•yCLEIDA
aijrtrjr^:
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WHERE TO SEND REPORTS
REGULAR, CERTIFIED MAIL, OVERNIGHT
OR HAND DELIVERED
SECTIONA. 6 (PAGE 3)
*FOR AFR TECHNICAL SUPPORT
CALL (703) 816-4434
THE USER SUPPORT HOTLINE NUMBER
IS TO BE USED FOR THE AFR SOFTWARE
AND DOES NOT PROVIDE REGULATORY
SUPPORT.
SECTION A 5 (PAGE 3)
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
HOTLINE 1-(800) 535-0202 OR
(703) 412-9877
HOURS OF OPERATIONS ARE
9:00 AM TO 6:00 PM E.S.T.
SECTION A. 7 (PAGE 4)
HOW TO OBTAIN FORMS
AND OTHER
INFORMATION
SECTION A. 7 (PAGE 4)
SECTION 313 EPA
REGIONAL CONTACTS
APPENDIXG.
STATE DESIGNATED
SECTION 313 CONTACTS
APPENDIXR
TABLE OF CONTENTS FOR YOUR
CONVENIENCE
-------
Important Information for Reporting Year 1997
The following information updates or corrects the Forms and Instructions for 1997. No other changes or
modifications have been made to the Forms or Instructions other than these listed here.
O All references to reporting year 1997 and all
other date related references have been .,
changed to reflect the current reporting year.
(i.e., reporting year 1996 has been changed
to reporting year 1997; prior year 1995 was
changed to prior year 1996, etc.) This change
was made for both the Form R and the
instructions.
O The back side of the pages of the Form R
include a box stating "This page intentionally
left blank". Please do not copy double-sided.
D Appendix A contains reporting instructions
specific to Federal facilities who are required
to report under Executive Order 12856.
Further guidance for Federal facilities may
be obtained from the EPCRA Hotline at 1-
800-535-0202.
n The States and Regional contact list (Appen-
dices F and G) have been updated.
O The Alternate Threshold provides eligible
facilities with the option of submitting a
simplified Form A on substitution of the full
Form R report. The Form A has OMB #
2070-0143.
O The Toxic Chemical List (Table II) has been
updated for Reporting Year 1997 to include
changes to the list that occurred since last
year. EPA has removed two chemicals from
the list, 2-bromo-2-nitropropane (bronopol)
and 2,6-dimethylphenol. Also, based on a
review of the OSHA carinogen status of the
listed chemicals, the de minimis levels for
three chemicals have been lowered from 1.0
to 0.1 percent. The chemicals with lower de
minimis levels are: 2,4-dinitrotoluene, 2,6-
dinitrotoluene, and nitrobenzene.
d Use of NAs in Section 8: Not applicable,
"NA," can now be used in Section 8.1
through 8.7 to indicate that the waste man-
agement activity is not occurring either on-
site or off-site.
D Two new disposal codes have been added to
the list of codes applicable for Part II, section
6.2 of the Form R. These codes apply to
metals and metal compounds.
D Appendix H provides a list of Section 313
related materials (e.g., industry-specific
guidance documents and information on
how to order documents free of charge.)
D The AFR97 software is now available in three
versions: DOS, Windows 3.1 and Windows
95/NT. The DOS version (EPA 745-C-98-
001) is included in this package. The Win-
dows 3.1 version (EPA 745-C-98-002) and the
Windows 95/NT version (EPA 745-C-98-003)
are available upon request by calling (800)
490-9198 or mailing request to: USEPA/
NECPI, P.O. Box 42419 Cincinnati, OH 45242-
2419, (800) 490-9198. To ensure that your
request is filled properly, please use the EPA
publication number (shown above) for the
version that you are ordering.
O All versions of the AFR97 software are
available for downloading from the Internet
(www.epa.gov/opptintr/afr). The Web site
also contains additional information, such
as Frequently Asked Questions, that may
be helpful when using APR.
O APR software will also be available on CD-
ROM this year. The CD-ROM will contain all
three versions of the APR software (DOS,
Windows 3.1 and Windows 95/NT); the
complete TRI Reporting Form R and Instruc-
tions (this book); and UTIL 97 software that
is useful for combining multiple TRI submis-
sions into a dBase file. The CD-ROM will be
available by request from NECPI (800 490-
9198). Please request EPA 745-C-98-004
when ordering.
O AFR97 software now generates the 5-page
Form R and the 2-page Form A. (The 9-page
form is no longer available.)
O The APR software contains two new codes
for Part II, Section 6.2, Column C:
"M41-Solidification /Stabilization -
metals and metal compounds only"
"M62 -Wastewater Treatment (Excluding
POTW) - metals and metal compounds
only"
Toxic Release Inventory Reporting Form and Instruction
-------
-------
Toxic Release Inventory Reporting Forms and Instructions
EPA's TRI Automated Form R (APR) Software for Reporting Year 1997 [[[ ...
Toxic Chemical Release Inventory Reporting Form R [[[
Toxic Chemical Release Inventory Reporting Form A [[[ . ..................................
A. General Information
A.I Who Must Report [[[ 1
A.2 How to Assemble a Complete Report [[[ 1
A.2.a. The Toxic Chemical Release Reporting Form, EPA Form R [[[ 1
A.2b The Toxic Chemical Release Reporting Form, EPA Form A ........................................ . .................. 1
A.3 Trade Secret Claims [[[ 2
A.4 Recordkeeping [[[ 2
A.5 How to Prepare a Voluntary Revision of a Previous Submission [[[ 3
Where to Submit a Voluntary Revision of a Previous Submission [[[ 3
A.6 When the Report Must be Submitted [[[ 3
A.6a Where to Send the Forms [[[ 3
A.7 How to Obtain Forms and Other Information [[[ 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.2a Multi-Establishment Facilities [[[ 5
B.2b Auxiliary Facilities [[[ 7
B.2c Property Owners [[[ 7
B.3 Activity Determination [[[ 7
-------
Toxic Release Inventory Reporting Forms and Instructions
Table of Contents
5. Parent Company Information 20
5.1 Name of Parent Company. 20
5.2 Parent Company's Dun and Bradstreet Number. 20
Part II. Chemical-Specific Information
Data Element
1. Toxic Chemical Identity. 20
1.1 CAS Number 20
1.2 Toxic Chemical or Chemical Category Name 21
1.3 Generic Chemical Name 21
2. Mixture Component Identity. 21
2.1 Generic Chemical Name Provided by Supplier 22
3. Activities and Uses of the Toxic Chemical at the Facility. 22
3.1 Manufacture the Toxic Chemical 22
3.2 Process the Toxic Chemical (incorporative activities) 22
3.3 Otherwise Use the Toxic Chemical (non-incorpirative activities) 23
4. Maximum Amount of the Toxic Chemical On-Site at Any Time During the Calendar Year....23
5. Quantity of the Toxic Chemical Entering each Environmental Medium 24
5.1 Fugitive or Non-Point Air Emissions 25
5.2 Stack or Point Air Emissions 25
5.3 Discharges to Receiving Streams or Water Bodies 25
5.4.1 Underground Injection On-Site to Class I Wells 26
5.4.2 Underground Injection On-Site to Class H-V Wells 26
5.5 Disposal to Land On-Site 26
5.5.1A RCRA Subtitle C Landfills 26
5.5.1B Other Landfills 26
5.5.2 Land Treatment/Application Fanning 26
5.5.3 Surface Impoundment 26
5.5.4 Other Disposal 26
5.A ColumnATotalRelease 26
5.B Column B Basis of Estimate 28
5.C Column C Percent From Stormwater. 28
6. Transfers of the Toxic Chemical in Wastes to Off-Site Locations 29
6.1 Discharges to Publicly Owned Treatment Works (POTW) 31
6.1.A.1 Total Transfers 31
6.1.A.2 Basis of Estimate 31
6.2 Transfer to Other Off-Site Locations 31
6.2.A Column A Total Transfers 32
6.2.B Column B Basis of Estimate 34
6.2.C Column C Type of Waste Management: Treatment/Disposal/Recycling/Energy Recovery. 34
7. On-Site Waste Treatment Energy Recovery and Recycling Methods 36
7A On-Site Waste Treatment Methods and Efficiency. 36
7A.a Column AGeneral Waste Stream 36
7A.b ColumnB Waste Treatment Method(s) Sequence 36
7A.c Column C Range of Influent Concentration 38
7A.d Column D Waste Treatment Efficiency Estimate 38
7A.e Column E Based on Operating Data? 40
7B On-Site Energy Recovery Processes 40
7C On-Site Recycling Processes 40
8. Source Reduction and Recycling Activities 42
Toxic Release Inventory Reporting Forms and Instructions
-------
Toxic Release Inventory Reporting Forms and Instructions
Table of Contents
D. How to Determine if your Facility Qualifies for the Alternate Threshold
and is Eligible for Reporting on the Form A
D.I Alternate Threshold 50
D.2 What is the Form A (certification statement)? 1 50
D.3 What is the total annual reportable amount? 50
D.4 Recordkeeping 50
D.5 Multi-establishment facilities 50
D.6 Trade secrets 51
D.7 Metals and metal compounds 51
E. Instructions for Completing EPA Alternate Threshold Form A
Part I. Facility Identification Information
1. Reporting Year. 52
2. Trade Secret Information 52
2.1 Are you claiming the chemical identity on page 1 trade secret? 52
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized? 52
3. Certification 52
4. Facility Identification 52
4.1 Facility Name, Location, and TRI Facility Identification Number. 52
4.2 Federal Facility Designation 53
4.3 Technical Contact 53
4.4 Intentionally Left Blank for the Certification Statement 53
4.5 ' Standard Industrial Classification (SIC) Code 53
4.6 Latitude and Longitude 53
4.7 Dun and BradstreetNumber. 53
4.8 EPA Identification Number. 54
4.9 NPDES Permit Number. 54
4.10 Underground Injection Well Code (UIC) Identification Number. 54
5. Parent Company Information 54
5.1 Name of Parent Company. 54
5.2 Parent Company's Dun & Bradstreet Number. 54
Part II. Chemical Specific Information
1. Toxic Chemical Identity. 55
1.1 CASNumber. 55
1.2 Toxic Chemical or Chemical Category Name 55
1.3 Generic Chemical Name 55
2. Mixture Component Identity. 56
2.1 Generic Chemical Name Provided by Supplier. 56
Table I SIC Codes 20-39 1-1
Table II Section 313 Toxic Chemical List for Reporting Year 1997 II-l
Table IE State Abbreviations III-l
Appendix A Federal Facility Reporting Information A.I
Appendix B Reporting Codes for EPA Form R B.I
Appendix C Common Errors in Completing Form R Reports C.I
Appendix D Supplier Notification Requirements D.I
Appendix E How to Determine Latitude and Longitude From Topographic Maps E.I
Appendix F State Designated Section 313 Contacts F.I
Appendix G Section 313 EPA Regional Contacts G.I
Appendix H Section 313 Related Materials and Information Access H.1
Toxic Release Inventory Reporting Forms and Instructions
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Software to
Subiviir
EUcTRONicAlly!
TRY IT! You'll LikE IT!
APR usage has increased from 13 percent in 1990 to 62 percent
in 1996.
APR Helps You!
Gives you (almost) paperless TRI reporting;
Uses easv, accurate "online" data entry of your Form R
information;
Minimizes keystrokes by selecting data from drop-down lists;
and
Uses error checking/online validation routines.
APR WebsiTE!
For the latest APR news visit
our APR website at
www.epa.gov/opptintr/afr
AFRJfdr DKQ& softwkre^s included
r ^! fcfc« tit* •j.ys.v+s ^ *& jV^ s *• , w* '»' j*i »
&*•»• -"**
request^ caning (800) 490-9198.*
-------
¥ t
Software to Computerize '
Form R Submissions
Automated Forrn R Software
for Reporting Year 1997
The Automated Form R (APR) for DOS software for reporting year
1997 is designed to make it easier for you to submit TRI data.
Enclosed with this reporting package is a copy of AFR97 for DOS, the
software that allows you to submit your TRI data for Reporting Year
1997 (RY97) on a diskette. The AFR97 program incorporates many of
your changes and suggestions for improvement.
If you need additional copies of the software, contact the National
Center for Environmental Publications and Information (NCEPI) at
(800) 490-9198.
APR for Windows software for 1997 TRI reporting will soon be
available from NCEPI (800-490-9198). Look for the most recent
information about our software at www.epa.gov/opptintr/afr or contact
Delores Evans at evans.delores@epamail.epa.gov or at (202) 260-1625
or Jan Erickson at erickson.jan@epamail.epa.gov or at (202) 260-3801.
We welcome your comments and suggestions — please send them to:
Janette Petersen, Chief
TRI Information Management Branch (MC 7407)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
e-mail: petersen.janette@epamail.epa.gov
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
PREVENTION, PESTICIDES AND
TOXIC SUBSTANCES
Dear APR User:
I want to thank you each of you who responded to my letter of October 6, 1997, about the AFR
Windows software. The tremendous response from you and other users has opened a much
needed and appreciated dialogue between EPA and the AFR user community.
We are pleased to tell you that the software has been redesigned in an effort to correct many of
the problems that you have reported to us. Beta testing was conducted to confirm this. We have
also employed 3rd party testing, to further confirm the quality of the software. In addition, we
were able to include many of your suggestions for software enhancements. We hope this adds to
the software's stability and usefulness.
Information on the availability of the Windows software is provided in this Form R Instruction
book. For additional information about the Windows software, you may contact Delores Evans
by e-mail, (evans.delores@epamail.epa.gov).
So that we can continue the dialogue and get information out to you quickly, we have set up the
following channels of communication:
1) Shared user e-mail list
2) A file of Fax numbers
3) A designated space on our web site to provide updated information and to receive
your comments, "www.epa.gov/opptintr/afr"
If you wish to add your name to any of the above lists, please e-mail your information to Delores
Evans (evans.delores@epamail.epa.gov) or send me a letter.
Thank you for your interest in the AFR, I look forward to working with you to continually
improve the TRI reporting process.
Allan S. Abramson, Director
Information Management Division (7407)
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable OH Based Inks on Recycled Paper (Minimum 20% Postconsumer)
-------
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Please Read This Message
Before Using AFR97
Software to Computerize
Form R Submissions
In 1987, the EPA developed a software package for reporting Toxic Release
Inventory (TRI) submissions, as required under Section 313, Title III of the Super-
fund Amendments and Reauthorization Act of 1986 and the Pollution Prevention Act
of 1990. The software is called Automated Form R or APR.
Since 1987, the EPA has encouraged submission of TRI data on diskettes because
electronic submissions significantly reduce errors. With electronic submissions,
your data can also be loaded automatically into EPA's computers.
Advisory
The enclosed Automated Form R software, although reviewed for quality assurance,
should be used with the understanding that all possible variations in the conditions of
hardware and software configurations, as well as the data entered, cannot always be
anticipated and may consequently have an effect on software use. Moreover, in an
ongoing effort to keep pace with the advent of technological advances, development
of new software may, on occasion, result in technical errors affecting use.
Therefore, we recommend that software users thoroughly reviewttheir TRI
submissions to ensure accuracy prior to sending them to EPA and the designated
State Agency. Any problems, concerns or questions should be referred to Technical
Support at (703) 816-4434.
Statement on Limitations of Warranty and Liability
To the maximum extent permitted by applicable law, the U.S. Environmental
Protection Agency makes no warranty, express or implied, and accepts no liability
for any damages, consequential or other (including without limitation, direct or
indirect damages for personal injury, loss of business profits, business interruption,
loss of business information, or any other pecuniary loss), concerning the use,
attempted use, or application of the enclosed EPCRA Section 313 Automated Form
R software.
We hope you will take this opportunity to submit your TRI reports on disk. If you
have any questions, please call:
Technical Support
(for AFR software support)
(703) 816-4434*
8:00 a.m. to 4:30 p.m.
Eastern Standard Time except
Federal holidays
* Please note that the EPCRA Hotline cannot respond to questions regarding AFR software use.
All calls concerning AFR usage must be made to Technical Support.
AFR97 for DOS
Features
»• AFR97 for DOS can be used
in DOS (version 5.0 or higher),
Windows™ 3.1, and Windows
95™*
»• AFR97 for DOS can be
installed on most Local Area
Networks (LANs). We
recommend that you contact
your organization's LAN
manager before installing
software on the LAN drive.
> AFR97 for DOS can be used
to submit original submissions
or revisions for any year
beginning with Reporting Year
1991.
»• AFR97 for DOS works with
most popular printer models.
» Qualified submitters can use
the two-page Form A.
'»• Technical Support is available
at (703) 816-4434.
IMPORTANT
NOTE:
»• AFR97 for DOS is limited to 98
unique POTW listings and 98
transfers to off-sites. If you
have more than 98 POTWs or
more than 98 transfers, you
will need to use AFR 97 for
Windows. Please contact the
Technical Support at (703)
816-4434 for more
information.
AFR97 for DOS is included in this package. AFR97 for Windows w\\ soon be available.-To request a
< -r ,,_,., r j "* ^ - _ •-' .,-",!*_ ^
copy, please call (8OO) 49O-9198& download it from our web site at www.epa.gov/jopptintr/air.
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Software to Computerize '
Form R Submissions
AFR System
Requirements
The enclosed Automated Form R
(AFR) for DOS* software is
supplied on one 3.5-inch, 1.44
MB (high-density) diskette in
compressed format. It must be
installed before you can enter
data. (High-density 5.25-inch
diskettes are available from
Technical Support.) The
hardware and software needed
to run AFR are:
* IBM PC XT or 100%
compatible with 512 K of
conventional memory;
*• MS-DOS 5.0 or higher;
>• 1.44 MB floppy disk drive for
3.5" diskettes or 1.2 MB
drive for 5.25" diskettes;
>• hard disk drive with at least
6.0 megabytes free;
> color or monochrome
monitor; and
+ a variety of printers
including HP LaserJet
II/III/IV, Epson dot-matrix, or
100% compatible printers
with IBM character set (a list
of supported print drivers is
available under the AFR
Print option).
> NOTE: If you are using
the AFR icon version for
Windows™, you must have
at least 6 MB of free hard
disk memory and 4 MB of
Random Access Memory
(RAM).
AFR for DOS
AFR for DOS software is designed for use in DOS and Windows environments.
AFR for DOS is not a Windows application, but it can be accessed from
Windows through AFR icons.
AFR can be installed on a LAN, but can only be accessed by one user at a time.
System Configuration
The system file CONFIG.SYS requires a minimum of FILES=61 and
BUFFERS=30 to run the software, together with a line that increases
environment space by 1024 bytes from its current value. The install program
will check CONFIG.SYS, and request permission to make changes if necessary.
For example, if you currently reserve a default value of 256 bytes for
environment space, the install program will change CONFIG.SYS to read:
shell=c: \cotnmand. com /e:1280 /p
How to Install TRI
Automated Form R Software
The TRI Automated Form R software must be installed from the DOS prompt,
rather than from the Windows Run command.
• Place the Installation Disk into the appropriate drive and change the default
drive letter to that of your diskette drive. (If your diskette drive is A: you
would type A: and press ENTER.)
• From the DOS prompt, type INSTALL A: X: (where A: is the disk drive and
X: is the drive to which you wish to install AFR*). Then, press ENTER.
Follow the directions displayed on the screen.
• If a change was made to your CONFIG.SYS file, you will be directed to reboot
your computer. After you reboot, type C: (or the letter of the drive to which
you have installed AFR) then press ENTER.
• Type FORMR then press ENTER to start AFR for DOS.
* AFR for DOS can be installed on most networks. Please contact your network
Administrator before installing this software on your LAN. Show the
Administrator this documentation to be sure that AFR97 will be compatible with
your LAN configuration.
: * AFR97 for bOS is included in this package. AFR97 for Windows will soon be available. To request a
\' > copy, pfease call (BOO) 49O-9198
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Printing Software Documentation from DOS
Automated Form R software documentation is stored on the diskette labeled
"Installation Disk." DOSAFR.TXT is a flat ASCII text file that may be printed
from the DOS prompt or any word processor or print utility, such as Windows™
Notepad. AFRDOS.WP5 is a WordPerfect 5.1 file containing the APR for DOS
User's Guide with screen illustrations.
To print DOSAFR.TXT from DOS, place the Installation Disk into the
appropriate drive and change the default drive letter to that of your diskette
drive. (If your diskette drive is A:, you would type A: and press ENTER.) From
the DOS prompt type the command TYPE DOS APR. TXT >PRN and press
ENTER. To print AFRDOS.WP5, open it in WordPerfect, and print it directly.
Printing Software Documentation from Windows
Open Windows. Move the cursor to the selected document icon to print, then
double click to open that document. Single click on File, then highlight Print.
Single click to begin printing the selected document.
Submitting Reports on Diskette
After data entry is complete and the data is validated, the software will copy
Form R transfer files to a formatted diskette for submission to EPA. (Diskettes
must be formatted using DOS 5.0 or higher on an IBM PC or compatible
computer.) Diskettes submitted to EPA may be either 5.25-inch or 3.5-inch.
Labeling Your Submission Diskette
A label must be attached to each diskette (not its jacket). The label
may be typed or legibly handwritten. A sample label with the necessary
information is shown at right.
The types of packaging and shipping used for magnetic media are left
to the discretion of the submitting facility. Please send completed
diskettes, along with a cover letter and an original certification signa-
ture from each submitting facility to:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attn: TRI Magnetic Media Submission
Note: A copy of each Form R or Form A must be submitted to your state.
Electronic copies are acceptable for many states. (See the information in the
column to the right for more information.)
Submitting
Electronically to
States
As of the publication of this book,
the following states confirmed
that they accept electronic
submissions:
AK
AZ
CA
CO
DC
DE
FL
GA
HI
IA
ID
IL
IN
KS
LA
MD
Ml
MN
MO
MT
NC
ND
NJ
NM
NY
NV
OH
OK
OR
PA
SC
SD
UT
VA
VT
WA
Wl
WV
If your state is not listed here,
please contact your state office
to confirm that paper
submissions are required.
TRIS Report
COMPANY NAME
Date:
Report
6/29/96 Density: HD
Year: 95
Number: 1 of 1
TECHNICAL CONTACT NAME
Contact: (505) 555-5369
AFR97 for DOS is included in this package. AFR97for Windows wilt soon be available. To request a copy,
please call (8OO) 49O-9198 or download it from our web site at www.epa.gov/opptintr/afr. • " \ k, '-^ " •;;'
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Information to Include in Your Cover Letter
If you are submitting reports on magnetic diskette to EPA, you must enclose a cover letter signed by the official
listed in Section 3 of Part I of the Form R (name and official title of owner/operator or senior management official)
for each separate facility. This letter can be printed from APR. The following letter is a sample.
Date
To Whom It May Concern:
Enclosed please find one (1) diskette containing toxic
chemical release reporting information for:
YOUR FACILITY NAME
This information is submitted as required under Section
313, Title III of the Superfund Amendments and Reauthoriza-
tion Act of 1986 and the Pollution Prevention Act of 1990.
A total of two (2) reports is included from our facility,
concerning the following chemicals:
Chemical Name
RY
CAS Number
1997
1997
NA20
7440-66-6
Lead compounds
Zinc
Our technical point of contact is:
TECHNICAL CONTACT NAME, Phone Number: (505) 555-1212,
[NAME] is available should any questions or problems arise
as you process these diskettes.
I hereby certify that I have reviewed the attached
documents and that, to the best of my knowledge and belief,
the submitted information is true and complete and that the
amounts and values in this report are accurate, based on
reasonable estimates using data available to the preparers
of this report.
Signature: Chris Submitter
* - AFR97 for DOS is included in this package. AFR97 for Windows will soon be available. To request
, a copy, please call (8OO) 49O-9198 or download it from our web site at www.epa.gov/opptintr/afr.
-------
"Paperwork Reduction Act Notice: The annual public burden for this collection information is
estimated to average 52.1 hours per response for the Form R, and 34.6 hours per response for the
Form A, including the time needed to review instructions; train personnel to be able to respond to a
collection of infomation; search data sources; complete and review the collection of information; and
transmit or otherwise disclose the information. Send comments regarding the burden estimate or any
other aspect of this collection of information, including suggestions for reducting the burden to:
Director, OPPE Regulatory Information Division, U.S. Environmental Protection Agency (mail code
2137), 401 M Street, S.W., Washington, DC 20460. Include the OMB number identified above in
any correspondence. Do not send the completed form to this address. The actual information or
form should be submitted in accordance with the instructions accompanying the form, or as specified
in the corresponding regulations."
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
horm Approved OMB Numt
Approval Expires: 04/2000
Page 1 of 5
FORMR
United States
Environmental Protection
Agency
TOXIC CHEMICAL RELEASE
INVENTORY REPORTING FORM
Section 313 of the Emergency Planning and Community
Right-to-Know Act of 1986, also known as Title III of the Superfund
Amendments and Reauthorization Act
WHERE TO SEND COMPLETED FORMS:
1 EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
Enter "X" here if this
is a revision
For EPA use only I
IMPORTANT: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1.
SECTION 2.
2.1
REPORTING YEAR 19
TRADE SECRET INFORMATION
Are you claiming the toxic chemical identified on page 2 trade secret? I — i
Is this copy |
I | Yes (Answer question 2.2; I I No Do not answer 2.2; 2 2
Attach substantiation "— ' go to Section 3 *"* (Answer only If
Sanitized I I Unsanitized
"YES" in 2.1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the
submitted information is true and complete and that the amounts and values in this report are accurate based on
reasonable estimates using data available to the preparers of this report.
Name and official title of owner/operator or senior management official:
SECTION 4. FACILITY IDENTIFICAT
41
Facility or Establishment Name |
Citv/Countv/State/Zio Code
4.2
4.3
4.4
4.5
4.6
4.7
Signature:
•irtM TRI Facility ID Number I
Facility or Establishment Name or Mailing Address (if different from street address! I
Mailing Address I
J City/Countv/State/Zio Code I
This report contains Information for:
(Important: check a or b; check c if applicable)
Technical Contact Name
Public Contact Name
SIC Code(s) (4 digits)
Latitude
., Pegrees
a I I Anentire , I — I Part of a
a- I 1 facilrty b. I — I faci|i(v
DA Federal
facility
Telephone Number (include area code) I
Telephone Number (include area code) I
a.
Minutes
b. c. d.
Seconds
Dun & Bradstreet
Number(s) (9 digits)
a.
b.
Deqrees
Longitude
EPA Identification Number(s) Facility NPDES Permit
4.8 (RCRAI.D. No.) (12 characters) 4.9 Numbers) (9 characters)
a.
b.
a.
b.
e. f.
Minutes Seconds
Underground Injection Well Code
4.1 0 • (UIC) I.D. Number(s) (12 digits)
a.
b.
SECTION 5. PARENT COMPANY INFORMATION
5.1
5.2
Name of Parent Company I I NA
Parent Company's Dun & Bradstreet Number
I I NA
(9 digits)
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
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Page 2 of5
EPA FORM R
PART II. CHEMICAL - SPECIFIC INFORMATION
SECTION 1.TOXIC CHEMICAL IDENTITY
TRIFACIU7Y ID NUMBER
Toxic Chemical, Category, or Generic Name
(Important: DO NOT complete this section if you
completed Section 2 below.)
1.1
CAS NUMBER (IMPORTANT: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part I. Section 2.1 Is checked 'yes'. Generic name must be structurally, descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY
(Important: DO NOT complete this section if you
complete Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY (important: check ail that apply.)
3.1 Manufacture the toxic chemical:
3.2
Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
a.
Produce b. I I Import
c.
d.
e.
f.CZU
If produce or import:
For on-site use/processing
For sale/distribution
As a byproduct
As an impurity
As a reactant
As a formulation component
As an article component
Repackaging
a- I I As a chemical processing aid
b- I I As a manufacturing aid
c. I I Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE AT ANY TIME DURING THE
CALENDAR YEAR
4.1
(Enter two-digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
A. Total Release (pounds/year)(enter
range from instructions or estimate)
B. Basis of estimate
(enter code)
C. % From Stormwater
5.1
Fugitive or non-point
air emissions
5.2
Stack or point
air emissions
NA
NA
5.3
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
5.3.1
5.3.2
5.3.3
5.4.1
Underground Injection on-site
to Class I Wells
NAD
5.4.2
Underground Injection on-site
to Class II-V Wells
If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box I 1
and indicate which Part II, Section 5.3 page this is, here I I (example: 1,2,3, etc.)
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds; C = 500 - 999 pounds.
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Page 3 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI FACILITY ID NUMBER
Toxic Chemical. Category, or Generic Name
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
NA
A. Total Release (pounds/year) (enter range
code from instructions or estimate)
B. Basis of Estimate
(enter code)
5.5
Disposal to land on-site
5.5.1A
RCRA Subtitle C landfills
D
5.5.1B
Other landfills
5.5.2
Land treatment/application
farming ^^^
5.5.3
Surface impoundment
D
5.5.4
Other disposal
D
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1 .A. Total Quantity Transferred to POTWs and Basis of Estimate
6.1.A.1. Total Transfers (pounds/year)
(enter range code or estimate)
6.1 .A.2 Basis of Estimate
(enter code)
POTWName
6.1.B.
POTW Address
City
State
County
Zip
POTW Name
6.1.B.
POTW Address
City State County Zip
If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
in this box I I and indicate which Part II. Section 6.1 page this is here I 1 (example: 1,2,3, etc.
AMA^IM-H • ft. «& *«-i-*k • &•^•kr-^F^*-* >v-^x ^w«i i^i-k *^r"i~ r*.v^*v~ i r"v*~» ATi/"\Mt»
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
6.2 OFF-SITE EPA IDENTIFICATION NUMBER (RCRA ID NO.)
Off-Site Location Name
Off-Site Address
City
State
County
Zip
Is location under control of reporting facility or parent company?
Yes
No
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds; C = 500 - 999 pounds.
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Page 4 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TR1 FACiLTTY ID NUMBER
Toxic Chemical. Category, or Generic Name
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (continued)
A. Total Transfers (pounds/year)
(enter range code or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1.
1.
1.M
2.
2.
2.M
3.
3.
3.M
4.
4.M
6.2
OFF-SITE EPA IDENTIFICATION NUMBER (RCRA ID NO.)
Off-Site Location Name
Off-Site Address
City
State
County
Zip
Is location under control of reporting facility or parent company?
Yes
No
A. Total Transfers (pound/year)
(enter ranae code or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1.
1.
1.M
2.
2.
2.M
3.
3.
3.M
4.
4.
4.M
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
n
A I" hi fNA^ Check here if no on-site waste treatment is applied to any
Applicable (NA> - waste stream containing the toxic chemical or chemical category.
a. General
Waste Stream
(enter code)
b. Waste Treatment Method(s) Sequence
[enter 3-character code(s)]
c. Range of Influent
Concentration
d. Waste Treatment
Efficiency
Estimate
e. Based on
Operating Data?
7A.1a
7A.1c
7A.1d
7A.1e
Yes
n
No
7A.2a
7A.2b
3 r
6
7A.2C
7A.2d
7A.2e
Yes
n
No
7A.3a
7A.3c
7A.3d
7A.3e
Yes
n
No
n
7A.4a
7A.4b |
3 C
6 r
7A.4c
7A.4d
7A.4e
Yes
No
n
7A.5a
7A.5c
7A.5d
7A.5e
Yes
| 0 I I 7 I I "I I | |
If additional pages of Part II, Sections 6.277A are attached, indicate the total number of pages in this
box I I and indicate which Part II. Sections 6.2/7A page this is, here. I I (example: 1.2.3. etc.)
No
n
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
Range Codes: A= 1-10 pounds; B=11- 499 pounds; C= 500 - 999 pounds.
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page 5 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI FACILITY ID NUMBER
Toxic Chemical, Category, or Generic Name
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
DNot 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)]
1 1 1 2 1 la
I 4 I I
SECTION 7C. ON-SITE RECYCLING PROCESSES
1 1 . Not applicable (NA) - Check here if no on-site recycling is applied to any waste
stream containing the toxic chemical or chemical category.
Recycling Methods [enter 3-character code(s)]
M 1 2| 3|
I 4| 5
6 1 1 7 | 8 1 1 9 I I 10|
SECTION 8. SOURCE REDUCTION AND RECYCLING
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
8.10.1
8.10.2
8.10.3
8.10.4
8.11
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
Prior Year
(pounds/year) '
ACTIVITIES
Column B
Current Reporting Year
(pounds/year)
Quantity released to the environment as a result of remedial actions,
catastrophic events, or one-time events not associated with production
processes (pounds/year)
Production ratio or activity index
Column C Column D
Following Year Second Following Year
(poundsfyear) (pounds/year)
Did your facility 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
[enter code(s)]
Methods to Identify Activity (enter codes)
a.
a.
a.
a.
b. c.
b. c.
b. c.
b. c.
Is additional optional information on source reduction, recycling, or pollution control activities ^® NO
included with this report? (Check one box) | | | |
* Report releases pursuant to EPCRA Section 329(8) including "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. 04/97) - Previous editions are obsolete.
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(IMPORTANT: Type or print; read instructions before completing form) Form Approved: OMB #2070-0143 Form Expires: os/siyss Pagelo12
&EPA
United States
Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY
FORMA
WHERE TO SEND
THIS STATEMENT:
1. EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
Enter "X" here if
this is a revision
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1.
REPORTING
YEAR
19
SECTION 2. TRADE SECRET INFORMATION
2.1
2.2
Are you claiming the toxic chemical identified on page 2 trade secret?
Yes: Answer question 2.2 and
attach substantiation forms.
No: Do not answer 2.2; continue
with Section 3.
If you answered yes in 2.1, is this copy:
Sanitized
Unsanitized
SECTION 3. CERTIFICATION (Important: Please read and sign after completing the statement.)
I hereby certify that to the best of my knowledge and belief, for the toxic chemical listed in this statement, the annual
reportable amount, as defined in 40 CFR 372.27(a), did not exceed 500 pounds for this reporting year and that the chemical
was manufactured, processed, or otherwise used in an amount not exceeding 1 million pounds during this reporting year.
Name and official title of owner/operator or senior management official
Signature
Date Signed
SECTION 4. FACILITY IDENTIFICATION
Facility or Establishment Name
TRI Facility ID Number
Mailing Address (if different from street address)
4.1
Zip Code
Street Address
City
County
State
Zip Code
4.2
This report contains information for:
(Important: check c if applicable; a and b have been intentionally left blank)
c.n
A Federal
facility
4.3
Technical Contact
Name
Telephone Number (include area code)
EPA Form 9350-2 (Rev. 11/94)
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(IMPORTANT: Type or print; read instructions before completing form)
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A. General Information
Reporting to the Toxic Chemical Release Inventory (TRI)
is required by section 313 of the Emergency Planning
and Community Right-to-Rnow Act (EPCRA, or Title
IE of the Superfund Amendments and Reauthorization
Act of 1986), Public Law 99-499. The information con-
tained in the Form R constitutes a "report," and the
submission of a report to the appropriate authorities
constitutes "reporting."
The Pollution Prevention Act, passed into law in Octo-
ber, 1990 (Pub. L. 101-508), added reporting require-
ments to Form R. These requirements affect all facilities
required to submit Form R under section 313 of EPCRA.
The data were required beginning with reports for
calendar year 1991.
Reporting is required to provide the public with infor-
mation 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 managed on-site or trans-
ferred off-site.
A completed Form R or Form A must be submitted for
each toxic chemical manufactured, processed, or other-
wise 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 require-
ments in the reporting rule. Together with the reporting
rule, they constitute the reporting requirements. All
references in these instructions are to sections in the
reporting rule unless otherwise indicated.
A.I Who Must Report
Section 313 of EPCRA requires that reports be filed by
owners and operators of facilities that meet all of the
following criteria.
Q TheJJacility has 10 or more full-time employees;
and
Q The facility is included in Standard Industrial
Classification (SIC) Codes 20 through 39;
and
Q The facility manufactures (defined to include im-
porting), processes, or otherwise uses any listed
toxic chemical in quantities greater than the estab-
lished threshold iu the course of a calendar year.
A.2 How to Assemble a Complete Report
A.2.a The Toxic Chemical Release Reporting
Form, EPA Form R
EPA Form R consist of two parts:
Q Part I, Facility Identification Information (page 1);
and
Q Part II, Chemical-Specific Information (pages 2-5).
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 must have an original signature on the certifi-
cation statement and the trade secret designation must be
entered as appropriate. Part II must be completed sepa-
rately for each toxic chemical or chemical category. Be-
cause a complete Form R consists of at least 5 unique
pages, any submission containing less than 5 unique
pages in not a valid submission.
A complete report for any listed toxic chemical that is not
claimed as a trade secret consists of the following com-
pleted parts:
Q Part I with an original signature on the certification
statement (section 2); and
Q Part II (Note: Section 8 is mandatory).
Staple all 5 pages of each report together. If you check yes
on Part II, Section 8.11, you may attach additional infor-
mation on pollution prevention activities at your facility.
A.2.b. The Alternate Toxic Chemical Release
Inventory Form, EPA Form A
EPA Form A was established in 1994 as a simplified form
of reporting based on an alternate threshold for facilities
with low amounts of a listed toxic chemical in waste. The
Form A serves as an alternate to Form R, such that
completion of the Form A is in leu of Form R. Like the
Form Rdescribed above, the Form A consists of two parts,
but only consists of a total of 2 pages.
Q Part I, Facility Identification Information, which
also includes the "certification" regarding the
eligibility to use the Form A (page 1 and the top
of page 2); and
Q Part II, Chemical Identification (the bottom of
page 2).
Toxic Release Inventory Reporting Forms and Instructions 1
-------
As with Form R, most of the information in Part I of Form
A can be completed, photocopied, and attached to each
eligible chemical-specific report, as long as each Form A
submitted has an original signature on the certification
statement, and the appropriate trade secret designation
for the form. Part n of the Form A must be completed
separately for each toxic chemical or chemical category.
A complete report for Form A consists of 2 pages for each
submission.
A.3 Trade Secret Claims
For any toxic chemical whose identity is claimed as 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 or Form A. 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 Part I, Sections
2.1 and 2.2, and Part IE, 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:
Q A completed "unsanitized" version of a
Form R or Form A report including the toxic
chemical identity (staple the pages together);
Q A sanitized version of a completed Form R or
Form A report in which the toxic chemical iden-
tity items (Part II, Sections 1.1 and 1.2) have
been left blank but in which a generic chemical
name has been supplied (Part II, Section 1.3)
(staple the pages together);
Q A completed "unsanitized" version of a trade
secret substantiation form (staple the pages
together); and
Q A sanitized version of a completed trade
secret substantiation form (staple the pages
together).
Securely fasten all four reports together.
2 Toxic Release Inventory Reporting Forms and Instructions
Some states also require submission of both sanitized and
unsanitized reports for toxic chemicals whose identity 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 or Form A to a state agency or Indian tribe that
does not require unsanitized forms. You may identify an
individual State's submission requirements by contact-
ing the appropriate state-designated Section 313 contact
(see Appendix F).
A.4 Recordkeeping
Sound recordkeeping practices 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 must keep a copy of each report filed for at least
three years from the date of submission. These reports
will be of use in subsequent years when completing
future reports.
Facilities must also maintain those documents, calcula-
tions, worksheets, and other forms upon which they
relied to gather information for prior reports. In the event
of a problem with data elements on a facility's Form R or
Form A, EPA may request documentation from the facil-
ity that supports the information reported.
EPA may conduct data quality reviews of Form R or Form
A submissions. An essential component of this process
involves reviewing a facility's records for accuracy and
completeness.
Facilities should keep a record for those toxic chemicals
for which they did not file a Form even though they are
not required to.
A partial list of records, organized by year, that a facility
should maintain include:
Q Previous years' Form Rs and Form As;
Q Section 313 Reporting Threshold Worksheets;
Q Engineering calculations and other notes;
Q Purchase records from suppliers;
Q Inventory data;
Q EPA (NPDES) permits and monitoring reports;
Q EPCRA Section 312, Tier II Reports;
Q Monitoring records;
Q Flowmeter data;
Q RCRA Hazardous Waste Generator's Report;
Q Pretreatment reports filed by the facility with
the local government;
Q Invoices from waste management companies;
Q Manufacturer's estimates of treatment efficien-
cies;
-------
Q RCRA Manifests;
Q Process diagrams that indicate emissions and
other releases; and
Ul Record for those toxic chemicals for which they
did not file a Form.
A.5 How to Prepare a Voluntary
Revision or a Previous Submission
Voluntary revisions must be submitted by October 15th
of the same year as the reporting deadline in order for the
revised data to be included in the next TRI data release.
Revisions should be submitted on a Form R or Form A
identical to the version originally submitted to EPA for
that reporting year. The Emergency Planning and Com-
munity Right-to-Know Information Hotline can help you
identify the version of Form R or Form A used for each
reporting year.
There are two options for making voluntary revisions:
The first is to submit a photocopy of your original
submission (from your file), with the corrections made in
blue or black ink. Re-sign and re-date the certification
statement on page 1. For revisions to 1990 and earlier
reporting year submissions, write the words "VOLUN-
TARY REVISION" on page 1 of the Form. For revisions
to 1991 and later reporting year submissions, on page 1 of
the form, enter "X" in the space marked "Enter 'X' here if
this is a revision."
The second option is to obtain a blank Form for the
reporting year affected by the correction (s). Complete all
data elements on this Form. Sign and date the certifica-
tion statement on page 1. For revisions to 1990 and earlier
reporting year submissions, write the words "VOLUN-
TARY REVISION" on page 1 of the Form R. For revision
to 1991 and later reporting year submissions, on page 1 of
the form, enter "X" in the space marked "Enter 'X' here if
this is a revision."
If you submitted your Form data on magnetic media, the
EPA software allows you to revise your Form data and
submit your revisions on magnetic media as well. The
documentation provided with the magnetic media sub-
mission software contains specific instructions, or you
may call the magnetic media User Support Hotline at
(703) 816-4434. The USER Support Hotline number is to
be used for the APR Software and does not provide
regulatory support. If you submitted your Form data
using software developed by an EPA approved Form
software developer, you must contact the software devel-
oper, to determine if the software you used allows for
magnetic media revisions. Please be careful when sub-
mitting magnetic media revisions to resubmit only the
revised submissions. Do not resubmit a diskette contain-
ing all of your original submissions if you are only revis-
ing one or a few of them.
Where to Submit a VoluntaryRevision of a Pre-
vious Submission
Revisions should be submitted to EPA and the appropri-
ate state agency (or the designated official of an Indian
tribe) to whom you submitted the original Form (see
Section A.6).
Please note: submissions for the next reporting year are
NOT considered revisions of the previous year's data.
A.6 When the Report Must be
Submitted
The report for any calendar year must be submitted on or
before July 1 of the following year whether using Form R
or Form A. Any voluntary revision to a report can be
submitted anytime during the calendar year, for the
current or any previous reporting year.
A.6a Where to Send the Forms
Submissions must be sent to both EPA and the State (or
the designated official of an Indian tribe). If a Report 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 regular mail to:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attn: Toxic Chemical Release Inventory
Certified mail, Overnight mail and hand-delivered sub-
missions only should be addressed to:
EPCRA Reporting Center.
c/o Computer Based Systems Inc.
Suite 300
4600 North Fairfax Drive
Arlington, VA 22203
(703) 816-4445
Toxic Release Inventory Reporting Forms and Instructions 3
-------
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, report submissions should be
sent to the entity designated in the cooperative agree-
ment.
Submission of section 313 reports in magnetic media and
compu ter-generated facismile formats has been approved
by EPA. EPA has developed a package called the "Toxic
Chemical Release Inventory Reporting System". The
easy-to-use diskettes come with complete instructions
for their use (See 'TRI Automated Form R (APR) Software
for Reporting Year 1997" and enclosed diskettes). It also
provides prompts and messages to help you report ac-
cording 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 or Form A
reports. To ensure accuracy, EPA will only accept mag-
netic media submissions and computer-generated fac-
similes that meet basic specifications established by EPA.
To determine if the software offered by a firm meets these
specifications, EPA reviews and approves all software
upon request. Call the Emergency Planning and Com-
munity 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 or Form A. If this is the case,
a magnetic media or computer-generated facsimile may
be unacceptable.
A.7 How to Obtain Forms and Other
Information
Acopy of both Forms is included in this booklet. Remove
the appropriate form and produce as many photocopies
as needed. Related guidance documents may be obtained
from:
EPA's TRI Web Site
http://www.epa.gov/opptintr/tri
The Emergency Planning and Community
Right-to-Know Information Hotline
(address and telephone number in next column)
U.S. EPA/NCEPI
P.O. Box 42419
Cincinnati, OH 45242-2419 '
(800) 490-9198
Fax (513) 489-8695
Internet:
http://www.epa.gov/ncepihom/index.html
See Appendix H for the document request form and
more information on available documents.
Questions about completing Form R or Form A may be
directed to the Emergency Planning and Community
Right-to-Know Information Hotline at the following ad-
dress or telephone numbers.
Emergency Planning and Community
Right -to-Know Information Hotline
U.S. Environmental Protection Agency
401 M St., SW (5101)
Washington, DC 20460
(800) 535-0202, (800) 424-9346 or (703) 412-9877;
TDD# (800) 553-7672
from 9:00 am - 6:00 pm Eastern Time
(Mon.-Fri., execept Federal Holidays)
EPA Regional Staff may also be of assistance. Refer to
Appendix G for a list of EPA Regional Offices.
4 Toxic Release Inventory Reporting Forms and Instructions
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B. How to Determine If Your Facility Must Submit A Report
(See figure 1 for more information)
B.I Full-Time Employee Determination
A "full-time employee/' for purposes of section 313 re-
porting, is defined as 2,000 work hours per year. The
number of full-time employees is dependent only upon
the totalnumber 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 working for your facility, add up the hours
worked by all employees during the calendar year, in-
cluding 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 employees is 20,000 hours or more, your
facility meets the ten employee threshold.
Examples include:
Q 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 16,500 hours. The number of
full-time employees for this facility is equal to
16,500 hours divided by 2,000 hours 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.
Q 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 employees 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 the workers at the
facility (12,000 hours), plus the time worked by
the sales staff for the facility (6,000 hours), plus
the time worked by the contract employees at
the facility (2,000 hours), or 20,000 hours. Divid-
ing 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 report-
ing 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 1. The first two
digits of a4-digit SIC code define a major business sector,
while the last two digits denote a facility's specialty
within the major sector. For a detailed description of 4-
digit SIC codes, refer to the "Standard Industrial Classifi-
cation Manual 1987." The facility should determine its
own SIC code (s), based on its activities on-site, using the
SIC Manual. State agencies and other organizations may
assign SIC codes on a different basis than the one used by
the SIC Manual. However, for purposes of TRI reporting,
these state assigned codes should not be used if they
differ from ones assigned using the SIC Manual.
The EPCRA Hotline can assist facilities with determining
which SIC codes are assigned for specific business activi-
ties as referenced in the SIC Manual. Clothbound edi-
tions of the SIC Manual are available in most major
libraries or may be ordered through the National Techni-
cal Information Service, 5285 Port Royal Road, Spring-
field, VA 22161, (703) 605-6000. The access number for
the clothbound manual is PB87-100012, and the price is
$30.00.
The North American Industry Classification System
(NAICS), is a new economic classification system that
will replace the 1987 SIC Code system. EPA will address
the SIC code change, as it relates to EPCRA in an upcom-
ing Federal Register notice. This upcoming change does
NOT affect the 1997 EPCRA section 313 reporting.
B.2.a Multi-Establishment Facilities
Your facility may include multiple establishments that
have different SIC codes. A multi-establishment facility
is a facility that consists of two or more distinct and
separate economic units. If your facility is a multi-
establishment facility, 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:
Q If the total value of the products shipped from or
produced at establishments with primary SIC
codes between 20 and 39 is greater than 50 per-
cent of the value of the entire facility's products
and services, the entire facility meets the SIC
code criterion.
Toxic Release Inventory Reporting Forms and Instructions 5
-------
Figure 1
Determining Applicability of Section 313 Requirements
Does your facility have 10
or more full-time
employees?
(see definition on page 5}
Yes i'
No
Is your facility classified
under SIC codes
20 through 39?
(see Table I, pages 1-1 -1-7)
Ves
No
Reporting is not required
'' for any chemical at the '
| facility for this year. |
Does your facility
manufacture, process, or
otherwise use any listed
chemical or chemical
category?
(see Table II, pages 1-1 -1-23)
yes
Manufacture or Process
No .
yes
Otherwise Use
1
Did your facility
otherwise use more than
10,000 pounds of
the chemical in
the calendar year?
yes
No
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.
6 Toxic Release Inventory Reporting Forms and Instructions
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Q If any one establishment with a primary SIC code
between 20 and 39 produces or ships products
whose value exceeds the value of products and
services produced or shipped by any other estab-
lishment within the facility, the facility also meets
the SIC code criterion.
The value of production attributable to aparticular estab-
lishment may be isolated by subtracting the product
value obtained from other establishments within the
same facility from the total product value of the facility.
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:
Q 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, amalgamation,
cyanidation, and the production of bullion at the
mine and mill sites (these processes are classified
under SIC code 1041, which is not a covered SIC
code in reporting year 1997). 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 sepa-
rate 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 3339).
Q A food processing establishment in a facility
processes crops grown at the facility in a separate
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 es-
tablishment, and then calculate the contribution
of the food processing establishment by subtract-
ing the crop value from the total value of the
product shipped from the processing establish-
ment (Value of product shipped from processing
- crop value = value of processing establishment)
A covered multi-establishment facility must make toxic
chemical threshold determinations and, if required, must
report all relevant information about releases, source
reduction, recycling, and waste managment activities
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 estab-
lishments in a multi-establishment facility can be, for all
practical purposes, separate business units. Therefore,
individual establishments may report releases and other
waste management activities separately, provided that
the total releases for the whole facility is represented by
the sum of the quantities and other quantities managed as
waste reported by the separate establishments and the
compliance determination is based on the entire facility.
B.2.b Auxiliary Facilities
An auxiliary facility is one that supports another facility's
activities (e.g., research and development laboratories,
warehouses, and storage facilities). 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 become 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 manu-
facture, process, or otherwise use.
B.2.c Property Owners
You are not required to report if you merely own real
estate on which a facility covered by this rule is located;
that is, you have no other business interest in the opera-
tion of that facility (e.g., your company owns an indus-
trial park). The operator of that facility, however, is
subject to reporting requirements.
B.3 Activity Determination
B.S.a Definitions of "Manufacture,"
"Process," and "Otherwise Use"
Manufacture: The term "manufacture" means to pro-
duce, prepare, compound, or import a listed 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, ihen you have
imported the chemical when that shipment arrives at
Toxic Release Inventory Reporting Forms and Instructions 7
-------
your facility directly from a source outside of the United
States. By ordering the chemical, you have "caused it to
be imported," even though you may have used an import
brokerage firm as an agent to obtain the toxic chemical.
Do Not Overlook Coincidental Manufacture
The term manufacture also includes coincidental produc-
tion of a toxic chemical (e.g., as a byproduct or impurity)
as a result of the manufacture, processing, otherwise use,
or treatment of other chemical substances. In the case of
coincidental production of an impurity (i.e., a toxic chemi-
cal that remains in the product that is distributed in
commerce), the de minimis exemption, discussed in Sec-
tion B.4.b of these instructions, applies. The de minimis
exemption does not apply to byproducts (e.g., a toxic
chemical that is separated from a process stream and
further processed or disposed). Certainlisted toxic chemi-
cals may be manufactured as a result of wastewater
treatment or other treatment processes. For example,
neutralization of acid wastewater can result in the coinci-
dental manufacture of ammonium nitrate (solution).
Process: The term "process" means the preparation of a
listed section 313 chemical, after its manufacture, for
distribution in commerce. Processing is usually the in-
tentional incorporation of a section 313 chemical into a
product (see Part IE, Section 3.2 of these instructions for
further clarification). Processing includes preparation of
the toxic chemicals in the same physical state or chemical
form as that 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 instruc-
tions) that contains a listed section 313 chemical as one
component.
Example 1: Coincidental Manufacture
Your company, a nitric acid manufacturer, uses aque-
ous ammonia in a waste treatment system to neutralize
an acidic wastewater stream containing nitric acid.
The reaction of ammonia and nitric acid produces a
solution of ammonium nitrate. Ammonium nitrate is
reportable under the nitrate compounds category and
is manufactured as a byproduct. If the ammonium
nitrate is produced in a quantity that exceeds the
25,000 pound manufacturing threshold, the facility
must report under the nitrate compounds category.
The aqueous ammonia is considered to be otherwise
used and 10% of the total aqueous ammonia would be
counted towards the 10,000 pound use threshold.
Reports for releases of ammonia must also include 10%
of the total aqueous ammonia from the solution of
ammonium nitrate (see the qualifier for the ammonia
listing).
Combustion of coal and/or fuel in boilers/furnaces
can result in the coincidental manufacture of metal
compounds and sulfuric acid (acid aerosols), hydro-
chloric acid (acid aerosols) and hydrogen fluoride.
Otherwise Use: The term "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
facility is not intentionally incorporated into a product
distributed in commerce (see Part II, Section 3.3 of these
Instructions for further clarification).
Example 2: Typical Process and Manufacture Activities
Q Your company receives toluene, a listed section 313 chemical, from another facility, and reacts the toluene
with air to form benzoic acid, which the company distributes in commerce. Your company processes
toluene and manufactures and processes benzoic acid. Benzoic acid, however, is not a listed section 313
chemical and thus does not trigger reporting requirements.
Q Your facility combines toluene purchased from a supplier with various materials to form paint. Your
facility processes toluene.
Q Your company receives a nickel compound (nickel compounds is a listed section 313 chemical category)
as a bulk solid and performs various size-reduction operations (e.g., grinding) before packaging the
compound in 50 pound bags, which the company sells. Your company processes the nickel compound.
Q 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 section 313 chemical that becomes incorporated into the
plastic, which the company distributes in commerce. Your facility processes the toxic chemical.
8 Toxic Release Inventory Reporting Forms and Instructions
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Examples: Otherwise Use
When your facility cleans equipment with toluene, you
are otherwise using toluene. Your facility also sepa-
rates 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.
B.S.b Activity Exemptions
Otherwise Use Exemptions. Certain otherwise uses of
listed section 313 chemicals are specifically exempted:
Q otherwise use as a structural component of the
facility;
Q otherwise use in routine janitorial or facility
grounds maintenance;
Q personal uses by employees or other persons;
Q otherwise use of products containing toxic chemi-
cals for the purpose of maintaining motor ve-
hicles operated by the facility; or
Q otherwise use of toxic chemicals contained in
intake water (used for processing or non-contact
cooling) or in intake air (used either as com-
pressed air or for combustion).
The exemption of otherwise use of a chemical 1) as a
structural component of the facility; or 2) in routine jani-
torial or facility grounds maintenance; or 3) for personal
use by an employee cannot be taken for activities involv-
ing process-related equipment.
Article Exemption. Listed toxic chemicals contained in
articles that are processed or otherwise used at a covered
facilitiy are exempt from threshold determinations and
release and other waste management determinations.
The exemption applies when the facility receives the
article from another facility or when the facility produces
the article itself. The exemption applies only to the
quantity of toxic chemical present in the article. If the
toxic chemical is manufactured (including imported),
processed, other otherwise used at the covered facility
other than as part of the article, in excess of an applicable
threshold quantity, the facility is required to report (40
CFR Section 372.38(b)). For a toxic chemical in an item to
be exempt as part of the article, the item must meet all the
following criteria in the Section 313 article definition; that
is, it must be 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 during end use, and that does not release
a toxic chemical under normal circumstances of process-
ing or otherwise use of the item at the facility.
If the processing or otherwise use of all like manufactured
items at a facility results in a total release of 0.5 pounds or
less of a toxic chemical in a reporting year to any environ-
mental media, EPA will allow this release 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
limit does not apply to each individual article, but applies
to the sum of all releases from processing or otherwise use
of all like articles. If all the releases of like articles over a
reporting year are completely captured and sent for
recycling/reuse on-site or off-site, the items may remain
exempt as articles. Any amount that is released and is not
recycled/reused will count toward the 0.5 pound per
year cut-off value.
Example 4: Article Exemption
Lead that is incorporated into a lead acid battery is processed to manufacture the battery, and therefore must
be counted toward threshold determinations and release and other waste management determinations.
However, the use of the lead 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.
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-
f oot 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 Forms and Instructions 9
-------
The article exemption applies to the normal processing or
otherwise use of an article. This exemption does not
apply to the manufacture of the article. Toxic chemicals
processed into articles produced at a facility must be
factored into threshold and release determinations.
If, as a result of processing or otherwise use, an item
retains its initial thickness or diameter, in whole or in
part, it meets the first part of the definition. If the item's
basic dimensional characteristics are totally altered dur-
ing processing or otherwise use, the item does not meet
the first part of the definition. An example of items that
do not meet the definition would be items which are cold
extruded, such as lead ingots which are formed into wire
or rods. On the other hand, cutting a manufactured item
into pieces which are recognizable as the article would
not change the orginial dimensions as long as the diam-
eter or the thickness of the item remained the same; the
article exemption would continue to apply. Metal wire
may be bent and sheet metal may be cut, punched,
stamped, or pressed without losing their article status as
long as the diameter of the wire or tubing or the thickness
of the sheet are not totally changed.
An important aspect of the article exemption is what
constitutes a release of a toxic chemcal. Any processing or
otherwise use of an article that results in a release to the
environment (of more than 0.5 pounds) negates the ex-
emption. Cutting, grinding, melting, or other processing
of a manufactured item could result in a release of a toxic
chemical during normal conditions of processing or oth-
erwise use and therefore, negate the exemption as an
article. Scrap pieces which are recognizable as an article
do not constitute a release.
De Minimis Exemption. The de minimis exemption
allows facilities to disregard certain minimal concentra-
tions of chemicals in mixtures or trade name products
they process or otherwise use when making threshold
determinations and release and other waste management
determinations. The de minimis exemption does not ap-
ply to the manufacture of a toxic chemical except if that
toxic chemical is manufactured as an impurity and re-
mains in the product distributed in commerce, or if the
toxic chemical is imported below the appropriate de
minimis level. The de minimis exemption does not apply
to a byproduct manufactured coincidentally as a result of
manufacturing, processing, otherwise use, or any waste
management activities.
When determining whether the de minimis exemption
applies to a listed toxic chemical, the owner/operator
should consider only the concentration of the toxic chemi-
cal in mixtures and trade name products in process
streams in which the toxic chemical is undergoing a
reportable activity. If the toxic chemical in a process
stream is manufactured as an impurity, imported, pro-
cessed, or otherwise used and is below the appropriate de
minimis concentration level, then the quantity of the toxic
chemical in that process stream does not have to be
applied to threshold determinations nor included in re-
lease or other waste management determinations. If a
toxic chemical in a process stream is below the appropri-
ate de minimis level, all releases and other waste manage-
ment activities associated with the toxic chemical in that
stream are exempt from EPCRA Section 313 reporting. It
is possible to meet an activity (e.g., processing) threshold
for a toxic chemical on a facility-wide basis, but not be
required to calculate releases or other waste management
quantities associated with a particular process because
that process involves only mixtures or trade name prod-
ucts containing the toxic chemical below the de minimis
level.
Once a toxic chemical concentration is above the appro-
priate de minimis level in the process stream, threshold
determinations and release and other waste management
determinations must be made, even if the chemical later
falls below the de minimis level in the same process
stream. Thus, all releases and other quantities managed
as waste that occur after the de minimis level has been
exceeded are subject to reporting. If a toxic chemical in a
mixture or trade name product above de minimis is
brought on-site, the de minimis exemption never applies.
The 0.1% de minimis levels are dictated by determina-
tions made by the National Toxicology Program (NTP),
Annual Report on Carcinogens, the International Agency
for Research and Cancer (IARC) Monographs, or 29 CFR
part 1910, subpart Z. Therefore, once a chemical's status
under NTP, IARC, or 29 CFR part 1910, subpart Z indi-
cates that the chemical is a carcinogen or potential car-
cinogen, the reporting facility may disregard levels of the
chemical below the 0.1% de minimis concentration pro-
vided that the other criteria for the de minimis exemption
is met. De minimis levels for chemical categories apply to
the total concentration of all chemicals in the category
within a mixture, not the concentration of each individual
category member within the mixture.
De Minimis Application to the Processing or Otherwise Use of
a Mixture
The de minimis exemption applies only to the processing
or otherwise using, of a listed toxic chemical in a mixture.
Threshold and release calculations begin at the point
where the chemical exceeds de minimis. If a listed toxic
chemical is present in a mixture at a concentration below
the de minimis level, this quantity of the substance does
not have to be included for threshold determination,
10 Toxic Release Inventory Reporting Forms and Instructions
-------
release and other waste management reporting, or sup-
plier notification requirements. The exemption will ap-
ply as long as the mixture containing de minimis amounts
of a toxic chemical never goes above the de minimis limit.
Also, see below the two examples in which a manufactur-
ing activity would qualify for the de minimis exemption.
Examples of Process and Otherwise Use Scenarios
There are many cases in which the de minimis "limit" is
crossed or recrossed within a process or otherwise use
scenario. The following examples are meant to illuminate
these complex reporting scenarios.
Example of Increasing Process Concentration to Above De
minimis Levels
A manufacturing facility receives toluene which contains
less than the de minimis concentration of chlorobenzene.
Through distillation, the chlorobenzene content in pro-
cess streams is increased over the de minimis concentra-
tion of 1 percent. From the point at which the
chlorobenzene concentration exceeds 1 percent in pro-
cess streams, the amount present must be factored into
threshold determinations and release and other waste
management estimates. The facility does not need to
consider the amount of chlorobenzene in the raw mate-
rial, i.e., when below de minimis levels, when making
threshold determinations. The facility does not have to
report emissions of chlorobenzene from storage tanks or
any other equipment where the chlorobenzene content is
less than 1 percent.
Example of Fluctuating Process Concentration
A manufacturer produces an ink product which contains
toluene, a listed toxic chemical below the de minimis
level. The process used causes the percentage of toluene
in the mixture to fluctuate: it rises above the de minimis
level for a time but drops below the level as the process
winds down. The facility must consider the chemical
toward threshold determinations from the point at which
it first exceeds the de minimis limit. Once the de minimis
limit has been crossed the exemption cannot be taken.
Example of Concentration Levels that Straddle the De Minimis
Level
A facility processes 9,500,000 Ibs. of mixtures containing
0.25-1.2% manganese. Manganese is subject to 1% de
minimis concentration exemption. The amount of mix-
ture subject to reporting is:
9,500,000 x (1.2-0.99)7(1.2-0.25) = 2,000,000 Ibs. non-ex-
empt mixture
The average concentration above de minimis is 1.1%.
2,000,000 x 0.011 manganese = 22,000 Ibs manganese
(below threshold)
In this example, because the facility's information per-
taining to the toxic chemical is available to two significant
figures, the facility used 0.99 to determine the amount of
the toxic chemical below the de minimis level. If the
facility has information pertaining to the chemical that is
available only to one significant figure, the facility should
use 0.9.
De Minimis Application in the Manufacture of the Listed
Chemical in a Mixture
The de minimis exemption generally does not apply to
the manufacturing of a toxic chemical. The de minimis
exemption may apply to mixtures and trade name prod-
ucts containing toxic chemicals that are imported into the
United States. Another exception applies to toxic chemi-
cals that are coincidentally manufactured as impurities
that remain in the product distributed in commerce at
below the de minimis levels. The amount remaining in
the product is exempt from threshold determinations. If
the chemical is separated from the final product, thereby
classifying the chemical as a byproduct, it cannot qualify
for the exemption. Any amount that is separated, or is
separate, from the product, is considered a byproduct
and is subject to threshold determinations and release
and other waste management estimates. Any amount of
a toxic chemical that is manufactured in a wastestream
must be accounted for on Form R.
Example of Coincidental Manufacture as a Product Impurity
Toluene 2,4-diisocyanate reacts with water to form trace
quantities of 2,4-diaminotoluene. The resulting product
contains 99 percent toluene 2,4-diisocyanate and 0.05
percent 2,4-diaminotoluene. The 2,4-diaminotoluene
would not be subject to Section 313 reporting nor would
supplier notification be required because the concentra-
tion of 2,4-diaminotoluene is below its de minimis con-
centration of 0.1 percent in the product. Coincidental
manufacture/production refers only to production of a
chemical via a chemical reaction. It would not include
separation of a byproduct from a purchased mixture
during a processing operation.
Example of Coincidental Manufacture as a Commercial
Byproduct and Impurity
Chloroform is a reaction byproduct in the production of
carbon tetrachloride. It is removed by distillation to a
concentration of less than 150 ppm (0.0150%) remaining
in the carbon tetrachloride. The separated chloroform at
Toxic Release Inventory Reporting Forms and Instructions 11
-------
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12 Tox/c Release Inventory Reporting Forms and Instructions
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90 percent concentration is sold as a byproduct. Chloro-
form is subject to a 0.1% (1000 ppm) de minimis level. Any
amount of chloroform manufactured and separated as
byproduct must be included in threshold determinations
because the de minimis exemption does not apply to
manufacture of a chemical. Releases of chloroform prior
to and during purification of the carbon tetrachloride
should be reported. The de minimis level can, however, be
applied to the chloroform remaining in the carbon tetra-
chloride as an impurity. Because the concentration of
chloroform remaining in the carbon tetrachloride is below
the de minimis level, this quantity of chloroform is ex-
empt from threshold determinations, release and other
waste management reporting, and supplier notification.
Example of Coincidental Manufacture as a Waste Byproduct
A small amount of formaldehyde is manufactured as a
reaction byproduct during the production of phthalic
anhydride. The formaldehyde is separated from the ph-
thalic anhydride as a waste gas and burned, leaving no
fomaldehyde in the phthalic anhydride. The amount of
formaldehyde produced and removed as waste must be
included in threshold determinations and release and
other waste management estimates even if the formalde-
hyde were present below the de minimis level in the
process stream where it was manufactured or in the
wastestream to which it was separated.
The de minimis exemption also does not apply to situa-
tions where the manufactured chemical is released or
transferred to wastestreams and thereby diluted to below
the de minimis level.
Laboratory Exemption
Laboratory Activities: Listed toxic chemicals that are
manufactured, processed, or otherwise used in labora-
tory activities at a covered facility under the direct super-
vision 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.
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:
Q 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:
Q 10,000 pounds during the course of a calendar
year.
B.4.a How to Determine If Your Facility Has
Exceeded Thresholds
To determine whether your facility has exceeded a sec-
tion 313 reporting threshold, compare quantities 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
worksheet is not required and the completed worksheet(s)
should not accompany Form R reports submitted to EPA
and the State.
Complete a separate worksheet for each section 313 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
throughout the facility. Pure forms as well 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 totaled for each activity to identify the
overall amount of the toxic chemical or chemical category
manufactured (including imported), processed, or other-
wise 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.
Toxic Release Inventory Reporting Forms and ^Instructions 13
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Step 2 is intended for use when one form or use of the toxic
chemical is exempt while other forms require reporting.
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 exempted amounts
of the toxic chemical or chemical categories at tihe 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 to document your determination for reporting or not
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 threshold and thus is not required to report for
that chemical.
You must submit a report if you exceed any threshold for
any listed toxic chemical or chemical category. For ex-
ample, 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
use threshold (10,000 pounds) and your facility must
report even though it did not exceed the process thresh-
old. 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.
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 calen-
dar 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 only
20,000 pounds is applied to a process, only the 20,000
pounds processed is counted toward a threshold deter-
mination, not the entire 100,000 pounds of the stockpile.
Threshold Determinations for On-Site Reuse
Operations.
Threshold determinations of listed toxic chemicals that
are 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 oper-
ates a refrigeration unit that contains 15,000 pounds of
anhydrous ammonia at the beginning of the year. The
system is charged with 2,000 pounds of anhydrous am-
monia during the year. The facility has therefore "other-
wise used" only 2,000 p ounds of the covered toxic chemical
and is not required to report (unless there are other
"otherwise use" activities of ammonia which, when taken
together, exceed the reporting threshold). If, however,
the whole refrigeration unit was recharged with 15,000
pounds of anhydrous ammonia during the year, the
facility would exceed the otherwise use threshold, and be
required to report.
This does not apply to toxic chemicals "recycled" off-site
and returned to a facility. Such toxic chemicals returned
to a facility are treated as the equivalent of newly pur-
chased material for purposes of section 313 threshold
determinations.
Threshold Determinations for Ammonia.
The listing for ammonia now includes the modifier "in-
cludes anhydrous ammonia and aqueous ammonia from
water dissociable ammonium salts and other sources; 10
percent of total aqueous ammonia is reportable under this
listing". The qualifer for ammonia means that anhydrous
forms of ammonia are 100 percent reportable and aque-
ous forms are limited to 10 percent of total aqueous
ammonia. Therefore, when determining threshold quan-
tities, 100 percent of anhydrous ammonia is included but
only 10 percent of total aqueous ammonia is included . If
any ammonia evaporates from aqueous ammonia solu-
tions, 100 percent of the evaporated ammonia is included
in threshold determinations.
For example, if a facility processes aqueous ammonia it
has processed 100 percent of the aqueous ammonia in that
solution. If the ammonia remains in solution, then 10% of
the total aqueous ammonia is counted towards threshold.
If there are any evaporative losses of anhydrous ammo-
nia, then 100 percent of those losses must be counted
towards the processing threshold. If the manufacturing,
processing, or otherwise use threshold for the ammonia
listing are exceeded, the facility must report 100 percent of
these evaporative losses in Sections 5 and 8 of the Form R.
Threshold Determinations for Chemical
Categories.
A number of chemical compound categories are subject to
reporting. See Table II for a listing of these toxic chemical
categories. When reporting for one of these toxic chemi-
cal categories, all individual members of a category that
are manufactured, processed, or otherwise used must be
counted. However, threshold determinations must be
made separately for each of the three activities. Do not
14 Toxic Release Inventory Reporting Forms and Instructions
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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 in solvent 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.e., (80%-50%)/2 + 50% = 65%).
3) Multiply total weight of Solvent X otherwise used by 65 percent (0.65).
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 percent 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 II, Section 2.1, "Mixture Component Identity." (Note: Because your supplier
is claiming the toxic chemical identity a trade secret, you do not have 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 concentration is estimated to be 90 percent (i.e., the mid-point between
upper and lower limits).
(100%+80%)/2=90%
3) The total weight of Solvent Y is multiplied by 90 percent (0.90) 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.
Toxic Release Inventory Reporting Forms and Instructions 15
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include in these threshold determinations for a category
any chemicals that are also specifically listed section 313
toxic chemicals (see Table n) or specific toxic chemicals
that have been deleted from the category (e.g., a class of
copper phthalocyanine compounds has been deleted from
the copper compounds category). Specifically listed
toxic chemicals are subject to their own, individual thresh-
old determination.
Threshold determinations for metal-containing com-
pounds present a special case. If, for example, your
facility processes several different lead 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 bothbecause they are separately listed toxic
chemicals. If your facility exceeds thresholds for both the
parent metal and compounds of that same metal, EPA
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. If you file one combined report, you must put
either the name of the metal or the name of the metal
compound category on the Form R. Do not put both
names on the Form R.
The case of metal compounds involving more than one
metal 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 compounds and one for chromium com-
pounds. Apply the total weight of the lead chromate to
the threshold determinations for both lead compounds
and chromium compounds. However, only the amount
of each parent metal released (not the amount of the
compound) would be reported on the appropriate sec-
tions of both Form Rs.
Nitrate Compounds (water dissociable; reportable only
when in aqueous solution). For the category nitrate
compounds (water dissociable; reportable only when in
aqueous solution), the entire weight of the nitrate com-
pound is counted towards the threshold. A nitrate
compound is covered by this listing only when in water
and only if dissociated. If no information is available on
the identity of the type of nitrate that is manufactured
processed or otherwise used, assume that the nitrate
compound exists as sodium nitrate.
B.4.b Mixtures and Trade Name Products
Toxic chemicals contained in mixtures and trade name
products must be factored into threshold determinations
and release and other waste management determina-
tions.
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 deter-
minations. If you know that a mixture contains a toxic
chemical but no concentration information is provided
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.
Observe the following guidelines in estimating concen-
trations of toxic chemicals in mixtures when only limited
information is available:
Q 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.
Q 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.
Q If you have no information other than the lower
bound concentration, calculate a midpoint as-
suming an upper bound concentration of 100
percent.
Q If you only know the upper bound concentration,
you must use it for threshold determinations.
Q In cases where you only have a concentration
range available, you should use the midpoint of
the range extremes.
16 Toxic Release Inventory Reporting Forms and Instructions
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B.5 Release and Other Waste Management
Determinations for Metals, Metal Com-
pounds, and Nitrate Compounds (wa-
ter dissociable; reportable only when in
aqueous solution)
Metal Compounds. Although the complete
weight of the metal compound must be used for
threshold determinations for the metal compound
categories, for release and other waste manage-
ment determinations, only the parent metal por-
tion of the metal compound must be considered.
Remember that for metal compounds that con-
sist of more than one metal, release and other
waste management reporting must be made for
each metal, provided that the appropriate thresh-
olds have been exceeded.
Metals and Metal Compounds. As stated above,
for metal compounds only the metal portion of
the metal compound should be considered in
determining release and other waste manage-
ment quantities for the metal compound catego-
ries. Therefore, if thresholds are separately
exceeded for the "parent" metal and its com-
pounds. EPA allows you to file a combined Form
R for the "parent" metal and its compounds. This
Form R would contain all of the release and other
• waste management information for both the "par-
ent" metal and metal portion of the related metal
compounds. For example, you exceed thresh-
olds for chromium. You also exceed thresholds
for chromium compounds. Instead of filing two
Form Rs you can file one combined Form R. This
Form R would contain information on quantities
of chromium released or otherwise managed as
waste and the quantities of the chromium por-
tion of the chromium compounds released or
otherwise managed as waste. Note that this does
not apply to the Form A. See the section in these
instructions on the Form A.
Nitrate Compounds (water dissociable; report-
able only in aqueous solution). Although the
complete weight of the nitrate compound must
be used for threshold determinations for the
nitrate compounds category, for release and other
waste management determinations only the ni-
trate portion of the compound must be consid-
ered.
Toxic Release Inventory Reporting Forms and Instructions 17
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C. Instructions for Completing EPA Form R
Parti. Facility Identification Information Section 4. Facility Identification
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 1997 reporting year must be
submitted on or before July 1,1998.
Section 2. Trade Secret Information
2.1 Are you claiming the chemical identity on
page 1 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 Section 2.2. Only
check "yes" if it is youmanufacture, process, 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 tihe 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 iden-
tity 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 title 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 com-
pleted.
4.1 Facility Name, Location, and TRI Facility
Identification Number
Enter the name of your facility (plant site name or appro-
priate facility designation), street address, mailing ad-
dress, 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 the
location 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 a pre-printed page 1 of the Form R that is attached
to the cover of this Toxic Chemical Release Inventory
Instructions for 1997. Please do not destroy this page 1.
When completing your Form R reports for 1997, you may
use this pre-printed page 1 instead of filling out a new
page one.
If your pre-printed page 1 is missing information re-
quired on Form R, insert that information in the appropri-
ate box in Part I, Section 4.1. For example, if your
pre-printed page 1 contains your street address and not
your mailing address, enter your mailing address in the
space provided.
If you do not have a pre-printed page 1, but know your
TRI Facility Identification Number, complete Section 4. If
you do not know your TRI Facility Identification Num-
ber, contact the EPCRA Hotline (see page 4). If your
facility has moved do not enter your TRI facility identifi-
cation number, enter "New Facility."
Enter "NA" in the space for the TRI Facility Identification
number 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 other waste
management activities and source reduction activities of
a listed toxic chemical if it meets a reporting threshold for
that toxic chemical. However, if the facility is composed
of several distinct establishments, EPA allows these es-
tablishments to submit separate reports for the toxic
chemical as long as all releases and other waste manage-
ment activites 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.
18 Toxic Release Inventory Reporting Forms and Instructions
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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 other
waste management activities and source reduction ac-
tivities involving the toxic chemical from the entire facil-
ity 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 establishment or group of establishments
does not manufacture, process, or otherwise use or re-
lease or otherwise manage as waste a toxic chemical, you
do not have to submit a report for that establishment or
group of establishments. (See also Section B.2a 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; how-
ever, 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
and does not necessarily need to be someone at the
location of the reporting facility. If this space is left blank,
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 facili-
ties that fall within SIC codes 20 to 39. If you do not know
your SIC code, consult the 1987 SIC Manual (see pg. 5).
The North American Industry Classification System
(NAICS), is a new economic classification system that
will replace the 1987 SIC code system. EPA will address
the SIC code change, as it relates to EPCRA, in an upcom-
ing Federal Register notice. This upcoming change does
NOT affect the 1997 EPCRA section 313 reporting.
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 blue-
prints, and site plans. Instructions on how to determine
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 Com-
pleting Form R Reports).
4.7 Dun and Bradstreet Number
Enter the 9-digit number assigned by Dun and Bradstreet
(D & B) for your facility or each establishment within your
facility. These numbers code the facility for financial
purposes. This number may be available from your
facility's treasurer or financial officer. You can also obtain
the numbers from your local Dun and Bradstreet office
(check the telephone book 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 (610) 882-7748 (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.
Toxic Release Inventory Reporting Forms and Instructions 19
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4.8 EPA Identification Number
5.1 Name of Parent Company
The EPA I.D. Number is a 12-character number assigned
to facilities covered by hazardous waste regulations un-
der the Resource Conservation and Recovery Act (RCRA).
FacUities 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.
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) identification
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, NA,
in Section4.10a. 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
Bestchem Corporation is not owned or controlled by any
other corporation but has sites throughout the country
whose names begin with Bestchem. In this case, Bestchem
Corporation would be listed as the parent company.
Note that a facility that is a 50:50 joint venture is its own
parent company.
Enter the name of the corporation or 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.
Part II. Chemical Specific Information
In Part II, you are to report on:
Q The toxic chemical being reported;
Q The general uses and activities involving the
toxic chemical at your facility;
Q Releases of the toxic chemical from the facility to
air, water, and land;
Q Quantities of the toxic chemical transferred to
off-site locations;
Q Information for on-site and off-site waste treat-
ment, energy recovery, disposal, and recycling of
the toxic chemical; and
Q Source reduction activities.
Section 1. Toxic Chemical Identity
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS) registry num-
ber in Section 1.1 exactly as it appears in Table II for the
chemical being reported. CAS numbers are cross-refer-
enced 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 Chlorophenols
N090 Chromium compounds
20 Toxic Release Inventory Reporting Forms and Instructions
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N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N171 Ethylenebisdithiocarbamic acid,
salts and esters, (EBDCs)
N230 Certain Glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes
N590 Polycyclic aromatic compounds
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N874 Warfarin and Salts
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 it appears in Table II. If the toxic chemical 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 actually a product trade name (e.g., dicof ol),
the 9th Collective Index name 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 generic name in
Part II, Section 1.3 of your sanitized Form R report.
Example 6: Mixture Containing Unidentified
Toxic Chemical
Your facility uses 20,000 pounds of a solvent that your
supplier has told you contains 80 percent "chlorinated
aromatic," their generic name for a toxic chemical subject
to reporting under section 313. You therefore know that
you have used 16,000 pounds of some listed toxic chemi-
cal which exceeds the "otherwise use" threshold. You
would file a Form R and enter the name "chlorinated
aromatic" in the space provided in Part II, Section 2.
EPA requests that the toxic chemical, chemical category,
or generic name also be placed in the box marked "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.
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 form if you complete this section. You do not need
to supply trade secret substantiation forms for this toxic
chemical because it is your supplier who is claiming the
chemical identity a trade secret.
Toxic Release Inventory Reporting Forms and Instructions 21
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2.1 Generic Chemical Name Provided by
Supplier
Enter the generic chemical name in this 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 component.
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 (see example 7,pg.
23, and figure 3, pg. 24). You are not required to report on
Form R the quantity manufactured, processed or other-
wise used. Report activities that take place only at your
facility, not activities that take place at other facilities
involving your products. You must check all 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 instruc-
tions or Part 40, Section 372.3 of the Code of Federal Regu-
lations 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.S.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 manufacture, 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 as a result of waste management are also
considered byproducts.
f. As an impurity - the toxic chemical is produced
coincidentally as a result of the manufacture,
processing, or otherwise use 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 (incorpo-
rative activities)
a. As a reactant - A natural or synthetic toxic chemi-
cal used in chemical reactions for the manufac-
ture of another chemical substance or of a product.
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 dis-
tributed for industrial, trade, or consumer use.
One example is the pigment components of paint
applied to a chair that is sold.
d. Repacfaging - Processing or preparation of a toxic
chemical (or product mixture) for distribution in
commerce in a different form, state, or quantity.
22 Toxic Release Inventory Reporting Forms and Instructions
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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 chemical processing aid - A toxic chemical that
is added to a reaction mixture to aid in the manu-
facture or synthesis of another chemical sub-
stance but is not intended to remain in or become
part of the product or product mixture. Ex-
amples of such toxic chemicals include, but are
not limited to, process solvents, catalysts, inhibi-
tors, initiators, reaction terminators, and solu-
tion buffers.
b. Asa manufacturing aid - 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, refrig-
erants, 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,
toxic chemicals used for treating wastes, and
toxic chemicals used to treat water at the facility.
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 codes
below) that indicates the maximum quantity of the toxic
chemical (e.g., in storage tanks, process vessels, on-site
shipping containers or in waste) at your facility at any
time during the calendar year. If the toxic chemical was
present at several 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 maximum
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
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 10,000 pounds, respectively) have been exceeded and the reporting of listed toxic
chemicals is therefore required.
Your facility manufactures diazomethane. Fifty percent is sold as a product. The remaining 50 percent is reacted
with alpha-naphthylamine, forming N-methyl-alpha-naphthylamine and also producing nitrogen gas.
Q Your company manufactures diazomethane, a listed toxic chemical, both for sale/distribution as a
commercial product and for on-site use/processing as a feedstock in the N-methyl-alpha-naphthylamine
production process. Because the diazomethane is a reactant, it is also processed. See Figure 3 for how this
information would be reported in Part II, Section 3 of Form R.
Q Your facility also processes alpha-naphthylamine, as a reactant to produce N-methyl-alpha-naphthy-
lamine, a chemical not on the section 313 list.
Toxic Release Inventory Reporting Forms and Instructions 23
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Figure 3
Qirr
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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., nickel compounds), include all chemical compounds
in the category when calculating the maximum amount,
using the entire weight of each compound.
Section 5. Quantity of the Toxic Chemical
Entering each Environmental
Medium
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.
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
f romplastic products in storage do not have to be counted
in estimates of releases of that toxic chemical from the
facility.
All releases of the toxic chemical to the air must be
classified as either point or non-point emissions, and
included in the total quantity reported for these releases
in Sections 5.1 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 must 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 emis-
sions. Engineering estimates and mass balance calcula-
tions (using purchase records, inventories, engineering
knowledge or process specifications of the quantity of the
toxic chemical entering product, hazardous waste mani-
fests, or monitoring records) may be useful in estimating
fugitive emissions.
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 this 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 Section 5.3 you are to enter the name(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
total of three spaces are provided on page 2 of Form R.
Enter the name of each receiving stream or surface water
body to which the toxic chemical being reported is di-
rectly 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 list a 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 treatment plants
discharge. Enter "NA" in Section 5.3.1. if you do not
discharge the listed toxic chemical to surface water bod-
ies.
Enter the total annual amount of the toxic chemical re-
leased from all discharge points at the facility to each
receiving stream or water body. Include process outfalls
such as pipes and open trenches, releases from on-site
wastewater treatment systems, and the contribution from
stormwater runoff, if applicable (see instructions for col-
umn C below). Do not include discharges to a POTW or
other off-site wastewater treatment facilities in this sec-
tion. These off-site transfers must be reported in Part II,
Section 6 of Form R. Wastewater analyses and flowmeter
data may provide the quantities you will need to com-
plete this section.
Discharges of listed acids (e.g., hydrogen fluoride; nitric
acid; and phosphoric acid,) may be reported as zero if the
discharges have been neutralized to pH 6 or above. If
Toxic Release Inventory Reporting Forms and Instructions 25
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wastewater containing a listed acid is discharged below
pH 6, then releases of the acid must be reported. In this
case, pH measurements may be used to estimate the
amount of mineral acid released.
5.4.1 Underground Inj action On-Site to Class
I Wells
Enter the total amount of the toxic chemical that was
injected into Class I wells at the facility. Chemical analy-
ses/ injection rate meters, and RCRA Hazardous Waste
Generator Reports are good sources for obtaining data
that will be useful in completing this section. Check the
Not Applicable "NA" box in Section 5.4.1 if you do not
inject the reported toxic chemical into Class I under-
ground wells.
5.4.2 Underground Inj ection On-Site to Class
H-V Wells
Enter the total amount of the toxic chemical that was
injected into wells at the facility other than Class I wells.
Chemical analyses and injection rate meters are good
sources for obtaining data that will be useful in complet-
ing this section. Check the Not Applicable "NA" box in
Section 5.4.2 if you do not inject the reported toxic chemi-
cal into Class H-V underground wells.
5.5 Disposal to Land On-Site
Five predefined subcategories for reporting quantities
released to land within the boundaries of the facility are
provided. Do not report land disposal at off-site locations
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).
5.5.1ARCRA Subtitle Clandfills—Enter the total amount
of the toxic chemical that was placed in RCRA Subtitle C
landfills. Leaks from landfills need not be reported as a
release because the amount of the toxic chemical has
already been reported as a release.
5.5.1B Other landfills — Enter the total amount of the
toxic chemical that was placed in landfills other than
RCRA Subtitle C landfills. Leaks from landfills need not
be reported as a release because the amount of the toxic
chemical has already been reported as a release.
5.5.2 Land treatment/application farming — 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 the
air occurring during the disposal operation must be in-
cluded in the total fugitive air releases reported in Part II,
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
(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 dis-
charge, it would be considered to be a surface impound-
ment used as a final disposal method. A facility should
determine, to the best of its ability, the percentage of a
volatile chemical, e.g. benzene, that is in waste sent to a
surface impoundment that evaporates in the reporting
year. The facility should report this as a fugitive air
emission in section 5.1. The balance should be reported in
section 5.5.3.
Quantities of the toxic chemical released to surface im-
poundments thatare used merely as 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 the sludges 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 underground pipe-
line 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 remaining 1,400
pounds would be reported as a release to land, other
disposal (Part II, Section 5.5.4).
5. 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
section of Form R. The total on-site releases from your
facility do not include transfers or shipments of the toxic
26 Toxic Release Inventory Reporting Forms and Instructions
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chemical from your facility for sale or distribution in
commerce, or of wastes to other facilities for waste treat-
ment, recycling, disposal, or energy recovery (see Part II,
Section 6 of these Instructions). Both routine releases,
such as fugitive air emissions, and accidental or non-
routine releases, such as 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:
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 on-site 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 greater than 0.5 pounds, you should either
enter the range code "A" for "1-10" or enter "I" in column
A. If the release is less than 0.5 pounds or less, you may
round to zero and enter "0" in column A.
Note that total annual releases of 0.5 pounds or less from
the processing or otherwise use of an article maintain the
article status of that item. Thus, if the only releases you
have are from processing an article, and such releases are
0.5 pounds or less 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 or less, report zero. However, if you report zero
releases, a basis of estimate must be provided in column
B.
For example, if nitric 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 II, Section5.4.1 and 5.4.2 of Form
R. Also, if the facility does not landfill the acidic waste,
NA would be checked in Part II, Section 5.5.1.B of Form R.
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 significant figures. 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 quanti-
ties or concentrations of any toxic chemical released into
the environment, or of the frequency of such releases,
beyond that which is required under other provisions of
law or regulation or as part of routine plant operations, is
required for the purpose of completing Form R.
You must estimate, 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 the toxic chemical present at your 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 trade name product. See Part 40,
Section 372.30(b) of the Code of Federal Regulations for
further information on ho w to calculate the concentration
and weight of the toxic chemical in the mixture or trade
name product.
Toxic Release Inventory Reporting Forms and Instructions 27
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If you are reporting a toxic chemical category listed in
Table II of these instructions rather than a specific toxic
chemical, you combine the release data for all chemcials
in the listed toxic chemical category (e.g., all glycol ethers
or all chlorophenols) and report the aggregate amount for
that toxic chemical in that category separately. For ex-
ample, 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 aqueous ammonia solution, releases should be re-
ported based on 10% of total aqueous ammonia. Ammo-
nia evaporating from aqueous ammonia solutions is
considered to be anhydrous ammonia; therefore 100% of
the anhydrous ammonia should be reported if it is re-
leased to the environment. For dissociable nitrate com-
pounds, release estimates should be based on the weight
of the nitrate only.
For metal compound categories (e.g., chromium com-
pounds), report release 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
oxide) and exclude any contribution to mass made by
other species in the molecule.
5. Column B 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,
such as those relating release quantity to through-
put or equipment type (e.g., air emission factors).
O- Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatil-
ization using published mathematical formulas)
28 Toxic Release Inventory Reporting Forms and Instructions
or best engineering judgment. This would in-
clude applying an 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
estimate of the quantity of the toxic chemical in the waste.
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 calculation also contributed to the
estimate, "monitoring" should be indicated because moni-
toring data were 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 the monitoring data relate to a concentration
of the toxic chemical in other process streams within the
facility.
It is important to realize that the accuracy 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 submis-
sions.
5. Column C Percent From Stormwater
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
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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 con-
tributed 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 these 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 submit-
ted chemical-specific monitoring data in permit applica-
tions, then these data must be used to calculate the
percent contribution from stormwater. Rates of flow can
be estimated by multiplying the annual amount of rain-
fall by the land area of title facility and then multiplying
that figure by the runoff coefficient. The runoff coeffi-
cient represents the fraction of rainfall that does not seep
into the ground but runs off as stormwater. The runoff
coefficient is directly related to how the land in the
drainage area is used. (See table on next page)
Description of Land Area
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%
Lawns: Heavy Soil
Flat, 2%
Average, 2-7%
Steep, 7%
Runoff Coefficient
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
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. Report the total amount of the toxic
chemical transferred off-site after any on-site waste treat-
ment, recycling, or removal is completed. Report zero for
transfers of listed mineral acids if they have been neutral-
ized to a pH of 6 or above prior to discharge to a Publicly
Owned Treatment Works (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: 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 POTWs, 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 3 of Form
R as many times as necessary and then number the boxes
consecutively for each POTW. At the bottom of Section 6.
you will find instructions for indicating the total number
of page 3s that you are submitting as part of Form R, as
well as indicating the sequence of those pages. For
example, your facility transfers the reported toxic chemi-
cal in wastewaters to three POTWs. You would photo-
copy page 3 once, indicate at the bottom of each page 3
that there are a total of two page 3s and then indicate the
first and second page 3. The boxes for the two POTWs on
the first page 3 would be numbered 6.1.B.1 and 6.1.B.2,
while the box for third POTW on the second page 3 would
be numbered 6.I.B.3.
If you report a transfer of the listed toxic chemical to one
or more other off-site locations, number the boxes in
section6.2 as 6.2.1,6.2.2, etc. If you transfer the listed toxic
Toxic Release Inventory Reporting Forms and Instructions 29
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Example 8: 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:
Runoff
Land Use % Total Area Coefficient
Unimproved area 50 0.20
Asphaltic streets 10 0.85
Concrete pavement 40 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 ft2) x (7.48 gal/ft3) x (0.545) = 7,458,221 gallons/year
Total stormwater runoff = 7.45 million gallons/year
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. 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:
(7,458,000 gallons stormwater)x(3.785 liters/gallon) = 28,228,530 liters stormwater
(28,228,530 liters stormwater)x(1.4 mg. zinc/liter) = 31,519.9 grams zinc=87 pounds zinc.
The total amount of zinc discharged from all sources of your facility is:
250 pounds zinc from wastewater discharged
+87 pounds zinc from stormwater runoff
337 pounds zinc total water discharged
Round to 340 pounds of zinc reported in section 5.3 column A on Form R
The percentage of zinc discharge through stormwater reported in section 5.3 column C on Form is:
87/337x100=26%
30 Toxic Release Inventory Reporting Forms and Instructions
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chemical to more than two other off-site locations, photo-
copy page 4 of Form R as many times as necessary and
then number the boxes consecutively for each off-site
location. At the bottom of page 4 you will find instruc-
tions for indicating the total number of page 4s that you
are submitting as part of 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 4 once, indi-
cate at the bottom of Section 6.2 on each page 4 that there
are a total of two page 4s and then indicate the first and
second page 4. The boxes for the two off-site locations on
the first page 4 would be numbered 6.2.1 and 6.2.2, while
the box for the third off-site location on the second page
4 would be numbered 6.2.3.
6.1 Discharges to Publicly Owned Treatment
Works (POTWs)
.In Section 6.1.A, estimate the quantity of the reported
toxic chemical transferred to all POTWs and the basis
upon which the estimate was made. In Section 6.I.B.,
enter the name 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
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:
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
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-
C-
E-
O-
Estimate is based on monitoring data or mea-
surements for the toxic chemical as transferred to
an off-site facility.
Estimate is based on mass balance calculations,
such as calculation of the amount of the toxic
chemical in streams entering and leaving process
equipment.
Estimate is based on published emission factors,
such as those relating release quantity to through-
put or equipment type (e.g., air emission factors).
Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatil-
ization using published mathematical formulas)
or best engineering judgment. This would in-
clude applying an estimated 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 chemcial
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 treatment, dis-
posal, recycling, or energy recovery. Also estimate the
quantity of the reported toxic chemical transferred and
the basis upon which the estimate was made. If appropri-
ate, you must report multiple activities for each off-site
location. For example, if your facility sends a reported
toxic chemical in waste 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 must
report both the waste treatment and recycle activities,
along with the quantity associated with each activity.
If your facility transfers a reported toxic chemical to an
off-site location and that off-site location performs more
than four activities on that chemical, provide the neces-
sary information in Box 6.2.1 for the off-site facility and
the first four activities. Provide the information on the
remainder of the activities in Box 6.2.2 and provide again
the off-site facility identification and location informa-
tion.
Toxic Release Inventory Reporting Forms and Instructions 31
-------
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 off-site locations's
EPA Identification Number (defined in 40 CFR 260.10
and therefore commonly referred to as the RCRA ID
Number). This number may be found on the Uniform
Hazardous Waste Manifest, which is required by RCRA .
regulations. If you ship or transfer wastes containing a*1"
toxic chemical and the off-site location does not have an
EPA Identification Number (e.g., it does not accept RCRA
hazardous wastes or the wastes in question are not clas-
sified as hazardous), enter NA in the box for the off-site
location EPA Identification Number. If you ship or
transfer the reported toxic chemical in wastes to another
country, enter the Federal Information Processing
Stardards (FIPS) code for that country in the country field
of the address for the off-site facility. The most commonly
used FIPS codes are listed below. To obtain a FIPS code
for a country not listed here, contact the EPCRA Hotline.
The following is an abridged list of countries to which a
U.S. facility might ship a listed toxic chemical.
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
Note: 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 significant heat of combustion value,
and is transferred to an off-site location for combustion in
an industrial kiln, furnace, or boiler, report the quantity
as used for the purposes of energy recovery. However,
toxic chemicals with little or no heat of combustion value
(e.g., chlorofluorocarbons) must be reported as treated.
6.2 Column A Total Transfers
For each off-site location, enter die total amount, in pounds,
of the toxic chemical that is contained in the waste trans-
ferred to that location. Do not enter the total poundage of
the waste. If the total amount transferred is less than 1,000
pounds, you may report a range by entering the appropri-
ate range code. The following reporting range codes are
to be used:
Code
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 for each off-site location, along
with the quantity of the reported toxic chemical associ-
ated with each activity. For example, your facility trans-
fers a total of 15,000 pounds of toluene to an off-site
location that will use 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.
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 loca-
tion, one of which receives the transfer of 15,000 pounds
of toluene as detailed.) If you need to report more than
four off-site transfers (involving different waste manage-
ment) to one location, continue reporting of these trans-
fers by listing the same location in the next off-site location
section.
Do not double or multiple count amounts 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 that 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 recovered and
then treated with the majority of the toxic chemical being
recovered and only a fraction subsequently treated, re-
port the appropriate recycling activity along with the
quantity.
32 Toxic Release Inventory Reporting Forms and Instructions
-------
Example 9: 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
207.2 x 2 = 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 selenite (round to 3,600 pounds)
Toxic Release Inventory Reporting Forms and Instructions 33
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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 folio wing
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 measure-
ments 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.
O - Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatil-
ization using published mathematical formulas)
or best engineering judgment. This would in-
clude applying an estimated removal efficiency
to a waste stream, even if the composition of the
stream before treatment was fully identified
through monitoring data.
E- Estimate is based on published emission factors,
such as those relating release quantity to through-
put or equipment type (e.g., air emission factors).
6.2 Column C Types of Waste Management:
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 code for
a single location when distinct quantities of the reported
toxic chemical are subject to different waste treatment,
purpose of waste treatment, disposal, recycling, or energy
recovery. You should use the code that, to the best of your
knowledge, represents the ultimate disposition of the
chemical.
If the toxic chemical is sent off-site for further direct reuse
(e.g., a toxic chemical in metal scrap) and does not un-
dergo a waste management activity (i.e., release [includ-
ing disposal], treatment, energy recovery, or recycling
[recovery] prior to that reuse, it need not be reported in
section 6.2 or section 8.
You must distinquish between incineration, which is
waste treatment, and legitimate energy recovery. In
order for you to claim that 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
must be combusted in a energy recovery unit such as an
industrial boiler, furnace, or kiln. In a situation where the
reported toxic chemical is in a waste that is 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
energy recovery unit but did not contribute to the heating
value of the waste (see Figure 4 for an example).
Metals and Metal Compounds.
Metals and metal compounds (remember that the release
and other waste management information that you report
for metal compounds will be the total amount of the
parent metal released or otherwise managed as waste
NOT the whole metal compound) will be managed in
waste either by being released (including disposed) or by
being recycled. The metal has no heat value and thus
cannot be combusted for energy recovery and cannot be
treated because it cannot be destroyed. Thus, transfers of
metals and metal compounds for further waste
management should be reported as either a transfer for
recycling or a transfer for disposal. The applicable waste
management code for transfers of metals and metal
compounds for recycling is M24. Applicable codes for
transfers for disposal include M10, M41, M62, M71, M72,
M73, M79, M90, M94, and M99. Note that two codes, M41
and M62, are new this year. These codes are for transfers
to waste management in which the wastestream may be
treated but the metal contained in the wastestream is not
treated and is ultimately released. For example, M41
would be used for a metal or metal compound which is
stabilized in preparation, for disposal.
Applicable codes for Part II, Section 6.2, column C are:
Disposal
M10 Storage Only
M41 Solidification/Stabilization-Metals and Metal
Compounds only
M62 Wastewater Treatment (Excluding POTW)-Met-
als and Metal Compounds 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
M99 Unknown
34 Toxic Release Inventory Reporting Forms and Instructions
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Figure 4
Hypothetical Section 6.2 Completed for Two Off-site Locations
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
1 Off-site EPA Identification Number (RCRA ID No.)
C.2._L cc
Off-Site Location Name
Acme Waste
Street Address
5 Market Street
)D5661 62461
Services
City |
Releaseville
State | Zip Code
CD 80
A. Total Transfers (pounds/year)
(enter range code or estimate)
1. 5,000
2. 7,500
3. 2,500
4. NA
461
County
Hill
Is location under control of reporting i 1 i 1
facility or parent company? j | Yes | X | No
B. Basis of Estimate
(enter code)
1.
2.
3.
O
C
O
4.
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. W|56
2. W|20
3. M72
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
6.2._2
Off-site EPA Identification Number (RCRA ID No.) |
Off-Site Location Name |
Street Address 1
City |
State |
z.0 r
Dumfry
CO
cooe
Combustion, Inc.
:acility Road
Zip Code I
805
A. Total Transfers (pounds/year)
(enter range code or estimate)
1.
2.
12,500
NA
3.
4.
00
.1 7725432
County |
Burns
Is location under control of re
facility or parent company?
B. Basis of Estimate
(enter code)
1.
O
2.
3.
4.
| | Yes | X
No
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1- M54
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 perchloroethylene
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 Forms and Instructions 35
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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
Most of the chemical-specific information required by
EPCRA Section 313 that is reported on Form R is specific
to the toxic chemical rather than the waste stream con-
taining the toxic chemical. However, EPCRA Section 313
does require that waste treatment methods applied on-
site to waste streams that contain the toxic chemcial be
reported. This information is collected in Section 7A of
Form R.
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
chemical;
(c) the range of concentration of the toxic chemicals
in the influent to the waste treatment method;
(d) the efficiency of each waste treatment method or
waste treatment sequence in destroying or re-
moving 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 corresp onds 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)
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
toxic chemicalbeing reported. Waste treatment methods
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 meth-
ods that apply to individual waste streams. If your
facility treats various wastewater streams containing the
toxic chemical in different ways, the different waste treat-
ment methods must be listed separately.
36 Toxic Release Inventory Reporting Forms and Instructions
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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 parameters differs
from one unit to the next, each scrubber must be listed
separately.
If your facility performs more than eight sequential waste
treatment methods on a single general waste stream,
continue listing the methods in the next row and renum-
ber 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.2a. The numeral
"I" 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
for an example of a hypothetical Section 7A completed 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 4 of Form R as many times as necessary.
At the bottom of page 4 you will find instructions for
indicating the total number of page 4s 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
C46 General Oxidation (including Disinfection) —
Other
C99 Other Chemical Treatment
Incineration/Thermal Treatment
F01 Liquid Injection
Fll Rotary Kiln with Liquid Injection Unit
F19 Other Rotary Kiln
F31 Two Stage
F41 Fixed Hearth
F42 Multiple Hearth
F51 Fluidized Bed
F61 Infra-Red
F71 Fume/Vapor
F81 Pyrolytic Destructor
F82 Wet Air Oxidation
F83 Thermal Dry ing/De water ing
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
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)
Toxic Release Inventory Reporting Forms and Instructions 37
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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
GDI 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 it typically enters the waste treatment step or
sequence. The concentration is based on the amount or
mass of the toxic chemical in the waste stream as com-
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) for solidsand
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 participate concentrations (at standard tem-
perature and pressure) as grains/cubic foot of air, multi-
ply 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 standard
conditions of 0°C (32°F) and 760 mmHg atmospheric
pressure.
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 amount or mass), not merely 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 applied to
the general waste stream, refers only to the percent de-
struction, degradation, conversion, or removal of the
listed toxic chemical from the waste stream, not the
percent conversion or removal of other constituents in the
waste stream. The efficiency also does not refer to the
general efficiency of the treatment method 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, biodegrad, or be physically removed from the
sludge.
Percent removal can be calculated as follows:
x 100, where
I = amount of the toxic chemical in the influent waste
stream (entering the waste treatment step 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
waste stream by multiplying the concentration (by weight)
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
38 Toxic Release Inventory Reporting Forms and Instructions
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FigureS
Hypothetical Section 7A
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
|_J Not Applicable (NA) - Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
a. General
Waste Stream
(enter code)
7A.1a
W
7A.2a
7A.3a
A
,
7A.1b
3
6
b. Waste Treatment Method(s) Sequence
[enter 3-character code(s)]
P17
P21
7A.2b
3
6
1
4
7
9/
7A.3b
3
6
4
7
1
4
7
P12
P61
B21
C44
A01
2
5
8
2
5
8
2
5
8
P18
P42
P11
NA
NA
c. Range of Influent
Concentration
7A.1c
NA
7A.2C
1
7A.3C
1
d . Waste
Treatment
Efficiency
Estimate
7A.1d
%
7A.2d
99 %
7A.3d
91 %
e. Based on
Operating Data?
7A.1e
Yes
No
7A.2e
Yes
X
No
7A.3e
Yes
X
No
Toxic Release Inventory Reporting Forms and Instructions 39
-------
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 incinerated,
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 metal, 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 par-
ent metal from the waste stream (except for incineration),
not the percent chemical conversion of the metal com-
pound. If a listed waste treatment method converts but
does not remove a metal (e.g., chromium reduction), the
method must be reported with a waste treatment effi-
ciency of zero.
Listed toxic chemicals that are strong mineral acids neu-
tralized 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 using best engineering judgment or other methods.
Example 10: Reporting On-Site Energy Recovery
One waste stream generated by your facility contains,
among other chemicals, toluene and Freon 113. Thresh-
old quantities are exceeded for both of these toxic chemi-
cals, and you would, therefore, submit two separate Form
R reports. This waste stream is sent to an on-site indus-
trial furnace which uses the heat generated in a thermal
hydrocarbon cracking process at your facility. Because
toluene has a significant 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 Freon 113 does not contribute any value for
energy recovery purposes, the combustion of Freon 113
in the industrial furnace is considered waste treatment,
not energy recovery. You would report Freon 113 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 re-
ported toxic chemical is incinerated on-site but does not
contribute energy to the process (e.g., chlorofluorocar-
bons), it must be considered waste treated on-site and
reported in Section 7A. Metals and metal compounds
cannot be combusted for energy recovery. Energy recov-
ery may take place only in one of the types of energy
recovery equipment listed below.
7A Column E Based on Operating Data? Energy Recovery Codes
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 efflu-
ent 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 recov-
ery 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.
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 meth-
ods 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.
40 Toxic Release Inventory Reporting Forms and Instructions
-------
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
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 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 for a 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,
then list the ten activities that recover the greatest amount
of the toxic chemical (again, in descending order).
Toxic Release Inventory Reporting Forms and Instructions 41
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Section 8 Source Reduction and
Recycling Activities
This Section includes the data elements mandated by
section 6607 of the Pollution Prevention Act of 1990
(PPA). Section 8 is a required section of Form R and
must be completed.
In Section 8, 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 the metal compound categories,
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 provided.
Section 8.1 through 8.9 must be completed for each toxic
chemical. Section 8.10 must be completed only if a
source reduction activity was newly implemented spe-
cifically (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
information on source reduction, recycling, or pollution
control activities implemented at any time at your facil-
ity.
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
following the reporting year and the second year fol-
lowing the reporting year (future estimates).
Beginning with the 1995 reporting year, facilities can
use applicable, "NA," in Sections 8.1 through 8.7 to
indicate that there is no on-site or off-site recycling,
energy recovery, treatment, or release.
Column A: Prior Year
Quantities forSections 8.1 through8.7mustbe reported
for the year immediately preceding the reporting year in
column A. For reports due July 1,1998 (reporting year
1997), the prior year is 1996. Information available at the
facility that may be used to estimate the prior year's
quantities include the prior year's Form R submission,
supporting documentation, and recycling, energy re-
covery, or treatment operating logs or invoices.
Column B: Current Reporting Year
Quantities forSections 8.1 through 8.7mustbe reported
for the current reporting year (1997) in column B.
Columns C and D: Following Year and Sec-
ond Following Year
Quantities for Sections 8.1 through 8.7 must be esti-
mated for 1998 and 1999. EPA expects reasonable
future quantity estimates using a logical basis. Infor-
mation available at the facility to estimate quantities of
the chemical expected during these years include
planned source reduction activities, market projections,
expected contracts, anticipated new product lines, com-
pany growth projections, and production capacity fig-
ures. Respondents should take into account protections
available for trade secrets as provided in EPCRA Sec-
tion 322 (42 USC 11042).
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 report-
ing. They are not intended for use in determining,
under the Resource Conservation and Recovery Act
Example 11: Reporting Future Estimates
A pharmaceutical manufacturing facility uses a listed
toxic chemical in the manufacture of a prescription
drug. During the reporting year (1997), the company
received approval from the Food and Drug Adminis-
tration to begin marketing their product as an over-
the-counter drug beginning in 1998. 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 two years following the reporting year. The
facility treats the toxic chemical on-site and the quan-
tity treated is directly proportional to production
activity. The facility thus estimates the total quantity
of the reported toxic chemical treated for the follow-
ing year (1998) by adding 30 percent to the amount in
column B (the amount for the current reporting year).
The second following year (1999) figure can be calcu-
lated by adding an additional 30 percent to the amount
reported in column C (the amount for the following
year (1998) projection).
42 Toxic Release Inventory Reporting Forms and Instructions
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(RCRA) Subtitle C regulations, whether a secondary
material is a waste when recycled. These definitions
also do not apply to the information that may be sub-
mitted in the Biennial Report required under RCRA. In
addition, these definitions 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
waste streams which may include more than one chemi-
cal. 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 process
and remains in the residual from the recycling process,
which is disposed. While the waste may be considered
recycled under RCRA, the toxic chemical constituent
would be considered to be disposed for TRI purposes.
Quantities Reportable in Sections 8.1 - 8.7
Section 8 of Form R uses data collected to complete Part
II, Sections 5 through 7. For this reason, Section 8
should be completed last. Sections 8.1,8.3,8.5,8.7, and
8.8 use data collected to complete sections 5 and 6 of
Form R. The relationship between sections 5,6, and 8.8
to sections 8.1, 8.3, 8.5, and 8.7 are provided below in
equation form.
8.1 Report releases pursuant to EPCRA Section
329(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 aban-
donment of barrels, containers, and other closed
receptacles)." Do not include any quantity treated
on-site or reported as treated off-site in section 6.
Metals and metal compounds reported, 1) in section
6.2 as sent off-site for stabilization/solidification
(M41) or wastewater treatment (excluding POTWs)
(M62) and/or ,2) in section 6.1-discharges to POTWs
should be reported in section 8.1. These quantities
should NOT be reported section 8.7.
§ 8.1 = § 5 +§ 6.2 (disposal only) + § 6.1 (metals
and metal compounds only) - §8.8 (release or
off-site disposal only)
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 (e.g. fuel oil no. 6). For
the purposes of reporting on Form R, reportable on-
site and off-site energy recovery is the combustion of
a waste containing a Section 313 toxic chemical when:
(a) The combustion unit is integrated into
an energy recovery system (i.e., indus-
trial furnaces, industrial kilns, and boil-
ers); and
(b) The toxic chemical is combustible and
has a heating value high enough to
sustain combustion, (e.g., 5000 BTU)
8.4 - 8.5 A toxic chemical in a waste that is recycled
on-site or is sent off-site for recycling.
§ 8.5 = § 6.2 (recycIing)-§ 8.8 (off-site recy-
cling)
8.6 - 8.7 A toxic chemical (except for metals and
metal compounds) 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.
§ 8.7 = § 6.1+§ 6.2 (treatment)-§ 8.8 (off-site
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
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 are in residues from the recycling
operation which is subsequently sent off-site for dis-
posal. These quantities would be reported as follows in
Section 8:
Toxic Release Inventory Reporting Forms and Instructions 43
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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 subsequently entered re-
cycling)
To report that 5,000pounds 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 chemi-
cal recycled, treated, and disposed by 3,500 pounds.
Do not include in Sections 8.1 through 8.7 any quanti-
ties of the toxic chemical released into the environment
due to remedial actions; catastrophic events such as
earthquakes, 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. 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, Catas-
trophic Events, or One-Time Events
Not Associated with Production
Process
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 earth-
quakes, fires, or floods; or
(3) one-time events not associated with
normal or routine production pro-
cesses.
These quantities should not be included in Sections 8.1
through 8.7.
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 ex-
ample, 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 appropriate. 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 cleaned up
from spills resulting 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 action (e.g., RCRA corrective action) to clean
Example 12: 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
toxic chemical is released as a liquid and pools on the ground. It is estimated that 1,000 pounds of the toxic
chemical 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 Toxic Release Inventory Reporting Forms and Instructions
-------
up the environmental contamination resulting from
past practices should be reported in Section 8.8 because
they cannot currently be addressed by source reduc-
tion methods. A remedial action for purposes of Sec-
tion 8.8 is a waste cleanup (including RCRA and
CERCLA operations) within the facility boundary. Most
remedial activities involve collecting and treating con-
taminated 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
included in the quantity reported in Sections 8.1 through
8.7 because such releases are generally unanticipated
and cannot be addressed by routine process-oriented
accident prevention techniques.
By checking your documentation for calculating esti-
mates made for Part II, Section 5, "Quantity of the Toxic
Chemical Entering each Environmental Medium," you
may be able to identify release amounts from the above
sources. Emergency 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 mainte-
nance records to identify one-time or catastrophic
events.
Note: While the information reported in Section 8.8
represents only remedial, catastrophic, or one-time
events not associated with production processes, Sec-
tion 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 catastrophic, remedial, or routine pro-
cess operations.
8.9 Production Ratio or Activity Index
For Section 8.9, you must provide a ratio of reporting
year 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 the
reported toxic chemical recycled, used for energy re-
covery, treated, or released. 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.
Example 13: 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 current reporting year 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 pro-
duced 20,000 pounds of titanium dioxide during the
reporting year and 26,000 pounds in the preceding
year, the production ratio would be 0.77 (20,000/
26,000).
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 chemi-
cals, the quantities of the toxic chemical(s) produced in
the current and prior years provide a good basis for the
ratio because that is the primary business activity asso-
ciated with the reported toxic chemical(s). In most
cases, the production ratio or activity index must be
based on some variable of production or activity rather
than on toxic chemical or material usage. Indices based
on toxic chemical or material usage may reflect the
effect of source reduction activities rather than changes
in business activity. 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 "other-
wise-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
recycled, used for energy recovery, treated, or released.
Examples of methods available include:
(1) Amount of toxic chemical manufactured in
1997 divided by the amount of toxic chemical
manufactured in 1996; or
(2) Amount of product produced in 1997 divided
by the amount of product produced in 1996.
Toxic Release Inventory Reporting Forms and Instructions 45
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Example 14: Determining an Activity Index
Your facility manufactures organic dyes in a batch process. Different colors of dyes are manufactured, and
between color changes, all equipment must be thoroughly cleaned with solvent containing glycol ethers 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 in December. This adds up to a total of 15,000 pounds and four color changeovers.
During the reporting year, 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 index of 0.5 (based on two color changeovers for the reporting year divided by four changeovers for the
preceding year) is more appropriate than a production ratio of 1.33 (based on 20,000 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 released.
A facility that manufactures thermoplastic composite parts for aircraft uses toluene 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
(5,200/2,000) represents the activities involving tolene usage in the facility. If the molds were cleaned after 1,000
parts were manufactured, a production ratio 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).
Example 15: "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 Toxic Release Inventory Reporting Forms and Instructions
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Example 16: 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 surf ace area to be painted for each bike. The bicycle production ratio is 1.1 (16,000/14,500). You
estimate 12,500 pounds of toluene treated, recycled, used for energy recovery, or released 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 released 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
released during the reporting year (13,500 pounds). The production ratio is calculated as follows:
Production ratio = (12,500/13,500 x 1.1) + (1,000/13,500 x 0.87) = 1.08
8.10 Did Your Facility Engage in any
Source Reduction Activities for this
Chemical during the Reporting
Year?
If your facility engaged in any source reduction activity
for the reported toxic chemical during the reporting
year, report the activity that was implemented and the
method used to identify the opportunity for the activity
implemented. If your facility did not engage in any
source reduction activity for the reported toxic chemi-
cal, enter not applicable, "NA," in Section 8.10.1 and
answer Section 8.11.
Source reduction means any practice which:
Q Reduces the amount of any hazardous sub-
stance, pollutant, or contaminant entering any
waste stream or otherwise released into the
environment (including fugitive emissions)
prior to recycling, treatment, or disposal; and
Q 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, reformula-
tion or redesign of products, substitution of raw
materials, and improvements in housekeeping, main-
tenance, training, or inventory control.
The term source reduction does not include any prac-
tice which alters the physical, chemical, or biological
characteristics or the volume of a hazardous substance,
pollutant, 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 elimi-
nate 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 the reported toxic chemical
recycled, treated, used for energy recovery, or dis-
posed. Do not report in this section any activities taken
to reduce or eliminate the quantities reported in Section
Toxic Release Inventory Reporting Forms and Instructions 47
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Example 17: Source Reduction
A facility assembles and paints furniture. Both the glue used to assemble the furniture and the paints contain
listed 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 the 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 not reduce the amount of toxic chemical recycled, and therefore is not considered a source 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
Sections 8.2-8.3), recycled (as reported in Sections 8.4-
8.5), or treated (as reported in Sections 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
techniques that reduce or eliminate the amounts of the
toxic chemical reported in Sections 8.1 through 8.7.
Actions taken to recycle, treat, or dispose of the toxic
chemical are not considered source reduction activi-
ties.
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 materi-
als 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 materi-
als 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, unload-
ing, 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 clean-
ing units
W64 Improved draining procedures
48 Toxic Release Inventory Reporting Forms and Instructions
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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 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
TOl 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
a formal company program)
T06 Employee recommendation (under a formal
company program)
T07 State government technical assistance
program
T08 Federal government technical assistance
program
T09 Trade association/industry technical
assistance program
T10 Vendor assistance
Til Other
8.11 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 optional information on
source reduction, recycling, or pollution control activi-
ties 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 activi-
ties. If there is a contact person at the facility, other than
the technical or public contact provided in Part I, Sec-
tion 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 submit-
tal to that agency.
Toxic Release Inventory Reporting Forms and Instructions 49
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D. How to Determine if Your Facility Qualifies for the
Alternate Threshold and is Eligible for Reporting on
the Form A
D.I Alternate Threshold
On November 30,1994, EPA published a final rule (59
FR 61488) that provides qualifying facilities a reduced
reporting option. Eligible facilities wishing to take
advantage of this reduced reporting option may report
on a simplified two page form referred to as Form A
and do not have to use Form R. The "TRI Alternate
Threshold for Facilities with Low Annual Reportable
Amounts," provides facilities otherwise meeting
EPCRA section 313 reporting thresholds the option of
reporting on Form A provided that they do not exceed
500 pounds for the total annual reportable amount (de-
fined below) for that chemical, and that their amounts
manufactured or processed or otherwise used do not
exceed 1 million pounds. As with determining section
313 reporting thresholds, amounts manufactured, pro-
cessed, or otherwise used are to be considered inde-
pendently. This modification does not apply to forms
being submitted on or before July 1,1995 (covering the
1994 reporting year). If you fill out a Form A for a toxic
chemical do not fill out a Form R for that same chemi-
cal.
D.2 What is the Form A (certification
statement)?
The Form A, which is described as the "certification
statement" in 59 FR 61488, is a simplified form of re-
porting and is intended as a means to reduce the com-
pliance burden associated with EPCRA section 313. The
Form A must be submitted on an annual basis for each
eligible chemical. Facilities wishing to take avantage
of this burden reducing option should submit a Form
A for such chemicals meeting the conditions described
below, and should not submit a Form R to the EPCRA
Reporting Center for that chemical. The information
submitted on the Form A includes facility identifica-
tion information and the chemical or chemical category
identity. The information submitted on the Form A will
appear in the TRI data base in the same manner that
information submitted on Form R appears. An ap-
proved Form A and a magnetic version of reporting
have been included in this 1997 Form and Instructions
package.
D.3 What is the total annual reportable
amount?
For the purpose of this optional reporting modifica-
tion, the annual reportable amount is equal to the com-
bined total quantities released at the facility, disposed
50 Toxic Release Inventory Reporting Forms and Instructions
within the facility, treated at the facility (as represented
by amounts destroyed or converted by treatment pro-
cesses), recovered at the facility as a result of recycle
operations, combusted for the purpose of energy re-
covery at the facility, and amounts transferred from the
facility to off-site locations for the purpose of recycle,
energy recovery, treatment, and/or disposal. These
volumes correspond to the sum of amounts reportable
for data elements on EPA Form R (EPA Form 9350-1;
Rev. 04/97) as Part II column B of section 8, data ele-
ments 8.1 (quantity released), 8.2 (quantity used for
energy recovery on-site), 8.3 (quantity used for energy
recovery off-site), 8.4 (quantity recycled on-site), 8.5
(quantity recycled off-site), 8.6 (quantity treated on-
site), and 8.7 (quantity treated off-site).
D.4 Recordkeeping
Each owner or operator who determines that they are
eligible, and wishes to apply the alternate threshold to
a particular chemical, must retain records substantiat-
ing this determination for a period of 3 years from the
date of the submission of the Form A. These records
must include sufficient documentation to support cal-
culations as well as the calculations made by the facil-
ity that confirm their eligibility for each chemical for
which the alternate threshold was applied.
A facility that fits within the category description, and
manufactures, processes or otherwise uses no more
than 1 million pounds of a listed toxic chemical annu-
ally, and whose owner/operator elects to take advan-
tage of the alternate threshold is not considered an
EPCRA section 313 covered facility for that chemical
for the purpose of submitting a Form R. This determi-
nation may provide further regulatory relief from other
federal or state regulations that apply to facilities on
the basis of their EPCRA section 313 reporting status.
A facility will need to reference other applicable regu-
lations in order to determine if their actual requirements
may be affected by this reporting modification.
D.5 Multi-establishment facilities
For the purposes of using Form A, the facility must also
make its determination based upon the entire facility's
operations including all of its establishments (see 59
FR 61488 for greater detail). If the facility as a whole is
able to take advantage of the alternate threshold, a
single Form A is required. The eligibility to submit a
Form A must be made on a whole facility determina-
tion. Thus, all of the information necessary to make
the determination must be assembled to the facility
level.
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D.6 Trade secrets
EPA is requiring that a facility submit a unique Form A
for each toxic chemical meeting the conditions of the
alternate threshold. Facilities may assert a trade se-
crecy claim for a chemical identity on the Form A as on
the Form R. Reports submitted on a per chemical ba-
sis protect against the disclosure of trade secrets. Form
A's with trade secrecy claims, like Form R's with simi-
lar claims, will be separately handled upon receipt to
protect against disclosure. Commingling trade secret
chemical identities with non-trade secret chemical iden-
tities on the same submission increases the risk of dis-
closure.
D.7 Metals and metal compounds
For metal compounds, the category level of 500 pounds
applies to the amount of parent metal waste that is re-
ported on Form R, but the thresholds apply to the
amount of metal compounds manufactured, processed,
or otherwise used. For Form R reporting involving both
listed parent metals and associated metal compounds,
the one million pound alternate threshold must be ap-
plied separately to the listed parent metal and the as-
sociated metal compound(s). Threshold determina-
tions must be made independently for each because
they are separately listed toxic chemicals.
• If the threshold is exceeded for the listed par-
ent metal but not the associated metal com-
pounds, then the releases of metal reported on
Form R for the parent metal should not include
the releases from the metal compounds.
• If both the parent metal and the associated
metal compounds exceed the alternate thresh-
old, then the facility has the option of filing one
Form R for both, using the metal compound
name and reporting total releases based on
parent metal content.
• If neither the parent metal nor the associated
metal compounds exceed the alternate thresh-
old, then the facility should file a Form A for
each, since the reporting thresholds must be
applied to each listed parent metal and each
metal compound category. EPA believes it is
appropriate to make this distinction between
filing the Form R and Form A because the Form
R accounts for amounts of metal released or
otherwise managed and Form A verifies that
the alternate threshold for each listed chemi-
cal or chemical category has not been exceeded.
Similarly, separate Form A's should be submitted for
all other listed chemicals even if EPA allows one Form
R to be filed for two or more listed chemicals, e.g., o-
xylene, p-xylene and xylene (mixed isomers). For ex-
ample, if a facility processes in three separate process
streams, xylene (mixed isomers), o-xylene, and p-xy-
lene, and exceeds the conditions of the alternate thresh-
old for each of these listed substances, the facility may
combine the appropriate information on the o-xylene,
p-xylene, and xylene (mixed isomers) into one Form
R.
Facilities that process o-xylene, p-xylene, and xylene
(mixed isomers) in separate process streams and do not
exceed the conditions of the alternate threshold for one
or more of the compounds, may submit a separate Form
A for each of the forms of xylene meeting the alternate
threshold and report on Form R for those forms that
do not. Similar to reporting on the parent metals and
metal compounds described above, facilities that sepa-
rately process all forms of xylene with individual ac-
tivity levels within the conditions of the alternate
threshold should file a separate Form A for each form
of xylene.
The following are specific instructions for completing
each part of EPA Alternate Threshold Form A. All of
the data elements that appear on the Alternate Thresh-
old Form A are a subset of and are identical to those on
Form R except for the content of the statement to be
signed by an authorized individual. The number des-
ignations of the parts and sections of these instructions
correspond to those in Form R unless otherwise indi-
cated.
Toxic Release Inventory Reporting Forms and Instructions 51
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E. Instructions for Completing EPA Alternate Threshold
Form A
For all parts of Form A:
1. Type or print information on the form in the
format requested. Use black ink. (Using
blue ink for the certification signature is
suggested as a means of indicating its
originality.)
All information on the Form A is required.
2.
3.
4.
Do not leave items in Parts I and II on the
Form Ablank 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 pro-
vided for a type of information, enter NA, in
the next blank space in the sequence.
Do not submit an incomplete form. The
certification statement (Part I) specifies that
the report is complete as submitted. See
page 1 of these instructions for the definition
of a complete submission.
Parti. Facility Identification Information
Section 1. Reporting Year
This is the calendar year to which the reported infor-
mation applies, not the year in which you are submit-
ting the report. Information for the 1997 reporting year
must be submitted on or before July 1,1998.
Section 2. Trade Secret Information
2.1 Are you claiming the chemical identity
on page 1 trade secret?
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 chemi-
cal identity trade secret in Part I, Section 2.1. Other-
wise, check "unsanitized."
Section 3. Certification
The Form A must be signed by the owner or operator
or a senior official with management responsibility 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 Form A. Each report
must contain an original signature. Unlike the certifi-
cation statement contained on Form R, the certification
statement provided on the Alternate Threshold Form
A pertains to the facility's eligibility of having met the
conditions as described in Section D or in the Federal
Register 59 PR 61488 (November 30, 1994). Print or
type in the space provided the name and title 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 com-
pleted.
Section 4. Facility Identification
4.1 Facility Name, Location, and TRI
Facility Identification Number
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 Section 2.2.
Only check "yes" if it is your manufacturing, process-
ing, or otherwise use of the toxic chemical whose iden-
tity 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 Sec-
tion 2.2.
Enter the name of your facility (plant site name or ap-
propriate 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
the location where the toxic chemicals are manufac-
tured, processed, or otherwise used. If your mailing
address and street address are the same, enter NA in
the space for the mailing address. Note that the mail-
ing address is provided first, followed by the street ad-
dress.
52 Toxic Release Inventory Reporting Forms and Instructions
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If you have submitted a Form R for previous reporting „ , T . .. n T ,- «, -,
years, a TRI Facility Identification Number has been 4'4 Intentlonally Left Blank
assigned to your facility. If you cannot locate your TRI
Facility Identification Number, please contact the Emer- 4.5 Standard Industrial Classification
gency Planning and Community Right-to-Know Infor- (SIC) Code
mation Hotline (see page 4).
Enter "NA" in the space for the TRI Facility Identifica-
tion Number if your facility has never filed a Form A
(certification statement) or a Form R. If you have previ-
ously submitted a Form A (certification statement) or a
Form R, use the TRI Facility Identification Number that
you have been assigned. If you previously submitted a
Form A(certification statement) or a Form R, but do not
know what it is, contact the EPCRA Hotline (see page
4). If your facility has moved, do not enter your TRI
facility identification number, enter NEW FACILITY.
4.2 Federal Facility Designation
On August 3,1993, Executive Order 12856 was signed
which directs federal facilities to comply with Right-
To-Know Laws and Pollution Prevention Requirements.
Please indicate in 4.2.C. if the reporting facility is a fed-
eral facility. If the reporting facility is not a federal fa-
cility, leave this space blank. Form R allows a facility to
report multiple submissions for the same chemical if
the facility is composed of several distinct establish-
ments. This data element provides the option of report-
ing full or partial facility information on Form R, how-
ever, this is not applicable for those facilities taking ad-
vantage of the Alternate Threshold and using Form A.
An explanation of this is provided in Section D.
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 A. This contact person does not have
to be the same person who prepares the report or signs
the Form A and does not necessarily need to be some-
one at the location of the reporting facility; however,
this person must be familiar with the details of the re-
port so that he or she can answer questions about the
information provided.
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 establish-
ments within the facilities that fall within SIC codes 20
to 39. If you do not know your SIC code, consult the
1987 SIC Manual (see page 5).
The North American Industry Classification System
(NAICS), is a new economic classification system that
will replace the 1987 SIC code system. EPA will ad-
dress the SIC code change, as it relates to EPCRA, in an
upcoming Federal Register notice. This upcoming
change does NOT affect the 1997 EPCRA section 313
reporting.
4.6 Latitude and Longitude
Enter the latitudinal and longitudinal coordinates of
your facility. Sources of these data include EPA per-
mits (e.g., NPDES permits), county property records,
facility blueprints, and site plans. Instructions on how
to determine these coordinates can be found in Appen-
dix E. Enter only numerical data. Do not preface num-
bers with letters such as N or W to denote the hemi-
sphere. Latitude and longitude coordinates of your
facility are very important for pinpointing the location
of reporting facilities and are required elements on the
Form A. EPA encourages facilities to make the best
possible measurements when determining latitude and
longitude. As with any other data field, missing, sus-
pect, or incorrect data may generate a Notice of Tech-
nical Error to be issued to the facility. (See Appendix
C: Common Errors in Completing Form R Reports).
4.7 Dun and Bradstreet Number
Enter the 9-digit number assigned by Dun and
Bradstreet (D & B) for your facility or each establish-
ment within your facility. These numbers code the fa-
cility for financial purposes. This number may be avail-
able from your facility's treasurer or financial officer.
You can also obtain the numbers from your local Dun
and Bradstreet office (check the telephone book White
Toxic Release Inventory Reporting Forms and Instructions 53
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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, Penn-
sylvania, at (215) 882-7748 (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 ID. 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 ID. Number. If your facility is not
required to have an ID. 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.
4.9 NPDES Permit Number
Enter the numbers of any permits your facility holds
under the National Pollutant Discharge Elimination
System (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 appli-
cable, 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) identifi-
cation 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 appli-
cable, NA, 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 com-
pany. For purposes of the Form A, 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
54 Toxic Release Inventory Reporting Forms and Instructions
owned by a foreign entity, enter not applicable, NA, in
this space. Corporate names should be treated as par-
ent company names for companies with multiple fa-
cility sites. For example, the Bestchem Corporation is
not owned or controlled by any other corporation but
has sites throughout the country whose names begin
with Bestchem. In this case, Bestchem Corporation
would be listed as the parent company. Note that a
facility that is a 50:50 joint venture is its own parent
company.
5.1 Name of Parent Company
Enter the name of the corporation or other business
entity that is your ultimate US parent company. If your
facility has no parent company, check the NAbox.
5.2 Parent Company's Dun & Bradstreet
Number
Enter the Dun and Bradstreet Number for your ulti-
mate 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.
-------
Part II. Chemical Specific Information
Reporting on the Alternate Threshold Form A for met-
als, metal compounds, and mixed isomers differs some-
what from Form R reporting. Please refer to Section D
for these guidelines.
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 re-
porting one of the toxic chemical categories in Table II
(e.g., chromium compounds), enter the applicable cat-
egory 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
N020
N040
N050
N078
N084
N090
N096
N100
N106
N120
N171
N230
N420
N450
N458
N495
N503
N511
N575
N583
N590
N725
N740
N746
N760
N874
N982
Antimony compounds
Arsenic compounds
Barium compounds
Beryllium compounds
Cadmium compounds
Chlorophenols
Chromium compounds
Cobalt compounds
Copper compounds
Cyanide compounds
Diisocyanates
Ethylenebisdithiocarbamic acid,
salts and esters, (EBDCS)
Certain Glycol ethers
Lead compounds
Manganese compounds
Mercury compounds
Nickel compounds
Nicotine and salts
Nitrate compounds
Polybrominated biphenyls (PBBs)
Polychlorinated alkanes
Polycyclic aromatic compounds
Selenium compounds
Silver compounds
Strychnine and salts
Thallium compounds
Warfarin and salts
Zinc compounds
If you are making a trade secret claim, you must report
the CAS number or category code on your unsanitized
Form A and unsanitized substantiation form. Do not
include the CAS number or category code on your sani-
tized Form A or sanitized substantiation form.
1.2 Toxic Chemical or Chemical Category
Name
Enter the name of the toxic chemical or chemical cat-
egory exactly as it appears in Table n. If the toxic chemi-
cal 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 chemical identity is actually a product trade name
(e.g., dicofol), the 9th Collective Index name 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 num-
ber. 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 A and unsanitized substantiation form. Do not
report the name of the toxic chemical on your sanitized
Form A or sanitized substantiation form. Include a ge-
neric name in Part II, Section 1.3 of your sanitized Form
A.
1.3 Generic Chemical Name
Complete Section 1.3 only if you are claiming the spe-
cific 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 A. Enter a generic
chemical name that is descriptive of the chemical struc-
ture. You must limit the generic name to seventy char-
acters (e.g., numbers, letters, spaces, punctuation) or
less. Do not enter mixture names in Section 1.3; see
Section 2 on next page.
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 accept-
able as a generic name. The generic name must appear
on both sanitized and unsanitized Form A, and the
name must be the same as that used on your substan-
tiation forms.
Toxic Release Inventory Reporting Forms and Instructions 55
-------
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
secret. Do not answer "yes" in Part I, Section 2.1 on
page 1 of the form if you complete this section. You do
not need 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 chemical name in this 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 maxi-
mum 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 identi-
fied mixture component.
56 Toxic Release Inventory Reporting Forms and Instructions
-------
-------
-------
TABLE I. SIC CODES 20-39
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
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
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 mills
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.e.c."
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 Mai'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
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 woo.d 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
1-2 Table I
*"Not elsewhere classified" indicated as "n.e.c.'
-------
2676 Sanitary paper products
2677 Envelopes
2678 Stationery tablets, and related products
2679 Converted paper and paperboard products,
n.e.c.*
27 Printing, Publishing, and Allied
Industries
2711 Newspapers: publishing, or publishing and
printing
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.*
*"Not elsewhere classified" indicated by "n.e.c."
Table I 1-3
-------
31 Leather and Leather Products
33 Primary Metal Industries
3111 Leather tanning 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.*
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 NonmetaUic mineral products, n.e.c.*
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
3354 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 Enameled 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)
1-4 Table I
*"Not elsewhere classified" indicated as "n.e.c.'
-------
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 Electroplating, 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.*
3495 Wire springs
3496 Miscellaneous fabricated wire products
3497 Metal foil and leaf
3498 Fabricated pipe and pipe fittings
3499 Fabricated metal 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 Paper 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.*
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 and 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*
*"Not elsewhere classified" indicated by "n.e.c."
Table I L5
-------
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
3639 Household appliances, n.e.c.*
3641 Electric lampbulbs and tubes
3643 Current carrying wiring devices
3644 Noncurrent carrying wiring devices
3645 Residential 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 and disks
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 variables; and
related products
3824 Totalizing fluid meters and counting devices
3825 Instruments for measuring and testing of
electricity and electrical signals
3826 Laboratory analytical instruments
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
3843 Dental equipment and supplies
3844 X-ray apparatus and tubes and related
irradiation apparatus
1-6 Table I
*"Not elsewhere classified" indicated as "n.e.c.'
-------
3845 Electromedical and electrotherapeutic
apparatus
3851 Ophthalmic goods
3861 Photographic equipment and supplies
3873 Watches, clocks, clockwork operated devices,
and parts
39 Miscellaneous Manufacturing
Industries
3911 Jewelry, precious metal
3914 Silverware, plated ware, and stainless steel
ware
3915 Jewelers' findings and materials, and lapidary
work
3931 Musical instruments
3942 Dolls and stuffed toys
3944 Games, toys and children's vehicles; except
dolls and bicycles
3949 Sporting and athletic goods, n.e.c.*
3951 Pens, mechanical pencils, and parts
3952 Lead pencils, crayons, and artists' materials
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.*
h"Not elsewhere classified" indicated by "n.e.c."
Table I 1-7
-------
-------
-------
-------
TABLE II. SECTION 313 TOXIC CHEMICAL LIST FOR
REPORTING YEAR 1997 (including Toxic Chemical
Specific toxic chemicals with CAS Numbers are listed in alphabetical starting on page II-3. A list of the same chemicals in
CAS Number order begins at the end of the alphabetical list of toxic chemicals. Covered chemical categories follow.
Certain toxic 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 or
when a certain activity is performed. The following chemicals are reportable only if they are manufactured, processed, or
otherwise used in the specific form(s) listed below:
Chemical CAS Number
Aluminum (fume or dust) 7429-90-5
Aluminum oxide (fibrous forms) 1344-28-1
Ammonia (includes anhydrous 7664-41-7
ammonia and aqueous ammonia
from water dissociable ammonium
salts and other sources; 10 percent
of total aqueous ammonia is reportable
under this listing)
Asbestos (friable) 1332-21-4
Hydrochloric acid (acid aerosols including 7647-01-0
mists, vapors, gas, fog, and other airborne
forms of any particle size)
Phosphorus (yellow or white) 7723-14-0
Sulfuric acid (acid aerosols 7664-93-9
including mists, vapors, gas, fog, and
other airborne forms of any particle size)
Vanadium (fume or dust) 7440-62-2
Zinc (fume or dust) 7440-66-6
Qualifier
Only if it is in a fume or dust form.
Only if it is a fibrous form.
Only 10 percent of aqueous forms.
100 percent of anhydrous forms.
Only if it is a friable form.
Only if it is an aerosol form as defined.
Only if it is a yellow or white form.
Only if it is an aerosol form as defined.
Only if it is in a fume or dust form.
Only if it is in a fume or dust form.
The qualifier for the following two chemicals is based on the chemical activity rather than the form of the chemical. These
chemicals are subject to EPCRA section 313 reporting requirements only when the indicated activity is performed.
Chemical
CAS Number
Isopropyl alcohol (manufacturing 67-63-0
- strong acid process, no supplier notification)
Saccharin (manufacturing, no supplier
notification)
81-07-2
Qualifier
Only if it is being manufactured by the strong
acid process.
Only if it is being manufactured.
There are no supplier notification requirements for isopropyl alcohol and saccharin since the processors and users of these
chemicals are not required to report. Manufacturers of these chemicals do not need to notify their customers that these are
reportable EPCRA section 313 chemicals.
[Note: Chemicals may be added to or deleted from the list. The Emergency Planning and Community Right-to-Know
Information Hotline, (800) 535-0202, (800) 424-9346 or (703) 412-9877, will provide up-to-date information on the status of
these changes . See section B.4.b of the instructions for more information on the de minimis values listed below.]
*C.I. means "Color Index"
H-l Table II
-------
Chemical Qualifiers
This table contains the list of individual toxic chemicals
and categories of chemicals subject to 1997 calendar
year reporting. Some of the toxic chemicals listed in this
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,
processed, and otherwise used.
Fume or dust. Three of the metals on the list (alumi-
num, 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 solu-
tions or slurries. As explained in Section B.S.a of these
instructions, the term manufacture includes the gen-
eration of a toxic chemical as a byproduct or impurity.
In such cases, a facility should determine if, for ex-
ample, it generated more than 25,000 pounds of alumi-
num fume or dust in 1997 as a result of its activities. If
so, the facility must report that it manufactures "alumi-
num (fume or dust)." Similarly, there may be 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 com-
merce. In reporting releases, the facility would only
report releases of the fume or dust.
EPA considers dusts to consist of solid particles gener-
ated by any mechanical processing of materials includ-
ing 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, except under electrostatic forces. A
fume is an airborne dispersion consisting of small solid
particles created by condensation from a gaseous state,
in distinction to a gas or vapor. Fumes arise from the
heating of solids such as lead. The condensation is
often accompanied 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 relat-
ing to manufacture. For isopropyl alcohol, the qualifier
is "manufacturing—strong acid process." For saccha-
rin, the qualifier simply is "manufacturing." For iso-
propyl alcohol, the qualifier means that only facilities
manufacturing isopropyl alcohol by the strong acid
process are required to report. In the case of saccharin,
only manufacturers of the toxic chemical are subject to
the reporting requirements. A facility that processes or
otherwise uses either toxic chemical would not be
requked 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.
Ammonia (includes anhydrous ammonia and aque-
ous ammonia from water dissociable ammonium salts
and other sources; 10 percent of total aqueous ammo-
nia is reportable under this listing). The qualifier for
ammonia means that anhydrous forms of ammonia are
100 percent reportable and aqueous forms are limited
to 10 percent of total aqueous ammonia. Therefore
when determining threshold and releases and other
waste management quantities all anhydrous ammonia
is included but only 10 percent of total aqueous ammo-
nia is included. Any evaporation of ammonia from
aqueous ammonia solutions is considered anhydrous
ammonia and should be included in threshold and
release determinations.
Sulfuric acid and Hydrochloric acid (acid aerosols
including mists, vapors, gas, fog, and other airborne
forms of any particle size). The qualifier for sulfuric
acid and hydrochloric acid means that the only forms of
this chemical that are reportable are aerosols. Aqueous
solutions are not covered by this listing but any aero-
sols generated from aqueous solutions are covered.
Nitrate compounds (water dissociable; reportable only
when in aqueous solution). The qualifier for the
nitrate compounds category limits the reporting to
nitrate compounds that dissociate in water, generating
nitrate ion. For the purposes of threshold determina-
tions the entire weight of the nitrate compound must be
included in all calculations. For the purposes of report-
ing releases and other waste management quantities
only the weight of the nitrate ion should be included in
the calulations of these quantities.
Phosphorus (yellow or white). The listing for phos-
phorus is qualified by the term "yellow or white." This
means that only manufacturing, processing, or other-
wise use of phosphorus in the yellow or white chemical
form triggers reporting. Conversely, manufacturing,
processing, or otherwise use of "black" or "red" phos-
phorus does not trigger reporting. Supplier notifica-
tion also applies only to distribution of yellow or white
phosphorus.
Asbestos (friable). The listing for asbestos is qualified
by the term "friable," referring to the physical charac-
teristic of being able to be crumbled, pulverized, or
reducible to a powder with hand pressure. Only manu-
facturing, processing, or otherwise use of asbestos in
the friable form triggers reporting. Supplier notifica-
tion applies only to distribution of mixtures or trade
name products containing friable asbestos.
n-2 Table II
*C.I. means "Color Index"
-------
Aluminum Oxide (fibrous forms). The listing for
aluminum 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 report-
ing. Supplier notification applies only to distribution of
mixtures or trade name products containing fibrous
forms of aluminum oxide.
CAS Number Chemical Name
De Minimis
Concentration
a. Alphabetical List of TRI Chemicals
CAS Number Chemical Name
De Minimis
Concentration
71751-41-2 Abamectin [Avermectin Bl] 1.0
30560-19-1 Acephate 1.0
(Acetylphosphoramidothioic acid
O,S-dimethyl ester)
75-07-0 Acetaldehyde 0.1
60-35-5 Acetamide 0.1
75-05-8 Acetonitrile 1.0
98-86-2 Acetophenone 1.0
53-96-3 2-Acetylaminofluorene 0.1
62476-59-9 Acifluorfen, sodium salt 1.0
[5-(2-Chloro-4-(trifluoromethyl)-
phenoxy)-2-nitrobenzoic acid,
sodium salt]
107-02-8 Acrolein 1.0
79-06-1 Acrylamide 0.1
79-10-7 Acrylic acid 1.0
107-13-1 Acrylonitrile 0.1
15972-60-8 Alachlor 1.0
116-06-3 Aldicarb 1.0
309-00-2 Aldrin 1.0
[l,4:5,8-Dimethanonaphthalene,
l,2,3,4,10,10-hexachloro-l,4,4a,
5,8,8a-hexahydro-(l.alpha.,
4.alpha.,4a.beta.,5.alpha.,8.alpha.,
8a.beta.)-]
28057-48-9 d-trans-Allethrin 1.0
[d-trans-Chrysanthemic acid of
d-allethrone]
107-18-6 Allyl alcohol 1.0
107-11-9 Allylamine 1.0
107-05-1 Allyl chloride 1.0
7429-90-5 Aluminum (fume or dust) 1.0
20859-73-8 Aluminum phosphide 1.0
1344-28-1 Aluminum oxide (fibrous forms)1.0
834-12-8 Ametryn 1.0
(N-Ethyl-N'-(l-methylethyl)-6-
(methylthio)-l,3,5,-triazine-
2,4-diamine)
117-79-3 2-Aminoanthraquinone 0.1
60-09-3 4-Aminoazobenzene 0.1
92-67-1 4-Aminobiphenyl 0.1
82-28-0 l-Amino-2- 0.1
methylanthraquinone
33089-61-1 Amitraz 1.0
61-82-5 Amitrole 0.1
7664-41-7 Ammonia 1.0
(includes anhydrous ammonia
and aqueous ammonia from water
dissociable ammonium salts and
other sources; 10 percent of total
aqueous ammonia is reportable
under this listing)
101-05-3 Anilazine 1.0
[4,6-Dichloro-N-(2-chlorophenyl)-
l,3,5-triazin-2-amine]
62-53-3 Aniline * 1.0
90-04-0 o-Anisidine . 0.1
104-94-9 .p-Anisidine 1.0
134-29-2 o-Anisidine hydrochloride 0.1
120-12-7 Anthracene 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
1332-21-4 Asbestos (friable) 0.1
1912-24-9 Atrazine 0.1
(6-Chloro-N-ethyl-N'-(l-
methylethyl)-l,3,5-triazine-2,4-
diamine)
7440-39-3 Barium 1.0
22781-23-3 Bendiocarb 1.0
[2,2-Dimethyl-l,3-benzodioxol-4-
ol methylcarbamate]
1861-40-1 Benfluralin 1.0
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)-
benzenamine)
17804-35-2 Benomyl . 1.0
98-87-3 Benzal chloride 1.0
55-21-0 Benzamide 1.0
71-43-2 Benzene 0.1
92-87-5 Benzidine 0.1
98-07-7 Benzoic trichloride 0.1
(Benzotrichloride)
98-88-4 Benzoyl chloride 1.0
94-36-0 Benzoyl peroxide 1.0
100-44-7 Benzyl chloride 1.0
7440-41-7 Beryllium 0.1
82657-04-3 Bifenthrin 1.0
92-52-4 Biphenyl 1.0
111-91-1 Bis(2-chloroethoxy) methane 1.0
111-44-4 Bis(2-chloroethyl) ether 1.0
*C.I. means "Color Index"
II-3 Table II
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
542-88-1 Bis(chloromethyl) ether 0.1
108-60-1 Bis(2-chloro-l-methylethyl)- 1.0
ether
56-35-9 Bis(tributyltin) oxide 1.0
10294-34-5 Boron trichloride 1.0
7637-07-2 Boron trifluoride 1.0
314-40-9 Bromacil 1.0
(5-Bromo-6-methyl-3-(l-
methylpropyl)-?4(lIi3H)-
pyrimidinedione)
53404-19-6 Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione, 5-
bromo-6-methyl-3-(l-methyl-
propyl), lithium salt]
7726-95-6 Bromine 1.0
35691-65-7 l-Bromo-l-(bromomethyl)- 1.0
1,3-propanedicarbonitrile
353-59-3 Bromochlorodifluoromethane 1.0
(Halon 1211)
75-25-2 Bromoform 1.0
(Tribromomethane)
74-83-9 Bromomethane 1.0
(Methyl bromide)
75-63-8 Bromotrifluoromethane 1.0
(Halon 1301)
1689-84-5 Bromoxynil 1.0
(3,5-Dibromo-4-
hydroxybenzonitrile)
1689-99-2 Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-
cyanophenylester)
357-57-3 Brucine 1.0
106-99-0 1,3-Butadiene 0.1
141-32-2 Butyl acrylate 1.0
71-36-3 n-Butyl alcohol 1.0
78-92-2 sec-Butyl alcohol 1.0
75-65-0 tert-Butyl alcohol 1.0
106-88-7 1,2-Butylene oxide 1.0
123-72-8 Butyraldehyde 1.0
7440-43-9 Cadmium 0.1
156-62-7 Calcium cyanamide 1.0
133-06-2 Captan 1.0
[lH-Isoindole-l,3(2H)-dione,
3a,4,7,7a-tetrahydro-2-
[(trichloromethyl)thio]-]
63-25-2 Carbaryl [1-Naphthalenol, 1.0
methylcarbamate]
1563-66-2 Carbofuran 1.0
75-15-0 Carbon disulfide 1.0
56-23-5 Carbon tetrachloride 0.1
463-58-1 Carbonyl sulfide 1.0
5234-68-4 Carboxin 1.0
(5,6-Dihydro-2-methyl-N-
phenyl-l,4-oxathiin-3-car-
boxamide)
120-80-9 Catechol 1.0
2439-01-2 Chinomethionat 1.0
[6-Methyl-l,3-dithiolo[4,5-
b]quinoxalin-2-one]
133-90-4 Chloramben 1.0
[Benzoic acid, 3-amino-2,5-
dichloro-]
57-74-9 Chlordane 0.1
[4,7-Methanoindan,
1,2,4,5,6,7,8,8-octachloro-
2,3,3a,4,7,7a-hexahydro-]
115-28-6 Chlorendic acid 0.1
90982-32-4 Chlorimuron ethyl 1.0
[Ethyl-2-[[[[(4-chloro-6-
methoxyprimidin-2
-yl)amino]carbonyl]amino]
sulfonyl]benzoate]
7782-50-5 Chlorine 1.0
10049-04-4 Chlorine dioxide 1.0
79-11-8 Chloroacetic acid 1.0
532-27-4 2-Chloroacetophenone 1.0
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza- 1.0
1-azoniaadamantane chloride
106-47-8 p-Chloroaniline 0.1
108-90-7 Chlorobenzene 1.0
510-15-6 Chlorobenzilate 1.0
[Benzeneacetic acid, 4-chloro-
.alpha.- (4-chlorophenyl)-.alpha.-
hydroxy-, ethyl ester]
75-68-3 l-Chloro-l,l-difluoroethane 1.0
(HCFC-142b)
75-45-6 Chlorodifluoromethane 1.0
(HCFC-22)
75-00-3 Chloroethane (Ethyl chloride) 1.0
67-66-3 Chloroform 0.1
74-87-3 Chloromethane (Methyl 1.0
chloride)
107-30-2 Chloromethyl methyl ether 0.1
563-47-3 3-Chloro-2-methyl-l- 0.1
propene
104-12-1 p-Chlorophenyl isocyanate 1.0
76-06-2 Chloropicrin 1.0
126-99-8 Chloroprene 1.0
542-76-7 3-Chloropropionitrile . •> 1.0
63938-10-3 Chlorotetrafluoroethane 1.0
354-25-6 l-Chloro-1,1,2,2- 1.0
tetrafluoroethane (HCFC-124a) 1.0
n-4 Table II
*C.I. means "Color Index"
-------
CAS Number Chemical Name
De Min.im.is
Concentration
CAS Number Chemical Name
De Minimis
Concentration
2837-89-0 2-Chloro-l,l,l,2- 1.0
tetrafluoroethane (HCFC-124)
1897-45-6 Chlorothalonil 1.0
[ 1,3-Benzenedicarbonitrile,
2,4,5,6-tetrachloro-]
95-69-2 p-Chloro-o-toluidine 0.1
75-88-7 2-Chloro-l,l,l- 1.0
trifluoroethane (HCFC-133a)
75-72-9 Chlorotrifluoromethane 1.0
(CFC-13)
460-35-5 3-Chloro-l,l,l- 1.0
trifluoropropane (HCFC-253fb)
5598-13-0 Chlorpyrifos methyl 1.0
[O,O-Dimethyl-O-(3,5,6-trichloro-
2-pyridyl)phosphorothioate]
64902-72-3 Chlorsulfuron 1.0
[2-Chloro-N-[[(4-methoxy-6-
methyl-l ,3,5-triazin-2-yl)
amino]carbonyl]
benzenesulfonamide]
7440-47-3 Chromium 1.0
4680-78-8 C.I. Acid Green 3 1.0
6459-94-5 C.I. Acid Red 114 0.1
569-64-2 C.I. Basic Green 4 1.0
989-38-8 C.I. Basic Red 1 1.0
1937-37-7 C.I. Direct Black 38 0.1
2602-46-2 C.I. Direct Blue 6 0.1
28407-37-6 C.I. Direct Blue 218 1.0
16071-86-6 C.I. Direct Brown 95 0.1
2832-40-8 C.I. Disperse Yellow 3 1.0
3761-53-3 C.I. Food Red 5 0.1
81-88-9 C.I. Food Red 15 1.0
3118-97-6 C.I. Solvent Orange 7 1.0
97-56-3 C.I. Solvent Yellow 3 1.0
842-07-9 C.I. Solvent Yellow 14 1.0
492-80-8 C.I. Solvent Yellow 34 0.1
(Auramine)
128-66-5 C.I. Vat Yellow 4 1.0
7440-48-4 Cobalt 0.1
7440-50-8 Copper 1.0
8001-58-9 Creosote 0.1
120-71-8 p-Cresidine 0.1
108-39-4 m-Cresol 1.0
95-48-7 o-Cresol 1.0
106-44-5 p-Cresol 1.0
1319-77-3 Cresol (mixed isomers) 1.0
4170-30-3 Crotonaldehyde 1.0
98-82-8 Cumene 1.0
80-15-9 Cumene hydroperoxide 1.0
135-20-6 Cupferron 0.1
[Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt]
21725-46-2 Cyanazine 1.0
1134-23-2 Cycloate 1.0
110-82-7 Cyclohexane 1.0
108-93-0 Cyclohexanol 1.0
68359-37-5 Cyfluthrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarbox-
ylic acid, cyano(4-fluoro-3-
phenoxyphenyl) methyl ester]
68085-85-8 Cyhalothrin 1.0
[3-(2-Chloro-3,3,3-trifluoro-1-
propenyl)-2,2-dimethylcyclo-
propanecarboxylic
acid cyano(3-phenoxyphenyl)
methyl ester]
94-75-7 2,4-D 0.1
[Acetic acid, (2,4-
dichlorophenoxy)-] 1.0
533-74-4 Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-
1,3,5-thiadiazine-2-thione)
53404-60-7 Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-
1,3,5-thiadiazine-2-thione,
ion(l-), sodium]
94-82-6 2,4-DB 1.0
1929-73-3 2,4-D butoxyethyl ester 0.1
94-80-4 2,4-D butyl ester 0.1
2971-38-2 2,4-D chlorocrotyl ester 0.1
1163-19-5 Decabromodiphenyl oxide 1.0
13684-56-5 Desmedipham 1.0
1928-43-4 2,4-D 2-ethylhexyl ester 0.1
53404-37-8 2,4-D 2-ethyl-4- 0.1
methylpentyl ester
2303-16-4 Diallate 1.0
[Carbamothioic acid, bis(l-
methylethyl)-S-(2,3-dichloro-
2-propenyl) ester]
615-05-4 2,4-Diaminoanisole 0.1
39156-41-7 2,4-Diaminoanisole sulfate 0.1
101-80-4 4,4'-Diaminodiphenyl ether 0.1
95-80-7 2,4-Diaminotoluene 0.1
25376-45-8 Diaminotoluene 0.1
(mixed isomers)
333-41-5 Diazinon 1.0
334-88-3 Diazomethane 1.0
132-64-9 Dibenzofuran 1.0
96-12-8 l,2-Dibromo-3- 0.1
chloropropane (DBCP)
106-93-4 1,2-Dibromoethane 0.1
(Ethylene dibromide)
*C.I. means "Color Index"
II-5 Table II
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
124-73-2 Dibromotetrafluoroethane 1.0
(Halon 2402)
84-74-2 Dibutyl phthalate 1.0
1918-00-9 Dicamba 1.0
(3,6-Dichloro-2-methoxybenzoic
acid)
99-30-9 Dichloran 1.0
[2,6-Dichloro-4-nitroaniline]
95-50-1 1,2-Dichlorobenzene 1.0
541-73-1 1,3-Dichlorobenzene 1.0
106-46-7 1,4-Dichlorobenzene 0.1
25321-22-6 Dichlorobenzene 0.1
(mixed isomers)
91-94-1 3,3'-Dichlorobenzidine 0.1
612-83-9 3,3'-Dich1orobenzidine 0.1
dihydrochloride
64969-34-2 3,3'-Dichlorobenzidine 0.1
sulfate
75-27-4 Dichlorobromomethane 1.0
764-41-0 l,4-Dichloro-2-butene 1.0
110-57-6 trans- l,4-DichIoro-2-butene 1.0
1649-08-7 1,2-Dichloro-U- 1.0
difluoroethane (HCFC-132b)
75-71-8 Dichlorodifluoromethane 1.0
(CFC-12)
107-06-2 1,2-Dichloroethane (Ethy lene 0.1
dichloride)
540-59-0 1,2-Dichloroethylene 1.0
1717-00-6 1,1-Dichloro-l-fluoroethane 1.0
(HCFC-141b)
75-43.4 Dichlorofluoromethane 1.0
(HCFC-21)
75-09-2 Dichloromethane (Methylene 0.1
chloride)
127564-92-5 Dichloropentafluoropropane 1.0
13474-88-9 1,1-Dichloro-1,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
111512-56-2 l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
422-44-6 1,2-Dichloro-1,1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
431-86-7 1,2-Dichloro-1,1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
507-55-1 1,3-Dichloro-l,1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
136013-79-1 1,3-Dichloro-l, 1,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
128903-21-9 2,2-Dichloro-1,1,1,3,3- 1.0
pentafluoropropane (HCFC-225aa)
422-48-0 2,3-Dichloro-1,1,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
422-56-0 3,3-Dichloro-1,1,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
97-23-4 Dichlorophene 1.0
[2,2'-Methylenebis(4-chlorophenol)]
120-83-2 2,4-Dichlorophenol 1.0
78-87-5 1,2-Dichloropropane 1.0
10061-02-6 trans-1,3-Dichloropropene 0.1
78-88-6 2,3-Dichloropropene 1.0
542-75-6 1,3-Dichloropropylene 0.1
76-14-2 Dichlorotetrafluoroethane 1.0
(CFC-114)
34077-87-7 Dichlorotrifluoroethane 1.0
90454-18-5 Dichloro-l,l,2-trifluoroethane 1.0
812-04-4 1,1-Dichloro-1,2,2- 1.0
trifluoroethane (HCFC-123b)
354-23-4 1,2-Dichloro-1,1,2- 1.0
trifluoroethane (HCFC-123a)
306-83-2 2,2-Dichloro-1,1,1- 1.0
trifluoroethane (HCFC-123)
62-73-7 Dichlorvos 0.1
[Phosphoric acid, 2,2-
dichloroethenyl dimethyl ester]
51338-27-3 Diclofop methyl 1.0
[2-[4-(2,4-Dichlorophenoxy)
phenoxyjpropanoic acid, methyl ester]
115-32-2 Dicofol 1.0
[Benzenemethanol, 4-chloro-
.alpha.-4-(chlorophenyl)-.alpha.-
(trichloromethyl)-]
77-73-6 Dicyclopentadiene 1.0
1464-53-5 Diepoxybutane 0.1
111-42-2 Diethanolamine 1.0
38727-55-8 Diethatyl ethyl 1.0
117-81-7 Di(2-ethylhexyl) phthalate 0.1
(DEHP)
64-67-5 Diethyl sulfate 0.1
35367-38-5 Diflubenzuron 1.0
101-90-6 Diglycidyl resorcinol ether 0.1
94-58-6 Dihydrosafrole 0.1
55290-64-7 Dimethipin 1.0
[2,3-Dihydro-5,6-dimethyl-1,4-
dithiin-1,1,4,4-tetraoxide]
60-51-5 Dimethoate 1.0
119-90-4 3,3'-Dimethoxybenzidine 0.1
20325-40-0 3,3'-Dimethoxybenzidine 0.1
dihydrochloride
(o-Dianisidine dihydrochloride)
111984-09-9 3,3'-Dimethoxybenzidine 0.1
hydrochloride
(o-Dianisidine hydrochloride)
H-6 Table II
*C.I. means "Color Index"
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
1.0
1.0
0.1
1.0
0.1
0.1
0.1
124-40-3 Dimethylamine
2300-66-5 Dimethylamine dicamba
60-11-7 4-Dimethylaminoazobenzene
121-69-7 N,N-Dimethylaniline
119-93-7 3,3'-Dimethylbenzidine (o-
Tolidine)
612-82-8 3,3'-Dimethylbenzidine
dihydrochloride (o-Tolidine
dihydrochloride)
41766-75-0 3,3'-Dimethylbenzidine
dihydrofluoride (o-Tolidine
dihydrofluoride)
79-44-7 Dimethylcarbamyl chloride
2524-03-0 Dimethyl
chlorothiophosphate
68-12-2 N,N-Dimethylformamide
57-14-7 1,1-Dimethylhydrazine
105-67-9 2,4-Dimethylphenol
131-11-3 Dimethyl phthalate
77-78-1 Dimethyl sulfate
99-65-0 m-Dinitrobenzene
528-29-0 o-Dinitrobenzene
100-25-4 p-Dinitrobenzene
88-85-7 Dinitrobutyl phenol (Dinoseb)
534-52-1 4,6-Dinitro-o-cresol
51-28-5 2,4-Dinitrophenol
121-14-2 2,4-Dinitrotoluene
606-20-2 2,6-Dinitrotoluene
25321-14-6 Dinitrotoluene
(mixed isomers)
39300-45-3 Dinocap
123-91-1 1,4-Dioxane
957-51-7 Diphenamid
122-39-4 Diphenylamine
122-66-7 1,2-Diphenylhydrazine
(Hydrazobenzene)
2164-07-0 Dipotassium endothall
[7-Oxabicyclo(2.2.1 )heptane-2,3-
dicarboxylic acid, dipotassium salt]
136-45-8 Dipropyl isocinchomeronate 1.0
138-93-2 Disodium 1.0
cyanodithioimidocarbonate
94-11-1 2,4-D isopropyl ester 0.1
1.0
0.1
1.0
1.0
0.1
541-53-7
330-54-1
2439-10-3
120-36-5
1320-18-9
2702-72-9
106-89-8
13194-48-4
0.1
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
110-80-5
140-88-5
100-41-4
541-41-3
759-94-4
74-85-1
107-21-1
151-56-4
75-21-8
96-45-7
75-34-3
52-85-7
60168-88-9
13356-08-6
66441-23-4
1.0 72490-01-8
39515-41-8
55-38-9
2,4-Dithiobiuret 1.0
Diuron 1.0
Dodine [Dodecylguanidine 1.0
monoacetate]
2,4-DP 0.1
2,4-D propylene glycol 0.1
butyl ether ester
2,4-D sodium salt 0.1
Epichlorohydrin 0.1
Ethoprop 1.0
[Phosphorodithioic acid O-ethyl
S,S-dipropyl ester]
2-Ethoxyethanol 1.0
Ethyl acrylate 0.1
Ethylbenzene 1.0
Ethyl chloroformate 1.0
Ethyl dipropylthiocarbamate 1.0
(EPTC)
Ethylene 1.0
Ethylene glycol 1.0
Ethyleneimine (Aziridine) 0.1
Ethylene oxide 0.1
Ethylene thiourea 0.1
Ethylidene dichloride 1.0
Famphur 1.0
Fenarimol 1.0
[.alpha.-(2-Chlorophenyl)-.alpha.-
(4-chlorophenyl)-5-pyrimidine-
methanol]
Fenbutatin oxide 1.0
(Hexakis(2-memyl-2-
phenylpropyl)distannoxane)
Fenoxaprop ethyl 1.0
[2-(4-((6-Chloro-2-benzoxazolylen)-
oxy)phenoxy)propanoic acid, ethyl
ester]
Fenoxycarb 1.0
[[2-(4-Phenoxyphenoxy)
ethyl]carbamic acid ethyl ester]
Fenpropathrin 1.0
[2,2,3,3-Tetramethylcyclopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester,
phosphorothioic acid]
*C.I. means "Color Index"
II-7 Table II
-------
CAS Number Chemical Name
De Minimis
Concentration
1.0
CAS Number Chemical Name
De Minimis
Concentration
51630-58-1 Ferwalerate
[4-Chloro-aIpha-(l-
methylethyl)benzeneacetic acid
cyano(3-phenoxyphenyl)methyl ester]
14484-64-1 Ferbam 1.0
[Tris(dimethylcarbamodithioato-
S,S')iron]
69806-50-4 Fluazifop butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic
acid, butyl ester]
2164-17-2 Fluometuron 1.0
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethyl)phenyl]-]
7782-41-4 Fluorine 1.0
51-21-8 Fluorouracil (5-Fluorouracil) 1.0
69409-94-5 Fluvalinate 1.0
[N-[2-Chloro-4-
(trifluoromethyl)phenyl]-DL-
valine(+)-cyano(3-phenoxyphenyl)-
methyl ester]
133-07-3 Folpet 1.0
72178-02-0 Fomesafen 1.0
[5-(2-Chloro-4-
(trifluoromethyl)phenoxy)-N-
methylsulfonyl-2-nitrobenzamide]
50-00-0 Formaldehyde 0.1
64-18-6 Formic acid 1.0
76-13-1 FreonllS 1.0
[Ethane, 1,1,2-trichloro-1,2,2,-
trifluoro-]
76-44-8 Heptachlor 0.1
[ 1,4,5,6,7,8,8-Heptachloro-3a,
4,7,7a-tetrahydro-4,7-methano-
IH-indene]
118-74-1 Hexachlorobenzene 0.1
87-68-3 Hexachloro-l,3-butadiene 1.0
319-84-6 alpha-Hexachlorocyclo- 1.0
hexane
77.47.4 Hexachlorocyclopentadiene 1.0
67-72-1 Hexachloroethane 1.0
1335-87-1 Hexachloronaphthalene 1.0
70-30-4 Hexachlorophene 1.0
680-31-9 Hexamethylphosphoramide 0.1
110-54-3 n-Hexane 1.0
51235-04-2 Hexazinone 1.0
67485-29-4 Hydramethylnon 1.0
[Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3-[4-
(trifluoromethyl)phenyl]-l-[2-[4-
(trifluoromethyl)phenyl]ethenyl]-2-
propenylidene]hydrazone]
302-01-2 Hydrazine 0.1
10034-93-2 Hydrazine sulfate 0.1
7647-01-0 Hydrochloric acid 1.0
(acid aerosols including mists, vapors,
gas, fog, and other airborne forms of
any particle size)
74-90-8 Hydrogen cyanide 1.0
7664-39-3 Hydrogen fluoride 1.0
123-31-9 Hydroquinone 1.0
35554-44-0 Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethy 1]-1 H-imidazole]
55406-53-6 3-Iodo-2-propynyl 1.0
butylcarbamate
13463-40-6 Iron pentacarbonyl 1.0
78-84-2 Isobutyraldehyde 1.0
465-73-6 Isodrin 1.0
25311-71-1 Isofenphos 1.0
[2-[[Ethoxyl[(l-methylethyl)amino]-
phosphinothioyl]oxy]
benzoic acid 1-methylethyl ester]
67-63-0 Isopropyl alcohol 1.0
(manufacturing-strong acid
process, no supplier notification)
80-05-7 4,4'-Isopropylidenediphenol 1.0
120-58-1 Isosafrole 1.0
77501-63-4 Lactofen 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-
nitro-,2-ethoxy- l-methyl-2-
oxoethyl ester]
7439-92-1 Lead 0.1
58-89-9 Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-
hexachloro-, (l.alpha.,2.alpha.,
S.beta, 4.alpha., S.alpha., 6.beta.)-]
330-55-2 Linuron 1.0
554-13-2 Lithium carbonate 1.0
121-75-5 Malathion 1.0
108-31-6 Maleic anhydride 1.0
109-77-3 Malononitrile 1.0
12427-38-2 Maneb 1.0
[Carbamodithioic acid, 1,2-
ethanediylbis-, manganese complex]
7439-96-5 Manganese 1.0
93-65-2 Mecoprop 0.1
149-30-4 2-Mercaptobenzothiazole (MET) 1.0
7439.97-6 Mercury 1.0
150-50-5 Merphos 1.0
126-98-7 Methacrylonitrile 1.0
137-42-8 Metham sodium (Sodium 1.0
methyldithiocarbamate)
H-8 Table II
*C.I. means "Color Index"
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
67-56-1 Methanol 1.0
20354-26-1 Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-
1,2,4-oxadiazolidine-3,5-dione]
2032-65-7 Methiocarb 1.0
94-74-6 Methoxone 0.1
((4-Chloro-2-methylphenoxy)
acetic acid) (MCPA)
3653-48-3 Methoxone sodium salt 0.1
((4-Chloro-2-methylphenoxy)
acetate sodium salt)
72-43-5 Methoxychlor 1.0
[Benzene, l,l'-(2,2,2-trichloro-
ethylidene)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
79-22-1 Methyl chlorocarbonate 1.0
101-14-4 4,4'-Methylenebis(2- 0.1
chloroaniline) (MBOCA)
101-61-1 4,4'-Methylenebis(N,N- 0.1
dimethyl)benzenamine
74-95-3 Methylene bromide
101-77-9 4,4'-Methylenedianiline
78-93-3 Methyl ethyl ketone
60-34-4 Methyl hydrazine
74-88-4 Methyl iodide
108-10-1 Methyl isobutyl ketone
624-83-9 Methyl isocyanate
556-61-6 Methyl isothiocyanate
[Isothiocyanatomethane]
75-86-5 2-Methyllactonitrile
80-62-6 Methyl methacrylate
924-42-5 N-Methylolacrylamide
298-00-0 Methyl parathion
109-06-8 2-Methylpyridine
872-50-4 N-Methyl-2-pyrrolidone
9006-42-2 Metiram
21087-64-9 Metribuzin
7786-34-7 Mevinphos
90-94-8 Michler's ketone
2212-67-1 Molinate
(IH-Azepine-l-carbothioic acid,
hexahydro-, S-ethyl ester)
1313-27-5 Molybdenum trioxide 1.0
76-15-3 Monochloropenta- 1.0
fluoroethane (CFC-115)
150-68-5 Monuron 1.0
505-60-2 Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]]
88671-89-0 Myclobutanil 1.0
[.alpha.-Butyl-.alpha.-
(4-chloropheny 1)-1H-1,2,4-triazole-
1-propanenitrile]
142-59-6 Nabam 1.0
300-76-5 Naled 1.0
91-20-3 Naphthalene 1.0
134-32-7 alpha-Naphthylamine 0.1
91-59-8 beta-Naphthylamine 0.1
7440-02-0 Nickel 0.1
1929-82-4 Nitrapyrin 1.0
(2-Chloro-6-(trichloromethyl)-
pyridine)
7697-37-2 Nitric acid 1.0
139-13-9 Nitrilotriacetic acid 0.1
100-01-6 p-Nitroaniline 1.0
99-59-2 5-Nitro-o-anisidine 1.0
98-95-3 Nitrobenzene 0.1
92-93-3 4-Nitrobiphenyl 0.1
1836-75-5 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
N-Nitrosodi-n-butylamine 0.1
N-Nitrosodiethylamine 0.1
N-Nitrosodimethylamine 0.1
N-Nitrosodiphenylamine 1.0
p-Nitrosodiphenylamine 1.0
N-Nitrosodi-n-propylamine 0.1
N-Nitroso-N-ethy 1 urea 0.1
N-Nifroso-N-methylurea 0.1
N-Nitrosomethylvinylamine 0.1
N-Nitrosomorpholine 0.1
N-Nitrosonornicotine 0.1
N-Nitrosopiperidine 0.1
5-Nitro-o-toluidine 1.0
Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl]-3(2H)-
pyridazinone]
2234-13-1 Octachloronaphthalene 1.0
19044-88-3 Oryzalin 1.0
[4-(DipropyIamino)-3,5-dinitro-
benzene sulfonamide]
20816-12-0 Osmium tetroxide 1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
51-75-2
55-63-0
88-75-5
100-02-7
79-46-9
924-16-3
55-18-5
62-75-9
86-30-6
156-10-5
621-64-7
759-73-9
684-93-5
4549-40-0
59-89-2
16543-55-8
100-75-4
99-55-8
27314-13-2
*C.I. means "Color Index"
II-9 Table II
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
301-12-2 Oxydemeton methyl 1.0
[S-(2-{Ethylsulfinyl)ethyl) O,O-
dimethyl ester phosphorothioic
acid]
19666-30-9 Oxydiazon 1.0
[3-[2,4-Dichloro-5-( 1-methyl-
ethoxy)phenyl]- 5-( 1,1-dimethyl
ethyl)-1,3,4-oxadiazol-2(3H)-one]
42874-03-3 Oxyfluorfen 1.0
10028-15-6 Ozone 1.0
123-63-7 Paraldehyde 1.0
1910-42-5 Paraquat dichloride 1.0
56-38-2 Parathion 1.0
[Phosphorothioic acid, O,O-
diethyl-O-(4-nitrophenyl)ester]
1114-71-2 Pebulate 1.0
[Butylethylcarbamothioic acid S-
propyl ester]
40487-42-1 Pendimethalin 1.0
[N-( 1 -Ethylpropyl)-3,4-dimethyl-
2,6-dinitrobenzenamine]
76-01-7 Pentachloroethane 1.0
87-86-5 Pentachlorophenol (PCP) 0.1
57-33-0 Pentobarbital sodium 1.0
79-21-0 Peracetic acid 1.0
594_42-3 Perchloromethyl mercaptan 1.0
52645-53-1 Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarbox-
ylic acid, (3-phenoxyphenyl)
methyl ester]
85-01-8 Phenanthrene 1.0
108-95-2 Phenol 1.0
26002-80-2 Phenothrin 1.0
[2,2-Dimethy l-3-(2-methyl-1 -
propenyl)cyclopropanecarboxylic
acid (3-phenoxyphenyl)methyl ester]
95-54-5 1,2-Phenylenediamine 1.0
108-45-2 1,3-Phenylenediamine 1.0
106-50-3 p-Phenylenediamine 1.0
615-28-1 1,2-Phenylenediamine 1.0
dihydrochloride
624-18-0 1,4-PhenyIenediamine 1.0
dihydrochloride
90-43-7 2-Phenylphenol 1.0
57-41-0 Phenytoin 0.1
75-44-5 Phosgene 1.0
7803-51-2 Phosphine 1.0
7664-38-2 Phosphoric acid 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
85-44-9 Phthalic anhydride 1.0
1918-02-1 Picloram 1.0
88-89-1 Picric acid 1.0
51-03-6 Piperonyl butoxide 1.0
29232-93-7 Pirimiphos methyl 1.0
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-
dimethylphosphorothioate]
1336-36-3 Polychlorinated biphenyls 0.1
(PCBs)
7758-01-2 Potassium bromate 0.1
128-03-0 Potassium 1.0
dimethyldithiocarbamate
137-41-7 Potassium N- 1.0
methyldithiocarbamate
41198-08-7 Profenofos 1.0
[O-(4-Bromo-2-chlorophenyl)-O-
ethyl-S-propyl phosphorothioate]
7287-19-6 Prometryn 1.0
[N,N'-Bis(l-methylethyl)-6-
methylthio-1,3,5-triazine-2,4-
diamine]
23950-58-5 Pronamide 1.0
1918-16-7 Propachlor 1.0
[2-Chloro-N-( 1 -methy lethyl)-N-
phenylacetamide]
1120-71 -4 Propane sultone 0.1
709-98-8 Propanil 1.0
[N-(3,4-Dichlorophenyl)-
propanamide]
2312-35-8 Propargite 1.0
107-19-7 Propargyl alcohol 1.0
31218-83-4 Propetamphos 1.0
[3-[(Ethylamino)
methoxyphosphinothioyl]oxy]-
2-butenoic acid, 1-methylethyl ester]
60207-90-1 Propiconazole 1.0
[ 1 -[2-(2,4-Dichloropheny l)-4-
propyl-1,3-dioxolan-2-yl]-methyl-
lH-l,2,4,-triazole]
57-57-8 beta-Propiolactone 0.1
123-38-6 Propionaldehyde 1.0
114-26-1 Propoxur 1.0
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
115-07-1 Propylene (Propene) 1.0
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)
11-10 Table II
*C.I. means "Color Index"
-------
CAS Number Chemical Name
De Minimis
Concentration
1.0
CAS Number Chemical Name
76578-14-8 Quizalofop-ethyl
[2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy]
propanoic acid ethyl ester]
10453-86-8 Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]-
methyl-2,2-dimethyl-3-(2-methyl-
1-propenyl) cyclopropane
carboxylate]
81-07-2 Saccharin (manufacturing, no 0.1
supplier notification)
94-59-7 Safrole 0.1
7782-49-2 Selenium 1.0
74051-80-2 Sethoxydim 1.0
[2-[l-(Ethoxyimino)butyl]-5-[2-
(ethylthio)propyI]-3-hydroxyl-2-
cyclohexen-1-one]
7440-22-4 Silver 1.0
122-34-9 Simazine 1.0
26628-22-8 Sodium azide 1.0
1982-69-0 Sodium dicamba 1.0
[3,6-Dichloro-2-methoxybenzoic
acid, sodium salt]
128-04-1 Sodium dimethyldithio- 1.0
carbamate
62-74-8 Sodium fluoroacetate 1.0
7632-00-0 Sodium nitrite 1.0
131-52-2 Sodium pentachlorophenate 1.0
132-27-4 Sodium o-phenylphenoxide 0.1
100-42-5 Styrene 0.1
96-09-3 Styrene oxide 0.1
7664-93-9 Sulfuricacid 1.0
(acid aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle size)
2699-79-8 Sulfuryl fluoride (Vikane) 1.0
35400-43-2 Sulprofos 1.0
[O-Ethyl O-[4-(methylthio)phenyl]
phosphorodithioic acid S-
propylester]
34014-18-1 Tebuthiuron 1.0
[N-[5-(l, 1 -Dimethylethyl)-1,3,4-
thiadiazol-2-yl]-N,N'-dimethylurea]
3383-96-8 Temephos 1.0
5902-51-2 Terbacil 1.0
[5-Chloro-3-(l,l-dimethylethyl)-6-
methyl-2,4(lH,3H)-pyrimidinedione]
630-20-6 1,1,1,2-Tetrachloroethane 1.0
79-34-5 1,1,2,2-Tetrachloroethane 1.0
De Minimis
Concentration
0.1
127-18-4 Tetrachloroethylene
(Perchloroethylene)
354-11 -0 1,1,1,2-Tetrachloro-2- 1.0
fluoroethane (HCFC-121 a)
354-14-3 1,1,2,2-Tetrachloro-l- 1.0
fluoroethane (HCFC-121)
961-11-5 Tetrachlorvinphos 1.0
[Phosphoric acid, 2-chloro-l-
(2,4,5-trichlorophenyl) ethenyl
dimethyl ester]
64-75-5 Tetracycline hydrochloride
7696-12-0 Tetramethrin
[2,2-DimethyI-3-(2-methyl-1 -
propenyl) cyclopropanecarboxylic
acid (l,3,4,5,6,7-hexahydro-l,3- •
dioxo-2H-isoindoI-2-yI)methyl ester]
7440-28-0 Thallium l.Q
148-79-8 Thiabendazole 1.0
[2-(4-Thiazolyl)-1 H-benzimidazole]
62-55-5 Thioacetamide 0.1
28249-77-6 Thiobencarfa l.o
[Carbamic acid, diethylthio-, S-
(p-chlorobenzyl)ester]
139-65-1 4,4'-Thiodianiline 0.1
59669-26-0 Thiodicarb 1.0
23564-06-9 Thiophanate ethyl 1.0
[[ 1,2-Pheny lenebis-
(iminocarbonothioyl)]biscarbamic
acid diethylester]
23564-05-8 Thiophanate methyl 1.0
79-19-6 Thiosemicarbazide 1.0
62-56-6 Thiourea 0.1
137-26-8 Thiram l.o
1314-20-1 Thorium dioxide 1.0
7550-45-0 Titanium tetrachloride 1.0
108-88-3 Toluene l.o
584-84-9 Toluene-2,4-diisocyanate 0.1
91-08-7 Toluene-2,6-diisocyanate 0.1
26471-62-5 Toluene diisocyanate (mixed 0.1
isomers)
95-53-4 o-ToIuidine 0.1
636-21-5 o-Toluidine hydrochloride 0.1
8001-35-2 Toxaphene . 0.1
43121-43-3 Triadimefon 1.0
[ l-(4-Ch!orophenoxy)-3,3-di-
methyl-1 -(1H-1,2,4- triazol-1 -yl)-2-
butanone]
2303-17-5 Triallate 1.0
*C.I. means "Color Index"
11-11 Table II
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
68-76-8
101200-48-d
1983-10-4
2155-70-6
78-48-8
52-68-6
76-02-8
120-82-1
71-55-6
79-00-5
79-01-6
75-69-4
95-95-4
88-06-2
96-18-4
57213-69-1
121-44-8
1582-09-8
26644-46-2
95-63-6
2655-15-4
639-58-7
76-87-9
126-72-7
72-57-1
51-79-6
7440-62-2
50471-44-8
Triaziquone 1.0
[2,5-Cyclohexadiene-1,4-dione,
2,3,5-tris(l-aziridinyl)-]
Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-1,3,5-
triazin-2-yl)-methylamino]-
carbonyl]amino]sulfonyl] benzole acid-,
methyl ester)
Tributyltin fluoride 1.0
Tributyltin methacrylate 1.0
S,S,S-Tributyltrithio- 1.0
phosphate (DBF)
Trichlorfon 1 -0
[Phosphonic acid, (2,2,2-trichloro-
1-hydroxyethyl)-, dimethyl ester]
Trichloroacetyl chloride 1.0
1,2,4-Trichlorobenzene 1.0
1,1,1 -Trichloroethane (Methyl 1.0
chloroform)
1,1,2-Trichloroethane 1.0
Trichloroethylene 0.1
Trichlorofluoromethane 1.0
(CFC-11)
2,4,5-Trichlorophenol 1.0
2,4,6-Trichlorophenol 0.1
1,2,3-Trichloropropane 0.1
Triclopyr triethylammonium 1.0
salt
Triethylamine 1.0
Trifluralin 1.0
[Benezeneamine, 2,6-dinitro-N,N-
dipropyl-4-(trifluoromethyl)-]
Triforine 1 -0
[N,N'-[ 1,4-Piperazinediylbis-
(2,2,2-trichloroethylidene)]
bisformamide]
1,2,4-Trimethylbenzene 1.0
2,3,5-Trimethylphenyl 1.0
methylcarbamate
Triphenyltin chloride 1.0
Triphenyltin hydroxide 1.0
Tris(2,3-dibromopropyl) 0.1
phosphate
Trypan blue 0.1
Urethane (Ethyl carbamate) 0.1
Vanadium (fume or dust) 1.0
Vinclozolin 1 -0
[3-(3,5-Dichlorophenyl)-5-ethenyl-
5-methyl-2,4-oxazolidinedione]
108-05-4 Vinyl acetate 0.1
593-60-2 Vinyl bromide 0.1
75-01-4 Vinyl chloride 0.1
75.35-4 Vmylidene chloride 1.0
108-38-3 m-Xylene 1.0
95-47-6 o-Xylene 1.0
106-42-3 p-Xylene 1.0
1330-20-7 Xylene (mixed isomers) 1.0
87-62-7 2,6-Xylidine 0.1
7440-66-6 Zinc (fume or dust) 1.0
12122-67-7 Zineb 1.0
[Carbamodithioic acid, 1,2-
ethanediylbis-, zinc complex]
n-12 Table II
*C.I. means "Color Index"
-------
b. CAS Numbered List of TRI Chemicals
CAS Number Chemical Name
DeMinimis
Concentration
CAS Number Chemical Name
DeMinimis
Concentration
50-00-0 Formaldehyde
51-03-6 Piperonyl butoxide
51-21-8 Fluorouracil (5-Fluorouracil)
51-28-5 2,4-Dinitrophenol
51-75-2 Nitrogen mustard
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
51 -79-6 Urethane (Ethyl carbamate)
52-68-6 Trichlorfon
[Phosphonic acid, (2,2,2-trichloro-
hydroxyethyl) dimethyl ester]
52-85-7 Famphur
53-96-3 2-Acetylaminofluorene
55-18-5 N-Nitrosodiethylamine
55-21-0 Benzamide
55-38-9 Fenthion
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester,
phosphorothioic acid]
55-63-0 Nitroglycerin
56-23-5 Carbon tetrachloride
56-35-9 Bis(tributyltin) oxide
56-38-2 Parathion
[Phosphorothioic acid, O,O-diethyl
O-(4-nitrophenyl) ester]
57-14-7 1,1-Dimethylhydrazine
57-33-0 Pentobarbital sodium
57-41-0 Phenytoin
57-57-8 beta-Propiolactone
57-74-9 Chlordane
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-
hexahydro-]
58-89-9 Lindane
[Cyclohexane, 1,2,3,4,5,6-hexa-
chloro-,(l.alpha.,2.alpha.,3.beta.,
4.alpha, 5.alpha.,6.beta.)-]
59-89-2 N-Nitrosomorpholine
60-09-3 4-Aminoazobenzene
60-11-7 4-Dimethylaminoazobenzene
60-34-4 Methyl hydrazine
60-35-5 Acetamide
60-51-5 Dimethoate
61-82-5 Amitrole
62-53-3 Aniline
62-55-5 Thioacetamide
62-56-6 Thiourea
0.1
1.0
1.0
1.0
0.1
0.1
1.0
1-
1.0
0.1
0.1
1.0
1:0
1.0
0.1
1.0
1.0
62-73-7
62-74-8
62-75-9
63-25-2
64-18-6
64-67-5
64-75-5
67-56-1
67-63-0
67-66-3
67-72-1
68-12-2
68-76-8
70-30-4
71-36-3
71-43-2
71-55-6
72-43-5
0.1
1.0
0.1
0.1
0.1
0.1
0.1
0.1
0.1
1.0
0.1
1.0
0.1
1.0
0.1
0.1
72-57-1
74-83-9
74-85-1
74-87-3
74-88-4
74-90-8
74-95-3
75-00-3
75-01-4
75-05-8
75-07-0
75-09-2
75-15-0
75-21-8
75-25-2
75-27-4
75-34-3
75-35-4
75-43-4
75-44-5
Dichlorvos 0.1
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
Sodium fluoroacetate 1.0
N-Nitrosodimethylamine 0.1
Carbaryl l.Q
[ 1 -Naphthalenol, methyIcarbamate]
Formic acid 1.0
Diethyl sulfate 0.1
Tetracycline hydrochloride 1.0
Methanol 1.0
Isopropyl alcohol 1.0
(manufacturing-strong acid process,
no supplier notification)
Chloroform 0.1
Hexachloroethane 1.0
N,N-Dimethylformamide 0.1
Triaziquone 1.0
[2,5-Cyclohexadiene-1,4-dione, 2,3,
5-tris(l-aziridinyl)-]
Hexachlorophene 1.0
n-Butyl alcohol 1.0
Benzene 0.1
1,1,1 -Trichloroethane (Methyl 1.0
chloroform)
Methoxychlor 1.0
[Benzene, 1, l'-(2,2,2-trichloro-
ethylidene)bis[4-methoxy-]]
Trypan blue 0.1
Bromomethane (Methyl bromide) 1.0
Ethylene 1.0
Chloromethane (Methyl chloride) 1.0
Methyl iodide 1.0
Hydrogen cyanide 1.0
Methylene bromide 1.0
Chloroethane (Ethyl chloride) 1.0
Vinyl chloride 0.1
Acetonitrile 1.0
Acetaldehyde 0.1
Dichloromethane (Methylene 0.1
chloride)
Carbon disulfide 1.0
Ethylene oxide 0.1
Bromoform (Tribromomethane) 1.0
Dichlorobromomethane 1.0
Ethylidene dichloride 1.0
Vmylidene chloride 1.0
Dichlorofluoromethane (HCFC-21) 1.0
Phosgene 1.0
*C.I. means "Color Index"
H-13 Table II
-------
CAS Number Chemical Name
DeMinimis
Concentration
CAS Number Chemical Name
DeMinimis
Concentration
75-45-6 Chlorodifluoromethane (HCFC-22) 1.0
75-55-8 Propyleneimine 0.1
75-56-9 Propylene oxide 0.1
75-63-8 Bromotrifluoromethane 1.0
(Halon 1301)
75-65-0 tert-Butyl alcohol 1.0
75-68-3 l-Chloro-l,l-difluoroethane 1.0
(HCFC-142b)
75-69-4 Trichlorofluoromethane (CFG-11)
75-71 -8 Dichlorodifluoromethane (CFC-12)
75-72-9 Chlorotrifluoromethane (CFC-13)
75-86-5 2-Methyllactonitrile
75-88-7 2-Chloro-1,1,1 -trifluoroethane
(HCFC-133a)
76-01-7 Pentachloroethane
76-02-8 Trichloroacetyl chloride
76-06-2 Chloropicrin
76-13-1 FreonllS
[Ethane, 1,1,2-trichloro-1,2,2,-
trifluoro-]
76-14-2 Dichlorotetrafluoroethane
(CFC-114)
76-15-3 Monochloropentafluoroethane
(CFC-115)
76-44-8 Heptachlor
[1,4,5,6,7,8,8-Heptachloro-
3a,4,7,7a-tetrahydro-4,7-
methano-1 H-indene]
76-87-9 Triphenyltin hydroxide
77.47.4 Hexachlorocyclopentadiene
77-73-6 Dicyclopentadiene
77-78-1 Dimethyl sulfate
78-48-8 S,S,S-Tributyltrithiophosphate
(DBF).
78-84-2 Isobutyraldehyde
78-87-5 1,2-Dichloropropane
78-88-6 2,3-Dichloropropene
78-92-2 sec-Butyl alcohol
78-93-3 Methyl ethyl ketone
79-00-5 1,1,2-Trichloroethane
79-01-6 Trichloroethylene
79-06-1 Acrylamide
79-10-7 Acrylic acid
79-11-8 Chloroacetic acid
79-19-6 Thiosemicarbazide
79-21-0 Peracetic acid
79-22-1 Methyl chlorocarbonate
79-34-5
79-44-7
79-46-9
80-05-7
80-15-9
80-62-6
81-07-2
1.0
1.0
.0
.0
.0
.0
.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
81-88-9
82-28-0
82-68-8
84-74-2
85-01-8
85-44-9
86-30-6
87-62-7
87-68-3
87-86-5
88-06-2
88-75-5
88-85-7
88-89-1
90-04-0
90-43-7
90-94-8
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
93-65-2
94-11-1
94-36-0
94-58-6
94-59-7
94-74-6
94-75-7
, 94-80-4
1,1,2,2-Tetrachloroethane 1.0
Dimethylcarbamyl chloride 0.1
2-Nitropropane 0.1
4,4'-Isopropylidenediphenol 1.0
Cumene hydroperoxide 1.0
Methyl methacrylate 1.0
Saccharin (manufacturing, no 0.1
supplier notification)
C.I. Food Red 15
l-Amino-2-methylanthraquinone 0.1
Quintozene 1.0
[Pentachloronitrobenzene]
Dibutyl phthalate 1.0
Phenanthrene 1.0
Phthalic anhydride 1.0
N-Nitrosodiphenylamine 1.0
2,6-Xylidine 0.1
Hexachloro-1,3-butadiene 1.0
Pentachlorophenol (PCP) 0.1
2,4,6-Trichlorophenol 0.1
2-NitrophenoI 1.0
Dinitrobutyl phenol (Dinoseb) 1.0
Picric acid 1 -0
o-Anisidine 0.1
2-Phenylphenol 1.0
Michler's ketone 0.1
Toluene-2,6-diisocyanate 0.1
Naphthalene 1.0
Quinoline 1 -0
beta-Naphthylamine 0.1
3,3'-Dichlorobenzidine 0.1
Biphenyl 1.0
4-Aminobiphenyl 0.1
Benzidine 0.1
4-Nitrobiphenyl 0.1
Mecoprop 0.1
2,4-D isopropyl ester 0.1
Benzoyl peroxide 1.0
Dihydrosafrole 0.1
Safrole 0.1
Methoxone 0.1
((4-Chloro-2-methylphenoxy)
acetic acid) (MCPA)
2,4-D [Acetic acid, (2,4- 0.1
dichlorophenoxy)-]
2,4-D butyl ester 0.1
11-14 Table II
*C.I. means "Color Index"
-------
CAS Number Chemical Name
DeMinimis
Concentration
CAS Number Chemical Name
DeMinimis
Concentration
94-82-6 2,4-DB
95-47-6 o-Xylene
95-48-7 o-Cresol
95-50-1 1,2-Dichlorobenzene
95-53-4 o-Toluidine
95-54-5 1,2-Phenylenediamine
95-63-6 1,2,4-Trimethylbenzene
95-69-2 p-Chloro-o-toluidine
95-80-7 2,4-Diaminotoluene
95-95-4 2,4,5-Trichlorophenol
96-09-3 Styrene oxide
96-12-8 1,2-Dibromo-3-chloropropane
(DBCP)
96-18-4 1,2,3-Trichloropropane
96-33-3 Methyl acrylate
96-45-7 Ethylene thiourea
97-23-4 Dichlorophene
[2,2'-Methylenebis(4-chlorophenol)]
97-56-3 C.I. Solvent Yellow 3 1
98-07-7 Benzole trichloride
(Benzotrichloride)
98-82-8 Cumene
98-86-2 Acetophenone
98-87-3 Benzal chloride
98-88-4 Benzoyl chloride
98-95-3 Nitrobenzene
99-30-9 Dichloran [2,6-Dichloro-4-
nitroaniline]
99-55-8 5-Nitro-o-toluidine
99-59-2 5-Nitro-o-anisidine
99-65-0 m-Dinitrobenzene
100-01-6 p-Nitroaniline
100-02-7 4-Nitrophenol
100-25-4 p-Dinitrobenzene
100-41-4 Ethylbenzene
100-42-5 Styrene
100-44-7 Benzyl chloride
100-75-4 N-Nitrosopiperidine
101-05-3 Anilazine
[4,6-Dichloro-N-(2-chlorophenyl)-
1,3,5-triazin-2-amine]
101-14-4 4,4'-Methylenebis(2-chloroaniline) 0.1
(MBOCA)
101-61-1 4,4'-Methylenebis(N,N-
dimethyl)benzenamine
101-77-9 4,4'-Methylenedianiline
101-80-4 4,4'-Diaminodiphenyl ether
101-90-6 Diglycidyl resorcinol ether
104-12-1 p-Chlorophenyl isocyanate
1.0
1.0
1.0
1.0
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
0.1
1.0
1.0
1.0
1.0
O.i
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
0.1
0.1
0.1
0.1
0.1
1.0
104-94-9
105-67-9
106-42-3
106-44-5
106-46-7
106-47-8
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
107-11-9
107-13-1
107-18-6
107-19-7
107-21-1
107-30-2
108-05-4
108-10-1
108-31-6
108-38-3
108-39-4
108-45-2
108-60-1
108-88-3
108-90-7
108-93-0
108-95-2
109-06-8
109-77-3
109-86-4
110-54-3
110-57-6
110-80-5
110-82-7
110-86-1
11 1-42-2
111-44-4
111-91-1
114-26-1
lie rvi i
115-28-6
p-Anisidine 1.0
2,4-Dimethylphenol 1.0
p-Xylene l.Q
p-Cresol l .0
1,4-Dichlorobenzene 0.1
p-Chloroaniline 0.1
p-Phenylenediamine 1.0
Quinone 1.0
1,2-Butylene oxide 1.0
Epichlorohydrin 0.1
1,2-Dibromoethane 0.1
(Ethylene dibromide)
1,3-Butadiene 0.1
Acrolein l .0
Allyl chloride 1.0
1,2-Dichloroethane (Ethylene 0.1
dichloride)
Allylamine 1.0
Acrylonitrile 0.1
Allyl alcohol 1.0
Propargyl alcohol 1.0
Ethylene glycol 1.0
Chloromethyl methyl ether 0.1
Vinyl acetate 0.1
Methyl isobutyl ketone 1.0
Maleic anhydride 1.0
m-Xylene 1.0
m-Cresol 1.0
1,3-Phenylenediamine 1.0
Bis(2-chloro-1 -methylethyl) ether 1.0
Toluene 1.0
Chlorobenzene 1.0
Cyclohexanol 1.0
Phenol 1.0
2-Methylpyridine 1.0
Malononitrile 1.0
2-Methoxyethanol 1.0
n-Hexane 1.0
trans-1,4-Dichloro-2-butene 1.0
2-Ethoxyethanol 1.0
Cyclohexane 1.0
Pyridine 1.0
Diethanolamine 1.0
Bis(2-chloroethyl) ether 1.0
Bis(2-chloroethoxy) methane 1.0
Propoxur 1.0
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
Propylene (Propene) 1.0
Chlorendic acid 0.1
*C.I. means "Color Index"
11-15 Table II
-------
CAS Number Chemical Name
DeMinimis
Concentration
CAS Number Chemical Name
DeMinimis
Concentration
115-32-2
116-06-3
117-79-3
117-81-7
118-74-1
119-90-4
119-93-7
120-12-7
120-36-5
120-58-1
120-71-8
120-80-9
120-82-1
120-83-2
121-14-2
121-44-8
121-69-7
121-75-5
122-34-9
122-39-4
122-66-7
123-31-9
123-38-6
123-63-7
123-72-8
123-91-1
124-40-3
124-73-2
126-72-7
126-98-7
126-99-8
127-18-4
128-03-0
128-04-1
128-66-5
131-11-3
131-52-2
J 32-27-4
132-64-9
133-06-2
133-07-3
133-90-4
Dicofol 1-0
[Benzenemethanol, 4-chloro-.alpha.
-4-(chlorophenyl)-.alpha.-
(trichloromethyl)-]
Aldicarb 1.0
2-Aminoanthraquinone 0.1
Di(2-ethylhexyl) phthalate (DEHP) 0.1
Hexachlorobenzene 0.1
3,3'-Dimethoxybenzidine 0.1
3,3'-Dimethylbenzidine (o-Tolidine)0.1
Anthracene 1.0
2,4-DP 0.1
Isosafrole 1 -0
p-Cresidine 0.1
Catechol 1-0
1,2,4-Trichlorobenzene 1.0
2,4-Dichlorophenol 1.0
2,4-Dinitrotoluene 0.1
Triethylamine 1.0
N,N-Dimethylaniline 1.0
Malathion 1 -0
Simazine 1 -0
Diphenylamine 1.0
1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
Hydroquinone
Propionaldehyde
Paraldehyde
Butyraldehyde
1,4-Dioxane
Dimethylamine
Dibromotetrafluoroethane
(Halon 2402)
Tris(2,3-dibromopropyl) phosphate 0.1
Methacrylonitrile 1.0
Chloroprene 1.0
Tetrachloroethylene 0.1
(Perchloroethylene)
Potassium dimethyldithiocarbamate 1.0
Sodium dimethyldithiocarbamate 1.0
C.I. Vat Yellow 4
Dimethyl phthalate
Sodium pentachlorophenate
Sodium o-phenylphenoxide
Dibenzofuran
Captan
[lH-Isoindole-l,3(2H)-dione, 3a,
4,7,7a-tetrahydro-2-
[(trichloromethyl)thio]-]
Folpet
Chloramben
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
134-29-2
134-32-7
135-20-6
136-45-8
137-26-8
137-41-7
137-42-8
138-93-2
139-13-9
139-65-1
140-88-5
141-32-2
142-59-6
148-79-8
149-30-4
150-50-5
150-68-5
151-56-4
156-10-5
156-62-7
298-00-0
300-76-5
301-12-2
302-01-2
306-83-2
309-00-2
314-40-9
319-84-6
330-54-1
330-55-2
333-41-5
334-88-3
353-59-3
o-Anisidine hydrochloride 0.1
alpha-Naphthylamine 0.1
Cupferron 0.1
[Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
Dipropyl isocinchomeronate 1.0
Thiram 1.0
Potassium N-methyldithio- 1.0
carbamate
Metham sodium (Sodium 1.0
methyldithiocarbamate)
Disodium cyanodithioimido- 1.0
carbonate
Nitrilotriacetic acid 0.1
4,4'-Thiodianiline 0.1
Ethyl acrylate 0.1
Butyl acrylate 1.0
Nabam 1.0
Thiabendazole 1.0
[2-(4-Thiazolyl)-1 H-benzimidazole]
2-Mercaptobenzothiazole 1.0
(MET)
Merphos
Monuron
Ethyleneimine (Aziridine)
p-Nitrosodiphenylamine
Calcium cyanamide
Methyl parathion
Naled
Oxydemeton methyl
[S-(2-(Ethylsulfmyl)ethyl) O,O-
dimethyl ester phosphorothioic acid]
Hydrazine 0.1
2,2-Dichloro-1,1,1 -trifluoroethane 1.0
(HCFC-123)
Aldrin 1.0
[ 1,4:5,8-Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro-1,4,4a,5,8,8a-
hexahydro-( 1 .alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
Bromacil 1-0
(5-Bromo-6-methyl-3-( 1-methyl-
propyl)-2,4( lH,3H)-pyrimidine-
dione)
alpha-Hexachlorocyclohexane 1.0
Diuron 1 -0
Linuron 1 -0
Diazinon 1 -0
Diazomethane 1.0
Bromochlorodifluoromethane 1.0
(Halon 1211)
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
[Benzoic acid, 3-amino-2,5-dichloro-]
11-16 Table II
*C.I. means "Color Index"
-------
CAS Number Chemical Name
DeMinimis
Concentration
CAS Number Chemical Name
DeMinimis
Concentration
354-11-0 l,l,l,2-Tetrachloro-2-fluoroethane 1.0
(HCFC-121a)
354-14-3 1,1,2,2-Tetrachloro-l-fluoroethane 1.0
(HCFC-121)
354-23-4 l,2-Dichloro-l,l,2-trifluoroethane 1.0
(HCFC-123a)
354-25-6 l-Chloro-l,l,2,2-tetrafluoroethane 1.0
(HCFC-124a)
357-57-3 Brucine 1.0
422-44-6 1,2-Dichloro-1,1,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
422-48-0 2,3-DichIoro-1,1,1,2,3- 1.0
pentafluoropropane (HCFC-225ba)
422-56-0 3,3-Dichloro-l,1,1,2,2- 1.0
pentafluoropropane (HCFC-225ca)
431-86-7 1,2-Dichloro-l,1,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
460-35-5 3-Chloro-1,1,1 -trifluoropropane 1.0
(HCFC-253fb)
463-58-1 Carbonyl sulfide 1.0
465-73-6 Isodrin 1.0
492-80-8 C.I. Solvent Yellow 34 (Auramine) 0.1
505-60-2 Mustard gas 0.1
[Ethane, 1,1 '-thiobis [2-chloro-]]
507-55-1 1,3-Dichloro-l, 1,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
510-15-6 Chlorobenzilate 1.0
[Benzeneacetic acid, 4-chloro-.
a!pha.-(4-chlorophenyl)-.alpha.-
hydroxy-, ethyl ester]
528-29-0 o-Dinitrobenzene 1.0
532-27-4 2-Chloroacetophenone 1.0
533-74-4 Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione)
534-52-1 4,6-Dinitro-o-cresol 1.0
540-59-0 1,2-Dichloroethylene 1.0
541-41-3 Ethyl chloroformate 1.0
541-53-7 2,4-Dithiobiuret 1.0
541-73-1 1,3-Dichlorobenzene 1.0
542-75-6 1,3-Dichloropropylene 0.1
542-76-7 3-Chloropropionitrile 1.0
542-88-1 Bis(chloromethyl) ether 0.1
554-13-2 Lithium carbonate 1.0
556-61-6 Methyl isothiocyanate 1.0
[Isothiocyanatomethane]
563-47-3 3-Chloro-2-methyI-l-propene 0.1
569-64-2 C.I. Basic Green 4 1.0
584-84-9 Toluene-2,4-diisocyanate 0.1
593-60-2 Vinyl bromide 0.1
594-42-3 Perchloromethyl mercaptan 1.0
606-20-2 2,6-Dinitrotoluene 0.1
612-82-8 3,3'-Dimethylbenzidine 0.1
dihydrochloride
(o-Tolidine dihydrochloride)
612-83-9 3,3'-Dichlorobenzidine 0.1
dihydrochloride
615-05-4 2,4-Diaminoanisole 0.1
615-28-1 1,2-Phenylenediamine 1.0
dihydrochloride
621-64-7 N-Nitrosodi-n-propylamine 0.1,
624-18-0 1,4-Phenylenediamine 1.0.
dihydrochloride
624-83-9 Methyl isocyanate 1.0
630-20-6 1,1,1,2-Tetrachloroethane 1.0
636-21-5 o-Toluidine hydrochloride 0.1
639-58-7 Triphenyltin chloride 1.0
680-31-9 Hexamethylphosphoramide - 0.1
684-93-5 N-Nitroso-N-methylurea 0.1
709-98-8 Propanil (N-(3,4-DichIorophenyl) ~1.0
propanamide)
759-73-9 N-Nitroso-N-ethylurea 0.1
759-94-4 Ethyl dipropylthiocarbamate 1.0
(EPTC)
764-41-0 l,4-Dichloro-2-butene 1.0
812-04-4 1,1 -Dichloro-1,2,2-trifluoroethane 1.0
(HCFC-123b)
834-12-8 Ametryn 1.0
(N-Ethy 1-N' -(I -methylethy l)-6-
(methylthio)-1,3,5,-triazine-2,4-
diamine)
842-07-9 C.I. Solvent Yellow 14 1.0
872-50-4 N-Methyl-2-pyrrolidone 1.0
924-16-3 N-Nitrosodi-n-butylamine 0.1
924-42-5 N-Methylolacrylamide 1.0
957-51-7 Diphenamid 1.0
961-11-5 Tetrachlorvinphos 1.0
[Phosphoric acid, 2-chloro-1 -{2,4,5-
trichlorophenyl)ethenyl dimethyl
ester]
989-38-8 C.I. Basic Red 1 1.0
1114-71-2 Pebulate 1.0
[Butylethylcarbamothioic acid S-
propyl ester]
1120-71 -4 Propane sultone 0.1
1134-23-2 Cycloate 1.0
1163-19-5 Decabromodiphenyl oxide 1.0
1313-27-5 Molybdenum trioxide 1.0
1314-20-1 Thorium dioxide 1.0
*C.I. means "Color Index"
H-17 Table II
-------
CAS Number Chemical Name
DeMinimis
Concentration
CAS Number Chemical Name
DeMinimis
Concentration
1319-77-3
1320-18-9
1330-20-7
1332-21-4
1335-87-1
1336-36-3
1344-28-1
1464-53-5
1563-66-2
1582-09-8
1634-04-4
1649-08-7
1689-84-5
1689-99-2
1717-00-6
1836-75-5
1861-40-1
1897-45-6
1910-42-5
1912-24-9
1918-00-9
1918-02-1
1918-16-7
1928-43-4
1929-73-3
1929-82-4
1937-37-7
Cresol (mixed isomers) 1.0
2,4-D propylene glycol butyl 0.1
ether ester
Xylene (mixed isomers) 1.0
Asbestos (friable) 0.1
Hexachloronaphthalene 1.0
Polychlorinated biphenyls (PCBs) 0.1
Aluminum oxide (fibrous forms) 1.0
Diepoxybutane 0.1
Carbofuran 1.0
Trifluralin 1.0
[Benezeneamine, 2,6-dinitro-N,N-
dipropyl-4-(trifluoromethyl)-]
Methyl tert-butyl ether 1.0
1,2-Dichloro-1,1 -difluoroethane 1.0
(HCFC-132b)
Bromoxynil 1.0
(3,5-Dibromo-4-hydroxybenzonitrile)
Bromoxynil octanoate 1.0
(Octanoic acid, 2,6-dibromo-4-
cyanophenyl ester)
1,1-Dichloro-l-fluoroethane 1.0
(HCFC-141b)
Nitrofen 0.1
[Benzene, 2,4-dichloro-1 -(4-
nitrophenoxy)-]
Benfluralin
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
Chlorothalonil 1.0
[1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
Paraquat dichloride 1.0
Atrazine 0.1
(6-Chloro-N-ethyl-N'-( 1 -methyl-
ethyl)- 1,3,5-triazine-2,4-diamine)
Dicamba 1 -0
(3,6-Dichloro-2-methoxybenzoic
acid)
Picloram 1.0
Propachlor 1.0
[2-Chloro-N-( 1 -methy lethyl)-N-
pheny 1 acetamide]
2,4-D 2-ethylhexyl ester 0.1
2,4-D butoxyethyl ester 0.1
Nitrapyrin 1 -0
(2-Chloro-6-(trichloromethyl)-
pyridine)
C.I. Direct Black 38 0.1
1982-69-0 Sodium dicamba 1.0
[3,6-Dichloro-2-methoxybenzoic
acid, sodium salt]
1983-10-4 Tributyltin fluoride 1.0
2032-65-7 Methiocarb 1.0
2155-70-6 Tributyltin methacrylate 1.0
2164-07-0 Dipotassium endothall 1.0
[7-Oxabicyclo(2.2.1 )heptane-2,3- ,
dicarboxylic acid, dipotassium salt]
2164-17-2 Fluometuron 1.0
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethyl)phenyl]-]
2212-67-1 Molinate 1.0
(IH-Azepine-l-carbothioic acid,
hexahydro-S-ethyl ester)
2234-13-1 Octachloronaphthalene 1.0'
2300-66-5 Dimethylamine dicamba 1.0
2303-16-4 Diallate 1.0
[Carbamothioic acid, bis(l-methy 1-
ethyl)-S-(2,3-dichloro-2-propenyl)
ester]
2303-17-5 Triallate 1.0
2312-35-8 Propargite 1.0
2439-01-2 Chinomethionat 1.0
[6-Methy 1-1,3-dithiolo[4,5-b]-
quinoxalin-2-one]
Dodine 1.0
[Dodecylguanidine monoacetate]
2524-03-0 Dimethyl chlorothiophosphate 1.0
2602-46-2 C.I. Direct Blue 6 0.1
2655-15-4 2,3,5-Trimethylphenyl methyl 1.0
carbamate
2699-79-8 Sulfuryl fluoride (Vikane) 1.0
2702-72-9 2,4-D sodium salt 0.1
2832-40-8 C.I. Disperse Yellow 3 1.0
2837-89-0 2-Chloro-l,l,l,2-tetrafluoroethane 1.0
(HCFC-124)
2971-38-2 2,4-D Chlorocrotyl ester 0.1
3118-97-6 C.I. Solvent Orange 7 1.0
3383-96-8 Temephos 1.0
3653-48-3 Methoxone sodium salt 0.1
((4-Chloro-2-methylphenoxy)
acetate sodium salt)
3761-53-3 C.I. Food Red 5 0.1
4080-31 -3 1 -(3-Chloroally l)-3,5,7-triaza-1 - 1.0
azoniaadamantane chloride
4170-30-3 Crotonaldehyde 1.0
4549-40-0 N-Nitrosomethylvinylamine 0.1
4680-78-8. C.I. Acid Green 3 1.0
1.0 2439-10-3
H-18 Table II
*C.I. means "Color Index"
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
5234-68-4 Carboxin 1.0
(5,6-Dihydro-2-methy 1-N-phenyl-1,
4-oxathiin-3-carboxamide)
5598-13-0 Chlorpyrifos methyl 1.0
[O,O-DimethyI-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate]
5902-51-2 Terbacil 1.0
[5-Chloro-3-( 1,1 -dimethylethyl)-6-
methy 1-2,4(1 H,3H)-
pyrimidinedione]
6459-94-5 C.I. Acid Red 114 0.1
7287-19-6 Prometryn • 1.0
[N,N'-Bis(l-methylethyl)-6-
methylthio-1,3,5-triazine-2,
4-diamine]
7429-90-5 Aluminum (fume or dust) 1.0
7439-92-1 Lead 0.1
7439-96-5 Manganese 1.0
7439-97-6 Mercury 1.0
7440-02-0 Nickel 0.1
7440-22-4 Silver 1.0
7440-28-0 Thallium 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
7440-39-3 Barium 1.0
7440-41-7 Beryllium 0.1
7440-43-9 Cadmium 0.1
7440-47-3 Chromium . • 1.0
7440-48-4 Cobalt 0.1
7440-50-8 . Copper 1.0
7440-62-2 Vanadium (fume or dust) 1.0
7440-66-6 Zinc (fume or dust) 1.0
7550-45-0 Titanium tetrachloride 1.0
7632-00-0 Sodium nitrite 1.0
7637-07-2 Boron trifluoride 1.0
7647-01-0 Hydrochloric acid 1.0
(acid aerosols including mists,
vapors, gas, fog, and other airborne
forms of any particle size)
7664-38-2 Phosphoric acid 1.0
7664-39-3 Hydrogen fluoride 1.0
7664-41-7 Ammonia 1.0
(includes anhydrous ammonia and
aqueous ammonia from water
dissociable ammonium salts and
other sources; 10 percent of total
aqueous ammonia is reportable under
this listing)
7664-93-9 Sulfuricacid 1.0
(acid aerosols including mists,
vapors, gas, fog, and other airborne
forms of any particle size)
7696-12-0
7697-37-2
7723-14-0
7726-95-6
7758-01-2
7782-41-4
7782-49-2
7782-50-5
7786-34-7
7803-51-2
8001-35-2
8001-58-9
9006-42-2
10028-15-6
10034-93-2
10049-04-4
10061-02-6
10294-34-5
10453-86-8
12122-67-7
12427-38-2
13194-48-4
13356-08-6
13463-40-6
13474-88-9
13684-56-5
14484-64-1
15972-60-8
16071-86-6
16543-55-8
17804-35-2
Tetramethrin i .0
[2,2-Dimethyl-3-(2-methyl-l- .
propenyl)cyclopropanecarboxylic
acid (l,3,4,5,6,7-hexahydro-l,3-
dioxo-2H-isoindol-2-yl)methyl
ester]
Nitric acid i.o
Phosphorus (yellow or white) 1.0
Bromine i.o
Potassium bromate 0.1
Fluorine i .0
Selenium i .0
Chlorine i .0
Mevinphps l .0
Phosphine i .0
Toxaphene Q. 1
Creosote o. 1
Metiram i .0
Ozone i.o
Hydrazine sulfate 0.1
Chlorine dioxide 1.0
trans-1,3-Dichloropropene 0.1
Boron trichloride 1.0
Resmethrin l .0
[[5-(Phenylmethyl)-3-furanyl]methyl-
2,2-dimethy l-3-(2-methyl-1 -
propenyl)cyclopropanecarboxylate]]
1.0
1.0
1.0
Zineb
[Carbamodithioic acid, 1,2-
ethanediylbis-, zinc complex]
Maneb
[Carbamodithioic acid, 1,2-
ethanediylbis-, manganese complex]
Ethoprop l .0
[Phosphorodithioic acid O-ethyl S,S-
dipropyl ester]
Fenbutatin oxide
(Hexakis(2-methyl-2-
phenylpropyl)distannoxane)
Iron pentacarbonyl
1,1-Dichloro-1,2,2,3,3-
pentafluoropropane (HCFC-225cc)
Desmedipham
Ferbam
[Tris(dimethylcarbamodithioato-
S,S')iron]
Alachlor . l .0
C.I. Direct Brown 95 0.1
N-Nitrosonornicotine 0.1
Benomyl l .0
*C.I. means "Color Index"
H-19 Table II
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
19044-88-3
19666-30-9
20325-40-0
20354-26-1
20816-12-0
20859-73-8
21087-64-9
21725-46-2
22781-23-3
23564-05-8
23564-06-9
23950-58-5
25311-71-1
25321-14-6
25321-22-6
25376-45-8
26002-80-2
26471-62-5
26628-22-8
26644-46-2
27314-13-2
28057-48-9
Oryzalin 1 -0
[4-(Dipropylamino)-3,5-
dinitrobenzenesulfonamide]
Oxydiazon 1.0
[3-[2,4-Dichloro-5-( 1-methyl-
ethoxy)phenyl]-5-(l,l-dimethyl-
ethyl)-1,3,4-oxadiazol-2(3H)-one]
3,3'-Dimethoxybenzidine 0.1
dihydrochloride (o-Dianisidine
dihydrochloride)
Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-
1,2,4-oxadiazolidine-3,5-dione]
Osmium tetroxide 1.0
Aluminum phosphide 1.0
Metribuzin 1 -0
Cyanazine 1.0
Bendiocarb 1.0
[2,2-Dimethyl-1,3-benzodioxol-4-ol
methylcarbamate]
Thiophanate methyl 1.0
Thiophanate ethyl 1.0
[[1,2-Phenylenebis-
(iminocarbonothioyl)]biscarbamic
acid diethyl ester]
Pronamide 1.0
Isofenphos 1.0
[2-[[Ethoxyl[(l-methylethy I)-
amino]phosphinothioyl]oxy]benzoic
acid 1-methylethy 1 ester]
Dinitrotoluene (mixed isomers) 1.0
Dichlorobenzene (mixed isomers) 0.1
Diaminotoluene (mixed isomers) 0.1
Phenothrin 1.0
[2,2-Dimethyl-3-(2-methyl-1-
propenyl)cyclopropanecarboxylic
acid (3-phenoxyphenyl)methyl ester]
Toluene diisocyanate 0.1
(mixed isomers)
Sodium azide 1.0
Triforine 1.0
[N,N' -[ 1,4-Piperazinediy lbis(2,2,2-
trichloroethylidene)]bisformamide]
Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl]-3(2H)-
pyridazinone]
d-trans-Allethrin 1.0
[d-trans-Chrysanthemic acid of d-
allethrone]
De Minimis
Concentration
1.0
28249-77-6 Thiobencarb
[Carbamic acid, diethylthio-, S-(p-
chlorobenzyl)ester]
28407-37-6 C.I. Direct Blue 218 1.0
29232-93-7 Pirimiphos methyl 1.0
[O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-dimethyl
phosphorothioate]
30560-19-1 Acephate 1.0
(Acetylphosphoramidothioic acid
O,S-dimethyI ester)
31218-83-4 Propetamphos 1.0
[3-[(Ethylamino)methoxy
phosphinothioyl]oxy]-2-butenoic
acid, 1-methylethyl ester]
33089-61-1 Amitraz 1.0
34014-18-1 Tebuthiuron 1.0
[N-[5-( 1,1 -Dimethylethyl)-1,3,4-
thiadiazol-2-yl]-N,N'-dimethylurea]
34077-87-7 Dichlorotrifluoroethane 1.0
35367-38-5 Diflubenzuron 1.0
35400-43-2 Sulprofos 1.0
[O-Ethyl O-[4-(methylthio)phenyl] -
phosphorodithioic acid S-propyl
ester]
35554-44-0 Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl]-lH-imidazole]
35691-65-7 l-Bromo-l-(bromomethyl)-l,3- 1.0
propanedicarbonitrile
38727-55-8 Diethatyl ethyl 1.0
39156-41-7 2,4-Diaminoanisole sulfate 0.1
39300-45-3 Dinocap 1 -0
39515-41-8 Fenpropathrin 1.0
[2,2,3,3-Tetramethylcyclopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
40487-42-1 Pendimethalin 1.0
[N-(l-Ethylpropyi)-3,4-dimethyl-2,6-
di nitrobenzenam i ne]
41198-08-7 Profenofos 1.0
[O-(4-Bromo-2-chlorophenyl)-O-
ethyl-S-propyl-phosphorothioate]
41766-75-0 3,3'-Dimethylbenzidine 0.1
dihydrofluoride (o-Tolidine
dihydrofluoride)
42874-03-3 Oxyfluorfen 1 -0
43121-43-3 Triadimefon 1.0
[ i -(4-Chlorophenoxy)-3,3-dimethyl-
1 -(1H-1,2,4-triazol-1 -yl)-2-butanone]
11-20 Table II
*C.I. means "Color Index"
-------
CAS Number Chemical Name
DeMinimis
Concentration
CAS Number Chemical Name
DeMinimis
Concentration
50471-44-8 Vinclozolin 1.0
[3-(3,5-Dichlorophenyl)-5-ethenyl-5-
methyl-2,4-oxazolidinedione]
51235-04-2 Hexazinone 1.0
51338-27-3 Diclofop methyl 1.0
[2- [4-(2,4-Dichlorophenoxy)-
phenoxy]propanoic acid, methyl
ester]
51630-58-1 Fenvalerate 1.0
[4-Chloro-alpha-(l-methylethyl)-
benzeneacetic acid cyano(3-
phenoxyphenyl)methyl ester]
52645-53-1 Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropane carboxylic
acid, (3-phenoxyphenyl)methyl
ester]
53404-19-6 Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione, 5-
bromo-6-methyl-3-( 1 -methylpropyl),
lithium salt]
53404-37-8 2,4-D 2-ethyl-4-methylpentyl ester 0.1
53404-60-7 Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-1,3,5-
thiadiazine-2-thione, ion(l-),
sodium]
55290-64-7 Dimethipin 1.0
[2,3-Dihydro-5,6-dimethyl-1,4-
dithiin 1,1,4,4-tetraoxide]
55406-53-6 3-Iodo-2-propynyl butylcarbamate 1.0
57213-69-1 Triclopyr triethylammonium salt 1.0
59669-26-0 Thiodicarb 1.0
60168-88-9 Fenarimol 1.0
[.alpha.-(2-Chlorophenyl)-.alpha.-4-
chlorophenyl)-5-pyrimidine-
methanol]
60207-90-1 Propiconazole 1.0
[l-[2-(2,4-Dichlorophenyl)-4-propyl-
1,3-dioxolan-2-yl]-methyl-1H-1,2,4,-
triazole]
62476-59-9 Acifluorfen, sodium salt 1.0
[5-(2-Chloro-4-(trifluoromethyl)-
phenoxy)-2-nitrobenzoic acid, sodium
salt]
63938-10-3 Chlorotetrafluoroethane 1.0
64902-72-3 Chlorsulfuron 1.0
[2-Chloro-N-[[(4-methoxy-6-methyl-
1,3,5-triazin-2-yl)amino]
carbonyl]benzenesulfonamide]
64969-34-2 3,3'-Dichlorobenzidine sulfate 0.1
66441-23-4 Fenoxaprop ethyl 1.0
[2-(4-((6-Chloro-2-benzoxazolylen)-
oxy)phenoxy)propanoic acid, ethyl
ester]
67485-29-4 Hydramethylnon 1.0
[Tetrahydro-5,5-dimethyl-2( 1H)-
pyrimidinone[3-[4-
(trifluoromethyl)phenyl]-1 -[2-[4-
(trifluoromethyl)phenyl]ethenyl]-2-
propenylidene]hydrazone]
68085-85-8 Cyhalothrin 1.0
[3-(2-ChIoro-3,3,3-trifluoro-1-
propenyl)-2,2-Dimethylcyclo-
propanecarboxylic acid cyano(3-
phenoxyphenyl) methyl ester]
68359-37-5 Cyfluthrin l.o
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic
acid, cyano(4-fluoro-3-
phenoxyphenyl)methyl ester]
69409-94-5 Fluvalinate 1.0
[N-[2-Chloro-4-(trifluoromethyl)-
phenyl]-DL-valine(+)-cyano(3-
phenoxyphenyl)methyl ester]
69806-50-4 Fluazifop butyl 1.0
[2- [4-[ [5-(Trifluoromethy l)-2-
pyridinyl]oxy]phenoxy]propanoic
acid, butyl ester]
71751-41-2 Abamectin [AvermectinBl] 1.0
72178-02-0 Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)-
phenoxy)-N-methylsulfonyI)-2-
nitrobenzamide]
72490-01-8 Fenoxycarb 1.0
[[2-(4-Phenoxyphenoxy)ethyl-]
carbamic acid ethyl ester]
74051-80-2 Sethoxydim 1.0
[2-[l-(Ethoxyimino)butyl]-5-[2-
(ethylthio)propyl]-3-hydroxyl-2-
cyclohexen-1 -one]
76578-14-8 Quizalofop-ethyl 1.0
[2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy]
propanoic acid ethyl ester]
77501-63-4 Lactoten 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-
ethoxy- l-methyl-2-oxoethyl ester]
82657-04-3 Bifenthrin 1.0
*C.I. means "Color Index"
11-21 'Table II
-------
CAS Number Chemical Name
De Minimis
Concentration
1.0
88671-89-0 Myclobutanil
[.a!pha.-Butyl-.alpha.-(4-
chloropheny 1)-1H-1,2,4-triazole-1 -
propanenitrile]
90454-18-5 Dichloro-l,l,2-trifluoroethane 1.0
90982-32-4 Chlorimuron ethyl 1.0
[Ethyl-2-[[[[(4-chloro-6-
methoxyprimidin-2-yl)amino]-carbonyl]-
amino]sulfonyl]benzoate]
101200-48-0 Tribenuron methyl 1.0
[2-[[[[(4-Methoxy-6-methyl-l,3,5-
triazin-2-yl)methylamino]carbonyl]
amino]sulfonyl]benzoic acid-, methyl
ester]
111512-56-2 l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
111984-09-9 3,3'-Dimethoxybenzidine 0.1
hydrochloride (o-Dianisidine
hydrochloride)
127564-92-5 Dichloropentafluoropropane 1.0
128903-21-9 2,2-Dichloro-1,1,1,3,3- 1.0
pentafluoropropane (HCFC-225aa)
136013-79-1 1,3-Dichloro-1,1,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
c. 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,
nickel, 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 OSHA carcinogen in which case the
0.1 percent de minimis concentration applies. The de
minimis concentration for each category is provided in
parentheses.
Antimony Compounds (1.0)
Includes any unique chemical substance thatcon-
tains antimony as part of that chemical's infra
structure.
Arsenic Compounds (inorganic compounds: 0.1;
organic compounds: 1.0)
Includes any unique chemical substance that
contains arsenic as part of that chemical's
infrastructure.
Barium Compounds (1.0)
Includes any unique chemical substance that
contains barium as part of that chemical's
infrastructure. This category does not include:
Barium sulfate CAS Number 7727-43-7
Beryllium Compounds (0.1)
Includes any unique chemical substance
that contains beryllium as part of that
chemical's infrastructure.
Cadmium Compounds (0.1)
Includes any unique chemical substance
that contains cadmium as part of that
chemical's infrastructure.
11-22 Table II
*C.I. means "Color Index"
-------
Chlorophenols (0.1)
OH
(5-x)
Where x = 1 to 5
Chromium Compounds (chromium VI compounds: 0.1;
chromium ID compounds: 1.0)
Includes any unique chemical substance that
contains chromium as part of that chemical's'
infrastructure.
Cobalt Compounds (0.1)
Includes any unique chemical substance that
contains cobalt as part of that chemical's infra-
structure.
Copper Compounds (1.0)
Includes any unique chemical substance that
contains copper as part of that chemical's infra-
structure.
This category does not include copper phthalocya-
nine compounds that are substituted with only
hydrogen, and/or chlorine, and/or bromine.
Cyanide Compounds (1.0)
X+CN~ where X = H* or any other group where a
formal dissociation may occur. For example KCN
or Ca(CN)2.
Diisocyanates (1.0)
This category includes only those chemicals listed
below.
38661 -72-2 1,3-Bis(methylisocyanate) -
cyclohexane
10347-54-3 1,4-Bis(methylisocyanate)-
cyclohexane
2556-36-7 1,4-Cyclohexane diisocyanate
134190-37-7 Diethy Idiisocy anatobenzene
4128-73-8 4,4'-Diisocyanatodiphenyl ether
75790-87-3 2,4'-Diisocyanatodiphenyl
sulfide
91-93-0 3,3'-Dimethoxybenzidine-4,4'-
diisocyanate
91 -97-4 3,3'-Dimethyl-4,4'-diphenylene
diisocyanate
139-25-3 3,3'-Dimethyldiphenylmethane-
4,4'-diisocyanate
822-06-0 Hexamethy lene-1,6-diisocyanate
4098-71-9 Isophorone diisocyanate
75790-84-0 4-MethyIdiphenylmethane-3,4-
diisocyanate
5124-30-1 l,l-Methylenebis(4-
, isocyanatocyclohexane)
101-68-8 Methylene bis(phenylisocyanate)
(MDI)
3173-72-6 1,5-Naphthalene diisocyanate
123-61 -5 1,3-Phenylene diisocyanate
104-49-4 1,4-Phenylene diisocyanate
9016-87-9 Polymeric diphenylmethane
diisocyanate
16938-22-0 2,2,4-Trimethylhexamethylene
diisocyanate
15646-96-5 2,4,4-Trimethylhexamethylene
diisocyanate
Ethylenebisdithiocarbamic acid, salts and esters
(EBDCs) (1.0)
Includes any unique chemical substance that
contains and EBDC or an EBDC salt as pan of
that chemical's infrastructure.
Certain Glycol Ethers (1.0)
R-(OCH,CH2)n-OR'
Where n = 1, 2, or 3
R = alkyl C7 or less; or
R = phenyl or alkyl substituted phenyl;
R' = H, or alkyl C7 or less; or
OR' consisting of carboxylic acid ester, sulfate,
phosphate, nitrate, or sulfonate.
Lead Compounds (inorganic compounds: 0.1; organic
compounds 1.0)
Includes any unique chemical substance that
contains lead as part of that chemical's infrastruc-
ture.
Manganese Compounds (1.0)
Includes any unique chemical substance that
contains manganese as part of that chemical's
infrastructure.
Mercury Compounds (1.0)
Includes any unique chemical substance that
contains mercury as part of that chemical's
infrastructure.
*C.I. means "Color Index"
H-23 Table II
-------
Nickel Compounds (0.1)
Includes any unique chemical substance that
contains nickel as part of that chemical's infra-
structure.
Nicotine and salts (1.0)
Includes any unique chemical substance that
contains nicotine or a nicotine salt as part of that
chemical's infrastructure.
Nitrate compounds (water dissociable; reportable only
when in aqueous solution) (1.0)
PolybrominatedBiphenyls (PBBs) (0.1)
(10-x)
Where x=l to 10
Polychlorinated alkanes (CIO to C13) (1.0, except for
those members of the category that have an average
chain length of 12 carbons and contain an average
chlorine content of 60 percent by weight which are
subject to the 0.1 percent de minimis)
,
where x= 10 to 13;
y = 3 to 12; and
the average chlorine content ranges from 40 -
70% with the limiting molecular formulas
C,0H19Cl3andCl3H16Cl12
Polycyclic aromatic compounds (PACs) (0.1 except for
benzo(a)phenanthrene and dibeuzo(a,e)fluoranthene
which are subject to the 1.0 percent de minimis)
This category includes only those chemicals
listed below.
56-55-3 Benz(a)anthracene
205-99-2 Benzo(b)fluoranthene
205-82-3 Benzo(j)fluoranthene
207-08-9 Benzo(k)fluoranthene
189-55-9 Benzo(rst)pentaphene
218-01-9 Benzo(a)phenanthrene
50-32-8 Benzo(a)pyrene
226-36-8 Dibenz(a,h)acridine
224-42-0 Dibenz(a,j)acridine
53-70-3 Dibenzo(a,h)anthracene
194-59-2 7H-Dibenzo(c,g)carbazole
5385-75-1 Dibenzo(a,e)fluoranthene
192-65-4 Dibenzo(a,e)pyrene
189-64-0 Dibenzo(a,h)pyrene
191 -30-0 Dibenzo(a,l)py rene
57-97-6 7,12-Dimethylbenz(a)anthracene
193-39-5 Indeno[l,2,3-cd]pyrene
3697-24-3 5-Methylchrysene
5522-43-0 1-Nitropyrene
Selenium Compounds (1.0)
Includes any unique chemical substance that
contains selenium part of that chemical's infra-
structure.
Silver Compounds (1.0)
Includes any unique chemical substance that
contains silver part of that chemical's infrastruc-
ture.
Strychnine and salts (1.0)
Includes any unique chemical substance that
contains strychnine or a strychnine salt as part of
that chemical's infrastructure.
Thallium Compounds (1.0)
Includes any unique chemical substance that
contains thallium as part of that chemical's
infrastructure.
Warfarin and salts (1.0)
Includes any unique chemical substance that
contains warfarin or a warfarin salt as part of that
chemical's infrastructure.
Zinc Compounds (1.0)
Includes any unique chemical substance that
contains zinc as part of that chemical's infrastruc-
ture.
11-24 Table H
*C.I. means "Color Index"
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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
PL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Neveda
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Commonwealth of Northern
Mariana Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
MT
NE
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 III-l
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APPENDIX A. FEDERAL FACILITY REPORTING
INFORMATION
Special Instructions for TRI Federal
Facility Reporting
Why Do Federal Facilities Need to Report?
EO 12856, Pollution Prevention and Right-to-Know Re-
porting, requires federal agencies to comply with the
Emergency Planning and Community Right-to-Know Act
of 1986 (EPCRA) and the Pollution Prevention Act of 1990
(PPA). By Executive Order, federal facilities must report
Toxics Release Inventory (TRI) data, pursuant to the Emer-
gency Planning and Community Right-to-Know Act of
1986, Section 313, to EPA beginning with calendar year
1994 data. TRI submissions are due to EPA on July 1 of
the year following each reporting (calendar) year.
Identifying Federal Facility Reports
Federal facility reports are identified as federal by several
indicators on the form. The facility name and parent com-
pany name are critical indicators and must be reported as
described below. Another critical indicator is the federal
facility report box. Federal facilities only should check
this box (Form R page 2, block 4.2c) to indicate that the
report is from a federal agency for a federal facility. Fed-
eral facilities should also complete the partial or complete
facility blocks (Form R page 2, block 4.2a and 4.2b) as ap-
propriate. If you are a federal facility reporting for the
first time, write "new" in the TRI Facility ID (TRIFID) box,
even if a contractor has reported for your facility in the
past. The contractor will retain the original TRIFID. You
will be assigned a new TRIFID the first time you report.
The "Double Counting" Problem
As structured, the law and the executive order require both
regulated industries and the federal government to report
TRI data, sometimes for the same site. In order to pre-
vent duplicate data in the TRI database, which could re-
sult in "double counting" data for some chemicals and
locations, EPA must be able to identify and distinguish
the "Government Owned Contractor Operated" (GOCO)
reports submitted by the federal contractor from the fed-
eral reports which contain data for the same site. To ac-
complish this, federal facility reports must be accompa-
nied by either 1) exact copies (paper or electronic) of all
contractor TRI reports included in the totals reported by
the federal facility, or 2) a cover letter which includes a
list of the facility contractors which submit TRI reports to
EPA, identifying each contractor by name, TRI technical
contact, and TRI facility name and address.
Magnetic Media Reporting
EPA encourages all federal facilities and GOCO facilities
to report using either EPA's Magnetic Media reporting soft-
ware, or one of the commercially available packages. If
the GOCO also submits its reports on magnetic media to
EPA and to the federal facility, the federal facility may sub-
mit magnetic media copies of their GOCO TRI reports to
EPA. Magnetic media reports must be accompanied by a
cover letter which includes:
- the required Form R certification statement;
- a list of the chemicals reported on the
federal facility's disk; and
- a list, identifying the contractor(s) by name
and by TRIFID number if they have an
assigned TRIFID number, and the chemicals
they reported (which are on the contractors'
attachment disk(s))
How to Report Your Facility Name
Facility name is a critical data element. It is used by EPA
to create the TRI facility ID number, which is a unique
number designed to identify a facility site. The facility
name and TRIFID number are used by all TRI data users
to link data from a single site across multiple reporting
years. Each federal facility will be assigned a new TRIFID
number when the federal report is entered into the Toxics
Release Inventory system for the first time. This TRIFID
number, generated when the first report is entered into
the Toxics Release Inventory System, will be included in
future reporting packages sent to federal facilities, and
should be used by federal facilities in all future reports.
Federal facilities should report their facility name
on page 1 of the Form Rs (Section 4.1), as shown in the
following example:
U.S. DOE Savannah River Site
It is very important that the agency name appear
first, followed by the specific plant or site name.
Federal facility GOCOs should report their names
as shown in the following example:
U.S. DOE Savannah River Site - Westinghouse Operations.
Appendix A A-l
-------
How to Report Your Standard Industrial Clas-
sification (SIC) Code
Federal facilities should report the SIC Code which most
closely represents the activities taking place at the site.
Additional guidance on determining your SIC code is pro-
vided in the Forms and Instructions booklet. The table on
the next page contains Public Administration SIC codes
91-97 covering executive, legislative, judicial, administra-
tive and regulatory activities of the Federal government.
Government-owned and operated business establish-
ments are classified in Major SIC groups 01-89 according
to the activity in which they .are engaged. For example, a
Veterans Hospital would be classified in Group 806 - Hos-
pitals.
How to Report Your "Parent Company" Name
Federal facilities should report their parent company name
on page 2 of the Form R's (Section 5.1) by reporting their
complete Department or Agency name, as shown in the
following example:
U.S. Department of Energy
Block 5.2, Parent Company's Dun & Bradstreet Number,
should be marked NA.
GOCOs should not report a federal department or agency
name as their parent company. A federal name in the par-
ent company name field will classify the report as fed-
eral, and the GOCO may be identified as a non-reporter.
How to Revise Your Data After It Has Been
Submitted
Any TKI Form R submitter may voluntarily revise their
submission if they find errors after their reports have been
sent to EPA. If a federal facility receives a copy of a revi-
sion from a GOCO, the facility should revise the federal
report, and submit the revised report to EPA and the ap-
propriate state along with an exact copy of the GOCO's
revision. If the revision is to a hardcopy report, the facil-
ity should photocopy the original form, use a blue or black
pen to mark out the incorrect value and write in the cor-
rected value. The revised report should be submitted to
EPA, with an "X" in the revision block on page 1 of the
Form R. If the revision is to a diskette, a new diskette
should be submitted, containing the data only for the re-
vised submission, not all the chemicals originally reported.
The cover letter must indicate that the submission is a re-
vision.
National Security Data
DO NOT SUBMIT NATIONAL SECURITY DATA TO
THE EPCRA REPORTING CENTER. National security
data are handled through a separate process. Facilities
should consult the Guidance for Implementing Executive
Order 12856 documents or call the EPCRA Hotline if their
Form R submission involves a national security data claim.
Who Should Sign Federal Form R Reports?
Federal Form R reports must be signed by the senior fed-
eral employee on-site. If no federal employee is on-site,
federal Form R reports must be signed by the senior fed-
eral employee with management responsibility for the site.
Federal Form R reports must be signed by a federal em-
ployee. Contractor employee signatures are not consid-
ered valid on federal reports.
More Help is Available!
Federal facilities may call EPA's EPCRA Hotline at 1-800-
535-0202 to ask specific questions concerning how to sub-
mit their Form R reports.
A-2 Appendix A
-------
Standard Industrial Classification
Codes 91-97
Division J- Public Administration
91 Executive, Legislative, and General
Government, Except Finance
9111 Executive Offices
9121 Legislative Bodies
9131 Executive and Legislative Offices Combined
9199 General Government, Not Elsewhere Classified
92 Justice, Public Order, and Safety
9211 Courts
9221 Police Protection
9222 Legal Counsel and Prosecution
9223 Correctional Institutions
9224 Fire Protection
9229 Public Order and Safety, Not Elsewhere Classified
93 Public Finance, Taxation, and Monetary
Policy
9311 Public Finance, Taxation, and Monetary Policy
94 Administration of Human Resource
Programs
9411 Administration of Educational Programs
9431 Administration of Public Health Programs
9441 Administration of Social, Human Resource and
Income Maintenance Programs
9451 Administration of Veterans' Affairs, Except Health
and Insurance
95 Administration of Environmental
Quality and Housing Programs
9511 Air and Water Resource and Solid Waste Manage-
ment
9512 Land, Mineral, Wildlife, and Forest Conservation
9531 Administration of Housing Programs
9532 Administration of Urban Planning and Commu-
nity and Rural Development
96 Administration of Economic
Programs
9611 Administration of General Economic Programs
9621 Regulation and Administration of Transporta-
tion Programs
9631 Regulation and Administration of Communica-
tions, Electric, Gas, and Other Utilities
9641 Regulation of Agricultural Marketing and Com-
modities
9651 Regulation, Licensing, and Inspection of Miscella-
neous Commercial Sectors
9661 Space Research and Technology
97 National Security and International
Affairs
9711 National Security
9721 International Affairs
Appendix A A-3
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APPENDIX B. REPORTING CODES FOR EPA FORM R
Part II, Section 1.1 - CAS Number
Toxic Chemical Category Codes
N010 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Clorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N171 Ethylenebisdithiocarbamic acid, salts
and esters(EBDCs)
N230 Glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N511 Nitrate compounds
N575 Polybrominated biphenyls (PBBs)
N583 Polchlorinated alkanes
N590 Polycyclic aromatic compounds
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts
N760 Thallium compounds
N874 Warfarin and salts
N982 Zinc compounds
Part II, 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 II, 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 relating release quantity to through-
put or equipment type (e.g., air emission factors).
O: Estimate is based on other approaches such as
engineering calculations (e.g., estimating volatil-
ization using published mathematical formulas
or best engineering judgment.) This would in-
clude applying an estimated removal efficiency
to a waste stream, even if the composition of the
waste stream before treatment was fully charac-
terized by monitoring data.
Part II, 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
M41 Solidification/Stabilization Metals and Metal
Compounds only
M50 Incineration/Thermal Treatment
M54 Incineration/Insignificant Fuel Value
M56 Energy Recovery
M61 Wastewater Treatment (Excluding POTW)
M62 Wastewater Treatment (Excluding POTW)
Metals and Metal Compounds only
Appendix B B-l
-------
M69 Other Waste Treatment
M71 Underground Injection
M72 Landfill/Disposal Surface Impoundment
M73 Land Treatment
M79 Other Land Disposal
M90 Other Off-Site Management
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 (PIPS') Codes
for Transfers of the Toxic Chemical to Other Countries
This is an abridged list of countries to which a U.S.
facility might ship a listed toxic chemical. For a
complete listing of FITS codes, consult your local
library. To obtain a PIPS code for a country not listed,
contact the EPCRA Hotline.
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 II, 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 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
C46 General Oxidation (including Disinfection) --
Other
C99 Other Chemical Treatment
Incineration/Thermal Treatment
F01 Liquid Injection
Fll Rotary Kiln with Liquid Injection Unit
F19 Other Rotary Kiln
F31 Two Stage
B-2 Appendix B
-------
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
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
Range of Influent Concentration
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 II, Section 7B - On-Site Energy Recovery
Processes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
U09 Other Energy Recovery Methods
Part II, 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 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
Part II, 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
Appendix B B-3
-------
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
SpilLand 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
Part II, 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 which 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
a formal company program)
T06 Employee Recommendation (under
a formal company program)
T07 State Government Technical Assistance
Program
T08 Federal Government Technical Assistance
Program
T09 Trade Association/Industry Technical
Assistance Program
T10 Vendor Assistance
Til Other
B-4 Appendix B
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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: Threshold
determination errors, errors completing the Form R and release estimation errors. These errors result in omission of
required toxic chemical reports, inaccurate data entered into the TRI database, prevention of report data being entered
into the database, and the underestimation or overestimation of quantities of toxic chemical reported.
Some .errors on the Form R do not allow the data to be processed. These type of errors are usually facility
identification/location errors, chemical identification errors, missing pages, invalid Form R, magnetic disk process-
ing errors, or more than one chemical reported per Form R. EPA will issue a Notice of Significant Error and / or a Notice
of Noncompliance to facilities with these types of errors. The notice will indicate that the Form R cannot be further
processed and entered into the TRI database and that changes must be submitted to EPA by a certain date or further
enforcement actions may be taken.
For other types of Form R completion errors, including missing required data or erroneous data, the facility will be
issued a Notice of Technical Error by EPA. This notice will explain the nature of the error and will require that
corrections be returned to EPA by a certain date. These type of errors usually involve, for example, the use of invalid
codes, missing required data or obvious errors such as incorrect latitude/longitude or facility identification numbers.
Other errors include incomplete off-site information and not reporting Section 5 and 6 quantities in the appropriate
fields in Section 8 and vice versa.
EPA may initiate an inspection to review the activities at a facility involving reportable toxic chemicals. If, as a result
of the inspection, EPA determines that the facility should have submitted a Form R, then EPA may take enforcement
action against the facility, which may involve the subsequent assessment of fines. Errors which result in non-reporting
violations include incorrect threshold determination, misapplying exemptions, and overlooking activity involving
a reportable chemical.
Facilities should also keep copies of submitted Form R reports and all documentation used to complete the report.
The documentation should include calculations for threshold determinations, the basis of exemptions applied, and
the estimation techniques and data used for all quantities reported on the Form R.
Form R Completion Errors
Q Invalid chemical identification on page 2. The
GAS number and the chemical name reported on
page 2 must exactly match the listed section 313
CAS number and toxic chemicalname. 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 (Table II). Mixture
names are to be entered in Part II, Section 2 only
if the supplier is claiming the identity of the toxic
chemical trade secret and that is the sole identifi-
cation. Mixture names that include the name or
CAS number of one or more section 313 toxic
chemical(s) are not valid uses of the mixture
name field.
Q Missing certification signature. An original
certification signature must appear on page 1 of
every Form R submitted to EPA.
Q Incomplete forms. A complete Form R report for
any toxic chemical or toxic chemical category
consists of at least five unique pages stapled
together. EPA cannot enter into the database
data from a package which contains only one
pagel,butseveralpage2's,3's,4's,5's, etc.These
are considered incomplete submissions.
Q Maximum amount on-site left blank. In a sur-
prising number of Form R submissions, Part II,
Section 4 on page 2 is left blank. The appropriate
code is required in this field.
q Invalid Forms. Be sure to use the correct version
of the form for the reporting year in question.
You cannot use forms provided for reporting
years 1987-1990 to report data for years 1991-
1995. You cannot use Form Rs provided for
reporting years 1987-1995 to report data for years
1996 and beyond.
Appendix C C-l
-------
Q "Questionable" entries, such as:
Missing or incorrect ZIP codes;
Missing county names;
Invalid SIC codes;
Missing or invalid Dun and
Bradstreet numbers;
Incomplete off-site and POTW
information (e.g., missing city name)
Incorrect entries such as these may require cor-
rections to be made by the facility. If amounts are
reported in units other than pounds (e.g., metric)
or with exponential numbers, EPA may require a
revision of the Form R to be submitted.
Q Incorrect latitude and longitude coordinates.
Latitude and longitude coordinates are impor-
tant data on the Form R. 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.
Q Incorrect completion of trade secret informa-
tion. The response to trade secret questions in
Section 1.2 and Section ILLS of a Form R must be
consistent. If trade secrecy is indicated, a sani-
tized Form R and two trade secret substantia-
tions (one sanitized) must be submitted in the
same package as the trade secret Form R. Leave
Section n.1.3 blank if no trade secret claim is
being made.
Q Revisions not identified. Revisions to previ-
ously submitted data may be provided to EPA by
making corrections in blue and black ink on a
completed copy of the Form R originally submit-
ted; if a revision is made for reporting year 1991
or later, mark an "X" in the space marked "Enter
"X" here if this is a revision" on page 1; provide
an original signature and new date, and send the
completed form to the EPCRA Reporting Center.
You must also send a copy of the revision to the
appropriate State agency. Revisions to data
submitted using magnetic media must be sub-
mitted with a newly signed cover letter.
Q Duplicate submissions not identified. Facili-
ties sometimes send multiple copies of the same
Form R to insure that EPA received a copy.
Duplicate submissions must be identified by
printing the word "DUPLICATE" inblue or black
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.
Q Failure to report waste treatment in Section 7A.
Waste treatment methods used to treat waste
streams containing toxic chemicals, and the effi-
ciencies of these methods, must be reported on
Form R. Information must be entered for all
waste streams, even if the waste treatment does
not affect the toxic chemical. If no waste treat-
ment is performed on waste streams containing
the toxic chemical, the box marked "Not Appli-
cable" in Part II, Section 7A must be checked on
the Form R. Follow the instructions for reporting
waste treatment methods for more than eight
treatment methods for a single waste stream.
Q Incorrect reporting of waste treatment methods
in Section 7A. The type of waste stream, influent
concentration, and waste treatment method for
each waste stream are required to be reported on
Form R using specific codes, along with the waste
treatment efficiency expressed as percent of re-
moval. Invalid or missing treatment codes or
missing efficiency data are common errors in
Section 7A.
Q 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 will not be
included as part of the TRI database.
Q Reporting discharges of mineral acids after neu-
tralization. When a waste stream containing a
mineral acid is neutralized to a pH of 6 or above,
the mineral acid is considered 100 percent neu-
tralized for purposes of EPCRA Section 313 re-
porting. As a result, the release of a neutralized
acid discharge should be reported on Form R as
zero.
Q Not completing all sections of Form R. Every
section of Form R must contain data or at least
one "NA".
Q Duplicate quantities in Part II, Sections 5 and 6.
A facility's discharge to a receiving stream should
not also be reported as a transfer to a POTW and
vice versa. Releases to on-site landfills should
not also be reported as an off-site transfer to
landfill and vice versa.
C-2 Appendix C
-------
Q Documentation. Any information used to com- Q
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
must be maintained by the submitting facility for Q
three years.
Q 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 must be 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. Other Q
commonly overlooked activities include impor-
tation of chemicals, generation of waste
byproducts, reaction intermediates, the use of
chemicals for cleaning of equipment, and the
combustion of coal and/or oil. Failure to cor-
rectly identify all uses of toxic chemicals at your
facility may result in the omission of a required
Form R.
Q Misclassification of a toxic chemical activity.
Failure to correctly classify a toxic chemical activ- Q
ity may result in an incorrect threshold determi-
nation. As a result, a Form Rmay not be submitted
when one is required. "Manufacture" means to
produce, prepare, compound, or import a listed
toxic chemical. "Process" means the preparation
of a listed toxic chemical after its manufacture,
which incorporates the toxic chemical into the
finalproduct, for distribution in commerce. "Oth-
erwise use" encompasses any use of a listed toxic
chemical that does not fall under the terms "manu-
facture" or "process." For example, solvents in
paint applied to a manufactured product are
often misclassified as processed, instead of oth-
erwise used. Because the solvents are not inten-
tionally incorporated into the final product, the
solvent is being otherwise used, not processed.
Failure to submit a Form R because of an incor-
rect threshold determination resulting from a
misclassif ication of a toxic chemical activity may
result in an enforcement action.
Toxic chemical in mixtures. When the toxic
chemical being reported is a component in a
mixture, report only the weight of the toxic chemi-
cal in the mixture. Refer to Section B.4.b of the
instructions for calulating the weight of a toxic
chemical in a mixture.
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 EPCRA Section 313
Questions and Answers document, which includes
"Directive #1: Article Exemption." For example,
only processing or otherwise use of an article is
exempt. Incorrectly assuming that the manufac-
ture of an article is exempt will result in incor-
rectly omitting toxic chemicals which are required
to be included in a threshold determination.
Misinterpretation of the toxic chemical list. Each
individually listed toxic chemical subject to sec-
tion 313 reporting requirements has a specific
Chemical Abstract Service (CAS) registry num-
ber or toxic chemical category code associated
with it. All information available at the facility,
such as MSDSs and the Common Synonyms for
Chemicals Listed Under Section 313 of EPCRA docu-
ment, must be used to identify the listed toxic
chemicals being reported.
Failure to consider a listed toxic chemical quali-
fier. Aluminum, vanadium, and zinc are quali-
fied as "fume or dust." Isopropyl alcohol and
saccharin have manufacturing qualifiers. Phos-
phorus is qualified as yellow or white. Asbestos
is qualified as friable. Aluminum oxide is quali-
fied as fibrous forms. Sulfuric Acid and hydro-
chloric acid are qualified as aerosol. Only toxic
chemicals in the form specified in the qualifier
require reporting under section 313 and should
be reported on Form R with the appropriate
qualifier in parentheses. For example, 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 isopropyl alcohol by the strong
acid process. If it is manufactured by another
process, or simply processed or otherwise used,
you are not required to report it.
Appendix C C-3
-------
Q 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.
Q Reporting zero 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 occur.
Only in special cases with completely closed
systems may no emission to air occur.
Q Reporting Chemical Category Codes in Section
1.1. Beginning with the 1991 reporting year, EPA
has assigned alphanumeric category codes to the
chemical categories for the purposes of reporting
in Section 1.1, the CAS number field. If you are
completing a Form Rf or a chemical category, you
must provide the appropriate code for that cat-
egory in Section 1.1. The category codes can be
found in the instructions for Section 1.1; Table II,
"Section 313 Toxic Chemical List;" and Appendix
B, "Reporting Codes for EPA Form R."
Q Reporting transfers to POTWs. When waste-
water containing a listed mineral acid is neutral-
ized to a pH of 6 or greater before being trans-
ferred to a POTW, the transfer estimate should be
reported as zero. It is incorrect to enter "NA"
(Not Applicable), in such a situation.
Q Reporting other off-site transfers. Beginning
with the 1991 reporting year, transfers off-site for
the purposes of recycling or combustion for en-
ergy 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 re-
covery, treatment, or disposal, respectively, must
also be reported in Section 6.2 along with the
receiving location and appropriate off-site waste
management code.
Q 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.
Q Reporting on-site recycling methods in Section
7C. When a quantity is reported in Section 8.4 as
recycled on-site, the type of recycling method
must be reported in Section 7C, and vice versa.
Q Reporting quantities in Section 8. This section
is mandatory; do not leave any box in Section 8
entirely blank. If your facility does not generate
any waste or does not engage in source reduction
or recycling activities enter zero or "NA" as ap-
propriate. 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 used in Section 4 (for
reporting the maximum amount of the reported
toxic chemical on-site) to report quantities in
Section 8.
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. Not applicable, "NA" can be
used in columns A, B, C, and D to indicate that the
reported toxic chemical will not undergo a spe-
cific activity such as treatment.
Q Quantities reported in Sections 8.1 through 8.7
must be mutually exclusive and additive. This
means that quantities of the reported toxic chemi-
cal should not be double-counted in Sections 8.1
through 8.7. Some facilities submitting Form Rs
have reported the same quantity of a toxic chemi-
cal as both treated and recycled on-site. Some
double-counting errors have been due to confu-
sion over the differences in how on-site treat-
ment of a toxic chemical is reported in Section 7A
as compared to Section 8. 6. In Section 7A, infor-
mation on the treatment of waste streams con-
taining 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 8.6, only the quantity of the
toxic chemical actually destroyed by the treat-
ment processes reported in Section 7A is re-
ported 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 wastewa-
ter containing the nickel compounds and re-
moves the nickel with a 99 percent efficiency.
The facility then further reclaims the nickel and
C-4 Appendix C
-------
Q
Q
makes it available for further use in its manufac-
turing processes. In completing Form R, the
facility should report the treatment of the waste-
water with a 99 percent efficiency for the removal
of the nickel in Section 7A, the method of recov-
ery 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 on-site or
disposed off-site, including releases from either
treatment or recycling activities, should be re-
ported in Section 8.1. The facility should not
report the quantity of nickel removed from the
wastewaters as a quantity treated on-site in Sec-
tion 8.6 because reporting the same quantity as
both treated and recycled on-site incorrectly re-
ports the nickel as destroyed and overestimates
the amount of total nickel managed in waste.
Quantities reported in Sections 8.1 through 8.7
must not be reported in Section 8.8 and vice
versa. Amounts in Section 8.1- 8.7 are associated
with normal or routine generations while the
amount in Section 8.8 is not.
For example, 10,000 pounds of a toxic chemical is
spilled due to a catastrophic storage tank rupture
during the reporting year. Of the total 10,000
pounds, 2,500 pounds volatilized and were re-
leased directly to the air .and the remaining 7,500
pounds were collected and sent off-site for treat-
ment. The total 10,000 pounds would be re-
ported 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.
Reporting toxic chemicals in RCRA wastes. Any
time a toxic chemical is contained in a waste that
is identified under RCRA, the waste is associated
with routine production-related activities, and
that chemical is recycled, combusted for energy
recovery, treated, or disposed either on or off-
site, then 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." Quantities of the toxic chemical that
are released on-site and reported in Section 5 of
the form should also be included in Section 8.1.
Also, quantities of the toxic chemical transferred
off-site for the purposes of disposal and reported
in Section 6.2 should also be included in Section
8.1.
A facility must include in Section 8.1 the follow-
ing quantities of the toxic chemical that are re-
leased on-site, or sent off-site for disposal that are
not associated with a catastrophic or non-pro-
duction related activity.
Quantities released directly to the environment
and disposed on-site
Fugitive or non-point air emissions (Section 5.1)
Stack or point air emissions (Section 5.2)
Discharges to receiving streams or water bodies
(Section 5.3)
Underground injections on-site to Class I Wells
(Section 5.4.1)
Underground injections on-site to Class II-V Wells
(Section 5.4.2)
Release to land on-site (Section 5.5)
RCRA Subtitle C landfills (Section5.5.1A)
Other landfills (Section5.5.1B)
land treatment/application farming
(Section 5.5.2)
surface impoundment (Section 5.5.3)
other disposal (Section 5.5.4)
Include in these quantities any releases from any
on-site 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;
M41 Solidification/Stabilization Metals and
Metal Compounds only
M62 Wasterwater Treatment (Excluding POTW)-
Metals and Metal Compounds 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.
Appendix C C-5
-------
Q Do not include in Section 8.1 any of the follow-
ing quantities:
• Releases to the environment on-site from re-
medial actions, catastrophic events, or one-time
events not associated with production processes
(these quantities are reported in Section 8.8 only).
• Quantities transferred off-site for disposal
from remedial actions, catastrophic events, or
one-time events not associated with production
processes (these quantities are reported in Sec-
tion 8.8 only).
Q 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 Q
R is to report the methods of energy recovery
used on-site in Section 7B but not report any
quantity associated with those methods. An-
other error is to report a quantity in Section 8.2 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 quan-
tity 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,or other one-time events Q
not associated with routine production practices,
that were combusted for energy recovery on-site.
Q 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 chemi-
cal does not have a BTU (British Thermal Unit)
value high enough to sustain combustion. Ex-
amples of toxic chemicals that do not have heat-
ing 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 Broker-Energy 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, or other one-time events
not associated with routine production practices,
that were sent off-site for the purposes of com-
bustion 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 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 any 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, or 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 8.5 that are reported in
Section 6.2 as transferred off-site for the purposes
of recycling using the following codes:
M20 Solvents/Organics recovery;
M24 Metals recovery;
M26 Other reuse or 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
C-6 Appendix C
-------
with non-production related activities such as
catastrophic releases and remedial actions, or
other one-time events not associated with rou-
tine 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 7A and 8.6 is different. Only
the quantity of the toxic chemical actually de-
stroyed during on-site treatment is reported in
Section 8.6. Section 7A contains treatment data
for physical removal and/or destruction of the Q
toxic chemical as well as information on treat-
ment methods used on the wastestream contain-
ing the toxic chemical regardless of its effect on
the toxic chemical. If a quantity is reported in
Section 8.6, Section 7A must be completed. For
example, a facility may treat wastewaters con-
taining a toxic chemical by physically 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 esti-
mate based on the amount of the toxic chemical
removed from the wastewaters. The quantity of
the toxic chemical removed would be reported as
disposed in Section 8.1, not as treated in Section
8.6. If some of the toxic chemical is destroyed Q
during treatment, the facility would report only
the amount of the toxic chemical actually de-
stroyed during treatment in Section 8.6 and the
amount ultimately disposed in Section 8.1 in
order to avoid double-counting the same quan-
tity in Section 8.
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, or other one-time events Q
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 Q
Section 6.2 as transferred off-site for the purposes
of treatment and using the following codes:
M50 Incineration/Thermal treatment;
M54 Incineration/Insignificant Fuel Value;
M61 Wastewater treatment (excluding POTW);
M69 Other waste treatment; and
M95 Transfer to Waste Broker-Waste Treatment.
In addition to those quantities, facilities should
include any quantity that is transferred to a POTW
(as reported in Section 6.1) in Section 8.7, except
for metals and metal compounds.
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, or other one-time events
not associated with routine production practices,
that were sent off-site for the purposes of treat-
ment 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 reme-
dial actions, catastrophic events, or one-time
events not associated with production pro-
cesses." Report in Section 8.8 those quantities
associated with non-production related activi-
ties such as catastrophic releases and remedial
actions, as well as other one-time events not
associated with routine production practices, that
were released to the environment on-site, or trans-
ferred off-site for the purposes of recycling, en-
ergy recovery, treatment or disposal. Quantities
included in Section 8.8 must not be also reported
in Sections 8.1 through 8.7.
Reporting the production ratio in Section 8.9. A
production ratio or activity index represents the
current year's production compared with that of
the previous year. The comparison (current RY/
previous RY) must be provided in Section 8.9.
Zeros, and negative numbers are not acceptable,
"NA" (Not Applicable), should be used .only when
the reported toxic chemical was not manufac-
tured, processed, or otherwise used in the year
prior to the reporting year.
Reporting source reduction activities in Sec-
tion 8.10. It is an error to report a source reduc-
tion activity in Section 8.10 without reporting at
least one method used to identify that activity
and vice versa.
Assuming threshold exceeded or not exceeded.
Facilities should consider all Section 313 Chemi-
cals used in very large or very small quantities
and calculate the annual usage of toxic chemicals
for threshold determinations.
Appendix C C-7
-------
Q Overlooking toxic chemicals in mixtures. Fa-
cilities should carefully review the most recent
MSDS for every mixture brought on site to iden-
tify all section 313 chemicals used during a re-
porting year.
Q Overlooking container residue. "RCRA Empty"
drum is NOT considered empty for TRI report-
ing. "RCRA Empty" drum is expected to contain
residual liquid possibly up to three inches. Fa-
cilities should consider all Section 313 chemicals
in residual liquid, include the quantities of toxic
chemicals in threshold calculations, and report
them as release if facilities meet reporting re-
quirements for the toxic chemicals. Facilities
should also include any on-site drum rinsing and
disposal of rinsate in threshold and release calcu-
lations.
C-8 Appendix C
-------
-------
-------
APPENDIX D. SUPPLIER NOTIFICATION
REQUIREMENTS
Because manufacturers reporting under section 313 must
know the toxic chemical composition of the products they
use to be able to accurately calculate releases, EPA re-
quires some suppliers of mixtures or trade name prod-
ucts containing one or more of the listed section 313 toxic
chemicals to notify their customers. This requirement has
been in effect since January 1,1989.
This appendix explains which suppliers must notify 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
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.
Note that beginning with the first shipments in 1998,
facilities in SIC codes 20-39 will be required to also notify
facilities in the newly added industry groups.
(3) You sell or otherwise distribute a mixture or Supplier Notification Must Include the
trade name product containing the toxic chemi- Following Information:
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 fewer 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 customers
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-
(1) A statement that the mixture or trade name prod-
uct contains a toxic chemical or chemicals subject
to the reporting requirements of EPCRA section
313(40CFR372);
(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
percent zinc oxide) that is a member of a reportable toxic
chemical category (i.e., zinc compounds), the notification
must indicate that the mixture contains a zinc compound
at 12 percent by weight. Supplying only the weight
percent of the parent metal (zinc) does not fulfill the
requirement. The customer must be told the weight
percent of the entire compound within a listed toxic
chemical category present in the mixture.
Appendix D D-l
-------
How the Notification Must Be Made
The required notification must be provided at least annu-
ally in writing. Acceptable forms of notice include letters,
product labeling, and product literature distributed to
customers. If you are required to prepare and distribute
a Material Safety Data Sheet (MSDS) for the mixture
under the Occupational Safety and Health Act (OSHA)
Hazard Communication Standard, your section 313 noti-
fication must be attached to the MSDS or the MSDS must
be modified to include the required information. (A
sample letter and recommended text for inclusion in an
MSDS appear at the end of this appendix.)
You must make it clear to your customers that any copies
or redistribution of theMSDSor other form of notification
must include the section 313 notice. In other words, your
customers should understand their requirement to in-
clude 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 b een provided
with an MSDS containing the section 313 information,
you may refer to the MSDS by a written letter in subse-
quent 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 dur-
ing 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 1997, supplier
notification for chemical ABC would have begun with the
first shipment in 1998.
You must send 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.
(2) Discover that your previous notification did not
properly identify the toxic chemicals in the mix-
ture or correctly indicate the percentage by
weight.
In these cases, you must:
(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.
Poods, drugs, cosmetics, pesticides, alco-
holic beverages, tobacco, or tobacco prod-
ucts packaged for distribution to the
general public.
D-2 Appendix D
-------
'^^^^^^^•^^••^^••^^••^
Any consumer product, as the term is Recordkeeping Requirements
f\£±T1V\£±f^ Ifl 4-1-1 S\ /"~* i-l-n n-m -.«*. «— T)_ 3 I. /t_ r . * ^^ *•
(3)
defined in the Consumer Product Safety
Act, packaged for distribution to the gen-
eral public. For example, if you mix or
package one-gallon cans of paint designed
for use by the general public, notification
is not required.
Your mixture or trade name product is contained
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 must contain a generic chemical
name that is descriptive of the structure of that
toxic chemical. For example, decabromodiphenyl
oxide could be described as a halogenated aro-
matic.
(2) Specific percentage by weight of a toxic chemical
in the mixture or trade name product to be a trade
secret, your notice must contain a statement that
the toxic chemical is present at a concentration
that does not exceed a specified upper bound. For
example, if a mixture contains 12 percent toluene
and you consider the percentage 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 thatprovides the basis for your claim.
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 the toxic chemical identity is
considered a trade secret and the appropriate-
ness of the generic chemical name provided in
the notification; and
(4) If claiming a 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 must be readily available for inspection
by EPA.
Appendix D D-3
-------
Sample Notification Letter
January 2,1998
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 zmc
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. Tnis 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 that if you repackage or otherwise redistribute this product to industrial customers, a
notice similar to this one should be sent to those customers.
Sincerely,
Emma Sinclair
Sales Manager
D-4 Appendix D
-------
Furniture Products
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):
108-88-3
NA
Chemical Name
Toluene
Zinc Compounds
Percent by Weight
20%
15%
This information should be included in all MSDSs that are copied and distributed for this material.
Material Safety Data Sheet
Appendix D D-5
-------
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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 incorrect
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 merid-
ian (Greenwich, England). Latitude and longitude are
measured in degrees, minutes, and seconds.
60" (seconds) = 1' (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 available
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 measure-
ments 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 cor-
responding to the numbered general area of in-
terest 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 of Topographic and
Other Published Maps for the state in which your facility is
located:
(5) The beginning of the catalog explains the mean-
ing of 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-
tion Branch of the USGS and from private map dealers.
The Catalog of Topographic 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
USGS, you must send a written request to the Distribu-
tion Branch of the USGS, containing the file number, map
reference code, the name of the city, state and zip code in
which your facility is located, payment of $4.00 per map
sheet and a handling charge of $3.50 for each order
mailed.
The Distribution Branch of the USGS can be reached at:
Distribution Branch of the USGS
P.O. Box 25286
Denver Federal Center
Denver, CO 80225
(303) 202-4700
(3) 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.
(4) 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 north-
south alignment, with the "0" on the
latitude line recorded in step 3 with the
ruler edge intersecting the point.
ALLOW 5 WEEKS FOR DELIVERY Without moving the ruler, read and record:
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 of Topographic 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 assistance:
Western states: (303) 202-4200
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.)
Once you have obtained the correct map for your facility:
(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 repre-
sented on the map, mark one of the structures
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 the map edge, and appear as black crosses at
four points in the interior of the map.
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.]
For example:
Point distance =
Total distance =
99.5
192.0
99.5 x 150"
192.0
77.7"
01'17.7"
(60" = I1; 77.7" = 60" + 17.7" = 01' 17.7")
Latitude in step 3
Increment
Latitude of point
32°17'30"
+ Ql'17.7"
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 lon-
gitude 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 x 150" = increment of longitude
total distance
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")
Longitude in step 3 78°05'00"
Increment + Ol'OS"
Longitude of point 78°06'05"
to the nearest second = 78°06'05"
Latitude/Longitude Diagram
WEST
NORTH
I
POINT
QUADRANGLE
+
GRATICULE
SOUTH
78°0730"
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
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APPENDIX E STATE DESIGNATED SECTION 313
CONTACTS
Note:
Use the appropriate address for submission of
Form R reports to your State. In addition, many
States have additional state reporting require-
ments. Check with your State contact on any
State requirements.
Submitting Electronically to States. As of the
publication of this book the following states
confirmed that they accept electronic submis-
sion.
AK
AZ
CA
CO
DC
DE
FL
GA
HI
IA
ID
IL
IN
KS
LA
MD
MI
MN
MO
MT
NC
ND
NJ
NM
NY
NV
OH
OK
OR
PA
SC
SD
UT
VA
VT
WA
WI
WV
If your state is not listed here. Please contact your
state office to confirm that paper submissions are
required.
Alabama
Mr. Edward Poolos
Alabama Emergency Response Commission
Alabama Department of Environmental Management
1751 Congressman W.L. Dickinson Drive
Montgomery, AL 36109
(334) 260-2717
eft@adma.state.al.us
Alaska
Ms. Camille Stephens
Department of Environmental Conservation
Division of Spill Prevention Response
410 Willoughby Avenue, Suite 105
Juneau, AK 99801-1795
(907) 465-5242
American Samoa
Pati Faiai
American Samoa EPA
American Samoa Government
Office of the Governor
Pago Pago, AS 96799
International Number (684) 633-2304
Arizona
Mr. Daniel Roe, Executive Director
Arizona Emergency Response Commission
Division of Emergency Management
5636 East McDowell Road
Phoenix, AZ 85008
(602) 231-6346
Mr. Bill Quinn
Arizona Department of Environmental Quality
Pollution Prevention Unit Manager
3033 N. Central
Phoenix, AZ 85012
(602) 207-4203
Arkansas
Mr. John Ward
Arkansas Department of Pollution Control and Ecology
P.O. Box 8913
8001 National Drive
Little Rock, AR 72209-8913
(501) 562-7444
California
Mr. Stephen Hanna
California Environmental Protection Agency
Assistant for Environmental Information
555 Capitol Mall
Suite 235
Sacramento, CA 95814
(916) 324-9924
shartna@hwl .ca.hw.net.gov
Colorado
Ms. Tamera Vanhorn
Colorado Emergency Planning Commission
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO 80222-1530
(303) 692-3017
tamera.van@state.co.us
Commonwealth of Northern Mariana Islands
Mr. Frank Russell Meecham, III
Division of Environmental Quality
Commonwealth of the Northern Mariana Islands
Doctor Torres Hospital
P.O. Box 1304
Saipan, MP 96950
International Number (670) 234-6984
Appendix F F-l
-------
Connecticut
Mr. Joseph Pulaski
Department of Environmental Protection
SERC Administrator
C/O Waste Management
79 Elm St.
Hartford, CT 06106-5127
(860)424-3373
Delaware
Mr. David Fees
Department of Natural Resources and
Environmental Control
Division of Air and Waste Management
89 King's Highway
P.O. Box 1401
Dover, DE 19903
(302) 739-4791
www.state.de.us/gov/agency
District of Columbia
Ms. Michele Penick
Environmental Planning Specialist
Emergency Response Commission for Title III
200014th Street, NW, 8th Floor
Washington, DC 20009
(202) 673-2101 (ext. 3159)
Florida
Mr. Sam Brackett
State Emergency Response Commission
Florida Department of Community Affairs
2555 Shumard Oak Blvd.
Tallahassee, FL 32399-2100
(904) 413-9928
In Florida: 800-635-7179
www.state.fl.us/comaff/dca.html
Georgia
Mr. Burt Langley
Georgia Emergency Response Commission
7 Martin Luther King Drive
Room 139
Atlanta, GA 30334
(404)656-6905
Guam
Ms. Conchita Tatano, Director
Guam EPA
Air and Land Division
P.O. Box 20439
Barrigada,GU 96921
International Number (671) 646-8863
Hawaii
Ms. Marsha Mealey
Hawaii State Emergency Response Commission
Hawaii State Department of Health
P.O. Box 3378
919 Ala Moana Blvd., Room 206
Honolulu, HI 96814
(808) 586-4694
Idaho
Ms.Margaret Ballard, Chief of Staff
Idaho Emergency Response Commission
4040 Guard Street
Gowen Field
P.O. Box 83720 •
Boise, ID 83720-3401
(208) 334-3263
Illinois
Mr. Joe Goodner
Illinois EPA
Office of Chemical Safety
Emergency Planning Unit
P.O. Box 19276
2200 Churchill Road
Springfield, IL 62794-9276
(217) 785-0830
epa8538@epa.st.il.us
Indiana
Ms. Paula Smith
Indiana Department of Environmental Management
Office of Pollution Prevention Technical Assistance
100 North Senate Ave. (N-1355)
P.O. Box 6015
Indianapolis, IN 46206-6015
(use complete address on all mail and deliveries)
(317) 232-8172
psmit@opn.dem.st.in.us.
Iowa
Mr. Pete Hamlin
Bureau Chief of Air Quality
Department of Natural Resources
Wallace Office Bldg.
7900 Hickman Rdv Suite I
Urbandale, IA 50322
(515) 281-8852
Kansas
Mr. Jon Flint
Kansas Emergency Response Commission
Right-to-Know Program
J Street and 2 North
Forbes Field Building 283
Topeka, KS 66620
(913) 296-1690
F-2 Appendix F
-------
Kentucky
Mr. Alex Barber
Ms. Gayla Steward
Kentucky Department for Environmental Protection
14 Reilly Road
Frankfort, KY 40601-1132
(502) 564-2150
barber@inrpath.nr.state.ky.us
Louisiana
Ms. Linda Brown
Department of Environmental Quality
Office of Secretary
P.O. Box 82263
7290 Bluebonnet Road
Baton Rouge, LA 70884-2263
(504) 765-0737
lindab@deq.st.la.us
Maine
Ms. Rayna Leibowitz
State Emergency Response Commission
State House Station Number 72
Augusta, ME 04333
(207) 287-4080
In Maine: (800)452-8735
rayna.b.leibowitz@st.me.us.
Maryland
Ms. Patricia Williams
State Emergency Response Commission
Maryland Department of the Environment
Toxics Inventory Program
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3800
Massachusetts
Mr. William T. Panos
Massachusetts Department of Environmental Protection
Bureau of Waste Prevention
1 Winter Street
Boston, MA 02108
(617) 574-6820
wpanos@st.ma.us
Michigan
Mr. Robert Jackson, Chief
Grants and Information
State Emergency Response Commission
Department of Environmental Quality
Assistance Division
333 S. Capitol
P.O. Box 30457
Lansing, MI 48933
(517)373-2731
certified mail only:
SARA Title III
333 S. Capitol
Town CTR, 2nd Floor
Lansing, MI 48909
(517)373-8481
Minnesota
Mr. John Chikkala
Minnesota Emergency Response Commission
B5 State Capitol Building
75 Constitution Ave.
St Paul, MN 55155
(612) 282-5396
Mississippi
Mr. John David Burns
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
P.O. Box 4501
Jackson, MS 39296-4501
certified mail only:
1410 Riverside Drive
Jackson, MS 39202
(601) 960-9000
Missouri
Mr. Eugene Nickel
Missouri Department of Natural Resources
Technical Assistant Program
P.O. Box 176
Jefferson City, MO 65102
(573) 526-6627
certified mail only:
Missouri Department of Natural Resources
1659 B East Elm Street
Jefferson City, MO 65101
(314) 526-3901or
(314) 526-3371
http://www.state.mo.st.us/dnr/deq/tap/hometap.htm
Montana
Mr. Tom Ellerhoff
Montana Emergency Response Commission
Environmental Sciences Division
Department of Health & Environmental Sciences
Capitol Station
Cogswell Building C-108
P.O. Box 200901
Helena, MT 59620-0901
(406) 444-5263
Appendix F F-3
-------
Nebraska
Mr. Mike Mallory, Coordinator
State of Nebraska Department of Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
certified mail only:
1200 N Street, Suite 400
Lincoln, NE 68509
(402) 471-4230
Nevada
Ms. Alene Coulson
Division of Environmental Protection
333 West Nye Lane
Carson City, NV 89706-0866
(702) 687-5872
New Hampshire
Mr. Leland Kimball
New Hampshire Office of Emergency
Management Agency
Title IH Program
State Office Park South
107 Pleasant Street
Concord, NH 03301-3809
(603) 271-2231
New Jersey
Mr. Andrew Opperman
Department of Environmental Protection
EPCRA Section 313
Bureau of Chemical Release Information & Prevention
P.O. Box 405
Trenton, NJ 08625-0405
(609) 984-3219
aopperman@dep.state.nj.us
New Mexico
Mr. Max Johnson, Coordinator
New Mexico Emergency Response Commission
Chemical Safety Office, Emergency Management Bureau
P.O. Box 1628
Santa Fe, NM 87504-1628
certified mail only:
4491 Cerrillos Road
Santa Fe,NM 87505
(505) 827-9223
New York
Mr. Sitansu Ghosh
New York Emergency Response Commission
New York State Department Of Environmental
Conservation
Bureau of Spill Prevention and Response
50 Wolf Road/Room 340
Albany, NY 12233-3510
(518) 457-4107
North Carolina
Ms. Ester Castaldo
North Carolina Emergency Response Commission
North Carolina Division of Emergency Management
116 West Jones Street
Raleigh, NC 27603-1335
(919) 733-3865
North Dakota
Mr. Robert Johnston
North Dakota Emergency Response Commission
Division of Emergency Management
P.O. Box 5511
Bismarck, ND 58506-5511
certified mail only:
Fraine Barracks Road, Building 35
Bismarck, ND 58506-5511 .
(701) 328-2111
Ohio
Ms. Cindy DeWulf
Ohio EPA
Division of Air Pollution Control
P.O. Box 1049
1800 Watermark Drive
Columbus, OH 43216-1049
(614) 644-4830
Oklahoma
Ms. Monty Elder
Department of Environmental Quality Support Services
1000 N.E. 10th Street
Oklahoma City, OK 73117-1212
(405) 271-1400 ext. 192
monty.elder@oklaoss.st.ok.us
Oregon
Mr. Bob Albers
Oregon Emergency Response Commission
c/o State Fire Marshall
4760 Portland Road, Northeast
Salem, OR 97305-1760
(503) 378-3473 (ext. 262)
F-4 Appendix F
-------
Pennsylvania
Mr. Thomas J. Ward, Jr.
Pennsylvania Emergency Management Council
Bureau of Worker and Community Right-to-Know
Room 1503
Labor and Industry Building
7th & Forster Streets
Harrisburg, PA 17120
(717) 783-2071
Puerto Rico
Mr. Genaro Toress
Director of Superfund and Emergency Division
Title IH-SARA Section 313
Puerto Rico Environmental Quality Board
Sernades Junco Station
P.O. Box 11488
Santurce, PR 00910
certified mail only:
Environmental Quality Board
Emergency Response and Remedial Office
National Plaza #431
Ponce de Leon Avenue
HatoRey,PR 00917
International Number (809) 766-8056
Rhode Island
Ms. Martha Delaney Mulcahey
Rhode Island Department of Environmental
Management
Division of Air Resources
291 Promenade Street
Providence, RI02908-5767
Attn: Toxic Release Inventory
(401) 277-2808
South Carolina
Mr. Michael Juras
Bureau of Air Quality
SC Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 734-7236
jurasms@columb31.dhec.state.sc.us
South Dakota
Ms. Lee Ann Smith, TRI Coordinator
South Dakota Department of Environment and
Natural Resources
523 East Capitol
Pierre, SD 57501-3181
(605) 773-3296
leeanns@denr.st.sd.us
Tennessee
Ms. Betty Eaves, Administrator
Tennessee Emergency Response Council
Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204
(615) 741-2986
1-800-262-3300 (in Tennessee)
1-800-258-3300 (out of state)
Texas
U.S. Postal Service Delivery including Certified Mail
Ms. Becky Kurka
Office of Pollution Prevention and Recycling
Texas Natural Resource Conservation Commission
P.O. Box 13087 (MC-112)
Austin, TX 78711-3087
(512) 239-3100
bkurka@tnrcc.state.tx.us
overnight express mail only:
(MC-112)
12100 Park 35 Building E
Austin, TX 78753
Utah
Mr. Neil Taylor
Utah Hazardous Chemical Emergency Response
Commission
Utah Department of Environmental Quality
Division of Environmental Response and
Remediation
P.O. Box 14484
168 North 1950 West, 1st Floor
Salt Lake City, UT 84116-4840
(801) 536-4100
Vermont
Mr. GaryGulka
Pollution Prevention Section
103 S. Main St.
Westbury,VT 05671-0411
(802) 241-3626
Virginia
Ms. Cathy Harris
Virginia Emergency Response Council
c/o Virginia Dept. of Environmental Quality
P.O. Box 10009
Richmond, VA 23240-0009
(804)698-4408 or 4489
http://www.deq.date.va.us.clharris
Appendix F F-5
-------
certified mail only:
Virginia Department of Environmental Quality
SARA Title HI Program
9th Floor,629 E. Main St.
Richmond, VA 23219
(804) 762-4489
Virgin Islands
Mr. Ben Nazario
Department of Planning and Natural Resources
U.S. Virgin Islands Emergency Response Commission
Title IH
Nisky Center, Suite 231
Charlotte Amalie
St. Thomas, VI00802
(809) 773-0565 (St. Croix)
(808) 774-3320 (St. Thomas)
Washington
Ms. Idell Hansen
CRTKUnit
Department of Ecology
P.O. Box 47659
Olympia, WA 98504-7659
(360-)407-6727 or (800)633-7585
ihan461@ecy.wa.gov
Federal Express or UPS mail only:
Department of Ecology
300 Desmond Drive
Lacey,WA 98503
Wyoming
Chairman, Mr. Mike Davis
Wyoming Emergency Response Commission
Wyoming Emergency Management Agency
Department of Environmental Quality
P.O. Box 1709
5500 Bishp Blvd.
Cheyenne, WY 82009
(307) 777-4900
(1) If an Indian tribe has chosen to act independently of a
state for the purpose of section 313 reporting, facilities
located within that Indian community should report to
the tribal SERC, or until the SERC is established, the Chief
Executive Officer of the Indian tribe, as well as to EPA;
(2) Facilities located within the Territories of the Pacific
should send a report to the Chief Administrator of the
appropriate territory, as well as to EPA.
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 25305-0360
(304) 558-5380
Wisconsin
Department of Natural Resources
101 South Webster
P.O. Box 7921
Madison, WI53707
Attn: Mr. Wes Taylor, Toxics Coordinator
(608) 266-9255
taylow@dnr.state.wi.us
F-6 Appendix F
-------
-------
-------
APPENDIX G. SECTION 313 EPA REGIONAL
CONTACTS
Region 1
Pesticides & Toxics Branch
USEPA Region 1 (SPT)
Assistance & Pollution Prevention Office
One Congress Street
Boston, MA 02203
(617) 565-3230
Connecticut, Massachusetts, Maine,
New Hampshire, Rhode Island, Vermont
Region 2
Pesticides & Toxics Branch
USEPA Region 2 (MS-105)
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
(732) 906-6890
Region 5
Pesticides & Toxic Substances Branch
USEPA Region 5 (DRT-14J)
77 West Jackson Blvd.
Chicago, IL 60604
(312) 886-6219
Illinois, Indiana, Michigan, Minnesota, Ohio, Wis-
consin
Region 6
Pesticides & Toxic Substances Branch
USEPA Region 6 (6PDT)
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-8013
New Jersey, New York, Puerto Rico, Virgin Islands Arkansas, Louisiana, New Mexico, Oklahoma, Texas
Region 3
Toxics Enforcement Branch
USEPA Region 3 (3WC33)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 566-2072
Delaware, Maryland, Pennsylvania, Virginia,
West Virginia, District of Columbia
Region 4
Pesticides & Toxics Branch
EPCRA Unit A
USEPA Region 4
Atlanta Federal Center
100 Alabama St., S.W.
Atlanta, GA 30303-3104
(404) 562-9191
Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee
Region 7
Toxics & Pesticides Branch (ARTD-TSPP))
USEPA Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7646
Iowa, Kansas, Missouri, Nebraska
Region 8
Toxic Substances Branch
USEPA Region 8 (8P2-TX)
999 18th Street. Suite 500
Denver, CO 80202-2466
(303) 312-6018
Colorado, Montana, North Dakota, South Dakota,
Utah, Wyoming
Appendix G G-l
-------
Region 9
Pesticides & Toxics Branch
USEPA Region 9 (CMD-4-2)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1121
Arizona, California, Hawaii, Nevada, American
Samoa, Guam, Commonwealth of the Northern
Mariana Islands
Region 10
Pesticides & Toxic Substances Branch
USEPA Region 10 (WCM-128)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-4016
Alaska, Idaho, Oregon, Washington
G-2 Appendix G
-------
-------
-------
APPENDIX H. SECTION 313 RELATED MATERIALS
AND INFORMATION ACCESS
To receive a copy of any of the section 313 documents
listed below, check the box(es) next to the desired
document(s). There is no charge for any of these docu-
ments. Be sure to type or clearly print your full mailing
address in the space provided on this form. Send this
request form/or call toll-free 1-800-490-9198:
U.S. EPA/NCEPI
P.O. Box 42419
Cincinnati, OH 45242-2419
(800) 490-9198
Fax: (513)489-8695
Internet:
http://www.epa.gov/ncepihom/index.html
Q 40 CFR 372, Toxic Chemical Release Reporting;
Community Right-to-Know; Final Rule
A reprint of the final section 313 rule as it ap-
peared in the Federal Register (FR) February 16,
1988 (53 FR 4500) (OTSFR 021688).
Q Toxic Chemical Release Inventory Reporting
Forms and Instructions for 1997, February 1998
(EPA 745-K-98-001)
Q Consolidated List of Chemicals Subject to
Reporting Under the Act (Title III List of Lists)
(EPA 740-R-95-001)
A consolidated 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
requirement(s) to which the chemical is subject.
Q The Emergency Planning and Community
Right-to-Know Act: Section 313 Release
Reporting Requirements, December 1997
(EPA 745/K-97-002)
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 Clas-
sification (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 the trade secret
provision, and contains a sample notification.
Q Trade Secrets Rule and Form (53 FR 28772)
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) and includes a copy of the trade
secret substantiation form.
Q Common Synonyms for Chemicals Listed Un-
der Section 313 of the Emergency Planning and
Community Right-to-Know Act
(EPA 745-R-95-008)
This glossary contains chemical names and their
synonyms for substances covered by the report-
ing requirements of EPCRA, section 313.
The glossary was developed to aid in determi-
ning whether a facility manufactures, processes,
or uses a chemical subject to section 313 report
ing.
Q Executive Order 12856 - Federal Compliance
with Right-to-Know Laws and Pollution Pre-
vention Requirements: Questions and Answers
(EPA 745-R-95-011)
This document assists Federal facilities in com-
plying with Executive Order 12856. This informa-
tion has been compiled by EPA from questions
received from Federal facilities. This document
is intended for the exclusive use of Federal facili-
ties in complying with sections 302,303,304,311,
312, and 313 of the Emergency Planning and
Community Right-to-Know Act (EPCRA) of 1986
and the Pollution Prevention Act of 1990, as
directed by the Executive Order.
Appendix H H-l
-------
Q Section 313 of the Emergency Planning and Q
Community Right-to-Know Act; Questions
and. Answer November 1997
(EPA 745-B-97-008) Q
Q Toxics Release Inventory: Reporting
Modifications Beginning with 1995 Report Q
ing Year February 1995 (EPA 745-R-95-009)
Q 1995 Toxics Release Inventory Public Data Q
Release State Fact Sheets (EPA 745-F-97-001)
The fact sheets in this document summarize Q
the basic 1995 Toxics Rlease Inventory (TRI)
data for each state. This document is
designed as a companion volume to EPA's Q
1995 Toxic Release Inventory Public Data
Release (EPA 745-R-97-005), a more detailed
examination of TRI data for 1995 and Q
previous years.
Q 1995 Toxics Release Inventory Public Data Q
Release (EPA 745-R-97-005)
This publication summarizes TRI data sub-
mitted for reporting year 1995: Q
where, how much, and which types of
chemicals are being released into the
environment and it provides comparisons to Q
TRI submissions for earlier years. Extensive
tables itemize releases and transfers by
media, chemicals, location and industry. Q
Similar reports for 1987-1994 are available for sale
from the Superintendent of Documents, U.S. Gov- Q
emment Printing Office, Washington, DC 20420-
9325 (202-512-1800).
Q
Industry Specific Technical Guidance Documents
EPA has developed a group of smaller, individual guid-
ance documents that target activities in industries who Q
primarily process or otherwise use the listed toxic chemi-
cals.
Q Monofilament Fiber Manufacture,
January 1988 (EPA 560-4-88-004a)
Q Printing Operations, January 1988
(EPA560-4-88-004b)
Q
Electrodeposition of Organic Coatings,
January 1988 (EPA 560-4-88-004c)
Spray Application of Organic Coatings,
January 1988 (EPA 560-4-88-004d)
Semiconductor Manufacture, January 1988
(EPA 560-4-88-004e)
Formulation of Aqueous Solutions,
March 1988 (EPA 560-4-88-004f)
Electroplating Operations, January 1988
(EPA 560-4-88-004g)
Textile Dyeing, February 1988
(EPA560-4-88-004h)
Presswood & Laminated Wood Products
Manufacturing, March 1988 (EPA 560-4-88-004i)
Roller, Knife, and Gravure Coating
Operations, February 1988
(EPA 560-4-88-004J)
Paper and Paperboard Production, February
1988 (EPA 560-4-88-004k)
Leather Tanning and Finishing
Processes, February 1988 (EPA 560-4-88-0041)
Wood Preserving, February 1988
(EPA560-4-88-004p)
Rubber Production and Compounding,
March 1988 (EPA 560-4-88-OOq)
Estimating Releases and Waste Treatment
Efficiencies, December 1987
(EPA 560-4-88-002)
Section 313 Reporting: Issue Paper Classifica-
tion and Guidance for the Metal Fabrication
Industry, January 1990 (EPA 745-B-90-100)
Section 313 Emergency Planning Community
Right-to-Know Act Guidance for Food Proces-
sors, June 1990 (EPA 560-4-90-014)
H-2 Appendix H
-------
Chemical Specific Guidance Documents
EPA has developed a group of guidance documents
specific to individual chemicals and chemical catego-
ries.
Q
Q
Q
Toxic Release Inventory
List of Toxic Chemicals within the
Polychlorinated Alkanes Category and
Guidance for Reporting, February 1995
(EPA 745-R-95-001)
Toxic Release Inventory
List of Toxic of Chemicals within the
Water Dissociable Nitrate Compounds
Category and Guidance for Reporting
May, 1996 (EPA 745-R-96-004)
Toxic Release Inventory
List of Toxic of Chemicals within the
Polycyclic Aromatic Compounds Category
February 1995 (EPA 745-R-95-003)
Toxic Release Inventory
List of Toxic Chemicals within the
Nicotine and Salts Category and Guidance
for Reporting, February 1995
(EPA 745-R-95-004)
Toxic Release Inventory
List of Toxic Chemicals within the
Strychnine and Salts Category and Guidance
for Reporting, February 1995
(EPA 745-R-95-005)
Toxic Release Inventory
List of Toxic Chemicals within the
Glycol Ethers Category and Guidance for
Reporting,
May 1995 (EPA 745-R-95-006)
Emergency Planning and Community Right-
to-Know Section 313: List of Toxic Chemicals
within the Chlorophenols Category,
November 1994 (EPA 745-B-95-004)
Emergency Planning and Community Right-
to-Know Section 313: Guidance for Reporting
Aqueous Ammonia, July 1995
(EPA 745-R-95-012)
Emergency Planning and Community
Right-to-KnowSection313:ListofToxicChemi-
cals, September, 1996 (EPA 745-B-96-002)
Q
Emergency Planning and Community Right-
to-Know Act Section 313, Guidance for Report
ing Sulfuric Acid (acid aerosols including
mists, vapors, gas, fog and other airborne
forms of any particle size), (EPA 745-B-97-007)
Emergency Planning and Community Right-
to-Know Act Section 313, Guidance for
Reporting Hydrochloric Acid (acid aerosols
including mists, vapors, gas, fog and other
airborne forms of any particle size),
(EPA 745-B-98-002)
Industry Specific Guidance Documents
EPA has develope a group of guidance documents spe-
cific to individual Industry.
Q Emergency Planning and Community Right-
to-Know Act Section 313, Guidance for RCRA
Subtitle C TSD Facilities and Solvent Recovery
Facilities (Version 1.0), October 1997
(EPA 745-B-97-015)
Q Emergency Planning and Community Right-
to-Know Act Section 313, Guidance for Petro-
leum Bulk Storage Facilities (Version 1.0),
October 1997 (EPA 745-B-97-014)
Q Emergency Planning and Community Right-
to-Know Act Section 313, Guidance for Coal
Minning Facilities (Version 1.0), October 1997.
EPA 745-B-97-012
Q Emergency Planning and Community Right-
to-Know Act Section 313, Guidance for Elec-
tricity Generating Facilities, (Version 1.0)
EPA 745-B-97-016
Ul Emergency Planning and Community Right-
to-Know Act Section 313, Guidance for
Chemical Distribution Facilities (Version 1.0)
EPA 745-B-98-013
Q Emergency Planning and Community Right-
to-Know Act Section 313, Guidance for Metal
Mining Facilities (Version 1.0)
EPA745-B-97-011
Appendix H H-3
-------
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 —
H-4 Appendix H
-------
OTHER RELEVANT SECTION 313 MATERIALS
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 support-
ing 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, 8600 Rockville Pike, Bethesda,
MD 20894, (301) 496-6531, average cost of $18.00 per
hour.
RTK-Net is an online network concerned with environ-
mental issues, in particular, matters arising from the
passage of the right-to-know provisions embodied in the
EPCRA legislation. RTK-net was established by two non-
profit organizations (Unison Institute and OMB Watch)
to provide access to TRI, link TRI with other environmen-
tal data, and exchange information among public interest
groups. RTK-Net is a full-service center providing free
dial in access privileges to government and industry as
well, more complete database services, training and tech-
nical support, e-mail, and electronic conferences pertain-
ing to issues such as health, activism, and environmental
justice. For more information contact RTK-Net, 1742
Connecticut Ave., NW, Washington, DC 20009-1146 or
phone 202-797-7200. You can register on-line by modem
at 202-234-8570, parameters 8,n,l, and log in as "public".
Toxics Release Inventory - CD-ROM
The CD-ROM contains the complete Toxic Release Inven-
tory since 1987, as well as Chemical Factsheets containing
health and environmental effects information for TRI
chemicals. User-friendly software provides the capabil-
ity to search data by facility, location, chemical, SIC code,
and many other access points. Other features allow
flexibility in printing standard and custom reports, data
downloading, and calculating releases for search sets (for
example, calculate average air releases for all pulp and
paper manufacturers). The same disc is available from
GPO and NTIS, although prices differ:
From GPO (Superintendent of Documents, U.S. Govern-
ment Printing Office, P.O. Box 371954, Pittsburgh, PA
15250-7954):
1987-1995 - S/N 055-000-00582-6, $43.00.
From NTIS (5285 Port Royal Road, Springfield, VA 22161,
703-605-6000):
1987-1995 - PB97-502587, $45.00.
Toxic Release Inventory (by State) - Diskettes
Diskettes containing frequently used data elements from
TRI are available on diskette in dBase and Lotus formats.
Accompanying documentation describes section 313 re-
porting requirements, and instructions for loading into
dBase and lotus software. dBase and Lotus software are
not included. Diskettes from GPO and NTIS are the same,
although the pricing formula differs between agencies.
Prices and order numbers shown are for the 1993 disks.
Earlier years are also available. The same data can be
downloaded or ordered on disk from the GPO Federal
Bulletin Board. Call GPO User Support at 202-512-1530
for more information.
From GPO (Superintendent of Documents, U.S. Govern-
ment Printing Office, Attn: Electronic Products, P.O. Box
37082, Washington, DC 20013-7082 (202-512-1530)
Individual state (number of disks per state vary):
3.50" disk-$15/disk
From NTIS (5285 Port Royal Road, Springfield, VA 22161,
703-605-6000):
Lotus & dBase formats.
1987 to 1992 Data available.
contact NTIS for price quote.
Toxic Release Inventory- Magnetic Tapes and Cartridge
Magnetic tapes contain the complete Toxic Release In-
ventory for 1993. Accompanying manual includes brief
overviews of Section 313 reporting requirements, a sample
Form R, lists of regional and states contacts and tape
layout information. The same tapes are available from
GPO and NTIS, although prices differ. Updated versions
are also available for earlier years.
From GPO (Superintendent of Documents, U.S. Govern-
ment Printing Office, Attn: Electronic Products, P.O. Box
37082, Washington, DC 20013-7082 (202-512-1530)
6250 (BPI) Density: $390.
Appendix H H-5
-------
From NTIS (5285 Port Royal Road, Springfield, VA 22161,
703-605-6000):
1600 $895.00 or 6250 (BPI) Density $820.00 or
3480 cartridge $895.00: (PB95 - 503876)
Toxic Release Inventory 1994: Reporting
Facilities Names and Addresses — Magnetic Tape
Note: Magnetic Tapes will not be produced for 1994
and later reporting years.
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, is intended to assist users of the
Toxics 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, the applicability of federal, state, and local regu-
lations, and monitoring data. Available from: National
Technical Information Service, 5285 Port Royal Road,
Springfield, VA 22161, (703) 605-6000, Document Num-
ber: PB92-501972, $212.00.
Consolidated List of Chemicals Subject to
Reporting Under the Act (Title III List of Lists), June
1994
Available as an IBM compatible disk from: The National
Technical Information Service, 5285 Port Royal Road,
Springfield, VA 22161, (703) 605-6000, Document Num-
ber: PB95-503165, $97.00.
The Toxic Release Inventory: Meeting the Challenge
(April 1988)
This 19 minute videotape explains the 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; VHS = $22.00.
To purchase, write or call:
Color Film Corporation
Video Division
770 Connecticut Avenue
Norwalk, CT 06854
(800) 882-1120
Chemicals in Your Community, A Citizen's Guide to
the Emergency Planning and Community Right-to-
Know Act, September 1988 (OSWER-88-002)
This booklet is intended to provide a general overview of
the EPCRA requirements and benefits for all audiences.
Part I of the booklet describes the provisions of EPCRA
and Part II describes more fully the authorities and re-
sponsibilities of the groups of people affected by the law.
Available through written request at no charge from:
Emergency Planning and Community
Right-to-Know Information Hotline
Mailcode: 5101
401 M Street, SW
Washington, DC 20460
Hotline 1-800-535-0202
POLLUTION PREVENTION
INFORMATION
An up-to-date source of information on p Dilution preven-
tion is the Enviro$en$e System, a computerized informa-
tion network. Enviro$en$e includes a directory of
representatives from Federal, State, and local govern-
ments; current news on pollution prevention activities;
program summaries for government agencies, public
interest groups, academic institutions, trade associations,
and industry; a data base of industry case studies; a
calendar of conferences, training seminars, and work-
shops; and specialized bulletin boards dedicated to vari-
ous topics. Enviro$en$e can be accessed in two ways:
1) Bullentin Board-modem:
(703)908-2092, Parameters: 8,n,l settings: ansi or v+100
user support: (703)908-2007.
2) World Wide Web-internet:
http://es.inel.gov/
under heading "EPA P2 and other initiatives"
H-6 Appendix H
-------
The Pollution Prevention Information Clearinghouse
(PPIC) was established as part of EPA's response to the
Pollution Prevention Act of 1990, which directed the
Agency to compile information, including a database, on
management, technical, and operational approaches to
source reduction. PPIC provides information to the
public and industries involved in conservation of natural
resources and in reduction or elimination of pollutants in
facilities, workplaces, and communities.
To request EPA information on pollution prevention or
obtain factsheets on pollution prevention from various
state programs call the PPIC reference and referral ser-
vice at 202-260-1023, or fax a request to 202-260-0178, or
write to:
PPIC
Mail Code 3404
401M St., SW
Washington, DC 20460
Appendix H H-7
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