United States
                    Environmental Protection
                    Agency
                   Office of Information
                   Analysis & Access
                   Washington, DC 20460
EPA-745-R-00-001
February 2000
&EPA
Emergency Planning and Community
Right-To-Know Act - Section 313
Reporting Modifications Beginning With Reporting Year
2000
   Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA)
requires certain facilities manufacturing, processing, or otherwise using listed toxic chemicals to report
their environmental releases of such chemicals annually. Beginning with the 1991 reporting year,
such facilities also must report pollution prevention and recycling data for such chemicals, pursuant to
section 6607 of the Pollution Prevention Act, 42 U.S.C. 13106.  When enacted, EPCRA section 313
established an initial list of toxic chemicals that was comprised of more than 300 chemicals and 20
chemical categories. EPCRA section 313(d) authorizes EPA to add chemicals to or delete chemicals
from the list, and sets forth criteria for these actions. The current EPCRA section 313 toxic chemical
list contains over 640 chemicals and chemical categories.

   The following information is provided to alert facilities of recent reporting modifications to the
EPCRA section 313 reporting requirements beginning with the 2000 reporting year. These
modifications do not apply to the forms being submitted on or before July 1, 2000 (covering the
1999 reporting year). However, since these modifications are effective January 1, 2000, facilities
should begin to apply these modifications to their data collection activities for 2000 reporting (reports
due on or before July 1, 2001).
                                      CONTENTS

   Introduction	  1
   Section l.OExpansion of the EPCRA Section 313 Toxic Chemical List	  2
   Section 2.0Lower Reporting Thresholds for Persistent, Bioaccumulative Toxic (PBT) Chemicals 3
   Section 3.0Other Changes to the Reporting Requirements for PBT Chemicals   	  4
   3.1 De Minimis Exemption	;	  4
   3.2 Data Precision	  4
   3.2 Range Reporting	  4
   3.3 Form A Exclusion	:		  4

Introduction. On October 29, 1999, EPA published a final rule (64 FR 58666) under section 313 of
the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), which lowers the
EPCRA section 313 reporting thresholds for certain persistent, bioaccumulative, and toxic (PBT)

-------
chemicals and adds certain other PBT chemicals to the EPCRA section 313 list of toxic chemicals.
These PBT chemicals are of particular concern not only because they are toxic but also because they
remain in the environment for long periods of time, are not readily destroyed, and build up or
accumulate in body tissue. Relatively small releases of PBT chemicals can pose human and
environmental health threats and consequently releases of these chemicals warrant recognition by
communities. The final rule included lower reporting thresholds for PBT chemicals and a special,
lower reporting threshold for the category of dioxin and dioxin-like compounds.  The rale also
included modifications to certain reporting exemptions and requirements for the chemicals newly
subject to the lower reporting thresholds.  EPA is developing reporting guidance for dioxin and dioxin-
like compounds and other PBT chemicals. The purpose of this document is to alert you to the changes
that this final rule has made to the EPCRA section 313 reporting requirements.

Section 1. Expansion of the EPCRA Section 313 Toxic Chemical List EPA has added seven
chemicals and two chemical compound categories to the list of toxic chemicals subject  to  reporting
under EPCRA section 313. The chemical abstract service registry number (CAS No.)  and name of
each added chemical is listed below.

CAS No.     Chemical Name
191-24-2     Benzo(g,h,i)perylene
206-44-0     Benzo(j,k)fluorene (fluoranthene) [as a member of the polycyclic aromatic
              compounds (PACs) category]
56.49.5      3-Methylcholanthrene [as a member of the PACs category]
29082-74-4   Octochlorostyrene
608-93-5     Pentachlorobenzene
79.94.7      Tetrabromobisphenol A (TBBPA)
7440-62-2    Vanadium (except when contained in an alloy)
NA          Vanadium compounds
NA          Dioxin and dioxin-like compounds (manufacturing; and the processing or  otherwise
             use of dioxin and dioxin-like compounds if the dioxin and dioxin-like compounds are
             present as contaminants in a chemical and if they were created during the
             manufacturing of that chemical).

   It should be noted that vanadium has been on the EPCRA section 313 list of toxic chemicals since
1987 with the qualifier "fume or dust." The new qualifier means that all forms of vanadium are now
reportable except when contained in an alloy.

   The dioxin and dioxin-like compounds category includes 17 specific compounds. The members of
the category are listed below by name and CAS No.
CAS No.     Chemical Name
1746-01 -6    2,3,7,8-tetrachlorodibenzo-p-dioxin
40321-76-4    1,2,3,7,8-pentachlorodibenzo-/?-dioxin
39227-28-6    1,2,3,4,7,8-hexachlorodibenzo-p-dioxin
Abbreviated Name
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD

-------
57653-85-7   1,2,3,6,7,8-hexachlorodibenzo-p-dioxin
19408-74-3   1,2,3,7,8,9-hexachlorodibenzo-^-dioxin
35822-46-9   1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin
3268-87-9    1,2,3,4,6,7,8,9-octachlorodibenzo-^-dioxin
51207-31 -9   2,3,7,8-tetrachlorodibenzofuran
57117-41-6   1,2,3,7,8-pentachlorodibenzofuran
57117-31 -4   2,3,4,7,8-pentachlorodibenzofuran
70648-26-9   1,2,3,4,7,8-hexachlorodibenzofuran
57117-44-9   1,2,3,6,7,8-hexachlorodibenzofaran
72918-21-9   1,2,3,7,8,9-hexachlorodibenzofuran
60851-34-5   2,3,4,6,7,8-hexachlorodibenzofuran
67562-39-4   1,2,3,4,6,7,8-heptachlorodibenzofuran
55673-89-7   1,2,3,4,7,8,9-heptachlorodibenzofiiran
39001-02-0   1,2,3,4,6,7,8,9-octachlorodibenzofuran
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HxCDF
1,2,3,4,7,8,9-HxCDF
1,2,3,4,6,7,8,9-OCDF
Section 2.  Lower Reporting Thresholds for Persistent, Bioaccumulative, and Toxic (PBT)
Chemicals. EPA has lowered the EPCRA section 313 reporting thresholds for 18 chemicals and
chemical categories that meet the EPCRA section 313 criteria for persistence and bioaccumulation. These
chemicals and their final thresholds are listed in the table below:
                Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals
Chemical Name or Chemical Category             CAS No.

Aldiin                                          309-00-2
Benzo(g,h,i)perylene                             191-24-2
Chlordane                                      57-74-9
Dioxin and dioxin-like compounds category         NA
   (manufacturing; and the processing or otherwise use
   of dioxin and dioxin-like compounds if the dioxin and
   dioxin-like compounds are present as contaminants in
   a chemical and if they were created during the
   manufacturing of that chemical)
Heptachlor                                     76-44-8
Hexachlorobenzene                              118-74-1
Isodrin                                         465-73-6
Methoxychlor                                   72-43-5
Octachlorostyrene                               29082-74-4
Pendimethalin                                   40487-42-1
Pentachlorobenzene                              608-93-5
Polycyclic aromatic compounds (PACs) category    NA
Polychlorinated biphenyl (PCBs)                  1336-36-3
Tetrabromobisphenol A                          79-94-7
  Section 313 Reporting Threshold (in
  pounds unless noted otherwise)
           100
           10
           10
           0.1 grams
           JO
           10
           10
           100
           10
           100
           10
           100
           10
           100

-------
 Toxaphene                                     8001-35-2             .10
 Trifluralin                                      1582-09-8             100
 Mercury                                       7439.97.6             10
 Mercury compounds                             NA                   10

    These lower reporting thresholds apply to the manufacturing, processing, and otherwise use of the
 chemicals and chemical categories listed in the above table.

 Section 3.0 Other Changes to the Reporting Requirements for PBT Chemicals. EPA has also
 made modifications to certain reporting exemptions and requirements for the PBT chemicals subject to the
 lower reporting thresholds. Each of these changes is discussed in the following subsections.

 3.1 De Minimis Exemption. EPA eliminated the de minimis exemption for all PBT chemicals. This
 means that facilities are required to include all amounts of PBT chemicals in threshold determinations
 and release and other waste management calculations regardless of the concentration of the PBT
 chemical in mixtures or trade name products.

 3,2 Data Precision. EPA has eliminated the half pound rule for PBT chemicals. This means mat
 facilities cannot automatically round quantities of a  half pound or less to zero. For PBT chemicals,
 except dioxin and dioxin-like compounds, the smallest amount that is required to be reported is 0.1
 pounds. Facilities should continue to report releases and other waste management amounts greater
 than 0.1 pounds at a level of precision supported by the accuracy of the underlying data and the
 estimation techniques on which the estimate is based.

    For the dioxin and dioxin-like compounds category facilities should also report at a level of
 precision supported by the accuracy of the underlying data and the estimation techniques on which the
 estimate is based.  However, the smallest quantity that is required to be reported on the Form R for the
 dioxin and dioxin-like compounds category is 0.0001 grams (i.e., 100 micrograms).

    Example: if the total quantity for section 5.2 (Stack or point air emissions) is 0.00005 grams or less,
    then zero can be entered. If the total quantity is between 0.00005 and 0.0001 grams then 0.0001
    grams can be entered or the actual number can be entered (e.g., 0.000075).

3.3 Range Reporting. EPA has eliminated range reporting for PBT chemicals.  This means that for
those sections of the Form R for which  range reporting is an option, the option cannot be used when
 reporting on a PBT chemical. Thus facilities must report an actual number rather than a selected
range.

3.4 Form A Exclusion

    EPA has excluded PBT chemicals from the alternate threshold of 1 million pounds. Therefore,
submitting a Form A rather than a Form R is not an option for the PBT chemicals subject to these new
reporting requirements.
'U.S. Government Printing Office: 2000 — 465-493

-------