical substance that contains
barium as part of that chemical's infrastructure. (1.0)
Beryllium Compounds - (Category Code N050) -
Includes any unique chemical substance that contains
beryllium as part of that chemical's infrastructure.
(Inorganic compounds: 0.1; organic compounds: 1.0)
Cadmium Compounds - (Category Code N078) -
Includes any unique chemical substance that contains
cadmium as part of that chemical's infrastructure.
(Inorganic compounds: 0.1; organic compounds: 1.0)
Chlorophenols - (Category Code N084) - (0.1)
where x = 1 to 5
*C.I. means "Color Index"
Table H n-11
-------
Chromium Compounds - (Category Code N090) -
Includes any unique chemical substance that contains
chromium as part of that chemical's infrastructure.
(chromium VI compounds: 0.1; chromium III com-
pounds: 1.0)
Cobalt Compounds - (Category Code N096) - Includes
any unique chemical substance that contains cobalt as
part of that chemical's infrastructure. (1.0)
Copper Compounds - (Category Code N100) -
Includes any unique chemical substance that contains
copper as part of that chemical's infrastructure. (1.0)
This category does not include:
Chemical CAS Number
C.I. Pigment Blue 15 147-14-8
C.I. Pigment Green 7 1328-53-6
C.I. Pigment Green 36 14302-13-7
Cyanide Compounds - (Category Code N106) -
X* CM1 where X = H* or any other group where a
formal dissociation may occur. For example, KCN or
Ca(CN)z. (1.0)
Glycol Ethers - (Category Code N230) - Includes
mono- and di- ethers of ethylene glycol, diethylene
glycol, and triethylene glycol. (1.0)
R-(OCH2CH2)n-OR'
R = alkyl or aryl groups
R'= R, H, or groups which, when
removed, yield glycol ethers with the
structure:
R-(OCH2CH2)n-OH
Polymers are excluded from this category.
Lead Compounds - (Category Code N420) - Includes
any unique chemical substance that contains lead as
part of that chemical's infrastructure. (Inorganic
compounds: 0.1; organic compounds: 1.0)
Manganese Compounds - (Category Code N450) -
Includes any unique chemical substance that contains
manganese as part of that chemical's infrastructure.
(1.0)
Mercury Compounds - (Category Code N458) -
Includes any unique chemical substance that contains
mercury as part of that chemical's infrastructure. (1.0)
Nickel Compounds - (Category Code N495) - Includes
any unique chemical substance that contains nickel as
part of that chemical's infrastructure. (0.1)
Polybrominated Biphenyls (PBBs) - (Category Code
N575) - (0.1)
where x = 1 to 10
Selenium Compounds - (Category Code N725) -
Includes any unique chemical substance that contains
selenium as part of that chemical's infrastructure. (1.0)
Silver Compounds - (Category Code N740) - Includes
any unique chemical substance that contains silver as
part of that chemical's infrastructure. (1.0)
Thallium Compounds - (Category Code N760) -
Includes any unique chemical substance that contains
thallium as part of that chemical's infrastructure. (1.0)
Zinc Compounds - (Category Code N982) - Includes
any unique chemical substance that contains zinc as
part of that chemical's infrastructure. (1.0)
H-12 Table II
*C.I.means "Color Index"
-------
TABLE III. STATE ABBREVIATIONS
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Commonwealth of the Northern
Mariana Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Teninessee
Texas
Utah
Vermont
Virginia
, Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MT
ME
NV
NH
NJ
NM
NY
NC
ND
MP
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY
Table III ffl-1
-------
-------
APPENDIX A. BLANK TOXIC CHEMICAL RELEASE
INVENTORY REPORTING FORM R
Appendix A A-l
-------
Public Reporting Burden
PubUcreportingburdenfor this collection of information is estimated to average 43 hours per
response, includng time for reviewing instructions, searching existing data sources, gathering
andmaintainingthe dataneeded, and completing and reviewing the collection of information.
Send comments regarding this burden estimate or any other aspect of this collection of
information, including suggestions for reducing this burden, to Chief, Information Policy
Branch (PM-223),U.S.EPA,401MStreet,SW,Washington,D.C.20460,Attention:TRIBurden,
and to the Office of Information and Regulatory Affairs, Office of Management and Budget
Paperwork Reduction Project (2070-0093), Washington, D.C. 20603.
A-2 Appendix A
-------
(IMPORTANT: Type or print; read Instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 11/92 Page 1 of 9
— *J^
TOXIC CHEMICAL RELEASE
,, . w . . INVENTORY REPORTING FORM
United States
Environmental Protection Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986,
Agen°y also known as Title III of the Superfund Amendments and Reauthorization Act
TRI FACILITY ID NUMBER
Toxic Chemical, Category, or Generic Name
WHERE TO SEND 1- EPCRA Reporting Center
COMPLETED FORMS: Washington. DC 20026-3779
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
IMPORTANT: See instructions to determine when "Not
Applicable (NA)" boxes should be checked.
Enter IC'bep if.
this is a revision
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1.
REPORTING
YEAR
19
SECTION 2. TRADE SECRET INFORMATION
Are you claiming the toxic chemical identified on page 3 trade secret?
Yes (Answer question 2.2;
Attach substantiation forms)
No (Do not answer 2.2;
Go to Section 3)
If yes in 2.1, is this copy: | [ Sanitized
Unsanitized
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
1 hereby certify that 1 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.
NameajKiofflcialiitleofownifr/operator or senior management officfet | ~
Signature
Date Signed
SECTION 4. FACILITY IDENTIFICATION
^ -;; v Facility or Estapfehrnent Name j ^fWfii^PNfirnrlwl
;*V4£:
,# ,.,\ v 'X Street Addressi||
> "?;5~ <
^:;,^LJ
-\ * x i%% Sta<& 1
:",c\ -Vfv. Mailing Address (Jtdifferentfromsfreetaddress) ]
; "x, *% -.^
^^i^-1
'yV^v.Stete |
:iSSfflifcsi
-------
-------
^EPA EPA FORM R
Protection PART 1. FACILITY IDENTIFICATIOI
A9ency INFORMATION (CONTINUED)
TRI FACILITY ID NUMBER
^ Toxic Chemical. Category, or Generic Name
SECTION 4. FACILITY IDENTIFICATION (Continued)
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9
4JO
This report contains information for;
(Important: check only one)
Technica
Public C(
Name
I Contact '
Name
>ntact '
SIC Code
(4-digit)
Latitude
and
Longitud
s • Degrees ,
e
Latitude
Minutes
Dun & Bradstreet Number(s) (9 digi
a. An entire facility
•
c. d.
Seconds Degrees
1
ts) ' * a-
r - b.
EPA Identification Number(s) (RCRA I.D. No.) a-
(12 characters)
* - b.
Facility NPDES Permit Number(s)
; (9 characters)
Underground Injection Well Code (UK
Number(s) s(12ti
= . a.
• , b.
D) I.D. a.
ligits)
b.
'
b. Part of a facility
Telephone Number (include area code)
Telephone Number (include area code)
e. f.
Longitude .. -
Minutes Seconds
SECTIONS. PARENT COMPANY INFORMATION
5.1
5.2
Name o| Parent, Company -;: ~ — ~
DMA
Parent Company's Dun & Bradstreet Number
DNA
(9 digits)
EPA Form 9350-1 (Rev. 5/14/92) - Previous editions are obsolete.
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Page 3 of 9
EPA
United States
Environmental Protection
Agency
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION
TRI FACILITY ID NUMBER
Toxic Chemical, Category, or Generic Name
SECTION 1 . TOXIC CHEMICAL IDENTITY (Important: DO NOT complete this
section if you complete Section 2 below.)
\% * ^"" f
*M-
PAS watroer (important; Enter only wroroipwexaotly as (tappeat&oi) the Section &13 H entetcaftgo'iy code if reporting & chemical category.) <
Toxic Ghernkal or Chemical Catagoiy Name {Important: Enter ontyone namaexacilyasttappearsonfteSecttoiiSiaJisl}
!
.Generic Chemical Name
(Important: Cotnpteledftly if Part I, Sect(o&2,l Jschecked^es," Generic Name must fae structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (lmP?rta.nt: DO NOT complete this
section if you complete Section 1 above.)
% <•* V° \ ^ ^
•rf s^ •• » A->
i..r: ;." -f.
Generic Chetftlca! Name Provided by Setter {Important: Maximum of TOcharacters, Including numbemjetfers, spaces, and ptmctuatlotu)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
r|f?
\::i,\t;^
IS
•• •-<• C1 \~- 5 ^
% "**»N '•-^V
;„ \^
•~thetbxleK?< *r
?£&%*$
^^^|Sc;
r^ptiterwisi^u^r^
; the toxics;^ \s^r-s
^_i lij MM ,^ - "- 1
If produce or imoort:
a. 1
Produce c.
b. | J Import d.
iB
a.D
b.n
e.
f.
For on-site use/processing
For sale/distribution
As a byproduct
As an impurity
As a reactant c. | | As an article component
As a formulation component d. | | Repackaging
As a chemical processing aid c. [
As a manufacturing aid
1 Ancillary or other use
SECTI
f>1 ;\
•'"Vs% \
ON 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE AT ANY TIME
DURING THE CALENDAR YEAR
(Enter two-digit code from instruction package.)
Ill
mm
m
w
MUM
l«
If!
*
EPA Form 9350-1(Rev. 5/14/92) - Previous editions are obsolete.
-------
-------
Protection
Agency
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
Page 4 of 9
TRI FACILITY ID NUMBER
Toxic Chemical, Category, or Generic Name
SECTION 5. RELEASES OF THE TOXIC CHEMICAL TO THE ENVIRONMENT ON-SITE
5-1
5.2
5.3
Fugitive or non-point air
emissions : V
Stack or point air
emissions
NA
NA
Discharges to receiving
streams or water bodies
1 (enter one name per box) :
5,3.1 Stream or Water Body Name
5:3:.211Sirearn^^
5.3.3 Stream or Water Body Name
5.4
5.5
5.5.1
5.5.2
5.5.3
5.5.4
Underground injections
on-site
| |NA
Releases to land on-site
Landfill
Land treatment/
application farming
Surface impoundment
Other disposal
NA
NA
| NA
| |NA
A. Total Release (pounds/
year) (enter range code from
instructions or estimate)
B. Basis of
Estimate
(enter code)
>": ", ,*', \> '"'"-""- ^* ', ^ -'' '' ,>Y ' y> " v^ >;^c^
. V f~ f ., \% •" s ' s' \ * '^ % "•" ^ * \*$ J S°° "• f f f-,
* % *' ' 'v'f^' ff^ ^ *. *""" "^ji % S fv'.ff "^ "^ '"''* ^ v"v "" "•f A
^S^^i^^llffi^
,
i
C. % From
Stormwater
^ ""„;" -;'?' y, -'.
"*N •> *f "" J f f f"
" -,\-" , '*- "- ''*"''<
Check here only if additional Section 5.3 information is provided on page 5 of this form.
EPA Form 9350-1 (Rev. 5/14/92) - Previous editions are obsolete.
Range C°deS: { 1 so 1 1 ' 4" P°UndS;
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Page 5 of 9
wEPA
United States
Environmental Protection
Agency
EPA FC
PART II. CHEMI
INFORMATION
i
>RM R
CAL-SPECIFIC ^
(CONTINUED)
mi FACILITY ID NUMBER
'oxic Chemical, Category, or Generic Name
SECTION 5.3 ADDITIONAL INFORMATION ON RELEASES OF THE TOXIC CHEMICAL TO THE
ENVIRONMENT ON-S1TE
,,,, Discharges to receiving A. Totaj Release (pounds/ B. Bas
5.3' Streams br water bodies year) '(enter range code from Est
- --'" '(enter one name per box) ' instructions or estimate) (ent
5.3._ls , Stream or Water Body Name
;5.3. Stream or Water Body Name
5.3. Stream or Water Body Name
SECTION 6. TRANSFERS
is of C. % From
imate Stormwater
sr code)
OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS
(POTW)
6.1 .A Total Quantity Transferred to POTWs and Basis of Estimate
6,1 Jt 1 .." total Transfers (pounds/year)
/ ;"' ^(enter range, code or estimate)
6.1. B POTW Name and Location Information
^ ^ „ POTW Name |
6.1. B.
Street Address *
cay-J
Slate'l"'!
County
Zip Code
6,1 ,Al2 Basis of Estimate
(enter code) s „„ \, ,
.. - - - - .
•. t. ^-. s •. s s •.
^L ,-, * POTW Name
G.I.B.
Street Address |
City |
Stale |
ilounty" 1
ZiflPode
If additional pages of Part II, Sections 5.3 and/or 6.1 are attached; indicate the total number of
pages in this box
and indicate which Part II; Sections 5.3/6,1 page this is, here.
, , , - (example: 1,2,3; etc.), s ,,,,, !?\
EPA Form 9350-1 (Rev. 5/14/92) - Previous editions are obsolete.
Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds;
C = 500 - 999 pounds.
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Page 6 of 9
4^ EPA EPA FORM R
i~™ yg&fisitiatf^
TRI FACILITY ID NUMBER
Toxic Chemical, Category, or Generic Name
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
^ „ * Off-site EPA Identification Number (RCRA ID No.) |
O.Z. __ :
- Qff^Site Location Name |
iKeiiftJress , •
City;\j
State \ Zip Code |
A. total Transfers (pounds/year) " '
; {enter range cods or estimate)
1.
2.
3.
4.
County -|
Is location under control of reporting r— -i i 1
facility or parent company? | | Yes | | No
J3«, Basis of Estimate
sv Center ?ode> \ - , ; , "\V;
1.
2.
3.
4.
C,>Typeof Waste treatment/Disposal? \
" Recycl ng^nergyRecbveiytsntec cotfe} ' v *
1. M
2. M
3. M
4. M
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
^ Off-site EPA Identification Number (RCRA'IDNo.)!
o.2.»t — , -••
Olf-site Locatron Name" 1
Street Address \ |
City |
s'ate -1 fipliiSsilil
A. total Transfers (pounds/year)^ >,* \ x, !-- "
5^{6ftterrarige"6Cid6ofestima(e|\^« , ^ -"
^..> ^.v^..x .v .*% j.« « •.;.\^ ....\....
1.
2.
3.
4.
i
County:^)
Is location under control of reporting i — i i 1
facility or parent company? | | Yes | | No
e.BasfeoifEstfmate -* ••""-••'•- -* -: \^\\/
leWersodej ,-;_ Vs^5 ,
1.
2.
3.
4.
C,:TypVof. Waste TfealmenVDisposaiA-
\ , Recycling/Energy Recovery {enteredde}^ %, ;v
1. M
2. M
3. M
4. M
If additional pages of Part II, Section 6.2 are attached, indicate the total number of pages in this
b°* CH and indicate which Part ir» Section 6,2 page this fs, here, f~~
EPA Form 9350-1 (Rev. 5/14/92) - Previous editions are obsolete.
Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds;
C = 500-999 pounds.
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Page 7 of 9
EPA FORM R
Protection PART II. CHEMICAL-SPECIFIC
Agency INFORMATION (CONTINUED)
TRI FACILITY ID NUMBER
Toxic Chemical, Category, or Generic Name
If additional copies of page 7 are attached, indicate the total number of pages in this
box
and indicate which page 7 this is, here.
(example: 1,2,3, etc.)
EPA Form 9350-1 (Rev. 5/14/92) - Previous editions are obsolete.
-------
-------
EPA FORM R
Protection PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
Page 8 of 9
TRI FACILITY ID NUMBER
Toxic Chemical, Category, or Generic Name
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
Not Applicable (NA) - Check here if no on-site energy recovery is applied to any waste
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)]
SECTION 7C. ON-SITE
Q Not Applicable (N
Recycling Methods [enter 3-characte
1
6
E RECYCLING PROCESSES
A) - Check here if no on-site recycling is
stream containing the toxic chemica
r code(s)]
2 34
789
applied to any waste
or chemical category.
5
10
EPA Form 9350-1 (Rev. 5/14/92) - Previous editions are obsolete.
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Page 9 of 9
United States
Environmental Protection
Agency
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
TRI FACILITY ID NUMBER
Chemical, Category, or Generic Name
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
All quantity estimates can be reported
using up to two significant figures.
8,1
8-2
8.3
8.4
8,5
8.6
8-7
8.8
8.9
8-10
Quantity released *
^ ^ ^
Quantity used for energy
recovery on-site
Quantity used for energy
recovery off-site,
Quantity recycled on-site
Quantity recycled off-site
Quantity treated on-site
Quantity treated off-site
Column A
1990
(pounds/year)
Column B
: 1991
; (pounds/year)
Column C
1992
(pounds/year)
Quantity released to the environment as a result of
remedial actions, catastrophic events, or one-time events
riot associated with production processes (pbunds/year)
Production ratio or activity index , !
Column D
1993
(pounds/year)
Did your faqility engage in any source reduction activities for this chemical during
the reporting year? If not, enter "NA" in Section 8.10.1 and answer Section 8.11.
Source Reduction Activities ..* .. ; * - , * ' , s ,
[enter code(s)] " , - " ' Methods to Jdentify Activity (enter codes) /
8.10.1
8.10.2
8.10,3
a.
8.10.4 _
dm
,8,11
b.
b.
b.
b.
C.
C.
C.
c.
Is additional optional information on source reduction, recycling, or
pollution control activities included with this report? (Check one box)
YES NO
I I
* •mtPr?inneoCa^ P1"?"3"*.10 EPCRA Section 329(8) jncluding "any spilling, leaking, pumping, pouring, emitting, emptying, discharging
injecting, escaping, leaching, dumping, or disposing into the environment." Do not include any quantity treated on-site or off-site.
EPA Form 9350 -1 (Rev. 5/14/92) - Previous editions are obsolete.
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-------
APPENDIX B. REPORTING CODES FOR EPA FORM R
Part H, Section 1.1 - CAS Number
Toxic Chemical Category Codes
N010 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Berylium compounds
N078 Cadmium compounds
N084 Clorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N230 Glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N575 Polybrominated biphenyls (PBBs)
N725 Selenium compounds
N740 Silver compounds
N760 Thallium compounds
N982 Zinc compounds
Part n, Section 4 - Maximum Amount of the Toxic
Chemical On-Site at Any Time During the Calendar
Year
Weight Range in Pounds
Range Code From...
To....
01
02
03
04
05
06
07
08
09
10
11
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
Part n, Section 5 - Releases of the Toxic Chemical to
the Environment On-Site and Part II, Section 6 -
Transfers of the Toxic Chemical in Waste Streams to
Off-Site Locations
Total Release or Transfer
Code
A
- B
C
Basis of Estimate
Range (Ibs)
1-10
11-499
500-999
M: ; Estimate is based on monitoring data or mea-
surements for the toxic chemical as transferred
to an off-site facility.
C: ! Estimate is based on mass balance calculations,
such as calculation of the amount of the toxic
; chemical in waste streams entering and leaving
process equipment.
E: Estimate is based on published emission factors,
such as those relatingreleasequantiry to through-
put or equipment type (e.g., air emission fac-
tors).
O: Estimate is based on other approaches such as
engineering calculations (e.g., estimating vola-
tilization using published mathematical formu-
las or best engineering judgment. This would
indudeapplyinganestimatedremovalefficiency
i to a waste stream, even if the composition of the
waste stream before treatment was fully charac-
terized by monitoring data.
Part n, Section 6 - Transfers of the Toxic Chemical in
Waste Streams to Off-Site Locations
Type of Waste Treatment/Disposal /Recycling/Energy
Recovery
M10 Storage Only
M20 Solvents/Organics Recovery
M24 Metals Recovery
M26 Other Reuse or Recovery
M28 Acid Regeneration
M40 Solidification/Stabilization
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M56 Energy Recovery
Appendix B B-l
-------
M61 Wastewater Treatment (Excluding POTW)
M69 Other Waste Treatment
M71 Underground Injection
M72 Landfill/Disposal Surface Impoundment
M73 Land Treatment
M79 Other Land Disposal
M90 Other Off-Site Management
M91 Transfer to Waste Broker
M92 Transfer to Waste Broker — Energy Recovery
M93 Transfer to Waste Broker - Recycling
M94 Transfer to Waste Broker - Disposal
M95 Transfer to Waste Broker - Waste Treatment
M99 Unknown
Federal Information Processing Standards (FTPS)
Codes for Transfers of the Toxic Chemical to Other
Countries
This is an abridged list of countires to which a U.S.
facility might ship a listed toxic chemical. For a
complete listing of FIPS codes, consult your local
library.
Country Code
Argentina AR
Belgium BE
Bolivia BL
Brazil BR
Canada CA
Chile CI
Columbia CO
Costa Rica CS
Cuba CU
Ecuador EC
El Salvador ES
France FR
Guatemala GT
Honduras HO
Ireland El
Italy IT
Mexico MX
Nicaragua NU
Panama PM
Paraguay PA
Peru PE
Portugal PO
Spain SP
Switzerland SZ
United Kingdom UK
Uruguay UY
Venezuela VE
Part n, Section 7A - Waste Treatment Methods and
Efficiency
General Waste Stream
A Gaseous (gases, vapors, airborne particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and
slurries)
Waste Treatment Methods
Air Emissions Treatment
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitalor
A06 Mechanical Separation
A07 Other Air Emission Treatment
Biological Treatment
Bll Biological Treatment — Aerobic
B21 Biological Treatment — Anaerobic
B31 Biological Treatment — Facultative
B99 Biological Treatment — Other
Chemical Treatment
C01 Chemical Precipitation — Lime or Sodium
Hydroxide
C02 Chemical Precipitation - Sulfide
C09 Chemical Precipitation - Other
Cll Neutralization
C21 Chromium Reduction
C31 Complexed Metals Treatment (other than pH
Adjustment)
C41 Cyanide Oxidation — Alkaline Chlorination
C42 Cyanide Oxidation — Electrochemical
C43 Cyanide Oxidation — Other
C44 General Oxidation (including Disinfection) --
Chlorination
C45 General Oxidation (including Disinfection) -
Ozonation
C46 General Oxidation (including Disinfection) --
Other
C99 Other Chemical Treatment
B-2 Appendix B
-------
Incineration/Thermal Treatment
Range of Influent Concentration
F01 Liquid Injection
Fl 1 Rotary Kiln with Liquid Injection Unit
F19 Other Rotary Kiln
F31 Two Stage
F41 Fixed Hearth
F42 Multiple Hearth
F51 FluidizedBed
F61 Infra-Red
F71 Fume/Vapor
F81 Pyrolytic Destructor
F82 Wet Air Oxidation
F83 Thermal Drying/Dewatering
F99 Other Incineration/Thermal Treatment
Physical Treatment
P01 Equalization
P09 Other Blending
Pll Settling/Clarification
P12 Filtration
P13 Sludge Dewatering (non-thermal)
P14 Air Flotation
P15 Oil Skimming
P16 Emulsion Breaking - Thermal
PI 7 Emulsion Breaking — Chemical
P18 Emulsion Breaking — Other
P19 Other Liquid Phase Separation
P21 Adsorption — Carbon
P22 Adsorption — Ion Exchange (other than for
recovery/reuse)
P23 Adsorption— Resin
P29 Adsorption - Other
P31 Reverse Osmosis (other than for recovery/
reuse)
P41 Stripping — Air
P42 Stripping - Steam
P49 Stripping - Other
P51 Acid Leaching (other than for recovery/
reuse)
P61 Solvent Extraction (other than recovery/
reuse)
P99 Other Physical Treatment
Solidification/Stabilization
G01 Cement Processes (including Silicates)
G09 Other Pozzolonic Processes (including
Silicates)
Gil Asphaltic Processes
G21 Thermoplastic Techniques
G99 Other Solidification Processes
1 = Greater than 1 percent
2 = 100 parts per million (0.01 percent) to 1 percent
(10,000 parts per million)
3 = 1 part per million to 100 parts per million
4 = 1 part per billion to 1 part per million
5 = Less than 1 part per billion
[Note: Parts per million (ppm) is milligrams/kilogram
(mass/mass) for solids and liquids; cubic centimeters/
cubic meter (volume/volume) for gases; milligrams/
liter for solutions or dispersions of the chemical in
water; and milligrams of chemical/kilogram of air for
particulates in air. If you have particulate
concentrations (at standard temperature and pressure)
as grains/cubic foot of air, multiply by 1766.6 to
convert to parts per million; if in milligrams /cubic
meters, multiply by 0.773 to obtain parts per million.
Factors are for standard conditions of 0°C (32°F) and
760 rnmHg atmospheric pressure.]
Part H, Section 7B - On-Site Energy Recovery
Processes
U01', Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
U09 Other Energy Recovery Methods
Part H, Section 7C - On-Site Recycling Processes
Rll Solvents/Organics Recovery - Batch Still
Distillation
R12 Solvents/Organics Recovery — Thin-Film
Evaporation
R13 Solvents/Organics Recovery — Fractionation
R14 , Solvents/Organics Recovery - Solvent
Extraction
R19 Solvents/Organics Recovery — Other
R21 Metals Recovery — Electrolytic
R22 Metals Recovery - Ion Exchange
R23 Metals Recovery - Acid Leaching
R24 Metals Recovery — Reverse Osmosis
R26 j Metals Recovery — Solvent Extraction
R27 Metals Recovery — High Temperature
R28 Metals Recovery — Retorting
R29 Metals Recovery — Secondary Smelting
R30 • Metals Recovery - Other
R40 Acid Regneration
R99 Other Reuse or Recovery
Appendix B B-3
-------
Part n, Section 8.10 - Source Reduction Activity
Codes
Good Operating Practices
W13 Improved maintenance scheduling,
recordkeeping, or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W19 Other changes in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials
do not stay in inventory beyond shelf-life
W22 Began to test outdated material — continue to
use if still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labelling procedures
W25 Instituted clearinghouse to exchange materials
that would otherwise be discarded
W29 Other changes in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading, unloading,
and transfer operations
W33 Installed overflow alarms or automatic shut-
off valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring
program of potential spill or leak sources
W39 Other spill and leak prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications
Process Modifications
W51 Instituted recirculation within a process
W52 Modified equipment, layout, or piping
W53 Use of a different process catalyst
W54 Instituted better controls on operating bulk
containers to minimize discarding of empty
containers
W55 Changed from small volume containers to
bulk containers to minimize discarding of
empty containers
W58 Other process modifications
Cleaning and Degreasing
W59 Modified stripping/cleaning equipment
W60 Changed to mechanical stripping/cleaning
devices (from solvents or other materials)
W61 Changed to aqueous cleaners (from solvents
or other materials)
W63 Modified containment procedures for cleaning
units
W64 Improved draining procedures
W65 Redesigned parts racks to reduce dragout
W66 Modified or installed rinse systems
W67 Improved rinse equipment design
W68 Improved rinse equipment operation
W71 Other cleaning and degreasing modifications
Surface Preparation and Finishing
W72 Modified spray systems or equipment
W73 Substituted coating materials used
W74 Improved application techniques
W75 Changed from spray to other system
W78 Other surface preparation and finishing
modifications
Product Modifications
W81 Changed product specifications
W82 Modified design or composition
W83 Modified packaging
W89 Other .product modifications
B-4 Appendix B
-------
Part H, Section 8.10 - Methods Used to Identify
Source Reduction Activities
For each source reduction activity, enter up to three of
the following codes that correspond to the method(s)
used to identify that activity and contributed most to
the decision to implement that activity.
T01 Internal Pollution Prevention Opportunity
Audit(s)
T02 External Pollution Prevention Opportunity
Audit(s)
T03 Materials Balance Audits
T04 Participative Team Management
T05 Employee Recommendation (Independent of
Participative Team Program)
T06 State Government Technical Assistance
Program
T07 Federal Government Technical Assistance
Program
T08 Trade Association/Industry Technical
Assistance Program
T09 Vendor Assistance
T10 Other
Appendix B B-5
323-732 - 92 - 7 QI, 3
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-------
APPENDIX C. COMMON ERRORS IN COMPLETING
FORM R REPORTS
The common errors in complying with section 313 and completing Form R occur in three areas: Form R entry errors,
threshold determination errors, and release estimation errors. It is important to note that although the Pollution
Prevention Act of 1990 has greatly impacted the Form R, many of these common errors will still exist. These errors
may prevent the entering of information from Form Rs into the Toxic Release Inventory (TRI) database, or may result
in overly large or small release estimates or omission of reportable releases of toxic chemicals. If a mistake is made
on the Form R that prevents it from being entered into the TRI database, the facility owner/operator will be issued
a Notice of Non-Compliance by EPA. The notice will indicate that the Form R cannotbe further processed and entered
into the TRI database and that changes must be submitted to EPA by a certain date or further enforcement actions
will be taken.
For other errors, including missingpieces of information or erroneous data (e.g., missing certification signature, non-
numeric SIC codes), the facility owner/operator will be issued a Notice of Technical Error by EPA. This notice will
explain the nature of the error and will require that the corrections be returned to EPA by a certain date.
Through examining Form Rs from other facilities in the same industry or through federal, state, and local referrals,
EPA may initiate an inspection to determine the toxic chemical-related activities at a facility. If, as a result of the
inspection, EPA determines mat the facility should have submitted a Form R, then EPA may take enforcementaction
againstthe facility, which may involve the subsequent assessment of fines. Likewise, if EPA determines in the process
of the inspection that the facility incorrectly calculated a threshold determination, the facility may also be subject to
penalties.
Discussed below are common errors made when completing Form Rs and the corresponding notices and
enforcement actions that may result from these errors.
Form R Completion Errors
• Invalid chemical identification on page 3. The
CAS number and the chemical name reported on
page 3 must exactly match the listed section 313
CAS number and toxic chemical name. The toxic
chemical category code must exactly match the
listed category code in Appendix B. A generic
chemical name should only be provided if you
are claiming the section 313 chemical identity as
a trade secret. Toxic chemical names and CAS
numbers should be taken directly from the sec-
tion 313 toxic chemical list. Mixture names are to
be entered in Part n, Section 2 if the supplier is
claiming the identity of the toxic chemical trade
secret and that is the sole identification. Mixture
names that include the name or CAS number of
one or more section 313 toxic chemical(s) are not
valid. Failure to correctly enter the chemical
identification information will result in a Notice
of Non-Compliance.
• Missing certification signature. An original
certification signature must appear on page 1 of
every Form R submitted to EPA. Failure to
provide an original certification signature will
result in a Notice of Technical Error.
Incomplete forms. A complete Form R report
for any toxic chemical or toxic chemical category
consists of at least eight unique pages stapled
together. Sending in a package which contains
only one page 1, but several page 2's, 3's, 4's, 5's,
6's, etc. will result in a Notice of Non-Compli-
ance.
Maximum amount on-site left blank. In a
surprising number of Form R submissions, Part
n, Section 4 on page 3 is left blank. Leaving this
section blank may result in a Notice of Technical
Error.
"Questionable" entries, such as:
Missing or incorrect ZIP codes;
Missing county names;
Non-numeric SIC codes;
Non-numeric or invalid Dun and
Bradstreet numbers;
Incomplete off-site and POTW
information (e.g., missing city name)
Incorrect entries such as these may result in a
Notice of Technical Error. If amounts are re-
ported in units other than pounds (e.g., metric)
Appendix C C-l
-------
or with exponential numbers, EPA may require •
a revision of the Form R to be submitted.
Incorrect latitude and longitude coordinates.
Latitude and longitude coordinates are impor-
tantdataontheFormR. These coordinates must
be determined using the correct map and correct
measuring techniques and reported in degrees,
minutes, and seconds. For additional guidance,
see Appendix E of the instructions document.
Missing, suspect, or incorrect latitude or longi-
tude coordinates will result in a Notice of Tech-
nical Error. •
Incorrect completion of trade secret informa-
tion. The response to trade secret questions in
Part I and Partn of a Form R must be consistent.
If trade secrecy is indicated, a sanitized Form R
and two trade secret substantiations (one sani-
tized) must be submitted in the same package as
the trade secret Form R. Failure to provide
complete trade secret submissions will result in
a Notice of Non-Compliance. •
Revisions not identified. Revisions to previ-
ously submitted data may be provided to EPA
by making corrections in red ink on a copy of the
Form R originally submitted; if a revision is
made for reporting year 1991 information, mark
an"X"inthespacemarked"Enter"X"hereifmis •
is a revision" on page 1; provide an original
signature, and send it to the EPCRA Reporting
Center. Youmustalsosendacopyoftherevision
to theappropriateStateagency. Failure to clearly
identify a revision may result in EPA entering it
into the TRI database as a new submission result-
ing in duplicative data for the facility. Revisions
to data submitted usingmagnetic media mustbe
made on hard copies of the original Form R and
submitted with a cover letter explaining that the •
original data was submitted on magnetic media.
Duplicate submissions not identified. Facili-
ties sometimes send multiple copies of the same
Form R to insure that EPA received a copy. O
Duplicate submissions must be identified by
printing the word "DUPLICATE" in red ink at
the top of page 1. Failure to clearly identify a
duplicate report may result in the duplicate
appearance of the data in the TRI database.
Failure to report waste treatment. Waste treat-
ment methods used to treat waste streams con-
taining toxic chemicals, and the efficiencies of
these methods, must be reported on Form R.
Informationmustbeenteredforallwastestreams,
even if the waste treatment does not affect the
toxic chemical. If no waste treatment is per-
formed on the toxic chemical, the box marked
"Not Applicable" in Part H, Section 7 must be
checked on the Form R. Failure to do so may
result in a Notice of Technical Error.
Incorrect reporting of waste treatment meth-
ods. The type of waste stream, influent concen-
tration, and waste treatment method for each
waste stream is required to be reported on Form
R using specific codes, along with the waste
treatment efficiency expressed as percent re-
moval. Incomplete or missing treatment codes
or missing efficiency data may result in a Notice
of Technical Error.
Reporting for delisted chemicals. Form R re-
ports for delisted chemicals or other non-listed
chemicals are not required. EPA identifies such
reports as nonreportable and notifies the facility
that these reports are not required and willnotbe
included as part of the TRI database.
Reporting discharges of mineral acids after
neutralization. Whena waste stream containing
a mineral acid is neutralized to a pH of 6 or
above, the mineral acid is considered 100 percent
neutralized. As a result, the release of a neutral-
ized acid discharge should be reported on Form
R as zero. Reporting a large amount of neutral-
ized acid as a release may result in a Notice of
Technical Error.
Not completing all sections of Form R. All
sections of Form R must contain data or "NA".
Failure to complete any section may result in a
Notice of Technical Error.
Duplicate data in Part II, Sections 5 and Part II,
Section 6. Reporting identical values as a dis-
charge to a receiving stream in Part II, Section5.3
and as a transfer to a POTW in Part II, Section 6.1
is interpreted by EPA as duplicative data and
may result in a Notice of Technical Error.
C-2 Appendix C
-------
Documentation. Any information used to com-
plete the Form R must be clearly documented in
facility records and be available for viewing by
EPA upon request. Failure to provide proper
documentation if requested by EPA may result
in an enforcement action. This documentation
should not be submitted with the Form R, but
mustbe maintained by the submitting facility for
three years.
Toxic chemical activity overlooked. Many fa-
cilities believe that because the section 313 re-
porting requirement pertains to manufacturers,
only the use of toxic chemicals in manufacturing
processes must be examined. Any activity in-
volving the manufacture, process, or otherwise
use of a listed toxic chemical mustbe included in
a threshold determination. For example, waste
treatment operations otherwise use toxic chemi-
cals to treat waste streams and may coinciden-
tally manufacture another listed toxic chemical
as a result of the waste treatment reaction. Fail-
ure to correctly identify all uses of toxic chemi-
cals at your facility may result in the omission of
a required Form R and may lead to an enforce-
ment action.
Misclassification of a toxic chemical activity.
Failure to correctly classify a toxic chemical
activity may result in an incorrect threshold
determination. As a result, a Form R may not be
submitted whenoneis required. "Manufacture"
means to produce, prepare, compound, or im-
porta listed toxic chemical. "Process" means the
preparation of a listed toxic chemical after its
manufacture, which incorporates the toxic chemi-
cal into the final product, for distribution in
commerce. "Otherwise use" encompasses any
use of a listed toxic chemical that does not fall
under the terms "manufacture" or "process."
For example, solvents in paint applied to a manu-
factured product are often misclassified as pro-
cessed, instead of otherwise used. Because the
solvents are not intentionally incorporated into
the final product, the solvent is being otherwise
used, not processed. Failure to submit a Form R
because of an incorrect threshold determination
resultingfromairdsclassificationofatoxicchemi-
cal activity may result in an enforcement action.
Incorrect interpretation of an exemption clause.
Only toxic chemicals meeting every condition of
an exemption clause may be omitted from the
reporting requirements. For additional guid-
ance on the scope of the section 313 exemptions
and specific examples, see the Toxic Chemical
Release Inventory Questions and Answers docu-
ment, which includes "Directive #1: Article
Exemption." For example, only the processing
or otherwise using an article is exempt. Incor-
rectly assuming the manufacture of an article is
exempt will result in incorrectly omitting toxic
chemicals which are required to be included in a
threshold determination. Failure to submit a
Form R due to an incorrect threshold determina-
tion resulting from the incorrect interpretation
of an exemption clause may result in an enforce-
ment action.
Misinterpretation of the toxic chemical list.
Each toxic chemical subject to section 313 report-
ing requirements has a specific Chemical Ab-
stract Service (CAS) registry number associated
with it. All information available at the facility,
such as MSDSs and the Common Synonyms for
Section 313 Chemicals document, must be used to
identify the listed toxic chemicals being reported.
Failure to consider alisted toxic chemical quali-
fier. Aluminum, vanadium, and zinc are quali-
fied as "fume or dust." Isopropyl alcohol and
saccharin have manufacturing qualifiers. Am-
monium nitrate and ammonium sulfate are quali-
fied as solutions. Phosphorus is qualified as
yellow or white. Asbestos is qualified as friable.
Aluminum oxide is qualified as fibrous forms.
Only forms of these toxic chemicals meeting the
qualifiers require reporting under section 313
and should be reported on Form R with the
appropriate qualifier in parentheses. For ex-
ample, isopropyl alcohol is listed on the toxic
chemical list with the qualifier "manufacturing-
strong acid process, no supplier notification."
The only facilities that should be reporting this
toxic chemical are those that manufacture iso-
propyl alcohol by the strong acid process. If it is
manufactured by another process, or simply
processed or otherwise used, you are not re-
quired to report it.
Appendix C C-3
-------
Incorrectly interpreting threshold definition. •
Thresholds for section 313 are based on the
amount of toxic chemicals manufactured, pro-
cessed, or otherwise used at the facility over the
course of a calendar year. The thresholds are not
based on the amount stored on-site at any one
time or the amount released to the environment.
Any toxic chemical that is reported that did not
exceed a threshold will resultin a Notice of Non-
Compliance. Any toxic chemical that was not
reported due to an incorrect threshold determi-
nation (i.e.,based on theamountreleased), which
should have been reported, may result in an
enforcement action.
Reportmgzero air emissions of a VOC. Volatile
organic chemicals (VOCs) are substances which
readily evaporate at room temperature. As a
result, when using these toxic chemicals in an
open tank,a painting or degreasing operation, or
similar open operations, air emissions will oc-
cur. Only in special cases with completely closed
systems may a zero emission to air occur. Failure
to report air emissions when submitting a Form
R for a VOC may result in underreporting of
releases.
G4 Appendix C
-------
APPENDIX D. SUPPLIER
REQUIREMENTS
Because manufacturers reporting under section313 must
know the toxic chemical composition of the products
they use to be able to accurately calculate releases, EPA
requires some suppliers of mixtures or trade name prod-
ucts containing one or more of the listed section313 toxic
chemicals to notify their customers. This requirement
has been in effect since January 1,1989.
This appendix explains which suppliers mustnotify their
customers, who must be notified, what form the notice
must take, and when it must be sent.
Who Must Supply Notification
You are covered by the section 313 supplier notification
requirements if you own or operate a facility which meets
all of the following criteria:
(1) Your facility is in Standard Industrial Classifica-
tion (SIC) codes 20-39 (see Table I);
(2) You manufacture, import, or process a listed
toxic chemical; and
(3) You sell or otherwise distribute a mixture or
trade name product containing the toxic chemi-
cal to either:
A facility in SIC Codes 20-39.
A facility that then sells the same mix-
ture or trade name product to a firm in
SIC codes 20-39.
Note that you may be covered by the supplier notifica-
tion rules even if you are not covered by the section 313
release reporting requirements. For example, even if
you have less than 10 full-time employees or do not
manufacture or process any of the toxic chemicals in
sufficient quantities to trigger the release reporting re-
quirements, you may still be required to notify certain
customers.
Who Must Be Notified
For each mixture or trade name product that contains a
listed toxic chemical, you will have to notify all custom-
ers in SIC codes 20-39 or distributors who in turn sell that
product to facilities in SIC codes 20-39. Unless you know
otherwise, you should assume that the chain of distribu-
tion includes facilities in SIC codes 20-39. (The notifica-
tion is limited to SIC codes 20-39 facilities and their
suppliers because only facilities in those SIC codes may
be required to report releases under section 313.)
An example would be if you sold a lacquer containing
toluene to distributors who then sell the product to other
manufacturers. The distributors are not in SIC codes 20-
39, but because they sell the product to companies in SIC
codes 20-39, they must be notified so that they may pass
the notice along to their customers, as required.
The language of the supplier notification requirements
covers mixtures or trade name products that are sold or
otherwise distributed. The "otherwise distributes" lan-
guage applies to intra-company transfers. However, if
the company has developed an internal communications
procedure that alerts their other facilities to the presence
and content of covered toxic chemicals in their products,
then EPA would accept this.
Supplier notification is also required if a waste mixture
containing a toxic chemical is sold to a recycling or
recovery facility. However, if the material is sent off-site
as a waste stream for treatment or disposal, then no
supplier notification is required.
Supplier Notification Must Include the
Following Information:
(1) A statement that the mixture or trade name
product contains a toxic chemical or chemicals
subject to the reporting requirements of EPCRA
section 313 (40 CFR 372);
(2) The name of each toxic chemical and the associ-
ated Chemical Abstracts Service (CAS) registry
number of each chemical if applicable. (CAS
numbers are not used for chemical categories,
since they can represent several individual toxic
chemicals.)
(3) The percentage, by weight, of each toxic chemi-
cal (or all toxic chemicals within a listed cat-
egory) contained in the mixture or trade name
product.
For example, if a mixture contains a chemical (i.e., 12
percentzinc oxide) that is a member of a reportable toxic
chemical category (i.e., zinc compounds), thenotification
must include that the mixture contains a zinc compound
at 12 percent by weight. Supplying only the weight
Appendix D D-l
-------
percent of the parent metal (zinc) does not fulfill the (2)
requirement. The customer must be told the weight
percent of the entire compound within a -listed toxic
chemical category present in the mixture.
Discover that your previous notification did not
properly identify the toxic chemicals in the mix-
ture or correctly indicate the percentage by
weight.
How the Notification Must Be Made
The required notification must be provided at least
annually in writing. Acceptable forms of notice include
letters/ product labeling, and product literature distrib-
uted to customers. If you are required to prepare and
distribute a Material Safety Data Sheet (MSDS) for the
mixture under the Occupational Safely and Health Act
(OSHA) Hazard Communication Standard, your section
313 notification must be attached to the MSDS or the
MSDS mustbe modified to include the required informa-
tion. (A sample letter and recommended text for inclu-
sion in an MSDS appear at the end of this appendix.)
You must make it dear to your customers that any copies
or redistribution of the MSDS or other form of notifica-
tion must include the section 313 notice. In other words,
your customers should understand their requirement to
include the section 313 notification if they give your
MSDS to their customers.
When Notification Must Be Provided
In general, you must notify each customer receiving a
mixture or trade name product containing a listed toxic
chemical with the first shipment of each calendar year.
You may send the notice with subsequent shipments as
well, but it is required that you send it with the first
shipment each year. Once customers have been pro-
vided with an MSDS containing the section313 informa-
tion, you may refer to the MSDS by a written letter in
subsequent years (as long as the MSDS is current).
If EPA adds toxic chemicals to the section 313 list, and
your products contain the newly listed toxic chemicals,
notify your customers with the first shipment made
during the next calendar year following EPA's final
decision to add the chemical to the list. For example, if
EPA adds chemical ABC to the list in September 1990,
supplier notification for chemical ABC would have be-
gun with the first shipment in 1991.
You mustsend a new or revised notice to your customers
if you:
(1) Change a mixture or trade name product by
adding, removing, or changing the percentage
by weight of a listed toxic chemical.
fa these easesr you must: r
(1) Supply a new or revised notification within 30
days of a change in the product or the discovery
of misidentified toxic chemical(s) in the mixture
or incorrect percentages by weight; and
(2) Identify in the notification the prior shipments of
the mixture or product in that calendar year to
which the new notification applies (e.g., if the
revised notification is made on August 12, indi-
cate which shipments were affected during the
period January 1 - August 12).
When Notifications Are Not Required
Supplier notification is not required for a "pure" toxic
chemical unless a trade name is used. The identity of the
toxic chemical will be known based on label information.
You are not required to make a "negative declaration."
That is, you are not required to indicate that a product
contains no section 313 toxic chemicals.
If your mixture or trade name product contains one of the
listed toxic chemicals, you are not required to notify your
customers if:
(1) Your mixture or trade name product contains
the toxic chemical in percentages by weight of
less than the following levels (These are known
as de minimis levels):
0.1 percent if the toxic chemical is de-
fined as an "OSHA carcinogen";
1 percent for other toxic chemicals.
De minimis levels for each toxic chemical and
chemical category are listed Table II.
(2) Your mixture or trade name product is one of the
following:
An article that does not release a listed
toxic chemical under normal conditions
of processing or otherwise use.
D-2 Appendix D
-------
(3)
Foods, drugs, cosmetics, pesticides, alco-
holic beverages, tobacco, or tobacco
products packaged for distribution to
the general public.
Any consumer product, as the term is
denned in the Consumer ProductSafety
Act, packaged for distribution to the
general public. For example, if you mix
or package one-gallon cans of paint de-
signed for use by the general public,
notification is not required.
Your mixture or trade name product is con-
tained in a waste stream being sent off-site for
waste treatment or disposal.
Trade Secrets
Chemical suppliers may consider the chemical name or
the specific concentration of a section 313 toxic chemical
in a mixture or trade name product to be a trade secret.
If you consider the:
(1) Specific identity of a toxic chemical to be a trade
secret, the notice mustcontain agenericchemical
name that is descriptive of the structure of that
toxicchemical.Forexample,decabromodiphenyl
oxide could be described as a halogenated aro-
matic.
(2) Specific percentage by weightof a toxicchemical
in the mixture or trade name product to be a
trade secret, your notice must contain a state-
ment that the toxic chemical is present at a
concentration that does not exceed a specified
upperbound. For example, if a mixture contains
12 percent toluene and you consider the percent-
age a trade secret, the notification may state that
the mixture contains toluene at no more than 15
percent by weight. The upper bound value
chosen must be no larger than necessary to
adequately protect the trade secret.
If you claim this information to be trade secret, you must
have documentation that provides the basis for your
claim.
Recordkeeping Requirements
You are required to keep records for three years of the
following:
(1) Notifications sent to recipients of your mixture
; or trade name product;
(2) ; Explanations of why a notification was consid-
ered necessary and all supporting materials used
to develop the notice;
(3) If claiming a specific toxic chemical identity a
trade secret, why flue toxic chemical identity is
considered a trade secret and the appropriate-
ness of the generic chemical name provided in
the notification; and
(4) If claiminga specific concentration a trade secret,
explanations of why a specific concentration is
considered a trade secret and the basis for the
upper bound concentration limit.
This information mustbe readily available for inspection
by EPA.
Appendix D D-3
-------
Sample Notification Letter
January 2,1992
Mr. Edward Burke
Furniture Company of North Carolina
1000 Main Street
Anytown, North Carolina 99999
Dear Mr. Burke:
The purpose of this letter is to inform you that a product that we sell to you, Furniture Lacquer KXZ-
1390, contains 20 percent toluene (Chemical Abstracts Service (CAS) number 108-88-3) and 15 percent
zinc compounds. We are required to notify you of the presence of toluene and zinc compounds in the
product under section 313 of the Emergency Planning and Community Right-to-Know Act of 1986. This
law requires certain manufacturers to report on annual emissions of specified toxic chemicals and
chemical categories.
If you are unsure whether or not you are subject to the reporting requirements of Section 313, or need
more information, call EPA's Emergency Planning and Community Right-To-Know Information Hotline
at (800) 535-0202. Your other suppliers should also be notifying you if section 313 toxic chemicals are in
the mixtures and trade name products they sell to you.
Please also note mat if you repackage or otherwise redistribute this product to industrial customers, a
notice similar to this one should be sent to those customers.
Sincerely,
Axel Leaf
Sales Manager
Furniture Products
D-4 Appendix D
-------
Sample Notification on an MSDS
Section 313 Supplier Notification
This product contains the following toxic chemicals subject to the reporting requirements of
section 313 of the Emergency Planning and Community Right-To-Know Act of 1986 (40 CFR 372):
CAS#
108-88-3
NA
Chemical Name
Toluene
Zinc Compounds
Percent by Weight
20% i
15%
This information should be included in all MSDSs that are copied and distributed for this material.
Material Safety Data Sheet
I I
Appendix D D-5
-------
-------
APPENDIX E. HOW TO DETERMINE LATITUDE AND
LONGITUDE FROM TOPOGRAPHIC MAPS
Latitude and longitude coordinates of reporting facilities
are very important for pinpointing facility location and
are a required data element on Form R. As such, EPA is
encouraging facilities to make the best possible measure-
ments when determining latitude and longitude. As
with any other data element, missing, suspect, or incor-
rect data may result in EPA issuing a Notice of Technical
Error to the facility.
Latitude is the distance north or south of the equator.
Longitude is the distance east or west of the prime
meridian (Greenwich, England). Latitude and longitude
are measured in degrees, minutes, and seconds.
60" (seconds) = I1 (minute)
60' (minutes) = 1° (degree)
The most important tool available for determining lati-
tude and longitude for your facility is the U.S. Geological
Survey (USGS) topographic quadrangle map. These
maps are published in varying degrees of detail. The
most detailed version of the topographic quadrangle
map is in 7.5 x 7.5 minute increments with a scale of
1:24000 (i.e., one inch on the map represents 2,000 feet).
Detailed topographic quadrangle maps are also avail-
able in 7.5 x 15 minute increments with a scale of 1:25000
(i.e., one inch on the map represents approximately four
miles). It is very important that latitude and longitude
measurements be made from one of the detailed maps
described above. Otherwise, measurements will not
accurately reflect the location of your facility and could
be identified as an error on your Form R submission.
In order to identify the detailed topographic quadrangle
map in which your facility is located, the USGS has
published an index and a catalog of topographic maps
available for each state. Both the index and the catalog
are available in many libraries or free of charge from the
Distribution Branch of the USGS (address on following
page). The Index to Topographic and Other Map Coverage
helps you to identify the most detailed map in which your
facility is located. To identify the most detailed map,
follow these simple steps on how to use the index:
(1) The beginning of each index contains a map of
the state, broken into numbered quadrangular
sections. The numbered quadrangular sections
are called general areas of interest. Identify the
numbered section in which your facility is lo-
cated.
(2) The subsequent pages of the index contain de-
tailed maps of each general area of interest, in
: numerical order. Identify the detailed map
corresponding to the numbered general area of
: interest identified in Step 1.
(3) Within this detailed map, identify the smaller
quadrangular area in which your facility is lo-
cated. This smaller quadrangular section is the
specific area of interest. Record first the letter
; then the number coordinate for your specific
area of interest (e.g., E4).
(4) Using the chart found on the same page as the
detailed map of the general area of interest,
\ record the name of the specific area of interest in
which your facility is located, identified by the
letter and number coordinates (e.g., Richmond).
The name of the specific area of interest and its corre-
sponding letter and number coordinates identify the
most detailed topographic quadrangle map in which
your facility is located. To identify the map reference
code and file number necessary to order this map, follow
these simple steps for using the Catalog ofTopographic and
Other Published Maps for the state in which your facility is
located:
(5) The beginning of the catalog explains the mean-
i ingof the reference code. On the pages following
'. this explanation, there are charts listed alpha-
betically by the name of the specific area of
interest with corresponding file numbers and
map reference codes. Using the name of the
specific area of interest recorded in Step 4, iden-
tify the file number and map reference code
from the chart for the map in which your facility
is located (e.g., file number 00692, map reference
: code 37977-E4-TF-024-00).
(6) Use the file number and map reference code to
obtain the specific topographic quadrangle map
in which your facility is located.
These detailed topographic quadrangle maps are avail-
able in many libraries or for purchase from the Distribu-
titin Branch of the USGS and from private map dealers.
The Catalog ofTopographic and Other Published Maps con-
tains a list of map depository libraries and topographic
map dealers for each state covered in the catalog. >
Appendix E E-l
-------
To purchase a topographic quadrangle map from the (3)
USGS, you must send a written request to the Distribu-
tion Branch of the USGS, containing thefilenumber, map
reference code, the name of the city, state and zip code in
which your facility is located, and payment of $250.
The Distribution Branch of the USGS can be reached at: (4)
Distribution Branch of the USGS
P.O. Box 25286
Denver Federal Center
Denver, CO 80225
(303) 236-7477
ALLOW 5 WEEKS FOR DELIVERY
In addition, you may purchase a topographic quadrangle
map from the USGS through a USGS Public Inquiry
Office. The Public Inquiry Offices are listed for each state
on the inside back cover of the Catalog ofTopographic and
Other Published Maps.
If you need help in determining your latitude and longi-
tude, once you have the necessary map, the National
Cartographic Information Center can provide assis-
tance:
Western states: (303) 236-5829
Eastern states: (314) 341-0851
Please call in advance of the section 313 reporting dead-
line to avoid unnecessary delays.
Determining Your Facility's Latitude
and Longitude
(See diagram next page.)
Read and record the latitude and longitude (in
degrees, minutes, and seconds) for the southeast
corner of the small quadrangle drawn in step
two. The latitude and longitude are printed at
the edges of the map.
To determine the increment of latitude above the
latitude line recorded in step 3,
position the map so that you face west;
place the ruler in approximately a nor thr
south alignment, with the "0" on the
latitude line recorded in step 3 with the
ruler edge intersecting the point.
Without moving the ruler, read and record:
the measurement from the latitude line
to the desired point (the point distance);
the measurement from the latitude line
to the north line of the small quadrangle
(the total distance).
Determine the number of seconds to be added to the
latitude recorded in step 3 by using the ratio:
Point distance
Total distance x 150" = increment of latitude
between lines
[Note: 150" is the number of seconds of arc for the side
of the small quadrangle on a 7.5' map. If you are using a
15' map, the multiplication factor is 300" instead of 150"
since each graticule is 5' of latitude or longitude.]
Onceyouhaveobtainedthecorrectmapforyourfacility: For examPle:
(1) Mark the location of your facility on the map
with a point. If your facility is large, choose a
point central to the production activities of the
facility. If certain structures in your facility are
represented on the map, mark one of the struc-
tures with a point
(2) Construct a small rectangle around the point
with fine pencil lines connecting the nearest 21 /
2' or 5' graticules. Graticules are intersections of
latitude and longitude lines that are marked on
themapedge,andappearasblackcrossesatfour
points in the interior of the map.
Point distance =
Total distance =
99.5 x 150" =
192.0
99.5
192.0
77.7"
0117.7"
(60" = I1; 77.7" = 60" + 17.7" = 01' 17.7")
Latitude in step 3
Increment
32°17'30"
+ 01'17.7"
Latitude of point 32°18'47.7"
to the nearest second = 32°18'48"
E-2 Appendix E
-------
(5) To determine the increment of longitude west of
the longitude line recorded in step 3,
position the map so that you face south;
place the ruler in approximately an east-
west alignment with the "0" on the
longitude line recorded in step 3 with
the ruler edge intersecting the point.
Without moving the ruler, read and record:
the measurement from the longitude
line to the desired point (the point dis-
tance);
the measurement from the longitude
line to the west line of the small quad-
rangle (the total distance).
Determine the number of seconds to be added to the
longitude recorded in step 3 by using the ratio:
Point distance
Total distance x 150" = increment of longitude
between lines
For example:
Point distance =
Total distance =
65.0
149.9
65.0 x 150" = 65" = Ol'OS"
149.9
(60" = 1'; 65" = 60" + 05" = Ol'OS")
78°05'00"
+ Ol'OS"
Longitude in step 3
Increment
Longitude of point 78°06Wr
to the nearest second = 78°06'05"
Latitude/Longitude Diagram
WEST
NORTH
~r
POINT
QUADRANGLE
i
GRATICULE
SOUTH
78°07'30"
78°05'00"
78°02'30"
32°22'30"
32°20'00"
EAST
32°17'30"
32°15'00"
78°00'00"
Point: Latitude 32°18'48" North; Longitude 78°06'05" West
Note: This diagram is based on a USGS 7.5 Minute Series Topographic Map. It is not drawn to scale.
Appendix E E-3
-------
-------
DESIGNATED SECTION 313
Use the appfflofniate address f or sufcmission of
R reports to your State.
WiBifijrd, Otief of -Operations " ; .'•;
^ Emergency Response Commission
Alafeanna Department of Environmental Management
1751 Congressman W.L. Dickinson Drive
Montgomery, AL 36109
(205)260^2700
Alaska
Ms. Camille Stevens
Alaska State Emergency Response Commission
410 Willoughby, Suite 105
Juneau, AK 99801-1795
(907) 465-5220
American Samoa
Pan' Faiai, Director
American Samoa EPA
Office of the Governor
Pago Pago, AS 96799
International Number (684) 633-2304
Arizona
Mr. Carl Funk
Arizona Emergency Response Commission
Division of Emergency Services, Bldg. 341
5636 East McDowell Road
Phoenix, AZ 85008
(602)231-6326
Arkansas
Mr. John Ward
Depository of Documents
Arkansas Department of Labor
10421 West Markham
Little Rock, AR 72205
(501) 562-7444
California
Mr. Stephen Hanna, Chief
Office of Environmental Information
Californian Environmental Protection Agency
P.O. Box 2815
Sacramento, CA 95812
(916)324-9924
Colorado . •..'..
Wlnfred Bromley
Colorado Emergency Planning Commission
Cok)fado3Jtepa^teient of fiealth .
4210 East lllth Avenue ' .;
•Denver, CO 80220
(303)331-4843
Commonwealth of Northern Mariana Islands
Mr. Frank Russell Meecham, HI
Division of Environmental QuaMry
P.O. Box 1304
Saipan, MP 96950
(670) 234-6984
Connecticut
Ms. Sue Vaughn, Title HI Coordinator
State Emergency Response Commission
Department of Environmental Protection
State Office Building, Room 146
165 Capitol Avenue
Hartford, CT 06106
(203)566-4856
Delaware
Mr. Phillip Retallick
Division of Air and Waste Management
Department of Natural Resources and
i Environmental Control
89 King's Highway
P.O. Box 1401
Dover, DE 19903
(302) 739-4764
District of Columbia
Mr. Stephen E. Rickman
Office of Emergency Preparedness
Frank Reeves Center for Municipal Affairs
200014th Street, NW
Washington, DC 20009
(202) 727-6161
Florida
Mr. Jim Loomis
State Emergency Response Commission
Florida Department of Community Affairs
2740 Center-view Drive
Tallahassee, FL 32399-2149
(904) 488-1472
In Florida: 800-635-7179
Appendix F F-l
-------
Georgia
Mr. Burt Langley
Georgia Emergency Response Commission
205 Butler Street, SE
Floyd Tower East
llth Floor, Suite 1166
Atlanta, GA 30334
(404) 656-6905
Guam
Mr. Fred Cashro
Guam EPA
D-107 Harmon Plaza
130 Rojas Street
Harmon, GU 96911
(671) 646-8864
Hawaii
Mr. Leslie Au
Hawaii State Emergency Response Commission
Hawaii State Department of Healm
P.O. Box 3378
Honolulu, HI 96801-9904
(808)586-4251
Idaho
Ms. Margaret Ballard
Idaho Emergency Response Commission
State House
Boise, ID 83720
(208)334-5888
Illinois
Mr. Joe Goodner
Emergency Planning Unit
Office of Emergency Management
DlinoisEPA
P.O. Box 19276
2200 Churchill Road
Springfield, IL 62794-9276
(217) 782-3637
Indiana
Mr. Skip Powers
Indiana Emergency Response Commission
5500 West Bradbury Avenue
Indianapolis, IN 46241
(317)243-5176
Iowa
Mr. Pete Hamlin
Department of Natural Resources
Wallace Building
900 East Grand Avenue
Des Moines, LA 50319
(515)281-8852
Kansas
Mr. Karl Birns
Right-to-Know Program
Kansas Emergency Response Commission
Mills Building, 5th Floor, Suite 501
109 S.W. 9th Street
Topeka, KS 66612
(913)296-1690
Kentucky
Ms. Valerie Hudson
Kentucky Department for Environmental Protection
14 Reilly Road
Frankfort, KY 40601
(502)564-2150
Louisiana
Mr. R. Bruce Hammatt
Emergency Response Coordinator
Department of Environmental Quality
P.O. Box 82215
7290 Bluebonnet
Baton Rouge, LA 70884-2263
(504) 765-0872
Maine
David D. Brown, Chair
State Emergency Response Commission
State House Station Number 72
Augusta, ME 04333
(207) 289-4080
In Maine: (800)452-8735
Maryland
Ms. Marsha Ways
State Emergency Response Commission
Maryland Department of the Environment
Toxics Information Center
2500 Broening Highway
Baltimore, MD 21224
(301) 631-3800
F-2 Appendix F
-------
Massachusetts
Mr. A. David Rodham, Director
Massachusetts EMA
P.O. Box 1496
400 Worcester Rd.
Framingham, Ma. 01701
(508)-820-2000
Michigan
Mr. Kent Kanagey
Title DI Coordinator
Michigan Department of Natural Resources
Environmental Response Division
Title IE Notification
P.O. Box 30028
Lansing, MI 48909
(517)373-8481
Minnesota
Mr; Steve Tomlyanovich
Minnesota Emergency Response Commission
175 Bigelow Building
450 North Syndicate
St Paul, MN 55104
(612) 643-3542
Mississippi
Mr. John David Burns
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
P.O. Box 4501
Jackson, MS 39296-4501
(601) 960-9000
Missouri
Mr. Jim Long
Missouri Emergency Response Commission
Missouri Department of Natural Resources
P.O. Box 3133
Jefferson City, MO 65102
(314)526-3344
Montana
Mr. Tom Ellerhoff, Co-Chairman
Montana Emergency Response Commission
Environmental Sciences Division
Department of Health & Environmental Sciences
Capitol Station
Cogswell Building A-107
Helena, MT 59620
(406)444-3948
Nebraska
Mr. John Steinauer, Coordinator
Nebraska Emergency Response Commission
Nebraska Department of Environmental Control
P.O. iBox 98922
State House Station
Lincoln, NE 68509-8922
(402)471-4251
Nevada
Mr. Joseph Quinn, Chief of Operations
State of Nevada, Division of Emergency Management
2525;South Carson Street
Carson City, NV 89710
(702)687-4240
New Hampshire
Mr. George L. Iverson, Director
New Hampshire State Emergency Management Agency
Title ffl Program
State Office Park Sourn
107 Pleasant Street
Concord, NH 03301
(603);271-2231
Newjersey
Mr. Alan Bookman
New Jersey Emergency Response Commission
SARA Title HI Section 313
Department of Environmental Protection and Energy
Division of Environmental Quality, Safety, Health, and
Analytical Programs
Right-to-Know
Bureau of Hazardous Substances Information
CN-405
Trenton, NJ 08625
(609) 984-5338
New Mexico
Mr. Max Johnson, Title IH Coordinator
New Mexico Emergency Response Commission
Chemical Safety Office, Emergency Management Bureau
P.O. Box 1628
Santa: Fe, MM 87504-1628
(505) 827-9223
Appendix F F-3
-------
New York
Mr. William Miner
New York Emergency Response Commission
New York State Department Of Environmental
Conservation
Bureau of Spill Prevention and Response
50 Wolf Road/Room 326
Albany, NY 12233-3510
(518)457-4107
North Carolina
Ms. Emily Kilpatrick
North Carolina Emergency Response Commission
North Carolina Division of Emergency Management
116 West Jones Street
Raleigh, NC 27603-1335
Attn: Emily Kilpatrick
(919)733-3865
North Dakota
Mr. Bob Johnston
North Dakota Emergency Response Commission
Division of Emergency Management
P.O. Box 5511
Bismarck, ND 58502-5511
(701)224-4589
Ohio
Ms. Cindy DeWulf
Ohio EPA
Division of Air Pollution Control
1800 Watermark Drive
Columbus, OH 43215
(614)644-3604
Oklahoma
Larry Gales
Oklahoma Department of Realm
Environmental Health Administration - 0200
1000 N.E. 10th Street
Oklahoma City, OK 73117-1299
(405)271-8056
Oregon
Mr. Dennis Walthall
Oregon Emergency Response Commission
c/o State Eire Marshall
4760 Portland Road, N.E.
Salem, OR 97305-1760
(503)378-3473
Pennsylvania
Mr. James Tinney
Pennsylvania Emergency Management Council
Bureau of Worker and Community Right-to-Know
Room 1503
Labor and Industry Building
7th & Foster Streets
Harrisburg, PA 17120
(717) 783-2071
Puerto Rico
Mr. Pedro Maldonado,
Puerto Rico Emergency Response Commissioner
Title ffl-SARA Section 313
Puerto Rico Environm'ental Quality Board
Sernades Junco Station
P.O. Box 11488
Santurce, PR 00910
(809)767-8181
Rhode Island
Ms. Martha Delaney Mulcahey
Rhode Island Department of Environmental
Management
Division of Air and Hazardous Materials
291 Promenade Street
Providence, RI02908-5767
Attn: Toxic Release Inventory
(401)277-2808
South Carolina
Mr. Michael Juras
South Carolina Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
Attn: EPCRA Reporting
(803) 935-6336
South Dakota
Ms. Lee Ann Smith, Title III Coordinator
South Dakota Emergency Response Commission
South Dakota Department of Environment and
Natural Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501-3151
(605) 773-3296
B4 Appendix F
-------
Tennessee
Mr. Lacy Suiter, Chairman
Tennessee Emergency Response Commission
Director, Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204
(615) 741-0001
1-800-262-3300 (in Tennessee)
1-800-258-3300 (out of state)
Texas
Ms. Becky Kuicka, Supervisor
Office of Pollution Prevention and Conservation
Texas Water Commission
P.O. Box 13087-Capitol Station
Austin, TX 78711-3087
(512) 463-7869
Utah
Mr. Neil Taylor
Utah Hazardous Chemical Emergency Response
Commission
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
1950 West North Temple
Salt Lake City, UT 84116-4840
(801)536-4100
Vermont
Dr. Jan Carney, Commissioner
Department of Health
60 Main Street
P.O. Box 70
Burlington, VT 05402
(802) 863-7281
Virginia
Ms. Sharon Kenneally-Baxter
Virginia Emergency Response Council
c/o Department of Waste Management
James Monroe Building
14th Floor
101 Norm 14tti Street
Richmond, VA 23219
(804)225-2581
Virgin Islands
Mr. Roy E. Adams, Commissioner
Department of Planning and Natural Resources
U.S. Virgin Islands Emergency Response Commission
Title HI
Nisky Center, Suite 231
Charlotte Amalie
StlThomas, VI00802
(809) 774-3320/Ext. 101 or 102
Washington
Mr. Idell Hansen, Supervisor
Community Right-To-Know Unit
Department of Ecology
P.O. Box 47659
Olympia, WA 98504-7659
(206)438-7252
West Virginia
Mr. Carl L. Bradford, Director
West Virginia Emergency Response Commission
West Virginia Office of Emergency Services
Main Capital Building 1, Room EB-80
Charleston, WV 25305
(304)558-5380
Wisconsin
Department of Natural Resources
P.O. Box 7921
Madison, WI53707
Attn: Russ Dumst, Toxics Coordinator
(608)266-9255
Wyoming
Mr. Joseph Daly, Executive Secretary
Wyoming Emergency Response Commission
Wyoming Emergency Management Agency
P.O. Box 1709
Cheyenne, WY 82003
(307) 777-7566
Notes:
(1) If an Indian tribe has chosen to act independently of
a state for the purpose of section 313 reporting, facilities
located within mat Indian community should report to
metribalSERC,oruntilmeSERCis established, fheChief
Executive Officer of the Indian tribe, as well as to EPA;
(2) Facilities located within me Territories of the Pacific
should send a report to the Chief Administrator of the
appropriate territory, as well as to EPA.
Appendix F F-5
-------
-------
APPENDIX G. SECTION 313 EPA REGIONAL
CONTACTS
Region 1
Pesticides & Toxics Branch
USEPA Region 1 (ATR)
One Congress Street
Boston, MA 02203
(617)565-3932
Connecticut, Massachusetts, Maine,
New Hampshire, Rhode Island, Vermont
Region 5
Pesticides & Toxic Substances Branch
USEPA Region 5 (SP-14J)
77 West Jackson Blvd.
Chicago, IL 60604
(312)353-5907
Illinois, Indiana, Michigan, Minnesota, Ohio,
Wisconsin
Region 2
Pesticides & Toxics Branch
USEPA Region 2 (MS-105)
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
(908) 906-6890
New Jersey, New York, Puerto Rico, Virgin Islands
Regions
Toxics & Pesticides Branch
USEPA Region 3 (3AT31)
841 Chestnut Street
Philadelphia, PA 19107
(215)597-1260
Delaware, Maryland, Pennsylvania, Virginia,
West Virginia, District of Columbia
Region 4
Pesticides & Toxics Branch
Title IE Unit
USEPA Region 4
345 Courtiand Street
Atlanta, GA 30365
(404)347-1033
Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee
Region 6
Pesticides & Toxic Substances Branch
USEPA Region 6 (6TPT)
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-7244
Arkansas, Louisiana, New Mexico, Oklahoma,
Texas
Region 7
Toxics & Pesticides Branch (TOPE)
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7020
Iowa, Kansas, Missouri, Nebraska
Region 8
Toxic Substances Branch
USEPA Region 8 (8AT-TS)
99918th Street
Denver, CO 80202-2405
(303)293-1730
Colorado, Montana, North Dakota, South Dakota,
Utah, Wyoming
Appendix G G-l
-------
Region 9
Pesticides & Toxics Branch
USEPA Region 9 (A-4-3)
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1087
Arizona, California, Hawaii, Nevada, American
Samoa, Guam, Commonwealth of the Northern
Mariana Islands
Region 10
Pesticides & Toxic Substances Branch
USEPA Region 10 (AT083)
1200 Sixth Avenue
Seattle, WA 98101
(206)553-4016
Alaska, Idaho, Oregon, Washington
G-2 Appetidix G
-------
APPENDIX H. STA3B WfcSTfe
These contacts may be able to provide information on source reduction, reuse, and recycling approaches to waste
mmimizatiojatadudingtedrnicala^^ Hbwever,
-------
Iowa
Center for Industrial Research and Service
205 Engineering Annex
Iowa State University
Ames, IA 50011
(515)294-3420
Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
DesMoines,IA 50319-0034
(525)281-8690
Kansas
Bureau of Waste Management
Department of Health and Environment
Forbes Field, Building 730
Topeka,KS 66620
(913)296-1607
Kentucky
Division of Waste Management
Natural Resources and Environmental Protection
Cabinet
18 Reilly Road
Frankfort, KY 40601
(502)564-6716
Louisiana
Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 44307
Baton Rouge, LA 70804
(504)342-1254
Maryland
Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200A
Annapolis, MD 21401
(301)974-3432
Maryland Environmental Service
2020 Industrial Drive
Annapolis, MD 21401
(301)269-3291
(800) 492-9188 (in Maryland)
Massachusetts
Office of Safe Waste Management
Department of Environmental Management
100 Cambridge Street, Room 1094
Boston, MA 02202
(617) 727-3260
Source Reduction Program
Massachusetts Department of Environmental Quality
Engineering
1 Winter Street
Boston, MA 02108
(617) 292-5982
Michigan
Resource Recovery Section
Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
(517)373-0540
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612)296-6300
Minnesota Technical Assistance Program
W-140 Boynton Health Service
University of Minnesota
Minneapolis, MN 55455
(612) 625-9677
(800) 247-0015 (in Minnesota)
Minnesota Waste Management Board
123 Thorson Center
7323 Fifty-Eighth Avenue North
Crystal, MN 55428
(612)536-0816
Missouri
Director, Environmental Improvement and Energy
Resource Authority
225 Madison Street
P.O. Box 744
Jefferson City, MO 65102
(314) 751-4919
H-2 Appendix H
-------
New Jersey
New Jersey Hazardous Waste Faculties Siting
Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609)292-1459
(609)292-1026
Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
(609) 984-6070
New York
New York State Environmental Facilities Corporation
50 Wolf Road
Albany, NY 12205
(518)457-3273
North Carolina
Pollution Prevention Pays Program
Department of Natural Resources and Community
Development
Post Office Box 27687
512 North Salisbury Street
Raleigh, NC 27611
(919) 733-7015
Governor's Waste Management Board
325 North Salisbury Street
Raleigh, NC 27611
(919) 733-9020
Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Raleigh, NC 27602
(919) 733-2178
Ohio
Division of Solid and Hazardous Waste Management
Ohio Environmental Protection Agency
P.O. Box 1049
1800 Watermark Drive
Columbus, OH 43266-0149
(614)481-7200
Ohio Technology Transfer Organization
Suite 200
65 East State Street
Columbus, OH 43266-0330
(614)466-4286
Oklahoma
Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK 73152
(405) 271-7353
Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204-1390
(503)229-5913
Pennsylvania
Pennsylvania Technical Assistance Program
501F. Orvis Keller Building
University Park, PA 16802
(814) 865-0427
Center for Hazardous Materials Research
University of Pittsburgh Applied Research Center
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
Bureau of Waste Management
Pennsylvania Department of Environmental Resources
P.O. Box 2063
Fulton Building
Third and Locust Streets
Harrisburg, PA 17120
(717)787-6239
Appendix H H-3
-------
Rhode Island
Ocean State Cleanup and Recycling Program
Rhode Island Department of Environmental
Management
9 Hayes Street
Providence, RI 02908-5003
(401)277-3434
(800) 253-2674 (in Rhode Island)
Center for Environmental Studies
Brown University
P.O. Box 1943
135 Angell Street
Providence, RI 02912
(401)863-3449
Tennessee
Center for Industrial Services
102 Alumni Building
University of Tennessee
Knoxville, TN 37966
(615)974-2456
Virginia
Office of Policy and Planning
Virginia Department of Waste Management
Monroe Building, llth Floor
101 North 14th Street
Richmond, VA 23219
(804)225-2667
Washington
Hazardous Waste Section
Mail Stop PV-11
Washington Department of Ecology
Olympia,WA 98504-8711
(206)459-6322
Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, WI 53707-7921
(608)267-3763
Wyoming
Solid Waste Management Program
Wyoming Department of Environmental Quality
Herschler Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7752
H-4 AppendixH
-------
APPENDIX I. SECTION 313 RELATED MATERIALS
To receive a copy of any of the section 313 documents
listed below, check the box(es) next to the desired
documents). There is no charge for any of these docu-
ments. Be sure to type your full mailing address in the
space provided on this form. Send this request form to:
Section 313 Document Distribution Center
P.O. Box 12505
Cincinnati, OH 45212
Q Section 313 Rule (40 CFR 372)
A reprint of the final section 313 rule as it ap-
peared in the Federal Register (FR) February 16,
1988.
Q Comprehensive List of Chemicals Subject to
Reporting Under the Act (Title m List of
Lists) (EPA500-B-92-002)
Aconsolidated list of specific chemicals covered
by the Emergency Planning and Community
Right-to-Know Act. The list contains the chemi-
cal name, CAS Registry Number, and reporting
requirements) to which the chemical is subject.
Q The Emergency Planning and Community
Right-to-Know Act: Section 313 Release
Reporting Requirements December 1991
(EPA700-K-92-001)
This brochure alerts businesses to their reporting
obligations under section 313 and assists in de-
termining whether their facility is required to
report. The brochure contains the EPA regional
contacts, the list of section 313 toxic chemicals
and a description of the Standard Industrial
Classification (SIC) codes subject to section 313.
Q Supplier Notification Requirements (EPA
560/4-91-006)
This pamphlet assists chemical suppliers who
may be subject to the supplier notification re-
quirements under section 313 of EPCRA. The
pamphlet explains the supplier notification re-
quirements, gives examples of situations which
require notification, describes me trade secret
provision, and contains a sample notification.
Q Trade Secrets Rule and Form (FR Reprint)
A reprint of the final rule that appeared in the
Federal Register of July 29,1988. This rule imple-
ments the trade secrets provision of the Emer-
gency Planning and Community Right-to-Know
Act (section 322). Includes a copy of the trade
secret substantiation form.
Industry Specific Technical Guidance Documents
EPA has developed a group of smaller, individual guid-
ance documents that target activities in industries who
primarily process or otherwise use the listed toxic chemi-
cals,
Q Electrodeposition of Organic Coatings
January 1988 (EPA 560/4-88-004c)
Q Electroplating Operations January 1988 (EPA
: 560/4-88-004g)
Q Formulating Aqueous Solutions March 1988
(EPA560/4-88-004f)
Q Leather Tanning and Finishing Processes
February 1988 (EPA 560/4-88-0041)
Q Monofilament Fiber Manufacture January
1988 (EPA 560/4-88-004a)
Q Paper Paperboard Production February 1988
(EPA560/4-88-004k)
Q Presswood & Laminated Wood Products
Manufacturing March 1988 (EPA 560/4-88-
004i)
Q Printing Operations January 1988 (EPA
560/4-88-004b)
Q Roller, Knife and Gravure Coating
Operations February 1988 (EPA
560/4/88/004J)
Q Rubber Production and Compounding
March 1988 (EPA 560/4-88-004q)
Q Semiconductor Manufacture January 1988
(EPA 560/4-88-004e)
Appendix I 1-1
-------
Q Spray Application of Organic Coatings
January 1988 (EPA560/4-88-004d)
Q Textile Dyeing February 1988 (EPA 560/4-88-
004h)
Q Wood Preserving February 1988 (EPA 560/4-
88-004p)
Please type mailing address here (Do not attach business cards)
Name/Title
Company Name
Mail Stop
Street Address
P.O. Box
City/State/Zip Code
1-2 Appendix I
-------
OTHER RELEVANT SECTION 313 MATERIALS
Toxics in the Community: National and Local
Perspectives (EPA 560/4-91-014)
This report summarizes the third year of toxic release
inventory data - where, how much, and which types of
toxic chemicals are being released into me environment
- and provides comparisons to the first two years' re-
leases. Available from: Superintendent of Documents,
Government Printing Office, Washington, DC 20402-
9325, Stock number: 055-000-00387-4, $24.00.
Toxic Release Inventory — On-line Database
A computerized on-line database of the toxic release
inventory data is available through the National Library
of Medicine's (NLM) TOXNET on-line system 24 hours
a day. Other NLM files on TOXNET can provide sup-
porting information in such areas as health hazards and
emergency handling of toxic chemicals. Information on
accessing the TOXNET system is available from: TRI
Representative, Specialized Information Services, Na-
tional Library of Medicine,8600RockvillePike,Bethesda,
MD 20894, (301) 496-6531, up to $37.00 per hour.
Toxic Release Inventory 1987-1989 — Magnetic Tape
Contains the complete toxic release inventory for report-
ingyears 1987-1989. Includes brief overviews of section
313 reporting requirements, a sample Form R, lists of
regional and state section 313 contacts. Available from:
National Technical Information Service,5285 Port Royal
Road, Springfield, VA 22161, (703) 487-4650.
1987 Document Number: PB89-186068
1600 (DPI) Density — $1,770.00
6250 (DPI) Density — $890.00
This tape is also available from the Government
Printing Office (GPO-(6250)) -- $500.00.
1988 Document Number: PB90-502030
1600 (BPI) Density — $1,550.00
6250 (BPI) Density — $1,100.00
The Government Printing Office also has this
tape available, GPO-(6250) - $500.00.
1989 Document Number: PB91-507509
Bom 1600 and 6250 (BPI) density - $1,550.00
Toxic Release Inventory 1987-1988: Reporting
Facilities Names and Addresses — Magnetic Tape
Contains the name, address, public contact, phone num-
ber, SIC code, Dun and Bradstreet number of each facility
that reported under section 313 in reporting year 1987.
Also includes, if applicable, parent company name and
meparentcompany'sDunandBradstreetnumber. Avail-
able from: National Technical Information Service, 5285
Port Royal Road, Springfield, VA 22161, (703) 487-4650.
1987 Document Number: PB89-186118, $220.00
; (1600 and 6250 (BPI) density.)
1988 Document Number: PB91-506816, $220.00
(1600 and 6250 (BPI) density.)
Section 313 Roadmaps Database — Diskette
A database of sources of information on the toxic chemi-
cals listed in section 313. The database, created in 1988
and updated in 1990 (a new update is scheduled in 1992),
is intended to assist users of the toxic release inventory
data in performing exposure and risk assessments of
these toxic chemicals. The roadmaps system displays
information, including the section 313 toxic chemicals'
health and environmental effects, me applicability of
federal, state, and local regulations, and monitoring data.
Available from: National Technical Information Service,
5285 Port Royal Road, Springfield, VA 22161, (703) 487-
4650, Document Number: PB90-501487, $195.00.
Comprehensive List of Chemicals Subject to
Reporting Under the Act (Title HI List of Lists)
Available as an IBM compatible disk from: The National
Technical Information Service, 5285 Port Royal Road,
Springfield, VA 22161, (703) 487-4650, Document Num-
ber: PB90-501479, $90.00.
The Toxic Release Inventory: Meeting the Challenge
(April 1988)
This 19 minute videotape explains tfie toxic release re-
porting requirements for plant facility managers and
others. State governments, local Chambers of Com-
merce, labor organizations, public interest groups, uni-
versities, and others may also find the video program
useful and informative.
3/4 inch = $30.75; Beta = $22.95; VHS = $22.00.
Appendix I 1-3
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To purchase, write or call:
Color Film Corporation
Video Division
770 Connecticut Avenue
NorwaD^CT 06854
(800) 882-1120
Form R: A Better Understanding
Developed by EPA Region 3, this videotape reviews the
Form R and explains how to correctly fill-out the FormR.
Available from: National Technical Information Service,
5285 Port Royal Road, Springfield, VA 22161, (703) 487-
4650, Document number: PB90-780446, $35.00.
Chemicals in Your Community, A Citizen's Guide to
the Emergency Planning and Community Right-to-
Know Act, September 1988 (OSWER-88-002)
Thisbookletisintendedtoprovideageneral overview of
the EPCRA requirements and benefits for all audiences.
Part I of the booklet describes the provisions of FJPCRA
and Part n describes more fully the authorities and
responsibilities of the groups of people affected by the
law. Available through written request at no charge
from:
Emergency Planning and Community
Right-to-Know Information Service
Mailcode: OS-120
401 M Street, SW
Washington, DC 20460
POLLUTION PREVENTION
INFORMATION
An up-to-date source.of information on pollution pre-
ventionisthePollutionPreventionlnformationExchange
System(PIES);thecomputerizedinfonnationnetworkof
EPA's Pollution Prevention Information Clearinghouse
(PPIC). PIES includes a directory of representatives from
Federal, State, and local governments; current news on
pollution prevention activities; program summaries for
government agencies, public interest groups, academic
institutions, trade associations, and industry; a data base
of industry case studies; a calendar of conferences, train-
ingseminars, and workshops;alegislationdatabase; and
specialized forums dedicated to various topics. Further
information on using PIES canbe obtained from the PPIC
Technical Support Hotline, (703) 821-4800.
Documents containing general information about the
PIES system and how to access them are listed below and
can be obtained by writing to:
PPIC
c/oSAIC
7600-A Leesburg Pike
Falls Church, VA 22043
The list below includes some of the material available
about the PIES system. Requests for these items should
include the code number found to the left of each entry.
PPIC-1. PPIC General Information Package
PPIC-2. 'TPIC: The Pollution Prevention Information
Clearinghouse." U.S. EPA Office of Environmental
Engineering and Technology Demonstration and Office
of Pollution Prevention. April 1990. Brochure.
PPIC-3. "PIES: The Pollution Prevention Information
Exchange System." U.S. EPA Office of Environmental
Engineering and Technology Demonstration and Office
of Pollution Prevention. May 1989. Brochure.
PPIC-4. "Pollution Prevention Information Exchange
System (PIES) User Guide, Version 1.1." U.S. EPA
Office of Environmental Engineering and Technology
DemonstrationandOfficeofPollutionPrevention(EPA/
600/9-89/086). September 1989. 70pp.
Additional information on source reduction, reuse, and
recycling approaches to waste minimization is available
through state programs that offer technical and/or finan-
cial assistance in the areas of waste minimization and
treatment. These state contacts are listed in Appendix H.
1-4 Appendix I
U.S. GOVERNMENT PRINTING OFFICE : 1992 O - 323-732 QL3
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