United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
March 1993
EPA 745-F-93-001
TOXIC CHEMICAL RELEASE INVENTORY
Data Quality Checks to Prevent Common
Reporting Errors on Form R
This document supplements Appendix C, "Common Errors in Completing Form
R Reports", of the Toxic Chemical Release Inventory Form and Instructions. Use of this
document may prevent the generation of Notices of Technical Errors (NOTEs) by U.S.
EPA for incorrectly completed Form Rs and improve the quality of the data made
available to the public. Information for all sections of Form R is not provided as only
the common errors relative to the 1991 reporting year are discussed in this document.
CONTENTS
Section 1. Toxic Chemical Identity 2
Reporting CAS numbers in Section 1.1 ... 2
Section 6. Transfer of the Toxic Chemical in Wastes to Off-Site Locations . . ... ... 2
Reporting transfers to POTWs. . . . . . 2
Reporting other off-site transfers . . . ............ 2
Section 7. On-Site Waste Treatment, Energy Recovery, and Recycling 2
Reporting on-site energy recovery methods in Section 7B 2
Reporting on-site recycling methods in Section 7C -. . 2
Sections. Source Reduction and Recycling Activities , 2
Reporting quantities in Section 8.1, "Quantity released." 4
Reporting quantities in Section 8.2, "Quantity used for energy recovery on-site !'5
Reporting quantities in Section 8.3, "Quantity used for energy recovery off-site,"5
Reporting quantities in Section 8.4, "Quantity recycled on-site." 6
Reporting quantities in Section 8.5, "Quantity recycled off-site." 6
Reporting quantities in Section 8.6, "Quantity treated on-site." ........... 6
Reporting quantities in Section 8.7, "Quantity treated off-site." 7
Reporting quantities in Section 8.8, "Quantity released to the environment as a
result of remedial actions, catastrophic events, or one-time events not
associated with production processes." 7
Reporting the production ratio in Section 8.9 7
Reporting source reduction activities in Section 8.10 8
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Section 1. Toxic Chemical Identity
Reporting CAS numbers in Section 1.1 Beginning with the 1991 reporting year,
EPA has assigned alphanumeric category codes to the twenty chemical categories for
the purposes of reporting in Section 1.1, the CAS number field. If you are completing a
Form R for a chemical category, you must provide the appropriate code for that
category in Section 1.1. The category codes can be found in the instructions for Section
1.1; Table H, "Section 313 Toxic Chemical List;" and Appendix B, "Reporting Codes for
EPA Form R."
Section 6. Transfers of the Toxic Chemical in Wastes to Off-Site Locations
Reporting transfers to POTWs. When all quantities of a listed mineral acid are
transferred to a POTW after being neutralized to a pH of 6 or greater, the quantity
transferred should be reported as zero. It is incorrect to enter "NA" (Not Applicable),
in such a situation.
Reporting other off-site transfers. Beginning with the 1991 reporting year,
transfers off-site for .the purposes of recycling or combustion for energy recovery are to
be reported in Section 6.2. Any quantities reported in Sections 8.5,8.3,8.7, and 8.1 as
sent off-site for recycling, energy recovery, treatment, or disposal, respectively, must
also be reported in Section 6.2 along with the receiving location and appropriate off-
site activity code.
Section?. On-Site Waste Treatment, Energy Recovery, and Recycling
Reporting on-site energy recovery methods in Section 7B. When a quantity is
reported in Section 8.2 as combusted for energy recovery on-site, the type of energy
recovery system used must be reported in Section 7B, and vice versa.
Reporting on-site recycling methods in Section 7C. When a quantity is reported
in Section 8.4 as recycled on-site, the type of recovery method must be reported in
Section 7C, and vice versa.
Section 8. Source Reduction and Recycling Activities
This section is mandatory: under no circumstances should a reporting facility
leave Section 8 entirely blank, even if the facility does not engage in source reduction or
recycling activities.
It is incorrect to enter "NA" (Not Applicable), in columns A, B, C, or D.
Entering "NA" in column A was allowable for the 1991 reporting year only. Zero (0)
can be used in columns A, B, C, and D to indicate that the reported toxic chemical will
not undergo a specific activity such as treatment.
Columns C and D, the future year projections for questions 8.1 through 8.7,
must be completed. EPA expects a reasonable estimate for the future year projections.
Zero (0) can be used in columns C and D to indicate that the manufacture, processing, or
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otherwise use of the chemical will be discontinued; in such cases, columns C and D for
Sections 8.1 through 8.7 must contain all zeroes.
It is incorrect to use range codes to report quantities in Section 8. Range codes
can be used only in Sections 5 and 6 of Form R.
It is incorrect to use the codes for reporting the maximum amount of the
reported toxic chemical on-site in Section 4 to report quantities in Section 8.
Quantities reported in Sections 8.1 through 8.7 must be mutually exclusive and
additive. This means that quantities of the reported toxic chemical should not be
double-counted in Sections 8.1 through 8.7. Some facilities submitting Form Rs for the
1991 reporting year have reported the same quantity of a toxic chemical as both treated
and recycled on-site.
Some double-counting errors have been due to confusion over the differences
in how on-site treatment of a toxic chemical is reported in Section 7A as compared to
Section 8. In Section 7A, information on the treatment of waste streams containing the
toxic chemical is reported, along with the percent efficiency in terms of destruction or
removal of the toxic chemical from each waste stream. In Section 8, only the quantity of
the toxic chemical actually destroyed through the treatment processes reported in
Section 7A is reported in Section 8.6 to avoid double-counting within Sections 8.1
through 8.7.
For example, a facility submits a Form R for nickel compounds. The facility treats
wastewaters containing the nickel compounds and removes the nickel with a 99 percent
efficiency. The facility then further reclaims the nickel and makes it available for
continued use in its manufacturing processes. In completing Form R, the facility should
report the treatment of the wastewaters with a 99 percent efficiency for the removal of
the nickel in Section 7A, the method of recovery for the nickel in Section 7C, and only
the amount of nickel made available for further use after reclamation as a quantity
recycled on-site in Section 8.4. Any quantities released or disposed, including releases
from either the treatment or recycling activities, should be reported in Section 8.1. The
facility should not report the quantity of nickel removed from the wastewaters as a
quantity treated on-site in Section 8.6 because reporting the same quantity as both
treated and recycled on-site doubles the quantity of nickel that was treated and
subsequently recycled on-site.
Quantities reported in Sections 8.1 through 8.7 must not be reported in Section
8.8 and vice versa.
For example, 10,000 pounds of a toxic chemical is spilled due to non-production
related activities during the reporting year. Of the total 10,000 pounds, 2,500 pounds
volatilized and were released directly to the air and the remaining 7,500 pounds were
collected and sent off-site for treatment. The total 10,000 pounds would be reported in
Section 8.8. The 2,500 pound release to air would be reported in Section 5.1 as a fugitive
emission, but it would not be reported in Section 8.1. The 7,500 pound transferred off-
site for treatment would be reported in Section 6.2, but it would not be reported in
Section 8.7.
Any time a reported toxic chemical is contained in a waste that is identified
under RCRA, and the waste is associated with routine production-related activities and
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is recycled, combusted for energy recovery, treated, or disposed either on- or offrsite,
that quantity of the toxic chemical must be included in the quantities reported in
Sections 8.1 through 8.7.
Reporting quantities in Section 8.1. "Quantity released." Facilities have
incorrectly completed this element in several ways. Often, quantities of the reported
toxic chemical that are released or disposed on-site and reported in Section 5 of the
form are not reported in Section 8.1. Also, quantities of the reported toxic chemical
transferred off-site for the purposes of disposal are reported in Section 6.2 but not in
Section 8.1.
To correctly report in Section 8.1, a facility must include any of the following
quantities of the reported toxic chemical that are released directly to the environment,
disposed of on-site, or sent off-site for disposal that are not associated with a
catastrophic event or non-production related activity:
Quantities released directly to the environment and disposed on-site (Section)
Fugitive or non-point air emissions
Stack or point air emissions
Discharges to receiving streams or water bodies
Underground injections on-site
Release to land on-site: landfill
land treatment/application farming
surface impoundment
other disposal
5.1
5.2
5.3
5.4
5.5.1
5.5.2
5.5.3
5.5.4
Include in these quantities any direct releases from any treatment, recycling, or
energy recovery activities.
Quantities disposed off-site
These are quantities that.are reported in Section 6.2 and associated with the following
codes:
M10 Storage Only;
M71 Underground Injection;
M72 Landfill/Disposal Surface Impoundment;
M73 Land Treatment;
M79 Other Land Disposal;
M90 Other Off-Site Management;
M94 Transfer to Waste Broker-Disposal; and
M99 Unknown.
Do not include in Section 8.1 any of the following quantities:
Direct releases or fugitive emissions from remedial actions, catastrophic
events, or one-time events not associated with production processes (these
quantities are reported in Section 8.8 only).
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Quantities of the toxic chemical associated with non-production related
activities, such as catastrophic releases and remedial actions, as well as other one-
time events not associated with routine production practices that were disposed
on-site or sent off-site for disposal (these quantities are reported in Section 8.8
only).
Reporting quantities in Section 8.2, "Quantity used for energy recovery on-site."
A quantity must be reported in Section 8.2 for the current (reporting) year when a
method of on-site energy recovery is reported in Section 7B, and vice versa. An error
facilities make when completing Form R is to report the methods of energy recovery
used on-site in Section 7B but not report the total quantity associated with those
methods. Another error is to report a quantity in this section if the combustion of the
toxic chemical took place in a system that did not recover energy (e.g. an incinerator).
It is also incorrect to report a quantity of the toxic chemical as combusted for energy
recovery if the toxic chemical does not have a BTU (British Thermal Unit) value high
enough to sustain combustion. Examples of toxic chemicals that do not have heating
values high enough to sustain combustion include metals, CFCs, and halons.
Do not include in Section 8.2 any quantities of the toxic chemical associated with non-
production related activities, such as catastrophic releases and remedial actions, as well
as other one-time events not associated with routine production practices, that were
combusted for energy recovery on-site.
Reporting quantities in Section 8.3. "Quantity used for energy recovery off-site."
As in Section 8.2, it is an error to report a quantity in this section if the off-site
combustion of the toxic chemical took place in a system that did not recover energy
(e.g. an incinerator). It is also incorrect to report a quantity of the toxic chemical as sent
off-site for the purposes of energy recovery if the toxic chemical does not have a BTU
(British Thermal Unit) value high enough to sustain combustion. Examples of toxic
chemicals that do not have heating values high enough to sustain combustion include
metals, CFCs, and halons. It is an error to not include quantities in Section 8.3 that are
reported in Section 6.2 as transferred off-site for the purposes of combustion for
energy recovery using the following codes:
M56 Energy Recovery; and
M92 Transfer to Waste BrokerEnergy Recovery.
Do not include in Section 8.3 any quantities of the toxic chemical associated with non-
production related activities such as catastrophic releases and remedial actions, as well
as other one-time events not associated with routine production practices, that were
sent off-site for the purposes of combustion for energy recovery (these quantities are
reported in Section 8.8 only).
Reporting quantities in Section 8.4, "Quantity recycled on-site." A quantity must
be reported in Section 8.4 for the current (reporting) year when a method of on-site
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recycling is reported in Section 7C, and vice versa. An error facilities make when
completing Form R is to report the methods of recycling used on-site in Section 7C but
not report the total quantity recovered using those methods. In addition, only the
amount of the chemical that was actually recovered is to be reported in Section 8.4.
Do not include in Section 8.4 any quantities of the toxic chemical associated with non-
production related activities such as catastrophic releases and remedial actions, as well
as other one-time events not associated with routine production practices, that were
recycled on-site.
Reporting quantities in Section 8.5. "Quantity recycled off-site." It is an error to
not include quantities in Section 8.3 that are reported in Section 6.2 as transferred off-
site for the purposes of recycling using the following codes:
M20 Organics recovery;
M24 Metals recovery;
M26 Other recovery;
M28 Acid regeneration; and
M93 Transfer to Waste Broker-Recycling.
Do not report in Section 8.5 the quantity actually recycled at the off-site facility - .
facilities should report the quantity that was sent off-site for the purposes of recycling.
Do not include in Section 8.5 any quantities of the toxic chemical associated with non-
production related activities such as catastrophic releases and remedial actions, as well
as other one-time events not associated with routine production practices, that were
sent off-site for the purposes of recycling (these quantities are reported in Section 8.8
only).
Reporting quantities in Section 8.6. "Quantity treated on-site." Quantities may
not always have to be reported in Section 8.6 when Section 7A is completed. This is
because the information reported in Sections 7 and 8 is different; information on how
waste streams containing the reported toxic chemical are treated is reported in Section
7, while the quantity of the toxic chemical actually destroyed as a result of on-site
treatment is reported in Section 8.6. If a quantity is reported in Section 8.6, Section 7A
must be completed. This may result in apparent discrepancies between Sections 7 and
8. For example, a facility may treat wastewaters containing a toxic chemical by
removing the toxic chemical and then disposing of it on-site. The treatment of the
wastewaters would be reported in Section 7A, with an efficiency estimate based on the
amount of the toxic chemical removed from the wastewaters. As the toxic chemical
undergoes treatment and then disposal, the facility would report only the amount of
the toxic chemical actually destroyed during treatment in Section 8.6 and the amount
ultimately disposed in Section 8.1 in order to avoid double-counting the same quantity
hi Section 8. In cases where the toxic chemical is not destroyed during a treatment
process and subsequently enters another activity, such as disposal (e.g., metals
removed from wastewaters and subsequently disposed on-site), the quantity of the
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toxic chemical would be reported as disposed in Section 8.1, not as treated in Section
8.6.
Do not include in Section 8.6 any quantities of the toxic chemical associated with
non-production related activities such as catastrophic releases and remedial actions, as
well as other one-time events not associated with routine production practices, that
were treated on-site.
Reporting quantities in Section 8.7. "Quantity treated off-site." It is an error to
not include quantities in Section 8.7 that are reported in Section 6.2 as transferred off-
site for the purposes of treatment and associated using the following codes:
M40 Solidification/stabilization;
M50 Incineration/thermal treatment;
M54 rncmeration/Ihsignificant Fuel Value;
M61 Wastewater treatment (excluding POTW);
M69 Other treatment; and
M95 Transfer to Waste Broker-Waste Treatment.
In addition to those quantities, facilities should report any quantity that is transferred
to a POTW (as reported in Section 6.1) in Section 8.7.
Do not include in Section 8.7 any quantities of the toxic chemical associated with non-
production related activities such as catastrophic releases and remedial actions, as well
as other one-time events not associated with routine production practices, that were
sent off-site for the purposes of treatment or discharged to a POTW (these quantities
are reported in Section 8.8 only).
Reporting quantities in Section 8.8. "Quantity released to the environment as a
result of remedial actions, catastrophic events, or one-time events not associated with
production processes." Report in Section 8.8 those quantities associated with non-
production related activities such as catastrophic releases and remedial actions, as well
as other one-time events not associated with routine production practices, that were
released directly to the environment, disposed on-site, or transferred off-site for the
purposes of recycling, energy recovery, treatment or disposal. Quantities reported in
Section 8.8 must not be reported in Sections 8.1 through 8.7.
Reporting the production ratio in Section 8.9 A production ratio or activity
index must be provided in Section 8.9. A zero is not acceptable and "NA" (Not
Applicable), can be used only when the reported toxic chemical was not manufactured,
processed, or otherwise used in the year prior to the reporting year.
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Reporting source reduction activities in Section 8.10 It is an error to report a
source reduction activity in Section 8.10 and not report at least one method used to
identify that activity and vice versa.
8
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