United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
February 1999
EPA 745-K-99-001
SEPA
Toxic Chemical Release Inventory
Reporting Forms and Instructions
Revised 1998 Version
Section 313
of the Emergency Planning and
Community Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthorization Act of 1986)
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsurner)
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WHERE TO SEND REPORTS
REGULAR, CERTIFIED MAIL, OVERNIGHT
OR HAND DELIVERED
SECTION A.7 (PAGES 4-5)
*FOR ATRS TECHNICAL SUPPORT
CALL (703) 816-4434
THE USER SUPPORT HOTLINE NUMBER
IS TO BE USED FOR THE ATRS SOFTWARE AND
DOES NOT PROVIDE REGULATORY SUPPORT.
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.8 (PAGE 5)
PLEASE SEND ONE COPY OF EACH
FORM TO EPA AT THE APPROPRIATE
ADDRESS LISTED IN SECTION A.7
(PAGE 4) AND TO YOUR STATE. DO
NOT SEND A COPY TO YOUR EPA
REGIONAL OFFICE
HOW TO OBTAIN FORMS
AND OTHER
INFORMATION
SECTION A.8 (PAGE 5)
STATE DESIGNATED
SECTION 313 CONTACTS
APPENDIX F.
SECTION 313 EPA REGIONAL
CONTACTS
APPENDIX G.
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Important Information for Reporting Year 1998 .
The following information updates or corrects the Forms and Instructions for Reporting Year 1997. No other changes
or modifications have been made to the Forms or Instructions other than these here.
D Covered facilities in the following industry groups will be required to submit TRI reports for the first time: coal
mining, metal mining, electricity generation (limited to facilities that combust coal and/or oil), hazardous waste
treatment and disposal, petroleum bulk plants and terminals, chemical wholesale, and solvent recycling. These
industry sectors were added in a final rule published on May 1,1997 (62 FR 23834).
O Note that the revised interpretation of "otherwise use" (May 1,1997; 62 FR 23834) was effective starting with the
1998 reporting year. These instructions have been revised to reflect that change.
CD Two exemptions were developed specifically for two of the new industry sectors. These include a coal mining
extraction exemption (limited to coal mining facilities) and an overburden exemption limited to covered metal
mining facilities. Each of these exemptions were defined in the Final rule adding the new industry sectors and
are described in these instructions.
D All references to reporting year 1998 and all other date related references have been changed to reflect the current
reporting year. (i.e., reporting year 1997 has been changed to reporting year 1998; prior year 1996 was changed
to prior year 1997, etc.) This change was made for both the Form R and the instructions.
O Starting with the 1998 reporting year, voluntary revisions must be submitted by July 31st of the same year as the
reporting deadline for the revised data to be included in the next TRI data release. In previous years, this
deadline was October 15th.
D 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 or (703) 412-9877.
D Appendix C "Common Errors in Completing Form R Reports" has been updated.
D The States and Regional contact list (Appendices 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.
O The EPCRA Section 313 Chemical List (Table II) has not change since last year.
O A list of Section 313 industry-specific guidance documents and chemical-specific guidance documents and
information on ordering these documents free of charge is provided on page ii.
D Included in this reporting package is a compact disk (CD) which contains several industry-specific regulatory
guidance documents, including documents specific to the newly added industry groups, the EPCRA Section 313
Questions and Answers book and all versions of ATRS98 (Windows 95,98 and NT; Windows 3.1 and DOS) and
the ATRS, Users Guide.
O These documents are also available on the internet at http://www.epa.gov/opptintr/tri.
Toxics Release Inventory Reporting Forms and Instructions
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Toxics JRelease Inventory Reporting Forms and Instructions
Table of Contents
EPA's Automated TRI Reporting Software for Reporting Year 1998 v
Chemical and Industry Guidance Documents vi-viii
Toxic Chemical Release Inventory Reporting Form R
Toxic Chemical Release Inventory Reporting Form A
A. General Information
A.I Who Must Report s 1
A.2 How to Assemble a Complete Report 1
A.2.a. The Toxic Chemical Release Reporting Form, EPA Form R 1
A.2.b. The Alternate Toxic Chemical Release Inventory Form, EPA Form A 2
A.3 Trade Secret Claims ;...'; 2
A.4 Recordkeeping ; 2
A.5 How to Prepare a Voluntary Revision of a Previous Submission 3
A.S.a. Where to Submit a Voluntary Revision of a Previous Submission 3
A.6 When the Report Must Be Submitted 3
A.7 Where to Send the Forms 4
A.7.a. How to Send Your Disks Containing Form R(s) and/or Form A(s) 4
A.7.a.l. Labeling Your Submission Diskette 4
A.7.a.2 Submitting Electronically to States 5
A. 8 How to Obtain Forms and Other Information 5
B. Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
B.I Full-Time Employee Determination 7
B.2 Primary SIC Code Determination 7
B.2.a. Multi-Establishment Facilities 8
B.2.b. Auxiliary Facilities 10
B.2.c. Property Owners 10
B.3 Activity Determination 10
B.S.a. Definitions of "Manufacture, "Process," and "Otherwise Use" 10
B.S.b. Activity Exemptions 13
B.4 Threshold Determinations 18
B.4.a. How to Determine If your Facility Has Exceeded Thresholds : 18
B.4.b. Threshold Determinations for On-Site Reuse Operations 19
B,4.c. Threshold Determinations for Ammonia 19
B.4.d. Threshold Determinations for Chemical Categories 19
B.4.e. Mixtures and Other Trade Name Products 20
B.5 Release and Other Waste Management Determinations for Metals, Metal Compounds,
and Nitrate Compounds 22
C. Instructions for Completing EPA Form R
Parti. Facility Identification Information
1. Reporting Year ........: 24
2. Trade Secret Information 24
2.1 r Are you claiming the toxic chemical identified on page 2 trade secret? 24
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized? 24
3. Certification 24
4. Facility Identification 24
4.1 Facility Name, Location, and TRI Facility Identification Number 24
4.2 Full or Partial Facility Indication 24
Toxics Release Inventory Reporting Forms and Instructions i
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Table of Contents
4.3 Technical Contact 25
4.4 Public Contact 25
4.5 Standard Industrial Classification (SIC) Code 25
4.6 Latitude and Longitude 26
4.7 Dun and Bradstreet Number 26
4.8 EPA Identification Number 26
4.9 NPDES Permit Number 26
4.10 Underground Injection Well Code (UIC) Identification Number 26
5. Parent Company Information 26
5.1 Name of Parent Company 26
5.2 Parent Company's Dun & Bradstreet Number 26
Part II. Chemical-Specific Information
1. Toxic Chemical Identity 27
1.0 CASNumber 27
1.2 Toxic Chemical or Chemical Category Name 27
1.3 Generic Chemical Name 28
2. Mixture Component Identity 28
2.1 Generic Chemical Name Provided by Supplier 28
3. Activities and Uses of the Toxic Chemical at the Facility 28
3.1 Manufacture the Toxic Chemical 28
3.2 Process the Toxic Chemical (incorporative activities) 29
3.3 Otherwise Use the Toxic Chemical (non-incorporative activities) 29
4. Maximum Amount of the Toxic Chemical On Site at Any Time During
the Calendar Year 30
5. Quantity of the Toxic Chemical Entering Each Environmental Medium On Site 31
5.1 Fugitive or Non-Point Air Emissions 31
5.2 Stack or Point Air Emissions 31
5.3 Discharges to Receiving Streams or Water Bodies 31
5.4.1 Underground Injection On-Site to Class I Wells 32
5.4.2 Underground Injection On Site to Class II-V Wells 32
5.5 Disposal to Land On Site 32
5.5.1A RCRA Subtitle C landfills 32
5.5.1B Other landfills 32
5.5.2 Land treatment/application farming 32
5.5.3 Surface impoundment 32
5.5.4 Other Disposal 33
5.A Column A: Total Release 33
5.B Column B: Basis of Estimate 34
5.C Column C: Percent From Stormwater 35
6. Transfers of the Toxic Chemical in Wastes to Off-Site Locations 36
6.1 Discharges to Publicly Owned Treatment Works (POTWs) 36
6.1.A.1 Total Transfers 36
6.1.A.2 Basis of Estimate 37
6.2 Transfers to Other Off-Site Locations 38
6.2.A Column A: Total Transfers - 40
6.2.B Column B: Basis of Estimate 40
6.2.C Column C: Type of Waste Management: Disposal/Treatment / Energy Recovery /Recycling 42
7. On-Site Waste Treatment, Energy Recovery, and Recycling Methods 44
7A. On-Site Waste Treatment Methods and Efficiency 44
7A.a. Column A: General Waste Stream 44
7A.b. Column B: Waste Treatment Method(s) Sequence 44
7A.c. Column C: Range of Influent Concentration 46
ii Toxics Release Inventory Reporting Forms and Instructions
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Table of Contents
7A.d. Column D: Waste Treatment Efficiency Estimate 46
7A.e Column E: Based on Operating Data? ; 47
7B. On-Site Energy Recovery Processes 47
7C. On-Site Recycling Processes 49
8. Source Reduction and Recycling Activities 49
D. Facility Eligibility Determination for Alternate Threshold and for Reporting on
EPA Form A
D.I Alternate Threshold 58
D.2 What is the Form A (certification statement)? 58
D.3 What is the total annual reportable amount? 58
D.4 Recordkeeping 58
D.5 Multi-establishment facilities 58
D.6 Trade secrets 59
D.7 Metals and metal compounds 59
E. Instructions for Completing EPA Form A
Part I. Facility Identification Information
1. Reporting Year 60
2. Trade Secret Information 60
2.1 Are you claiming the toxic chemical identified on page 2 trade secret? 60
2.2 If "yes" in 2.1, is this copy sanitized or unsanitized? 60
3. Certification 60
4. Facility Identification 60
4.1 Facility Name, Location, and TRI Facility Identification Number 60
4.2 Federal Facility Designation 61
4.3 Technical Contact 61
4.4 Intentionally Left Blank 61
4.5 Standard Industrial Classification (SIC) Code 61
4.6 Latitude and Longitude '...... 61
4.7 Dun and Bradstreet Number(s) 62
4.8 EPA Identification Number(s) 62
4.9 Facility NPDES Permit Number(s) '.'.'.'.'.'.'.'.'. 62
. 4.10 Underground Injection Well Code (UIC) Identification Number(s) 62
5. Parent Company Information 62
5.1 Name of Parent Company 62
5.2 Parent Company's Dun & Bradstreet Number 62
Part II. Chemical Identification
1. Toxic Chemical Identity 62
1.1 CAS Number '.'.'.'.'.'.'.'.'.'.'.'. 62
1.2 Toxic Chemical or Chemical Category Name 63
1.3 Generic Chemical Name 63
2. Mixture Component Identity 63
2.1 Generic Chemical Name Provided by Supplier 63
Table I SIC Codes 10-73 I_l
Table II EPCRA Section 313 Chemical List for Reporting Year 1997 II-l
Table III State Abbreviations HI-1
Toxics Release Inventory Reporting Forms and Instructions iii
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Table of Contents
Appendix A Federal Facility Reporting Information A-l
Appendix B Reporting Codes for EPA Form R B-l
Appendix C Common Errors in Completing Form R Reports C-l
Appendix D Supplier Notification Requirements D-l
Appendix E How to Determine Latitude and Longitude From Topographic Maps E-l
Appendix F State Designated Section 313 Contacts F-l
Appendix G Section 313 EPA Regional Contacts G-l
Appendix H Section 313 Related Materials and Information Access H-l
iv Toxics Release Inventory Reporting Forms and Instructions
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Automated TRI Reporting Software
runatfti TRt
About ATRS
ATRS98 is EPA's Automated TRI Reporting Software for reporting TRI data for 1998 and any preceding year. This
software was formerly called Automated Form R. Its name has been changed to better reflect the fact that it also
allows for "small quantity releases" certification reporting, which is done using our Form A.
Listed below are some features which are new this year:
ATRS98 on CD
Distributing our software on compact disk (CD) allows us to provide you with several of our industry-specific
regulatory guidance documents and the EPCRA Section 313 Questions and Answers book in addition to all versions
of ATRS98 (Windows 95, 98 and NT; Windows 3.1 and DOS) and the ATRS Users Guide.
Certification Statement (alternative reporting using Form A)
Until this year, firms submitting Form A could only report one EPCRA Section 313 chemical per form. To make your
reporting easier, we have modified the Form A so that multiple EPCRA Section 313 chemicals are reported on a single
form.
"Recycle" Your Old Data
The "reload data function" allows you to reload existing TRI data from any of the following sources which you may
have saved from previous TRI reporting: (1) any APR/ATRS submission diskette, (2) AFR97 for DOS database, or (3)
AFR96/97 for Windows database. Once reloaded this data can easily be edited to update it as needed for 1998
reporting.
Y2K Compliance
All data fields containing year data have been expanded to four digits. All data fields containing month, day and year
follow the mm/dd/yyyy format.
PQTWs, Offsites, and Stream Data
Previous versions of our software limited users to only 99 POTWs, off-site locations, and streams. ATRS98 has no
limit on these data fields; you can enter as many as you need.
TRI Facility ID Number
If you have submitted TRI data to EPA in the past, we have assigned you a TRI facility ID number (TRIFID). If you
select CD-ROM on the Select Components screen when installing ATRS98, you will enable a feature which allows you
to display a master list of TRIFIDs, with associated facility names and addresses. By choosing the correct entry from
this list, you eliminate the need to re-enter all your facility identification information.
If you are a new reporter, or have reported in the past but have never used our reporting software, we hope you will
give ATRS98 a try.
Automated TRI Reporting Software v
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Chemical and Industry Guidance Documents
To receive a copy of any of the section 313 documents
listed below, check the box(es) next to the desired
documents). There is no charge for any of these
documents. Be sure to type or clearly print your full
mailing address in the space provided on the third page
of this form (page viii). 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
O 40 CFR 372, Toxic Chemical Release Reporting;
Community Right-to-Know; Final Rule
A reprint of the final section 313 rule as it appeared
in the Federal Register (FR) February 16,1988 (53 PR
4500) (OTSFR 021688).
Q Toxics Chemical Release Inventory Reporting
Forms and Instructions for 1998, February 1999
(EPA 740-K-99-001)
Q Consolidated List of Chemicals Subject to
Reporting Under the Act, (Title III List of Lists)
(EPA 550-B-98-017) Q
A consolidated list of specific chemicals covered by
the Emergency Planning and Community Right-to-
Know Act. The list contains the chemical 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,
January 1999 (EPA 745-K-99-002)
The brochure alerts businesses to their reporting
obligations under section 313 and assists in
determining whether their facility is required to
report. The brochure contains the EPA regional ,-.
contacts, the list of section 313 toxic chemicals and
a description of the Standard Industrial
Classification (SIC) codes subject to section 313.
Q Supplier Notification Requirements,
(EPA 560-4-91-006)
This pamphlet assists chemical suppliers who may
be subject to the supplier notification requirements,
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
implements the trade secrets provision of the
Emergency 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 Under
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 reporting
requirements of EPCRA section 313. The glossary
was developed to aid in determining whether a
facility manufactures, processes, or otherwise uses
a chemical subject to section 313 reporting.
Executive Order 12856 - Federal Compliance with
Right-to-Know Laws and Pollution Prevention
Requirements: Questions and Answers,
February 1999 (EPA 745-R-99-001)
This document assists federal facilities in
complying with Executive Order 12856. This
information has been compiled by EPA from
questions received from Federal facilities. This
document is intended for the exclusive use of
Federal facilities 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.
Section 313 of the Emergency Planning and
Community Right-to-Know Act; Questions and
Answers, December 1998 (EPA 745-B-98-004)
The revised 1998 EPCRA Section 313 Questions and
Answers document assists regulated facilities in
complying with the reporting requirements of
vi TOXJ'CS Release Inventory Reporting Forms and Instructions
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Chemical and Industry Guidance Documents
Q
EPCRA section 313. This updated document
presents interpretive guidance in the form of
answers to many commonly asked questions on
compliance with EPCRA section 313. In addition,
this document includes comprehensive written
directives to assist covered facilities in
understanding some of the more complicated
regulatory issues. This updated guidance document
is intended to supplement the instructions for
completing the Form R and the Alternate Threshold
Certification Statement (Form A).
Toxics ReleaselnventoryrReportingModifications
Beginning with 1995 Reporting Year, February
1995 (EPA 745-R-95-009)
Chemical-Specific Guidance
EPA has developed a group of guidance documents
specific to individual chemicals and chemical categories.
Q Toxics Release Inventory List of Toxic Chemicals
within the Polychlorinated Alkanes Category and
Guidance for Reporting,
February 1995 (EPA745-R-95-001)
Q ToricsReleaselnventoryListofToxicChemicalswithin
the Water Dissociable Nitrate Compounds Category
and Guidance for Reporting,
May 19% (EPA745-R-96-003)
Q Toxics Release Inventory List of Toxic Chemicals within
the Polyclic Aromatic Compounds Category,
February 1995 (EPA745-R-95-004)
Q ToxicsReleaselnventoryListofToxicChemicalswithin
the Nicotine and Salt Category and Guidance for
Reporting,
February 1995 (EPA745-R-95-004)
Q ToxicsReleaselnventorylJstofToxicChemicalswithin
the Strychnine and Salts Category and Guidance for
Reporting, February 1995 (EPA745-R-95-005)
Q Toxics Release Inventory List of Toxic Chemicals
within the Glycol Ethers Category and Guidance for
Reporting,
May 1995 (EPA745-R-95-006)
Q Emergency Planning and Community Right-to-Know
Section 313: List of Toxic Chemicals within the
Chlorophenols Category,
November 1994 (EPA745-B-95-004)
Q Emergency Planning and Community Right-to-
Know Section 313: Guidance for Reporting
Aqueous Ammonia, July 1995 (EPA745-R-95-012)
Q Emergency Planning and Community Right-to-
Know Section 313: Guidance for Reporting
Sulfuric Acid (acid aerosols including mists,
vapors, gas, fog and other airborne forms of any
particle size), November 1997 (EPA745-B-97-007)
Industry-Specific Guidance
EPA has developed a group of individual guidance documents
for certain industries.
Q Section 313 of the Emergency Planning and
Community Right-to-Know Act; Toxic Chemical
Release Inventory; Data Quality Checks to
Prevent Common Reporting Errors on Form
R/Form A, August 1998 (EPA 745-R-98-012)
Q Emergency Planning and Community Right-to-Know
Act Section 313 Reporting Guidance for Spray
Application and Electrodeposition of Organic Coatings,
December 1998 (EPA 745-R-98-014)
Q Emergency Planning and Community Right-to-Know
Act Section 313 Reporting Guidance for Food
Processors, September 1998 (EPA 745-R-98-011)
Q Emergency Planning and Community Right-to-Know
Act Section 313 Reporting Guidance for Rubber and
Plastics Manufacturing,
December 1998 (EPA 745-R-99-017)
Q Emergency Planning and Community Right-to-Know
Act Section 313 Reporting Guidance for Semiconductor
Manufacturing, December 1998 (EPA 745-R-98-007)
Q Emergency Planning and Community Right-to-Know
Act Section 313: Guidance for Metal Mining Facilities;
Januaryl999 (EPA 745-B-99-001)
Toxics Release Inventory Reporting Forms and Instructions vii
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Chemical and Industry Guidance Documents
Q Emergency Planning and Community Right-to-Know
Act Section 313: Guidance for Coal Mining Facilities,
January 1999 (EPA 745-B-99-002)
Q Emergency Planning and Community Right-to-
Know Act Section 313: Guidance for Electricity
Generating Facilities,
January 1999 (EPA 745-B-99-003)
Q Emergency Planning and Community Right-to-
Know Act Section 313: Guidance for RCRA
Subtitle C TSD Facilities and Solvent Recovery
Facilities, January 1999 (EPA 745-B-99-004)
Q
Emergency Planning and Community Right-to-
Know Act Section 313: Guidance for Chemical
Distribution Facilities,
January 1999 (EPA 745-B-99-005)
Emergency Planning and Community Right-to-Know
Act Section 313: Guidance for Chemical Petroleum
BulkStorage Facilities, January 1999 (EPA 745-B-99-006)
PLEASE TYPE MAILING ADDRESS HERE (DO NOT ATTACH BUSINESS CARDS)
Name/Tide
Company Name
Mail Stop
Street Address
P.O. Box
City/State/Zip Code
viii Toxics Release Inventory Reporting Forms and Instructions
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Paperwork Reduction Act Notice: The annual public burden related to the Form R, which
is approved under OMB Control No. 2070-0093, is estimated to average 52.1 hours per
response. The annual public burden related to the Form A, which is approved under OMB
Control No. 2070-0143, is based on a combination of the estimated burdens for 1)
determining whether a listed toxic chemical is eligible for certification under the alternate
threshold, and 2) completing the Form A. The burden of determining eligibility for
certification is estimated to average 33.2 hours for each chemical that is certified. The
burden of completing the Form A is estimated to average 1.4 hours, regardless of the
number of chemicals being certified. The total burden per response is the combination of
these two, and will vary depending on the number of listed toxic chemicals being certified.
According to the Paperwork Reduction Act, "burden" means the total time, effort,
or financial resources expended by persons to generate, maintain, retain, or disclose or
provide information to or for a Federal agency. For this collection it includes the time
needed to review instructions; train personnel to be able to respond to the collection of
information; search data sources; complete and review the collection of information; and
transmit or otherwise disclose the information. An agency may not conduct or sponsor, and
a person is not required to respond to, a collection of information unless it displays a
currently valid OMB control number. The OMB control numbers for this information
collection appear above and on the forms. In addition, the OMB control numbers for EPA's
regulations, after initial display in the final rule, are listed in 40 CFR part 9.
Send comments on the accuracy of the provided burden estimates, and any
suggested methods for minimizing respondent burden, including through the use of
automated collection techniques to the Director, OP Regulatory Information Division, U.S.
Environmental Protection Agency (Mail Code 2137), 401 M Street, S.W., Washington, D.C.
20460. Include the OMB control number in any correspondence, but do not submit the
requested information to this address. The completed forms should be submitted in
accordance with the instructions accompanying the form, or as specified in the
corresponding regulation.
Toxics Release Inventory Reporting Forms and Instructions ix
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IMPORTANT.- Type w print; read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 04/2000
Page 1 of 5
EPA
FORM R
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
mportant: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
Are you claiming the toxic chemical identified on page 2 trade secret?
Yes (Answer question 2.2;
Attach substantiation forms)
No (Do not answer 2.2;
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted
iformation is true and complete and that the amounts and values in this report are accurate based on reasonable estimates
ising data available to the preparers of this report.
lame and official title of owner/operator or senior management official:
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
L1
TRI Facility ID Number
acility or Establishment Name
Facility or Establishment Name or Mailing Address(if different from street address)
Mailing Address
Jity/County/State/Zip Code
City/County/State/Zip Code
This report contains information for:
artant : check a or b; check c if applicable)
a.
An entire
facility
Part of a
facility
c.
A Federal
facility
L3
Technical Contact Name
Telephone Number (include area code;)
u
Public Contact Name
Telephone Number (include area codej
L.5
SIC Code (s) (4 digits)
b.
c.
d.
e.
1.6
Latitude
Degrees
Minutes
Seconds
Longitude
Degrees
Minutes
Seconds
Dun & Bradstreet
Number(s) (9 digits)
4.8
EPA Identification Number
(RCRA'I.D. No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
a.
b.
SECTION 5. PARENT COMPANY INFORMATION
Name of Parent Company
NA
Parent Company's Dun & Bradstreet Number
NA
'A Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
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r
This side intentionally
left blank.
Please do not copy
double-sided!
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Page 2 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility (D Number
Toxic Chemical, Category or Generic Name
SECTION 1. TOXIC CHEMICAL IDENTITY
(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 1, 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 completed 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 all that apply.)
3.1
Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3
Otherwise use the toxic chemical:
Produce
b.
Import
c.
d.
e.
f.
If produce or import:
For on-site use/processing
For sale/distribution
As a byproduct
As an impurity
a.
b.
c.
d.
As a reactant
As a formulation component
As an article component
Repackaging
a.
b.
c.
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE 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 ONSITE
A. Total Release (pounds/year)
(Enter range code or estimate*)
B. Basis of Estimate
(enter code)
C. % From Stormwater
5.1
5.2
5.3
Fugitive or non-point
air emissions
Stack or point
air emissions
NA
NA
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 onsite
to Class I Wells
5.4.2
Underground Injection onsite
to Class II-V Wells
NA
NA
f additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box
nd indicate the Part II, Section 5.3 page number in this box. | | (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
>ART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)
TR) Facility ID Number
Toxic Chemical, Category, or Generic Name
ECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE (Continued)
NA
A. Total Release (pounds/year) (enter range
code* or estimate)
B. Basis of Estimate
(enter code)
Disposal to land onsite
5.1A
RCRA Subtitle C landfills
5.1 B
Other landfills
5.2
Land treatment/application
farming
5.3
Surface Impoundment
5.4 Other disposal
ECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
1.A Total Quantity Transferred to POTWs and Basis of Estimate
1.A.1. Total Transfers (pounds/year)
(enter range code* or estimate)
6.1.A.2 Basis of Estimate
(enter code)
1.B.
POTW Name
3TW Address
State
County
Zip
1.B.
POTW Name
DTW Address
State
County
Zip
additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
this box | | and indicate the Part II, Section 6.1 page number in this box | | (example: 1,2,3, etc.)
ECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
2. _ Off-Site EPA Identification Number (RCRA ID No.)
ff-Site Location Name
f-Site Address
State
County
Zip
ocation under control of reporting facility or parent company?
Yes
No
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 11. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility 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.
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 (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.
4. M
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
Not Applicable (NA) -
Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
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
Based on
Operating Data ?
7A.1a
7A.1c
7A.1d
7A.1e
Yes No
7A.2c
7A.2d
7A.2e
Yes No
7A.3c
7A.3d
7A.4c
7A.4d
7A.5c
7A.5d
If additional pages of Part II, Section 6.2/7A are attached, indicate the total number of pages in this
and indicate the Part II, Section 6.2/7A page number in this box : | | (example: 1,2,3, etc)
box
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
Not Applicable (NA) - Check here if no on-site energy recovery is applied to any waste
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)]
SECTION 7C. ON-SITE RECYCLING PROCESSES
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)]
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
Column A
Prior Year
(pounds/year)
Column B
Current Reporting Year
(pounds/year)
Column C
Following Year
(pounds/year)
Column D
Second Following Year
(pounds/year)
Quantity released **
Quantity used for energy recovery
onsite
Quantity used for energy recovery
offsite
Quantity recycled onsite
.5
.6
.7
Quantity recycled offsite
Quantity treated onsite
Quantity treated offsite
Quantity released to the environment as a result of remedial actions,
catastrophic events, or one-time events not associated with production
processes (pounds/year)
.9
Production ratio or activity index
.10
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)
.10.1
b.
c.
.10.2
c.
.10.3
a.
10.4
b.
11
Is additional information on source reduction, recycling, or pollution control activities
included with this report ? (Check one box)
YES
NO
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 onsite or offsite.
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
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PORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0143 Page 1 of
*> United States
^^ Environments
Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY
FORMA
WERE 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
nportant: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PARTI. FACILITY IDENTIFICATION INFORMATION
ECTION 1. REPORTING YEAR ^^_^^
ECTION 2. TRADE SECRET INFORMATION
Are you claiming the toxic chemical identified on page 2 trade secret?
Yes (Answer question 2.2;
Attach substantiation forms)
No (Do not answer 2.2;
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1)
ECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
iereby certify that to the best of my knowledge and belief, for each toxic chemical listed in the statement, the annual reportable
nount as defined in 40 CFR 372.27 (a), did not exceed 500 pounds for this reporting year and that the chemical was
lanufactured, processed, or otherwise used in an amount not exceeding 1 million pounds during this reporting year.
ame and official title of owner/operator or senior management official:
Signature:
Date Signed:
ECTION 4. FACILITY IDENTIFICATION
.1
TRI Facility ID Number
scility or Establishment Name
Facility or Establishment Name or Mailing Address(if different from street address)
reel
Mailing Address
ity/County/State/Zip Code
City/County/State/Zip Code
This report contains information for: (Important : check c if applicable)
c.
A Federal
facility
Technical Contact Name
Telephone Number (include area codej
.4
Intentionally left blank
.5
SIC Code (s) (4 digits)
a.
b.
c.
d.
e.
.6
Latitude
Degrees
Minutes
Seconds
Longitude
Degrees
Minutes
Seconds
Dun & Bradstreet
Number(s) (9 digits)
4.8
EPA Identification Number
(RCRA I.D. No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
b.
ECTION 5. PARENT COMPANY INFORMATION
Name of Parent Company
NA
Parent Company's Dun & Bradstreet Number
NA
A Form 9350-2
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IMPORTANT: Type or print; read instructions before completing form
Page of
EPA FORM A
PART II. CHEMICAL IDENTIFICATION
TRIFID:
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
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 completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
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 completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
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 completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of.
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 Parti, 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 completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
EPA Form 9350-2
(Make additional copies of this page, if needed)
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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-Know Act (EPCRA, or Title HI of
the Superfund Amendments and Reauthorization Act of
1986), Public Law 99-499. The information contained 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 October,
1990 (Pub. L. 101-508), added reporting requirements 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
information on the releases of EPCRA Section 313
chemicals in their communities and to provide EPA with
release information to assist the Agency in determining
the need for future regulations. Facilities must report the
quantities of both routine and accidental releases of
EPCRA Section 313 chemicals, as well as the maximum
amount of the EPCRA Section 313 chemical on site
during the calendar year and the amount contained in
wastes managed on site or transferred off site.
A completed Form R or Form A must be submitted for
each EPCRA Section 313 chemical manufactured,
processed, or otherwise used at each covered facility as
described in the reporting rules in 40 CFR Part 372
(originally published February 16,1988, in the Federal
Register and November 30,1994, in the Federal Register
(for Form A)). These instructions supplement and
elaborate on the requirements in the reporting rule.
Together with the reporting rule, they constitute the
reporting requirements. All references in these
instructions are to sections in the reporting rule unless
otherwise indicated.
A.1 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 The facility has 10 or more full-time employees; and
Q The facility is included in Standard Industrial
Classification (SIC) Codes 10 (except 1011,1081, and
1094), 12 (except 1241), 20-39, 4911 (limited to
facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust
coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/ or oil for
the purpose of generating electricity for distribution
in commerce), 4953 (limited to facilities regulated
under the RCRA Subtitle C, 42 U.S.C. section 6921
et seq.), 5169, 5171, and 7389 (limited to facilities
primarily engaged in solvents recovery services on
a contract or fee basis); and
Q The facility manufactures (defined to include
importing), processes, or otherwise uses any
EPCRA Section 313 chemical in quantities greater
than the established threshold in 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
The five-page 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
chemical-specific report. However, Part I of each Form
R submitted must have an original signature on the
certification statement and the trade secret designation
must be entered as appropriate. Part II must be
completed separately for each EPCRA Section 313
chemical or chemical category. Because a complete Form
R consists of at least five unique pages, any submission
containing less than five unique pages is not a valid
submission.
A complete report for any EPCRA Section 313 chemical
that is not claimed as a trade secret consists of the
following completed parts:
Q Part I with an original signature on the certification
statement (section 3); and
Q Part II (Note: Section 8 is mandatory).
Staple all five pages of each report together. If you check
yes on Part II, Section 8.11, you may attach additional
Toxics Release Inventory Reporting Forms and Instructions 1
-------
General Information
information 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 substitute for
reporting Form R information. This is based on an
alternate threshold for facilities with low amounts of an
EPCRA Section 313 chemical in waste. The Form A
serves as an alternate to Form R, such that completion of
the Form A is in lieu of Form R. Like the Form R
described above, the Form A consists of two parts, but
only consists of a total of two 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).
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 II of the Form A must be
completed separately for each EPCRA Section 313
chemical or chemical category. A complete report for
Form A consists of two pages for each submission.
A.3 Trade Secret Claims
For any EPCRA Section 313 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 the
EPCRA Section 313 report. One set of reports, the
"unsanitized" version, should provide the actual identity
of the EPCRA Section 313 chemical. The other set of
reports the "sanitized" version, should provide only a
generic identity of the EPCRA Section 313 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 II, Section 1.3, of the instructions.
In summary, a complete report to EPA for an EPCRA
Section 313 chemical claimed as a trade secret must
include all of the following:
Q A completed "unsam'tized" version of Form R or
Form A report including the EPCRA Section 313
chemical identity (staple the pages together);
Q A sanitized version of a completed Form R or Form
A report in which the EPCRA Section 313 chemical
identity 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.
Some states also require submission of both sanitized and
unsanitized reports for EPCRA Section 313 chemicals
whose identity is claimed as a trade secret. Others
require only a sanitized version. Facilities may
jeopardize the trade secret status of an EPCRA Section
313 chemical by submitting an unsanitized version of the
EPCRA Section 313 report to a state agency or Indian
tribe that does not require unsanitized forms. You may
identify an individual State's submission requirements
by contacting the appropriate state-designated Section
313 contact (see Appendix F).
A.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,
calculations, 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 report, EPA may request
documentation from the facility that supports the
information reported.
2 Toxics Release Inventory Reporting Forms and Instructions
-------
General Information
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 EPCRA Section 313 chemicals for which
they did not file EPCRA Section 313 reports.
A partial list of records, organized by year, that a facility
should maintain include:
Q Previous years' EPCRA Section 313 reports;
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 efficiencies;
Q RCRA Manifests;
Q Process diagrams that indicate emissions and other
releases; and
Q Records for those EPCRA Section 313 chemicals for
which they did not file EPCRA Section 313 reports.
A.5 How to Prepare a Voluntary
Revision of a Previous
Submission
Starting with the 1998 reporting year, voluntary revisions
must be submitted by July 31st of the same year as the
reporting deadline 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 EPCRA
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
"VOLUNTARY REVISION" on page 1 of the Form. For
revisions to 1991 and later reportingyear 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
certification statement on page 1. For revisions to 1990
and earlier reporting year submissions, write the words
"VOLUNTARY REVISION" on page 1 of the Form R. For
revision to 1991 and later reportingyear 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
submission 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 ATRS and does not provide regulatory
support. If you submitted your Form R data using
software developed by an EPA approved Form software
developer, you must contact the software developer, to
determine if the software you used allows for magnetic
media revisions. Please be careful when submitting
magnetic media revisions to resubmit only the revised
submissions. Do not resubmit a diskette containing all of
your original submissions if you are only revising one or
a few of them.
A.5.a. Where to Submit a Voluntary
Revision of a Previous Submission
Revisions should be submitted to EPA and the
appropriate state agency (or the designated official of an
Indian tribe) to whom you submitted the original Form
(see Section A.G.a).
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.
Toxics Release Inventory Reporting Forms and Instructions 3
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General Information
A.7 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
submissions 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
Also send a copy of the report to the State in which the
facility is located. ("State" also includes: 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 jurisdiction.) 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
agreement.
Submission of Section 313 reports in magnetic media and
computer-generated facsimileformats has beenapproved
by EPA. EPA has developed a package called the
"AutomatedToxicChemicalReleaselnventory Reporting
Software (ATRS)." The easy-to-use CD-ROM / diskettes
come with complete instructions for their use (See "ATRS
for Reporting Year 1998" and enclosed CD-ROM /
diskettes). It also provides prompts and messages to
help you report according to EPA instructions. For copies
of the CD-ROM / diskettes you may call the EPCRA
Hotline.
Many firms are offering computer software to assist
facilities in producing magnetic media submissions for
computer-generated facsimiles of EPCRA Section 313
reports. To ensure accuracy, EPA will only accept
magnetic media submissions and computer-generated
facsimiles 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 EPCRA 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 EPCRA Section 313 report. If this is
the case, a magnetic media or computer-generated
facsimile may be unacceptable.
A.7.a. How to Send Your Disks Containing
Form R(s) and/or Form A(s)
Included in this reporting package (on the enclosed CD-
ROM) is the Automated TRI Reporting Software (ATRS).
If you use the ATRS, please follow the instructions below
for submitting your TRI forms on magnetic media.
A.7.a.l Labeling Your Submission Diskette
A label must be attached to each diskette. The label may
be typed or legibly handwritten. A sample label with the
necessary information is shown below.
TRIS Report
Company Name
Date: 6/29/1999
Report Year 1998
Density: HD
Number: 1 of 1
Contact:
Technical Contact Name
(505) 555-5369
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 signature from each
submitting facility to:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-3348
Attn: TRI Magnetic Media Submission
If you are submitting reports on magnetic diskette to
EPA, you must enclose a cover letter signed by the
4 Toxics Release Inventory Reporting Forms and Instructions
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General Information
official listed in section 3 of Part I of the Form R or Form
A (name and official title of owner/operator or senior
management official) for each separate facility. This letter
can be printed from the ATSR. The letter on the next
page is a sample.
A.7.a.2 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
PL
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.
A.8 How to Obtain Forms and Other
Information
A copy 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'sTRI Web Site: http:// www.epa.gov/opptintr/tri
The Emergency Planning and Community Right-to-Know
Information Hotline
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 Chemical and Industry Specific Documents section
for the document request form and more information on
available documents.
Questions about completing Form R or Form A may be
directed to the EPCRA Hotline at the following address
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 a.m. - 6:00 p.m. Eastern Time
(Mon. - Fri., except Federal Holidays)
EPA Regional Staff may also be of assistance. Refer to
Appendix G for a list of EPA Regional Offices.
Toxics Release Inventory Reporting Forms and Instructions 5
-------
General Information
Sample Letter
June 20,1999
To Whom It May Concern:
Enclosed please find one (1) diskette containing toxic chemical release reporting information for:
YOUR FACILITY NAME
Tin's information is submitted as required under Section 313 of the Emergency Planning and Community Right-
to-Know 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
Lead compounds
Zinc
RY
1998
1998
CAS Number
NA420
7440-66-6
Our technical point of contact is:
TECHNICAL CONTACT NAME, Telephone 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
6 Toxics Release Inventory Reporting Forms and Instructions
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B. Facility Eligibility Determination for Submitting an EPCRA
Section 313 Report
This section will help you determine whether you must
submit an EPCRA Section 313 report. This section
discusses EPCRA Section 313 reporting requirements
such as the number of full-time employees, primary SIC
Code, and chemical activity threshold quantities. The
EPCRA Section 313 chemicals and chemical categories
subject to reporting are listed in Table II (also see 40 CFR
372.65). (See Figure 1 for more information)
B.I Full-Time Employee
Determination
The number of full-time employees is dependent only
upon the total number of hours worked by all employees
for the facility during the calendar year and not the
number of persons working. Therefore, a "full-time
employee," for purposes of Section 313 reporting, is
defined as 2,000 work hours per year and includes paid
leave and holidays. To determine the number of
full-time employees working for your facility, add up the
hours worked by all employees during the calendar year,
including contract employees and sales and support staff
working for the facility, and divide the total by 2,000
hours. In other words, if the total number of hours
worked by all 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
1,500 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 six workers and three
sales staff. The six 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, five 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. Dividing the 20,000
hours by 2,000 yields 10 full-time employees. This
facility has met the full time employee criteria and
may be subject to reporting if the other criteria are
met.
B.2 Primary SIC Code
Determination
Standard Industrial Classification (SIC) codes 10 (except
1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4939 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4953 (limited to
facilities regulated under the RCRA Subtitle C, 42 U.S.C.
section 6921 et seq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services
on a contract or fee basis) are covered by the rule and are
listed in Table 1. The first two digits of a 4-digit SIC
code define a major business sector, while the last two
digits denote a facility's specialty within the major sector.
For a detailed description of 4-digit SIC Codes, refer to
the "Standard Industrial Classification 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
activities as referenced in the SIC Manual. Clothbound
editions of the SIC Manual are available in most major
libraries or may be ordered through the National
Technical Information Service, 5285 Port Royal Road,
Springfield, 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
upcoming Federal Register notice. This upcoming
change does NOT affect the 1998 EPCRA Section 313
reporting.
Toxics Release Inventory Reporting Forms and Instructions 1
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Does your facility have 10 or more full-
time employees or the equivalent?
(see definition under B.I)
NO
YES
Is your facility's primary SIC Code
included on the EPCRA Section 313 list?
(see B.2 and Table I)
NO
YES
Does Your Facility Manufacture, Process,
or Otherwise Use Any EPCRA Section 313
Chemicals and Chemical Categories?
fsee Table n.B.3rB.5. and D.1-D.7)
YES
Does Your Facility Exceed Any of the
Thresholds for a Chemical or a Chemical
Category (after excluding quantities that are
exempt from threshold calculations)
NO
STOP
NO EPCRA
SECTION 313
REPORTS
REQUIRED FOR
ANY CHEMICALS
YES
AN EPCRA SECTION 313 REPORT IS
REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY
YES
Is the amount manufactured, OR processed, OR otherwise used less than or equal to
1,000,000 pounds AND is the reportable amount less than or equal to 500 Ibs/yr
YES
FORMA
OR
FORM R IS REQUIRED FOR THIS
CHEMICAL OR CHEMICAL CATEGORY
FORM R IS REQUIRED FOR THIS
CHEMICAL OR CHEMICAL
CATEGORY (FORM A CANNOT
BE SUBMITTED)
Figure 1 EPCRA Section 313 Reporting Decision Diagram
B.Z.a. Multi-Establishment Facilities
Your facility ma/ 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, shipped, or services provided 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 produced, shipped,
or services provided at establishments with primary
SIC Codes 10 (except 1011, 1081, and 1094), 12
(except 1241), 20-39, 4911 (limited to facilities that
combust coal and/or oil for the purpose of
generating electricity for distribution in commerce),
4931 (limited to facilities that combust coal and/or
8 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
oil for the purpose of generating electricity for
distribution in commerce), 4939 (limited to facilities
that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce),
4953 (limited to facilities regulated under the RCRA
Subtitle C, 42 U.S.C. section 6921 et seq.), 5169, 5171,
and 7389 (limited to facilities primarily engaged in
solvents recovery services on a contract or fee basis)
is greater than 50 percent of the value of the entire
facility's products and services, the entire facility
meets the SIC code criterion.
Q If any one establishment with a primary SIC Code 10
(except 1011,1081, and 1094), 12 (except 1241), 20-
39, 4911 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity
for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4939 (limited to facilities that combust
coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4953
(limited to facilities regulated under the RCRA
Subtitle C, 42 U.S.C. section 6921 et seq.), 5169,5171,
or 7389 (limited to facilities primarily engaged in
solvents recovery services on a contract or fee basis)
produces or ships products or provides services
whose value exceeds the value of products and
services produced or shipped by any other
establishment within the facility, the facility also
meets the SIC Code criterion.
The value of production or service attributable to a
particular establishment may be isolated by subtracting
the product value obtained from other establishments
within the same facility from the total product or service
value of the facility. This procedure eliminates the
potential for "double counting" production and services
in situations where establishments are engaged in
sequential production or service activities at a single
facility.
Examples include:
Q A facility in coating, engraving and allied services
has two establishments. The first establishment, a
general automotive repair service, is in SIC Code
7537, which is not a covered SIC Code. However,
the second establishment, a metal paint shop is in
SIC Code 3479, which is a covered SIC Code. The
metal paint shop paints the parts received from
general automotive repair. service. The facility
determines the product is worth $500/unit as
received from the general automotive repair service
(in non covered SIC Code 7537) and the value of the
product is $1500/unit after processing by the metal
paint shop (in covered SIC Code 3479). The value
added by the metal paint shop is obtained by
subtracting the value of the products from the
general automotive repair service from that of the
value of the products of the metal paint shop. (In
this example, the added = $l,500/unit- $500/unit =
$l,000/unit.) The value added ($1,000/unit) by the
establishment in SIC Code 3479 is more than 50% of
the product value. Therefore, the facility's primary
SIC Code is 3479, which is a covered SIC Code.
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.
Alternatively, the facility could first determine the value
of the crops grown at the agricultural establishment, and
then calculate the contribution of the food processing
establishment by subtracting the crop value from the
total value of the product shipped from the processing
establishment (value of product shipped from processing
- crop value = value of processing establishment)
A covered multi-establishment facility must make
EPCRA Section 313 chemical threshold determinations
and, if required, must report all relevant information
about releases and other waste management activities,
and source reduction activities associated with an
EPCRA Section 313 chemical for the entire facility, even
from establishments that are not in SIC Codes 10 (except
1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4939 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4953 (limited to
facilities regulated under the RCRA Subtitle C, 42 U.S.C.
section 6921 et seq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services
on a contract or fee basis). EPA realizes, however, that
certain establishments 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 and other waste
management quantities for the whole facility are
represented by the sum of the releases and other
quantities managed as waste reported by each of the
separate establishments and the compliance
determination is based on the entire facility.
Toxics Release Inventory Reporting Forms and Instructions 9
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
B.2.b. Auxiliary Facilities
An auxiliary facility is one that supports another covered
establishment's activities (e.g., research and development
laboratories, warehouses, and storage facilities). An
auxiliary facility can assume the SIC Code of another
covered establishment if its primary function is to service
that other covered establishment's operations. For the
purposes of EPCRA Section 313, auxiliary facility is
defined as one primarily engaged in performing support
services for another covered establishment or multiple
establishments of a covered facility and is in a different
physical location than the primary facility. In addition, an
auxiliary facility performs an integral role in the primary
facility's activities. In general, an auxiliary facility's basic
administrative services (paperwork, payroll,
employment) are performed by the primary facility.
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 covered
establishment in SIC Codes 10 (except 1011, 1081, and
1094), 12 (except 1241), 20-39, 4911 (limited to facilities
that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4939 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4953 (limited to facilities
regulated under the RCRA Subtitle C, 42 U.S.C. section
6921 et seq.), 5169, 5171, and 7389 (limited to facilities
primarily engaged in solvents recovery services on a
contract or fee basis). Auxiliary facilities that are in these
aforementioned codes are required to report if they meet
the employee criterion and reporting thresholds for
manufacture, process, or otherwise use.
B.2,c. Properly 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
operation of that facility (e.g., your company owns an
industrial 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
produce, prepare, compound, or import an EPCRA
Section 313 chemical. (See Part II, Section 3.1 of these
instructions for further clarification.)
Import is defined as causing the EPCRA Section 313
chemical to be imported into the customs territory of the
United States. If you order an EPCRA Section 313
chemical (or a mixture containing the chemical) from a
foreign supplier, then you have imported the chemical
when that shipment arrives at your facility directly from
a source outside of the United States. By ordering the
chemical, you have "caused it to be imported," even
though you may have used an import brokerage firm as
an agent to obtain the EPCRA Section 313 chemical.
Do Not Overlook Coincidental Manufacture
The term manufacture also includes coincidental
production of an EPCRA Section 313 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., an EPCRA Section 313 chemical that
remains in the product that is distributed in commerce),
the de minimis exemption, discussed in Section B.3.b of
these instructions, applies. The de minimis exemption
does not apply to byproducts (e.g., an EPCRA Section
313 chemical that is separated from a process stream and
further processed or disposed). Certain EPCRA Section
313 chemicals may be manufactured as a result of
wastewater treatment or other treatment processes. For
example, neutralization of acid wastewater can result in
the coincidental manufacture of ammonium nitrate
(solution), reportable as a member of the nitrate
compound category.
Process: The term "process" means the preparation of a
listed Section 313 chemical, after its manufacture, for
distribution in commerce. Processing is usually the
intentional incorporation of a Section 313 chemical into a
product (see Part II, Section 3.2 of these instructions for
further clarification). Processing includes preparation of
the EPCRA Section 313 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 instructions) that contains a listed Section 313
chemical as one component.,
Otherwise Use: The term "otherwise use" means any use
of an EPCRA Section 313 chemical, including an EPCRA
Section 313 chemical contained in a mixture or other
trade name product, or waste that is not covered by the
terms "manufacture" or "process." Otherwise use of an
EPCRA Section 313 chemical does not include disposal,
10 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
stabilization (without subsequent distribution
commerce), or treatment for destruction unless:
in
(1) The EPCRA Section 313 chemical that was disposed,
stabilized, or treated for destruction was received from
off-site for the purposes of further waste management; or
(2) The EPCRA Section 313 chemical that was disposed,
stabilized, or treated for destruction was manufactured
as a result of waste management activities on materials
received from off-site for the purposes of waste
management activities. Relabeling or redistributing of the
EPCRA Section 313 chemical where no repackaging of
the EPCRA Section 313 chemical occurs does not
constitute an otherwise use or processing of the EPCRA
Section 3l3 chemical." (See 62 FR 23846 and Part II,
Section 3.3 of these Instructions for further clarification).
• Example 1: Coincidental Manufacture
Your company, a nitric acid manufacturer, uses^aqueous 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 215,000-pound manufacturing
threshold, the facility must report under the nitrate compounds category.
The aqueous ammonia is considered to be otherwise used andlO% of the total aqueous ammonia would be counted
towards ,the 10,000-pound use thresholdu 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).
• * . '~f- ~ i
As another example; combustion of coal or other fuel in boilers/furnaces can result in the coincidental manufacture
of metal compounds and sulfurie acid (acid aerosols), .hydrochloric acid (acid aerosols) and hydrogen fluoride.
Toxics Release Inventory Reporting Forms and Instructions 11
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Q
Q
Q
Q
Example 2: Typical Process and Manufacture Activities
Your company receives toluene, a EPCRA 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 EPCRA
Section 313 chemical and thus does not trigger reporting requirements.
Your facility combines toluene purchased from a supplier with various materials to form paint. Your
facility processes toluene.
Your company receives a nickel compound (nickel 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.
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 EPCRA Section 313
chemical.
In the combustion of coal or oil, metal compounds may be produced from either the parent metal or a metal
compound contained in the coal or oil. If a metal undergoes a change of valence, a metal compound is
considered to be manufactured. For example, during the combustion process copper in valence state zero
changes to copper in valence state +2 in a compound such as copper (II) oxide (CuO). Furthermore, a
metallic compound could be transformed to another metallic compound without a change in valency (e.g,,
copper (H) chloride (CuCI) is transformed to copper (II) oxide). The transformation to a new compound
by combustion without a change in valence state is also considered to be "manufactured" for purposes of
EPCRA Section 313.
Example 3: Typical Otherwise Use Activities
Q When your facility cleans equipment with toluene, you are otherwise using toluene. Your facility also
separates two components of a mixture by dissolving one component in toluene, and subsequently recovers
the toluene from the process for reuse or disposal. Your facility otherwise uses toluene.
Q A covered facility receives a waste containing 12,000 pounds of Chemical A, an EPCRA Section 313
chemical, from off site. The facility treats the waste, destroying Chemical A and in the treatment process
manufactures 10,500 pounds of Chemical B, another EPCRA Section 313 chemical. Chemical B is disposed
on site. Since the waste containing chemical A was received from off site for the purpose of waste
management, the amount of Chemical A must be included in the otherwise use threshold determination
for Chemical A. The otherwise use threshold is 10,000 pounds and since the amount of Chemical A exceeds
this threshold, all releases and other waste management activities for Chemical A must be reported.
Chemical B was manufactured in the treatment of a waste received from off site. The facility disposed of
Chemical B on site. Since chemical B was generated from waste received from off site for treatment for
destruction, disposal, or stabilization, the disposal of chemical B is considered to be otherwise used. Thus,
the amount of Chemical B must be considered in the otherwise used threshold determination. Thus, the
reporting threshold for Chemical B has also been exceeded and all releases and other waste management
activities for Chemical B must be reported.
12 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
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 EPCRA
Section 313 chemicals for the purpose of
maintaining motor vehicles operated by the
facility; or
Q Otherwise use of EPCRA Section 313 chemicals
contained in intake water (used for processing
or non-contact cooling) or in intake air (used
either as compressed air or for combustion).
The exemption of an EPCRA Section 313 chemical
otherwise used 1) as a structural component of the
facility; or 2) in routine janitorial or facility grounds
maintenance; or 3) for personal use by an employee
cannot be taken for activities involving process-related
equipment.
Article Exemption. EPCRA Section 313 chemicals
contained in articles that are processed or otherwise used
at a covered facility are exempt from threshold
determinations and release and other waste management
calculations. 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 EPCRA Section 313 chemical
present in the article. If the EPCRA Section 313 chemical
is manufactured (including imported), processed, or
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 an EPCRA Section 313 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
an EPCRA Section 313 chemical under normal
circumstances of processing or otherwise use of the item
at the facility.
If the processing or otherwise use of all like items
manufactured at a facility results in a total release of 0.5
pound or less of an EPCRA Section 313 chemical in a
reporting year to any environmental 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.
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. EPCRA Section
313 chemicals processed into articles produced at a
facility must be factored into threshold determinations
and release and waste management calculations.
If, in the course 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
during 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 that are recognizable as the article would
not change the original dimensions as long as the
diameter 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 is not totally changed.
An important aspect of the article exemption is what
constitutes a release of an EPCRA Section 313 chemical.
Any processing or otherwise use of an article that results
in a release to the environment (of more than 0.5 pounds)
negates the exemption. Cutting, grinding, melting, or
other processing of a manufactured item could result in
a release of an EPCRA Section 313 chemical during
normal conditions of processing or otherwise use and
therefore, negate the exemption as an article. Scrap
pieces that are recognizable as an article do not constitute
a release.
De Minimis Exemption. The de minimis exemption
allows facilities to disregard certain minimal
concentrations of chemicals in mixtures or other trade
name products they process or otherwise use when
making threshold determinations and release and other
Toxics Release Inventory Reporting Forms and Instructions 13
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Example 4: Article Exemption
Q 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.
Q 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
eight-foot piece of wire is broken into two four-foot pieces of wire, without releasing any EPCRA Section
313 chemicals. Each four-foot piece is identifiable as a piece of wire; therefore, the article status for these
pieces of wire remains intact.
Q EPCRA Section 313 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.
waste management calculations. The de minimis
exemption does not apply to the manufacture of an
EPCRA Section 313 chemical except if that EPCRA
Section 313 chemical is manufactured as an impurity
and remains in the product distributed in commerce,
or if the EPCRA Section 313 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 an EPCRA Section 313 chemical, the
owner/operator should consider only the
concentration of the EPCRA Section 313 chemical in
mixtures and other trade name products in process
streams in which the EPCRA Section 313 chemical is
undergoing a reportable activity. If the EPCRA Section
313 chemical in a process stream is manufactured as an
impurify, imported, processed, or otherwise used and
is below the appropriate de minimis concentration level,
then the quantity of the EPCRA Section 313 chemical
in that process stream does not have to be applied to
threshold determinations nor included in release or
other waste management determinations. If an EPCRA
Section 313 chemical in a process stream is below the
appropriate de minimis level, all releases and other
waste management activities associated with the
EPCRA Section 313 chemical in that stream are exempt
from EPCRA Section 313 reporting. It is possible to
meet an activity (e.g., processing) threshold for an
EPCRA Section 313 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
other trade name products containing the EPCRA
Section 313 chemical below the de minimis level.
Once an EPCRA Section 313 chemical concentration is
above the appropriate de minimis level in the process
stream, threshold determinations and release and
other waste management calculations 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 an EPCRA Section 313 chemical in a
mixture or other trade name product above de minimis
is brought on site, the de minimis exemption never
applies.
De minimis levels for EPCRA Section 313 chemicals and
chemical categories are set at concentration levels of
either at 1% or 0.1%. The 0.1% de minimis levels are
dictated by determinations 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 indicates
that the chemical is a carcinogen or potential
carcinogen, the reporting facility may disregard levels
of the chemical below the 0.1% de minimis
concentration provided that the other criteria for the de
minimis exemption are 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.
14 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Renort
De Minimis Application to the Processing or
Otherwise Use of a Mixture
The de minimis exemption applies only to the
processing or otherwise use, of an EPCRA Section 313
chemical in a mixture. Threshold determinations and
release and other waste management calculations
begin at the point where the chemical exceeds de
minimis. If an EPCRA Section 313 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, release and
other waste management reporting, or supplier
notification requirements. The exemption will apply as
long as the mixture containing de minimis amounts of
an EPCRA Section 313 chemical never goes above the
de minimis limit. Provided below are two examples in
which a manufacturing activity would qualify for the
de minimis exemption.
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 an EPCRA Section 313 chemical.
The de minimis exemption may apply to mixtures and
other trade name products containing EPCRA Section
313 chemicals that are imported into the United States.
Another exception applies to EPCRA Section 313
chemicals 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 an EPCRA
Section 313 chemical that is manufactured in a
wastestream must be considered toward threshold
determinations and release and other waste
management calculations and accounted for on Form
R.
The de minimis exemption also does not apply to
situations where the manufactured chemical is
released of transferred to wastestreams and thereby
diluted to below the de minimis level.
Example 5: De Minimis Applications to Process and Otherwise Use Scenarios
~ ^ i r ' ' *• !"~"=_ s
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.
Increasing Concentration to Above De Minimis Levels During Processing * /
A manufacturing facility receives toluene that contains less than the de-)ninimis concentration of chlorobenzene.
Through distillation, the chlorobenzene content in process streatas-is increased over ih'e de minimis concentration
of 1 percent. From the point at which the chlorobenzene concentration exceeds 1 percent in process streams, the
amount present must be factoredinto threshold determMations and release^andother waste managementestimates.
The facility does not need to consider the amount of chlorobenzene in the'raw material, i.e., whenbelqw 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. ^
l» * *" "• fy "* t/S / s* %>f " •> , "1
- / " "->•> , ^
Fluctuating Concentration During Processing ' *-"„,.
_ - , * " f s, ^ S ~* J» /
\ * ' ~* „ «,**',>
A manufacturer produces antjnk product that contains toluene;, an EfCRA Section 313''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 musf consider the
chemical toward threshold determinations from the point at which it first exceeds the de m/m'm/s limit. Once the
de min/misjimit has been crossed the exemption cannot be taken.,.
Toxics Release Inventory Reporting Forms and Instructions 15
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Example 6: Concentration Ranges Straddling the De Miaimis Value
Q A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25% manganese. Manganese is
eligible for the 1 % de minimis concentration exemption. The amount of rnixture subject to reporting is the quantity
containing manganese above the de minimis concentration:
(8,000,000) x (1.25% - 0.99%) * (1.25% - 0.25%)
The average concentration of manganese that is not exempt (above the de minimis) is:
(1.25% +1.00%) -s- (2)
(8.000,000) x (1.25%-0.99%)
(1.25%-0.25%)
(2)
^ •
Therefore, the amount of manganese that is subject to threshold determination and release and other waste
management estimates is:
s 23,400 pounds manganese (which is below the processing threshold) ,
In this scenario, because the facility's information pertaining to manganese was available to two decimal places,
0.99 was used to determine the amount below the cfe minimis concentrations. If the information was available to
one decimal place, 0.9 should be used, as in the scenario below.
Q As in the previous example, manganese is present in a mixture, of which 8,000,000 pounds is processed,
The MSDS states the mixture contains 0.2% to 1.2% manganese. The amount of mixture subject to reporting (above
cfe minimis) is: . ,
(8,000,000) x (1.2% - 0.9%) + (1.2% - 0.2%)
The average concentration of manganese that is not exempt (above de minimis) is:
(1.2% +1.0%)* (2)
Therefore, the amount of manganese that is subject to threshold determinations and release and other waste
management estimates is:
(8,000,000) x q.2%-0.9%)
0-2**1-0*)] - 26,400 pounds
(2)
'• 26,400 pounds manganese (which is above the processing threshold)
16 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Example 7: De Minimis Application in the Coincidental Manufacture in a Mixture
Coincidental Mann factore as afroduct Impurity , * *
Toluene-2,4-diisqcyanate reacts with trace amounts of water to form trace quantities of 2,4-diaminotoluehe. The
resulting product contains 99 percent toluene-2,^-dnsocyanate 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 concentration of 2,4-diaminotoluehe is below its de minimis concentration of 01 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 operatioru
Coincidental Manufacture as a Cqmmercial'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
90 percent concentration is sold as a byproduct. Chloroform is subject to a 0.1%\(100dppm) de minimiflevel. Any
amount of chloroform manufactured and separated as byproduct must be included in threshold determinations
because the de minimis exemption does not apply to manufacJure 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 tetrachloride as an impurity. Because .the concentration of chloroform
remaining in the carbon tetrachloride is below the de minimis level, this quantity of chloroform is exempt from
threshold determinations, release and other waste management reporting, and supplier notification.,
Coincidental Manufacture as a Waste Byproduct
A small amount of formaldehyde is manufactured as, a .reaction byproduct during the production of phthalic
anhydride. The formaldehydes separated from the phthalic anhydride as a waste gas and burned, leaving no
formaldehyde 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 formaldehyde
were present below the de minimis level in the process stream where it was manufactured or in the wastestream
to which it was separated, s '
Laboratory Activities Exemption
Laboratory Activities: EPCRA Section 313 chemicals that
are manufactured, processed, or otherwise used in
laboratory activities at a covered facility under the direct
supervision of a technically qualified individual do not
have to be considered for threshold determinations and
release and other waste management calculations.
However, pilot plant scale and specialty chemical
production do not qualify for this laboratory activities
exemption, nor do the use of EPCRA Section 313
chemicals for laboratory support activities, such as the
use chemicals for equipment maintenance.
Coal Extraction Activities Exemption
If an EPCRA Section 313 chemical is manufactured,
processed, or otherwise used in extraction by facilities in
SIC Code 12, a person is not required to consider the
quantity of the EPCRA Section 313 chemical so
manufactured, processed, or otherwise used when
considering threshold determinations and release and
other waste management calculations. Reclamation
activities occurring simultaneously with coal extraction
activities (e.g., cast blasting) are included in the
exemption. However, otherwise use of ash, waste rock,
Example 8:, Extraction Exemption for Coal Mining
Facilities
Many materials containing EPCRA section- 313
chemicals may be used or otherwise managed during
coal, mining extraction activities. Included among
theseafe explosives for blasting operations, solvents,
lubricants, and fuels for extraction related-equipment
maintenance and use, as well as overburden and
mineral deposits. The EPCRA section 313 chemicals
contained in these materials are exempt "from
threshold determinations and release and other waste
management calculation^ when manufactured,
processed, or otherwise used during extraction
activities at coal mines.
Toxics Release Inventory Reporting Forms and Instructions 17
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Facility Eligibility Determination [or Submitting an EPCRA Section 313 Report
or fertilizer for reclamation purposes are not considered
part of extraction; non-exempt amounts of Section 313
chemicals contained in these materials must be
considered toward threshold determinations and release
and other waste management calculations.
Metal Mining Overburden Exemption
If an EPCRA Section 313 chemical that is a constituent of
overburden is manufactured, processed or otherwise
used by facilities in SIC Code 10, a person is not required
to consider the quantity of the EPCRA Section 313
chemical so manufactured, processed, or otherwise used
when considering threshold determinations and release
and other waste management calculations.
For purposes of EPCRA section 313 reporting,
overburden is the unconsolidated material that overlies
a deposit of useful material or ore. It does not include
any portion of the ore or waste rock.
B.4 Threshold Determinations
Section 313 reporting is required if threshold quantities
are exceeded. Separate thresholds apply to the amount of
the EPCRA Section 313 chemical that is manufactured,
processed, or otherwise used.
You must submit a report for any EPCRA Section 313
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 an EPCRA
Section 313 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
Section 313 reporting threshold, compare quantities of
EPCRA Section 313 chemicals that you manufacture,
process, or otherwise 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 EPCRA Section
313 chemical or chemical category. Base your threshold
determination for EPCRA Section 313 chemicals with
qualifiers only on the quantity of the EPCRA Section 313
chemical satisfying the qualifier.
Use of the worksheet is divided into three steps:
Step 1 allows you to record the gross amount of the
EPCRA Section 313 chemical or chemical category
involved in activities throughout the facility. Pure forms
as well as the amounts of the EPCRA Section 313
chemical or chemical category present in mixtures or
other trade name products must be considered. The
types of activity (i.e., manufacturing, processing, or
otherwise using) for which the EPCRA Section 313
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 EPCRA Section 313
chemical or chemical category manufactured (including
imported), processed, or otherwise used.
Step 2 allows you to identify uses of the EPCRA Section
313 chemical or chemical category that were included in
Step 1 but are exempt under Section 313. Do not include
in Step 2 exempt quantities of the EPCRA Section 313
chemical not included in the calculations in Step 1. For
example, if Freon contained in the building's air
conditioners was not reported in Step 1, you would not
include the amount as exempt in Step 2. Step 2 is
intended for use when a quantity or use of the EPCRA
Section 313 chemical is exempt while other quantities
require reporting. Note the type of exemption for future
reference. Also identify, if applicable, the fraction or
percentage of the EPCRA Section 313 chemical present
that is exempt. Add the amounts in each activity to
obtain a subtotal for exempted amounts of the EPCRA
Section 313 chemical or chemical categories at the facility.
Step 3 involves subtracting the result of Step 2 from the
results of Step 1 for each activity. Compare this net sum
to the applicable activity threshold. If the threshold is
met or exceeded for any of the three activities, a facility
must submit a Form R for that EPCRA Section 313
chemical or chemical category. Do not sum quantities of
the EPCRA Section 313 chemical that are manufactured,
processed, and otherwise used at your facility, because
each of these activities requires a separate threshold
18 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
determination. For example, if in a calendar year you
processed 20,000 pounds of a chemical and you
otherwise used 6,000 pounds of that same EPCRA
Section 313 chemical, your facility has not met or
exceeded any applicable threshold and thus is not
required to report for that chemical.
This worksheet should be retained to document your
determination for reporting or not reporting, but should
not be submitted with the report.
You must submit a report if you exceed any threshold for
any EPCRA Section 313 chemical or chemical category.
For example, if your facility processes 22,000 pounds of
an EPCRA Section 313 chemical and also otherwise uses
16,000 pounds of that same EPCRA Section 313 chemical,
it has exceeded the otherwise use threshold (10,000
pounds) and your facility must report even though it did
not exceed the process threshold. However, in preparing
your reports, you must consider all non-exempted
activities and all releases and other waste management
quantities of the EPCRA Section 313 chemical from your
facility, not just releases and other waste management
quantities from the otherwise use activity.
Also note that threshold determinations are based upon
the actual amounts of an EPCRA Section 313 chemical
manufactured, processed, or otherwise used over the
course of the calendar year. The threshold determination
may not relate to the amount of an EPCRA Section 313
chemical brought on site during the calendar year. For
example, if a stockpile of 100,000 pounds of an EPCRA
Section 313 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 determination,
not the entire 100,000 pounds of the stockpile.
B.4.b. Threshold Determinations for On-Site
Reuse Operations.
Threshold determinations of EPCRA Section 313
chemicals that are reused at the facility are based only on
the amount of the EPCRA Section 313 chemical mat is
added during the year, not the total volume in the
system. For example, a facility operates a refrigeration
unit that contains 15,000 pounds of anhydrous ammonia
at the beginning of the year. The system is charged with
2,000 pounds of anhydrous ammonia during the year.
The facility has therefore "otherwise used" only 2,000
pounds of the EPCRA Section 313 chemical and is not
required to report (unless there are other "otherwise use"
activities of ammonia, that 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 EPCRA Section 313 chemicals
"recycled" or "reused" off site and returned to a facility.
Such EPCRA Section 313 chemicals returned to a facility
are treated as the equivalent of newly purchased material
for purposes of Section 313 threshold determinations.
B.4.c. Threshold Determinations for
Ammonia
The listing for ammonia includes the modifier "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". 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 quantities, 100 percent of anhydrous ammonia
is included but only 10 percent of total aqueous ammonia
is included. If any ammonia evaporates from aqueous
ammonia solutions, 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
percent of the total aqueous ammonia is counted towards
threshold. If there are any evaporative losses of
anhydrous ammonia, 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.
B.4.d. Threshold Determinations for
Chemical Categories
A number of chemical compound categories are subject
to reporting. See Table II for a listing of these EPCRA
Section 313 chemical categories. When reporting for one
of these EPCRA Section 313 chemical 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 include
in these threshold determinations for a category any
chemicals that are also specifically EPCRA Section 313
chemicals (see Table II) or specific EPCRA Section 313
chemicals that have been deleted from the category (e.g.,
a class of copper phthalocyanine compounds has been
Toxics Release Inventory Reporting Forms and Instructions 19
-------
deleted from the copper compounds category).
Specifically EPCRA Section 313 chemicals are subject to
their own, individual threshold determination.
Organic Compounds
For the organic compound categories, you are required
to account for the entire weight of all compounds
within a specific compound category (e.g., glycol ethers)
at the facility for BOTH the theshold determination and
release and other waste management estimates.
Metal-Containing Compounds
Threshold determinations for metal-containing
compounds 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
determinations for both because they are separately listed
EPCRA Section 313 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
compounds. Apply the total weight of the lead chromate
to the threshold determinations for both lead compounds
and chromium compounds. (Note: Only the amount of
each parent metal released or otherwise managed as
waste (not the amount of the compound, would be
reported on the appropriate sections of both Form Rs. See
B.5.)
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 compound 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.e. Mixtures and Other Trade Name
Products
EPCRA Section 313 chemicals contained in mixtures and
other trade name products must be factored into
threshold determinations and release and other waste
management calculations.
If your facility processed or otherwise used mixtures or
other trade name products during the calendar year, you
are required to use the best information available to
determine whether the components of a mixture are
above the de minimis concentration and, therefore, must
be included in threshold determinations and release and
other waste management calculations. If you know that
a mixture or other trade name product contains a specific
EPCRA Section 313 chemical, combine the amount of the
EPCRA Section 313 chemical in the mixture or other
trade name product with other amounts of the same
EPCRA Section 313 chemical processed or otherwise
used at your facility for threshold determinations and
release and other waste management calculations. If you
know that a mixture contains an EPCRA Section 313
chemical but no concentration information is provided by
the supplier, you do not have to consider the amount of
the EPCRA Section 313 chemical present in that mixture
for purposes of threshold determinations and release and
other waste management calculations.
Observe the following guidelines in estimating
concentrations of EPCRA Section 313 chemicals in
mixtures when only limited information is available:
Q If you know the lower and upper bound
concentrations of an EPCRA Section 313 chemical in
a mixture, use the midpoint of these two
concentrations for threshold determinations.
Q If you know only the lower bound concentration,
you should subtract out the percentages of any other
known components to determine a reasonable upper
bound concentration, and then determine a
midpoint.
Q If you have no information other than the lower
bound concentration, calculate a midpoint assuming
an upper bound concentration of 100 percent.
20 Toxics Release Inventory Reporting Forms and Instructions
-------
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Facility Eligibility Determination for Submitting an EPCRA Section 313 Report
Q If you only know the upper bound concentration,
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Q In cases where you only have a concentration range
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extremes.
B.5
Release and Other Waste
Management Determinations for
Metals, Metal Compounds, and
Nitrate Compounds
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
management determinations, only the parent metal
portion of the metal compound must be considered.
Remember that for metal compounds that consist of more
than one metal, release and other waste management
reporting must be made for each metal, provided that the
appropriate thresholds 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 management
quantities for the metal compound categories. Therefore,
if thresholds are separately exceeded for the "parent"
metal and its compounds, 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
"parent" metal and metal portion of the related metal
compounds. For example, you exceed thresholds 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 portion of the chromium compounds released
or otherwise managed as waste. When filing one
combined Form R for an EPCRA Section 313 metal and
metal compound category, facilities should identify the
chemical reported as the metal compound category name
and code in Section 1 of the Form R. Note that this does
not apply to the Form A. See the section in these
instructions on the Form A.
Nitrate Compounds (water dissociable; reportable 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 nitrate portion of
the compound must be considered.
22 Toxics Release Inventory Reporting Forms and Instructions
-------
Facility Eligibility Determination for Submitting an EPCRA Section 313Reoort
-Example 9: Mixture and Other Trade Name Products
./. * ^ - rt~1""^^ >
Scenario #1: Your facility otherwise uses 12,'000 founds of an industrial solvent (Solvent X) fo?equipmentcleaning.
.The Material Safety Data Sheet (MSDS) for the solvent indicates that itconteins at least 50 percent methyl ethyl
ketone (MEK), an EPCRA Section §13 chemical; however, it also'states'tihat theisolyei^t contains 20 percent non-
hazardous surfactants. This is the only MEK-cpntaining chemical'used at the facility. •; ~ "
•s j !y *"•>. " ~* 1 y ' ™ _J
Follow these steps to determine if the quantity of .pie EPCRA Section 313 chemical in solvent X exceeds the
threshold for otherwise use. " " Ily * " „ - '' -~ ' -
1) Determine a reasonable maximum concentration for the EPCRA Section 313' chemical by subtracting out
the non-hazardous surfactants (i,e., 10Q%~20% —$Q%), '\, . "• '
j^ i > ^B '
2) Determine the midpoint between thejcnqwn minimum (50%) and the reasonable maximum calculated
- - above (i.e., (80%,-t-50%)/2'= 65%). " - - '.
> N S , "~ '~ f- ' I
3) Multiply total weight of Solvent X other wise used by 65 percent (Os65). " "
112/000poundsx0.65 ='7,800pounds, <" ' ^ " .''",.'-.
4) Because the total amount of MEK otherwise used at the facility was less than the 10,000-pbund otherwise
use threshold, the facility is hot required to file a FqrmRfor MEK. ,
Scenario #2: Your facility otherwise used 15,000 pounds of Solvent-Y to clean printed circuit boards. The MSDS
for the solventlists only that Solvent Y contains at least 80 percent- of an EPCRA Section 313 chemical that is only
identified as chlorinated hydrocarbons. ' , - - " ' "-
"* •" f ,,$ ~ i
-------
C. Instructions for Completing EPA Form R
Part I. Facility Identification
Information
Section 1. Reporting Year
This is the calendar year to which the reported
information applies, not the year in which you are
submitting the report. Information for the 1998 reporting
year must be submitted on or before July 1,1999.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA Section 313
chemical identified on page 2 trade secret?
Answer this question only after you have completed the
rest of the report. The specific identity of the EPCRA
Section 313 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 you manufacture, process, or
otherwise use the EPCRA Section 313 chemical whose
identity is a trade secret. (See page 2 of these instructions
for specific information on trade secrecy claims.) If you
checked "no," proceed to Section 3; do not answer
Section 2.2.
2.2 If "yes" in 2.1, is this copy sanitized or
unsanitized?
Answer this question only after you have completed the
rest of the report. Check "sanitized" if this copy of the
report is the public version that does not contain the
EPCRA Section 313 chemical identity but does contain a
generic name in its place, and you have claimed the
EPCRA Section 313 chemical identify 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
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 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 statement applies to all the information
supplied on the form and should be signed only after the
form has been completed.
Section 4. Facility Identification
4.1 Facility Name, Location, and TRI Facility
Identification Number
Enter the name of your facility (plant site name or
appropriate facility designation), street address, mailing
address, city, county, state, and zip code in the space
provided. Do not use a post office box number as the
street address. The street address provided should be
the location where the EPCRA Section 313 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 information)
on a pre-printed page 1 of the Form R that is attached to
the cover of this Toxic Chemical Release Inventory
Instructions for 1998. Please do not destroy this page 1.
When completing your Form R reports for 1998, 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
required by Form R, insert that information in the
appropriate 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 receive a pre-printed page 1
which contains incorrect information, you may edit the
page.
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
Number, contact the EPCRA Hotline (see page 4). If your
facility has moved, do not enter your TRI facility
identification 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 an EPCRA Section 313 chemical if the facility
meets a reporting threshold for that EPCRA Section 313
chemical. However, if the facility is composed of several
distinct establishments, EPA allows these establishments
to submit separate reports for the EPCRA Section 313
24 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part I of EPA Form R
chemical as long as all releases and other waste
management activities of the EPCRA Section 313
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.
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
establishments in your facility, provided all releases and
other waste management activities and source reduction
activities involving the EPCRA Section 313 chemical from
the entire facility are reported. This allows you the
option of reporting separately on the activities involving
an EPCRA Section 313 chemical at each establishment, or
group of establishments (e.g., part of a covered facility),
rather than submitting a single Form R for that EPCRA
Section 313 chemical for the entire facility. However, if
an establishment or group of establishments does not
manufacture, process, or otherwise use or release or
otherwise manage as waste an EPCRA Section 313
chemical, you do not have to submit a report for that
establishment or group of establishments for that
particular chemical. (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.
However, this person must be familiar with the details of
the report so that he or she can answer questions about
the information provided.
4.4 Public Contact
Enter the name and telephone number (including area
code) of a person who can respond to questions from the
public about the report. If you chcjose 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 Industrial
Classification (SIC) Code for your facility. Table I lists
the SIC Codes within 10 (except 1011,1081, and 1094), 12
(except 1241), 20-39, 4911 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4953 (limited to facilities regulated under the
RCRA Subtitle C, 42 U.S.C. section 6921 et seq.), 5169,
5171, and 7389 (limited to facilities primarily engaged in
solvents recovery services on a contract or fee basis). If
the report covers more than one establishment, enter the
primary 4-digit SIC Code for each establishment starting
with the primary SIC Code for the entire facility. You are
required to enter SIC Codes only for those establishments
within the facility that fall within SIC Codes 10 (except
1011, 1081, and 1094), 12 (except 1241), 20-39, 4911
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4939 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4953 (limited to
facilities regulated under the RCRA Subtitle C, 42 U.S.C.
section 6921 et seq.), 5169, 5171, and 7389 (limited to
facilities primarily engaged in solvents recovery services
on a contract or fee basis). If you do not know your SIC
Code, consult the 1987 SIC Manual.
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 upcoming
Federal Register notice. This upcoming change does
NOT affect the 1998 EPCRA Section 313 reporting.
Toxics Release Inventory Reporting Forms and Instructions 25
-------
Instructions for Completing Part I of EPA Form R
4.6 Latitude and Longitude
Enter the latitudinal and longitudinal coordinates of your
facility. Sources of these data include EPA permits (e.g.,
NPDES permits), county property records, facility
blueprints, and site plans. Instructions on how to
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
measurements when determining latitude and longitude.
As with any other data field, missing, suspect, or
incorrect data may generate a Notice of Technical Error
to be issued to the facility. (See Appendix C: Common
Errors in Completing Form R Reports).
4.7 Dun and Bradstreet Number
Enter the nine-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 D & B 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 D & B numbers, enter
those numbers in Part I, section 4.7.
4.8 EPA Identification Number
The EPA I.D. Number is a 12-character number assigned
to facilities covered by hazardous waste regulations
under the Resource Conservation and Recovery Act
(RCRA). Facilities not covered by RCRA are not likely to
have an assigned I.D. Number. If your facility is not
required to have an I.D. Number, enter not applicable,
NA, in box (a). If your facility has been assigned EPA
Identification Numbers, you must enter those numbers in
the spaces provided in Section 4.8.
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 EPCRA Section 313 chemical being reported. This
nine-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 EPCRA Section 313 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 Section 4.10a. You are only required
to provide the UIC number for wells that receive the
EPCRA Section 313 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.
5.1 Name of Parent Company
Enter the name of the corporation or other business
entity that is your ultimate U.S. parent company. If your
facility has no parent company, check the NA box.
5.2 Parent Company's Dun & Bradstreet Number
Enter the D & B number for your ultimate U.S. 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 D & B number,
check the NA box.
26 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
Part II. Chemical Specific
Information
In Part II, you are to report on:
Q
Q
The EPCRA Section 313 chemical being reported;
The general uses and activities involving the EPCRA
Section 313 chemical at your facility;
On-site releases of the EPCRA Section 313 chemical
from the facility to air, water, and land;
Quantities of the EPCRA Section 313 chemical
transferred to off-site locations;
Information for on-site and off-site disposal,
treatment, energy recovery, and recycling of the
EPCRA Section 313 chemical; and
Source reduction activities.
Section 1. EPCRA Section 313 Chemical
Identity
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS) registry
number in Section 1.1 exactly as it appears in Table fl of
these instructions for the chemical being reported. CAS
numbers are cross-referenced with an alphabetical list of
chemical names in Table II. If you are reporting one of
the EPCRA Section 313 chemical categories in Table II
(e.g., chromium compounds), enter the applicable
category code in the CAS number space. EPCRA Section
313 chemical category codes are listed below and can also
be found in Table n, c. Chemical Categories.
EPCRA Section 313 Chemical Category Codes
N010 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
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 (water dissociable,
reportable only in aqueous solution)
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes (CIO to C13)
N590 Polycyclic aromatic compounds (PACs)
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.
Example 10: Mixture Containing Unidentified
EPCRA Section 313 Chemical
Your facility uses 20,000 pounds ofa solvent thatyour
supplierhastpldy6ucontain&80percent"chl6rinated
aromatic/' their generic name for an EPCRA Section
313 chemical subject to reporting under Section 313.
You, therefore, know that you have used 16,000
poundsof some EPCRASection313 chemical and that
exceeds the "otherwise use" threshold. You would
file,, a Form R and enter the name "chlorinated
aromatic" in the space provided in Part n, Section 2.
1.2 EPCRA Section 313 Chemical or Chemical
Category Name
Enter the name of the EPCRA Section 313 chemical or
chemical category exactly as it appears in Table n. If the
EPCRA Section 313 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 EPCRA Section 313 chemical identify 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 n, such as individual members of a reportable
EPCRA Section 313 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.
Toxics Release Inventory Reporting Forms and Instructions 27
-------
Instructions for Completing Part II of EPA Form R
If you are making a trade secret claim, you must report
the specific EPCRA Section 313 chemical identity on your
unsanitized Form R and unsanitized substantiation form.
Do not report the name of the EPCRA Section 313
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.
EPA requests that the EPCRA Section 313 chemical,
chemical category, or generic name also be placed in the
box marked "Toxic Chemical, 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
EPCRA Section 313 chemical identity of the EPCRA
Section 313 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 EPCRA Section 313
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 Rs, 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 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 EPCRA
Section 313 chemical because it is your supplier who is
claiming the chemical identity a trade secret.
1. You determine that the mixture contains an
EPCRA Section 313 chemical but the only identity
you have for that chemical is a generic name;
2. You know either the specific concentration of that
EPCRA Section 313 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 EPCRA
Section 313 Chemical at the
Facility
Indicate whether the EPCRA Section 313 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 figure 3). You are not required to report on
Form R the quantity manufactured, processed or
otherwise 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. Refer to the definitions of
"manufacture," "process," and "otherwise use" in the
general information section of these instructions or Part
40, Section 372.3 of the Code of Federal Regulations for
additional explanations.
3.1 Manufacture the EPCRA Section 313 Chemical
Persons who manufacture (including import) the EPCRA
Section 313 chemical must check at least one of the
following:
a. Produce - The EPCRA Section 313 chemical is
produced at the facility.
b. Import - The EPCRA Section 313 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.)
2.1
^ • ^t. • ITVT T> -j ju c i- And check at least one of the following:
Generic Chemical Name Provided by Supplier °
Enter the generic chemical name in this section only if
the following three conditions apply:
c.
For on-site use/processing- The EPCRA Section 313
chemical is produced or imported and then further
processed or otherwise used at the same facility. If
28 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
you check this block, you must also check at least one
item in Part II, Section 3.2 or 3.3.
d.
e.
For sale/distribution - The EPCRA Section 313
chemical is produced or imported specifically for
sale or distribution outside the manufacturing
facility.
As a byproduct- The EPCRA Section 313 chemical
is produced coincidentally during the manufacture,
processing, or otherwise use of another chemical
substance or mixture and, following its production,
is separated from that other chemical substance or
mixture. EPCRA Section 313 chemicals produced as
a result of waste management are also considered
byproducts.
f. As an impurity- The EPCRA Section 313 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 other trade name
product with that other chemical.
In summary, if you are a manufacturer of the EPCRA
Section 313 chemical, you must check (a) and/or (b), and
at least one of (c), (d), (e), and (f) in Section 3.1.
3.2 Process the EPCRA Section 313 Chemical
(incorporative activities)
a.
b.
c.
As a reactant - A natural or synthetic EPCRA
Section 313 chemical is used in chemical reactions
for the manufacture of another chemical substance
or of a product. Includes but is not limited to,
feedstocks, raw materials, intermediates, and
initiators.
As a formulation component - An EPCRA Section
313 chemical is added to a product (or product
mixture) prior to further distribution of the product
that acts as a performance enhancer during use of
the product. Examples of EPCRA Section 313
chemicals used in this capacity include, but are not
limited to, additives, dyes, reaction diluents,
initiators, solvents, inhibitors, emulsifiers,
surfactants, lubricants, flame retardants, and
rheological modifiers.
As an article component - An EPCRA Section 313
chemical becomes an integral component of an
article distributed for industrial, trade, or consumer
use. One example is the pigment components of
paint applied to a chair that is sold.
d. Repackaging - this consists of processing or
preparation of an EPCRA Section 313 chemical (or
product mixture) for distribution in commerce in a
different form, state, or quantity. This includes, but
is not limited to, the transfer of material from a bulk
container, such as a tank truck to smaller containers
such as cans or bottles.
Example 11: Activities and Uses of EPCRA Section
313 Chemicals
In the example below, it is assumed that the threshold
quantities lor manufacture/process, or otherwise use
(25,000 pounds, 25,00'b pounds, and 10,000 pounds,
Respectively) havefteen exceeded'and the'reporting of
EPCRA Section 313'chemicals is therefore required.
Your facility mantifactures diazomethane. Fifty
;percentis 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, an
EPCRA .Secttdn 3i3 chemical, both for
sale/distribution as a commeicial product and
for on-site use/processing as a feedstock in the
N^methyl-alpha-naphthyl-amine production
process. Because the diazomethane is a reactant,
, it is also processed. See Figure 3 for how this
information wou|d be reported in Part II, Section
SofFormR. " a
Q Your facility'alsoprocesses alpha-naphthylamine,
' ' as a reactant to '.produce N-methyl-alpha-
naphthylamine, a chemical not on the Section 313
list: - :
3.3 Otherwise Use the EPCRA Section 313 Chemical
(non-incorporative activities)
a. As a chemical processing aid - An EPCRA Section
313 chemical that is added to a reaction mixture to
aid in the manufacture or synthesis of another
chemical substance but is not intended to remain in
or become part of the product or product mixture is
Otherwise used as chemical processing aid.
Examples of such EPCRA Section 313 chemicals
include, but are not limited to, process solvents,
catalysts, inhibitors, initiators, reaction terminators,
and solution buffers.
Toxics Release Inventory Reporting Forms and Instructions 29
-------
Instructions for Completing Part II of EPA Form R
Figure 3
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete
this section if you complete Section 2 below.
CASNumberflmportant Enter only one number exactly as ft appears on the Section 313 list Enter category code if reporting a chemical category.
1.1
334-88-3
Toxic Chemical or Chemical Category Name {Important EnteronlyonenameexacayasitappearsontheSeclion313ist)
1.2
Diazomethane
1.3
Generic Chemical Name (Important: Complete only if Part 1. Section 2.1is 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.)
Generic Chemical Name Provided by SuppBer (Important Maximum of 70 characters, including numbers, fetters, spaces, and punctuation.)
2.1
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: CHECK ALL THAT APPLY.)
3.1
Manufacture the toxic chemical:
3.2
Process the toxic chemical:
3.3
Otherwise use the toxic chemical:
Ef,
Produce b.
Import
If produce or import:
83" c. For on-srte use/processing
Ef d, Forsafe/d&ributfon
CD «. Asabyproduct
CD f. Asanknpurity
0 a. Asareactant
I I b. As a fMmulation component
CD c. As an article component
[D d. Repackaging
a. I I As a chemical processing aid
b. EH As a manufacturing aid
c. CD Anclary or other use
b. As a manufacturing aid - An EPCRA Section 313
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 is otherwise used as a manufacturing aid.
Examples include, but are not limited to, process
lubricants, metalworking fluids, coolants,
refrigerants, and hydraulic fluids.
c. AndUary or other use - An EPCRA Section 313
chemical is used at a facility for purposes other than
aiding chemical processing or manufacturing as
described above is otherwise used as ancillary or
other use. Examples include, but are not limited to,
cleaners, degreasers, lubricants, fuels, EPCRA
Section 313 chemicals used for treating wastes, and
EPCRA Section 313 chemicals used to treat water at
the facility.
Section 4. Maximum Amount of the EPCRA
Section 313 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
EPCRA Section 313 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 EPCRA Section 313 chemical was present at several
locations within your facility, use the maximum total
amount present at the entire facility at any one time.
30 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Weight Range in Pounds
Range Code
01
02
03
04
05
06
07
08
09
10
11
From...
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
To....
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 EPCRA Section 313 chemical present at your facility
was part of a mixture or other trade name product,
determine the maximum quantity of the EPCRA Section
313 chemical present at the facility by calculating the
weight percent of the EPCRA Section 313 chemical only.
Do not include the weight of the entire mixture or other
trade name product. This data may be found in the Tier
II form your facility may have prepared under Section
312 of EPCRA. See Part 40, Section 372.30(b) of the Code
of Federal Regulations for further information on how to
calculate the weight of the EPCRA Section 313 chemical
in the mixture or other trade name product. For EPCRA
Section 313 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 EPCRA Section
313 Chemical Entering Each
Environmental Medium On Site
hi Section 5, you must account for the total aggregate on-
site releases of the EPCRA Section 313 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.
On-site releases to the environment include emissions to
the air, discharges to surface waters, and releases to land
and underground injection wells. If you have 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
an EPCRA Section 313 chemical that are lost due to
natural weathering or corrosion, normal/natural
degradation of a product, or normal migration of an
EPCRA Section 313 chemical from a product. For
example, amounts of an EPCRA Section 313 chemical that
migrate from plastic products in storage do not have to
be counted in estimates of releases of that EPCRA Section
313 chemical from the facility.
All releases of the EPCRA Section 313 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 EPCRA Section 313
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
impoundments and spills; (3) releases from building
ventilation systems; and (4) any other fugitive or non-
point air emissions. Engineering estimates and mass
balance calculations (using purchase records, inventories,
engineering knowledge or process specifications of the
quantity of the EPCRA Section 313 chemical entering
product, hazardous waste manifests, 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 EPCRA Section 313
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 equipment would generally fall in this
category. Monitoring data, engineering estimates, and
mass balance calculations may help you to complete this
section.
5.3 Discharges to Receiving Streams or Water
Bodies
In Section 5.3 you are to enter all the names of the
streams or water bodies to which your facility directly
discharges the EPCRA Section 313 chemical on which
you are reporting. A total of three spaces is provided on
page 2 of Form R. Enter the name of each receiving
stream or surface water body to which the EPCRA
Toxics Release Inventory Reporting Forms and Instructions 31
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Instructions for Completing Part II of EPA Form R
Section 313 chemical being reported is directly
discharged. Report the name of the receiving stream or
water body as it appears on the NPDES permit for the
facility. If the stream is not covered by a permit, enter
the name of the off-site stream or water body by which it
is publicly known. Do not list a series of streams through
which the EPCRA Section 313 chemical flows. Be sure to
include all the receiving streams or water bodies 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 EPCRA Section 313 chemical to surface
water bodies.
Enter the total annual amount of the EPCRA Section 313
chemical released 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 column C below). Do not include
discharges to a POTW or other off-site wastewater
treatment facilities in this section. These off-site transfers
must be reported in Part II, Section 6 of Form R.
Wastewater analyses and flowmeter data may provide
the quantities you will need to complete this section.
Discharges of listed acids (e.g., hydrogen fluoride, nitric
acid, and phosphoric acid) may be reported as zero if the
discharges have been neutralized to pH 6 or above. If
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 Injection On-Site to Class I
Wells
Enter the total amount of the EPCRA Section 313
chemical that was injected into Class I wells at the
facility. Chemical analyses, 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
EPCRA Section 313 chemical into Class I underground
wells.
5.4.2 Underground Injection On Site to Class II-V
Wells
Enter the total amount of the EPCRA Section 313
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 completing this section. Check the Not
Applicable "NA" box in Section 5.4.2 if you do not inject
the reported EPCRA Section 313 chemical into Class II-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).
5.5.1 A RCRA Subtitle C landfills -Enter the total
amount of the EPCRA Section 313 chemical that was
placed in RCRA Subtitle C landfills. Leaks from landfills
need not be reported as a release because the amount of
the EPCRA Section 313 chemical has already been
reported as a release.
5.5.1B Other landfills — Enter the total amount of the
EPCRA Section 313 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 EPCRA Section 313 chemical has already
been reported as a release.
5.5.2 Land treatment/application farming — Land
treatment is a disposal method in which a waste
containing an EPCRA Section 313 chemical is applied
onto or incorporated into soil. While this disposal
method is considered a release to land, any volatilization
of EPCRA Section 313 chemicals into the air occurring
during the disposal operation must be included 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
excavation, or diked area formed primarily of earthen
materials (although some may be lined with man-made
materials), that is designed to hold an accumulation of
liquid wastes or wastes containing free liquids.
Examples of surface impoundments are holding, settling,
storage, and elevation pits; ponds, and lagoons. If the
pit, pond, or lagoon is intended for storage or holding
without discharge, it would be considered to be a surface
impoundment 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
32 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
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 EPCRA Section 313 chemical released to
surface impoundments that are 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 EPCRA Section 313
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 an
EPCRA Section 313 chemical released to land that does
not fit the categories of landfills, land treatment, or
surface impoundment. This other disposal would
include any spills or leaks of EPCRA Section 313
chemicals to land. For example, 2,000 pounds of benzene
leaks from an underground pipeline into the land at a
facility. Because the pipe was only a few feet from the
surface at the erupt point, 30 percent of the benzene
evaporates into the air. The 600 pounds released to the
air would be reported as a fugitive air release (Part II,
Section 5.1) and the remaining 1,400 pounds would be
reported as a release to land, other disposal (Part II,
Section 5.5.4).
Column A: Total Release
Only on-site releases of the EPCRA Section 313 chemical
to the environment 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 EPCRA Section 313 chemical from your
facility for sale or distribution in commerce, or of wastes
to other facilities for disposal, treatment, energy
recovery, or recycling (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, must be included in your estimate of the
quantity released.
Releases of Less Than 1,000 Pounds. For total annual
releases or off-site transfers of an EPCRA Section 313
chemical from the facility of less than 1,000 pounds, the
amount may be reported either as an estimate or by using
the range codes that have been developed. The reporting
range codes to be used are:
Code
A
B
C
Range (pounds)
1-10
11-499
500-999
Do not enter a range code and an estimate in the same
box in column A. Total annual on-site releases of an
EPCRA Section 313 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 pound, you should either
enter the range code "A" for "1-10" or enter "I" in
column A. If the release is equal to or less than 0.5
pound, you may round to zero and enter "0" in column
A.
Note that total annual releases of 0.5 pound 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
equal to or less than 0.5 pound per year, you are not
required to submit a report for that EPCRA Section 313
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 an EPCRA
Section 313 chemical to a particular medium, report
either NA, not applicable, or zero, as appropriate. Report
NA only when there is no possibility a release could have
occurred to a specific media. If a release to a specific
media could have occurred, but either did not occur or
the annual aggregate release was equal to or less than 0.5
pound, 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 zero
release for the EPCRA Section 313 chemical. If the facility
has no underground injection well, "NA" would be
written in Part I, Section 4.10 and checked in Part II,
Section 5.4 .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 need not
be reported to more than two significant figures. This
Toxics Release Inventory Reporting Forms and Instructions 33
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Instructions for Completing Part II of EPA Form R
estimate should be in whole numbers. Do not use
decimal points.
Calculating On-Site Releases. To provide the release
information required in column A in this section, you
must use the best 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 EPCRA Section 313
chemical.
When relevant monitoring data or emission
measurements are not readily available, reasonable
estimates of the amounts released must be made using
published emission factors, material balance calculations,
or engineering 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
quantities or concentrations of any EPCRA Section 313
chemical released into the environment, or of the
frequency of such releases, beyond that 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 EPCRA Section 313 chemical or
chemical category that is released annually to each
environmental medium on site. Include only the quantity
of the EPCRA Section 313 chemical in this estimate. If the
EPCRA Section 313 chemical present at your facility was
part of a mixture or other trade name product, calculate
only the releases of the EPCRA Section 313 chemical, not
the other components of the mixture or other trade name
product. If you are only able to estimate the releases of
the mixture or other trade name product as a whole, you
must assume that the release of the EPCRA Section 313
chemical is proportional to its concentration in the
mixture or other trade name product. See Part 40,
Section 37230(b) of the Code of Federal Regulations for
further information on how to calculate the concentration
and weight of the EPCRA Section 313 chemical in the
mixture or other trade name product.
If you are reporting an EPCRA Section 313 chemical
category listed in Table II of these instructions rather than
a specific EPCRA Section 313 chemical, you combine the
release data for all chemicals in the EPCRA Section 313
chemical category (e.g., all glycol ethers or all
chlorophenols) and report the aggregate amount for that
EPCRA Section 313 chemical in that category separately.
For example, if your facility releases 3,000 pounds per
year of 2-chlorophenol, 4,000 pounds per year of 3-
chlorophenol, and 4,000 pounds per year of 4-
chlorophenol to air as fugitive emissions, you should
report that your facility releases 11,000 pounds per year
of chlorophenols to air as fugitive emissions in Part II,
Section 5.1.
For aqueous ammonia solutions, releases should be
reported based on 10% of total aqueous ammonia.
Ammonia evaporating from aqueous ammonia solutions
is considered to be anhydrous ammonia; therefore, 100%
of the anhydrous ammonia should be reported if it is
released to the environment. For dissociable nitrate
compounds, release estimates should be based on the
weight of the nitrate only.
For metal compound categories (e.g., chromium
compounds), 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.
Column B: Basis of Estimate
For each release estimate, you are required to indicate the
principal method used to determine the amount of
release 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
measurements for the EPCRA Section 313 chemical.
C- Estimate is based on mass balance calculations, such
as calculation of the amount of the EPCRA Section 313
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 volatilization
using published mathematical formulas) or best
engineering judgment. This would include applying an
estimated removal efficiency to a treatment, even if the
composition of the waste before treatment was fully
identified through monitoring data.
34 Toxics Release Inventory Reporting Forms and Instructions
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For example, if 40 percent of stack emissions of the
reported EPCRA Section 313 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 EPCRA
Section 313 chemical being reported, the form should
identify the estimate as based on engineering calculations
or best engineering judgment (O).
If a mass balance calculation yields the flow rate of a
waste, but the quantity of reported EPCRA Section 313
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 EPCRA Section
313 chemical in the waste.
If the concentration of the EPCRA Section 313 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 monitoring 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 EPCRA Section 313
chemical released. Monitoring data should be indicated
as the basis of estimate only if the EPCRA Section 313
chemical concentration is measured in the waste being
released into the environment. Monitoring data should
not be indicated, for example, if the monitoring data
relate to a concentration of the EPCRA Section 313
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 submissions.
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 EPCRA Section 313
chemical in stormwater runoff (including unchanneled
runoff), you must include that quantity of the EPCRA
Section 313 chemical in your water release in column A
and indicate the percentage of the total quantity (by
Instructions for Completing Part II of EPA Form R
weight) of the EPCRA Section 313 chemical contributed
by stormwater in column C (Section 5.3C).
If your facility has monitoring data on the EPCRA Section
313 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
EPCRA Section 313 chemical, enter zero 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 EPCRA Section 313 chemical,
but has submitted chemical-specific monitoring data in
permit applications, 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 rainfall by the land area of the facility and then
multiplying that figure by the runoff coefficient. The
runoff coefficient 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 below)
Description of Land Area
Business
Downtown areas
Neighborhood areas
Industrial
Light areas
Heavy areas
Industrial
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
Toxics Release Inventory Reporting Forms and Instructions 35
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Instructions for Completing Part II of EPA Form R
IMHBBIIMHPBI^^MMBI^^^MH^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^™
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 Cis
of Area i.
runoff coefficient for a specific land use
Section 6. Transfers of the EPCRA Section
313 Chemical in Wastes to Off-
Site Locations
You must report in this section the total annual quantity
of the EPCRA Section 313 chemical in wastes sent to any
off-site facility for the purposes of disposal, treatment,
energy recovery, or recycling. Report the total amount of
the EPCRA Section 313 chemical transferred off-site after
any on-site waste treatment, recycling, or removal is
completed. Report zero for transfers of listed mineral
acids if they have been neutralized 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
reported EPCRA Section 313 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 reported EPCRA Section 313 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 EPCRA Section 313
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
EPCRA Section 313 chemical 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 EPCRA Section 313
chemical in wastewaters to three POTWs. You would
photocopy 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 EPCRA Section 313
chemical to one or more other off-site locations, number
the boxes in section 6.2 as 6.2.1,6.2.2, etc. If you transfer
the EPCRA Section 313 chemical to more than two other
off-site locations, photocopy page 4 of Form R as many
times as necessary and men number the boxes
consecutively for each off-site location. 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 indicating the sequence of those pages.
For example, your facility transfers the reported EPCRA
Section 313 chemical to three other off-site locations. You
would photocopy page 4 once, indicate 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
EPCRA Section 313 chemical transferred to all POTWs
and the basis upon which the estimate was made. In
Section 6.1 .B., enter the name and address for each
POTW to which your facility discharges wastewater
containing the reported EPCRA Section 313 chemical.
If you do not discharge wastewater containing the
reported EPCRA Section 313 chemical to a POTW, enter
not applicable, NA, in the box for the POTW's name in
Section 6.1 .B._.
6.1.A.1 Total Transfers
Enter the total amount, in pounds, of the reported
EPCRA Section 313 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
36 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 12: Stormwater Runoff
Your facility is located in a semi-arid region of the United Stktes that has an annual precipitation (including
snowfall) of 12 inches of rain. (Snowfall should be converted to fhe 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 js 50 percent unimproved area, 10 percent asphaltic
streets, and 40 percent concrete pavement. .
The total stormwater-nmoff from youi facility is therefore calculated as" follows;
Land Use
Unimproved area
Asphaltic streets
Concrete pavement
% TotaiArea
' 50
10 ,
40
Runoff '
Coefficient
"- 0.20
0.85
0:90
Weighted-average runoff coefficient = (50%) x (0.20) \ (10%) x (0.85) + (40%) x (0.90) = 0.545
(Rainfall) x (land area) x (conversion factor) x (runoff coefficient) = stormwater runoff
(1 ft/year) x (1,829,520 ft2) x (7.48 gal/ft3) x (0.545) = 7,458,222 gallons/year ,
Total-stormwater runoff = 7,458,222 gallons/year , '
Your stormwater monitoring data shows thatthe average concentration of zinc in the Stormwater jrunoff 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: '
(7,458,222 gallons stormwater)x(3.785 liters/gallon) = 28,229,370 liters,stormwater
(28,229,370 liters stormwater)x(1.4 mg zinc/liter) x lO'3 g/mg x (1/454) Ib/g = 87 Ib 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 / * '
The percentage of zinc discharge through stormwater reported in section 5.3 column C on jForm is:
87/337x100 = 26% ' : ,
6.1.A.2 Basis of Estimate
You must identify the basis for your estimate of the total
quantity of the reported EPCRA Section 313 chemical in
the wastewater transferred to all POTWs. Enter one of
the following letter codes that applies to the method by
which the largest percentage of the estimate was derived.
M- Estimate is based on monitoring data or
measurements for the EPCRA Section 313 chemical as
transferred to an off-site facility.
C - Estimate is based on mass balance calculations, such
as calculation of the amount of the EPCRA Section 313
chemical in 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 volatilization
using published mathematical formulas) or best
Toxics Release Inventory Reporting Forms and Instructions 37
-------
Instructions for Completing Part II of EPA Form R
engineering judgment. This would include 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 an EPCRA Section 313 chemical to more
than one POTW, you should report the basis of estimate
that was used to determine the largest percentage of the
EPCRA Section 313 chemical that was transferred.
Example 13: Reporting Metals and Metal
Compounds that are Sent Off Site
A facility manufactures a product containing
elemental lead. Various metal fabrication operations
for the process produce a wastewater stream that
contains some residual lead and off-specification lead
material. The wastewater is collected and sent
directly to a POTW. Periodic monitoring data show
that 500 pounds of lead were transferred to the POTW
in the reporting year. The off-specification products
(containing lead) are collected and sent off site to a
landfill. Sampling analyses of the product combined
with hazardous waste manifests were used to
determine that 1,200 pounds of lead in the off-spec
product were sent to the off-site landfill.
Therefore, the facility should report 500 pounds in
Section 6.1, 1200 pounds in Section 6.2 - M72 and
1,700 pounds in Section 8.1 - Quantify Released Off
Site.
Note that for EPCRA Section 313 chemicals that are
not metals or metal compounds, the quantity sent to
POTWs and to other off-site treatment locations
should be reported in Section 8.7 - Quantity Treated
Off Site.
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 EPCRA Section 313 chemical for the purposes of
disposal, treatment, energy recovery, or recycling. Also
estimate the quantity of the reported EPCRA Section 313
chemical transferred and the basis upon which the
estimate was made. This would include any residual
chemicals in "empty" containers transferred off site. EPA
expects that all containers (bags, totes, drums, tank
trucks, etc.) will have a small amount of residual solids
and/ or liquids. Please see following summary of residue
quantities left in drums and tanks when emptied.
If appropriate, you must report multiple activities for
each off-site location. For example, if your facility sends
a reported EPCRA Section 313 chemical in waste to an
off-site location where some of the EPCRA Section 313
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 EPCRA Section 313
chemical to an off-site location and that off-site location
performs more than four activities on that chemical,
provide the necessary 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 information.
If you do not ship or transfer wastes containing the
reported EPCRA Section 313 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 an EPCRA Section 313 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 classified as hazardous), enter
NA in the box for the off-site location EPA Identification
Number. If you ship or transfer the reported EPCRA
Section 313 chemical in wastes to another country, enter
meFederallnformationProcessingStandards (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 an EPCRA Section 313 chemical.
Country
Argentina
Belgium
Bolivia
Brazil
Canada
Chile
Columbia
Costa Rica
Code
AR
BE
BL
BR
CA
CI
CO
CS
38 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
Cuba
Ecuador
El Salvador
France
Guatemala
Honduras
Ireland
Italy
Mexico
Nicaragua
CU
EC
ES
FR
GT
HO
El
IT
MX
NU
Panama
Paraguay
Peru
Portugal
Spain
Switzerland
United Kingdom
Uruguay
Venezuela
PM
PA
PE
PO
SP
SZ
UK
UY
VE
Summary of Residue Quantities From Pilot-Scale Experimental Study3*
(weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
.Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined
tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
', , , .-'- Material i . -
Kerosene"
1.93 - 3.08
2.48
1.69 - 4.08
2.61
0.244 - 0.472
0.404
0.032 - 0.080
0.054
0.020 - 0.039
0.033
0.031 - 0.042
0.038
0.024-0.049
0.040
Water"
1.84 - 2.61
2.29
2.54-4.67
3.28
0.266 - 0.458
0.403
0.026 - 0.039
0.034
0.016 - 0.024
0.019
0.033 - 0.034
0.034
0.020 - 0.040
0.033
Motor Oil6
1.97-2.23
2.06
1.70 - 3.48
2.30
0.677 - 0.787
0.737
0.328 - 0.368
0.350
0.100 - 0.121
0.111
0.133 - 0.191
0.161
0.112 - 0.134
0.127
Surfactant
Solutionf
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
i-rom Keleases During Cleaning of Equipment." Prepared by PEI Associates, Inc., for the U.S. Environmental Protection Agency,
Office of Pesticides and Toxic Substances, Washington DC, Contract No. 68-02-4248. June 30,1986.
"The values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid materials. At
viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information on this table is not
applicable.
Tor kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
Tor motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm2
Tor surfactanct solution, viscosity = 3 centipoise, surface tension = 31.4 dynes/cm2
Toxics Release Inventory Reporting Forms and Instructions 39
-------
Instructions for Completing Part II of EPA Form R
Example 14: Container Residue
You have determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility purchases
and uses one thousand 55-gallon steel drums that contain a 10% solution of the chemical. Further, it is assumed
that the physical properties of the solution are similar to water. The solution is pumped from the drums directly
into a mixing vessel and the "empty" drums are triple-rinsed with water. The rinse water is indirectly discharged
to a POTW and the cleaned drums are sent to a drum reclaimer.
In this example, it can be assumed that all of the residual solution in the drums was transferred to the rinse water.
Therefore, the quantity transferred to the drum reclaimer should be reported as "zero." The annual quantity of
residual solution that is transferred to the rinse water can be estimated by multiplying the mean weight percent of
residual solution remaining in water from pumping a steel drum by the total annual weight of solution in the drum
(density of solution multiplied by drum volume). If the density is not known, it may be appropriate to use the
density of water (8.34 pounds per gallon):
(2.29%) x (8.34 pounds/gallon) x (55 gallons/drum) * (1,000 drums)
= 10,504 pounds solution
The concentration of the EPCRA Section 313 chemical in the solution is only 10 percent.
(10,504 pounds solution) x (10%) = 1,050 pounds
Therefore, 1,050 pounds of the chemical are transferred to the POTW. ,.^___:_
6.2 Column A: Total Transfers
For each off-site location, enter the total amount, in
pounds, of the EPCRA Section 313 chemical that is
contained in the waste transferred to that location. Do
not enter the total poundage of the waste. If the total
amount transferred is less 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
If you transfer the EPCRA Section 313 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 EPCRA Section
313 chemical associated with each activity. For example,
your facility transfers a total of 15,000 pounds of toluene
to an off-site location that will use 5,000 pounds for the
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 location, 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 management) to one location, continue
reporting of these transfers 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 EPCRA Section 313
chemical is sent to an off-site facility for sequential
activities and the specific quantities associated with each
activity are unknown, 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 EPCRA
Section 313 chemical sent off site, not the ultimate
disposition of the EPCRA Section 313 chemical. For
example, when an EPCRA Section 313 chemical is first
recovered and then treated with the majority of the
EPCRA Section 313 chemical being recovered and only a
fraction subsequently treated, report the appropriate
recycling activity along with the quantity.
6.2 Column B: Basis of Estimate
You must identify the basis for your estimates of the
quantities of the reported EPCRA Section 313 chemical in
waste transferred to each off-site location. Enter one of
the following letter codes that applies to the method by
which the largest percentage of the estimate was derived.
40 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
Figure 4
Hypothetical Secton 6.2 Completed for Two Off-Site Locations
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
^^ ^ Off-Site EPA Identification Number (RCRA No.)
Off-Site Location Name
Street Address
"
"P*»1f»OOj
State
Cu
Ar*mf* \X
CUD^661<3
/aste Services
2461
> Market Street
sville
Zip Code
A. Total Transfers (poundsyyear)
(enter range code or estimate)
1. 5,000
2. 7,500
3. 2,500
4. NA
S C\A & 1 's ^oca^on under a
olWJl facility or parent co
B. Basis of Estimate
(enter code)
i.O
2.C
3.0
4.
County
TT411
1 nil
mp^nyfreP°rtn9 ° YeS S N°
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M5^
2. M20
3. M''2
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 LOCATION
A 7 ^ Off-Site EPA Identification Number (RCRA No.)
Off-Site Location Name
Street Address
City
f~Vitnh"n«
CUU16//2
tkm, Inc.
5432
25 Facility Road
)umfrj
State
T
Zip Code
A. Total Transfers (poundsyyear)
(enter range code or estimate)
1. 12,500
2. NA
3.
4.
OA^AA 1s t003*"00 under ot
5U3UU facility or parent co
B. Basis of Estimate
(enter code)
1. O
2.
3.
4.
County
Burns
mtrol of reporting r— , r^, NQ
mpany
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 purposesof 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 hearing value of the waste.
Toxics Release Inventory Reporting Forms and Instructions 41
-------
Instructions for Completing Part II of EPA Form R
M- Estimate is based on monitoring data or
measurements for the EPCRA Section 313 chemical
as transferred to an off-site facility.
C- Estimate is based on mass balance calculations, such
as calculation of the amount of the EPCRA Section
313 chemical in streams entering and leaving
process equipment.
E- Estimate is based on published emission factors,
such as those relating release quantity to throughput
or equipment type (e.g., air emission factors).
O- Estimate is based on other approaches such as
engineering calculations (e.g., estimating
volatilization using published mathematical
formulas) or best engineering judgment. This would
include applying an estimated removal efficiency to
a waste stream, even if the composition of the
stream before treatment was fully identified through
monitoring data.
6.2 Column C: Type of Waste Management:
Disposal/Treatment/Energy Recovery/Recycling
Enter one of the following M codes to identify the type of
disposal, treatment, energy recovery, or recycling
methods used by the off-site location for the reported
EPCRA Section 313 chemical. You must use more than
one line and code for a single location when distinct
quantities of the reported EPCRA Section 313 chemical
are subject to different waste management activities,
including disposal, treatment, energy recovery, or
recycling. You should use the code that, to the best of
your knowledge, represents the ultimate disposition of
the chemical.
If the EPCRA Section 313 chemical is sent off site for
further direct reuse (e.g., an EPCRA Section 313 chemical
in used solvent that will be used as lubricant at another
facility) and does not undergo a waste management
activity (i.e., release [including disposal], treatment,
energy recovery, or recycling [recovery]) prior to that
reuse, it need not be reported in section 6.2 or section 8.
Incineration vs. Energy Recovery
You must distinguish between incineration, which is
waste treatment, and legitimate energy recovery. For
you to claim that a reported EPCRA Section 313 chemical
sent off-site is used for the purposes of energy recovery
and not for waste treatment, the EPCRA Section 313
chemical must have a significant heating value and must
be combusted in an energy recovery unit such as an
industrial boiler, furnace, or kiln. In a situation where
the reported EPCRA Section 313 chemical is in a waste
that is combusted in an energy recovery unit, but the
EPCRA Section 313 chemical does not have a significant
heating value, e.g., metals CFCs, use code M54,
Incineration/Insignificant Fuel Value, to indicate that the
EPCRA Section 313 chemical was incinerated in an
energy recovery unit but did not contribute to the heating
value of the waste.
Metals and Metal Compounds
Metals and metal compounds will be managed in waste
either by being released (including disposed) or by being
recycled. 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 recycled and NOT the whole metal
compound. 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
codes for transfers of metals and metal compounds for
recycling are M24, metals recovery, M93, waste broker -
recycling, or M26, other reuse/recovery. Applicable
codes for transfers for disposal include M10, M41, M62,
M71, M72, M73, M79, M90, M94, and M99. These codes
are for off-site transfers for further 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 that 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)-
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
M99 Unknown
42 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
Example 15: Calculating Releases andTpther Waste Management Quantities
Your facility disposes of 14,000 pounds of lead chromate (PbCrO JPbO) in an on-site landfill and transfers 16,000
pounds of lead selenite (PJbSeO4) to an off-site land disposal facility. You-would therefore-be submitting three
separate reports on the following: lead compounds, selenium compounds, andchromium compounds. However,
the quantities you would be reporting would be the pounds of "parent" metal being released on site or transferred
off sitefor further waste management All quantities are based on mass balance calculations (See Sections, Column
B for information on Basis of Estimate and Section 6.2, Column C for waste, management cpdes and information
on transfers of EPCRA Section 313 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 (PbCrO JPbO)
Lead (2,Pb atoms) ^
Chromium (1 Cr atom)
Lead chromate is therefore (% by weight)
>", Molecular weight -v 546.37
Atomic weight = 207.2x2 = 414.4
Atomic weight '=, 51.996
(414.4/546.37) = 75.85% lead and
(51.996/546.37) = 9.52% chromium
Lead Selenite (PbSeO)
Lead (1 Pb atom)
Selenium (1 Se atom)
Molecular weight
, Atomic weight
Atomic weight
= , 350.17
-' 207.2
'= 78.96
,'Lead selenite is therefore (% by weight)
\ (207,2/350,17) ;= 59:17% lead and
• ' (78,96/350,17) - 22,55% selenium! ' ,
The total pounds of lead, chromium, and selenium disposed on or off site from your facility are as follows:
T ' - - . "'.'':,. ,?,'' - -' \
Lead ,, . " ,~
Disposal on site:
Transfer off site for disposal:
Chromium
Disposal on site:
Selenium
Transfer off site for disposal:
0,7585 x 14,000 = 10,619-pounds from lead chromate:
0.5917 x 16,000 = '9,467 pounds from lead selenite
Q.i)952 x 14,000 ='1,333 pounds from lead chromate
0.2255 x 16,000 = 3,608, pounds-from lead selenite
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
Recycling
M20 Solvents/Organics Recovery
M24 Metals Recovery
Toxics Release Inventory Reporting Forms and Instructions 43
-------
Instructions for Completing Part II of EPA Form R
M26 Other Reuse or Recovery
M28 Acid Regeneration
M93 Transfer to Waste Broker-Recycling
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 EPCRA Section 313 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 EPCRA Section 313 chemical rather than the waste
stream containing the EPCRA Section 313 chemical.
However, EPCRA Section 313 does require that waste
treatment methods applied on-site to waste streams that
contain the EPCRA Section 313 chemical be reported.
This information is collected in Section 7 A of Form R.
In Section 7A, you must provide the following
information if you treat the reported EPCRA Section 313
chemical on-site:
(a) The general waste stream types containing the
EPCRA Section 313 chemical being reported;
(b) The waste treatment method(s) or sequence used on
all waste streams containing the EPCRA Section 313
chemical;
(c) The range of concentration of the EPCRA Section
313 chemicals in the influent to the waste treatment
method;
(d) The efficiency of each waste treatment method or
waste treatmentsequence in destroying or removing
the EPCRA Section 313 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 EPCRA Section 313 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 EPCRA Section 313 chemical
that is treated. Enter the letter code that corresponds to
the general waste stream type:
A Gaseous (gases, vapors, airborne particulates)
W Wastewater (aqueous waste)
L Liquid waste streams (non-aqueous waste)
S Solid waste streams (including sludges and
slurries)
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
appreciable 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 waste treatment code from the list
below for each on-site waste treatment method used on
a waste stream containing the EPCRA Section 313
chemical, regardless of whether the waste treatment
method actually removes the specific EPCRA Section 313
chemical being 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 EPCRA Section 313
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 treatment. Report waste
treatment methods that apply to the aggregate waste
stream, as well as waste treatment methods that apply to
individual waste streams. If your facility treats various
wastewater streams containing the EPCRA Section 313
chemical in different ways, the different waste treatment
methods must be listed separately.
If your facility has several pieces of equipment
performing 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
44 Toxics Release Inventory Reporting Forms and Instructions
-------
Instructions for Completing Part II of EPA Form R
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
renumber appropriately those waste treatment method
code boxes you used to continue the sequence. For
example, if the general waste stream in box 7A.la had
nine treatment methods applied to it, the ninth method
would be indicated in the first method box for row 7A.2a.
The numeral "1" would be crossed out, and a "9" would
be inserted.
Treatment applied to any other general waste stream
types would then be listed in the next empty row. In the
scenario above, for instance, the second general waste
stream would be reported in row 7A.3a. See Figure 5 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 Aerobic
B21 Anaerobic
B31 Facultative
B99 Other Biological Treatment
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 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)
Toxics Release Inventory Reporting Forms and Instructions 45
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Instructions for Completing Part II of EPA Form R
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
GO! 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
concentration of the EPCRA Section 313 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 EPCRA Section 313
chemical in the waste stream as compared 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 EPCRA Section ,
313 chemical in the influent:
1 s Greater than 10,000 parts per million (1 percent)
2 » 100 parts per million (0.01 percent) to 10,000 parts
per million (1 percent)
3-1 part per million (0.0001 percent) to 100 parts per
million (0.01 percent)
4 = 1 part per billion to 1 part per million
5 s 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 meter, multiply by 0.773 to obtain parts
per million. These conversion factors are for standard
conditions of 0° C (32° F) and 760 mm Hg atmospheric
pressure.
7A Column D: Waste Treatment Efficiency Estimate
In the space provided, enter the number indicating the
percentage of the EPCRA Section 313 chemical removed
from the waste stream through destruction, biological
degradation, chemical conversion, or physical removal.
The waste treatment efficiency (expressed as percent
removal) represents the percentage of the EPCRA Section
313 chemical destroyed or removed (based on amount or
mass), not merely changes in volume or concentration of
the EPCRA Section 313 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 destruction,
degradation, conversion, or removal of the EPCRA
Section 313 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 an EPCRA Section 313
chemical may evaporate, biodegrade, or be physically
removed from the sludge.
Percent removal can be calculated as follows:
x 100, where
I = amount of the EPCRA Section 313 chemical in the
influent waste stream (entering the waste treatment
step or sequence) and
E = amount of the EPCRA Section 313 chemical in the
effluent waste stream (exiting the waste treatment step
or sequence).
Calculate the amount of the EPCRA Section 313 chemical
in the influent waste stream by multiplying the
concentration (by weight) of the EPCRA Section 313
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 efficiency can be
reported as 100 percent if no volatile EPCRA Section 313
chemicals were removed with the water or evaporated
into the air. Percent removal does not apply to
incineration because the waste stream, such as
wastewater or liquids, may not exist in a comparable
46 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
form after waste treatment and the purpose of
incineration as a waste treatment is to destroy the
EPCRA Section 313 chemical by converting it to carbon
dioxide and water or other byproducts. In cases where
the EPCRA Section 313 chemical is incinerated, the
percent efficiency must be based on the amount of the
EPCRA Section 313 chemical destroyed or combusted,
except for metals or metal compounds. In the cases in
which 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
EPCRA Section 313 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 compound. Metals are not
destroyed, only physically removed or chemically
converted from one form into another. The waste
treatment efficiency reported must represent only
physical removal of the parent metal from tihe waste
stream (except for incineration), not the percent chemical
conversion of the metal compound. 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 efficiency of zero.
EPCRA Section 313 chemicals that are strong mineral
acids neutralized to a pH of 6 or above are considered
treated at a 100 percent efficiency.
All data readily available at your facility must be used to
calculate waste treatment efficiency and influent EPCRA
Section 313 chemical concentration. If data are lacking,
estimates must be made using best engineering judgment
or other methods.
7A Column E: Based on Operating Data?
This column requires you to indicate "Yes" or "No" to
whether the waste treatment efficiency estimate is based
on actual operating data. For example, you would check
"Yes" if the estimate is based on monitoring of influent
and effluent wastes under typical operating conditions.
If the efficiency estimate is based on published data for
similar processes or on equipment supplier's literature,
or if you otherwise estimated either the influent or
effluent waste comparison or the flow rate, check "No."
Section 7B On-Site Energy Recovery Processes
In Section 7B, you must indicate the on-site energy
recovery methods used on the reported EPCRA Section
313 chemical. If you do not perform on-site energy
recovery for the reported EPCRA Section 313 chemical,
check the Not Applicable (NA) box at the top of Section
7B.
Only EPCRA Section 313 chemicals that have a significant
heating value and are combusted in an energy recovery
unit such as an industrial furnace, kiln, or boiler, can be
reported as combusted for energy recovery in this
section. If a reported EPCRA Section 313 chemical is
incinerated on site but does not contribute energy to the
process (e.g., chlorofluorocarbons), it must be considered
waste treated on site and reported in Section 7A. Metals
and metal compounds cannot be combusted for energy
recovery and should NOT be reported in this section.
Energy recovery may take place only in an industrial kiln,
furnace, or boiler.
Energy Recovery Codes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
U09 Other Energy Recovery Methods
If your facility uses more than one on-site energy
recovery method for the reported EPCRA Section 313
chemical, list the methods used in descending order
(greatest to least) based on the amount of the EPCRA
Section 313 chemical entering such methods.
Toxics Release In ventory Reporting Forms and Instructions 47
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Instructions for Completing Part II of EPA Form R
Example 16: On-Site Waste Treatment
A process at the facility generates a wastewater>stream containing an EPCRA Section 313 chemical (chemical A).
A second process generates a wastewater stream containing two EPCRA Section 313 chemicals, a metal (chemical
B) and a mineral acid (chemical C). Thresholds for all three chemicals have been exceeded and you are in the
process of completing separate Form Rs for each chemical.
These two wastewater streams are combined and sent to an on-site wastewater treatment system before being
discharged to a POTW. This system consists of an oil/water separator that removes 99% of chemical A; a
neutralization tank in which the pH is adjusted to 7.5, thereby destroying 100% of the mineral acid (chemical C);
and a settling tank where 95% of the metal (chemical B) is removed from the water (and eventually,landfilled off
site).
Section 7A should be completed slightly differently when you file the Form R for each of the chemicals. The table
accompanying this example shows how Section 7A should be completed for each chemical. First, on each Form R
you should identify the iype of waste stream in Section TA.la as wastewater (aqueous waste, code W). Next, on
each Form R you should list the code for each of the treatment steps that is applied to the entire waste stream,
regardless of whether the operation affects the chemical for Which you are completing the Form R (for instance,
the first four blocks of Section 7A.lb of all three Form Rs should show; P19 (liquid phase separation), Cll
(neutralization), Pll (settling/clarification), and N/A (to signify the end of the treatment system). Note that
Section 7A.lb is the only section of the Form R that is not chemical specific. It applies to the entire waste stream
being treated. Section 7A.lc of each Form R should show the concentration of the specific chemical in the influent
to the first step of the process (oil/water separation). For this example, assume chemicals A, B, and C are all
present at concentrations greater than 1 %. Therefore, code "1" should be entered. Section 7A.ld is also chemical
specific. It applies to the efficiency of the entire system in destroying and/ or removing the chemical for which you
are preparing the Form R. You should enter 99% when filing for chemical A, 95% for chemical B, and 100% for
chemical C. Finally, you should report whether the influent concentration and efficiency estimates are based on
operating data for each chemical, as appropriate. •
Chemical A
7A.la
W
7A.lc
7A.ld
99 %
7A.le
Yes
X
No
Chemical B
7A.la
W
7A.lb
3. Pll
6.
7A.lc
7A.ld
95 %
7A.le
Yes
X
No
Chemical C
7A.la
W
7A.lb
3. Pll
6.
7A.lc
7A.ld
100 %
7A.le
Yes
X
No
48 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Note that the quantity-removed and/or destroyed js not reported in Section 7 and that the efficiency reported in
Section7A.ld refers to.the amount'of EPCRA Section 313 chemical destroyed and/or removed from the applicable
waste stream. The amount actually destroyed should be reported in Section 8.6 (quantity treated on site). For
example, when completing the Form R for chemical B you should report "Q", pounds *M Section 8.6 because the
metal has been removed from the wastewater stream, but not actually destroye'd. The quantify of chemical B that
is'ultimately landfilled off site should be reported in Sections 6.2 and 8.1. However, when completing the Form,
R for chemical C you should report the entire quantity inr Section 8.6-because raising the-pH to 7.5 will completely
destroy the mineral acid, , _""",, '. , " :
Example 17: Reporting On-Site Energy Recovery
One waste stream generated by your facility contains,
among other chemicals, toluene and Freort; 113.
Threshold quantities are exceeded for both of these
EPCRA Section 313 chemicals., and you would,
therefore, submit two separate Form R reports. -This
waste stream is sent to an 6n-site industrial furnace
thatusesthe heat generated1 in a thermal hydrocarbon
crackingprocess at your facility. Because toluene has
a significant heat value (17)440 BTIJ/pound) and the
energy is recovered in an industrial furnace, the,code
"U02" would be reported in Section 7B for thjj 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 treatmentstep
(i.e., incineration), in Section 7A, column b. *
Section 7C On-Site Recycling Processes
In Section 7C, you must report the recycling methods
used on the EPCRA Section 313 chemical. If you do not
conduct any on-site recycling of the reported EPCRA
Section 313 chemical, check the Not Applicable (NA) box
at the top of Section 7C.
In this section, use the codes below to report only the
recycling methods in place at your facility that are
applied to the EPCRA Section 313 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 an EPCRA Section 313 chemical, enter the
codes in the space provided in descending order (greatest
to least) of the volume of the reported EPCRA Section
313 chemical recovered by each process. If your facility
uses more than ten separate methods for recycling the
reported EPCRA Section 313 chemical on site, then list
the ten activities that recover the greatest amount of the
EPCRA Section 313 chemical (again, in descending
order).
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 activities and quantities of the EPCRA Section
313 chemicals managed as waste. For all appropriate
questions, report only the quantity, in pounds, of the
reported EPCRA Section 313 chemical itself. Do not
include the weight of water, soil, or other waste
constituents. When reporting on the metal compound
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Instructions for Completing Part II of EPA Form R
categories, report only the amount of the parent metal as
you do when estimating release amounts.
Sections 8.1 through 8.9 must be completed for each
EPCRA Section 313 chemical. Section 8.10 must be
completed only if a source reduction activity was newly
implemented specifically (in whole or in part) for the
reported EPCRA Section 313 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 facility.
Sections 8.1 through 8.7 require reporting of quantities
for the current reporting year, the prior year, and
quantities anticipated in both the first year immediately
following the reporting year and the second year
following 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 for Sections 8.1 through 8.7 must be reported
for the year immediately preceding the reporting year in
column A. For reports due July 1,1999 (reporting year
1998), the prior year is 1997. 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
recovery, treatment, or disposal operating logs or
invoices. New industries can enter NA in Sections 8.1 -
8.7 in column A for reporting year 1998 reporting only
because facilities in these industries were not required to
collect data for reporting year 1997.
Column B: Current Reporting Year
Quantities for Sections 8.1 through 8.7 must be reported
for the current reporting year (1998) in column B.
Columns C and D: Following Year and Second
Following Year
Quantities for Sections 8.1 through 8.7 must be estimated
for 1999 and 2000. EPA expects reasonable future
quantity estimates using a logical basis. Information
available at the facility to estimate quantities of the
chemical expected during these years include planned
source reduction activities, market projections, expected
contracts, anticipated new product lines, company
growth projections, and production capacity figures.
Respondents should take into account protections
available for trade secrets as provided in EPCRA Section
322 (42 USC11042) for the chemical identity.
Relationship to Other Laws
The reporting categories for quantities recycled, used for
energy recovery, treated, and disposed apply to
completing Section 8 of Form R as well as to the rest of
Form R. These categories are to be used only for TRI
reporting. They are not intended for use in determining,
under the Resource Conservation and Recovery Act
(RCRA) Subtitle C regulations, whether a secondary
material is a waste when recycled. These definitions also
do not apply to the information that may be submitted 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 EPCRA Section 313 chemicals reported on Form R
and for hazardous 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 that may include more than one
chemical. For example, a RCRA hazardous waste
Example 18: Reporting Future Estimates
A pharmaceutical manufacturing facility uses an
EPCRA Section 313 chemical in the manufacture of a
prescription drug. During the reporting year (1998),
the company received approval from the Food and
Drug Administration to begin marketing their
product as an over-the-counter drug beginning in
1999. 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 subsequent production of this
drug will increase their use of the reported EPCRA
Section 313 chemical by 30 percent per year for the
two years following the reporting year. The facility
treats the EPCRA Section 313 chemical on site and the
quantity treated is directly proportional to production
activity. The facility thus estimates the total quantity
of the reported EPCRA Section 313 chemical treated
for the following year (1999) by adding 30 percent to
the amount in column B (the amount for the current
reporting year). The second following year (2000)
figure can be calculated by adding an additional 30
percent to the amount reported in column C (the
amount for the following year (1999) projection).
50 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
containing an EPCRA Section 313 chemical is recycled to
recover certain constituents of that waste, but not the
toxic chemical reported under EPCRA section 313. The
EPCRA Section 313 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 EPCRA
Section 313 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.
Section 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 abandonment of
barrels, containers, and other closed receptacles)." This
includes on-site releases in section 5 and off-site releases
(including disposal) in section 6, but excludes quantities
reported in sections 5 and 6 due to remedial actions,
catastrophic events, or non-production related events
(see the discussion on section 8.8.)
Metals and metal compounds reported, 1) in section 6.2
as sent off site for stabilization/solidification (M41-
metals) or wastewater treatment (excluding POTWs)
(M62-metals) and/or, 2) in section 6.1 - discharges to
POTWs should be reported in section 8.1. These
quantities should NOT be reported in section 8.7 because
the metals are ultimately disposed.
§ 8.1 = § 5 + § 6.2 (disposal) + § 6.1 (metals and metal
compounds only) - §8.8 (on-site release or off-site
disposal due to catastrophic events)1
Sections 8.2 and 8.3. These relate to a EPCRA Section
313 chemical or a mixture containing an EPCRA Section
313 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
'§8.8 includes quantities of toxic chemical released on site or
managed as waste off site due to remedial actions, catastrophic events,
or one-time events not associated with the production processes.
off-site energy recovery is the combustion of a waste
containing an EPCRA Section 313 chemical when:
(a) The combustion unit is integrated into an energy
recovery system (i.e., industrial furnaces, industrial
kilns, and boilers); and
(b) The EPCRA Section 313 chemical is combustible and
has a significant heating value (e.g., 5000 BTU)
§ 8.2 is reported in section 8 only
§ 8.3 = § 6.2 (energy recovery) - §8.8 (off-site energy
recovery due to catastrophic events)1
Sections 8.4 and 8.5. These relate to an EPCRA Section
313 chemical in a waste that is recycled on site or is sent
off site for recycling.
§ 8.4 is reported in section 8 only
§ 8.5 = § 6.2 (recycling) - § 8.8 (off-site recycling due to
catastrophic events)1
Section 8.6 and 8.7. These relate to an EPCRA Section
313 chemical (except for metals and metal compounds) or
a mixture containing an EPCRA Section 313 chemical that
is treated on site or is sent to a POTW or other off-site
location for waste treatment.
§ 8.6 is reported in section 8 only
§ 8.7 = § 6.1 (excluding metal/metal compounds) +§ 6.2
(treatment) - § 8.8 (off-site treatment due to catastrophic
events)1
An EPCRA Section 313 chemical or an EPCRA Section
313 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
activities.
Do not include in Sections 8.1 through 8.7 any quantities
of the EPCRA Section 313 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 a drunk driver crashing his/her car into
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Instructions for Completing Part II of EPA Form R
a drum storage area. 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.
(See Example 20: Quantity released to the Environment
as a Result of Remedial Actions, Catastrophic Events,
or One-Time Events Not Associated with Production
Processes)
Example 19: Avoiding Double-Counting
Quantities in Sections 8.1 through 8.7
For example, 5,000 pounds of EPCRA Section 313
chemical enters a treatment operation. Three
thousand pounds of the EPCRA Section 313
chemical exits the treatment operation and then
enters a recycling operation. Five hundred pounds
of the EPCRA Section 313 chemical are in residues
from the recycling operation that is subsequently
sent off site for disposal. These quantities would be
reported as follows in Section 8:
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
recycling)
To report that 5,000pounds were treated, 3,000pounds
were recycled, and that 500 pounds were sent off site for
disposal would result in over-counting the quantities of
EPCRA Section 313 chemical recycled, treated, and
disposed by 3,500 pounds.
8.8 Quantity Released to the Environment as a
Result of Remedial Actions, Cata-strophic
Events, or One-Time Events Not Associated with
Production Processes
In Section 8.8, enter the total quantity of EPCRA Section
313 chemical released directly into the environment or
sent off site for recycling, energy recovery, treatment, or
disposal during the reporting year due to any of the
following events:
(1) remedial actions;
(2) catastrophic events such as earthquakes, fires, or
floods; or
(3) one-time events not associated with normal or
routine production processes.
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
example, spills that occur as a routine part of production
operations and could be reduced or eliminated by
improved handling, loading, or unloadingprocedures 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 an EPCRA Section 313 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 EPCRA Section 313 chemical
generated from a remedial action (e.g., RCRA corrective
action) to clean up the environmental contamination
resulting from past practices should be reported in
Section 8.8 because they cannot currently be addressed
by source reduction methods. A remedial action for
purposes of Section 8.8 is a waste cleanup (including
RCRA and CERCA operations) within the facility
boundary. Most remedial activities involve collecting
and treating contaminated material.
Also, releases caused by catastrophic events are to be
incorporated into the quantity reported in Section 8.8.
Such releases may be caused by natural disasters (e.g.,
hurricanes and earthquakes) or by large-scale accidents
(e.g., fires and explosions), hi addition, releases due to
one-time events not associated with production (e.g.,
terrorist bombing) are to be included in Section 8.8.
These amounts are not included in the quantities
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.
52 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example 20: Quantity Released to the Environment as a Result of Remedial Actions, Catastrophic Events, or
One-Time Events Not Associated with Production Processes. '
rA chemical manufacturer produces an EPCRASectioh 313 chemical in a reactor that operates at low pressure. The
,reactants arid* the EPCRA Section 313 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 eontrgl panel (which 13 state-of-the-art and undergoes routitie inspection and
maintenance), the temperature and pressure'in the reactor increase, Hie realtor ruptures, and the EPCRA Section
313 chemical is released. Because the malfunction coukknptbe anticipated and, therefore, could not be reasonably
addressed by specific source reduction activities^ the amount released is included in Sectiqh 8.8. In this case, much
of the EPCRA Section 313 chemical is released as a liquid and pools on the ground. It is estimated that 1,000 pounds
of'the EPCRA Section 313 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 EPCRA Section 313 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).
By checking your documentation for calculating
estimates made for Part n, Section 5, "Quantity of the
Toxic Chemical Entering Each Environmental Medium
On Site," you may be able to identify release amounts
from the above sources. Emergency notifications under
CERCA and EPCRA as well as accident histories
required under the Clean Air Act may provide useful
information. You should also check facility incident
reports and maintenance records to identify one-time or
catastrophic events.
Note: While the information reported in Section 8.8
represents only remedial, catastrophic, or one-time
events not associated with production processes, Section
5 of Form R (on-site releases to the environment) and
Section 6 (off-site transfers for further waste
management), must include all on-site releases and
transfers as appropriate, regardless of whether they arise
from catastrophic, remedial, or routine process
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
production that is the primary influence on the quantity
of the reported EPCRA Section 313 chemical recycled,
used for energy recovery, treated, or released. The ratio
or index must be reported to the nearest tenths or
hundredths place (i.e., one or two digits to the right of
the decimal point). If the manufacture or use of the
reported EPCRA Section 313 chemical began during the
current reporting year, enter not applicable, "NA," as the
production ratio or activity index. Note, this is not to be
reported as a percent (i.e., report 1.10 for a 10% increase,
not 110%);
It is important to realize that if your facility reports more
than one reported EPCRA Section 313 chemical, the
production ratio or activity index may vary for different
chemicals. For facilities that manufacture reported
EPCRA Section 313 chemicals, the quantities of the
EPCRA Section 313 chemical(s) produced in the current
and prior years provide a good basis for the ratio because
that is the primary business activity associated with the
reported EPCRA Section 313 chemical(s). hi most cases,
the production ratio or activity index must be based on
some variable of production or activity rather than on
EPCRA Section 313 chemical or material usage. Indices
based on EPCRA Section 313 chemical or material usage
may reflect the effect of source reduction activities rather
than changes in business activity. EPCRA Section 313
chemical or material usage is therefore not a basis to be
used for the production ratio or activity index where the
EPCRA Section 313 chemical is "otherwise-used" (i.e.,
non-incorporative activities such as extraction solvents,
metal degreasers, etc.).
While several methods are available to the facility for
determining this data element, the production ratio or
activity index must be based on the variable that most
directly affects the quantities of the EPCRA Section 313
chemical recycled, used for energy recovery, treated, or
released. Examples of methods available include:
Toxics Release Inventory Reporting Forms and Instructions 53
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Instructions for Completing Part II of EPA Form R
(1) Amount of EPCRA Section 313 chemical (2) Amount of product produced in 1998 divided by the
manufactured in 1998 divided by the amount of amount of product produced in 1997.
EPCRA Section 313 chemical manufactured in 1997;
or
Example 21: Determining a Production Ratio
Your facility's only use of toluene is as a paint carrier for a painting operation. You painted 12,000 refrigerators
in the current reporting year and 10,000 refrigerators 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, including titanium dioxide. Hydrochloric acid (acid aerosols) is
produced as a waste byproduct during the production process. An appropriate production ratio for hydrochloric
acid (acid aerosols) is the annual titanium dioxide production, not me amount of byproduct generated. If the
facility produced 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). "_
Example 22: 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 l-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 toluene 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-trichloromethane in a vapor
DEGREASER. The decreasing 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 decreasing
operation. If the decreasing 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). '
54 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
Example, 23: "NA" is Entered as the Production Ratio or ActivityfIndex
^ < •#* iv. =. t
Your facility began production of semiconductor chips during this reporting" year. Perchlqroefhylene is used as
•a cleaning solvent for this operation >and this is thepnly use of 1he EPCRA Section 313 chemical in jour facility.'
You would enter not applicable, "NA," in Section $9' because you have no -basis of comparison M'the prior year
for the purposes of developing'trie-activity index. '"
, Example 24: Determining the Production Ratio Based oh a Weighted Average
At many facilities, a reported EPCRA Section 313 chemical is used in more than one production process: In these
cases, a production ratio of 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 EPCRA Section 313 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 thepriorsyear. There were no significant design modifications that
changed the total surface area tqbejpainted fc?r each bike. The bicycle production ratio is T.I (16,0,00/14^500). YOU
estimate 12,500 pounds of toluene recyclecl, used for energy recovery, treated, 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: _: „
f - ^ " ? rf J M '
Production ratio"= 1.1 ^(12,500/13;500)+" 0.87 x (1,000/13,500) = 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 EPCRA Section 313 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 EPCRA
Section 313 chemical, enter not applicable, "NA," in
Section 8.10.1 and answer Section 8.11.
Source reduction means any practice that:
Q Reduces the amount of any hazardous substance,
pollutant, or contaminant entering any waste stream
or otherwise released into the environment
(including fugitive emissions) prior to recycling,
energy recovery, 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
modifications, process or procedure modifications,
reformulation or redesign of products, substitution of
raw materials, and improvements in housekeeping,
maintenance, training, or inventory control.
The term source reduction does not include any practice
that alters the physical, chemical, or biological
characteristics or the volume of a hazardous substance,
pollutant, or contaminant through a process or activity
that 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,
using for energy recovery, treating, or disposing of an
EPCRA Section 313 chemical. Report in this section only
the source reduction activities implemented to reduce or
eliminate the quantities reported in Sections 8.1 through
8.7. The focus of the section is only those activities that
are applied to reduce routine or reasonably anticipated
releases and quantities of the reported EPCRA Section
313 chemical recycled, treated, used for energy recovery,
or disposed. Do not report in this section any activities
Toxics Release Inventory Reporting Forms and Instructions 55
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Instructions for Completing Part II of EPA Form R
taken to reduce or eliminate the quantities reported in
Section 8.8.
Example 25: Source Reduction
A facility assembles and paints furniture. Both the
glue used to assemble the furniture and the paints
contain EPCRA Section 313 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, that
contains an EPCRA Section 313 chemical that is
collected and recovered. The recovered solvent is
used to dean the painting equipment. The recycling
activity does not reduce the amount of EPCRA
Section 313 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," ihe appropriate code(s)
indicating the type of actions taken to reduce the amount
of the reported EPCRA Section 313 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 EPCRA Section 313 chemical reported in
Sections 8.1 through 8.7. Actions taken to recycle,
combust for energy recovery, treat, or dispose of the
EPCRA Section 313 chemical are not considered source
reduction activities.
Source Reduction Activity Codes:
Good Operating Practices
W13 Improved maintenance scheduling, record
keeping, or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W19 Other changes made in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials do
not stay in inventory beyond shelf-life
W22 Began to test outdated material — continue to
use if still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange materials
that would otherwise be discarded
W29 Other changes made in inventory control
SpiU and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading, unloading,
and transfer operations
W33 Installed overflow alarms or automatic shut-off
valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring program
of potential spill or leak sources
W39 Other changes made in spill and leak prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications made
Process Modifications
W51 Instituted re-circulation within a process
W52 Modified equipment, layout, or piping
W53 Used 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 made
Cleaning and Decreasing
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
56 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form R
W65 Redesigned parts racks to reduce drag out
W66 Modified or installed rinse systems
W67 Improved rinse equipment design
W68 Improved rinse equipment operation
W71 Other cleaning and decreasing modifications
made
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 made
Product Modifications
W81 Changed product specifications
W82 Modified design or composition of product
W83 Modified packaging
W89 Other product modifications made
In columns a through c of Section 8.10, the "Methods to
Identify Activity", you must enter one or more of the
following code(s) that correspond to those internal and
external method(s) or information sources you used to
identify the possibility for a source reduction activity
implementation at your facility. If more than three
methods were used to identify the source reduction
activity, enter only the three codes that contributed most
to the decision to implement the activity.
Methods to Identify Activity
T01 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 Optional 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 activities you
have implemented in the reporting year or in prior years
for the reported EPCRA Section 313 chemical. If you are
not including additional information, check "No."
If you submit additional optional information, try to limit
this information to one page that summarizes the source
reduction, recycling, or pollution control activities. If
there is a contact person at the facility, other than the
technical or public contact provided in Part I, Section 4,
the summary page should include that person's name
and telephone number for individuals who wish to
obtain further information about those activities. Also
submit a copy of this additional information to the
appropriate state agency as part of the Form R submittal
to that agency.
Toxics Release Inventory Reporting Forms and Instructions 57
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D. Facility Eligibility Determination for Alternate Threshold and
for Reporting on EPA Form A
D.3 What is the total annual reportable
amount?
This section will help to determine whether you can
submit the simplified Form A report. The criteria are
based on total annual reportable amount of listed
chemical or chemical category and the amount
manufactured, processed, or otherwise used.
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 (defined below)
for that chemical, and that their amounts manufactured
or processed or otherwise used do not exceed
one-million pounds. As with determining section 313
reporting thresholds, amounts manufactured, processed,
or otherwise used are to be considered independently.
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 an EPCRA
Section 313 chemical do not fill out a Form R for that
same chemical.
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
reporting and is intended as a means to reduce the
compliance burden associated with EPCRA section 313.
The Form A must be submitted on an annual basis for
each eligible chemical. Facilities wishing to take
advantage 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
identification 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 approved Form A and a magnetic version of
reporting have been included in this 1998 Forms and
Instructions package.
For the purpose of this optional reporting modification,
the annual reportable amount is equal to the combined
total quantities released at the facility, disposed within
the facility, treated at the facility (as represented by
amounts destroyed or converted by treatment processes),
recovered at the facility as a result of recycle operations,
combusted for the purpose of energy recovery 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 elements 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 substantiating
this determination for a period of three years from the
date of the submission of the Form A. These records
must include sufficient documentation to support
calculations as well as the calculations made by the
facility 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
one-million pounds of an EPCRA Section 313 chemical
annually, and whose owner/operator elects to take
advantage 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 determination
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 regulations 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
58 Toxics Release Inventory Reporting Forms and Instructions
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Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form A
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 determination. Thus,
all of the information necessary to make the
determination must be assembled to the facility level.
D.6 Trade secrets
EPA is requiring that a facility submit a unique Form A
for each EPCRA Section 313 chemical meeting the
conditions of the alternate threshold. Facilities may
assert a trade secrecy claim for a chemical identity on the
Form A as on the Form R. Reports submitted on a per
chemical basis protect against the disclosure of trade
secrets. Form As with trade secrecy claims, like Form Rs
with similar claims, will be separately handled upon
receipt to protect against disclosure. Commingling trade
secret chemical identities with non-trade secret chemical
identities on the same submission increases the risk of
disclosure.
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
reported 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
applied separately to the listed parent metal and the
associated metal compound(s). Threshold
determinations must be made independently for each
because they are separately listed EPCRA Section 313
chemicals.
Q If the threshold is exceeded for the listed parent
metal but not the associated metal compounds, then
the releases of metal reported on Form R for the
parent metal should not include the releases from
the metal compounds.
Q If both the parent metal and the associated metal
compounds exceed the alternate threshold, 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.
Q If neither the parent metal nor the associated metal
compounds exceed the alternate threshold, 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 chemical
or chemical category has not been exceeded.
Similarly, separate Form As 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 example, if a
facility processes in three separate process streams,
xylene (mixed isomers), o-xylene, and p-xylene, and
exceeds the conditions of the alternate threshold 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 separately
process all types (i.e., isomers) of xylene with individual
activity levels within the conditions of the alternate
threshold should file a separate Form A for each type of
xylene.
Toxics Release Inventory Reporting Forms and Instructions 59
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E. Instructions for Completing EPA Form A
The following are specific instructions for completing
each part of EPA Form A. All of the data elements that
appear on 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
designations of the parts and sections of these
instructions correspond to those in Form R unless
otherwise indicated.
For all parts of Form A:
Q 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.)
Q All information on the Form A is required.
D Do not leave items in Parts I and n on the Form A
blank unless specifically directed to do so; if an item
does not apply to you, enter not applicable, NA, in
the space provided. If your information does not fill
all the spaces provided for a type of information,
enter NA, in the next blank space in the sequence.
Q Do not submit an incomplete form. The certification
statement (Parti, Section 3) specifies that the report
is complete as submitted. See page 1 of these
instructions for the definition of a complete
submission.
Part I. Facility Identification
Information
Section 1. Reporting Year
This is the calendar year to which the reported
information applies, not the year in which you are
submitting the report. Information for the 1998 reporting
year must be submitted on or before July 1, 1999.
Section 2. Trade Secret Information
2.1 Are you claiming the EPCRA Section 313
chemical identified on page 2 trade secret?
The specific identity of the EPCRA Section 313 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, processing, or otherwise use
of the EPCRA Section 313 chemical whose identity is a
trade secret. (See page 2 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?
Check "sanitized" if this copy of the report is the public
version that does not contain the EPCRA Section 313
chemical identity but does contain a generic name in its
place, and you have claimed the EPCRA Section 313
chemical identity trade secret in Part I, Section 2.1.
Otherwise, 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 certification 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 FR
61488 (November 30, 1994). Print or type in the space
provided the name and title of the person who signs the
statement. This certification statement applies to all the
information supplied on the form and should be signed
only after the form has been completed.
Section 4. Facility Identification
4.1 Facility Name, Location, and TRI Facility
Identification Number
Enter the name of your facility (plant site name or
appropriate facility designation), street address, mailing
address, city, county, state, and zip code in the space
provided. Do not use a post office box number as the
street address. The street address provided should be
the location where the EPCRA Section 313 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. Note that the
mailing address is provided first, followed by the street
address.
If you have submitted a Form R for previous reporting
years, a TRI Facility Identification Number has been
assigned to your facility. If you cannot locate your TRI
Facility Identification Number, please contact the
60 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part I of EPA Form A
Emergency Planning and Community Right-to-Know
Information Hotline (see page 4).
Enter "NA" in the space for the TRI Facility Identification
Number if your facility has never filed a Form A
(certification statement) or a Form R. If you have
previously submitted a Form A or a Form R, use the TRI
Facility Identification Number that you have been
assigned. If you previously submitted a Form A or a
Form R, but do not know what it is, contact the EPCRA
Hotline. 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
that 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 federal facility. If the reporting facility is not
a federal facility, 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
establishments. This data element provides the option of
reporting full or partial facility information on Form R,
however, this is not applicable for those facilities taking
advantage of the Alternate Threshold and 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 someone
at the location of the reporting facility; however, this
person must be familiar with the details of the report so
that he or she can answer questions about the
information provided.
4.4 Intentionally Left Blank
4.5 Standard Industrial Classification (SIC) Code
Enter the appropriate four-digit primary Standard
Industrial Classification (SIC) code for your facility.
Table I lists the SIC codes 10 (except 1011, 1081, and
1094), 12 (except 1241), 20-39, 4911 (limited to facilities
that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4931
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4939 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for
distribution in commerce), 4953 (limited to facilities
regulated under the RCRA Subtitle C, 42 U.S.C. section
6921 et seq.), 5169, 5171, and 7389 (limited to facilities
primarily engaged in solvents recovery services on a
contract or fee basis). If the report covers more than one
establishment, enter the primary four-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 facilities that fall
within SIC codes 10 (except 1011, 1081, and 1094), 12
(except 1241), 20-39, 4911 (limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4939
(limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in
commerce), 4953 (limited to facilities regulated under the
RCRA Subtitle C, 42 U.S.C. section 6921 et seq.), 5169,
5171, and 7389 (limited to facilities primarily engaged in
solvents recovery services on a contract or fee basis). 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 address
the SIC code change, as it relates to EPCRA, in an
upcoming Federal Register notice. This upcoming
change does NOT affect the 1998 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
blueprints, 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, S, E, 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 A. EPA
encourages facilities to make the best possible
measurements when determining latitude and longitude.
As with any other data field, missing, suspect, or
incorrect data may generate a Notice of Technical Error
to be issued to the facility. (See Appendix C: Common
Errors in Completing Form R Reports).
Toxics Release Inventory Reporting Forms and Instructions 61
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Instructions for Completing Part II of EPA Form A
4.7 Dun and Bradstreet Number(s)
Enter the nine-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 D & B 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 center located in Allentown,
Pennsylvania, 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 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(s)
The EPA I.D. Number is a 12-character number assigned
to facilities covered by hazardous waste regulations
under RCRA. Facilities not covered by RCRA are not
likely to have an assigned I.D. Number. If your facility is
not required to have an I.D. Number, enter not
applicable, NA, in box (a). If your facility has been
assigned EPA Identification Numbers, you must enter
those numbers in the spaces provided in Section 4.8.
4.9 Facility NPDES Permit Number(s)
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 EPCRA Section 313 chemical being reported. This
nine-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
NA, in Section 4.9a.
4.10 Underground Injection Well Code (UIC)
Identification Number(s)
If your facility has a permit to inject a waste containing
the EPCRA Section 313 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 NA
in Section 4.1 Oa. You are only required to provide the
UIC number for wells that receive the EPCRA Section 313
chemical being reported.
Section 5. Parent Company Information
You must provide information on your parent company.
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 owned by a
foreign entity, enter 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.
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 NA box.
5.2 Parent Company's Dun & Bradstreet Number
Enter the D&B 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 D& B number,
check the NA box.
Part II. Chemical Identification
Reporting on the Alternate Threshold Form A for metals,
metal compounds, and mixed isomers differs somewhat
from Form R reporting. Please refer to Section D for
these guidelines.
Section 1. Toxic Chemical Identity
(Important: DO NOT complete this section if you
completed Section 2 of Part II below.)
1.1 CAS Number
Enter the Chemical Abstracts Service (CAS) registry
number in Section 1.1 exactly as it appears in Table II for
the chemical being reported. CAS numbers are
cross-referenced with an alphabetical list of chemical
names in Table II of these instructions. If you are
reporting one of the EPCRA Section 313 chemical
categories in Table II, part c (e.g., chromium compounds),
enter the applicable category code in the CAS number
62 Toxics Release Inventory Reporting Forms and Instructions
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Instructions for Completing Part II of EPA Form A
space. EPCRA Section 313 chemical category codes are
listed below and can also be found in Table II, part c and
Appendix B-l.
EPCRA Section 313 Chemical Category Codes
N010 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
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 (water dissociable;
reportable only when in aqueous solution)
N575 Polybrominated biphenyls (PBBs)
N583 Polychlorinated alkanes (CIO to CIS)
N590 Polycyclic aromatic compounds (PACs)
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 A and unsanitized substantiation form. Do not
include the CAS number or category code on your
sanitized Form A or sanitized substantiation form.
1.2 EPCRA Section 313 Chemical or Chemical
Category Name
Enter the name of the EPCRA Section 313 chemical or
chemical category exactly as it appears in Table II. If the
EPCRA Section 313 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 EPCRA Section 313 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
EPCRA Section 313 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 EPCRA Section 313 chemical identity on your
unsanitized Form A and unsanitized substantiation form.
Do not report the name of the EPCRA Section 313
chemical on your sanitized Form A or sanitized
substantiation form. Include a generic 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 specific
EPCRA Section 313 chemical identity of the EPCRA
Section 313 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 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 on next page.
In-house plant codes and other substitute names that are
not structurally descriptive of the EPCRA Section 313
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 A, and
the name must be the same as that used on
substantiation forms.
your
Section 2. Mixture Component Identity
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 EPCRA Section
313 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:
Toxics Release Inventory Reporting Forms and Instructions 63
-------
Instructions for Completing Part II of EPA Form A
•••••••^^•••I^^MHBI^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
1. You determine that the mixture contains an EPCRA
Section 313 chemical but the only identity you have
for that chemical is a generic name;
2. You know either the specific concentration of that
EPCRA Section 313 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.
64 Toxics Release Inventory Reporting Forms and Instructions
-------
Table I. SIC Codes
10 Metal Mining (except 1011,1081
and 1094)
1021 Copper Ores
1031 Lead and Zinc Ores
1041 Gold Ores
1044 Silver Ores
1061 Ferroalloy Ores, Except Vanadium
1099 Miscellaneous Metal Ores, Not Elsewhere
Classified
12 Coal Mining (except 1241)
1221 Bituminous Coal and Lignite Surface Mining
1222 Bituminous Coal Underground Mining
1231 Anthracite Mining
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 small wares 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
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-1
-------
Table I
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.*
23 Apparel and Other Finished
Products made from Fabrics and
Other Similar Materials
2311 Men's and boys' suits, coats, and overcoats
2321 Men's and boys' shirts, except work shirts
2322 Men's and boys' underwear and nightwear
2323 Men's and boys' neckwear
2325 Men's and boys' separate trousers and slacks
2326 Men's and boys' work clothing
2329 Men's and boys' clothing, n.e.c.*
2331 Women's, misses', and juniors' blouses and
shirts
2335 Women's, misses', and juniors' dresses
2337 Women's, misses', and juniors' suits, skirts, and
coats
2339 Women's, misses', and juniors', outerwear,
n,e.c.*
2341 Women's, misses', children's, and infants'
underwear and nightwear
2342 Brassieres, girdles, and allied garments
2353 Hats, caps, and millinery
2361 Girls', children's and infants' dresses, blouses,
and shirts
2369 Girls', children's and infants' outerwear, n.e.c.*
2371 Fur goods
2381 Dress and work gloves, except knit and all
leather
2384 Robes and dressing gowns
2385 Waterproof outerwear
2386 Leather and sheep lined clothing
2387 Apparel belts
2389 Apparel and accessories, n.e.c.*
2391 Curtains and draperies
2392 House furnishings, 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 wood buildings and components
2491 Wood preserving
2493 Reconstituted wood products
2499 Wood products, n.e.c.*
25 Furniture and Fixtures
2511 Wood household furniture, except upholstered
2512 Wood household furniture, upholstered
2514 Metal household furniture
2515 Mattresses, foundations, and convertible beds
2517 Wood television, radio, phonograph, and
sewing machine cabinets
2519 Household furniture, n.e.c.*
2521 Wood office furniture
2522 Office furniture, except wood
2531 Public building and related furniture
2541 Wood office and store fixtures, partitions,
shelving, and lockers
2542 Office and store fixtures, partitions, shelving,
and lockers, except wood
2591 Drapery hardware and window blinds and
shades
2599 Furniture and fixtures, n.e.c.*
26 Paper and Allied Products
2611 Pulp mills
2621 Paper mills
2631 Paperboard mills
2652 Setup paperboard boxes
2653 Corrugated and solid fiber boxes
2655 Fiber cans, tubes, drums, and similar products
2656 Sanitary food containers, except folding
2657 Folding paperboard boxes, including sanitary
2671 Packaging paper and plastics film, coated and
laminated
1-2 Toxics Release Inventory Reporting Forms and Instructions
*"Not elsewhere classified" indicated by "n.e.c."
-------
Table I
2672
2673
2674
2675
676
2677
2678
2679
27
2711
2721
2731
2732
2741
2752
2754
2759
2761
2771
2782
2789
2791
2796
Coated and laminated paper, n.e.c.*
Plastics, foil, and coated paper bags
Uncoated paper and multiwall bags
Die-cut paper and paperboard and cardboard
Sanitary paper products
Envelopes
Stationery tablets, and related products
Converted paper and paperboard products,
n.e.c.
Printing, Publishing, and Allied
Industries
Newspapers: publishing, or publishing and
printing
Periodicals: publishing, or publishing and
printing
Books: publishing, or publishing and printing
Book printing
Miscellaneous publishing
Commercial printing, lithographic
Commercial printing, gravure
Commercial printing, n.e.c.*
Manifold business forms
Greeting cards
Blank books, looseleaf binders and devices
Bookbinding and related work
Typesetting
Plate making 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
851 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 lathe cut mechanical
rubber products
3069 Fabricated rubber products, n.e.c.*
3081 Unsupported plastics film and sheet
3082 Unsupported plastics profile shapes
3083 Laminated plastics plate, sheet, and profile
shapes
3084 Plastics pipe
3085 Plastics bottles
3086 Plastics foam products
3087 Custom compounding of purchased plastics
resins
3088 Plastics plumbing fixtures
3089 Plastics products, n.e.c.*
31 Leather and Leather Products
3111 Leather tanning and finishing
3131 Boot and shoe cut stock and findings
3142 House slippers
3143 Men's footwear, except athletic
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-3
-------
Table I
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'shandbags 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 Nonmetallic mineral products, n.e.c.*
33 Primary Metal Industries
3312 Steel works, blast furnaces (including coke
ovens), and rolling mills
3313 Electrometallurgical products, except steel
3315 Steel wiredrawing and steel nails and spikes
3316 Cold-rolled steel sheet, strip, and bars
3317 Steel pipe and tubes
3321 Gray and ductile iron foundries
3322 Malleable iron foundries
3324 Steel investment foundries
3325 Steel foundries, n.e.c.*
3331 Primary smelting and refining of copper
3334 Primary production of aluminum
3339 Primary smelting and refining of nonferrous
metals, except copper and aluminum
3341 Secondary smelting and refining of nonferrous
metals
3351 Rolling, drawing, and extruding of copper
3353 Aluminum sheet, plate, and foil
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)
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
1-4 Toxics Release Inventory Reporting Forms and Instructions
*"Not elsewhere classified" indicated by "n.e.c.'
-------
Table I
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, dry-cleaning, 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*
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
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-5
-------
Table I
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
propulsionunits 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
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
1-6 Toxics Release Inventory Reporting Forms and Instructions
*"Not elsewhere classified" indicated by "n.e.c."
-------
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.*
49 Electric, Gas, and Sanitary
Services (limited to 4911, 4931, 4939 and
4953)
4911 Electric Services (limited to facilities that
combust coal and/or oil for the purpose of
generating electricity for distribution in
commerce)
4931 Electric and Other Services Combined (limited
to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution
in commerce)
• Table I
4939 Combination utilities, Not Elsewhere Classified
(limited to facilities that combust coal and/or oil
for the purpose of generating electricity for
distribution in commerce)
4953 Refuse Systems (limited to facilities regulated
under the RCRA Subtitle C, 42 U.S.C. section
6921 etseq.)
51 Wholesale Trade-Nondurable
Goods (limited to 5169 and 5171)
5169 Chemical and Allied Products, Not Elsewhere
• Classified
5171 Petroleum Terminals and Bulk Stations
73 Business Services (limited to 7389)
7389 Business Services, Not Elsewhere Classified
(limited to facilities primarily engaged in
solvents recovery services on a contract or fee
basis)
*"Not elsewhere classified" indicated by "n.e.c."
Toxics Release Inventory Reporting Forms and Instructions 1-7
-------
-------
Table II. EPCRA Section 313 Chemical List For Reporting Year 1998
(including Toxic Chemical Categories)
Specific EPCRA Section 313 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 EPCRA Section 313 chemicals.
Covered chemical categories follow.
Certain EPCRA Section 313 chemicals listed in Table II have parenthetic "qualifiers." These qualifiers indicate that
these EPCRA Section 313 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 81-07-2
notification)
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
"C.I. means "Color Index"
Toxics Release Inventory Reporting Form and Instructions II-l
-------
Table II
[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.]
Chemical Qualifiers
This table contains the list of individual EPCRA Section
313 chemicals and categories of chemicals subject to 1998
calendar year reporting. Some of the EPCRA Section 313
chemicals listed have parenthetic qualifiers listed next to
them. An EPCRA Section 313 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 (aluminum,
vanadium, and zinc) contain the qualifier "fume or dust."
Fume or dust refers to dry forms of these metals but does
not refer to "wet" forms such as solutions or slurries. As
explained in Section B.3.a of these instructions, the term
manufacture includes the generation of an EPCRA
Section 313 chemical as a byproduct or impurity. In such
cases, a facility should determine if, for example, it
generated more than 25,000 pounds of aluminum fume or
dust in the reporting year as a result of its activities. If
so, the facility must report that it manufactures
"aluminum (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
EPCRA Section 313 chemicals or other products for
distribution in commerce. In reporting releases, the
facility would only report releases of the fume or dust.
EPA considers dusts to consist of solid particles
generated by any mechanical processing of materials
including crushing, grinding, rapid impact, handling,
detonation, and decrepitation of organic and inorganic
materials such as rock, ore, and metal. Dusts do not tend
to flocculate, 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 EPCRA Section 313 chemical list contain a
qualifier relating to manufacture. For isopropyl alcohol,
the qualifier is "manufacturing — strong acid process."
For saccharin, the qualifier simply is "manufacturing."
For isopropyl alcohol, the qualifier means that only
facilities manufacturing isopropyl alcohol by the strong
acid process are required to report. In the case of
saccharin, only manufacturers of the EPCRA Section 313
chemical are subject to the reporting requirements. A
facility that processes or otherwise uses either EPCRA
Section 313 chemical would not be required to report for
those EPCRA Section 313 chemicals. In both cases,
supplier notification does not apply because only
manufacturers, not users, of the EPCRA Section 313
chemical must report.
Ammonia (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). 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 ammonia
is included. Any evaporation of ammonia from aqueous
ammonia solutions is considered anhydrous ammonia
and should be included in threshold determinations and
release and other waste management calculations.
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 aerosols
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 determinations the
entire weight of the nitrate compound must be included
in all calculations. For the purposes of reporting 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
phosphorus is qualified by the term "yellow or white."
This means that only manufacturing, processing, or
otherwise use of phosphorus in the yellow or white
chemical form triggers reporting. Conversely,
II-2 Toxics Release Inventory Reporting Form and Instructions
*C.I. means "ColorIndex"
-------
Table II
manufacturing, processing, or otherwise use of "black"
or "red" phosphorus does not trigger reporting. Supplier
notification 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 characteristic
of being able to be crumbled, pulverized, or reducible to
a powder with hand pressure. Only manufacturing,
processing, or otherwise use of asbestos in the friable
form triggers reporting. Supplier notification applies
only to distribution of mixtures or other trade name
products containing friable asbestos.
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
application. Only manufacturing, processing, or
otherwise use of aluminum oxide in the fibrous form
triggers reporting. Supplier notification applies only to
distribution of mixtures or other trade name products
containing fibrous forms of aluminum oxide.
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-CMoro-4-(trifluoromethyl)-
phenoxy)-2-nitrobenzoic acid,
sodium salt]
107-02-8 Acrolein l.o
79-06-1 Acrylamide 0.1
79-10-7 Acrylic acid 1.0
107-13-1 Acrylonitrile 0.1
15972-60-8 Alachlor l.o
116-06-3 Aldicarb 10
309-00-2 Aldrin l.o
[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-methylanthraquinone 0.1
33089-61-1 Amitraz 1.0
61-82-5 Amitrole 0.1
*C.I. means "Color Index"
Toxics Release Inventory Reporting Form and Instructions II-3
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
1.0
1.0
0.1
1.0
0.1
1.0
1.0
0.1
0.1
0.1
7664-41-7 Ammonia
(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
[4,6-Dichloro-N-(2-chlorophenyl)-
l,3,5-triazin-2-amine]
62-53-3 Aniline
90-04-0 o-Anisidine
104-94-9 p-Anisidine
134-29-2 o-Anisidine hydrochloride
120-12-7 Anthracene
7440-36-0 Antimony
7440-38-2 Arsenic
1332-21-4 Asbestos (friable)
1912-24-9 Atrazine
(6-Chloro-N-ethyl-N'-(l-
methylethyl)-l,3,5-triazine-2,4-diamine)
7440-39-3 Barium
22781-23-3 Bendiocarb
[2,2-Dimethyl-l,3-benzodioxol-4-
ol methylcarbamate]
1861-40-1 Benfluralin
(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)-benzenamine)
17804-35-2 Benomyl
98-87-3 Benzal chloride
55-21-0 Benzamide
71-43-2 Benzene
92-87-5 Benzidine
98-07-7 Benzoic trichloride
(Benzotrichloride)
98-88-4 Benzoyl chloride
94-36-0 Benzoyl peroxide
100-44-7 Benzyl chloride
7440-41-7 Beryllium
82657-04-3 Bifenthrin
92-52-4 Biphenyl
111-91-1 Bis(2-chloroethoxy) methane
Ul-44-4 Bis(2-chloroethyl) ether
542-88-1 Bis(chloromethyl) ether
108-60-1 Bis(2-chloro-l-methylethyl)ether
56-35-9 Bis(tributyltin) oxide
10294-34-5 Boron trichloride
7637-07-2 Boron trifluoride
1.0 314-40-9
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
53404-19-6
7726-95-6
35691-65-7
353-59-3
75-25-2
74-83-9
75-63-8
1689-84-5
1689-99-2
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
357-57-3
106-99-0
141-32-2
71-36-3
78-92-2
75-65-0
106-88-7
123-72-8
7440-43-9
156-62-7
133-06-2
63-25-2
1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4
120-80-9
2439-01-2
Bromacil 1-0
(5-Bromo-6-methyl-3-(l-
methylpropyl)-2,4(lH,3H)-
pyrimidinedione)
Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione/ 5-
bromo-6-methyl-3-(l-methyl-
propyl), lithium salt]
Bromine 1-0
l-Bromo-l-(bromomethyl)- 1.0
1,3-propanedicarbonitrile
Bromochlorodifluoromethane 1.0
(Halon 1211)
Bromoform (Tribromomethane) 1.0
Bromomethane 1-0
(Methyl bromide)
Bromotrifluoromethane 1.0
(Halon 1301)
Bromoxynil 1-0
(3,5-Dibromo-4-hydroxybenzonitrile)
Bromoxynil octanoate 1-0
(Octanoic acid, 2,6-dibromo-4-
cyanophenylester)
Brucine 1-0
1,3-Butadiene 0.1
Butyl acrylate 1.0
n-Butyl alcohol 1.0
sec-Butyl alcohol 1.0
tert-Butyl alcohol 1-0
1,2-Butylene oxide 1-0
Butyraldehyde 1-0
Cadmium 0.1
Calcium cyanamide 1.0
Captan 1-0
[lH-Isoindole-l,3(2H)-dione,
3a,4,7,7a-tetrahydro-2-
[(trichloromethyl)thio]-]
Carbaryl [1-Naphthalenol, 1.0
methylcarbamate]
Carbofuran 1-0
Carbon disulfide 1.0
Carbon tetrachloride 0.1
Carbonyl sulfide 1.0
Carboxin 1-0
(5,6-Dihydro-2-methyl-N-
phenyl-l,4-oxathiin-3-carboxamide)
Catechol 1-0
Chinomethionat 1.0
[6-Methyl-l,3-dithiolo[4,5-
b]quinoxalin-2-one]
II-4 Toxics Release Inventory Reporting Form and Instructions
*C.l. means "Color Index"
-------
Table II
CAS Number
133-90-4
Chemical Name
Chloramben
De Minimis
Concentration
1.0
CAS Number
5598-13-0
Chemical Name
Chlorpyrifos methyl
De Minimis
Concentration
1.0
[Benzole acid, 3-amino-2,5-dichloro-]
57-74-9 Chlordane 0.1
[4,7-Methanoindan, 64902-72-3
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- 7440-47-3
methoxyprimidin-2 4680-78-8
-yl)amino]carbonyl]amino] 6459-94-5
sulfonyljbenzoate] 569-64-2
7782-50-5 Chlorine 1.0 989-38-8
10049-04-4 Chlorine dioxide 1.0 1937-37-7
79-11-8 Chloroacetic acid 1.0 2602-46-2
532-27-4 2-Chloroacetophenone 1.0 28407-37-6
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza- 1.0 16071-86-6
1-azoniaadamantane chloride 2832-40-8
106-47-8 p-Chloroaniline 0.1 3761-53-3
108-90-7 Chlorobenzene 1.0 81-88-9
510-15-6 Chlorobenzilate 1.0 3118-97-6
[Benzeneacetic acid, 4-chloro- 97-56-3
.alpha.- (4-chlorophenyl)-.alpha.- 842-07-9
hydroxy-, ethyl ester] 492-80-8
75-68-3 l-Chloro-l,l-difluoroethane 1.0
(HCFC-142b) 128-66-5
75-45-6 Chlorodifluoromethane 1.0 7440-48-4
(HCFC-22) 7440-50-8
75-00-3 Chloroethane (Ethyl chloride) 1.0 8001-58-9
67-66-3 Chloroform 0.1 120-71-8
74-87-3 Chloromethane (Methyl chloride) 1.0 108-39-4
107-30-2 Chloromethyl methyl ether 0.1 95-48-7
563-47-3 3-Chloro-2-methyl-l-propene 0.1 106-44-5
104-12-1 p-Chlorophenyl isocyanate 1.0 1319-77-3
76-06-2 Chloropicrin 1.0 4170-30-3
126-99-8 Chloroprene 1.0 98-82-8
542-76-7 3-Chloropropionitrile 1.0 80-15-9
63938-10-3 Chlorotetrafluoroethane 1.0 135-20-6
354-25-6 l-Chloro-1,1,2,2- 1.0
tetrafluoroethane (HCFC-124a)
2837-89-0 2-Chloro-l,l,l,2- 1.0 21725-46-2
tetrafluoroethane (HCFC-124) 1134-23-2
1897-45-6 Chlorothalonil 1.0 110-82-7
[1,3-Benzenedicarbonitrile, 108-93-0
2,4,5,6-tetrachloro-] 68359-37-5
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 (CFC-13) 1.0
460-35-5 3-Chloro-l,l,l- 1.0
trifluoropropane (HCFC-253fb)
[O,O-Dimethyl-O-(3,5,6-trichloro-
2-pyridyl)phosphorothioate]
Chlorsulfuron 1.0
[2-Chloro-N-[[(4-methoxy-6-
methyl-l,3,5-triazin-2-yl)
amino]carbonyl]
benzenesulfonamide]
Chromium 1.0
C.I. Acid Green 3 1.0
C.I. Acid Red 114 0.1
C.I. Basic Green 4 1.0
C.I. Basic Red 1 1.0
C.I. Direct Black 38 0.1
C.I. Direct Blue 6 0.1
C.I. Direct Blue 218 1.0
C.I. Direct Brown 95 0.1
C.I. Disperse Yellow 3 1.0
C.I. Food Red 5 0.1
C.I. Food Red 15 1.0
C.I. Solvent Orange 7 1.0
C.I. Solvent Yellow 3 1.0
C.I. Solvent Yellow 14 1.0
C.I. Solvent Yellow 34 0.1
(Auramine)
C.I. Vat Yellow 4 1.0
Cobalt 0.1
Copper 1.0
Creosote 0.1
p-Cresidine 0.1
m-Cresol 1.0
o-Cresol 1.0
p-Cresol 1.0
Cresol (mixed isomers) 1.0
Crotonaldehyde 1.0
Cumene 1.0
Cumene hydroperoxide 1.0
Cupferron 0.1
[Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt]
Cyanazine 1.0
Cycloate 1.0
Cyclohexane 1.0
Cyclohexanol 1.0
Cyfluthrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarbox-
ylic acid, cyano(4-fluoro-3-
phenoxyphenyl) methyl ester]
*C.I. means "ColorIndex"
Toxics Release Inventory Reporting Form and Instructions 11-5
-------
Tabk-Il
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
68085-85-8
94-75-7
533.74.4
53404-60-7
94-82-6
1929-73-3
94-80-4
2971-38-2
1163-19-5
13684-56-5
1928-43-4
53404-37-8
2303-16-4
615-05-4
39156-41-7
101-80-4
95-80-7
25376-45-8
333-41-5
334-88-3
132-64-9
96-12-8
106-93-4
124-73-2
84-74-2
1918-00-9
99-30-9
95-50-1
541-73-1
106-46-7
25321-22-6
Cyhalothrin 1.0
[3-(2-ChIoro-3,3,3-trifluoro-l-
propenyl)-2,2-dimethylcyclo-
propanecarboxylic
acid cyano(3-phenoxyphenyl)
methyl ester]
2,4-D 0.1
[Acetic acid, (2,4-dichlorophenoxy)-]
Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-
l,3,5-thiadiazine-2-thione)
Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-
l,3,5-thiadiazine-2-thione, ion(l-),
sodium]
2,4-DB 1.0
2,4-D butoxyethyl ester 0.1
2,4-D butyl ester 0.1
2,4-D chlorocrotyl ester 0.1
Decabromodiphenyl oxide 1.0
Desmedipham 1.0
2,4-D 2-ethylhexyl ester
2,4-D 2-ethyl-4-
methylpentyl ester
Diallate
[Carbamothioic acid, bis(l-
methylethyl)-S-(2,3-dichloro-
2-propenyl) ester]
2,4-Diaminoanisole
2,4-Diaminoanisole sulfate
4,4'-Diaminodiphenyl ether
2,4-Diaminotoluene
Diaminotoluene (mixed isomers)
Diazinon
Diazomethane
Dibenzofuran
l,2-Dibromo-3-
chloropropane (DBCP)
1,2-Dibromoethane 0.1
(Ethylene dibromide)
Dibromotetrafluoroethane 1.0
(Halon 2402)
Dibutyl phthalate 1.0
Dicamba 1.0
(3,6-Dichloro-2-methoxybenzoic acid)
Dichloran 1.0
[2,6-Dichloro-4-nitroaniline]
1,2-Dichlorobenzene 1.0
1,3-Dichlorobenzene 1.0
1,4-Dichlorobenzene 0.1
Dichlorobenzene (mixed isomers) 0.1
91-94-1 3,3-Dichlorobenzidine 0.1
612-83-9 3,3'-Dichlorobenzidine 0.1
dihydrochloride
64969-34-2 3,3'-Dichlorobenzidine sulfate 0.1
75-27-4 Dichlorobromomethane 1.0
764-41-0 l,4-Dichloro-2-butene 1.0
110-57-6 trans-l,4-Dichloro-2-butene 1.0
1649-08-7 l,2-Dichloro-l,l- 1.0
difluoroethane (HCFC-132b)
75-71-8 Dichlorodifluoromethane (CFC-12) 1.0
107-06-2 1,2-Dichloroethane (Ethylene 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 (HCFC-21) 1.0
75-09-2 Dichloromethane (Methylene 0.1
chloride)
127564-92-5 Dichloropentafluoropropane 1.0
13474-88-9 l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane (HCFC-225cc)
l,l-Dichloro-l,2,3,3,3- 1.0
pentafluoropropane (HCFC-225eb)
l,2-Dichloro-l,l,2,3,3- 1.0
pentafluoropropane (HCFC-225bb)
l,2-Dichloro-l,l,3,3,3- 1.0
pentafluoropropane (HCFC-225da)
l,3-Dichloro-l,l,2,2,3- 1.0
pentafluoropropane (HCFC-225cb)
l,3-Dichloro-l,l,2,3,3- 1.0
pentafluoropropane (HCFC-225ea)
2,2-Dichloro-l,l,l,3,3- 1.0
pentafluoropropane (HCFC-225aa)
2,3-Dichloro-l,l,l,2,3- 1.0
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l,l,l,2,2- 1.0
pentafluoropropane (HCFC-225ca)
Dichlorophene 1.0
[2,2'-Metit\ylenebis(4-chlorophenol)]
120-83-2 2,4-Dichlorophenol 1.0
78-87-5 1,2-Dichloropropane 1.0
10061-02-6 trans-l,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 l,l-Dichloro-l,2,2- 1.0
trifluoroethane (HCFC-123b)
0.1
0.1
1.0
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
0.1
111512-56-2
422-44-6
431-86-7
507-55-1
136013-79-1
128903-21-9
22-48-0
422-56-0
97-23-4
II-6 Toxics Release Inventory Reporting Form and Instructions
*C.I. means "ColorIndex"
-------
Table II
CAS Number Chemical Name
De Minimis
Concentration
1.0
CAS Number Chemical Name
De Minimis
Concentration
354-23-4 l,2-Dichloro-l,l,2-
trifluoroethane (HCFC-123a)
306-83-2 2,2-Dichloro-l,l,l- 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)
phenoxy]propanoic acid, methyl ester]
115-32-2 Dicofol - 1.0
[Benzenemethanol, 4-chloro-
.alpha.-4-(chIorophenyl)-.alpha.-
(trichloromethyl)-]
77-73-6 Dicyclopentadiene
1464-53-5 Diepoxybutane
111-42-2 Diethanolamine
38727-55-8 Diethatyl ethyl
117-81-7 Di(2-ethylhexyl) phthalate (DEHP)
64-67-5 Diethyl sulfate
35367-38-5 Diflubenzuron
101-90-6 Diglycidyl resorcinol ether
94-58-6 Dihydrosafrole
55290-64-7 Dimethipin
[2,3-Dihydro-5,6-dimethyl-l,4-
dithiin-l,l,4,4-tetraoxide]
60-51-5 Dimethoate
119-90-4 3,3'-Dimethoxybenzidine
dihydrochloride)
20325-40-0 3,3'-Dimethoxybenzidine 0.1
dihydrochloride(o-Dianisidine
111984-09-9 3,3'-Dimethoxybenzidine 0.1
hydrochloride
(o-Dianisidine hydrochloride)
124-40-3 Dimethylamine 1.0
2300-66-5 Dimethylamine dicamba 1.0
60-11-7 4-Dimethylaminoazobenzene 0.1
121-69-7 N,N-Dimethylaniline 1.0
119-93-7 3,3'-Dimethylbenzidine (o-Tolidine) 0.1
612-82-8 3,3'-Dimethylbenzidine 0.1
dihydrochloride (o-Tolidine
dihydrochloride)
41766-75-0 3,3'-Dimethylbenzidine 0.1
dihydrofluoride (o-Tolidine
dihydrofluoride)
79-44-7 Dimethylcarbamyl chloride 0.1
2524-03-0 Dimethyl 1.0
chlorothiophosphate
68-12-2 N,N-Dimethylformamide 0.1
57-14-7 1,1-Dimethylhydrazine 0.1
105-67-9 2,4-Dimethylphenol 1.0
131-11-3 Dimethyl phthalate 1.0
77-78-1 Dimethyl sulfate 0.1
99-65-0 m-Dinitrobenzene 1.0
528-29-0 o-Dinitrobenzene 1.0
100-25-4 p-Dinitrobenzene 1.0
88-85-7 Dinitrobutyl phenol (Dinoseb) 1.0
534-52-1 4,6-Dinitro-o-cresol 1.0
51-28-5 2,4-Dinitrophenol i.o
121-14-2 2,4-Dinitrotoluene 0.1
606-20-2 2,6-Dinitrotoluene 0.1
25321-14-6 Dinitrotoluene (mixed isomers) 1.0
39300-45-3 Dinocap 1.0
123-91-1 1,4-Dioxane 0.1
Diphenamid 1.0
Diphenylamine 1.0
1,2-Diphenylhydrazine 0.1
(Hydrazobenzene)
Dipotassium endothall 1.0
[7-Oxabicyclo(2.2.1)heptane-2,3-
dicarboxylic acid, dipotassium salt]
Dipropyl isocinchomeronate 1.0
Disodium 1.0
cyanodithioimidocarbonate
2,4-D isopropyl ester 0.1
2,4-Dithiobiuret 1.0
Diuron i.o
Dodine [Dodecylguanidine 1.0
monoacetate]
120-36-5 2,4-DP 0.1
1320-18-9 2,4-D propylene glycol 0.1
butyl ether ester
2702-72-9 2,4-D sodium salt 0.1
106-89-8 Epichlorohydrin 0.1
13194-48-4 Ethoprop 1.0
[Phosphorodithioic acid O-ethyl
S,S-dipropyl ester]
110-80-5 2-Ethoxyethanol 1.0
140-88-5 Ethyl acrylate 0.1
100-41-4 Ethylbenzene 1.0
541-41-3 Ethyl chloroformate 1.0
759-94-4 Ethyl dipropylthiocarbamate 1.0
(EPTC)
74-85-1 Ethylene 1.0
107-21-1 Ethylene glycol 1.0
151-56-4 Ethyleneimine (Aziridine) 0.1
75-21-8 Ethylene oxide 0.1
96-45-7 Ethylene thiourea 0.1
75-34-3 Ethylidene dichloride 1.0
52-85-7 Famphur 1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
1.0
1.0
0.1
957-51-7
122-39-4
122-66-7
2164-07-0
136-45-8
138-93-2
94-11-1
541-53-7
330-54-1
2439-10-3
*C.I. means "Color Index"
Toxics Release Inventory Reporting Form and Instructions 11-7
-------
II
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
1.0
1.0
1.0
1.0
1.0
1.0
76-44-8
118-74-1
87-68-3
319-84-6
77-47-4
67-72-1
1335-87-1
70-30-4
680-31-9
110-54-3
51235-04-2
67485-29-4
60168-88-9 Fenarimol 1.0 76-13-1
[.alpha.-(2-Chlorophenyl)-.alpha.-
(4-chlorophenyl)-5-pyrimidine-
methanol]
13356-08-6 Fenbutatin oxide
(Hexakis(2-methyl-2-
phenylpropyl)distannoxane)
66441-23-4 Fenoxaprop ethyl
[2-(4-((6-Chloro-2-benzoxazolylen)-
oxy)phenoxy)propanoic acid, ethyl
ester]
72490-01-8 Fenoxycarb
[[2-(4-Phenoxyphenoxy)
ethyljcarbamic acid ethyl ester]
39515-41-8 Fenpropathrin
[2,2,3,3-Tetramethylcyclopropane
carboxylic acid cyano(3-
phenoxyphenyl)methyl ester]
55-38-9 Fenthion
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester,
phosphorothioic acid]
51630-58-1 Fenvalerate
[4-Chloro-alpha-(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
De Minimis
Concentration
1.0
302-01-2
10034-93-2
7647-01-0
74-90-8
7664-39-3
123-31-9
35554-44-0
55406-53-6
13463-40-6
78-84-2
465-73-6
25311-71-1
67-63-0
80-05-7
120-58-1
Freon 113
[Ethane, l,l,2-trichloro-l,2,2,-
trifluoro-]
Heptachlor 0.1
[l,4,5,6,7,8,8-Heptachloro-3a,
4,7,7a-tetrahydro-4,7-methano-
IH-indene]
Hexachlorobenzene 0.1
Hexachloro-l,3-butadiene 1.0
alpha-Hexachlorocyclo- 1.0
.hexane
Hexachlorocyclopentadiene 1.0
Hexachloroethane 1.0
Hexachloronaphthalene 1.0
Hexachlorophene 1.0
Hexamethylphosphoramide 0.1
n-Hexane 1-0
Hexazinone 1.0
Hydramethylnon 1.0
[Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3-[4-
(trifluoromethyl)phenyl]-l-[2-[4-
(trifluoromethyl)phenyl]ethenyl]-2-
propenylidenejhydrazone]
Hydrazine 0.1
Hydrazine sulfate 0.1
Hydrochloric acid 1.0
(acid aerosols including mists, vapors,
gas, fog, and other airborne forms of
any particle size)
Hydrogen cyanide 1.0
Hydrogen fluoride 1.0
Hydroquinone 1.0
Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl]-lH-imidazole]
3-Iodo-2-propynyl 1.0
butylcarbamate
Iron pentacarbonyl 1.0
Isobutyraldehyde 1.0
Isodrin 1.0
Isofenphos[2-[[Ethoxyl[(l- 1.0
methylethyl)amino]-
phosphinothioyljoxy]
benzoic acid 1-methylethyl ester]
Isopropyl alcohol 1.0
(manufacturing-strong acid
process, no supplier notification)
4,4'-Isopropylidenediphenol 1.0
Isosafrole 1.0
II-8 Toxics Release Inventory Reporting Form and Instructions
*C.l. means "ColorIndex"
-------
Table II
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
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)
67-56-1 Methanol 1.0
20354-26-1 Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-
l,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) (MECCA)
101-61-1 4,4'-Methylenebis(N,N- 0.1
dimethyl)benzenamine
74-95-3 Methylene bromide 1.0
101-77-9 4,4'-Methylenedianiline 0.1
78-93-3 Methyl ethyl ketone 1.0
60-34-4 Methyl hydrazine 1.0
74-88-4 Methyl iodide 1.0
108-10-1 Methyl isobutyl ketone 1.0
624-83-9 Methyl isocyanate 1.0
556-61-6 Methyl isothiocyanate 1.0
[Isothiocyanatomethane]
75-86-5 2-MethyIlactonitrile 1.0
80-62-6 Methyl methacrylate 1.0
924-42-5 N-Methylolacrylamide 1.0
298-00-0 Methyl parathion 1.0
109-06-8 2-Methylpyridine 1.0
872-50-4 N-Methyl-2-pyrrolidone 1.0
9006-42-2 Metiram 1.0
21087-64-9 Metribuzin 1.0
7786-34-7 Mevinphos 1.0
90-94-8 Michler's ketone 0.1
2212-67-1 Molinate 1.0
(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
[.aIpha.-Butyl~.aIpha.-
(4-chlorophenyl)-lH-l,2,4-triazole-
1-propanenitrile]
142-59-6 Nabam 10
300-76-5 Naled l.Q
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)-]
51-75-2 Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
55-63-0 Nitroglycerin 1.0
"C.I. means "Color Index"
Toxics Release Inventory Reporting Form and Instructions II-9
-------
Table H
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
88-75-5 2-Nitrophenol
100-02-7 4-Nitrophenol
79-46-9 2-Nitropropane
924-16-3 N-Nitrosodi-n-butylamine
55-18-5 N-Nitrosodiethylamine
62-75-9 N-Nitrosodimethylamine
86-30-6 N-Nitrosodiphenylamine
156-10-5 p-Nitrosodiphenylamine
621-64-7 N-Nitrosodi-n-propylamine
759-73-9 N-Nitroso-N-ethylurea
684-93-5 N-Nitroso-N-methylurea
4549-40-0 N-Nitrosomethylvinylamine
59-89-2 N-Nitrosomorpholine
16543-55-8 N-Nitrosonornicotine
100-75-4 N-Nitrosopiperidine
99-55-8 5-Nitro-o-toluidine
27314-13-2 Norflurazon
[4-Chloro-5-(methylamino)-2-[3-
(trifluoromethyl)phenyl]-3(2H)-
pyridazinone]
2234-13-1 Octachloronaphthalene
19044-88-3 Oryzalin
[4~(Dipropylamino)-3,5-dinitro-
benzene sulfonamide]
20816-12-0 Osmium tetroxide
301-12-2 Oxydemeton methyl
[S-(2-(Ethylsulfinyl)ethyI) O,O-
dimethyl ester phosphorothioic acid]
19666-30-9 Oxydiazon
[3-[2,4-Dichloro-5-(l-methyl-
ethoxy)phenyl]- 5-(l,l-dimethyl
ethyl)-l,3,4-oxadiazol-2(3H)-one]
42874-03-3 Oxyfluorfen
10028-15-6 Ozone
123-63-7 Paraldehyde
1910-42-5 Paraquat dichloride
56-38-2 Parathion
[Phosphorothioic acid, O,O-
diethyl-O-(4-nitrophenyl)ester]
1114-71-2 Pebulate
[Butylethylcarbamothioic acid S-
propyl ester]
40487-42-1 Pendimethalin
[N-(l-Ethylpropyl)-3,4-dimethyl-
2,6-dinitrobenzenamine]
76-01-7 Pentachloroethane
87-86-5 Pentachlorophenol (PCP)
57-33-0 Pentobarbital sodium
79-21-0 Peracetic acid
594-42-3 Perchloromethyl mercaptan
1.0
1.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
0.1
0.1
0.1
0.1
0.1
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
1.0
1.0
1.0
1.0
1.0
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-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic
acid (3-phenoxyphenyl)methyl ester]
95-54-5 1,2-Phenylenediamine
108-45-2 1,3-Phenylenediamine
106-50-3 p-Phenylenediamine
615-28-1 1,2-Phenylenediamine
dihydrochloride
624-18-0 1,4-Phenylenediamine 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 (PCBS) 0.1
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-l,3,5-triazine-2,4-diamine]
23950-58-5 Pronamide 1.0
1918-16-7 Propachlor 1.0
[2-Chloro-N-(l-methylethyl)-N-
phenylacetamide]
1120-71-4 Propane sultone 0.1
11-10 Toxics Release Inventory Reporting Form and Instructions
*C.l. means "Color Index"
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
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
[l-[2-(2,4-Dichlorophenyl)-4-
propyl-l,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 I'Q
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
115-07-1 Propylene (Propene)
75-55-8 Propyleneimine
75-56-9 Propylene oxide
110-86-1 Pyridine
91-22-5 Quinoline
106-51-4 Quinone
82-68-8 Quintozene
(Pentachloronitrobenzene)
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 01
7782-49-2 Selenium 10
74051-80-2 Sethoxydim 1.0
[2-[l-(Ethoxyimino)butyl]-5-[2-
(ethylthio)propyl]-3-hydroxyl-2-
cyclohexen-1-one]
7440-22-4 Silver 1 Q
122-34-9 Simazine . i.o
26628-22-8 Sodium azide 10
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
7632-00-0
131-52-2
132-27-4
100-42-5
96-09-3
7664-93-9
2699-79-8
35400-43-2
34014-18-1
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
3383-96-8
5902-51-2
630-20-6
79-34-5
127-18-4
354-11-0
354-14-3
961-11-5
64-75-5
7696-12-0
7440-28-0
148-79-8
62-55-5
28249-77-6
139-65-1
59669-26-0
Sodium fluoroacetate 1.0
Sodium nitrite l'o
Sodium pentachlorophenate 1.0
Sodium o-phenylphenoxide 0 1
Styrene o.l
Styrene oxide 0.1
Sulfuric acid I.Q
(acid aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle size)
Sulfuryl fluoride (Vikane) 1 0
Sulprofos i.o
[O-Ethyl O-[4-(methylthio)phenyl]
phosphorodithioic acid S-propylester]
Tebuthiuron i.o
[N-[5-(l,l-Dimethylethyl)-l,3,4-
thiadiazol-2-yI]-N,N'-dimethylurea]
Temephos i.o
Terbacil i.o
[5-Chloro-3-(l,l-dimethyIethyl)-6-
methyl-2,4(lH,3H)-pyrimidinedione]
1,1,1,2-Tetrachloroethane 1.0
1,1,2,2-Tetrachloroethane 1.0
Tetrachloroethylene 0.1
(Perchloroethylene)
l,l,l,2-Tetrachloro-2- 1.0
fluoroethane (HCFC-121a)
1,1,2,2-Tetrachloro-l- 1.0
fluoroethane (HCFC-121)
Tetrachlorvinphos 1.0
[Phosphoric acid, 2-chloro-l-
(2,4,5-trichlorophenyl) ethenyl
dimethyl ester]
Tetracycline hydrochloride 1.0
Tetramethrin i.o
[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]
Thallium i.o
Thiabendazole i.o
[2-(4-Thiazolyl)-lH-benzimidazole]
Thioacetamide 0 1
Thiobencarb l'o
[Carbamic acid, diethylthio-, S-
(p-chlorobenzyl)ester]
4,4'-Thiodianiline 0 1
Thiodicarb 1 0
*C.I. means "Color Index"
Toxics Release Inventory Reporting Form and Instructions
11-11
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
23564-06-9
23564-05-8
79-19-6
62-56-6
137-26-8
1314-20-1
7550-45-0
108-88-3
584-84-9
91-08-7
26471-62-5
95-53-4
636-21-5
8001-35-2
43121-43-3
2303-17-5
68-76-8
101200-48-0
1983-10-4
2155-70-6
78-48-8
52-68-6
76-02-8
120-82-1
71-55-6
Thiophanate ethyl
[[1,2-Phenylenebis-
(iminocarbonothioyl)]biscarbamic
acid diethylester]
Thiophanate methyl
Thiosemicarbazide
Thiourea
Thiram
Thorium dioxide
Titanium tetrachloride
Toluene
Toluene-2,4-diisocyanate
Toluene-2,6-diisocyanate
Toluene diisocyanate (mixed
isomers)
o-Toluidine
o-Toluidine hydrochloride
Toxaphene
Triadimefon
[l-(4-Chlorophenoxy)-3,3-di-
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
0.1
0.1
0.1
0.1
1.0
butanone]
Triallate
Triaziquone
[^S-Cyclohexadiene-l^dione,
2,3,5-tris(l-aziridinyl)-]
Tribenuron methyl
[2-[[[[(4-Methoxy-6-methyl-l,3,5-
triazin-2-yl)-methylarnino]-
carbonyl]amino]sulfonyl] benzoic acid-
methyl ester)
Tributyltin fluoride
Tributyltin methacrylate
S^S-Tributyltrithio-
phosphate (DBF)
Trichlorfon
[Phosphoric acid,(2,2,2-trichloro-l-
hydroxy-ethyl)-,dimethyl ester]
Trichloroacetyl chloride
1,2,4-Trichlorobenzene
1,1,1-Trichloroethane (Methyl
chloroform)
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
79-00-5 1,1,2-Trichloroethane
79-01-6 Trichloroethylene
75-69-4 Trichlorofluoromethane (CFC-11)
95-95-4 2,4,5-Trichlorophenol
88-06-2 2,4,6-Trichlorophenol
96-18-4 1,2,3-Trichloropropane
57213-69-1 Triclopyr triethylammonium salt
121-44-8 Triethylamine
1582-09-8 Trifluralin
[Benezeneamine, 2,6-dinitro-N,N-
dipropyl-4-(trifluoromethyl)-]
26644-46-2 Triforine
[N,N'-[l,4-Piperazinediylbis-
(2,2,2-trichloroethylidene)]
bisformamide]
95-63-6 1,2,4-Trimethylbenzene
2655-15-4 2,3,5-Trimethylphenyl
methylcarbamate
639-58-7 Triphenyltin chloride
76-87-9 Triphenyltin hydroxide
126-72-7 Tris(2,3-dibromopropyl)
phosphate
72-57-1 Trypan blue
51-79-6 Urethane (Ethyl carbamate)
7440-62-2 Vanadium (fume or dust)
50471-44-8 Vinclozolin
[3-(3,5-Dichlorophenyl)-5-ethenyl
methyl-2,4-oxazolidinedione]
108-05-4 Vinyl acetate
593-60-2 Vinyl bromide
75-01-4 Vinyl chloride
75-35-4 Vinylidene chloride
108-38-3 m-Xylene
95-47-6 o-Xylene
106-42-3 p-Xylene
1330-20-7 Xylene (mixed isomers)
87-62-7 2,6-Xylidine
7440-66-6 Zinc (fume or dust)
1222-67-7 Zineb
[Carbamodithioic acid,
l,2-ethanediyibis-,zinc complex]
1.0
0.1
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
[-5-
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
H-12 Toxics Release Inventory Reporting Form and Instructions
"C.I. means "Color Index"
-------
CAS Numbered List of TRI
Chemicals
CAS Number Chemical Name
CAS Number Chemical Name
De Minimis
Concentration
50-00-0 Formaldehyde 0.1
51-03-6 Piperonyl butoxide 1.0
51-21-8 Fluorouracil (5-Fluorouracil) 1.0
51-28-5 2,4-Dinitrophenol 1.0
51-75-2 Nitrogen mustard 0.1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
51-79-6 Urethane (Ethyl carbamate) 01
52-68-6 Trichlorfon 1.0
[Phosphonic acid, (2,2,2-trichloro-l-
hydroxyethyl) dimethyl ester]
52-85-7 Famphur 1.0
53-96-3 2-Acetylaminofluorene 0.1
55-18-5 N-Nitrosodiethylamine 0.1
55-21-0 Benzamide 10
55-38-9 Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester,
phosphorothioic acid]
55-63-0 Nitroglycerin 1.0
56-23-5 Carbon tetrachloride 0.1
56-35-9 Bis(tributyltin) oxide 1.0
56-38-2 Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-
O-(4-nitrophenyl) ester]
57-14-7 1,1-Dimethylhydrazine 0.1
57-33-0 Pentobarbital sodium 1.0
57-41-0 Phenytoin 0.1
57-57-8 beta-Propiolactone 01
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-]
58-89-9 Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexa-
chloro-Xl.alpha.^.alpha.^.beta.,
4.alpha, 5.alpha.,6.beta.)-]
59-89-2 N-Nitrosomorpholine 0.1
60-09-3 4-Aminoazobenzene 0.1
60-11-7 4-Dimethylaminoazobenzene 0.1
60-34-4 Methyl hydrazine 1.0
60-35-5 Acetamide • 0.1
60-51-5 Dimethoate 1.0
61-82-5 Amitrole 0.1
62-53-3 Aniline 1.0
62-55-5 Thioacetamide 0.1
62-56-6 Thiourea o!l
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
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
De Minimis
Concentration
0.1
Dichlorvos
[Phosphoric acid, 2,2-
dichloroethenyl dimethyl ester]
Sodium fluoroacetate 1.0
N-Nitrosodimethylamine 0.1
Carbaryl l.Q
[1-Naphthalenol, methylcarbamate]
Formic acid 1.0
Diethyl sulfate 0.1
Tetracycline hydrochloride 1.0
Methanol i.o
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-l,4-dione, 2,3,
5-tris(l-aziridinyl)-]
Hexachlorophene 1.0
n-Butyl alcohol 1.0
Benzene o.l
1,1,1-Trichloroethane (Methyl 1.0
chloroform)
Methoxychlor 1.0
[Benzene, l,l'-(2,2,2-trichloro-
ethylidene)bis[4-methoxy-]]
Trypan blue 0.1
Bromomethane (Methyl bromide) 1.0
Ethylene l.Q
Chloromethane (Methyl chloride) 1.0
Methyl iodide l.Q
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
Vinylidene chloride 1.0
Dichlorofluoromethane 1.0
(HCFC-21)
Phosgene l.Q
*C.I. means "ColorIndex"
Toxics Release Inventory Reporting Form and Instructions 11-13
-------
CAS Number Chemical Name
De Minimis
Concentration
1.0
CAS Number Chemical Name
De Minimis
Concentration
0.1
0.1
1.0
1.0
1.0
75-45-6 Chlorodifluoromethane
(HCFC-22)
75-55-8 Propyleneimine
75-56-9 Propylene oxide
75-63-8 Bromotrifluoromethane
(Halon 1301)
75-65-0 tert-Butyl alcohol
75-68-3 l-Chloro-l,l-difluoroethane
(HCFC-142b)
75-69-4 Trichlorofluoromethane (CFC-11) 1.0
75-71-8 Dichlorodifluoromethane 1.0
(CFC-12)
75-72-9 Chlorotrifluoromethane (CFC-13) 1.0
75-86-5 2-Methyllactonitrile 1.0
75-88-7 2-Chloro-l,l,l-trifluoroethane 1.0
(HCFC-133a)
76-01-7 Pentachloroethane
76-02-8 Trichloroacetyl chloride
76-06-2 Chloropicrin
76-13-1 Freon 113
[Ethane, l,l,2-trichloro-l,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-lH-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 1,1,2,2-Tetrachloroethane
79.44.7 Dimethylcarbamyl chloride
1.0
1.0
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
1.0
0.1
0.1
1.0
1.0
1.0
0.1
0.1
79_46-9 2-Nitropropane
80-05-7 4,4'-Isopropylidenediphenol
80-15-9 Cumene hydroperoxide
80-62-6 Methyl methacrylate
81-07-2 Saccharin (manufacturing, no
supplier notification)
81-88-9 C.I. Food Red 15
82-28-0 l-Amino-2-methylanthraquinone 0.1
82-68-8 Quintozene 1-0
[Pentachloronitrobenzene]
84-74-2 Dibutyl phthalate
85-01-8 Phenanthrene
85-44-9 Phthalic anhydride
86-30-6 N-Nitrosodiphenylamine
87-62-7 2,6-Xylidine
87-68-3 Hexachloro-l,3-butadiene
87-86-5 Pentachlorophenol (PCP)
88-06-2 2,4,6-Trichlorophenol
88-75-5 2-Nitrophenol
88-85-7 Dinitrobutyl phenol (Dinoseb)
88-89-1 Picric acid
90-04-0 o-Anisidine
90-43-7 2-Phenylphenol
90-94-8 Michler's ketone
91-08-7 Toluene-2,6-diisocyanate
91-20-3 Naphthalene
91-22-5 Quinoline
91-59-8 beta-Naphthylamine
91-94-1 3,3'-Dichlorobenzidine
92-52-4 Biphenyl
92-67-1 4-Aminobiphenyl
92-87-5 Benzidine
92-93-3 4-Nitrobiphenyl
93-65-2 Mecoprop
94-11-1 2,4-D isopropyl ester
94-36-0 Benzoyl peroxide
94-58-6 Dihydrosafrole
94-59-7 Safrole
94-74-6 Methoxone
((4-Chloro-2-methylphenoxy)
acetic acid) (MCPA)
94-75-7 2,4-D [Acetic acid, (2,4-
dichlorophenoxy)-]
94-80-4 2,4-D butyl ester
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
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
0.1
0.1
1.0
0.1
0.1
0.1
0.1
0.1
1.0
0.1
0.1
0.1
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
11-14 Toxics Release Inventory Reporting Form and Instructions
"C.I. means "Color Index"
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
95-69-2
95-80-7
95-95-4
96-09-3
96-12-8
96-18-4
96-33-3
96-45-7
97-23-4
97-56-3
98-07-7
98-82-8
98-86-2
98-87-3
98-88-4
98-95-3
99-30-9
99-55-8
99-59-2
99-65-0
100-01-6
100-02-7
100-25-4
100-41-4
100-42-5
100-44-7
100-75-4
101-05-3
101-14-4
101-61-1
101-77-9
101-80-4
101-90-6
104-12-1
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
p-Chloro-o-toluidine 0.1
2,4-Diaminotoluene 0.1
2,4,5-Trichlorophenol 1.0
Styrene oxide 0.1
l,2-Dibromo-3-chloropropane 0.1
(DBCP)
1,2,3-Trichloropropane 0.1
Methyl acrylate 1.0
Ethylene thiourea 0.1
Dichlorophene 1.0
[2,2'-Methylenebis(4-chlorophenol)]
C.I. Solvent Yellow 3 1.0
Benzole trichloride 0.1
(Benzotrichloride)
Cumene 1.0
Acetophenone 1.0
Benzal chloride 1.0
Benzoyl chloride 1.0
Nitrobenzene 0.1
Dichloran [2,6-Dichloro-4- 1.0
nitroaniline]
5-Nitro-o-toluidine 1.0
5-Nitro-o-anisidine 1.0
m-Dinitrobenzene 1.0
p-Nitroaniline 1.0
4-Nitrophenol l.o
p-Dinitrobenzene l.o
Ethylbenzene l.o
Styrene 0.1
Benzyl chloride l.o
N-Nitrosopiperidine 0.1
Anilazine 1.0
[4,6-Dichloro-N-(2-chlorophenyl)-
l,3,5-triazin-2-amine]
4,4'-Methylenebis(2-chloro- 0.1
aniline)(MBOCA)
4,4'-Methylenebis(N/N- 0.1
dimethyl)benzenamine
4,4'-Methylenedianiline 0.1
4,4-Diaminodiphenyl ether 0.1
Diglycidyl resorcinol ether 0.1
p-Chlorophenyl isocyanate 1.0
p-Anisidine l.o
2,4-Dimethylphenol 1.0
p-Xylene 1.0
p-Cresol 1.0
1,4-Dichlorobenzene 0.1
p-Chloroaniline 0.1
p-Phenylenediamine 1.0
Quinone 1.0
1,2-Butylene oxide 1.0
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
111-42-2
111-44-4
111-91-1
114-26-1
115-07-1
115-28-6
115-32-2
116-06-3
117-79-3
117-81-7
118-74-1
119-90-4
Epichlorohydrin
1,2-Dibromoethane
(Ethylene dibromide)
1,3-Butadiene
Acrolein
Allyl chloride
1,2-Dichloroethane (Ethylene
dichloride)
Allylamine
Acrylonitrile
Allyl alcohol
Propargyl alcohol
Ethylene glycol
Chloromethyl methyl ether
Vinyl acetate
Methyl isobutyl ketone
Maleic anhydride
m-Xylene
m-Cresol
1,3-Phenylenediamine
0.1
0.1
0.1
l.o
l.o
0.1
l.o
0.1
l.o
1.0
l.o
0.1
0.1
1.0
1.0
l.o
l.o
1.0
Bis(2-chloro-l-methylethyl) ether 1.0
Toluene I.Q
Chlorobenzene l.o
Cyclohexanol l.o
Phenol 1.0
2-Methylpyridine 1.0
Malononitrile l.o
2-Methoxyethanol 1.0
n-Hexane 1.0
trans-l,4-Dichloro-2-butene 1.0
2-Ethoxyethanol l.o
Cyclohexane l.o
Pyridine l.o
Diethanolamine l.o
Bis(2-chloroethyl) ether 1.0
Bis(2-chloroethoxy) methane 1.0
Propoxur l.o
[Phenol, 2-(l-methylethoxy)-,
methylcarbamate]
Propylene (Propene) 1.0
Chlorendic acid 0.1
Dicofol 1.0
[Benzenemethanol, 4-chloro-.alpha.
-4-(chlorophenyl)-.alpha.-
(trichloromethyl)-]
Aldicarb l.o
2-Aminoanthraquinone 0.1
Di(2-ethylhexyl) phthalate 0.1
(DEHP)
Hexachlorobenzene 0.1
3,3'-Dimethoxybenzidine 0.1
*C.I. means "Color Index"
Toxics Release Inventory Reporting Form and Instructions 11-15
-------
CAS Number Chemical Name
De Minimis
Concentration
0.1
CAS Number Chemical Name
De Minimis
Concentration
119-93-7 3,3'-Dimethylbenzidine
(o-Tolidine)
120-12-7 Anthracene
120-36-5 2,4-DP
120-58-1 Isosafrole
120-71-8 p-Cresidine
120-80-9 Catechol
120-82-1 1,2,4-Trichlorobenzene
120-83-2 2,4-Dichlorophenol
121-14-2 2,4-Dinitrotoluene
121-44-8 Triethylamine
121-69-7 N,N-Dimethylaniline
121-75-5 Malathion
122-34-9 Simazine
122-39-4 Diphenylamine
122-66-7 1,2-DiphenyIhydrazine
(Hydrazobenzene)
123-31-9 Hydroquinone
123-38-6 Propionaldehyde
123-63-7 Paraldehyde
123-72-8 Butyraldehyde
123-91-1 1,4-Dioxane
124-40-3 Dimethylamine
124-73-2 Dibromotetrafluoroethane
(Halon 2402)
126-72-7 Tris(2/3-dibromopropyl)
phosphate
126-98-7 Methacrylonitrile
126-99-8 Chloroprene
127-18-4 Tetrachloroethylene
(Perchloroethylene)
128-03-0 Potassium
dimethyldithiocarbamate
128-04-1 Sodium dimethyldithiocarbamate 1.0
128-66-5 CI. Vat Yellow 4
131-11-3 Dimethyl phthalate
131-52-2 Sodium pentachlorophenate
132-27-4 Sodium o-phenylphenoxide
132-64-9 Dibenzofuran
133-06-2 Captan
[lH-Isoindole-l,3(2H)-dione, 3a,
4,7,7a-tetrahydro-2-
[(trichloromethyl)thio]-]
133-07-3 Folpet
133-90-4 Chloramben
[Benzoic acid, 3-amino-2,5-dichloro-]
134-29-2 o-Anisidine hydrochloride 0.1
134-32-7 alpha-Naphthylamine 0.1
135-20-6 Cupferron 0-1
[Benzeneamine, N-hydroxy-N-
nitroso, ammonium salt]
1.0
0.1
1.0
0.1
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
0.1
1.0
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
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
354-11-0
1.0
1.0
1.0
Dipropyl isocinchomeronate
Thiram
Potassium N-methyldithio-
carbamate
Metham sodium (Sodium
methyldithiocarbamate)
Disodium cyanodithioimido-
carbonate
Nitrilotriacetic acid
4,4-Thiodianiline
Ethyl acrylate
Butyl acrylate
Nabam
Thiabendazole
[2-(4-Thiazolyl)-lH-benzimidazole]
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
L_ ^_ _, f
2-Mercaptobenzothiazole
(MET)
Merphos
Monuron
Ethyleneimine (Aziridine)
p-Nitrosodiphenylamine
Calcium cyanamide
Methyl parathion
Naled
Oxydemeton methyl
[S-(2-(Ethylsulfinyl)ethyl) O,O-
dimethyl ester phosphorothioic
acid]
Hydrazine
2,2-Dichloro-l/l,l-trifluoroethane 1.0
(HCFC-123)
Aldrin 1-0
[l,4:5,8-Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro-
l,4,4a,5,8,8a-hexahydro-
(l.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
Bromacil
(5-Bromo-6-methyl-3-(l-methyl-
propyl)-2,4(lH,3H)-pyrimidine-
dione)
alpha-Hexachlorocyclohexane
Diuron
Linuron
Diazinon
Diazomethane
Bromochlorodifluoromethane
(Halon 1211)
l,l,l,2-Tetrachloro-2-fluoro-
ethane (HCFC-121a)
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
II-16 Toxics Release Inventory Reporting Form and Instructions
*C.I. means "ColorIndex"
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
354-14-3
354-23-4
354-25-6
357-57-3
422-44-6
422-48-0
422-56-0
431-86-7
460-35-5
463-58-1
465-73-6
492-80-8
505-60-2
507-55-1
510-15-6
528-29-0
532-27-4
533-74-4
534-52-1
540-59-0
541-41-3
541-53-7
541-73-1
542-75-6
542-76-7
542-88-1
554-13-2
556-61-6
563-47-3
1,1,2,2-Tetrachloro-l- 1.0
fluoroethane (HCFC-121)
l,2-Dichloro-l,l,2- I.Q
trifluoroethane (HCFC-123a)
l-Chloro-1,1,2,2- 1.0
tetrafluoroethane (HCFC-124a)
Brucine 1.0
l,2-Dichloro-l,l,2,3,3- 1.0
pentafluoropropane
(HCFC-225bb)
2,3-Dichloro-l,l,l,2,3- 1.0
pentafluoropropane
(HCFC-225ba)
3,3-Dichloro-l,l,l,2,2- 1.0
pentafluoropropane
(HCFC-225ca)
l,2-Dichloro-l,l,3,3,3- 1.0
pentafluoropropane
(HCFC-225da)
3-Chloro-l,l,l-trifluoropropane 1.0
(HCFC-253fb)
Carbonyl sulfide 1.0
Isodrin 1.0
C.I. Solvent Yellow 34 0.1
(Auramine)
Mustard gas 0.1
[Ethane, l,l'-thiobis[2-chloro-]]
l,3-Dichloro-l,l,2,2,3- i.o
pentafluoropropane
(HCFC-225cb)
Chlorobenzilate 1.0
[Benzeneacetic acid, 4-chloro-.
alpha.-(4-chlorophenyl)-.alpha.-
hydroxy-, ethyl ester]
o-Dinitrobenzene 1.0
2-Chloroacetophenone 1.0
Dazomet l.Q
(Tetrahydro-3,5-dimethyl-2H-
l,3,5-thiadiazine-2-thione)
4,6-Dinitro-o-cresol 1.0
1,2-Dichloroethylene 1.0
Ethyl chloroformate 1.0
2,4-Dithiobiuret 1.0
1,3-Dichlorobenzene 1.0
1,3-Dichloropropylene 0.1
3-Chloropropionitrile 1.0
Bis(chloromethyl) ether 0.1
Lithium carbonate 1.0
Methyl isothiocyanate 1.0
[Isothiocyanatomethane]
3-Chloro-2-methyl-l-propene 0.1
569-64-2
584-84-9
593-60-2
594-42-3
606-20-2
612-82-8
612-83-9
615-05-4
615-28-1
621-64-7
624-18-0
624-83-9
630-20-6
636-21-5
639-58-7
680-31-9
684-93-5
709-98-8
759-73-9
759-94-4
764-41-0
812-04-4
834-12-8
842-07-9
872-50-4
924-16-3
924-42-5
957-51-7
961-11-5
989-38-8
1114-71-2
1120-71-4
1134-23-2
1163-19-5
1313-27-5
C.I. Basic Green 4 1.0
Toluene-2,4-diisocyanate 0.1
Vinyl bromide 0.1
Perchloromethyl mercaptan 1.0
2,6-Dinitrotoluene 0.1
3,3'-Dimethylbenzidine 0.1
dihydrochloride
(o-Tolidine dihydrochloride)
3,3'-Dichlorobenzidine 0.1
dihydrochloride
2,4-Diaminoanisole 0.1
1,2-Phenylenediamine 1.0
dihydrochloride
N-Nitrosodi-n-propylamine 0.1
1,4-Phenylenediamine 1.0
dihydrochloride
Methyl isocyanate 1.0
1,1,1,2-Tetrachloroethane 1.0
o-Toluidine hydrochloride 0.1
Triphenyltin chloride 1.0
Hexamethylphosphoramide 0.1
N-Nitroso-N-methylurea 0.1
Propanil (N-(3,4-Dichlorophenyl) 1.0
propanamide)
N-Nitroso-N-ethylurea 0.1
Ethyl dipropylthiocarbamate 1.0
(EPTC)
l,4-Dichloro-2-butene 1.0
l,l-Dichloro-l,2,2-trifluoroethane 1.0
(HCFC-123b)
Ametryn i.o
(N-Ethyl-N'-(l-methylethyl)-6-
(methylthio)-l,3,5,-triazine-2,4-
diamine)
C.I. Solvent Yellow 14 1.0
N-Methyl-2-pyrrolidone 1.0
N-Nitrosodi-n-butylamine 0.1
N-Methylolacrylamide 1.0
Diphenamid 1.0
Tetrachlorvinphos 1.0
[Phosphoric acid, 2-chloro-l-
(2,4,5-trichlorophenyl)ethenyI
dimethyl ester]
C.I. Basic Red 1 i.o
Pebulate i.o
[Butylethylcarbamothioic acid S-
propyl ester]
Propane sultone 0.1
Cycloate i.o
Decabromodiphenyl oxide 1.0
Molybdenum trioxide 1.0
*C.I. means "Color Index"
Toxics Release Inventory Reporting Form and Instructions 11-17
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
1.0
1.0
0.1
1314-20-1 Thorium dioxide
1319-77-3 Cresol (mixed isomers)
1320-18-9 2,4-D propylene glycol butyl
ether ester
1330-20-7 Xylene (mixed isomers)
1332-21-4 Asbestos (friable)
1335-87-1 Hexachloronaphthalene
1336-36-3 Polychlorinated biphenyls (PCBs) 0.1
1344-28-1 Aluminum oxide (fibrous forms) 1.0
1464-53-5 Diepoxybutane
1563-66-2 Carbofuran
1582-09-8 Trifluralin
[Benezeneamine, 2,6-dinitro-
N,N-dipropyl-4-
(trifluoromethyl)-]
1634-04-4 Methyl tert-butyl ether
1649-08-7 l,2-Dichloro-l,l-difluoroethane
(HCFC-132b)
1689-84-5 Bromoxynil
(3,5-Dibromo-4-
hydroxybenzonitrile)
1689-99-2 Bromoxynil octanoate
(Octanoic acid, 2,6-dibromo-4-
cyanophenyl ester)
1717-00-6 1,1-Dichloro-l-fluoroethane
(HCFC-141b)
1836-75-5 Nitrofen
[Benzene, 2,4-dichloro-l-(4-
nitrophenoxy)-]
1861-40-1 Benfluralin
(N-ButyI-N-ethyl-2,6-dinitro-4-
(trifluoromethyl)benzenamine)
1897-45-6 Chlorothalonil
[1,3-Benzenedicarbonitrile,
2,4,5,6-tetrachloro-]
1910-42-5 Paraquat dichloride
1912-24-9 Atrazine
(6-Chloro-N-ethyl-N'-(l-methyl-
ethyl)-l,3,5-triazine-2,4-diamine)
1918-00-9 Dicamba
(3,6-Dichloro-2-methoxybenzoic
acid)
1918-02-1 Picloram
1918-16-7 Propachlor
[2-Chloro-N-(l-methylethyl)-N-
phenylacetamide]
1928-43-4 2,4-D 2-ethylhexyl ester
1929-73-3 2,4-D butoxyethyl ester
1929-82-4 Nitrapyrin
(2-Chloro-6-(trichloromethyl)-
pyridine)
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1
0.1
1.0
1937-37-7 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
2032-65-7 Methiocarb
2155-70-6 Tributyltin methacrylate
2164-07-0 Dipotassium endothall
[7-Oxabicyclo(2.2.1)heptane-2,3-
dicarboxylic acid, dipotassium
salt]
2164-17-2 Fluometuron
[Urea, N,N-dimethyl-N'-[3-
(trifluoromethyl)phenyl]-]
2212-67-1 Molinate
(IH-Azepine-l-carbothioic acid,
hexahydro-S-ethyl ester)
2234-13-1 Octachloronaphthalene
2300-66-5 Dimethylamine dicamba
2303-16-4 Diallate
[Carbamothioic acid, bis(l-
methyl- ethyl)-S-(2,3-dichloro-
2-propenyl) ester]
2303-17-5 Triallate
2312-35-8 Propargite
2439-01-2 Chinomethionat
[6-Methyl-l,3-dithiolo[4,5-b]-
quinoxalin-2-one]
2439-10-3 Dodine
[Dodecylguanidine monoacetate]
2524-03-0 Dimethyl chlorothiophosphate 1.0
2602-46-2 C.I. Direct Blue 6
2655-15-4 2,3,5-Trimethylphenyl methyl
carbamate
2699-79-8 Sulfuryl fluoride (Vikane)
2702-72-9 2,4-D sodium salt
2832-40-8 C.I. Disperse Yellow 3
2837-89-0 2-Chloro-l,l,l,2-
tetrafluoroethane (HCFC-124)
2971-38-2 2,4-D Chlorocrotyl ester
3118-97-6 C.I. Solvent Orange 7
3383-96-8 Temephos
3653-48-3 Methoxone sodium salt
((4-Chloro-2-methylphenoxy)
acetate sodium salt)
3761-53-3 C.I. Food Red 5
4080-31-3 l-(3-Chloroallyl)-3,5,7-triaza-l-
azoniaadamantane chloride
4170-30-3 Crotonaldehyde
4549-40-0 N-Nitrosomethylvinylamine
4680-78-8 C.I. Acid Green 3
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
1.0
0.1
1.0
1.0
0.1
1.0
1.0
0.1
0.1
1.0
1.0
0.1
1.0
11-18 Toxics Release Inventory Reporting Form and Instructions
*C.I. means "Color Index"
-------
Table II
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
5234-68-4 Carboxin 1.0
(5,6-Dihydro-2-methyl-N-phenyl-
l,4-oxathiin-3-carboxamide)
5598-13-0 Chlorpyrifos methyl 1.0
[O,O-Dimethyl-O-(3,5,6-trichloro-
2-pyridyl)phosphorothioate]
5902-51-2 Terbacil 1.0
[5-Chloro-3-(l,l-dimethylethyl)-
6-methyl-2,4(lH,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-l,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 Sulfuric acid 1.0
(acid aerosols including mists,
vapors, gas, fog, and other
airborne forms of any particle
size)
7696-12-0 Tetramethrin 1.0
[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]
7697-37-2 Nitric acid 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
7726-95-6 Bromine 1.0
7758-01-2 Potassium bromate 0.1
7782-41-4 Fluorine 1.0
7782-49-2 Selenium 1.0
7782-50-5 Chlorine 1.0
7786-34-7 Mevinphos 1.0
7803-51-2 Phosphine 1.0
8001-35-2 Toxaphene 0.1
8001-58-9 Creosote 0.1
9006-42-2 Metiram 1.0
10028-15-6 Ozone 1.0
10034-93-2 Hydrazine sulfate 0.1
10049-04-4 Chlorine dioxide 1.0
10061-02-6 trans-l,3-Dichloropropene 0.1
10294-34-5 Boron trichloride 1.0
10453-86-8 Resmethrin 1.0
[[5-(Phenylmethyl)-3-furanyl]
methyl- 2,2-dimethyl-3-(2-methylr
1-propenyl) cyclopropane-
carboxylate]]
12122-67-7 Zineb 1.0
[Carbamodithioic acid, 1,2-
ethanediylbis-, zinc complex]
12427-38-2 Maneb 1.0
[Carbamodithioic acid, 1,2-
ethanediylbis-, manganese
complex]
13194-48-4 Ethoprop 1.0
[Phosphorodithioic acid O-ethyl
S,S-dipropyl ester]
13356-08-6 Fenbutatin oxide 1.0
(Hexakis(2-methyl-2-
phenylpropyl)distannoxane)
13463-40-6 Iron pentacarbonyl 1.0
13474-88-9 l,l-Dichloro-l,2,2,3,3- 1.0
pentafluoropropane
(HCFC-225cc)
13684-56-5 Desmedipham 1.0
*C.I. means "ColorIndex"
Toxics Release Inventory Reporting Form and Instructions 11-19
-------
Table II
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
14484-64-1
15972-60-8
16071-86-6
16543-55-8
17804-35-2
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
Ferbam 1.0
[Tris(dimethylcarbamodithioato-
S,S')iron]
Alachlor 1.0
C.I. Direct Brown 95 0.1
N-Nitrosonornicotine 0.1
Benomyl 1.0
Oryzalin 1-0
[4-(Dipropylamino)-3,5-
dinitrobenzenesulfonamide]
Oxydiazon 1.0
[3-[2,4-Dichloro-5-(l-methyl-
ethoxy)phenyl]-5-(l,l-dimethyl-
ethyl)-l,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
Metnbuzin 1-0
Cyanazine 1.0
Bendiocarb 1.0
p^-Dimethyl-l/S-benzodioxol-
4-olmethylcarbamate]
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-methylethyl)-
amino]phosphinothioyl]oxy]
benzoic acid 1-methylethyl ester]
Drnitrotoluene (mixed isomers) 1.0
Dichlorobenzene (mixed isomers) 0.1
Diaminotoluene (mixed isomers) 0.1
Phenothrin 1.0
[2,2-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic
acid (3-phenoxyphenyl)methyl
ester]
Toluene diisocyanate 0.1
(mixed isomers)
Sodium azide 1.0
De Minimis
Concentration
1.0
26644-46-2 Triforine
[N,N'-[l,4-Piperazinediylbis
(2,2,2-trichloroethylidene)]
bisformamide]
27314-13-2 Norflurazon 1.0
[4-Chloro-5-(methylamino)-2-
[3-(trifluoromethyl)phenyl]-3(2H)-
pyridazinone]
28057-48-9 d-trans-Allethrin 1.0
[d-trans-Chrysanthemic acid of
d-allethrone]
28249-77-6 Thiobencarb 1.0
[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-dimethyl 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-(l,l-Dimethylethyl)-l,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]
11-20 Toxics Release Inventory Reporting Form and Instructions
*C.I. means "ColorIndex"
-------
CAS Number Chemical Name
De Minimis
Concentration
CAS Number Chemical Name
De Minimis
Concentration
40487-42-1
41198-08-7
41766-75-0
42874-03-3
43121-43-3
50471-44-8
51235-04-2
51338-27-3
51630-58-1
52645-53-1
53404-19-6
53404-37-8
53404-60-7
55290-64-7
55406-53-6
57213-69-1
59669-26-0
Pendimethalin 1.0
[N-(l-Ethylpropyl)-3,4-dimethyl-
2,6-dinitrobenzenamine]
Profenofos 1.0
[O-(4-Bromo-2-chlorophenyl)-O-
ethyl-S-propyl-phosphorothioate]
3,3'-Dimethylbenzidine 0.1
dihydrofluoride (o-Tolidine
dihydrofluoride)
Oxyfluorfen 1.0
Triadimefon 1.0
[l-(4-Chlorophenoxy)-3,3-
dimethyl-l-(lH-l,2,4-triazol-l-yl)-
2-butanone]
Vinclozolin 1.0
[3-(3,5-Dichlorophenyl)-5-
ethenyl-5-methyl-2,4-
oxazolidinedione]
Hexazinone 1.0
Diclofop methyl 1.0
[2-[4-(2,4-Dichlorophenoxy)-
phenoxyjpropanoic acid, methyl
ester]
Fenvalerate 1.0
[4-Chloro-alpha-(l-methylethyl)-
benzeneacetic acid cyano(3-
phenoxyphenyl)methyl ester]
Permethrin 1.0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropane carboxylic
acid, (3-phenoxyphenyl)methyl
ester]
Bromacil, lithium salt 1.0
[2,4(lH,3H)-Pyrimidinedione, 5-
bromo-6-methyl~3-(l-methyl
propyl), lithium salt]
2,4-D 2-ethyl-4-methylpentyl 0.1
ester
Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-
l,3,5-thiadiazine-2-thione, ion(l-),
sodium]
Dimethipin 1.0
dithiin 1,1,4,4-tetraoxide]
3-Iodo-2-propynyl butyl 1.0
carbamate
Triclopyr triethylammonium salt 1.0
Thiodicarb 1.0
60168-88-9
60207-90-1
62476-59-9
63938-10-3
64902-72-3
64969-34-2
66441-23-4
67485-29-4
68085-85-8
68359-37-5
69409-94-5
69806-50-4
71751-41-2
72178-02-0
Fenarimol i.o
[.alpha.-(2-Chlorophenyl)-
.alpha.-4-chlorophenyl)-5-
pyrimidine-methanol]
Propiconazole 1.0
[l-[2-(2,4-Dichlorophenyl)-4-
propyl~l,3-dioxolan-2-yl]-methyl-
1.0
1 0
l.Q
0.1
1.0
1.0
Acifluorfen, sodium salt
[5-(2-Chloro-4-(trifluoromethyl)-
phenoxy)-2-nitrobenzoic acid,
sodium salt]
Chlorotetrafluoroethane
Chlorsulfuron
[2-Chloro-N-[[(4-methoxy-6-
methyl- l,3,5-triazin-2-yl)amino]
carbonyljbenzenesulfonamide]
3,3'-Dichlorobenzidine sulfate
Fenoxaprop ethyl
[2-(4-((6-Chloro-2-benzoxa
zolylen)-oxy)phenoxy)propanoic
acid, ethyl ester]
Hydramethylnon
[Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3-[4-
(trifluoromethyl)phenyl]-l-[2-[4-
(trifluoromethyl)phenyl]ethenyl]-
2-propenylidene]hydrazone]
Cyhalothrin
[3-(2-Chloro-3,3,3-trifluoro-l-
propenyl)-2,2-Dimethylcyclo-
propanecarboxylic acid cyano(3-
phenoxyphenyl) methyl ester]
Cyfluthrin
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic
acid, cyano(4-fluoro-3-
phenoxyphenyl)methyl ester]
Fluvalinate
[N-[2-Chloro-4-(trifluoromethyl)-
phenyl]-DL-valine(+)-cyano(3-
phenoxyphenyl)methyl ester]
Fluazifop buiyl
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic
acid, butyl ester]
Abamectin [Avermectin Bl]
Fomesafen
[5-(2-Chloro-4-(trifluoromethyl)-
phenoxy)-N-methylsulfonyl)-2-
nitrobenzamide]
i.o
1.0
1.0
*C.I. means "ColorIndex"
Toxics Release Inventory Reporting Form and Instructions 11-21
-------
Table II
CAS Number Chemical Name
De Minimis
Concentration
1.0
1.0
1.0
1.0
1.0
1.0
72490-01-8 Fenoxycarb
[[2-(4-Phenoxyphenoxy)ethyl-]
carbamic acid ethyl ester]
74051-80-2 Sethoxydim
[2-[l-(Ethoxyimino)butyl]-5-[2-
(ethylthio)propyl]-3-hydroxyl-2-
cyclohexen-1-one]
76578-14-8 Quizalofop-ethyl
[2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy]
propanoic acid ethyl ester]
77501-63-4 Lactofen
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-
nitro-, 2-ethoxy-l-methyl-2-oxo
ethyl ester]
82657-04-3 Bifenthrin
88671-89-0 Myclobutanil
[.alpha.-Butyl-.alpha.-(4-
chIorophenyl)-lH-l,2,4-triazole-l-
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-
pentafluoropropane (HCFC-
225eb)
111984-09-9 3,3'-Dimethoxybenzidine
hydrochloride (o-Dianisidine
hydrochloride)
127564-92-5 Dichloropentafluoropropane
128903-21-9 2,2-Dichloro-l,l,l,3,3-
pentafluoropropane (HCFC-
225aa)
136013-79-1 l,3-Dichloro-l,l,2,3,3-
pentafluoropropane (HCFC-
225ea)
1.0
0.1
1.0
1.0
1.0
c. Chemical Categories
Section 313 requires reporting on the EPCRA Section
313 chemical categories listed below, in addition to the
specific EPCRA Section 313 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.
EPCRA Section 313 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.
N010 Antimony Compounds (1.0)
Includes any unique chemical substance that
contains antimony as part of that chemical's
infrastructure.
N020 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.
N040 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
N050 Beryllium Compounds (0.1)
Includes any unique chemical substance
that contains beryllium as part of that
chemical's infrastructure.
N078 Cadmium Compounds (0.1)
Includes any unique chemical substance
that contains cadmium as part of that
chemical's infrastructure.
II-22 Toxics Release Inventory Reporting Form and Instructions
*C.I. means "ColorIndex"
-------
Table II
N084 Chlorophenols (0.1)
OH
N090
N096
N100
Where x = 1 to 5
Chromium Compounds (chromium VI
compounds: 0.1; chromium III 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
infrastructure.
Copper Compounds (1.0)
Includes any unique chemical substance that
contains copper as part of that chemical's
infrastructure. This category does not include
copper phthalocyanine compounds that are
substituted with only hydrogen, and/or chlorine,
and/or bromine.
N106 Cyanide Compounds (1.0)
X*CN- where X = H* or any other group where a
formal dissociation may occur. For example
KCNorCa(CN)2.
N120 Diisocyanates (1.0)
This category includes only those chemicals
listed below.
38661-72-2 l,3-Bis(methylisocyanate) -
cyclohexane
10347-54-3 l,4-Bis(methylisocyanate)-
cyclohexane
2556-36-7 1,4-Cyclohexane
diisocyanate
134190-37-7 Diethyldiisocyanatobenzene
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'-Dimethyldiphenyl
methane-4,4'-diisocyanate
822-06-0 Hexamethylene-1,6-
diisocyanate
4098-71-9 Isophorone diisocyanate
75790-84-0 4-Methyldiphenylmethane-
3,4-diisocyanate
5124-30-1 1,1-Methylene bis(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-Oyl 2,2,4-Trimethylhexamethene
diisocyanate
15646-96-5 2,4,4-Trimethylhexa-
methylene diisocyanate
N171 Ethylenebisdithiocarbamic acid, salts and
esters (EBDCs) (1.0)
Includes any unique chemical substance that
contains an EBDC or an EBDC salt as part of
that chemical's infrastructure.
N230 Certain Glycol Ethers (1.0)
R-(OCH2CH2)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.
N420 Lead Compounds (inorganic compounds:
0.1; organic compounds 1.0)
Includes any unique chemical substance that
contains lead as part of that chemical's
infrastructure.
N450 Manganese Compounds (1.0)
Includes any unique chemical substance that
contains manganese as part of that chemical's
infrastructure.
*C.I. means "Color Index"
Toxics Release In ven tory Reporting Form and Instructions 11-23
-------
Table II
N458 Mercury Compounds (1.0)
Includes any unique chemical substance that
contains mercury as part of that chemical's
infrastructure.
N495 Nickel Compounds (0.1)
Includes any unique chemical substance that
contains nickel as part of that chemical's
infrastructure.
N503 Nicotine and salts (1.0)
Includes any unique chemical substance that
contains nicotine or a nicotine salt as part of that
chemical's infrastructure.
N511 Nitrate compounds (water dissociable;
reportable only when in aqueous solution)
(1.0)
N575 Polybrominated Biphenyls (PBBs) (0.1)
H(10-x)
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)pyrene
57-97-6 7,12-Dimethylbenz(a)
anthracene
193-39-5 Indeno[l,2,3-cdlpyrene
3697-24-3 5-Methylchrysene
5522-43-0 1-Nitropyrene
N725 Selenium Compouds (1.0)
Includes any unique chemical substance that
contains selenium as part of that chemical's
infrastructure.
N740 Silver Compounds (1.0)
Includes any unique chemical substance that
contains silver as part of that chemical's
infrastructure.
Where x = 1 to 10
N583 Polychlorinated alkanes (CIO to CIS) (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 mlnimis)
.
where x = 10 to 13;
y = 3 to 12; and
the average chlorine content ranges from 40 -
70% with the limiting molecular formulas
C18HI9C13 and C13H,6C112
N590 Polycyclic aromatic compounds (PACs) (0.1
except for benzo(a)phenanthrene and
dibenzo(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
N746 Strychnine and salts (1.0)
Includes any unique chemical substance that
contains strychnine or a strychnine salt as part of
that chemical's infrastructure.
N760 Thallium Compounds (1.0)
Includes any unique chemical substance that
contains thallium as part of that chemical's
infrastructure.
N874 Warfarin and salts (1.0)
Includes any unique chemical substance that
contains warfarin or a warfarin salt as part of that
chemical's infrastructure.
N982 Zinc Compounds (1.0)
Includes any unique chemical substance that
contains zinc as part of that chemical's
infrastructure.
11-24 Toxics Release Inventory Reporting Form and Instructions
'C.I. means "ColorIndex"
-------
Table III. State Abbreviations
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Commonwealth of 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
Toxics Release Inventory Reporting Form and Instructions III-l
-------
-------
Appendix A. Federal Facility Reporting Information
Special Instructions for TRI Federal
Facility Reporting
Why Do Federal Facilities Need to
Report?
Executive Order 12856, Pollution Prevention and Right-
to-Know Reporting, 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 EPCRA Section 313 and PPA Section 6607 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. Reporting by
the federal facility however does not alter the reporting
obligation of on-site contractors. The "Government
Owned Contractor Operated" (GOCO) facilities must
continue to report TRI data if they are subject to EPCRA
section 313.
Identifying Federal Facility Reports
Federal facility reports are identified as federal by several
indicators on the form. The facility name and parent
company 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. Federal facilities should also complete
the partial or complete facility blocks (Form R page 2,
block 4.2a and 4.2b) as appropriate. 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
prevent duplicate data in the TRI database, which could
result 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
federal reports which contain data for the same site. To
accomplish this, federal facility reports must be
accompanied 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
software, 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
submit magnetic media copies of their GOCO TRI
reports to EPA. Magnetic media reports must be
accompanied by a cover letter which includes:
D Required Form R certification statement;
D List of the chemicals reported on the federal
facility's disk; and
D List, identifying the contractor(s) by name and 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.
Toxics Release Inventory Reporting Forms and Instructions A-l
-------
Aooendix A
Federal facility GOCOs should report their names as
shown in the following example:
U.S. DOE Savannah River Site - Westmghouse
Operations.
How to Report Your Standard
Industrial Classification (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
provided in the Forms and Instructions booklet. The
table on the next page contains Public Administration SIC
codes 91-97 covering executive, legislative, judicial,
administrative and regulatory activities of the Federal
government Government-owned and operated business
establishments 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 - Hospitals.
How to Report Your "Parent Company"
Name
Federal facilities should report their parent company
name on page 2 of the Form Rs (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 parent company name field will classify the report
as federal, and the GOCO may be identified as a non-
reporter.
How to Revise Your Data After It Has
Been Submitted
been sent to EPA. If a federal facility receives a copy of a
revision from a GOCO, the facility should revise the
federal report, and submit the revised report to EPA and
the appropriate state along with an exact copy of the
GOCO's revision. If the revision is to a hardcopy report,
the facility should photocopy the original form, use a
blue or black pen to mark out the incorrect value and
write in the corrected 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 revised submission, not all the chemicals
originally reported. The cover letter must indicate that
the submission is a revision.
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
federal employee on-site. If no federal employee is on-
site, federal Form R reports must be signed by the senior
federal employee with management responsibility for the
site. Federal Form R reports must be signed by a federal
employee. Contractor employee signatures are not
considered valid on federal reports.
More Help is Available!
Federal facilities may call EPA's EPCRA Hotline at (800)
535-0202, (800) 424-9346 or (703) 412-9877 to ask specific
questions concerning how to submit their Form R
reports.
Any TRI Form R submitter may voluntarily revise their
submission if they find errors after their reports have
A-2 Toxics Release Inventory Reporting Forms and Instructions
-------
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
Management
9512 Land, Mineral, Wildlife, and Forest
Conservation
9531 Administration of Housing Programs
9532 Administration of Urban Planning and
Community and Rural Development
96 Administration of Economic
Programs
9611 Administration of General Economic
Programs
9621 Regulation and Administration of
Transportation Programs
9631 Regulation and Administration of
Communications, Electric, Gas, and
Other Utilities
9641 Regulation of Agricultural Marketing
and Commodities
9651 Regulation, Licensing, and Inspection
of Miscellaneous Commercial Sectors
9661 Space Research and Technology
97 National Security and
International Affairs
9711 National Security
9721 International Affairs
Toxics Release Inventory Reporting Forms and Instructions A-3
-------
-------
Appendix B. Reporting Codes For EPA Form R
Form R Part II
Section 1.1. CAS Number
EPCRA Section 313 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
Section 4.
Range Code
01
02
03
04
05
06
07
08
Antimony compounds
Arsenic compounds
Barium compounds
Beryllium compounds
Cadmium compounds
Clorophenols
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)
Polchlorinated alkanes
Polycyclic aromatic compounds
Selenium compounds
Silver compounds
Strychnine and salts
Thallium compounds
Warfarin and salts
Zinc compounds
Maximum Amount of the
EPCRA Section 313 Chemical
On-Site at Any Time During
the Calendar Year
Weight Range in Pounds
From... To....
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
Weight Range in Pounds
Range Code From... To....
09 100,000,000 499,999,999
10 500,000,000 999,999,999
11 1 billion more than 1 billion
Section 5. Releases of the Toxic Chemical
to the Environment On-Site
and
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
measurements for the EPCRA Section 313
chemical as transferred to an off-site facility.
C: Estimate is based on mass balance calculations,
such as calculation of the amount of the EPCRA
Section 313 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
volatilization using published mathematical
formulas) or best engineering judgment. This
would include applying an estimated removal
efficiency to a treatment, even if the composition
of the waste before treatment was fully identified
through monitoring data.
Toxics Release Inventory Reporting Forms and Instructions B-l
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Appendix B
Section 6. Transfers of the Toxic Chemical
in Waste Streams to Off-Site
Locations
Tvpe of Waste Disposal/Treatment/ Enerev
Recovery/Recycling
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
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
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
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
Federal Information Processing Standards
(FIPS) Codes for Transfers of the EPCRA
Section 313 Chemical to Other Countries
This is an abridged list of countries to which a U.S.
facility might ship an EPCRA Section 313 chemical. For
a complete listing of FIPS codes, consult your local
library. To obtain a FIPS code for a country not listed,
contact the EPCRA Hotline.
Country
Argentina
Belgium
Bolivia
Brazil
Canada
Chile
Columbia
Costa Rica
Code
AR
BE
BL
BR
CA
CI
CO
CS
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
B-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
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 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 for
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
Range of Influent Concentration
1 = Greater than 10,000 parts per million (1
percent)
2 = 100 parts per million (0.01 percent) to 10,000
parts per million (1 percent)
3 = 1 part per million (0.0001 percent) to 100 parts
per million (0.01 percent)
4 = 1 part per billion to 1 part per million
5 = Less than 1 part per billion
fNote: 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 mmHg
atmospheric pressure.]
Section 7B. On-Site Energy Recovery
Processes
U01 Industrial Kiln
U02 Industrial Furnace
U03 Industrial Boiler
U09 Other Energy Recovery Methods
Toxics Release Inventory Reporting Forms and Instructions B-3
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Appendix B
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
Section 8.10. Source Reduction Activity
Codes
Good Operating Practices
W13 Improved maintenance scheduling, record
keeping, or procedures
W14 Changed production schedule to minimize
equipment and feedstock changeovers
W19 Other changes in operating practices
Inventory Control
W21 Instituted procedures to ensure that materials
do not stay in inventory beyond shelf-life
W22 Began to test outdated material — continue to
use if still effective
W23 Eliminated shelf-life requirements for stable
materials
W24 Instituted better labeling procedures
W25 Instituted clearinghouse to exchange materials
that would otherwise be discarded
W29 Other changes in inventory control
Spill and Leak Prevention
W31 Improved storage or stacking procedures
W32 Improved procedures for loading, unloading,
and transfer operations
W33 Installed overflow alarms or automatic shut-off
valves
W35 Installed vapor recovery systems
W36 Implemented inspection or monitoring
program of potential spill or leak sources
W39 Other changes made in spill and leak
prevention
Raw Material Modifications
W41 Increased purity of raw materials
W42 Substituted raw materials
W49 Other raw material modifications made
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 drag out
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 products
B-4 Toxics Release Inventory Reporting Forms and Instructions
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Appendix B
W83 Modified packaging
W89 Other product modifications
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)
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
Toxics Release Inventory Reporting Forms and Instructions B-5
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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 and other waste management estimation errors. These
errors result in omission of required EPCRA Section 313 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 EPCRA Section 313 chemical reported.
Some errors on the Form R do not allow the data to be processed. These types of errors are usually facility
identification/ location errors, chemical identification errors, missing pages, invalid Form Rs, magnetic disk processing
errors, or more than one chemical reported per Form R. EPA will issue a Notice of Significant Error (NOSE) or a
Notice of Noncompliance (NON) to facilities with these type 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 (NOTE) 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 EPCRA Section 313 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 that 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 reports.
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.
General Considerations
Q Incomplete Forms. A complete Form R report for a
single EPCRA Section 313 chemical or single EPCRA
Section 313 chemical category consists of five pages
stapled together. EPA cannot enter into the
database data from a package that contains only one
page 1, but several page 2s, 3s, 4s, and/or 5s. Such
forms are considered incomplete submissions.
Threshold Determinations
G Calculating threshold determinations. Annual
quantities manufactured, processed, or otherwise
used for Section 313 chemicals must be calculated,
not surmised. The assumption that thresholds are
exceeded commonly leads to error.
Q Misclassification of EPCRA Section 313 chemical
activity. Failure to correctly classify an EPCRA
Section 313 chemical activity may result in an
incorrect threshold determination. As a result, a Form R
may not be submitted when one is required.
Q EPCRA Section 313 chemical activity overlooked.
Many facilities believe that because the section 313
reporting requirement pertains to manufacturers,
only the use of EPCRA Section 313 chemicals in
manufacturing processes must be examined. Any
activity involving the manufacture, process, or
otherwise use of an EPCRA Section 313 chemical or
chemical category must be included in threshold
determinations. Commonly overlooked activities
include importation of chemicals, generation of
waste byproducts, processing of naturally occurring
metal compounds in ore, manufacturing and
processing of reaction intermediates, the use of
chemicals for cleaning of equipment, and the
generation of byproducts during combustion of coal
and/or oil. Facilities should take a systematic
approach to identify all chemicals ana mixtures
used in production and non-production capacities,
Toxics Release Inventory Reporting Forms and Instructions C-l
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Appendix C
including catalysts, well treatment chemicals, and
wastewater treatment chemicals.
Q Reporting EPCRA Section 313 chemicals in
mixtures and other trade name products. EPCRA
Section 313 chemicals contained in mixtures
(including ores and stainless steel alloys) and other
trade name products must be factored into
threshold determinations and release and other
waste management determinations, provided that
the de minlmis exemption cannot be taken. When the
EPCRA Section 313 chemical being reported is a
component in a mixture or other trade name
product, report only the weight of the EPCRA
Section 313 chemical in the mixture. Refer to Section
B.4b of this document to calculate the weight of an
EPCRA Section 313 chemical in a mixture or other
trade name product.
Q Reporting coincidental manufacturing.
Coincidental manufacturing must not be
overlooked. If coal and/or fuel oil and other raw
materials that contain EPCRA Section 313 chemicals
are used in boilers/burners, there is a potential for
the coincidental manufacture of EPCRA Section 313
chemicals such as sulfuric acid (acid aerosols),
hydrochloric acid (acid aerosols), hydrogen
fluoride, and metal compounds. Additionally,
manufacturing of EPCRA Section 313 chemicals
during waste treatment is commonly overlooked.
For example, the treatment of nitric acid may result
in the coincidental manufacturing of a reportable
chemical (nitrate compounds).
Container Residue
Q Overlooking container residue. Container residue
must not be disregarded in release and other waste
management calculations. Even a "RCRA empty"
drum is expected to contain a residue and it must be
considered for TRI reporting. Additionally, on-site
drum rinsing and disposal of the rinsate will result
in a release and other waste management activity.
Refer to "Estimating Releases and Waste Treatment
Efficiencies for Toxic Chemical Reporting Forms."
Part I. Facility Identification
Information
Section 1. Reporting Year
Q Invalid Forms. The correct version of the form for
the reporting year in question must be used. Forms
provided for reporting years 1987-1990 must not be
used to report data for reporting years 1991-1995.
Form Rs provided for reporting years 1987-1995
must not be used to report data for years 1996 and
later.
Section 2. Trade Secret Information
Q Incorrect completion of trade secret information.
The responses to trade secret questions in Part I
Section 2 and Part II Section 1.3 of Form R/Form A
must be consistent. If trade secrecy is indicated, a
sanitized Form R/Form A and two trade secret
substantiations (one sanitized) must be submitted in
the same package as the trade secret Form R/Form
A. Part II Section 1.3 should be blank if no trade
secret claim is being made.
Section 3. Certification
Q Missing certification signature. An original
certification signature must appear on page 1 of
every Form R/Form A submitted to EPA.
Section 4. Facility Identification
Q Incorrect latitude and longitude coordinates.
Latitude and longitude coordinates are important
data on the Form R/Form A. These coordinates
must be determined using the correct map and
correct measurement techniques and reported in
degrees, minutes, and seconds. For additional
guidance, see Appendix E of this document.
Q "Questionable" entries. Incorrect entries may
require corrections to be made by the facility.
Questionable entries may include:
Missing or incorrect street address;
Missing or incorrect ZIP codes;
Missing County names;
Invalid SIC codes;
Missing or invalid Dun and Bradstreet numbers;
Missing or invalid RCRA, NPDES, or UIC
C-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix C
numbers; and
• Incomplete off site and POTW information
(e.g., missing city name)
If amounts are reported in units other than pounds (e.g.,
metric units) or with exponential numbers, EPA may
require a revision of the Form R/Form A submitted.
Part II. Chemical-Specific
Information
Section 1. Toxic Chemical Identity
Q Reporting chemical abstract service (CAS)
numbers in Section 1.1. Beginning with the 1991
reporting year, EPA has assigned alphanumeric
category codes to the twenty chemical categories for
the purposes of reporting the CAS number field in
Section 1.1. When completing a Form R for a
chemical category, the appropriate code for that
category must be provided in Section 1.1. The CAS
numbers are listed in Table II: "Section 313 Toxic
Chemical List," and if needed, the category codes
are listed in Appendix B: "Reporting Codes for EPA
FormR." Category guidance documents are listed in
the Chemical and Industry Guidance Documents
section in this document.
Q Failure to check for synonyms. Some reportable
chemicals (especially glycol ethers and toluene
diisocyanates) have many synonyms that do not
readily imply they are in the category. For example,
"benzene,l,3-diisocyanatomethyl" may not be
readily recognized as "toluene diisocyanate (mixed
isomers)."
Ul Invalid chemical identification in Section 1.2. The
CAS number and the chemical name reported here
must exactly match the listed official Section 313
CAS number and EPCRA Section 313 chemical
name.
Q Failure to consider an EPCRA Section 313 chemical
qualifier. Only EPCRA Section 313 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 EPCRA
Section 313 chemical list with the qualifier
"manufacturing- strong acid process, no supplier
notification." Thus, the ONLY facilities that should
report this EPCRA Section 313 chemical are those
that manufacture isopropyl alcohol by the strong
acid process.
Ul Generic chemical name in Section 1.3. A generic
chemical name should only be provided if the
Section 313 chemical identity is claimed as a trade
secret.
Section 2. Mixture Component Identity
Q Identifying chemicals used in mixtures. Facilities
must carefully review the most recent MSDS or
supplier notification for every mixture brought on
site to identify all Section 313 chemicals used during
a reporting year. Although some mixtures may not
have MSDSs, the best readily available information
should be used to determine the presence of EPCRA
Section 313 chemicals in ores and alloys.
Q Mixture names in Section 2.1. Mixture names are
to be entered here only if the supplier is claiming the
identity of the EPCRA Section 313 chemical a trade
secret and that is the sole identification. Mixture
names that include the name or CAS number of one
or more EPCRA Section 313 chemicals are not valid
uses of the mixture name field.
Section 3. Activities and Uses of the Toxic
Chemical at the Facility
Ul Reporting EPCRA Section 313 chemical activity.
EPCRA Section 313 chemical activity is commonly
overlooked or misclassified. Any activity involving
the manufacture, process, or otherwise use of an
EPCRA Section 313 chemical must be examined.
For example, waste treatment operations otherwise
use EPCRA Section 313 chemicals to treat waste
streams and may coincidentally manufacture an
additional EPCRA Section 313 chemical as a result
of the treatment reaction. Such activity must be
considered. Further, EPCRA Section 313 chemical
activity must be correctly classified as either
"manufactured," "processed," or "otherwise used."
Section 3.1 "Manufacture"means to produce,
prepare, compound, or import an
EPCRA Section 313 chemical.
Section 3.2 "Process" means the preparation of an
EPCRA Section 313 chemical after its
manufacture, which incorporates the
EPCRA Section 313 chemical into the
Toxics Release Inventory Reporting Forms and Instructions C-3
-------
Appendix C
final product,
commerce.
for distribution in
Section 3.3
"Otherwise use" encompasses any use of
an EPCRA Section 313 chemical that
does not fall under the terms
"manufacture" or "process," and
includes treatment for destruction,
stabilization (without subsequent
distribution in commerce), disposal, and
other use of an EPCRA Section 313
chemical, including an EPCRA Section
313 chemical contained in a mixture or
other trade name product. Otherwise
use of an EPCRA Section 313 chemical
does not include isposal, stabilization
(without subsequent distribution in
commerce), or treatment for destruction
unless:
1. The EPCRA Section 313 chemical that was
disposed, stabilized, or treated for destruction
was received from off site for the purposes of
further waste management; or
2. The EPCRA Section 313 chemical that was
disposed, stabilized, or treated for destruction
was manufactured as a result of waste
management activities on materials received
from off site for the purposes of further waste
management activities.
For example, solvents in paint applied to a manufactured
product are often misclassified as processed, instead of
otherwise used. Because the solvents are not
incorporated into the final product, the solvent is being
otherwise used, not processed. Such situations must be
interpreted accurately.
Section 4. Maximum Amount of the Toxic
Chemical On-Site at any Time
During the Calendar Year
Q Maximum amount on site left blank. The
appropriate code is required in this field.
Section 5. Quantity of the Toxic Chemical
Entering Each Environmental
Medium On Site
single building vent. Additionally, stack emissions
from storage tanks, including loading, working, and
breathing losses from tanks, must not be overlooked
or reported as fugitive emissions.
Q Overlooking some releases to land. Section 313
chemicals placed in stockpiles or in surface
impoundments should be reported as a "release to
land" even if no Section 313 chemicals leak from
these sources. Quantities of Section 313 chemicals
land-treated should be reported as a "release to
land."
Section 6. Transfers of the Toxic Chemical
in Wastes to Off-site Locations
Q Reporting discharges to POTWs in Section 6.1.
When quantities of a listed mineral acid are
neutralized to a pH of 6 or greater, the quantity
reported as discharged to a POTW should be
reported as zero. It is incorrect to enter "NA" (Not
Applicable), in such a situation.
Q Reporting other off-site transfers in Section 6.2.
Any quantities reported in Sections 8.1,8.3,8.5, and
8.7 as sent off site for disposal, treatment, energy
recovery, or recycling, respectively, must also be
reported in Section 6.2 along with the receiving
location and appropriate off-site activity code.
Section 7 A. On-Site Waste Treatment
Methods and Efficiency
Q Failure to report waste treatment methods in
Section 7A. Waste treatment methods used to treat
waste streams containing EPCRA Section 313
chemicals, and the efficiencies of these methods,
must be reported on Form R. Information must be
entered for all waste streams, even if the waste
treatment method does not affect the EPCRA
Section 313 chemical. If no waste treatment is
performed on waste streams containing the EPCRA
Section 313 chemical, the box marked "Not
Applicable" in Section 7 A must be checked on Form
R.
Section 7B. On-Site Energy Recovery
Processes
Q Incorrectly reporting stack emissions. Fugitive
emissions from general indoor air must not be
reported as stack emissions when released from a
C-4 Toxics Release Inventory Reporting Forms and Instructions
Incorrect reporting of waste treatment methods in
Section 7A. The type of waste stream, influent
-------
Appendix C
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 removal. The waste
treatment codes are listed in Appendix B:
"Reporting Codes for EPA Form R," of the Toxic
Chemical Release Inventory Reporting Forms and
Instructions.
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.
Section 7C. On-Site Recycling Processes
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 recovery method must
be reported in Section 7C, and vice versa.
Section 8. Source Reduction and Recycling
Activities
This section is mandatory. Under no circumstances
should a reporting facility leave Section 8 entirely blank,
even if the facility does not engage in source reduction or
recycling activities.
Q Columns C and D, the future year projections for
questions 8.1 through 8.7, must be completed. EPA
expects a reasonable estimate for the future year
projections. Zero can be used in columns C and D to
indicate that the manufacture, process, or otherwise
use of the chemical will be discontinued. In such
cases, columns C and D for Section 8.1 through 8.7
must all contain zeroes.
Q It is incorrect to use range codes to report quantities
in Section 8. Range codes can be used only in Section
5 and Section 6 of Form R.
Q It is incorrect to use the same codes from Section 4
for reporting the maximum amount of the reported
EPCRA Section 313 chemical on site to report
quantities in Section 8.
Ul Quantities reported in Section 8.1 through Section
8.7 are mutually exclusive and additive. This means
that quantities of the reported EPCRA Section 313
chemical must not be double-counted in Section 8.1
through Section 8.7.
Q Some double-counting errors have been due to
confusion over the differences in how on-site
treatment of an EPCRA Section 313 chemical is
reported in Section 7A as compared to Section 8. In
Section 7A, information on the treatment of waste
streams containing the EPCRA Section 313 chemical
is reported, along with the percent efficiency in
terms of destruction or removal of the EPCRA
Section 313 chemical from each waste stream. In
Section 8, only the quantity of the EPCRA Section 313
chemical actually destroyed through the treatment
processes reported in Section 7A is reported in
Section 8.6 to avoid double-counting within Sections
8.1 through 8.7.
Q Quantities reported in Sections 8.1 through 8.7 must
not be reported in Section 8.8 and vice versa.
Q Any time a reported EPCRA Section 313 chemical is
contained in a waste, and the waste is associated
with routine production-related activities and is
recycled, combusted for energy recovery, treated,
disposed, or otherwise released either on- or off-site,
that quantity of the EPCRA Section 313 chemical
must be included in the quantities reported in
Sections 8.1 through 8.7.
Q Reporting quantities in Section 8.1 "Quantity
released". Quantities of EPCRA Section 313
chemicals that are released (including disposed) on
site and reported in Section 5 of Form R must be
reported in Section 8.1. Quantities of EPCRA Section
313 chemicals transferred off site for the purposes of
disposal reported in Section 6.2 must appear in
Section 8.1 using the following codes:
Q M10 Storage Only;
Q M41 Solidification/Stabilization — Metals and
Metal Compounds Only;
Q M62Wastewater Treatment (excluding POTW)-
Metals and Metal Compounds Only;
Q M71 Underground Injection;
Q M72 Landfill/Disposal Surface Impoundment;
Q M73 Land Treatment;
Q M79 Other Land Disposal;
Q M90 Other Off-Site Management; and
Q M94 Transfer to Waste Broker — Disposal
Q M99 Unknown.
Metals and metal compounds transferred off site to
POTWs in Section 6.1 must appear in Section 8.1. To
report correctly in Section 8.1, a facility must include
quantities that are released to the environment,
either on site or off site, excluding releases due to
Toxics Release Inventory Reporting Forms and Instructions C-5
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Aooendix C
catastrophic events or non-production
activities.
related
Q
Q
§8.1 = §5 + §6.1 (metals and metal compounds only)
+§6.2 (disposal only) - §8.8 (on-site or off-site
release due to catastrophic events)2
Reporting quantities in Section 8.2 "Quantity used
for energy recovery on site". A quantity must be
reported in Section 8.2 for the current (reporting)
year when a method of on-site energy recovery is
reported in Section 7B, and vice versa. An error
facilities make when completing Form R is to report
the methods of energy recovery used on -site in
Section 7B but not report the total quantity
associated with those methods. Another error is to
report a quantity in this section if the combustion of
the EPCRA Section 313 chemical took place in a
system that did not recover energy (e.g., an
incinerator). A quantity of the EPCRA Section 313
chemical combusted for energy recovery must not
be reported if the EPCRA Section 313 chemical does
not have a significant heating value. Examples of
EPCRA Section 313 chemicals that do not have
significant heating values include metals, metal
compounds, and halons. Metals and metal portions
of metal compounds will never be treated or
combusted for energy recovery. Section 8.2 must
not include any quantities of the EPCRA Section 313
chemical associated with non-production related
activities, such as catastrophic releases and remedial
actions, as well as other one-time events not
associated with routine production practices, that
were combusted for energy recovery on site.
Reporting quantities in Section 8.3 "Quantity used
for energy recovery off site". As in Section 8.2, a
quantity must not be reported in this section if the
off-site combustion of the EPCRA Section 313
chemical took place in a system that did not recover
energy (e.g., incinerator). A quantity of an EPCRA
Section 313 chemical must not be reported as sent
off site for the purposes of energy recovery if the
EPCRA Section 313 chemical does not have a
significant heating value. Examples of EPCRA
Section 313 chemicals that do not have significant
heating values include metals, metal compounds,
and halons. Metals and metal portions of metal
compounds will never be treated or combusted for
energy recovery. Quantities must be reported 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:
Q M56 Energy Recovery
Q M92 Transfer to Waste Broker -
Recovery
Energy
§8.3 = §6.2 (energy recovery) - §8.8 (off-site
energy recovery due to catastrophic
events)2
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
the total quantity recovered using those methods.
In addition, only the amount of the chemical that
was actually recovered is to be reported in Section
8.4. Any quantities of the EPCRA Section 313
chemical associated with non-production related
activities such as catastrophic releases and remedial
actions, as well as other one-time events not
associated with routine production practices that
were recycled on site must not be included in
Section 8.8.
Reporting quantities in Section 8.5. "Quantity
recycled off site". Quantities reported in Section 6.2
as transferred off site for the purposes of recycling
must be included in Section 8.5 using the following
codes:
Q M20 Solvents/Organic Recovery;
Q M24 Metals Recovery;
Q M26 Other Reuse or Recovery;
Q M28 Acid Regeneration;
Q M93 Transfer to Waste Broker — Recycling.
Quantities that are actually recycled at an off-site
facility must not be reported in Section 8.5 —
facilities should report the quantity that was sent
off site for the purposes of recycling.
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling due
to catastrophic events)2
1 §8.8 includes quantities of toxic chemical released on site
or managed as waste off site due to remedial actions, catastrophic
events, or one-time events not associated with the production
processes.
C-6 Toxics Release Inventory Reporting Forms and Instructions
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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 Section 7A and Section 8 is different.
Information on how waste streams containing the
reported EPCRA Section 313 chemical are treated is
reported in Section 7A, while the quantity of the
EPCRA Section 313 chemical actually destroyed as
a result of on-site treatment is reported in Section
8.6. If a quantity is reported in Section 8.6, Section
7A must be completed but the reverse may not be
true. This may result in apparent discrepancies
between Section 7A and Section 8. For example, a
facility may treat wastewater containing an EPCRA
Section 313 chemical by removing the EPCRA
Section 313 chemical and then disposing of it on site.
The treatment of the wastewater would be reported
in Section 7A, with an efficiency estimate based on
the amount of the EPCRA Section 313 chemical
removed from the wastewater. Although the waste
stream has been treated because the EPCRA Section
313 chemical has been removed, the EPCRA Section
313 chemical has not been treated because it has not
been destroyed. The facility would report only the
amount of the EPCRA Section 313 chemical actually
destroyed during treatment in Section 8.6 and the
amount ultimately disposed in Section 8.1 to avoid
double-counting the same quantity in Section 8. In
cases where the EPCRA Section 313 chemical is not
destroyed during a treatment process and
subsequently enters another activity, such as
disposal (e.g., metals removed from wastewater and
subsequently disposed on site), the quantity of the
EPCRA Section 313 chemical would be reported as
disposed in Section 8.1, not as treated in Section 8.6.
Quantities of the EPCRA Section 313 chemical
associated with non-production related activities
such as catastrophic releases and remedial actions,
as well as one-time events not associated with
routine production practices, that were treated on
site, must not be included in Section 8.6. Metals will
never be treated or combusted for energy recovery.
Reporting quantities in Section 8.7 "Quantity
treated off site". Quantities reported in Section 6.2
as transferred off site for the purposes of treatment
must be included in Section 8.7 using the following
codes:
a
a
a
M50 Incineration/Thermal Treatment;
M54 Incineration/Insignificant Fuel Value;
M61 Wastewater Treatment (excluding
POTW);
M69 Other Waste Treatment; and
Q M95 Transfer to Waste Broker - Waste
Treatment.
Quantities of an EPCRA Section 313 chemical,
except metals and metal compounds, sent off site to
a POTW should also be reported in Section 8.7.
To report correctly EPCRA Section 313 chemicals in
Section 8.7, use the following equation.
§8.7 = §6.1 (excluding metal/metal compounds)
+ §6.2 (treatment) - §8.8 (off-site treatment
due to catastrophic events)3
Q Reporting quantities in Section 8.8 "Quantity
released to the environment as a result of
remedialactions catastrophic events or one-time
events not associated with production processes".
The quantities that are reported in Section 8.8 are
associated with non-production related activities
such as catastrophic releases and remedial actions,
as well as one-time events not associated with
routine production practices, that were released
directly to the environment or transferred off site
for the purposes of recycling, energy recovery,
treatment or disposal. Quantities reported in
Section 8.8 must not be reported in Section 8.1
through Section 8.7.
Q Reporting the production ratio in Section 8.9. A
production ratio or activity index must be provided
in Section 8.9. A zero is not acceptable and "NA"
(Not Applicable) can be used only when the
reported EPCRA Section 313 chemical was not
manufactured, processed, or otherwise used in the
year prior to the reporting year.
Q Calculating production ratio in Section 8.9. In
calculating a production ratio for "otherwise used"
chemicals, an activity index must be used rather
than quantities purchased or released from year to
year.
Ul Reporting Source reduction activities in Section
8.10. It is an error to report a source reduction
activity in Section 8.10 and not report at least one
method used to identify that activity and vice
versa.
§8.8 includes quantities of toxic chemical released on site or
managed as waste off site due to remedial actions, catastrophic events,
or one-time events not associated with the production processes.
Toxics Release Inventory Reporting Forms and Instructions C-7
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Aooendix C
Toxic Release Inventory Notices
Notices of Data Change (NDCs). NDCs correct data
quality errors that are not technical or scientific. For
example, if a facility transposes CAS numbers (the
submitter lists 7623-00-0 for sodium nitrite instead of
7632-00-0), the EPCRA Reporting Center (RC) will send
a notice to the facility indicating that the number has
been corrected. If a facility lists a specific glycol ethers
subcategory, the EPCRA RC will replace this subcategory
with the reportable name "certain glycol ethers." If a
facility submits a non-reportable chemical, the EPCRA
RC will file the form as a miscellaneous submission and
inform the facility.
Notices of Significant Error (NOSEs). NOSEs are sent
to submitters for the following types of errors (see listing,
below). These errors will prevent data from being
entered into the system.
1. You have submitted your Toxic Chemical Release
Inventory report on an invalid form by using either
the form not applicable for the reporting year, or a
facsimile form that has not been approved by EPA.
2. You have submitted an incomplete Toxic Chemical
Release Inventory Form. All pages of the form must
be completed and resubmitted to EPA.
3. You have provided incomplete facility identification
information.
4. You have either left the chemical identification
blank, or the CAS number you reported is not listed
on the Section 313 list of toxic chemicals.
5. You have provided a valid CAS number and a valid
chemical name, but they do not match.
6. You have provided a valid CAS number, but the
chemical name you provided is not a Section 313
chemical name or recognized synonym.
7. You have reported for multiple chemicals in one
Form R report.
Notices of Noncompliance (NONs). NONs are issued
for the same exact errors as NOSEs (see NOSE errors,
above). If a facility does not respond to a NOSE within
21 days, EPA will issue a NON. NONs are the only
notices that are not issued by the TRI Information
Management Branch of the Office of Pollution Prevention
and Toxics, but rather by the Office of Enforcement and
Compliance Assurance (OECA). If there is no response
to the NON, then OECA is informed.
Notices of Technical Error (NOTEs). NOTEs are issued
to submitters for errors that allow data to be entered into
the system, but these errors can skew any analyses if they
are not corrected.
101. You mustsign the form and date the signature, part
I, section 3.
102. You must enter the name and telephone number of
the technical contact for the facility in part I, section
4.3.
103. For each receiving stream in part II, section 5.3, you
must enter an estimate of the release or "NA" in
column A.
104. You must list the name of the receiving stream for
each release in part II, section 5.3, column A.
105. You must list the name and location of the POTW
for the discharge reported in part II, section 6.1 .A.I.
"NA" is not acceptable.
106. For total discharges of this chemical to POTWs
listed in part II, section 6.1.B, you must enter an
estimate of the total discharge or "NA" in part II,
section 6.1 .A.I.
107. You must list the name and location of the other off
site(s) for the transfer(s) of waste indicated in part
II, section 6.2.A. "NA" is not acceptable.
108. For each other off site listed in part II, section 6.2,
you must enter at least one estimated transfer or
"NA" in column A.
109. You did not enter any information in part II, section
8.1 - 8.7. you must enter an estimate," 0", or "NA" in
each box for section 8.1 - 8.7, columns A,B,C,& D.
110. You must enter a non-negative estimate for any
quantity reported in columns A through D of part
II, section 8.1 through 8.7.
111. You must enter either a non-negative value or zero
for part II, section 8.8, "quantity released as a result
of remedial actions, catastrophic events, or one
time-events not associated with production
processes."
112. You did not correctly complete part II section 8.9.
You must enter a non-negative, non-zero
"production ratio or activity index" for this
chemical. See the instructions for calculation of this
ratio. If the manufacture, process, or use of the
reported chemical began during the current
reporting year, enter "NA".
117. You did not correctly complete part II, section 6.2,
column C, "type of treatment/disposal/etc." For
each off-site transfer, you must enter the treatment,
C-8 Toxics Release Inventory Reporting Forms and Instructions
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recycling, energy recovery, or disposal code for the
method used. See the Form R instructions for valid
codes.
201. You either did not provide a standard industrial
classification (SIC) code to identify the activities
occurring at your facility or you provided an invalid
code(s) (part I, section 4.5). Non-federal facilities
must provide at least one valid primary four-digit
SIC code between 20(00) and 39(99).
202. You did not correctly complete part I, section 4.6,
latitude and longitude for your facility. "NA" is not
an acceptable entry. Latitude and longitude should
be seven digits with leading and/or trailing zeroes.
The 48 contiguous U.S. states have latitudes ranging
(south to north) from 24 degrees 33 minutes 00
seconds to 48 degrees 23 minutes 00 seconds and
longitudes (east to west) from 66 degrees 57 minutes
00 seconds to 124 degrees 44 minutes 00 seconds
respectively. Please consult Form R, appendix E
and instructions.
212. You did not indicate in part II, section 3 which
activity(ies) and use(s) of the EPCRA Section 313
chemical occur at your facility. Check at least one.
213. You did not complete part II, section 4. You must
enter the "maximum amount of chemical on site at
any time during the calendar year". Report the
maximum amount as a two digit code. See the
instructions for valid codes.
214. You did not complete part II, sections, "Quantityof
the Toxic Chemical Entering each Environmental
Medium On Site." If you did not release the
chemical to the environment, enter "0" or "NA" as
appropriate for each release type.
215. You did not complete part II, section 6.1,
"discharges to POTW." If you did not discharge the
chemical in waste water to a POTW(s), enter "NA"
• in section 6.I.A.I or section 6.I.B.I.
216. You did not complete part II, section 6.2, "Transfers
to Other Off- site Locations." If you did not transfer
the chemical in waste to other off-site locations,
enter "NA" in section 6.2, the first off-site EPA
identification number (RCRA ID No.) and/or
off-site location name.
217. You incorrectly completed part II, section 6.2
column C "Type of Waste Treatment / Disposal /
Recycling / Energy Recovery." For each off-site
transfer, you must enter the treatment, recycling,
energy recovery, or disposal code for the method
used. See the instructions for valid codes.
218. You did not enter any information in part II, section
7A, "On-site Waste Treatment Methods and
Efficiency." If you do not treat wastes containing
the EPCRA Section 313 chemical at your facility,
check "NA."
220. You must enter either a zero or a non-negative
value for an estimate in part II, section 5 or for an
off-site transfer in part II, section 6.
221. You did not enter any information in part II, section
7B, "On-site Energy Recovery Processes" or in part
II, section 7C "On-site Recycling Processes." You
must enter at least one method code or check " NA"
in each section.
222. You did not complete column B in part II, section
8.1. You must enter an estimate, "NA", or "0" in
this column.
223. You did not complete column B in part II, section
8.2. You must enter an estimate, "NA", or "0" in
this column.
224. You did not complete column B in part II, section
8.3. You must enter an estimate, "NA", or "0" in
this column.
225. You did not complete column B in part II, section
8.4. You must enter an estimate, "NA", or "0" in
this column.
226. You did not complete column B in part II, section
8.5. You must enter an estimate, "NA", or "0" in
this column.
227. You did not complete column B in part II, section
8.6. You must enter an estimate, "NA", or "0" in
this column.
228. You did not complete column B in part II, section
8.7. You must enter an estimate, "NA", or "0" in
this column.
239. You did not complete part 1, section 4.2.C. If your
facility is a federal facility, please check the 'federal
facility' box.
244. If you report releases in part II, section 5 and/or off
site transfer in section 6.2 and/or quantities
transferred off site to POTWs in section 6.1, you
must report an estimate in part II, section 8.1
through 8.7 column B and/or section 8.8.
Toxics Release Inventory Reporting Forms and Instructions C-9
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245. If you enter an estimate in part II, section 8.1
through 8.7, column B and/or section 8.8, you must
also report releases in part II, section 5 and/or off
site transfers in section 6.2 and/or quantities
transferred off site to POTWs in section 6.1 and/or
more waste treatment, energy recovery, or recycling
codes in section 7.
318. You entered an invalid energy recovery method
code in part II, section 7B, "On-site Energy Recovery
Processes." The code consists of a "U" followed by
two digits. See appendix B of the Form R and
instructions for valid codes.
319. You entered an invalid recycling code in part II,
section 7C, "On-site Recycling Processes." The code
consists of an "R" followed by two digits. See
appendix B of the Form R and instructions for valid
codes.
321. If you enter an estimate in part II, section 8.2,
column B, "Quantity Used for Energy Recovery On
Site," you must enter one or more energy recovery
codes in part II, section 7B.
322. If you enter an "On-site Energy Recovery Process"
code in part II, section 7B, you must enter an
estimate of the quantity used for energy recovery in
part II, section 8.2, column B.
325. If you enter an estimate in part II, section 8.4,
column B "Quantity Recycled On Site", you must
enter one or more recycling codes in part II, section
7C.
326. If you enter one or more on-site recycling process
codes in part II, section 7C. You must enter an
estimate in part II, section 8.4, column B, "Quantity
Recycled On Site."
329. If you enter an estimate in part II, section 8.6,
column B "Quantity Treated On Site", you must
complete part II, section 7A "On-site Waste
Treatment Methods and Efficiency." "NA" is not an
acceptable entry.
332. You have entered an invalid code in part II, section
8.10.1-4. "Source Reduction Activity" codes consist
of the letter "W" followed by two digits. See
appendix B of the appropriately dated Form R and
instructions for valid codes.
341. You have not correctly completed part II, section
8.10.1. If you enter one or more "Methods to
Identify Activity" code in part II, section 8.10.1 (A -
C), you must also enter the associated "Source
C-10 Toxics Release Inventory Reporting Forms and Instructions
Reduction Activity " code, which consist of the
letter "W" followed by two digits. See Appendix B
of the instructions for valid codes. If your facility
did not undertake any source reduction activities,
enter "NA" in the first column of section 8.10.1.
342. You have not correctly completed part II, section
8.10.2. If you enter one or more "Methods to
Identify Activity" code in part II, section 8.10.2 (A
- C), you must also enter the associated "Source
Reduction Activity " code, which consist of the
letter "W" followed by two digits. See appendix B
of the instructions for valid codes. If your facility
did not undertake any source reduction activities,
enter "NA" in the first column of section 8.10.2.
343. You have not correctly completed part II, section
8.10.3. If you enter one or more "Methods to
Identify Activity" code in part II, section 8.10.3 (A
- C), you must also enter the associated "Source
Reduction Activity " code, which consist of the
letter "W" followed by two digits. See appendix B
of the instructions for valid codes. If your facility
did not undertake any source reduction activities,
enter "NA" in the first column of section 8.10.3.
344. You have not correctly completed part II, section
8.10.4. If you enter one or more "Methods to
Identify Activity" code in part II, section 8.10.4 (A
- C), you must also enter the associated "Source
Reduction Activity " code, which consist of the
letter "W" followed by two digits. See appendix B
of the instructions for valid codes. If your facility
did not undertake any source reduction activities,
enter "NA" in the first column of section 8.10.4.
346. You did not complete columns A, C, or D in part II,
section 8.1. You must enter an estimate, "NA", or
"0" in each column.
347. You did not complete columns A, C, or D in part II,
section 8.2. You must enter an estimate, "NA", or
"0" in each column.
348. You did not complete columns A, C, or D in part II,
section 8.3. You must enter an estimate, "NA", or
"0" in each column.
349. You did not complete columns A, C, or D in part II,
section 8.4. You must enter an estimate, "NA", or
"0" in each column.
350. You did not complete columns A, C, or D in part II,
section 8.5. You must enter an estimate, "NA", or
"0" in each column.
-------
^^^^^^^^^""•"^^^"••^^^^^••^^^^••^^^^•^^^^^•MI^^^^BB^^M
351. You did not complete columns A, C, or D in part II, 352. You did not complete columns A, Q or D in part II
section 8.6. You must enter an estimate, "NA", or section 8.7. You must enter an estimate, "NA" or
"0" in each column. "0" in each column.
Release Value Reports are sent out for each form that is
submitted. They display all the release and other waste
management values for the submitter's own review.
Toxics Release Inventory Reporting Forms and Instructions C-ll
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idl!.
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Appendix D. Supplier Notification Requirements
Because manufacturers reporting under section 313 must
know the EPCRA Section 313 chemical composition of
the products they use to be able to accurately calculate
releases, EPA requires some suppliers of mixtures or
other trade name products containing one or more of the
EPCRA section 313 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 Classification
[SIC] codes 20-39;
(2) You manufacture, import, or process an EPCRA
Section 313 chemical; and
(3) You sell or otherwise distribute a mixture or other
trade name product containing the EPCRA Section
313 chemical to either:
Q A facility in a covered SIC Code
(see Table I).
Q A facility that then may sell the same mixture or
other trade name product to a firm in a covered
SIC Code (see Table 1).
Note that you may be covered by the supplier
notification 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
EPCRA Section 313 chemicals in sufficient quantities to
trigger the release and other waste management
reporting requirements, you may still be required to
notify certain customers.
Who Must Be Notified
Also, note that beginning with the 1998 reporting year,
seven new industries are now covered by most of the
EPCRA section 313 reporting requirements. These new
industries are not required to comply with most of the
supplier notification requirements. Industries whose
primary SIC code is not within 20 through 39 are not
required to initiate the distribution of notifications for
EPCRA Section 313 chemicals in mixtures or other trade
name products that they send to their customers.
However, if these facilities receive notifications from
their suppliers about EPCRA Section 313 chemicals in
mixtures or other trade name products, they should
forward the notifications with the EPCRA Section 313
chemicals they send to other covered users.
An example would be if you sold a lacquer containing
toluene to distributors who then may sell the product to
other manufacturers. The distributors are not in a
covered SIC code, but because they sell the product to
companies in covered SIC codes, 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 other trade name products that are
sold or otherwise distributed. The "otherwise
distributes" language 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 EPCRA
Section 313 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.
Supplier Notification Must Include the
Following Information:
(1) A statement that the mixture or other trade name
product contains an EPCRA Section 313 chemical
or chemicals subject to the reporting requirements
of EPCRA section 313 (40 CFR 372);
(2) The name of each EPCRA Section 313 chemical
and the associated 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 EPCRA Section 313 chemicals.);
and
(3) The percentage, by weight, of each EPCRA Section
313 chemical (or all EPCRA Section 313 chemicals
within a listed category) contained in the mixture
or other trade name product.
Toxics Release Inventory Reporting Forms and Instructions D-l
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Appendix D
For example, if a mixture contains a chemical (i.ev 12
percent zinc oxide) that is a member of a reportable
EPCRA Section 313 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 an EPCRA Section 313 chemical
category present in the mixture.
How the Notification Must Be Made
The required notification must be provided at least
annually in writing. Acceptable forms of notice include
letters, product labeling, and product literature
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 notification 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 the MSDS or other form of
notification must include the section 313 notice. In other
words, your customers should understand their
requirement to include the section 313 notification if they
give your MSDS to their customers.
When Notification Must Be Provided
In general, you must notify each customer receiving a
mixture or other trade name product containing an
EPCRA Section 313 chemical with the first shipment of
each calendar year. You may send the notice with
subsequent shipments as well, but it is required that you
send it with the first shipment each year. Once
customers have been provided with an MSDS containing
the section 313 information, you may refer to the MSDS
by a written letter in subsequent years (as long as the
MSDS is current).
If EPA adds EPCRA Section 313 chemicals to the section
313 list, and your products contain the newly added
EPCRA Section 313 chemicals, notify your customers
with the first shipment made during the next calendar
year following EPA's final decision to add the chemical
to the list. For example, if EPA adds chemical ABC to the
list in September 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 other trade name product by
adding, removing, or changing the percentage by
weight of an EPCRA Section 313 chemical; or
(2) Discover that your previous notification did not
properly identify the EPCRA Section 313
chemicals in the mixture 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 EPCRA Section 313 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, indicate
which shipments were affected during the period
January 1 - August 12).
When Notifications Are Not Required
Supplier notification is not required for a "pure" EPCRA
Section 313 chemical unless a trade name is used. The
identity of the EPCRA Section 313 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 EPCRA Section 313 chemicals.
If your mixture or other trade name product contains one
of the EPCRA Section 313 chemicals, you are not required
to notify your customers if:
(1) Your mixture or other trade name product
contains the EPCRA Section 313 chemical in
percentages by weight of less than the following
levels (These are known as de minimis levels):
Q 0.1 percent if the EPCRA Section 313 chemical
is defined as an "OSHA carcinogen";
Q 1 percent for other EPCRA Section 313
chemicals.
D-2 Toxics Release Inventory Reporting Forms and Instructions
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Aooendix D
De minimis levels for each EPCRA Section 313
chemical and chemical category are listed in Table
II.
(2) Your mixture or other trade name product is one of
the following:
Q An article that does not release an EPCRA
Section 313 chemical under normal conditions
of processing or otherwise use.
Q Foods, drugs, cosmetics, alcoholic beverages,
tobacco, or tobacco products packaged for
distribution to the general public.
Q Any consumer product, as the term is defined
in the Consumer Product Safety Act, packaged
for distribution to the general public. For
example, if you mix or package one-gallon cans
of paint designed for use.by the general public,
notification is not required.
(3) You are initiating distribution of a mixture or other
trade name product containing one or more EPCRA
Section 313 chemicals and your facility is in any of
the newly covered SIC codes including facilities
whose SIC code is within SIC major group codes 10
(except 1011, 1081, and 1094), 12 (except 1241);
industry codes 4911 (limited to facilities that
combust coal and/or oil for the purpose of
generating power for distribution in commerce),
4931 (limited to facilities that combust coal and/or
oil for the purpose of generating power for
distribution in commerce), or 4939 (limited to
facilities that combust coal and/or oil for the
purpose of generating power for distribution in
commerce); or 4953 (limited to facilities regulated
under the Resource Conservation and Recovery Act,
subtitle C, 42 U.S.C. Section 6921 et seq.) or 5169, or
5171, or 7389 (limited to facilities primarily engaged
in solvents recovery services on a contract or fee
basis).
Trade Secrets
Chemical suppliers may consider the chemical name or
the specific concentration of an EPCRA Section 313
chemical in a mixture or other trade name product to be
a trade secret. If you consider the:
(1) Specific identity of an EPCRA Section 313 chemical
to be a trade secret, the notice must contain a
generic chemical name that is descriptive of the
structure of that EPCRA Section 313 chemical. For
example, decabromodiphenyl oxide could be
described as a halogenated aromatic.
(2) Specific percentage by weight of an EPCRA
Section 313 chemical in the mixture or other trade
name product to be a trade secret, your notice
must contain a statement that the EPCRA Section
313 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 that provides the basis for your
claim.
Recordkeeping Requirements
You are required to keep records for three years of the
following:
(1) Notifications sent to recipients of your mixture or
other trade name product;
(2) All supporting materials used to develop the
notice;
(3) If claiming a specific EPCRA Section 313 chemical
identity a trade secret, why the EPCRA Section 313
chemical identity is considered a trade secret and
the appropriateness 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.
Toxics Release Inventory Reporting Forms and Instructions D-3
-------
Appendix D
Sample Notification Letter
January 2,1999
Mr. Edward Burke
Furniture Company of North Carolina
1000 Main Street
Anytown, North Carolina 99999
Dear Mr. Burke:
This letter is to inform you that a product that we sell to you, Furniture Lacquer KXZ-1390, contains one or more
chemicals subject to Section 313 of Emergency Planning and Community Right-to-Know Act (EPCRA). We are
required to notify you of the presence of these chemicals in the product under EPCRA section 313. This law
requires certain industrial facilities to report on annual emissions and other waste management of specified
EPCRA Section 313 chemicals and chemical categories. Our product contains:
D Toluene, Chemical Abstract Service (CAS) number 108-88-3, 20 percent, and
O Zinc compounds, 15 percent.
If you are unsure whether you are subject to the reporting requirements of EPCRA Section 313, or need more
information, call EPA's EPCRA Hotline at (800) 535-0202, (800) 424-9346 or (703) 412-9877. Your other suppliers
should also be notifying you about EPCRA Section 313 chemicals in the mixtures and other trade name products
they sell to you.
Finally, please note that if you repackage or otherwise redistribute this product to industrial customers, a notice
similar to this one must be sent to those customers.
Sincerely,
Emma Sinclair
Sales Manager
Furniture Products
D-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix D
Furniture Products
Sample Notification on an MSDS
Section 313 Supplier Notification
This product contains the following EPCRA Section 313 chemicals subject to the reporting requirements of
Section 313 of the Emergency Planning and Community Right-To-Know Act of 1986 (40 CFR 372):
CAS#
108-88-3
NA
Chemical Name
Toluene
Zinc Compounds
Percent by Weight
20%
15%
1ms information should be included in all MSDSs that are copied and distributed for this material.
Material Safety Data Sheet
Appendix D D-5
-------
-------
Appendix E. How To Determine Latitude and Longitude From
Topographic Maps
—^•••^^^^^^^"^^^^•••^^^•^^^^^^B
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
measurements 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
meridian (Greenwich, England). Latitude and longitude
are measured in degrees, minutes, and seconds.
60" (seconds) = V (minute)
60' (minutes) = 1° (degree)
The most important tool available for determining
latitude 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 1:250,000
(i.e., one inch on the map represents approximately four
miles). It is very important that latitude and longitude
measurements be made from one of the detailed maps
described above. Otherwise, measurements will not
accurately reflect the location of your facility and could
be identified as an error on your Form R submission.
In order to identify the detailed topographic quadrangle
map in which your facility is located, the USGS has
published an index and a catalog of topographic maps
available for each state. Both the index and the catalog
are available in many libraries or free of charge from the
Distribution Branch of the USGS (address on following
page). The Index to Topographic and Other Map Coverage
helps you to identify the most detailed map in which
your facility is located. To identify the most detailed
map, follow these simple steps on how to use the index:
(1) The beginning of each index contains a map of the
state, broken into numbered quadrangular sections.
The numbered quadrangular sections are called
general areas of interest. Identify the numbered
section in which your facility is located.
(2) The subsequent pages of the index contain detailed
maps of each general area of interest, in numerical
order. Identify the detailed map corresponding to
the numbered general area of interest identified in
Step 1.
(3) Within this detailed map, identify the smaller
quadrangular area in which your facility is located.
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
corresponding 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 meaning of
the reference code. On the pages following this
explanation, there are charts listed alphabetically 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, identify 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
available in many libraries or for purchase from the
Distribution Branch of the USGS and from private map
dealers. The Catalog of Topographic and Other Published
Maps contains a list of map depository libraries and
topographic map dealers for each state covered in the
catalog.
To purchase a topographic quadrangle map from the
USGS, you must send a written request to the
Distribution 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.
Toxics Release Inventory Reporting Forms and Instructions E-l
-------
The Distribution Branch of the USGS can be reached at: - position the map so that you face west;
Distribution Branch of the USGS
P.O. Box 25286
Denver Federal Center
Denver, CO 80225
(303) 202-4700
ALLOW 5 WEEKS FOR DELIVERY
In addition, you may purchase a topographic quadrangle
map from the USGS through a USGS Public Inquiry
Office. The Public Inquiry Offices are listed for each state
on the inside back cover of the Catalog of Topographic and
Other Published Maps.
If you need help in determining your latitude and
longitude, 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
deadline 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 represented 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 2.5' 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.
(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,
E-2 Toxics Release Inventory Reporting Forms and Instructions
- 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.
Without moving the ruler, read and record:
- the measurement from the latitude line to the
desired point (the point distance);
- the measurement from the latitude line to the
north line of the small quadrangle (the total
distance).
Determine the number of seconds to be added to the
latitude recorded in step 3 by using the ratio:
Point distance x 150" = increment of latitude
Total distance
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"
0117.7"
(60" = 1'; 77.7" = 60" + 17.7" = 01' 17.7")
Latitude in step 3
Increment
Latitude of point
to the nearest second
32°17'30"
+ Ql'17.7"
32°18'47.7"
= 32°18'48"
(5) To determine the increment of longitude west of
the longitude line recorded in step 3,
- position the map so that you face south;
- place the ruler in approximately an east-west
alignment with the "0" on the longitude line
recorded in step 3 with the ruler edge
intersecting the point.
-------
Aovendix E
Without moving the ruler, read and record:
- the measurement from the longitude line to the
desired point (the point distance);
- 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 = 65.0
Total distance = 149.9
65.0 x 150" = 65" = Ol'OS"
149.9
(60" = I1; 65" = 60" + 05" = Ol'OS")
Longitude in step 3
Increment
Longitude of point
to the nearest second
78°05'00"
+ Ol'OS"
78°06'05"
= 78°06'05"
Note: Use the appropriate address for submission of
Form R reports to your State. In addition, many States
have additional state reporting requirements. Check
with your State contact on any State requirements.
Latitude/Longitude Diagram
WEST
NORTH
POINT
QUADRANGLE
GRATICULE
SOUTH
78-W30"
78°02'30"
32=22-30-
32°20W
EAST
32°17'30"
32°1J'00"
Point Latitude 32°18'48' North, Lontitude 78°06'05' West
Note: This diagram is based on a USGS 7.5 Minute Series Topographic Map. It is not drawn to scale.
Toxics Release Inventory Reporting Forms and Instructions E-3
-------
-------
Appendix F. State Designated Section 313 Contacts
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
Submitting Electronically to States: As of the
publication of this book the following states confirmed
that they accept electronic submission.
AK
AZ
CA
CO
DC
DE
FL
GA
HI
IA
If your state is not listed here. Please contact your
state office to confirm that paper submissions are
required.
Alabama
Mr. Kirk Chandler
Alabama Emergency Response Commission
Alabama Department of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
(334) 260-2717
Fax: (334) 272-8131
kfc@adem.state.al.us
Alaska
Ms. Camille Stephens
Department of Environmental Conservation
Government Preparedness and Response Program
410 Willoughby Avenue, Suite 105
Juneau, AK 99801-1795
(907) 465-5242
Fax: (907) 465-5244
cstephen@envircon.state.ak.us
American Samoa
Mr. Togipa Tausaga
American Samoa EPA
American Samoa Government
Office of the Governor
Pago Pago, AS 96799
International Number (684) 633-2304
asepa@samoatelco.com
Arizona
Mr. Daniel Roe, Executive Director
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, AZ 85008
(602)231-6346
Fax: (602)392-7519
roed@dem.state.az.us
Mr. Bill Quinn
Arizona Department of Environmental Quality
Pollution Prevention Unit Manager
3033 N. Central
Phoenix, AZ 85012
(602) 207-4203
Fax: (602) 207-4538
quinn.bill@en.state.az.us
Arkansas
Mr. Bob Johns
Arkansas Office of Emergency Services
P.O. Box 758
Conway, AR 72203-0758
Attn: Office of Hazardous Materials
(501) 703-9789
Fax: (501) 703-9754
Certified Mail ONLY
Mr. Bob Johns
Arkansas Office of Emergency Services
1835 South Donaghey
Conway, AR 72032
Attn: OHM
California
Mr. Stephen Hanna
California Environmental Protection Agency
Department of Toxic Substances Control
P.O. Box 806
Sacramento, CA 95812-0806
(916) 324-9924
Fax: (916) 324-1788
shanna@dtsc.ca.gov
Colorado
Mr. Kirk Mills
Mail Stop PPP-B2
Colorado Emergency Planning Commission
Colorado Department of Public Health and
Environment
4300 Cherry Creek Drive South
Denver, CO 80246
(303) 692-3017
Fax: (303) 782-4969
kirk.mills@state.co.us
Toxics Release Inventory Reporting Forms and Instructions F-l
-------
Commonwealth of Northern Mariana Islands
Mr. Ignacio V. Cabrera, Director
Division of Environmental Quality
Commonwealth of the Northern Mariana Islands
P.O. Box 1304
Saipan, MP 96950
International Number (670) 234-6984
Fax: (670) 234-1003
deq.director@saipan.com
Connecticut
Mr. Joseph Pulaski
SERC Administrator
Department of Environmental Protection
79 Elm Street, 4th Floor
Hartford, CT 06106-5127
(860) 424-3373
Fax: (860) 424-4509
joesph.pulaski@po.state.ct.us
Delaware
Mr. David Fees
EPCRA Reporting Program
Air Quality Management, DNREC
156 South State Street
Dover, DE 19901
(302) 739-4791
Fax (302) 739-3160
dfces@dnrec.state.de.us
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)
Fax: (202) 673-2290
Florida
Mr. Sam Bracket!
State Emergency Response Commission
Florida Department of Community Affairs
2555 Shumard Oak Blvd.
Tallahassee, FL 32399-2100
(850) 413-9928
Fax: (850) 488-1739
sam.brackett@dca.state.fl.us
Georgia
Dr. Bert K. Langley
Georgia Emergency Response Commission
7 Martin Luther King, Jr. Drive, Room 139
Atlanta, GA 30334
(404) 656-6905
Fax: (404) 657-7893
bert Iangley@mail.dnr.state.ga.us
Guam
Ms. Conchita Tatano, Director
Air and Land Division
Guam EPA
P.O. Box 22439, GMF
Barrigada, GU 96921
International Number (671) 475-1658
Fax: (671) 477-9402
Hawaii
Ms. Marsha Graf
Hawaii State Emergency Response Commission
Hawaii Department of Health
919 Ala Moana Blvd., 3rd Floor, Room 206
Honolulu, HI 96814
(808) 586-4249
Fax: (808) 586-7537
heer@eha.health.state.hi.us
Idaho
Mr. Bill Bishop
Bureau of Hazardous Materials
4040 Guard Street, Bldg. 600
Gowen Field
P.O. Box 83720
Boise, ID 83705-5004
(208) 334-3263
Fax: (208) 334-3267
bbishop@bds.state.id.us
Illinois
Mr. Joe Goodner
Illinois EPA
Office of Chemical Safety #28
1021 N. Grand Avenue, East
P.O. Box 19276
Springfield, IL 62794-9276
(217) 785-0830
Fax: (217)782-1431
epa8538@epa.state.il.us
Certified or Express Mail ONLY
Mr. Joe Goodner
Illinois EPA
Office of Chemical Safety #28
1021 N. Grand Avenue, East
Springfield, IL 62702
F-2 Toxics Release Inventory Reporting Forms and Instructions
-------
Aooendix F
Indiana
Ms. Paula Smith/Mr. Harry Davis
Indiana Department of Environmental Management
Office of Pollution Prevention Technical Assistance
Indiana Government Center North
100 North Senate Ave.
P.O.Box 6015
Indianapolis, IN 46206-6015
(317) 232-8172
Fax: (317) 233-5627
psmith@dem.state.in.us.
hdavis@dem.state.in.us
Iowa
Ms. Catharine Fitzsimmons, Supervisor
Compliance Assistance Section
Air Quality Bureau
Department of Natural Resources
7900 Hickman Rd., Suite I
Urbandale, IA 50322
(515) 281-8034
Fax: (515) 281-5094
craffen@max.state.ia.us
Kansas
Mr. Scott Bangert
Kansas Emergency Response Commission
Right-to-Know Program
J Street and 2 North
Forbes Field Building 283
Topeka, KS 66620
(785) 296-1689
Fax: (785) 296-1545
Kentucky
Mr. Alex Barber
Kentucky Department for Environmental Protection
14 Reilly Road
Frankfort, KY 40601-1132
(502) 564-2150
Fax: (502) 564-4245
barber@nrpath.nr.state.ky.us
Louisiana
Ms. Linda Brown
Department of Environmental Quality
Office of Secretary
P.O. Box 82263
Baton Rouge, LA 70884-2263
(504) 765-0737
Fax: (504) 765-0742
lindab@deq.state.Ia.us
Maine
Ms. Rayna Leibowitz
State Emergency Response Commission
72 State House Station
Augusta, ME 04333
(207) 287-4080
Fax: (207) 287-4079
rayna.b.leibowitz@state.me.us
Maryland
Ms. Patricia Williams
Maryland Department of the Environment
Technical and Regulatory Services Administration
Community Right-to-Know
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3800
Fax: (410) 631-3873
pwilliams@mde.state.md.us
Massachusetts
Mr. William T. Panos
Massachusetts Department of Environmental
Protection
Bureau of Waste Prevention
1 Winter Street
Boston, MA 02108
(617) 574-6820
Fax: (617) 292-5858
william.panos@state.ma.us
Michigan
Mr. Robert Jackson
State Emergency Planning and Community
Right-to-Know
Michigan Dept. of Environmental Quality
Environmental Assistance Division
P.O. Box 30457
Lansing, MI 48909
(517) 373-8481
Fax: (517) 241-7966
TACKSORC@state.mi.us
Certified Mail ONLY
Mr. Robert Jackson
State Emergency Planning and Community
Right-to-Know
Michigan Dept. of Environmental Quality
Environmental Assistance Division
333 S. Capitol
Town CTR, 2nd Floor
Lansing, MI 48909
Toxics Release Inventory Reporting Forms and Instructions F-3
-------
Minnesota
Mr. Steve Tomlyanovich
Department of Public Safety
Emergency Response Commission
444 Cedar Street, Suite 223
St Paul, MN 55101
(612) 282-5396
Fax: (612) 296-0459
steve.tomlyanovich@state.mn.us
Mississippi
Mr. John David Burns
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
P.O. Box 4501
Jackson, MS 39296-4501
(601) 960-9000
Fax: (601) 352-8314
Certified Mail ONLY
Mr. John David Burns
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
1410 Riverside Drive
Jackson, MS 39202
Missouri
Mr. Gene Nickel
Technical Assistance Program
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
(573) 526-6627
Fax: (573) 526-5808
nrnicke@mail.dnr.state.mo.us
Certified Mail ONLY
Mr. Gene Nickel
Technical Assistance Program
Missouri Department of Natural Resources
1659 B East Elm Street
Jefferson City, MO 65101
Montana
Mr. Tom Ellerhoff
Montana Emergency Response Commission DEQ
Metcalf Building
1520 East 6th Avenue
Helena, MT 59620-0901
(406) 444-5263
Fax: (406) 444-4386
tellerhoff@mt.gov
Nebraska
Mr. Mike Mallory, Coordinator
State of Nebraska Department of Environmental
Quality
P.O. Box 98922
Lincoln, NE 68509-8922
(402) 471-4251
Fax: (402) 471-2909
deq055@mail.deq.state.ne.us
Certified Mail ONLY:
Mr. Mike Mallory, Coordinator
State of Nebraska Department of Environmental
Quality
1200 N Street, Suite 400
Lincoln, NE 68509
Nevada
Ms. Alene Coulson
c/o State Emergency Response Commission
555 Wright Way
Carson City, NV 89711-0925
(775) 687-4670 (ext. 3006)
Fax: (775) 687-6396
New Hampshire
Mr. Leland Kimball
New Hampshire Office of Emergency
Management Agency, Title III Program
State Office Park South
107 Pleasant Street
Concord, NH 03301
(603) 271-2231
Fax: (603) 225-7341
leek@nhoem.state.nh.us
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
Fax: (609) 633-7031
aopperma@dep.state.nj.us
F-4 Toxics Release Inventory Reporting Forms and Instructions
-------
Appendix F
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
(505) 476-9620
Fax: (505) 476-9695
Mjohnson@DPS.state.nm.us
Certified Mail ONLY
Mr. Max Johnson, Coordinator
New Mexico Emergency Response Commission
Chemical Safety Office
Emergency Management Bureau
4491 Cerrillos Road
Santa Fe,NM 87505
New York
Mr. Sitansu Ghosh
New York State Department of Enviromental
Conservation
Pollution Prevention Unit
50 Wolf Road, Room 298
Albany, NY 12233-8010
(518) 485-8472
Fax: (518) 457-2570
sbghosh@gw.dec.state.ny.us
North Carolina
Mr. Richard Berman
North Carolina Emergency Response Commission
North Carolina Division of Emergency Management
116 West Jones Street
Raleigh, NC 27603-1335
(919) 733-3899
Fax: (919) 733-7554
rberman@ncem.org
North Dakota
Mr. Robert W. Johnston
North Dakota State Division of Emergency
Management
P.O. Box 5511
Bismarck, ND 58502-5511
(701) 328-2111
Fax: (701) 328-2119
bjhnsto@state.nd.us
Certified Mail ONLY
Mr. Robert W. Johnston
North Dakota State Division of Emergency
Management
Fraine Barracks Road, Building 35
Bismarck, ND 58506-5511
Ohio
Ms. Cindy DeWulf
Ohio EPA
Division of Air Pollution Control
P.O. Box 1049
1800 Watermark Drive
Columbus, OH 43216-1049
(614) 644-3606
Fax: (614) 644-3681
cindy.dewulf@epa.state.oh.us
Oklahoma
Ms. Monty Elder
Department of Environmental Quality
Risk Communication
P.O. Box 1677
Oklahoma City, OK 73117-1212
(405)702-6139
(800)869-1400
Fax: (405) 702-6101
monty.elder@deqmail.state.ok.us
Oregon
Mr. Bob Albers
Oregon Emergency Response Commission
Office of State Fire Marshall
4760 Portland Road, Northeast
Salem, OR 97305-1760
(503) 378-3473 (ext. 262)
Fax: (503) 373-1825
bob.ALBERS@state.or.us
Pennsylvania
Mr. Thomas J. Ward, Jr.
Bureau of PennSafe
Labor and Industry Building
7th & Forster Streets, Room 1503
Harrisburg, PA 17120
(717) 783-2071
Fax: (717) 783-5099
Toxics Release Inventory Reporting Forms and Instructions F-5
-------
Aooendix F
Pennsylvania
Ms. Peg Forte
Bureau of PennSafe
PA Dept. Labor and Industry
1503 L & I Bldg.
7th & Forster Streets
Harrisburg, PA 17120
(717) 787-2450
Fax: (717) 783-5099
pforte@dli.state.pa.us
Puerto Rico
Mr. Genaro Torres
Director of Superfund and Emergencies
Title III-SARA Section 313
Environmental Quality Board
Ferrnadez Junco Station
P.O. Box 11488
Santurce, PR 00910
(787) 766-2823
Fax: (787) 766-0150
Certified Mail ONLY
Mr. Genaro Toress
Director of Superfund and Emergencies
Environmental Quality Board
Emergency Response and Remedial Office
National Plaza #431
Ponce de Leon Avenue
Hato Rey, PR 00917
Rhode Island
Ms. Karen Slattery
RI Department of Environmental Management
Division of Air Resources
291 Promenade Street
Providence, RI 02908-5767
Attn: Toxic Release Inventory
(401) 222-2808 (ext. 7030)
Fax: (401) 222-2017
kslatter@dem.state.ri.us
South Carolina
Mr. Michael Juras
Community Right-to-Rnow
Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 898-4385
Fax: (803) 898-4117
in rasms@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
Fax: (605) 773-6035
leeanns@denr.state.sd.us
Tennessee
Ms. Betty Eaves, Administrator
Tennessee Emergency Response Council
Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204
(615) 741-2986
Fax: (615) 242-9635
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) 239-3147
Fax: (512) 239-3165
bkurka@tnrcc.state.tx.us
Overnight Express Mail ONLY
Ms. Becky Kurka
Office Pollution Prevention and Recycling
Texas Natural Resources Conservation Commission
12100 Park 35 Circle, Building E (MC-112)
Austin, TX 78753
Utah
Mr. Neil Taylor
Division of Environ. Response and Remediation
168 North 1950 West
Salt Lake City, UT 84116
(801) 536-4102
Fax: (801) 536-4242
ntaylor@deq.state.ut.us
F-6 Toxics Release Inventory Reporting Forms and Instructions
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Appendix F
Vermont
Mr. Paul Van Hollebeke
VT Dept. of Environmental Conservation
Environmental Assistance Division
103 S. Main St.
Waterbury, VT 05671-0411
(802) 241-3629
Fax: (802) 241-3273
paulv@dec.anr.state.vt.us
Virginia
Mr. Harry Gregori
Virginia Emergency Response Council
Virginia Dept. of Environmental Quality
P.O. Box 10009
Richmond, VA 23240-0009
(804) 698-4374
Fax: (804) 698-4277
hegregori@deq.state.va.us
Virgin Islands
Mr. Austin Moorehead
Department of Planning and Natural Resources
Division of Environmental Protection
1118 Waterguthomes
Christianshead, St. Croix 00820-5965
(304) 773-0565 (St. Croix)
Fax: (304) 773-9310 (St. Croix)
(340) 777-4577 (St. Thomas)
Fax: (340) 774-5416 (St. Thomas)
Washington
Ms. Idell Hansen
Department of Ecology, CRTK Unit
P.O. Box 47659
Olympia, WA 98504-7659
(360)407-6727 or (800) 633-7585
Fax: (360) 360-407-6715
ihan461@ecy.wa.gov
Federal Express or UPS Mail ONLY
Ms. Idell Hansen
Department of Ecology
Community Right-to-Know Unit
300 Desmond Drive
Lacey, WA 98503
West Virginia
Mr. John W. Pack, Jr.
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
Fax: (304) 344-4538
West Virginia
Ms. Jan Taylor
National Institute for Chemical Studies
2300 MacCorkle Ave., SE
Charleston, WV 25304
(304) 346-6264
Fax: (304)346-6349
taylornics@aol.com
Wisconsin
Mr. Dennis Pippen
Department of Natural Resources
101 South Webster
P.O. Box 7921
Madison, WI53707
(608) 266-6043
Fax: (608) 267-5231
pippid@mail.state.wi.us
Wyoming
Mr. Bob Bezek
Hazardous Materials Planner
Wyoming ERC/EMA
Department of Environmental Quality
P.O. Box 1709
5500 Bishop Blvd.
Cheyenne, WY 82009-3302
(307) 777-4900
Fax: (307) 635-6017
hellerj@wy-iso.army.mil
Notes:
(1) If an Indian tribe has chosen to act independently of
a state for the purpose of section 313 reporting, facilities
located within the 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.
Toxics Release Inventory Reporting Forms and Instructions F-7
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Appendix G. Section 313 Regional Contacts
Region 1
Assistance and Pollution Prevention Office
USEPA Region 1 (SPT),
JFK Federal Building
Boston, MA 02203
(617) 918-1829
Fax: (617)918-1810
Email: peavey.dwight@epa.gov
Connecticut, Maine, Massachusetts, New Hampshire,
Rhode Island, Vermont
Region 2
Pesticides and Toxics Branch
USEPA Region 2 (MS-105)
2890 Woodbridge Avenue
Building 10
Edison, NJ 08837-3679
(732) 906-6890
Fax: (732)321-6788
Email: lopez.nora@epa.gov
New Jersey, New York, Puerto Rico, Virgin Islands
Region 3
Toxics Programs and Enforcement Branch
USEPA Region 3 (3WC33)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 814-2072
Fax: (215)814-3114
Email: reilly.william@epa.gov
Delaware, District of Columbia, Maryland,
Pennsylvania, Virginia, West Virginia
Region 4
EPCRA Enforcement Section
USEPA Region 4
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, GA 30303
(404) 562-9191
Fax: (404)562-9163
Email: velez.ezequiel@epa.gov
Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee
Region 5
Pesticides and Toxics Branch
USEPA Region 5 (DT-8J)
77 West Jackson Boulevard
Chicago, IL 60604
(312) 886-6219
Fax: (312)353-4788
Email: codina.thelma@epa.gov
Illinois, Indiana, Michigan, Minnesota, Ohio,
Wisconsin ;
Region 6
Pesticides and Toxics Substances Branch
USEPA Region 6 (6PDT)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 665-8013
Fax: (214)665-6762
Email: layne.warren@epa.gov
Arkansas, Louisiana, New Mexico, Oklahoma, Texas
Region 7
Air, RCRA and Toxics Division
USEPA Region 7 (ARTD/CRIB)
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7472
Fax: (913)551-7065
Email: hirtz.james@epa.gov
Iowa, Kansas, Missouri, Nebraska
Region 8
Office of Pollution Prevention, Pesticides and Toxics
USEPA Region 8 (8P-P3T)
99918th Street, Suite 500
Denver, CO 80202
(303) 312-6447
Fax: (303)312-6044
Email: dhieux.joyel@epa.gov
Colorado, Montana, North Dakota, South Dakota,
Utah, Wyoming
Region 9
Pesticides and Toxics Branch
USEPA Region 9 (CMD-4-2)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1121
Fax: (415)744-1073
Email: browning.adam@epa.gov
Arizona, California, Hawaii, Nevada, American Samoa,
Guam, Commonwealth of the Northern Mariana Islands
Region 10
Office of Waste & Chemicals Management
USEPA Region 10 (WCM-128)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-4016
Fax: (206)553-8509
Email: colt.christina@epa.gov
Alaska, Idaho, Oregon, Washington
Toxics Release Inventory Repporting Forms and Instructions G-l
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Appendix H. Other Relevant Section 313 Materials
a 1996 Toxics Release Inventory Public Data
Release State Fact Sheets
(EPA 745-F-98-001)
The fact sheets can be found on the Internet at
http:/ / www.epa.gov/ opptintr/tri/fact96.htm The fact
sheets in this document summarize the basic 1996 Toxics
Release Inventory (TRI) data for each state. This
document is designed as a companion volume to EPA's
1996 Toxics Release Inventory Public Data Release (EPA
745-R-98-005), a more detailed examination of TRI data
for 1995 and previous years.
a 1996 Toxics Release Inventory Public Data
Release, Ten Years of Right-to-Know
(EPA 745-R-98-005)
This publication can be found on the Internet at
http://www.epa.gov/opptintr/tri/pubdat96.htm This
document provides an overview of the information
collected through TRI. It summarizes data collected for
calendar year 1996. For comparison purposes, this report
also provides basic data for the two preceding years
(1994 and 1995), for the period since the Pollution
Prevention Act mandated collection of waste
management data (1991), and for the baseline year (1988).
In addition to the usual analysis of TRI data on a national
basis, the 1996 Public Data Release contains, for the first
time, chapters that provide industry-specific analyses of
TRI data. The new chapters cover the following
industries: pulp and paper, petroleum, chemical
manufacturing, primary metals, electronics, and federal
facilities.
Q 1996 Toxics Release Inventory Public Data
Release - 10 Years of Right-to-Know: Industry
Sector Analyses (EPA 745-R-98-018)
This publication can be found on the Internet at
http://www.epa.gov/opptintr/tri/pubdat96.htm This
publication is a complement to the earlier sector chapters
completed in the 1996 TRI Public Data Release. The
document contains industry-specific analyses of the
following industries: food and kindred products; tobacco
products; textile mill products; apparel and other
finished products made from fabrics and similar
materials; lumber and wood products, except furniture;
furniture and fixtures; printing, publishing, and allied
industries; rubber and miscellaneous plastics products;
leather and leather roducts; stone, clay, glass, and
concrete products; fabricated metal products; industrial
and commercial machinery and computer equipment;
transportation equipment; measuring, analyzing, and
controlling instruments; and miscellaneous
manufacturing industries.
Q Similar reports for 1987-1995 are available for sale
from the Superintendent of Documents, U.S.
Government Printing Office, Washington, DC
20420-9325 (202-512-1800).
D Toxic Release Inventory - On-line Database
The TRI home page (http://www.epa.gov/opptintr/tri)
offers information useful to both novice and experienced
users of the toxics community. It provides, in lay terms,
a description of what TRI is, how it can be used, a
discussion of TRI and health issues, and much more. You
can find out about TRI products, view or download the
1996 TRI data release reports, and identify who to contact
for more information in EPA regions and state programs
across the country. From the TRI home page, you can
"link" to other EPA and non-EPA sites that allow you to
search the TRI database online.
Another EPA Web site, the Envirofacts Warehouse
(http://www.epa.gov/enviro) provides free access to
five of EPA's largest databases containing Superfund
data, Safe Drinking Water information, Hazardous Waste
information, Water Discharge permits, Air Releases, and
TRI information. The user can read about EPA's
databases, generate reports, and produce maps showing
the location of TRI and other facilities. Envirofacts allows
the user to search the TRI and other databases by facility
name, geographic location, SIC Code, or chemical name
and to produce reports on the facilities and map their
locations. A variety of user-specified parameters let
users point and click to customize their searches. The
maps include facility locations as well as user defined
demographic information, schools, hospitals, roads,
bodies of water, and more. Maps can be printed out or
saved in various formats including GIF, JPG, TIP, PDF,
EPS, ARC/INFO and more. TRI is specifically addressed
through Envirofact's TRI page
(http: / / www.epa.gov / enviro / html / tris / tr is over Jew.
html)
A computerized on-line database of the Toxic Release
Inventory data is also available through the National
Library of Medicine's (NLM) TOXNET on-line system at
http://toxnet.nlm.nih.gov. Other NLM files on TOXNET
can provide supporting 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, National Library of Medicine, 8600
Rockville Pike, Bethesda, MD 20894 (301) 496-6531.
Toxics Releases Inventory Forms and Instructions H-l
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Appendix H
RTK-Net (http://www.rtk.net) is an online network
concerned with environmental issues, in particular,
matters arising from the passage of right-to-know pro-
visions embodied in EPCRA legislation. RTK-net was
established by two non-profit organizations (Unison
(Unison Institute and OMB Watch) to provide access to
TRI, link TRI with other environmental data, and
exchange information among public interest groups.
RTK-Net is a full-service center providing free dial-in
access privileges to complete database services, training
and technical support, e-mail and electronic conferences
pertaining 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".
Q Toxics Release Inventory - CD-ROM
The TRI CD-ROM contains the complete Toxic Release
Inventory since 1987, as well as Chemical Factsheets
containing health and environmental effects information
for TRI chemicals. User-friendly software provides the
capability 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). To make TRI
information widely available for public use, the TRI CD-
ROM is distributed free of charge to non-profit
organizations, citizen groups, educators and government
agencies through NCEPI. The same CD is available for
purchase from GPO and NTIS. You may order the TRI
CD-ROM from EPA's web page at
http://www.epa.gov/opptintr/tri/cd-rom.htm or
contact one of the agencies listed below:
NCEPI:
National Center for Environmental Publications and
Information
P.O. Box 42419
Cincinnati, OH 45242
Phone: (800) 490-9198
GPO:
U.S. Government Printing Office
Superintendent of Documents
P.O. Box 371954
Pittsburgh, PA 15250-7954
Phone: (202) 512-1800
NTIS:
National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
Phone: (800) 553-6847
Q Toxic Release Inventory (by State) - Diskettes
Diskettes containing frequently used data elements from
TRI are available dBase and Lotus formats.
Accompanying documentation describes section 313
reporting 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
1996 disks. Earlier years are also available. The 1996
data can be downloaded for free in dBase format from
EPA's web site at
http://www.epa.gov/opptintr/tri/disks96.htm. or
ordered on disk from:
GPO:
U.S. Government Printing Office
Superintendent of Documents
P.O. Box 371954
Pittsburgh, PA 15250-7954
Phone: (202) 512-1800
Individual state (one disk per state): 3.50" disk-$15/disk
NTIS:
National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
Phone: (800) 553-6847
Lotus & dBase formats.
1987 to 1992 Data available.
Contact NTIS for price quote.
Q Consolidated List of Chemicals Subject to
Reporting Under the Act (Title III List of Lists),
(November 1998)
http://www.epa.gov/ceppo/pubs/title3.pdf
Available as an IBM compatible disk from: The National
Technical Information Service, 5285 Port Royal Road,
Springfield> VA22161, (703)605-6000, DocumentNumber:
PB98-500473, $69.00.
H-2 Toxics Release Inventory Reporting Forms and Instructions
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Appendix H
Q The Toxic Release Inventory: Meeting the
Challenge (April 1988)
This 19 minute videotape explains the toxic release
reporting requirements for plant facility managers and
others. State governments, local Chambers of
Commerce, labor organizations, public interest groups,
universities, and others may also find the video program
useful and informative.
3/4 inch = $30.75; VHS = $22.00.
To purchase, write or call:
Color Film Corporation
Video Division
770 Connecticut Avenue
Norwalk, CT 06854
(800)882-1120
Q Chemicals in Your Community, A Citizen's
Guide to the Emergency Planning and
Community Right-to-Know Act, September 1988
(OSWER-88-002)
This booklet is intended to provide a general overview of
the EPCRA requirements and benefits for all audiences.
Part I of the booklet describes the provisions of EPCRA
and Part II describes more fully the authorities and
responsibilities of groups of people affected by the law.
Available through written request at no charge from:
Emergency Planning and Community
Right-to-Know Information Hotline
Mailcode: 5101
401 M Street, SW
Washington, DC 20460
Hotline 1-800-535-0202
Q Chemicals in the Environment
Issue number 6 of Chemicals in the Environment (CIE),
published in the Fall of 1997, is devoted entirely to TRI.
This 22 page publication contains 19 articles ranging from
the history of TRI to the future of new TRI products.
Articles include perspectives from the community, State,
Federal, and International level. The publication also
provides valuable information on training and contacts
within the EPA. CIE is available free over the Internet
(http://www.epa.gov/opptintr/cie) or from NCEPI by
asking for publication EPA749-R-97- OOlb. To request
copies, contact:
National Center for Environmental Publications and
Information
P.O. Box 42419
Cincinnati, OH 45242-2419
Call: (800) 490-9198
POLLUTION PREVENTION INFORMATION
Q Environ$en$e
An up-to-date source of information on pollution
prevention is the Enviro$en$e System, a computerized
information network. Enviro$en$e includes a directory
of representatives from Federal, State, and local
governments; current news on pollution prevention
activities; program summaries for government agencies,
public and industry; a data base of industry case studies;
a calendar of conferences, training seminars, and
workshops; and specialized bulletin boards dedicated to
various topics. Enviro$en$e can be accessed in two ways:
1) Bulletin board-modem:
(703)908-2092, Parameters: 8,nl settings: ansi or v+100
user support: (703)908-2007.
2) World Wide Web-internet:
http://www.epa.gov/envirosense under heading "EPA
P2 and other initiatives"
Q The Pollution Prevention Information
Clearinghouse (PPIC)
PPIC was established as part of EPA's response to the
Pollution Prevention Act of 1990, which directed
theAgency 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
service at 202-260-1023, or fax a request to 202-260-0178,
or write to:
PPIC
Mail Code 3404
401 M St., SW
Washington, DC 20460
Toxics Releases Inventory Forms and Instructions H-3
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