United Slates
Environmental Protection
Agency
Office of Toxic
Substances
Washington, D.C. 20460
January 1989
EPA 560/4-89-001
v>EPA Toxic Chemical Release Inventory
Reporting Package for 1988
Form, instructions and other information to support reporting under Section 313 of the
Emergency Planning and Community Right-to-Know Act.
Commmrr mgM-B-Kitni AM
(Ttw IK at 9* SuMflund Am«ndm«nu
and ffeMjthorauon Act at I960)
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United States
Environmental Protection
Agency
Office of Toxic
Substances
Washington, D.C. 20460
Revised January 1989
EPA 560/4-88-005
?/EPA
Toxic Chemical Release Inventory
Reporting Form R and Instructions
Revised 1988 Version
Section 313
of the Emergency Planning and
Community Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthorization Act of 1986)
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EPA FORM R SUBMISSION CHECKLIST
Before you submit your facility's Form R submission, please review the following checklist to make sure that your report is
complete and correct.
Have you:
[ ] Prepared a complete, separate, and independent Form R for each chemical including Parts I, II, III, and IV (pages 1 -5)?
[ ] Provided an original signature on Part I, Section 2 for each chemical submission?
[ ] Entered the chemical name and CAS number in Part III, Sections 1.2 and 1.3 (page 3) exactly as they appear on the section
313 chemical list?
[ ] Checked that "NA" is entered, as appropriate, for all items that do not apply to your facility?
[ ] Included your facility's latitude and longitude on Part I, Section 3.6?
[ ] Made a copy of each report to be submitted to the state and a copy of each report for your own files?
If you are claiming a trade secret, have you:
[ ] Provided two complete Form Rs:
Q One that identifies the chemical ("unsanitized"); and
Q One that provides a generic chemical identity ("sanitized")?
[ ] Provided two complete trade secret substantiation forms:
Q One that identifies the chemical ("unsanitized"); and
G One that provides a generic chemical identity ("sanitized")?
Both Form Rs must include Parts I, II, III, and IV; both must contain an original signature.
[ ] Checked that the sanitized and unsanitized versions are correctly identified in Part I, Section 1.2?
Submit Form R by July 1 to EPA and the appropriate agency in your State.
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Important Changes in the Section 313 Requirements for
Reporting Year 1988
Reporting requirements for calendar year 1988 reports (due July 1, 1989), differ from 1987 requirements
in three respects:
(1) The 1988 threshold for manufacturing or processing a covered toxic chemical is
50,000 pounds (the threshold was 75,000 pounds for reporting year 1987). You
must use this threshold in determining whether you are subject to the reporting
requirements. (See "Threshold Determinations," p.7, for more information.)
(2) Latitude and logitude information must be included in the report. (See Part I,
Section 3.6, p. 13 and Appendix B for more information).
(3) The following chemicals that were covered for the 1987 year are not covered for
the 1988 reporting year:
CAS Number
C.I. Acid Blue 9 disodium salt 2650-18-2
C.I. Acid Blue 9 diammonium salt 3844-45-9
Reporting is not required for these chemicals (see the Final Rule October 7,1988
(53 FR 23108) for more information).
Supplier Notification Begins in 1989
With the first shipment of product in calendar year 1989, suppliers must
provide notice to their customers regarding all mixtures or trade name
products that contain listed toxic chemicals. The notice must be attached
to the Material Safety Data Sheets (MSDSs). The data in the notice must
be used for threshold and release calculations beginning with reports
submitted for calendar year 1989 due July 1,1990. The notification may
be used for threshold and release calculations for calendar year 1988, if the
notification information is the best available information at the facility.
(See "Mixture and Trade Name Products, Supplier Notification," p. 8 for
more information.)
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TABLE OF CONTENTS
Eiflfi
GENERAL INFORMATION 1
How to Assemble a Complete Report 1
Trade Secret Claims 1
Recordkeeping 1
When the Report Must Be Submitted 2
Where to Send the Report 2
How to Obtain Forms and Other Information 2
Who Must Submit This Form 2
HOW TO DETERMINE IF YOUR FACILITY MUST SUBMIT EPA FORM R 3
Does Your Facility Have Ten or More Full-Time Employees? 3
Is Your Facility's SIC Code In the 20-39 Range? 3
Multi-Establishment Facilities 3
Auxiliary Facilities 5
Facility-Related Exemptions 5
Does Your Facility "Manufacture," "Process," or "Otherwise Use" One or More
of the Chemicals Covered by the Reporting Rule? 5
Definitions of "Manufacture," "Process," and
"Otherwise Use" 6
Exemptions 6
During a Calendar Year, Does Your Facility Manufacture, Process, or Otherwise
Use a Listed Chemical in Quantities Greater than the Threshold Established
for that Year? 7
How to Determine tf Thresholds Are Exceeded 7
Mixtures and Trade Name Products 8
INSTRUCTIONS FOR COMPLETING SPECIFIC SECTIONS
OF EPA FORM R 12
PART I. FACILITY IDENTIFICATION INFORMATION 12
1.1 Are You Claiming the Chemical Identity on Page 3 Trade Secret? 12
1.2 If "Yes" in 1.1, is This Copy Sanitized or Unsanitized? 12
1.3 Reporting Year 12
2. Certification 12
3. Facility Identification 12
3.1 Facility Name and Location 12
3.2 Full or Partial Facility Indication 13
3.3 Technical Contact 13
3.4 Public Contact 13
3.5 Standard Industrial Classification (SIC) Code 13
3.6 Latitude and Longitude 13
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Page
3.7 Facility Dun and Bradstreet Number 13
3.8 EPA Identification Number 13
3.9 NPDES Permit Number 14
3.10 Receiving Streams or Water Bodies 14
3.11 Underground Injection Well Code (DIG) Identification Number 14
4. Parent Company Information 14
4.1 Name of Parent Company 14
4.2 Parent Company's Dun and Bradstreet Number 14
PART II. OFF-SITE LOCATIONS TO WHICH TOXIC CHEMICALS ARE
TRANSFERRED IN WASTES 14
1. Publicly Owned Treatment Works (POTWs) 14
2. Other Off-Site Locations 15
PART III. CHEMICAL-SPECIFIC INFORMATION 15
1.1 [Reserved] 15
1.2 CAS Number 15
1.3 Chemical or Chemical Category Name 15
1.4 Generic Chemical Name 15
2. Mixture Component Identity 16
3. Activities and Uses of the Chemical at the Facility 16
3.1 Manufacture of the Chemical 16
3.2 Process of the Chemical 16
3.3 Otherwise use the Chemical 17
4. Maximum Amount of the Chemical On-Site at Any Time During
the Calendar Year 19
5. Releases of the Chemical to the Environment On-Site 19
5.1 Fugitive or Non-Point Air Emissions 19
5.2 Stack or Point Air Emissions 19
5.3 Discharges to Receiving Streams or Water Bodies 19
5.4 Underground Injection 20
5.5 Releases to Land 20
A. Total Release 20
B. Basis of Estimate 22
C. Percent From Stormwater 22
6. Transfers of the Chemical in Waste to Off-Site Locations 25
A. Total Transfers 25
B. Basis of Estimate 25
C. Type of Treatment/Disposal 25
7. Waste Treatment Methods and Efficiency 25
A. General Waste Stream 25
B. Treatment Method 26
C. Range of Influent Concentration 27
D. Sequential Treatment? 27
E. Treatment Efficiency Estimate 27
F. Based on Operating Data? 28
8. Optional Information on Waste Minimization 28
A. Type of Modification 29
B. Quantity of the Chemical in the Wastestream Prior to
Treatment/Disposal 29
C. Index 29
D. Reason for Action 29
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wtopEimr OF
oract or SUPERFUND
SECTION 313 REPORTING PACKAGE
This Section 313 Reporting Package contains revised reporting and other
guidance materials for the Toxic Chemical Release Inventory reporting
requirements (Section 313 of the Emergency Planning and Community Right-to-
Know Act of 1986). These materials have been updated for calendar year 1988
reports.
Content of the Reporting Package
Tabs 1 & 2. Toxic Chemical Release Inventory Reporting Form R and Instructions
(January 1989) , revised to reflect changes in the form and 1988
reporting year thresholds; includes guidance on Section 313
requirements and preparation of your submission package, listings
of codes used on the form, regional and state contacts, and a
reply form to send in for more information;
Tab 3. The Toxic Chemical Release Inventory Questions and Answers
(January 1989) , a compilation of answers to the most commonly
asked questions on Section 313 requirements;
Tab 4. Reprint of the Section 313 Final Rule (40 CFR Part 372, 53 FR
4500), including EPA's response to comments on the proposed rule
and the names and CAS numbers of chemicals covered under the law;
Tab 5. Title III List of Lists (November 1988), a consolidated list of
chemicals subject to reporting under Title III of SARA; and
Tab 6. Toxic Chemical Release Inventory Magnetic Media Submission
Instructions (January 1989), guidance on the proper formatting,
packaging, and supporting documentation for electronic media
submissions.
Additional information and guidance materials are available from the Emergency
Planning and Community Right-to-Know Information Hotline, U.S. Environmental
Protection Agency, WH-562-A, 401 M Street, S.W., Washington, D.C., 20460
(1-800-535-0202, or 202-479-2449 in Washington, D.C. and Alaska).
Changes for the 1988 Reporting Year
• The reporting thresholds for manufacturing and processing of
listed chemicals have been lowered to 50,000 pounds. The
threshold for "otherwise using" a listed chemical remains 10,000
pounds. (For the 1989 reporting year and beyond, thresholds for
manufacturing and processing will be lowered to 25,000 pounds.)
• EPA Reporting Form R has been changed slightly for 1988 reporting,
to make it easier to understand and complete.
• The latitude and longitude of facilities must be reported for 1988
and subsequent years (this is no longer optional information).
(The Form and Instructions document explains how to determine
latitude and longitude coordinates.)
U.S. Environmental Protection Agency
Region 5, Library 1-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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t .,;.». »•*» *. " " .*"."*
m Supplier notification requirements go into effect starting with the
first shipment in January of 1989. Suppliers must inform customer
facilities of the presence and percentage content of listed chemicals in
their products.
• Magnetic media reporting can be used regardless of the number of
individual chemical reports you are submitting. EPA encourages
you to take advantage of electronic reporting to ensure data
accuracy during processing into the national database.
• C.I. Acid Blue 9, diammonium salt and C.I. Acid Blue 9, disodium
salt were delisted in October 1988. Titanium dioxide was delisted
in June 1988. Section 313 reports are no longer required for
these chemicals.
Problems to Avoid
Forms submitted for reporting year 1987 contained several common errors.
To avoid receiving a notice of non-compliance, be especially careful that:
• Facility information is submitted with each report. A
completed report consists of all four parts of Form R.
• Each report has an original (not photocopied)
certification signature.
• The chemical or chemical category that is being
reported is properly identified by name or CAS number.
• Fugitive emissions of volatile chemical substances
(e.g., toluene) are accounted for on the report.
• Codes are correctly entered on the form, (e.g., the
use of off-site treatment codes for on-site treatment
processes must be avoided).
• A basis of estimate code is indicated for all release
estimates.
Recordkeeping. Incomplete Forms, and Compliance Penalties
Facilities are subject to the following requirements under Section 313:
• Each facility must document its release estimate
calculations and assumptions, and retain the
documentation for a minimum of three years after
reports are submitted.
• Forms that are submitted with errors, or with
incomplete or suspect data, will trigger a notice of
non-compliance from EPA. A facility receiving such
will have 30 days to re-submit reports.
• Non-complying facilities are subject to a fine of up
to $25,000 for every day they are in non-compliance.
ii
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Ill
Page
TABLE I SIC Codes 20-39 30
TABLE II Section 313 Toxic Chemical List 36
TABLE III State Abbreviations 45
Additional Materials Available on Section 313 46
APPENDIX A Example of a Completed Form R for a Hypothetical Facility
Reporting Under Title III, Section 313 47
APPENDIX B How to Determine Latitude and Longitude From Topographic Maps 52
APPENDIX C Worksheet for Performing Threshold Determinations 54
APPENDIX D Reporting Codes for EPA Form R 59
APPENDIX E State Designated Section 313 Contacts 62
APPENDIX F Section 313 EPA Regional Contacts 67
APPENDIX G Section 313 Final Rule 68
Index 75
Form R
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Page 1
GENERAL INFORMATION
Submission of EPA Form R, the Toxic Chemical Release
Inventory Reporting Form, is required by section 313 of the
Emergency Planning and Community Right-to-Know Act (Title
III of the Superfund Amendments and Reauthorization Act of
1986), Public Law 99-499. The information contained in Form
R constitutes a "report," and the submission of a report to the
appropriate authorities constitutes "reporting." Reporting is
required to provide the public with information on the release
of listed toxic chemicals from your facility to the environment
during the past year. Facilities must report the quantities of
both routine and accidental releases of listed chemicals, as
well as the maximum amount of the listed chemical ever on-
site during the calendar year and the amount contained in
wastes transferred off-site.
A completed Form R must be submitted for each toxic chemi-
cal manufactured, processed, or otherwise used at each
covered facility as prescribed in the reporting rule in 40 CFR
Part 372 (published February 16, 1988 in the Federal Regis-
ter). These instructions supplement and elaborate on the
requirements in the reporting rule. (See Appendix G for a copy
of the regulations). Together with the reporting rule, they
constitute the reporting requirements. All references in these
instructions are to sections in the reporting rule unless other-
wise indicated.
HOW TO ASSEMBLE A COMPLETE REPORT
The Toxic Chemical Release Reporting Form, EPA Form R,
consists of four parts:
Q Part I, Facility Identification Information (page 1);
Q Part II, Off-Site Locations to Which Toxic Chemicals are
Transferred in Wastes (page 2);
Q Part III, Chemical-Specific Information (pages 3 and 4);
and
Q Part IV, Supplemental Information (page 5).
Form R is designed so that most of the information required in
Part I and all of the information required in Part II can be filled
out and then photocopied and attached to each chemical-
specific report. Part I may be a photostatic copy as long as it
has an original signature on the certification statement and the
trade secret designation is appropriate. You have the option
to complete Part II for only the off-site locations that apply to
the individual chemical cited in the report cj; you can list all off-
site locations that apply to all chemicals being reported and
include a photostatic copy of this Part II with each individual
report. Part III must be completed separately for each
chemical. Part IV provides additional space, if needed, to
complete the information required by the preceding sections of
the form. Include Part IV in your report, even if it is blank.
A complete report for any listed toxic chemical that is not
claimed trade secret consists of the following completed parts:
Q Part I with an original signature on the certification state-
ment (Section 2);
Q Part II;
Q Part III (Section 8 is optional); and
Q Part IV (even if blank).
Staple the pages of each report together. Do not submit
supporting documentation or other materials; such data will
not be processed with your Form R submission.
TRADE SECRET CLAIMS
For any chemical whose identity is claimed as a trade secret
you must submit to EPA two versions of the form as prescribed
in 40 CFR Part 350, published July 29, 1988 in the Federal
Register (53 FR 28772). Use the order form in this document
to obtain a copy of the rule and substantiation form. One
version identifies the chemical; the second version does not
identify the chemical specifically, but provides instead a ge-
neric identity. Only this latter version will be available to the
public. For further explanation of the trade-secret provisions,
see the instructions below for Part I, Sections 1.1 and 1.2 and
Part III, Sections 1.1-1.4.
A complete report for a toxic chemical claimed trade secret
includes all of the above items plus the following:
Q A completed Form R report including the chemical identity
(staple the pages together);
Q A "sanitized" version of a completed Form R report in
which the chemical identity items (Part III, Sections 1.2
and 1.3) have been left blank but in which a generic
chemical name has been supplied (Part III, Section 1.4)
(staple the pages together);
Q A completed trade secret substantiation form (staple the
pages together);
Q A "sanitized" version of the trade secret substantiation
form (staple the pages together).
Securely fasten all four reports together.
RECOROKEEPING
You must keep a copy of each report. In addition, you must
keep the supporting materials used to develop the information
contained in the report. These records must be kept at the
facility for a period of three years from the date of the
submission and must be readily available for inspection by
EPA.
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General
Page 2
WHEN THE REPORT MUST BE SUBMITTED
The report for any calendar year must be submitted on or
before July 1 of the following year (e.g., the report for calendar
year 1988, January-December, must be submitted on or
before July 1,1989).
VOLUNTARY REVISION OF A PREVIOUS
SUBMISSION
If you are making a voluntary revision to a previous Form R
submission, enter "Voluntary Revision" in the space marked
"This space foryouroptional use" onall'ive pages of the form.
If you have obtained the Document Control Number (DCN) of
the original submission from EPA, enter that number also in
this space. You must include the facility and chemical names
on the form exactly as they were reported previously to enable
tracking of the original data. If your facility's name has
changed since the original submission, you must enter the
facility name which appeared in the original submission; also
indicate the new facility name in the optional use space on
page 1 ofFormRonly. You must complete the entire form (or
a voluntary revision and send a copy of the revision to the
state. Submissions for the next calendar year are not consid-
ered revisions of a previous year's data.
WHERE TO SEND THE REPORT
Form R submissions must be sent to both EPA and the State.
Send EPA reports by mail to:
U.S. Environmental Protection Agency
P.O. Box 70266
Washington, D.C. 20024-0266
Attn: Toxic Chemical Release Inventory
Hand-delivered submissions only should be addressed to:
EPA Title III Reporting Center
470 L'Enfant Plaza East
Suite 7103, SW
Washington, DC 20024
Attn: Toxic Chemical Release Inventory
In addition, you must send a copy of the report to the State in
which the facility is located ("State" refers to: State of the U.S.,
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). Referto Appendix E (page 62)
for the appropriate State address for your facility. If your
facility is located on Indian land, send a copy to the Chief
Executive Officerof the applicable Indian tribe, unless the tribe
has entered into a cooperative agreement with the State. In
this case, Form R submissions should be sent to the entity
designated in the cooperative agreement to receive the forms.
Copies of the report sent to the State or Indian tribe should be
the "sanitized," non-trade-secret version of the report, unless
the State specifically requires otherwise. The report submitted
to EPA should include both trade-secret and non-trade-secret
versions. For additional information, refer to the discussion of
trade-secret/confidentiality claims in the instructions for com-
pleting Part III, Section 1 of Form R.
HOW TO OBTAIN FORMS AND OTHER
INFORMATION
A copy of Form R is included in this booklet. Remove this form
and photocopy as many copies of it as you need. Additional
copies of EPA Form R and related guidance documents may
be obtained from:
Section 313 Document Distribution Center
P.O.Box 12505
Cincinnati, OH 45212
See the request form located before Appendix A (page 47) for
more information on available documents. Questions about
how to fill out the form may be submitted in writing to:
Emergency Planning and Community Right-to-
Know Information Hotline
U.S. Environmental Protection Agency
401 M Street, S.W. (OS-120)
Washington, DC 20460
Alternatively, you may call (800) 535-0202 (in Washington,
D.C. and Alaska, (202) 479-2449) from 8:30-7:30 Eastern
Time.
EPA Regional Staff may also be able to help you. Refer to
Appendix F (page 67) for a list of EPA Regional Contacts.
WHO MUST SUBMIT THIS FORM
Section 313 of Title III requires that reports be filed by owners
and operators of facilities that meet all three of the following
criteria:
Q The facility has 10 or more full-time employees;
Q The facility is included in Standard Industrial Classification
(SIC) Codes 20 through 39; and
Q The facility manufactured (defined to include imported),
processed, or otherwise used in the course of a calendar
year any listed chemical in quantities greater than the
established threshold.
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Pages
General
HOW TO DETERMINE IF YOUR FACILITY MUST SUBMIT EPA FORM R
(See Figure 1 for more information.)
DOES YOUR FACILITY HAVE TEN OR MORE
FULL-TIME EMPLOYEES?
A "full-time employee," for purposes of section 313 reporting,
is defined as 2,000 work hours per year. To determine the
number of full-time employees atyourf acility, add up the hours
worked by all employees during the calendar year, including
contract employees and sales and support staff working at the
facility. 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 employee threshold.
IS YOUR FACILITY'S SIC CODE IN THE 20-39
RANGE?
Table I on page 30 includes a listing of SIC codes 20-39 and
the associated 4-digit SIC codes covered by the rule. 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. You may already know the SIC code of your
business as a result of your having had to develop insurance
or other reports. If you are not familiar with the SIC codes that
apply to yourfacility, contact yourtrade association, Chamber
of Commerce, or legal counsel. For a detailed description of
4-digit SIC codes, refer to the "Standard Industrial Classifica-
tion Manual 1987." Clothbound editions should be available in
most major libraries or may be ordered through the National
Technical Information Service, 5285 Port Royal Road, Spring-
field, VA, 22161, (703) 487-4650. The access number for the
clothbound manual is PB87-100012, and the price is $30.00.
If you are unsure of your SIC code, review your operations to
determine if you produce products of the type described in SIC
codes 20-39. If the value of those products is greaterthan any
other types of goods and services that you produce at that
location, then you meet the SIC code criterion.
Section 313 requires that reports be filed 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, however,
classifies business "establishments," which are defined as
"distinct and separate economic activities [that] are performed
at a single physical location."
Establishments, in the SIC code system, are to be treated as
separate activities. In many cases, a section 313 "facility" is
the same as an "establishment" as defined by the SIC code
system.
Multi-establishment Facilities
Your facility may include multiple establishments that have
different primary SIC codes. If so, calculate the value of the
products produced or shipped from each establishment within
the facility and then use the following rule to determine if your
facility meets the SIC code criterion:
Q If the total value of the products shipped from or produced
at establishments with primary SIC codes between 20
and 39 is greaterthan 50 percent of the value of the entire
facility's products, the facility meets the SIC code crite-
rion.
Q If any one establishment with a primary SIC code between
20 and 39 produces or ships products whose value
exceeds the value of products produced or shipped by
any other establishment within the facility, the facility also
meets the SIC code criterion.
In calculating the value of production attributable to a particu-
lar establishment, the facility may adjust the value of produc-
tion from that establishment by subtracting out the value of
products which that establishment obtains from other estab-
lishments within the same facility and incorporates into its final
production. This procedure eliminates the potential for "double
counting" production in situations where establishments are
engaged in sequential production activities at a single facility.
Examples include:
Q One establishment in a facility mines ore; all of the ore is
smelted at a second establishment in the facility. The
facility could calculate the value of production for each
establishment separately. Alternatively, the facility could
determine the value of ore production and subtract it from
the value of the output from the smelter operation, which
would yield the value of production for the latter establish-
ment.
G A food processing establishment in a facility processes
crops grown at the facility in a separate establishment.
The facility could calculate the value of the products of
each establishment by determining the total value of
production from each establishment. Alternatively, the
facility could determine the value of the crops grown at the
agricultural establishment. Then, to calculate the contri-
bution of the food processing establishment, the facility
would subtract the crop value from the total value of the
product shipped from the processing establishment.
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General
Page 4
Figure 1
Flowchart for Determining Applicability
Does your facility have 10 or
more full-time employees?
(see definition on page 3)
Yes
Is your facility classified under
SIC codes 20 through 39?
Does your facility manufacture,
process or otherwise use
any listed chemical or chemical
category?
Manufacture
or Process
Yes
Otherwise
Use
Calendar year 1988
All other years
pu
Reporting not required.
Reporting not required.
Reporting not required.
Did your facility otherwise use
more than 10,000 pounds of
the chemical in the calendar
year?
No
Yes _
Reporting not required.
Report must be filed.
No _
Did your facility manufacture or
process more than 50,000
pounds of the chemical in
1988? • Yes
Reporting not required.
Report must be filed.
No
Did your facility manufacture or
process more than 25,000
pounds of the chemical In the
past calendar year? I Yes
Reporting not required.
Report must be filed.
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PageS
General
A covered multi-establishment facility must make chemical
threshold determinations and report all relevant information
about releases and waste treatment associated with a listed
chemical, even from establishments that are not in SIC codes
20-39. EPA realizes, however, that certain establishments in
a multi-establishment facility can be, for all practical purposes,
separate business units. Therefore, individual establishments
may report separately, provided that the total release and
other required information is reported for the whole facility.
Auxiliary Facilities
An auxiliary facility is one that directly supports another
establishment's activities (e.g., research and development
laboratories, warehouses, storage facilities, and waste-treat-
ment facilities). An auxiliary facility can take on the SIC code
of another covered facility if its primary function is to service
that other covered facility's operations. Thus, a separate
warehouse facility (i.e. one not located within the physical
boundries of a covered facility) may become a covered facility
because it services a 20-39 facility. Auxiliary facilities that are
in SIC codes 20-39 are required to report if they meet the
employee criterion and chemical thresholds for manufacture,
process, or use. Auxiliary establishments that are part of a
multi-establishment facility must be factored into threshold de-
terminations for the facility as a whole.
Facility-Related Exemptions
Listed toxic chemicals that are manufactured, processed, or
otherwise used in laboratories at a covered facility under the
supervision of a technically qualified individual do not have to
be factored into the threshold or release calculations. How-
ever, pilot plant scale or specialty chemical production do not
qualify for this laboratory exemption.
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.
DOES YOUR FACILITY "MANUFACTURE,
PROCESS, OR USE" ONE OR MORE OF THE
CHEMICALS COVERED BY THE REPORTING
RULE?
Table II (page 36 of these instructions) contains the list of
individual chemicals and categories of chemicals subject to
1988 calendar year reporting. Some of the chemicals listed in
Table II have parenthetic qualifiers listed next to them. A
chemical that is listed without a qualifier is subject to reporting
in all forms in which it is manufactured, processed, and used.
Fume or dust. Three of the metals on the list (aluminum,
vanadium, and zinc) contain the qualifier "fume or dust." This
qualifier means that a facility is manufacturing, processing, or
using the metal in the form of fume or dust. Fume ordust does
not refer to "wet" forms, solutions or slurries, for example, but
only dry or anhydrous forms of these metals. As explained on
page 6 of these instructions, the term manufacture includes
the generation of a chemical as a byproduct or impurity. In
such cases, a facility should determine if, for example, it
generated more than 50,000 pounds of aluminum fume or
dust in 1988 as a result of its activities. If so, the facility must
report that it manufactures "aluminum (fume ordust)." Simi-
larly, there may be certain technologies in which one of these
metals is processed in the form of a fume or dust to make other
chemicals or other products for distribution in commerce. In
reporting releases, the facility would only report releases of the
fume or dust.
Manufacturing qualifiers. Two of the list entries contain a
qualifier relating to manufacture. For isopropyl alcohol, the
qualifier reads "manufacturing-strong acid process." For sac-
charin, the qualifier simply reads "manufacturing." In the case
of isopropyl alcohol, the qualifier means that only facilities that
manufacture isopropyl alcohol by the strong acid process are
required to report. In the case of saccharin, only manufac-
turers of the chemical are subject to the reporting require-
ments. A facility that processes or otherwise uses either
chemical would not be required to report for those chemicals.
In both cases, supplier notification does not apply.
Solutions. Four substances on the list, ammonium nitrate,
ammonium sulfate, sodium hydroxide, and sodium sulfate,
are qualified by the term "solution," which refers to the
physical state of these chemicals. Only facilities that manufac-
ture, process, or otherwise use these chemicals in the form of
a solution are required to report. Supplier notification applies
only if the chemical is distributed as a solution. (See page 7 for
information on calculating threshold and release determina-
tions for solutions.)
Phosphorus (yellow or white^. The listing for phosphorus is
qualified by the term "yellow or white." This refers to a
chemical state of phosphorus meaning that only manufac-
turing, processing, or use of phosphorus in the yellow or white
states triggers reporting. Conversely, manufacturing, proc-
essing, or use of "black" or "red" phosphorus do 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 a physical characteristic of asbes-
tos. The term "friable" means crumbled, pulverized, or
reducible to a powder with hand pressure. Again, only
manufacturing, processing, or use of asbestos in the friable
form triggers reporting. Similarly, supplier notification applies
only to distribution of friable asbestos.
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General
Page6
Definitions of "Manufacture," "Process," and
"Otherwise Use"
Manufacture: The term "manufacture" means to produce,
prepare, compound or import a listed toxic chemical. Import
is defined as causing the chemical to be imported into the
customs territory of the United States. If you order a covered
toxic chemical (or a mixture containing the chemical) from a
foreign supplier, then you have imported the chemical when
that shipment arrives at yourf acility. 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
chemical. The term manufacture also includes coincidental
production of a toxic chemical (e.g., as a byproduct or impu-
rity) as a result of the manufacture, processing, use, or
disposal of other chemical substances. In the case of coinci-
dental production of an impurity (i.e., a chemical that remains
in the product that is distributed in commerce), the de minimi's
limitation, discussed on page 8, applies. The de minimis
limitation does not apply to byproducts (e.g., a chemical that
is separated from a process stream and further processed or
disposed). Certain listed toxic chemicals may be manufac-
tured as a result of wastewater treatment or other treatment
processes. For example, neutralization of acid wastewater
can result in the coincidental manufacture of sodium sutfate
(solution).
EXAMPLE
Your company, a nitric acid manufacturer, uses ammonia in a
waste treatment system to neutralize an acidic wastewater
stream containing nitric acid. The reaction of the ammonia
and nitric acid produces an ammonium nitrate solution.
Ammonium nitrate solution is a listed toxic substance, as are
nitric acid and ammonia. Your facility otherwise uses ammo-
nia as a reactant and manufactures ammonium nitrate solu-
tion as a byproduct. If the ammonium nitrate solution is
produced in a quantity that exceeds the threshold (e.g.,
50,000 pounds for 1988), releases of ammonium nitrate
solution from the facility must be reported. If more than 10,000
pounds of ammonia is added to the wastewater treatment
system, then releases of ammonia must also be reported.
Process: The term "process" means the preparation of a
listed toxic chemical, after its manufacture, for distribution in
commerce. Processing includes preparation of the chemical
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 process-
ing of a component in a mixture or other trade name product
(see page 8) that is a listed toxic chemical.
EXAMPLE
The examples below illustrate the categorization of some
typical process and manufacture activities.
Q Your company receives toluene, a listed toxic chemical,
from another facility, reacts the toluene with air to form
benzole acid, and further reacts the benzole acid with a
cadmium catalyst to form terephthalic acid. Cadmium
compounds and terephthalic acid are also listed toxic
chemicals. Your company processes toluene, and uses
(not processes) the cadmium catalyst (see the definition
of "otherwise used" below). Yourcornpany manufactures
benzole acid and terephthalic acid. Benzole acid, how-
ever, is not a listed chemical and thus does not trigger
reporting requirements.
Q Your company receives a nickel compound (nickel com-
pound is a listed toxic chemical category) as a bulk solid
and performs various size-reduction operations (e.g.,
grinding) before packaging the compound in 50-lb bags.
Your company processes the nickel compound.
Q Your company receives a prepared mixture of resin and
chopped fiberto be used in the injection molding of plastic
products. The resin contains a listed chemical that
becomes incorporated into the plastic. Yourf acility proc-
i the chemical.
Otherwise Use: The term "otherwise use" encompasses any
use of a listed chemical at a facility that does not fall under the
definitions of "manufacture" or "process." A chemical that is
used by a facility is not intentionally incorporated into a product
distributed in commerce.
EXAMPLE
When your facility cleans equipment with toluene, you are
using toluene. However, if your facility incorporates toluene
into a mixture for distribution in commerce, your facility is
processing that chemical. 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 uses toluene.
Exemptions
Use Exemptions. Certain uses of listed chemicals are specifi-
cally exempted: use as a structural component of the facility;
use in routine janitorial or facility grounds maintenance; per-
sonal uses by employees or other persons; use of products
containing toxic chemicals for the purpose of maintaining
motor vehicles operated by the facility; or use of toxic chemi-
cals contained in intake water (used for processing or non-
contact cooling) or in intake air (used either as compressed air
or for combustion).
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Page?
General
Article Exemptions. You do not have to factor into threshold
or release determinations quantities of a listed toxic chemical
contained in an article il that article is processed or used at
your facility. An article is defined as a manufactured item that
is formed to a specific shape or design during manufacture,
that has end-use functions dependent in whole or in part upon
its shape or design during end-use, and that does not release
a toxic chemical under normal conditions of the processing or
use of that item at the facility.
The release criteria in the article definition is not absolute.
Reporting of releases under section 313 may be rounded to
the nearest pound. Releases of less than 0.5 pounds per year
do not negate the article status of an item that meets the first
two criteria in the article definition. If when processing or using
an item the estimate of total annual releases of a toxic
chemical is less than 0.5 pounds, then the facility may round
this estimate to zero. Thus, the article status of the item would
be retained because, in effect, the releases are calculated to
be zero. Low level releases of a toxic chemical from an item
due to normal or natural degradation, corrosion, etc., does not
negate the article status.
The article exemption applies to the normal processing or use
of an article. It does not apply to the manufacture of an article.
Toxic chemicals contained in articles manufactured at a facility
must be factored into threshold and release determinations.
The following examples apply the article exemption:
Q Lead that is incorporated into a lead acid battery is
processed in order to manufacture the battery, and there-
fore must be counted toward threshold and release deter-
minations. 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 Metal rods that are extruded into wire are not articles
because their form changes during processing. How-
ever, wire that is twisted or bent is an article as long as it
remains identifiably wire.
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 8-foot piece of
wire is broken into two 4-foot pieces of wire, without
releasing any toxic chemicals. Each 4-foot piece is
identifiable as a piece of wire; therefore, the article status
for these pieces of wire remain intact.
Q When the processing or use of an item generates fumes,
dust, filings, and grindings, the article exemption is not
applicable. The chemical(s) in the item must be counted
toward the appropriate threshold determination, and the
fumes, dust, filings, and grindings reported as releases or
wastes. However, if all wastes generated are recycled,
whether on- or off-site, the exemption is applicable.
Q Toxic chemicals formed into pellets are not articles be-
cause the pellet form is simply a convenient form for
further processing of the material. Plastic pellets in-
tended for extrusion are not articles. The same is true for
metal ingots.
Q A closed item containing toxic chemicals (e.g., a trans-
former containing PCBs) that does not release the chemi-
cals during normal use is considered an article if the
facility uses the item as intended and the toxic chemicals
are not released. If the facility services the transformer by
replacing the toxic chemicals, the chemicals must be
counted in threshold and release calculations.
DURING A CALENDAR YEAR, DOES YOUR
FACILITY MANUFACTURE, PROCESS, OR USE A
LISTED CHEMICAL IN QUANTITIES GREATER
THAN THE THRESHOLD ESTABLISHED FOR
THAT YEAR?
Section 313 sets certain reporting threshold quantities, which
vary depending upon the yearfor which the report is submitted
and whether the chemical is manufactured, processed, or
otherwise used. You must submit a report if the quantity of a
listed chemical that is manufactured or processed over the
course of the year at your facility exceeds the following
threshold:
Q For calendar year 1987, 75,000 pounds;
Q For calendar year 1988, 50,000 pounds;
G For calendar year 1989 and subsequent years, 25,000
pounds.
You must submit a report if the quantity of a listed chemical
that is otherwise used at your facility exceeds 10,000 pounds
during the course of a calendar year.
How to Determine if Thresholds Are Exceeded
To determine whether your facility has exceeded a threshold,
compare quantities of listed chemicals that you manufacture,
process, or use to the separate respective thresholds for those
activities. A worksheet for threshold determinations is in-
cluded in Appendix C (page 54). Do not add together the
quantities of the chemical that are manufactured, processed,
and used at your facility, because each of these activities
requires a separate threshold determination. For example, if
in 1988 you processed 20,000 pounds of a chemical and you
used 6,000 pounds of that same chemical, your facility has not
met or exceeded any applicable threshold and thus is not
required to report for that chemical.
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General
Page8
You must submit a report if you exceed any threshold for any
listed chemical or chemical category. For example, if your
facility processes 22.000 pounds of a listed chemical and also
otherwise uses 16,000 pounds of that same chemical, al-
though you do not exceed the process threshold, you do
exceed the otherwise used threshold (10,000 pounds) and
you therefore must report. However, in preparing your re-
ports, you must consider all non-exempted activities and all
releases of that chemical from your facility, not just the
releases from the use activity.
Also note that threshold determinations are based upon the
actual amounts of a chemical manufactured, processed, or
used over the course of the calendar year, which may not
equal the amount brought on-site. Thus, stockpiles of listed
chemicals intended fora process that is not operated during a
calendar year do not count toward threshold determinations.
Threshold determinations of listed toxic chemicals that are
recycled or reused at the facility are based only on the amount
of the chemical that is added to such recycle/reuse activity
during the year, not the total volume in the system. For
example, a facility operates a refrigeration unit that contains
15,000 pounds of ammonia at the beginning of the year. The
system is charged with 2,000 pounds of ammonia at some
point of the year. The facility has therefore "used" only 2,000
pounds of the covered chemical and is not required to report
(unless there are other "uses" of ammonia which, when taken
together, exceed the reporting threshold). If, however, the
whole refrigeration unit had to be recharged with 15,000
pounds of ammonia during the year, the facility would have
exceeded the use threshold.
Threshold determinations for metal-containing compounds
present a special case. If, for example, you process several
different lead compounds, you would base your threshold
determination on the total weight of all lead compounds
processed. However, if you process 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 toxic chemicals. If you exceed thresholds for both the
parent metal and compounds of that same metal, EPA allows
you to file one joint report instead of two (e.g., one report for
lead compounds, including lead) because the release informa-
tion you will report in connection with metal compounds will be
the total pounds of the parent metal released.
One other case involving metal compounds should be noted.
Some metal compounds may contain more than one listed
metal. For example, lead chromate is considered 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.
Mixtures and Trade Name Products
De Minimis Limitation. Toxic chemicals in mixtures and in
tradename products must be factored into threshold and
release determinations. However, a listed chemical does not
have to be considered if it is present in a mixture at a
concentration below a specified de minimis level. In general,
the de minimis level is 1.0%, or 0.1 % if the chemical meets the
OSHA carcinogen standard. See Table II for the de minimis
value associated with each listed toxic chemical. EPA in-
cluded this exemption in the rule as a burden reducing step,
primarily because facilities are not likely to have information on
the presence of a chemical in a mixture or tradename product
beyond that available in the product's MSDS. The de minimis
levels are consistent with OSHA requirements for develop-
ment of the MSDS.
Forthreshold determinations, the de minimis limitation applies
to:
Q A listed toxic chemical in a mixture or tradename product
received by the facility.
Q A listed toxic chemical manufactured during a process
where the chemical remains in a mixture or product
distributed by the facility.
The de minimis does not apply to:
Q A chemical in a wastestream resulting from processes in
which that chemical is produced, whether as a product,
byproduct, or impurity. A threshold determination must
be made on the annual quantity of the chemical present
in the wastestream, regardless of the concentration. For
example, quantities of formaldehyde created as a result
of waste treatment must be applied toward the threshold
for "manufacture" of this chemical, regardless of the
concentration of this chemical in the wastestream.
Q Chemicals in ores, wastes, etc., that undergo intentional
beneficiation for purposes of production of that chemical.
For example, a company recovers; silver by processing
waste material containing silver at less than 1% total
weight of the material. Although silver is received at less
than the de minimis concentration, the de minimis would
not apply because the process concentrates and pro-
duces silver as an end product.
In general, when the de minimis applies to threshold determi-
nations and the percent in the mixture is below the de minimis,
then you are not required to report releases associated with
the processing or use of the chemical in that mixture. Note that
it is possible to meet the threshold for a chemical on a facility-
wide basis, but not be required to calculate releases from a
particular process because that process involves only mix-
tures containing the chemical below the de minimis level.
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Page 9
General
Application of the de minimis limitation to process streams
must also be reviewed. Mixtures containing listed toxic
chemicals can be added to a process or generated within a
process. In both cases (assuming thresholds are exceeded)
a facility is required to consider and report releases from the
process up to the point at which the concentration of the
chemical falls below the de minimis level. For example, a 10%
solution of a listed chemical is mixed into a formulated cleaning
solution, resulting in a final concentration of less than 1 %.
Releases such as air emissions from the mix vessel are
counted, but releases from the finished formulation are not
counted.
Supplier Notification. In 1989, suppliers of facilities in SIC
codes 20-39 will be required to develop and distribute a notice
if the mixtures or trade name products that they manufacture
or process, and subsequently distribute, contain listed toxic
chemicals and are distributed to other companies in SIC codes
20-39 or to companies that sell the product to facilities in SIC
codes 20-39. If a Material Safety Data Sheet (MSDS) is not
required forthe mixture ortrade name product, the notification
must be written. Otherwise, the notice must be incorporated
into or attached to the MSDS for that product. The supplier
notification requirement begins with the first shipment of a
product in 1989 and must accompany the first shipment each
year thereafter. In addition, a new or revised notice must be
sent if a change occurs in the product which affects the weight
of a listed chemical or if it is discovered that a previous notice
did not properly identify the chemicals or the percentage by
weight.
Note to Suppliers: An item is still considered an article if you
can determine that the total releases of any toxic chemical that
are likely to occur from the processing or use of that article by
your largest volume customer for the product will not equal or
exceed 0.5 pounds per year. (See page 7 for further explana-
tion of half-pound rounding for articles.)
If listed toxic chemicals are present above the de minimis cut-
off level, your supplier must identify the specific components
as they appear in Table II and provide their percentage
composition by weight in the mixture or product. If your
supplier maintains that the identity of a toxic chemical is a trade
secret, a generic identity that is structurally descriptive must
be supplied on the notice. A maximum concentration level
must be provided if your supplier contends that chemical
composition information is a trade secret. In either case, you
do not need to make a trade secret claim on behalf of your
supplier (unless you consider your use of the proprietary
mixture a trade secret). Report using the generic name
provided in the notification. (See the instructions for Part III,
Section 2 on page 16 for more information.) If the listed
chemical is present below the de minimis level, no notification
is required.
If you imported, processed, or otherwise used mixtures or
trade name products during calendar year 1988, you are
required to use the best information you have available to
determine whetherthe components of a mixture are above the
de minimis concentration and therefore must be included in
threshold and release determinations. If you know that a
mixture ortrade name product contains a specific toxic chemi-
cal, combine the amount of the chemical in the mixture or
product with the individual amounts of the same chemical
manufactured, processed, or otherwise used at your facility for
threshold and release determinations. If you know only the
maximum concentration of the toxic chemical present in the
mixture or product, then you are required to assume that the
toxic chemical is present at that concentration and calculate
the weight accordingly. (See Figure 2 for more information.)
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General
Page 10
Figure 2
Mixture and Trade Name Products -
How They Factor Into Your Reports
Any covered toxic chemicals In mixtures or trade name products (M/TNP) must be factored
into your threshold and release determinations.
Do you know that a listed §313
chemical is present In M/TNP?
Yes
I No
Jri
You cannot report for this
M/TNP.
Is specific chemical identity
known?
Yes
Go to Case B on
next page.
1
Case A - Specific listed chemical identity is known
Do you know specific or upper
bound concentration of the
chemical in the M/TNP?
Yes
p..
You cannot report for this
M/TNP.
J
Concentration x total pounds used or processed =
Quantity of listed!
chemical used or processed.
1
Add this quantity to other
known quantities of same
chemical used/processed.
Has the use or the process
threshold been exceeded for
that listed chemical?
Yes
No
Report that listed
chemical In Part
III, Section 1 and
complete the
rest of Form R.
J
Report not
required.
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Page 11
General
Figure 2 (continued)
Case B - Generic identity is known (e.g., your supplier has told you it
is §313 chemical but considers the specific identification as trade
secret).
Is the M/TNP used in excess of •
1 0,000 Ibs/year or processed in 1
excess of the applicable thresh- 1
old for the year? 1
Yes
i
Do you know the specific or 1
upper bound concentration? 1
Yes
i
l
Does the concentration x total L
pounds of M/TNP used or proc- 1
essed exceed the use or appll- 1
cable process threshold? 1
Yes
1
No
Report the generic name in Part
III, Section 2 of the form and
complete the rest of Form R.
You do not have to report for
this M/TNP.
This mixture cannot be included
in your report.
This mixture cannot be included
in your report.
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Form R - Part I
Page 12
INSTRUCTIONS FOR COMPLETING SPECIFIC SECTIONS OF EPA FORM R
The following are specific instructions for completing each part
of EPA Form R. The number designations of the parts and
sections of these instructions correspond to those in Form R
unless otherwise indicated.
A sample, completed Form R for a hypothetical facility report-
ing under Title III, section 313, is included as Appendix A (page
47). You may want to referto this sample as you read through
these instructions.
Answer this question only after you have completed the rest of
the report. The specific identity of the toxic chemical being
reported in Part III, Sections 1.2 and 1.3, may be designated
as trade secret. If you are making a trade secret claim, mark
"yes" and proceed to Section 1.2. Only check "Yes" if It Is your
manufacturing, processing, or use of the chemical that is a
trade secret. (See page 1 of these instructions for specific
information on trade secrecy claims.) If you checked "no,"
proceed to Section 1.3; do not answer Section 1.2.
Instructions for Completing All Parts of Form R:
1. Type or print information on the form in the units and
format requested.
2. Longitudinal and latitudinal data were optional for the
1987 reports but are required for 1988 and subsequent
reporting years. All information on Form R is required
except Part III, Section 8.
3. Do not leave items on Form R blank unless specifically
directed to do so; if an item does not apply to you, enter
"NA," not applicable, 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.
4. Do not submit an incomplete form. The certification
statement (Part I) specifies that the report is complete as
submitted. See page 1 of these instructions forthe defini-
tion of a complete submission.
5. When completing Part IV, supplemental information, or
additional pages for Part II of the form, number the
additional information sequentially from the prior sections
of the form.
6. The box labelled "This space for your optional use" on
each page may be used to differentiate one chemical-
specific submission from another. You are not required to
enter any information in this space. See page 2 for use
of this box relating to a voluntary revision of a previous
submission.
1.2 If "ves" in 1.1. 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 and you have claimed the chemical identity
trade secret in Part III, Section 1.1. Otherwise, check "unsani-
tized."
1.3 Reporting Year
Enter the last two digits of the calendar year to which the
reported information applies, not the year in which you are
submitting the report. Information forthe 1988 reporting year
must be submitted on or before July 1,1989.
2. 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 complete-
ness 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.
3. Facility Identification
PART I. FACILITY IDENTIFICATION INFORMATION
1.1 Are vou claiming the chemical identity on page 3 trade
secret?
3.1 Facility Name and Location
Enter the name of your facility (plant site name or appropriate
facility designation), street address, city, county, state, and zip
code in the space provided. Do not use a post office box
number as the address. The address provided should be the
location where the chemicals are manufactured, processed,
or otherwise used.
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Page 13
Form R - Part I
3.2 Fulj or Partial Facility Indication
A covered facility must report all releases of a listed chemical
if it meets a reporting threshold for that chemical. However, if
the facility is composed of several distinct establishments,
EPA allows these establishments to submit separate reports
for the chemical as long as all releases of the chemical from
the entire facility are accounted for. Indicate in Section 3.2
whether your report is for the entire covered facility as a whole
or for part of a covered facility. Check box a. if the chemical
information applies to the entire covered facility. Check box b.
if the chemical information applies only to part of a covered
facility.
Section 313 requires reports by "facilities," which are defined
as "all buildings, equipment, structures, and other stationary
items which are located on a single site or on contiguous or
adjacent sites and which are owned or operated by the same
person."
The SIC code system defines business "establishments" as
"distinct and separate economic activities [that] are performed
at a single physical location." Under section 372.30(c) of the
reporting rule, you may submit a separate Form R for each
establishment, or for groups of establishments, in your cov-
ered facility, provided that all releases of the toxic chemicals
from the entire covered facility are reported. This allows you
the option of reporting separately on the activities involving a
toxic chemical at each establishment, or group of establish-
ments (e.g., part of a covered facility), rather than submitting
a single Form R for that chemical for the entire facility.
However, if an establishment or group of establishments does
not manufacture, process, or otherwise use or release a toxic
chemical, you do not have to submit a report for that establish-
ment or group of establishments.
3.3 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.
3.4 Public Contact
Enter the name and telephone number (including area code)
of a person who can respond to questions from the public
about the report. If you choose to designate the same person
as both the technical and the public contact, you may enter
"Same as Section 3.3" 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.
3.5 Standard Industrial Classification (SIC1 Code
Enter the appropriate 4-digit primary Standard Industrial Clas-
sification (SIC) code for your facility (Table I, page 30, lists the
SIC codes within the 20-39 range). If the report covers more
than one establishment, enter the primary 4-digit SIC code lor
each establishment. You are required to enter SIC codes only
for those establishments within the facility that fall within SIC
codes 20 to 39.
3.6 Latitude and Longitude
Enter the latitudinal and longitudinal coordinates of your facil-
ity. Sources of these data include EPA permits (e.g., NPDES
permits), county property records, facility blueprints, and site
plans. Instructions on how to develop these coordinates can
be found in Appendix B (page 52). Enter only numerical data.
Do not preface numbers with letters such as N or W to denote
the hemisphere.
3.7 Facility Dun and Bradstreet Number
Enter the 9-digit number assigned by Dun and Bradstreet
(D&B) for your facility or each establishment within your
facility. These numbers code the facility for financial pur-
poses. This number may be available from your facility's
treasurer orfinancial officer. You can also obtain the numbers
from your local Dun and Bradstreet office (check the White
Pages). If none of your establishments has been assigned a
D&B number, enter not applicable, NA, in box a. If only some
of your establishments have been assigned Dun and Brad-
street numbers, enter those numbers in Section 3.7.
3.8 EPA Identification Number
The EPA I.D. Number is a 12-digit 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 yourfacility 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 3.8.
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Form R - Part II
Page 14
3.9 NPDES Permit Number
Enter the numbers of any permits your facility holds under the
National Pollutant Discharge Elimination System (NPDES).
This 9-digit 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 box
a.
3.10 Receiving Streams or Water Bodies
In Section 3.10 you are to enter the name(s) of the stream(s)
or water body(ies) to which your facility directly discharges the
chemicals you are reporting. A total of six spaces are
provided, lettered a through f. The information you provide
relates directly to the discharge quantity information required
in Part III, Section 5.3. You can complete Section 3.10 in one
of two ways. You can enter only those stream names that
relate to the specific chemical that is the subject of the report
or, you can enter all stream names that relate to all covered
chemicals being reported by the facility. Enterthenameofthe
first receiving stream or surface water body to which the
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 you do not have a permit,
enter the name of the off-site stream or water body by which
it is publicly known. Be sure to include the receiving stream(s)
or water body(ies) that receive stormwater runoff from your
facility. Qp not enter names of streams to which off-site
treatment plants discharge. Also do not list a sen'es of streams
through which the chemical flows. Enter not applicable, NA, in
3.10a. if you do not discharge any listed toxic chemicals to
surface water bodies.
3.11 Underground Injection Well Code (UIC) Identification
Number
If your facility has a permit to inject a chemical-containing
waste that includes the toxic chemicals 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 3.11 a.
4. Parent Company Information
You must provide information on your parent company. For
purposes of Form R, a parent company is defined as the
highest holder 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 sites. For
example, the Bestchem Corporation is not owned orcontrolled
by any other corporation. It has several sites throughout the
country whose names begin with Bestchem. In this case,
Bestchem Corporation would be listed as the "parent" com-
pany.
4.1 Name of Parent Company
Enterthe name of the corporation or other business entity that
is your parent company. If your facility has no parent com-
pany, enter not applicable, NA.
4.2 Parent Company's Dun & Bradstreet Number
Enter the Dun and Bradstreet Number lor your parent com-
pany, if applicable. The number may tie obtained from the
treasurer or financial officer of the company. If your parent
company does not have a Dun and Bradstreet number, enter
not applicable, NA.
PART II. OFF-SITE LOCATIONS TO WHICH TOXIC
CHEMICALS ARE TRANSFERRED IN WASTES
In this part of the form you are required to list all off-site
locations to which you transfer wastes containing toxic chemicals.
Do not list locations to which products containing toxic chemi-
cals are shipped for sale or distribution in commerce or for
further use. Also, do not list locations to which wastes
containing chemicals are sold or sent for recovery, recycling,
or reuse of the toxic chemicals. The information that you enter
in this section relates to data you will report in Part III, Section
6. You may complete Part II for only the off-site locations that
apply to the specific chemical cited in a particular report or you
can list all off-site locations that apply to all chemicals being
reported and include a photostatic copy of Part II with each
individual report. List only publicly owned treatment works
(POTWs) and off-site treatment or disposal facilities.
1. Publicly Owned Treatment Works (POTWs)
Enter the name and address of each POTW to which your
facility discharges wastewater containing toxic chemicals for
which you are reporting. If you do not discharge wastewater
containing the reported toxic chemicals to a POTW, enter not
applicable, NA in the facility name line of 1.1.
If you discharge such wastewater to more than two POTWs,
use additional copies of Part II. Cross through the printed
numbers and write in numbers forthese locations in ascending
order (e.g., 1.3,1.4). Check the box at the bottom of the page
and indicate the number of additional pages of Part II that are
attached.
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Page 15
Form R - Part III
2. Other Off-Site Locations
Enter in the spaces provided, the name and address of each
location (other than POTWs) to which you ship or transfer
wastes containing toxic chemicals. If you do not ship or
transfer wastes containing toxic chemicals to off-site loca-
tions, enter not applicable, NA in the Off-site location name line
of 2.1. Also enter the EPA Identification Number (RCRA I.D.
Number) for each such location if known to you. This number
may be found on the Uniform Hazardous Waste Manifest,
which is required by RCRA regulations. Also indicate in the
space provided whetherthe location is owned or controlled by
your facility or your parent company. If the facility does not
have a RCRA I.D. number, enter not applicable, NA, in this
space.
If yourf acility transfers toxic chemicals to more than six off-site
locations, use additional copies of Part II. Cross through the
printed numbers and write in numbers for these locations in
ascending order (i.e., 2.7, 2.8). Check the box at the bottom
of the page and indicate the number of additional pages of Part
II that are attached.
EXAMPLE
Yourfacility is involved in chrome plating of metal parts, which
are shipped to an off-site warehouse not owned by your
company for distribution. Your facility produces an aqueous
plating waste that is treated on-sits to recover chromium
sludge. The effluent from the on-site treatment plant, which
contains chromium compounds (a listed toxic chemical), is
piped to a POTW. The chromium sludge is transferred to an
off-site, privately owned recovery firm. Chromium is recov-
ered from the sludge by an ion exchange process. Yourfacility
also produces a solid waste containing chromium, which is
sent to an off-site permitted landfill owned by your facility.
You must report the locations of the POTW and the permitted
landfill in Sections 1 and 2 of Part II of Form R. Do not report
the location of the warehouse or give any information about
the on-site treatment plant in this section. Indicate that the
landfill is underthe control of yourfacility. You are not required
to report the location of the off-site, privately owned recovery
firm or provide any information concerning off-site recovery.
PART III. CHEMICAL-SPECIFIC INFORMATION
In Part III, you are to identify the toxic chemical being reported.
You are to indicate some general uses and activities related to
the chemical at your facility. Also in Part III you will enter
quantitative data relating to releases of the chemical directly
from the facility to air, water, and land. Quantities of the
chemical transferred to off-site locations, identified in Part II,
are also reported in this part. The final required section
provides for reporting of waste treatment information. An
additional optional section is included in this part that allows
you to report waste minimization information associated with
the chemical.
1.1 [Reserved]
1.2 CAS Number
Enter the Chemical Abstracts Service (CAS) registry number
in Section 1.2 exactly as it appears in Table II, page 36, 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 chemical catego-
ries in Table II (e.g., copper compounds), enter not applicable,
NA, in the CAS number space.
If you are making a trade secret claim, you must report the
CAS number on your unsanitized Form R and unsanitized
substantiation form. Do not report it on your sanitized Form R
and sanitized substantiation form.
1.3 Chemical or Chemical Category Name
Enter the name of the chemical or chemical category exactly
as it appears in Table II. If the chemical name is followed by
a synonym in parentheses, report the chemical by the name
that directly follows the CAS number (i.e., not the synonym).
If the listed chemical identity is actually a product tradename
(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,
including individual members of a reportable category. For
example, if you use silver nitrate, do not report silver nitrate
with its CAS number. Report this chemical as "silver com-
pounds" with no CAS number.
If you are making a trade secret claim, you must report the
specific chemical identity on your unsanitized Form R and
unsanitized substantiation form. Do not report the chemical
name on your sanitized Form R and sanitized substantiation
form; report a generic name in Section 1.4 below.
1.4 Generic Chemical Name
Complete Section 1.4 only if you are claiming the specific
chemical identity of the toxic chemical as a trade secret and
have marked the trade secret block in Part I, Section 1.1 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 1.4; see Section 2 below.
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Form R - Part
Page 16
In-house plant codes and other substitute names that are not
structurally descriptive of the chemical identity being withheld
as a trade secret are not acceptable as a generic name. The
generic name must appear on both sanitized and unsanitized
Form R's, and the name must be the same as that used on
your substantiation forms. The Emergency Planning and
Community Right-to-Know Information Hotline can provide
you with assistance in selecting an appropriate generic name.
2. Mixture Component Identity
Do not complete this section if you have completed Section 1
of Part III. Report the generic name provided to you by your
supplier in the section if your supplier is claiming the chemical
identity proprietary or trade secret. Do not answer "yes" in
Part I, Section 1.1 on page 1 of the form if you complete this
section. You do not need to supply substantiation forms.
Enter the generic chemical name in this section only if the
following four conditions apply:
1. The amount of the particular mixture or trade name prod-
uct you "use" exceeds 10,000 pounds or the amount you
"process" exceeds the applicable process threshold for
the year (i.e., 50,000 Ibs. in 1988);
2. You determine that the mixture contains a listed toxic
chemical but the only identity you have for that chemical
is a generic name;
3. You know either the specific concentration of that toxic
chemical component or a maximum concentration figure;
and
4. You determine by multiplying the concentration figure by
the total annual amount of the whole mixture used (or
processed) that you exceed the use or process threshold
for that single, generically identified mixture component.
EXAMPLE
Your facility uses 20,000 pounds of asolvent that yoursupplier
has told you contains 80 percent "chlorinated aromatic," their
generic name for a chemical subject to reporting under section
313. You therefore know that you have used 16,000 pounds
of some listed toxic chemical which exceedsthe use threshold.
You would file a Form R and enter the name "chlorinated
aromatic" in the space provided in Part III, Section 2.
3. Activities and Uses of the Chemical at the Facility
Indicate in this section whether the chemical is manufactured
(including imported), processed, or otherwise used at the
facility and the general nature of such activities and uses at the
facility during the calendar year. Report activities that take
place only at your facility, not activities that take place at other
facilities involving your products. You rqust check all the
blocks in this section that apply. If you are a manufacturer of
the chemical, you must check a and/or b, and at least one of
c, d, e, or f. Refer to the definitions of "manufacture,"
"process," and "otherwise use" in the general information
section of these instructions or section 372.3 of the rule for
explanations supplementing those provided below.
3.1 Manufacture the Chemical
Check at least one:
a. Produce- A chemical included in this category is produced
at the facility.
b. Import- A chemical included in this category is imported
by the facility into the Customs Territory of the United
States.
Check at least one:
c. For on-sfte use/processing - A chemical included in this
category is produced or imported and then further proc-
essed or otherwise used at the same facility. If you check
this block you must also check at least one item in 3.2 or
3.3.
d. For sale/distribution - A chemical in this category is pro-
duced or imported specifically for sale or distribution
outside the manufacturing facility.
e. As a byproduct- A chemical in this category is produced
coincidentally during the production, processing, use, or
disposal of another chemical substance or mixture and,
following its production, is separated from that other
chemical substance or mixture. Chemicals produced and
released as a result of waste treatment or disposal are
also considered byproducts.
f. As an impurity- A chemical in this category is produced
coincidentally as a result of the manufacture, processing
or use of another chemical but remains primarily In the
mixture or product with that other chemical.
3.2 Process the Chemical (incorporative-tvpe activities)
a. As a reactant - A natural or synthetic chemical used in
chemical reactions for the manufacture of another chemi-
cal substance or of a product. Includes, but is not limited
to, feedstocks, raw materials, intermediates, and initia-
tors.
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Page 17
Form R - Part
b. As a formulation component - A chemical added to a
product or product mixture prior to further distribution of
the product that acts as a performance enhancer during
use of the product. Examples of chemicals used in this
capacity include, but are not limited to, additives, dyes,
reaction diluents, initiators, solvents, inhibitors, emulsifi-
ers, surfactants, lubricants, flame retardants, and rheol-
ogical modifiers.
c. As an article component - A chemical substance that
becomes an integral component of an article distributed
for industrial, trade, orconsumer use. One example is the
pigment components of paint applied to a chair that is
sold.
d. Repackaging only- Processing or preparation of a chemi-
cal 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 cans or bottles.
3.3 Otherwise Use the Chemical (non-incorporative-tvpe
activities^
a. As a chemical processing aid- A chemical that is added to
a reaction mixture to aid in the manufacture or synthesis
of another chemical substance but is not intended to
remain in or become part of the product or product
mixture. Examples of such chemicals include, but are not
limited to, process solvents, catalysts, inhibitors, initia-
tors, reaction terminators, and solution buffers.
b. As a manufacturing aid- A chemical that aids the manu-
facturing process but does not become part of the result-
ing product and is not added to the reaction mixture during
the manufacture or synthesis of another chemical sub-
stance. Examples include, but are not limited to, lubri-
cants, metalworking fluids, coolants, refrigerants, and
hydraulic fluids.
c. Ancillary or other use - A chemical in this category is used
at a facility for purposes otherthan as a chemical process-
ing aid or manufacturing aid as described above. In-
cludes, but is not limited to, cleaners, degreasers, lubri-
cants, and fuels.
EXAMPLE
In the example below, it is assumed that the threshold quan-
tities for manufacture, process, or otherwise use (50,000
pounds, 50,000 pounds, and 10,000 pounds, respectively, for
1988) have been exceeded and the reporting of listed chemi-
cals is therefore required.
1. Yourfacility receives toluene and naphthalene (both listed
toxic chemicals) from an off-site location. You react the
toluene with air to form benzole acid and react the
naphthalene with sulfuric acid, which forms phthalic acid
and also produces sulfur dioxide fumes. Your facility
processes toluene and naphthalene. Both are used as
reactants to produce benzole acid and phthalic acid,
chemicals not on the section 313 list.
The phthalic acid and benzole acid are reacted to form a
reaction intermediate. The reaction intermediate is dis-
solved in sulfuric acid, which precipitates terephthalic acid
(TPA). Fifty percent of the TPA is sold as a product and
50 percent is further processed at your facility into polyes-
ter fiber. The TPA is treated with ethylene glycol to form
an intermediate product, which is condensed to polyester.
Your company manufactures terephthalic acid, a listed
chemical, both for sale/distribution as a commercial prod-
uct and for on-site use/processing as a feedstock in the
polyester process. Because it is a reactant. it is also
processed.
Yourfacility also uses, as well as processes, sulfuric acid,
a listed substance, as it serves as a process solvent to
precipitate terephthalic acid.
2. The intermediate product, from which the polyester is
prepared, contains dimethyl phthalate, a listed substance.
The method of reporting this substance depends on its
eventual disposition in the polyester production process:
(a) If the dimethyl phthalate is removed from the interme-
diate product before it is reacted to form polyester
fiber, then dimethyl phthalate is manufactured at your
facility as a byproduct.
(b) If it is incorporated into the polyester fiber in an un-
reactedform. then it is manufactured at yourfacility as
an impurity.
(c) If the dimethyl phthalate participates in the reaction to
form polyester fiber without leaving the process, then
it is processed as a reactant (intermediate), as are the
ethylene glycol and terephthalic acid in the process.
Sections of Part III that have been completed for scenario
2(c), are illustrated on the following page.
3. Your facility operates a fume scrubber that uses sodium
hydroxide solution and recovers the sulfur dioxide fumes
from the phthalic acid production process as sodium
sulfate solution. Both sodium solutions are listed chemi-
cals. Your facility manufactures sodium sulfate as a
byproduct and otherwise uses sodium hydroxide.
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Form R - Part
Page 18
4. Your facility applies C.I. disperse yellow 3, a listed chemi-
cal, to the finished polyester fiber as a dye, which is
incorporated into the polyester fiber product and remains
in the product after it is sold. Your facility processes the
C.I disperse yellow 3 as an article component.
D
(Important: Type or print; read instructions before completing form.)
D
Page 3 of 5
A ppA EPA FORM R
^Jr E-rf-V PART III. CHEMICAL-SPECIFIC INFORMATION
(This space for your optional use.)
1. CHEMICAL IDENTITY(Do not complete this section if you complete Section 2.)
1.1
1,2
1.3
1.4
2.
[Reserved]
CAS Number (Enter the number exactly as it appears on the 313 list. Enter NA if reporting a chemical category.)
131-11-3
Chemical or Chemical Category Name (Enter
Dimethyl Phthalate
Generic Chemical Name (Complete only if Part
the name exactly as it appears on the 313 list.)
Section 1.1 is checked "Yes.™ Generic name must be structurally descriptive.)
MIXTURE COMPONENT IDENTITY (Do not complete this section if you complete Section 1 .)
Generic Chemical Name Provided by Supplier (Limit the name to a maximum ot 70 characters (e,g.. numbers, letters, spaces, punctuation) )
3. ACTIVITIES AND USES OF THE CHEMICAL AT THE FACILITY (Check all that apply.)
3.1
3.2
3.3
Manufacture the
chemical: TV 1
a . I J Produce
b. 1 J Import
If produce or import:
[X 1 For on-site
c.l J use/processing "•
e.[ J As a byproduct f.
' I For sale/
J distribution
j As an impurity
Process the r i r 1 As a formulation f ] As an article
chemical: a. [X J As a reactant b.(. J component c.l J component
d.[ J Repackaging only
Otherwise us* f 1 As a chemical
. . . a. 1 J processing aid
the chemical:
b . I J As a manufacturing aid c .
J Ancillary or other use
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Page 19
Form R - Part III
4. Maximum Amount of the Chemical On-Site at Any
Time During the Calendar Year
Insert the appropriate code (see below) that indicates the
maximum quantity of the chemical (e.g., in storage tanks,
process vessels, on-site shipping containers) at yourfacility at
any timeduring the calendar year. If the chemical was present
at several locations within yourfacility, use the maximum total
amount present at the entire facility at any one time.
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 toxic chemical present at your facility was part of a
mixture or trade name product, determine the maximum
quantity of the chemical present at the facility by calculating
the weight of the toxic chemical only. Do not include the weight
of the entire mixture or trade name product. See section
372.30(b) of the reporting rule for further information on how
to calculate the weight of the chemical in the mixture or trade
name product. For chemical categories (e.g., copper com-
pounds), include all chemicals in the category when calculat-
ing the weight of the toxic chemical.
5. Releases of the Chemical to the Environment On-Site
In Section 5, you must account forthe total aggregate releases
of the toxic chemical to the environment on-site from your
facility for the calendar year. 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), enter not
applicable, NA: do not leave blank. Check the box on the last
line of this section if you use Part IV, the supplemental
information sheet.
You are not required to count as a release quantities of a toxic
chemical that are lost due to natural weathering or corrosion,
normal/natural degradation of a product, or normal migration
of a chemical from a product. For example, amounts of a
covered toxic chemical that migrate from plastic products in
storage do not have to be counted in estimates of releases of
that chemical from the facility. Also, amounts of listed metal
compounds (e.g., copper compounds) that are lost due to
normal corrosion of process equipment do not have to be
considered as releases of copper compounds from the facility.
All air releases of the chemical from the facility must be
accounted for. Do not enter information on individual emission
points or releases. Enter only the total release. If there is
doubt about whether an air release is a point or non-point
release, you must identify the release as one or the other
rather than leave items 5.1 and 5.2 blank. 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
These are releases 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; (3) releases from building ventilation sys-
tems; and (4) any other fugitive or non-point air emissions.
5.2 Stack or Point Air Emissions
These are releases 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.
5.3 Discharges to Receiving Streams or Water Bodies
Enter the applicable letter code for the receiving stream or
water body from Section 3.10 of Part I of the form. Also, enter
the total annual amount of the 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 sys-
tems, and the contribution from stormwater runoff, if appli-
cable (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 ill, Section 6 of the form.
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Form R - Part
Page 20
5.4 Underground Injection
Enter the total annual amount of the chemical that was injected
into all wells, including Class I wells, at the facility.
5.5 Releases to Land
Report quantities of the chemical that were landf illed, treated
or applied in farming, impounded, or otherwise disposed of al
the facility. Do not report land disposal at off-site locations in
this section.
For the purpose of this form, a surface impoundment is
considered "final disposal." Quantities of the chemical re-
leased to surface impoundments that are used merely as part
of a wastewater treatment process generally must not be
reported in this section of the form. However, if the impound-
ment accumulates sludges containing the chemical, you must
include an estimate in this section unless the sludges are
removed and otherwise disposed of (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 the form.
A. Total Release
Only on-site releases of the toxic chemical to the environment
for the calendar year are to be reported in this section of the
form. The total releases from your facility do not include
transfers or shipments of the chemical from your facility for
sale or distribution in commerce or of wastes to other facilities
for treatment or disposal (see Part III, Section 6). 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.
Total annual releases or off-site transfers of a toxic chemical
from the facility of less than 1 pound may be reported in one
of several ways. The fractional figure may be entered in
column A.2. However, EPA encourages rounding to the
nearest pound. For example, if the estimate is 0.5 pounds or
greater, you should either check the range bracket of "1 -499"
in column A.1 or enter "1" in column A.2. Do not use both
columns A.1 and A.2. If the release is less than 0.5 pounds,
you may round to zero and check the "0" bracket in A.1. Note
that releases of less than 0.5 pounds from the processing or
use of an article does not negate the article status of that item.
Thus, if the only releases you have are from an article and such
releases are less than 0.5 pounds per year, you are not
required to submit a report for that chemical.
A.1 Reporting Ranges
For reports submitted for calendar years 1987,1988 and 1989
only, you may take advantage of range reporting for releases
to an environmental medium that are less than 1,000 pounds
for the year. If you choose this option, mark one of the three
boxes, 0,1-499, or 500-999, that corresponds to releases of
the chemical to the appropriate environmental medium (i.e.,
any line item). You are not required, however, to use these
range check boxes; you have the option of providing a specific
figure in column A.2, as described below. However, do not
mark a range and also enter a specific estimate in A.2.
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.2. Any estimate provided in column A.2 is
required to be accurate to no more than two significant digits.
A.2 Enter Estimate
If you do not use the range reporting option, provide your
estimates of releases in pounds for the year in column A.2.
This estimate is required to be rounded to no more than two
significant digits.
Calculating Releases - To provide the release information
required in both columns A.1 and A.2 in this section of the
form, you must use all readily available data (including rele-
vant monitoring data and emissions measurements) collected
at your facility pursuant to other provisions of law or as part of
routine plant operations, to the extent you have such data for
the toxic 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 an v toxic chernjcal released into the environ-
ment, or of the frequency of such releases, is required for the
purpose of completing this form, bevond that which is required
under other provisions of law or regulation or as part of routine
plant operations.
You must estimate as accurately as possible the quantity in
pounds of the chemical or chemical category that is released
annually to each environmental medium. Include only the
quantity of the toxic chemical component of the waste stream
in this estimate. If the toxic chemical present at your facility
was part of a mixture or trade name product, calculate only the
releases of the chemical. Do not report releases of the other
components of the mixture or trade name product. If you are
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Page 21
Form R - Part III
only able to estimate the releases of the mixture ortrade name
product as a whole, you must assume that the release of the
toxic chemical is proportional to its concentration in the mix-
ture or trade name product. See section 372.30(b) of the
reporting rule (Appendix G) for further information on how to
calculate the concentration and weight in the mixture ortrade
name product.
If you are reporting a chemical category listed in Table II of
these instructions, rather than a specific chemical, you must
combine the release data for all chemicals in the listed chemi-
cal category (e.g., all glycol ethers or all chlorophenols) and
report the aggregate amount for that chemical category. Do
not report releases of each individual chemical in that category
separately. Forexample,if yourfacility releases3,000pounds
per year of 2-chlorophenol, 4,000 pounds per year of 3-chlo-
rophenol, and 4,000 pounds per year of 4-chlorophenol, you
should report that your facility releases 11,000 pounds per
year of chlorophenols.
For listed chemicals with the qualifier "solution," such as
sodium sulfate, at concentrations of 1 percent (or 0.1 percent
in the case of a carcinogen) or greater, the chemical concen-
trations must be factored into threshold and release calcula-
tions because threshold and release amounts relate to the
amount of chemical in solution, not the amount of solution.
For metalcompoundcategories (e.g., chromium compounds),
report releases of only the parent metal. For example, a user
of various inorganic chromium salts would report the total
chromium released in each waste type regardless of the
chemical form (e.g., as the original salts, chromium ion, oxide)
and exclude any contribution to mass made by other species
in the molecule.
EXAMPLE
Your facility disposes of 14,000 pounds of lead chromate
(PbCrO4PbO) and 15,000 pounds of zinc dichromate
(ZnCr2O73H2O) in an on-site landfill and transfers 16,000
pounds of lead selenate (PbSeO4) to an off-site land disposal
facility. You would therefore be submitting four separate
reports on the following: lead compounds, zinc compounds,
selenium compounds, and chromium compounds. However,
the quantities you would be reporting would be the pounds of
"parent" metal being released or transferred off-site. All
quantities are based on mass balance calculations (See
Section 5.B for information on Basis of Estimate and Section
6.C for treatment/disposal codes and information on transfers
of chemical wastes). You would calculate releases of lead,
zinc, chromium, and selenium by first determining the percent-
age by weight of these metals in the materials you use as
follows:
Lead Chromate (PbCrO4PbO) -
Molecular weight
Lead 2Pb-
Molecular weight =
Chromate 1 Cr -
Molecular weight =
546.37
207.2x2 = 414.4
51.996
Lead chromate is therefore (% by weight)
(414.4/546.37) = 75.85% lead and (51.996/546.37) =
9.52% chromium
You can then calculate the total amount of the metals that you
must report.
14,000 pounds of lead chromate contains:
14,000x0.7585 = 10,619 Ibs of lead
14,000x0.0952 = 1,332.8 Ibs of chromium
Similarly, zinc dichromate is (65.38/335.4) = 19.49% zinc and
(51.996 x 2/335.4) = 31.01% chromium, and lead selenate is
(207.2/350.17) = 59.17% lead and (78.96/350.17) = 22.55%
selenium.
The total pounds of lead, chromium, zinc, and selenium
released or transferred from yourfacility are as follows:
Lead
Release:
0.7585 x 14,000 = 10,619.0 Ibs from lead chromate (round
to 11,000 Ibs)
Transfer:
0.5917 x 16,000 = 9,467.2 Ibs from lead selenate (round to
9,500 Ibs)
As an example, the releases and transfers of lead should be
reported as illustrated on the next page.
Chromium
Release:
0.0952 x 14,000 = 1,332.8 Ibs from lead chromate (round to
1,300 Ibs)
Release:
0.3101 x 15,000 = 4,651.5 Ibs from zinc dichromate (round
to 4,700 Ibs)
Zinc
Release:
0.1949 x 15,000 = 2,923.5 Ibs from zinc dichromate (round
to 2,900 Ibs)
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Form R - Part I
Page 22
Selenium
Transfer:
0.2255 x 16,000 = 3,608.0 Ibs of selenium from lead
selenate (round to 3,600 Ibs)
B. Basis of Estimate
For each release estimate, you are required to indicate the
principal method by which the quantity was derived. Enter a
letter code from below that identifies the method that applies
to the largest portion of the total estimated quantity. EPA
requires that decimal fractions be rounded to no more than two
significant digits when reporting releases.
For example, if 40 percent of stack emissions of the reported
substance 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. The codes are as
follows:
M -Estimate is based on monitoring data or measurements
forthe toxic chemical as released to the environment and/
or off-site facility.
C -Estimate is based on mass balance calculations, such as
calculation of the amount of the toxic chemical in streams
entering and leaving process equipment.
E -Estimate is based on published emission factors, such as
those relating release quantity to through-put or equip-
ment type (e.g., air emission factors).
O -Estimate is based on other approaches such as engineer-
ing calculations (e.g., estimating volatilization using pub-
lished mathematical formulas) or best engineering judg-
ment. This would include applying an estimated removal
efficiency to a waste stream, even if the composition of
the stream before treatment was fully characterized by
monitoring data.
If the monitoring data, mass balance, or emission factor used
to estimate the release is not specific to the toxic chemical
being reported, the form should identify the estimate as based
on engineering calculations or judgment.
If a mass balance calculation yields the flow rate of a waste
stream, but the quantity of reported chemical in the waste
stream is based on solubility data, report "O" because "engi-
neering calculations" were used as the basis of estimate of the
quantity of the chemical in the waste stream.
If the concentration of the chemical in the waste stream was
measured by monitoring equipment and the flow rate of the
waste stream was determined by mass balance, then the
primary basis of estimate is "monitoring" (M) even though a
mass balance calculation also contributed to the estimate.
"Monitoring" should be indicated because monitoring data
was used to estimate the concentration of the waste stream.
Mass balance (C) should only be indicated if it is directly used
to calculate the mass (weight) of chemical released. Monitor-
ing data should be indicated as the basis of estimate only if the
chemical concentration is measured in the waste stream being
released into the environment as opposed to measured in
other process streams containing the chemical.
C. Percent From Stormwater
This column relates only to Section 5.3 - Discharges to
receiving streams or water bodies. If your facility has monitor-
ing data on the amount of the chemical in stormwater runoff
(including unchanneled runoff), you must include that quantity
of the chemical in your water release in column A and indicate
the percentage of the total quantity (by weight) of the chemical
contributed by stormwater in column C (5.3c).
If your facility has monitoring data on the chemical and an
estimate of flow rate, you must use this data to determine the
percent stormwater.
If you have monitored stormwater but did not detect the
chemical, enter zero (0) in column C. If your facility has no
stormwater monitoring data for the chemical, enter not appli-
cable, NA, in this space on the form.
1. CHEMICAL IDENTITY) Do not complete this section If you complete Section 2.)
1.1
1.2
1.3
1.4
2.
[Reserved]
CAS Number (Enter the number exactly as It appears on the 313 list. Enter NA If reporting a chemical category.)
NA
Chemical Or Chemical Category Name (Enter the name exactly as It appears on the 313 list.)
Lead Compounds
Generic Chemical Name (Complete only If Part 1, Section 1. 1 Is checked "Yes. " Generic name must be structurally descriptive. )
MIXTURE COMPONENT IDENTITY (Do not complete this section if you complete Section 1 .)
Generic Chemical Name Provided by Supplier (Limit the name to a maximum of 70 characters (e.g., numbers, letters, spaces, punctuation).)
-------
Page 23
Form R - Part
5. RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
You may report releases of less than
1,000 Ibs. by checking ranges under A. 1.
(Do not use both A.1 and A.2)
5.1 Fugitive or non-point air emissions
5.2 Stack or point air emissions
5.3 Discharges to receiving
streams or water bodies
(Enter letter code from Part I
Section 3.10 for stream(s) in
the box provided )
5.3.2
5.3.3
D
5.4 Underground injection
5.5 Releases to land
5 5 1 On-site landfill
552 Land treatment/application farming
5.5.3 Surface impoundment
5.5 4 Other disposal
5.1a
5.2a
5.3.1a
5.3.2a
5.3.3a
5.4a
5.5 1a
5.5,2a
5 5.3a
5.5.4a
A. Total Release
(Ibs/yr)
A.1
Reporting Ranges
0 1-499 500-999
A.2
Enter
Estimate
NA
NA
NA
NA
11,000
NA
NA
NA
I I (Check if additional information is provided on Part IV-Supplemental Information )
B. Basis of
Estimate
(enter code)'
5 2b
5.3 1b
5 3 2b
5.3.3b
5.4b
5.5.1b
5 5.2b
5.5.3b
5 5,4b
C % From Stormwater
5.3 1c NA
5 3 2c
D
(Important: Type or print; read instructions before completing form.)
D
Page 4 of 5
6 EPA EPA FORM R
PART III. CHEMICAL-SPECIFIC INFORMATION
(continued)
6. TRANSFERS OF THE
(This space for your optional use )
CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
You may report transfers
of less than 1.000 Ibs. by check ng
ranges under A.1 . (Do not use
both A.1 and A. 2)
Discharge to POTW . . . .
(enter location number 1,11
6.1 .1 'rom Part II, Section 1.) | ' | [
Other off-site location
e> ^ (enter location number
6.2.1 from Part II, Sections.)
(enter location number
6.2 2 from Part II, Sections.)
Other off-site location
(enter location number
6.2.3 from Part II. Sections.)
* 1
ZL
2
A. Total Transfers
(Ibs/yr)
A.1
Reporting Ranges
0 1^*99 500-999
[][][]
[][][]
[][][]
[][][]
A. 2
Enter
Estimate
NA
9,500
NA
B. Basis of Estimate
(enter code)
6 1.1b
""""1
6 2 1b 1
6 2.2b
6.2 3b
C Type of Treatment/
Disposal
^^^(entercode^^^^
6 2 1c M 7 2
6 2 2c M
6 2.3c M
[ ]( Check if additional information is provided on Part IV-Supplemental Information.)
-------
Form R - Part
Page 24
EXAMPLE
Bi-monthly stormwater monitoring data shows that the aver-
age concentration of zinc in the stormwater runoff from your
facility from a biocide containing a zinc compound is 1.4
milligrams per liter, and the total annual stormwater discharge
from the facility is 7.527 million gallons. The total amount of
zinc discharged to surface water through the plant wastewater
discharge (non-stormwater) is 250 pounds per year. The total
amount of zinc discharged with stormwater is:
(7,527,000 gallons stormwater) x (3.785 liters/gallon)
= 28,489,695 liters stormwater
(28,489,695 liters stormwater) x (1.4 mg. zinc/liter)
= 39,885.6 g zinc
= 87.9 Ibs zinc
The total amount of zinc discharged from all sources of your
facility is:
250 Ibs zinc from wastewater discharge
+ 87.9 Ibs zinc from stormwater runoff
337.9 Ibs zinc total water discharge
Round to 340 Ibs. of zinc for report.
The percentage of zinc discharged through stormwater is:
87.9/337.9x100 = 26%
If yourfacility does not have periodic measurements of storm-
water releases of the 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
infiltrate 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
Railroad yard areas
Unimproved areas
Streets
Asphalt ic
Concrete
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
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%
0.70-0.85
0.70-0.85
0,75-0.95
0.05-0.10
0.10-0.15
0.15-0.20
0.13-0.17
0.18-0.22
0.25-0.35
Choose the most appropriate runoff coefficient for your site or
calculate a weighted-average coefficient, which takes into
account different types of land use at yourfacility:
Weighted-average
runoff coefficient =
+ Area2C2 +
Total Site Area
where C, = runoff coefficient for a specific land use of Area,.
EXAMPLE
Your facility is located in a semi-ahd region of the United
States which has an annual precipitation (including snowfall)
of 12 inches of rain. (Snowfall should be converted to the
equivalent inches of rain; assume one Foot of snow is equiva-
lent to one inch of rain.) The area covered by yourfacility is 42
acres (about 170,000 square meters or 1,829,520 square
feet). The area of yourfacility is 50 percent unimproved area,
10 percent asphaltic streets, and 40 percent concrete pave-
ment.
The total stormwater runoff from your facility is therefore
calculated as follows:
Land Use % Area
Unimproved area 50
Asphaltic streets 10
Concrete pavement 40
Runoff
Coefficient
0.20
0.85
0.90
Weighted-average (50%) x (0.20) + (10%) x (0.85)
runoff coefficient = + (40%) x (0.90)
100% Area
= 0.545
(Rainfall) x (land area) x (conversion factor) x (runoff coeffi-
cient) = stormwater runoff
(1 foot) x (1,829,520 ft2) x (7.48 gal/ft3) x (0.545)
= 7,458,221 gallons/year
Total stormwater runoff = 7.45 million gallons/year
-------
Page 25
Form R - Part III
6. Transfers of the Chemical in Waste to Off-Site Locations
You must report in this section the total annual quantity of the
chemical sent to any of the off-site disposal, treatment, or
storage facilities for which you have provided an address in
Part II. You are not required to report quantities of the
chemical sent off-site for purposes of recycle or reuse.
On line 6.1.1, report the amount of the listed chemical trans-
ferred to a POTW listed in Part II, Section 1. In the block
provided, enterthe numberf rom Part II, Section 1 correspond-
ing to the POTW to which the discharge is sent. For example,
if the discharge is sent to the location listed in Part II, Section
1.1, then enter "1" in the block provided (the first digit of this
section number has been preceded). If you transfer waste
containing the toxic chemical to more than one POTW, check
the box at the bottom of Section 6 and use the Part IV, the
supplemental information sheet to report these transfers.
On lines 6.2.1 through 6.2.3, report the amount of the chemical
transferred to other off-site locations corresponding to those
listed in Part II, Sections 2.1 through 2.6, including privately
owned wastewatertreatment facilities. In the block provided,
enterthe number from Part II, Section 2 corresponding to the
off-site location to which the transfer is sent. For example, if
the transfer is sent to the location listed in Part II, Section 2.3,
enter "3" in the block provided (the first digit of this section
number has been preceded). If you need additional space,
check the box at the bottom of Section 6 and use the
supplemental information sheet (Part IV, Section 6) to report
these transfers.
A. Total Transfers
Follow the instructions for providing estimates as presented in
the instructions for column A of Section 5 above. Enter the
amount, in pounds, of the toxic chemical that is being trans-
ferred, including mixtures or trade name products containing
the chemical. Do not enter the total poundage of wastes. See
Section 5 for information on reporting off-site transfers of less
than 1 pound. As in Section 5, if the total amount transferred
is less than 1,000 pounds, you may report a range, but only for
reporting years 1987, 1988, and 1989. Enter not applicable,
NA, if you have no off-site transfers.
B. Basis of Estimate
You must identify the basis for your estimate. Enterthe letter
code that applies to the method by which the largest percent-
age of the estimate was derived. Use the same codes
identified in the instructions for column B of Section 5.
C. Type of Treatment/Disposal
Enter one of the following codes to identify the type of
treatment or disposal method used by the off-site location for
the chemical being reported. You should use more than one
line for a single location when the toxic chemical is subject to
different disposal methods; the same location code may be
used more than once. You may have this information in your
copy of EPA Form SO, Item S of the Annual/Biennial Hazard-
ous Waste Treatment, Storage, and Disposal Report (RCRA).
Applicable codes for this Section 6(c) are as follows:
M10 Storage Only
M40 Solidification/Stabilization
M50 Incineration/Thermal Treatment
M61 Wastewater Treatment (Excluding POTW)
M69 Other Treatment
M71 Underground Injection
M72 Landfill/Disposal Surface Impoundment
M73 Land Treatment
M79 Other Land Disposal
M90 Other Off-Site Management
M91 Transfer to Waste Broker
M99 Unknown
7. Waste Treatment Methods and Efficiency
In Section 7, you must provide the following information
related to the chemical for which releases are being reported:
(A) the general waste stream types containing the chemical
being reported; (B) the waste-treatment methods used on all
waste streams containing the chemical; (C) the range of
concentrations of the chemical in the influent to the treatment
method; (D) whether sequential treatment is used; (E) the
efficiency or effectiveness of each treatment method in re-
moving the chemical; and (F) whetherthe treatment efficiency
figure was based on actual operating data. Use a separate line
in Section 7 for each treatment method used on a waste
stream. Report in this section only information about treat-
ment of waste streams at your facility, not about off-site
treatment. If you do not perform on-site treatment of wastes,
enter not applicable, NA, in 7.1b.
A. General Waste Stream
For each waste treatment method, indicate the type of waste
stream containing the chemical that is treated. Enterthe letter
code that corresponds to the general waste stream type:
A = Gaseous (gases, vapors, airborne particulates)
W= Wastewater (aqueous waste)
L = Liquid waste (non-aqueous waste)
S = Solid waste (including sludges and slurries)
If a waste is a mixture of water and organic liquid, you must
report it as wastewater unless the organic content exceeds 50
percent. 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
-------
Form R - Part
Page 26
viscosity or density of the waste is considerably different from
that of process wastewater.
B. Treatment Method
Enter the appropriate code from one of the lists below for each
treatment method used on a waste stream containing the toxic
chemical, regardless of whether the treatment method actu-
ally removes the specific chemical being reported. Treatment
methods must be reported for each type of waste being
treated (i.e., gaseous wastes, aqueous wastes, liquid non-
aqueous wastes, and solids).
Waste streams containing the chemical may have a single
source or may be aggregates of many sources. For example,
process waterf ram several pieces of equipment at yourfacility
may be combined priorto treatment. Report treatment meth-
ods that apply to the aggregate waste stream, as well as
treatment methods that apply to individual waste streams. If
your facility treats various wastewater streams containing the
chemical in different ways, the different treatment methods
must each be listed separately.
Your facility may have several pieces of equipment perform-
ing a similar service and for such equipment you may combine
the reporting on a single line. It is not necessary to enter four
lines of datatocoverfourscrubberunits,for example, if allfour
are treating wastes of similar character (e.g., sulfuric acid mist
emissions), have similar influent concentrations, and have
similar removal efficiencies. If, however, any of these parame-
ters differ from one unit to the next, each scrubber must be
listed separately.
Air Emissions Treatment
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
Biological Treatment
611 Biological Treatment - Aerobic
B21 Biological Treatment - Anaerobic
B31 Biological Treatment - Facultative
B99 Biological Treatment - Other
Chemical Treatment
C01 Chemical Precipitation ~ Lime or Sodium
Hydroxide
C02 Chemical Precipitation -- Sulfide
C09 Chemical Precipitation - Other
C11 Neutralization
C21 Chromium Reduction
C31 Compiexed 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
F11 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
P11 Settling/Clarification
P12 Filtration
P13 Sludge Dewatering (non-thermal)
P14 Air Flotation
P15 Oil Skimming
P16 Emulsion Breaking -- Thermal
P17 Emulsion Breaking--Chemical
P18 Emulsion Breaking -- Other
P19 Other Liquid Phase Separation
P21 Adsorption -- Carbon
P22 Adsorption -- Ion Exchange (other than for
recovery/reuse)
P23 Adsorption -- Resin
P29 Adsorption - Other
P31 Reverse Osmosis (other than for recovery/reuse)
P41 Stripping - Air
P42 Stripping -- Steam
P49 Stripping - Other
P51 Acid Leaching (other than for recovery/reuse)
P61 Solvent Extraction (other than recovery/reuse)
P99 Other Physical Treatment
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Page 27
Form R - Part
Recovery/Reuse
R01 Reuse as Fuel -- Industrial Kiln
R02 Reuse as Fuel -- Industrial Furnace
R03 Reuse as Fuel -- Boiler
R04 Reuse as Fuel - Fuel Blending
R09 Reuse as Fuel -- Other
R11 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
R29 Metals Recovery -- Other
R99 Other Reuse or Recovery
Solidification/Stabilization
G01 Cement Processes (including Silicates)
G09 Other Pozzolonic Processes (including Silicates)
G11 Asphaltic Processes
G21 Thermoplastic Techniques
G99 Other Solidification Processes
C. Range of Influent Concentration
The form requires an indication of the range of concentration
of the toxic chemical in the waste stream (i.e., the influent) as
it typically enters the treatment equipment. Enter in the space
provided one of the following code numbers corresponding to
the concentration of the chemical in the influent:
1 = Greater than 1 percent
2 =100 parts per million (0.01 percent) to 1 percent
(10,000 parts per million)
3 =1 part per million to 100 parts per million
4 = 1 part per billion to 1 part per million
5 = Less than 1 part per billion
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 chemi-
cal/kilogram of airfor 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. Factors are for standard conditions of
0°C (32°F) and 760 mmHg atmospheric pressure.]
D. Sequential Treatment?
The blocks in this column may be used in the following case:
Q Individual treatment steps are used in a series to treat the
chemical, but
G You have no data on the individual efficiencies of each
step, but you are able to estimate the overall efficiency of
the treatment sequence.
If this is the case, then you may do the following:
Q List the appropriate codes for the treatment steps in order
(column B) and then put an "X" in the boxes in column D
for all these sequential treatment steps.
Q Enter the appropriate code for the influent concentration
(column C) for only the first treatment step in the se-
quence. Leave this item blank for the rest of the treatment
steps in the sequence only . Enter NA in column E for the
efficiency of preceding steps in the sequence.
Q Provide the treatment efficiency (column E) for the entire
sequence by entering that value in connection with the
last treatment step in the sequence only. Enter NA in
column E for the efficiency of preceding steps in the
sequence.
An example of how to use the sequential treatment option is
provided in Appendix A (page 47).
E. Treatment Efficiency Estimate
In the space provided, enter the number indicating the per-
centage of the toxic chemical removed from the waste stream
through destruction, biological degradation, chemical conver-
sion, or physical removal. The treatment efficiency (ex-
pressed as percent removal) represents the mass or weight
percentage of chemical destroyed or removed, not merely
changes in volume or concentration of the chemical or the
waste stream. The efficiency refers only to the percent
conversion or removal of the listed toxic chemical from the
waste stream, not the percent conversion or removal of other
waste stream constituents (alone or together with the listed
chemical), and not the general efficiency of the method for any
waste stream. For some treatments, the percent removal will
represent removal by several mechanisms, as in secondary
wastewater treatment, where a chemical may evaporate, be
biodegraded, or be physically removed in the sludge.
Percent removal must be calculated as follows:
X100
I
where I » mass of the chemical in the Influent waste stream
and E = mass of the chemical in the effluent waste stream.
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Form R - Part
Page 28
Q Mark yes or no in column F only in connection with the final
step in the sequence. Do not mark in this column for pro-
ceeding steps in the sequence.
Calculate the mass or weight of chemical in the waste stream
being treated by multiplying the concentration (by weight) of
the chemical in the waste stream by the flow rate. In most
cases, the percent removal compares the treated effluent to
the influent for the particular type of waste stream. However,
for some treatment methods, such as incineration or solidifica-
tion of wastewater, the percent removal of the chemical from
the influent waste stream would be reported as 100 percent
because the waste stream does not exist in a comparable form
after treatment. Some of the treatments (e.g., fuel blending
and evaporation) do not destroy, chemically convert, or physi-
cally remove the chemical from its waste stream. For these
treatment methods, an efficiency of zero must be reported.
For metal compounds, the calculation of the reportable con-
centration and treatment efficiency is based on the weight of
the parent metal, not on the weight of the metal compounds.
Metals are not destroyed, only physically removed or chemi-
cally converted from one form into another. The treatment
efficiency reported represents only physical removal of the
parent metal from the waste stream, not the percent chemical
conversion of the metal compound. If a listed treatment
method converts but does not remove a metal (e.g., chromium
reduction), the method must be reported, but the treatment
efficiency must be reported as zero.
All data available at your facility must be utilized to calculate
treatment efficiency and influent chemical concentration. You
are not required to collect any new data for the purposes of this
reporting requirement. If data are lacking, estimates must be
made using best engineering judgment or other methods.
F. Based on Operating Data?
This column requires you to indicate "Yes" or "No" to whether
the 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. For sequential treatment, do not
indicate "Yes" or "No" in column F for a treatment step unless
you have provided a treatment estimate in column E.
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."
ously indicated, in Part II, Section 2.1, ol Form R, the location
of the off-site facilities and the quantity of each reported
chemical transferred to off-site facilities in Part III, Section
6.2.1, of the form, using a separate form for each chemical.
One waste stream generated by yourfacility is aqueous waste
containing leadchromate, zincdichromate, and leadselenate
as discussed in a previous example in these instructions. In
this example, the waste is transferred to off-site facilities after
on-site wastewater treatment. The on-site wastewater treat-
ment plant precipitates metal sludges. The wastewater is first
treated with sulfuric acid and sodium disulfate to reduce the
hexavalent chromate to trivalent chromium and then treated
with lime to raise the pH. This precipitates chromium hydrox-
ide, zinc hydroxide, and lead hydroxide, but does not remove
the selenium. The selenium is removed from the wastewater
by an ionic exchange system. The chromium, zinc, and lead
hydroxide sludge (solid) waste is transferred to an off-site land
disposal facility and the selenium-containing ion exchange
resin is transferred to an off-site facility for metal recovery (off-
site recovery should02! be reported). The treated wastewater
is sent to a POTW after neutralization. You would indicate the
following treatment methods for the on-site treatment of each
of the lead, zinc, chromium, and selenium compounds:
C21 - Chromium Reduction
C01 - Chemical Precipitation -- Lime or Sodium
Hydroxide
R22 - Metals Recovery - Ion Exchange
C11 - Neutralization
All sequential treatment steps must be indicated for aj| the
metal compound categories reported even if the treatment
method does not affect the particular metal. For example,
ionic exchange must be reported as a treatment method for
lead, zinc, chromium, and selenium compounds, even though
the method affects only the selenium compound.
You would calculate the percent removal of chromium, lead,
zinc, and selenium, by subtracting the amount of each metal
in the wastewater discharge from the amount of each metal in
the wastewater before treatment, and then dividing by the
amount of each metal in the wastewater before treatment.
You would indicate a discharge to a POTW in Part III, Section
6.1.1 and the location of the POTW in Part II, Section 1.1. You
would also indicate the release of the metal sludge to an off-
site land disposal facility in Part III, Section 6.2.1.
EXAMPLE
Yourfacility produces several different waste streams treated
on-site and transferred to off-site facilities. You have previ-
8. Optional Information on Waste Minimization
Information provided in Part III. Section 8. of Form R is
optional. In this section, you may identify waste minimization
efforts relating to the reported toxic chemical that may not
have been reflected in your responses to previous sections of
the form. Waste minimization reduces the amount of the
-------
Page 29
Form R - Part
chemical in wastes that are generated. Treatment or disposal
does not minimize waste, but recycling or reuse of a waste
should be counted as waste minimization. Waste minimiza-
tion applies to air emissions and wastewater, as well as to
liquid or solid materials that are released, disposed of, or
treated. For example, a program to recycle material from
reactor clean ing could reduce the amount of a listed chemical
in wastewater prior to treatment. This reduction might not
show up in annual reports of releases to receiving streams
(due to effective treatment, for example) but would be cap-
tured in this section.
A. Type of Modification
Enter from the following list the one code that best describes
the type of waste minimization activity:
M1 Recycling/Reuse On-Site
M2 Recycling/Reuse Off-Site
M3 Equipment/Technology Modifications
M4 Process Procedure Modifications
M5 Reformulation/Redesign of Product
M6 Substitution of Raw Materials
M7 Improved Housekeeping, Training, Inventory
Control
M8 Other Waste Minimization Technique
B. Quantity of the Chemical in the Wastestream Prior to
Treatment/Disposal
Enter the pounds of the toxic chemical contained in all wastes
in the reporting year and the pounds contained in all wastes in
the year prior to the reporting year. Alternatively, to protect
confidential information, you may wish to enter only the
percentage by which the weight of the chemical in the wastes
has changed. This figure may be calculated using the follow-
ing formula:
(toxic chemical in wastes in reporting year -
toxic chemical in wastes in prior veart
toxic chemical in wastes in prior year
x100
The resulting figure may be either negative or positive (i.e.. if
the amount of waste generated has been reduced, a negative
number should be reported).
C. Index
Enter the ratio of reporting-year production to production in the
year prior to the reporting year. This index should be calcu-
lated to most closely reflect activities involving the chemical.
The index provides a means for users of the data to distinguish
effects due to changes in business activity from the t sets
specifically due to waste minimization efforts. It is not neces-
sary to indicate the units on which the index is based. Ex-
amples of acceptable indices include:
Q Amount of chemical produced in 1988/amount of chemi-
cal produced in 1987. For example, a company manufac-
tures 200,000 pounds of a chemical in 1987 and 250,000
pounds of the same chemical in 1988. The index figure to
report would be 1.3 (1.25 rounded to two significant
digits).
Q Amount of paint produced in 1988/amount of paint pro-
duced in 1987.
G Number of appliances coated in 1988/number of appli-
ances coated in 1987.
Q Square feet of solar collector fabricated in 1988/square
feet of solar collector fabricated in 1987.
D. Reason for Action
Finally, enter the codes from the following list that best
describe the reason for initiating the waste minimization effort:
R1 Regulatory Requirement for the Waste
R2 Reduction of Treatment/Disposal Costs
R3 Other Process Cost Reduction
R4 Self-Initiated Review
R5 Other (e.g., discontinuation of product,
occupational safety).
-------
Page 30
TABLE I
SIC CODES 20-39
20 Food and Kindred Products
2011 Meat packing plants
2013 Sausages and other prepared meat products
2015 Poultry slaughtering and processing
2021 Creamery butter
2022 Natural, processed, and imitation cheese
2023 Dry, condensed, and evaporated dairy products
2024 Ice cream and frozen desserts
2026 Fluid milk
2032 Canned specialties
2033 Canned fruits, vegetables, preserves, jams, and
jellies
2034 Dried and dehydrated fruits, vegetables, and soup
mixes
2035 Pickled fruits and vegetables, vegetable sauces
and seasonings, and salad dressings
2037 Frozen fruits, fruit juices, and vegetables
2038 Frozen specialties, n.e.c.*
2041 Flour and other grain mill products
2043 Cereal breakfast foods
2044 Rice milling
2045 Prepared flour mixes and doughs
2046 Wet corn milling
2047 Dog and cat food
2048 Prepared feeds and feed ingredients for animals
and fowls, except dogs and cats
2051 Bread and other bakery products, except cookies
and crackers
2052 Cookies and crackers
2053 Frozen bakery products, except bread
2061 Cane sugar, except refining
2062 Cane sugar refining
2063 Beet sugar
2064 Candy and other confectionary 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, except corn, cottonseed, and
soybean
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, com 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, man made fiber, and silk
2231 Broadwoven fabric mills, wool (including dyeing
and finishing)
2241 Narrow fabric and other smallwares mills: cotton,
wool, silk, and manmade fiber
2251 Women's full length and knee length hosiery, except
socks
2252 Hosiery, n.e.c.*
2253 Knit outerwear mills
2254 Knit underwear and nightwear mills
2257 Weft knit fabric mills
2258 Lace and warp knit fabric mills
2259 Knitting mills, n.e.c.*
2261 Finishers of broadwoven fabrics of cotton
2262 Finishers of broadwoven fabrics of manmade fiber
and silk
2269 Finishers of textiles, n.e.c.*
2273 Carpets and rugs
2281 Yarn spinning mills
2282 Yarn texturizing, throwing, twisting, and winding
mills
2284 Thread mills
2295 Coated fabrics, not rubberized
2296 Tire cord and fabrics
2297 Nonwoven fabrics
2298 Cordage and twine
2299 Textile goods, n.e.c.*
23 Apparel and Other Finished Products made from
Fabrics and Other Similar Materials
2311 Men's and boys' suits, coats, and overcoats
-------
Page 31
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' under-
wear and nightwear
2342 Brassieres, girdles, and allied garments
2353 Hats, caps, and millinery
2361 Girls', children's and infants' dresses, blouses, and
shirts
2369 Girls', children's and infants' outerwear, n.e.c.*
2371 Fur goods
2381 Dress and work gloves, except knit and all leather
2384 Robes and dressing gowns
2385 Waterproof outerwear
2386 Leather and sheep lined clothing
2387 Apparel belts
2389 Apparel and accessories, n.e.c.*
2391 Curtains and draperies
2392 Housefurnishings, except curtains and draperies
2393 Textile bags
2394 Canvas and related products
2395 Pleating, decorative and novelty stitching, and
tucking for the trade
2396 Automotive trimmings, apparel findings, and
related products
2397 Schiffli machine embroideries
2399 Fabricated textile products, n.e.c.*
24 Lumber and Wood Products, Except Furniture
2411 Logging
2421 Sawmills and planing mills, general
2426 Hardwood dimension and flooring mills
2429 Special product sawmills, n.e.c.*
2431 Millwork
2434 Wood kitchen cabinets
2435 Hardwood veneer and plywood
2436 Softwood veneer and plywood
2439 Structural wood members, n.e.c.*
2441 Nailed and lock corner wood boxes and shook
2448 Wood pallets and skids
2449 Wood containers, n.e.c.*
2451 Mobile homes
2452 Prefabricated wood buildings and components
2491 Wood preserving
2493 Reconstituted wood products
2499 Wood products, n.e.c.*
25 Furniture and Fixtures
2511 Wood household furniture, except upholstered
2512 Wood household furniture, upholstered
2514 Metal household furniture
2515 Mattresses, foundations, and convertible beds
2517 Wood television, radio, phonograph, and sewing
machine cabinets
2519 Household furniture, n.e.c.*
2521 Wood office furniture
2522 Office furniture, except wood
2531 Public building and related furniture
2541 Wood office and store fixtures, partitions, shelving,
and lockers
2542 Office and store fixtures, partitions, shelving, and
lockers, except wood
2591 Drapery hardware and window blinds and shades
2599 Furniture and fixtures, n.e.c.*
26 Paper and Allied Products
2611 Pulp mills
2621 Paper mills
2631 Paperboard mills
2652 Setup paperboard boxes
2653 Corrugated and solid fiber boxes
2655 Fiber cans, tubes, drums, and similar products
2656 Sanitary food containers, except folding
2657 Folding paperboard boxes, including sanitary
2671 Packaging paper and plastics film, coated and
laminated
2672 Coated and laminated paper, n.e.c.*
2673 Plastics, foil, and coated paper bags
2674 Uncoated paper and multiwall bags
2675 Die-cut paper and paperboard and cardboard
2676 Sanitary paper products
2677 Envelopes
2678 Stationery tablets, and related products
2679 Converted paper and paperboard products, n.e.c.*
27 Printing, Publishing, and Allied Industries
2711 Newspapers: publishing, or publishing and
printing
2721 Periodicals: publishing, or publishing and printing
2731 Books: publishing, or publishing and printing
2732 Book printing
2741 Miscellaneous publishing
2752 Commercial printing, lithographic
2754 Commercial printing, gravure
2759 Commercial printing, n.e.c.*
2761 Manifold business forms
2771 Greeting cards
2782 Blankbooks, looseleaf binders and devices
-------
Page 32
2789 Bookbinding and related work
2791 Typesetting
2796 Platemaking and related services
28 Chemicals and Allied Products
2812 Alkalies and chlorine
2813 Industrial gases
2816 Inorganic pigments
2819 Industrial inorganic chemicals, n.e.c.*
2821 Plastics materials, synthetic resins, and non-
vulcanizable elastomers
2822 Synthetic rubber (vulcanizable elastomers)
2823 Cellulosic manmade fibers
2824 Manmade organic fibers, except cellulosic
2833 Medicinal chemicals and botanical products
2834 Pharmaceutical preparations
2835 In vitro and in vivo diagnostic substances
2836 Biological products, except diagnostic substances
2841 Soap and other detergents, except specialty
cleaners
2842 Specialty cleaning, polishing, andsanitation prepa-
rations
2843 Surface active agents, finishing agents, sutfonated
oils, and assistants
2844 Perfumes, cosmetics, and othertoiletpreparations
2851 Paints, varnishes, lacquers, enamels, and allied
products
2861 Gum and wood chemicals
2865 Cyclic organic crudes and intermediates, and
organic dyes and pigments
2869 Industrial organic chemicals, n.e.c.*
2873 Nitrogenous fertilizers
2874 Phosphatic fertilizers
2875 Fertilizers, mixing only
2879 Pesticides and agricultural chemicals, n.e.c.*
2891 Adhesives and sealants
2892 Explosives
2893 Printing ink
2895 Carbon black
2899 Chemicals and chemical preparations, n.e.c.*
29 Petroleum Refining and Related Industries
2911 Petroleum refining
2951 Asphalt paving mixtures and blocks
2952 Asphalt felts and coatings
2992 Lubricating oils and greases
2999 Products of petroleum and coal, n.e.c.*
30 Rubber and Miscellaneous Plastics Products
3011 Tires and inner tubes
3021 Rubber and plastics footwear
3052 Rubber and plastics hose and belting
3053 Gaskets, packing, and sealing devices
3061 Molded, extruded, and lathecut mechanical rubber
products
3069 Fabricated rubber products, n.e.c.*
3081 Unsupported plastics film and sheet
3082 Unsupported plastics profile shapes
3083 Laminated plastics plate, sheet, and prof ile 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 athtetic
3144 Women's footwear, except athletic
3149 Footwear, except rubber, n.e.c.*
3151 Leather gloves and mittens
3161 Luggage
3171 Women's handbags and purses
3172 Personal leather goods, except women's hand-
bags 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
-------
Page 33
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, blastfurnaces (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
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
-------
Page 34
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 powertransmission 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 elec-
tronic computers
3579 Office machines, n.e.c.*
3581 Automatic vending machines
3582 Commercial laundry, drycleaning, and pressing
machines
3585 Air conditioning and warm air heating equipment
and commercial and industrial refrigeration equip-
ment
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 equip-
ment, 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
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 communi-
cations equipment
3669 Communications equipment, n.e.c.*
3671 Electron tubes
3672 Printed circuit boards
3674 Semiconductors and related devices
3675 Electronic capacitors
3676 Electronic resistors
3677 Electronic coils, transformers, and other inductors
3678 Electronic connectors
3679 Electronic components, n.e.c.*
3691 Storage batteries
3692 Primary batteries, dry and wet
3694 Electric equipment for internal combustion
engines
3695 Magnetic and optical recording media
3699 Electrical machinery, equipment, and supplies,
n.e.c.*
37 Transportation Equipment
3711 Motor vehicles and passenger car bodies
3713 Truck and bus bodies
3714 Motor vehicle parts and accessories
3715 Truck trailers
3716 Motor homes
3721 Aircraft
3724 Aircraft engines and engine parts
3728 Aircraft parts and auxiliary equipment, n.e.c.*
3731 Ship building and repairing
3732 Boat building and repairing
3743 Railroad equipment
3751 Motorcycles, bicycles and parts
3761 Guided missiles and space vehicles
3764 Guided missile and space vehicle propulsion units
and propulsion unit parts
3769 Guided missile and space vehicle parts and auxil-
iary equipment, n.e.c.*
3792 Travel trailers and campers
3795 Tanks and tank components
3799 Transportation equipment, n.e.c.*
-------
Page 35
38 Measuring, Analyzing, and Controlling Instruments;
Photographic, Medical and Optical Goods; Watches
and Clocks
3812 Search, detection, navigation, guidance, aeronau-
tical, 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
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.*
"'Not elsewhere classified" indicated by "n.e.c."
-------
Page 36
TABLE II
SECTION 313 TOXIC CHEMICAL LIST FOR REPORTING YEAR 1988
(including Chemical Categories)
Specific toxic chemicals with CAS Number are listed in alphabetical order on this page. A list of the same chemicals in CAS
Number order begins on page 40. Covered Chemical Categories are listed beginning on page 43.
[Note: Chemicals may be added to or deleted from the list.
The Emergency Planning and Community Right-to-Know In-
formation Hotline, (800)535-0202 or (202) 479-2449 in
Washington, D.C. or Alaska, will provide up-to-date informa-
tion on the status of these changes. See page 7 of the
instructions for more information on the de minimis values
listed below.]
a. Alphabetical Chemical List
CAS Number Chemical Name
De Minimis
Concentration
75-07-0 Acetaldehyde 0.1
60-35-5 Acetamide 0.1
67-64-1 Acetone 1.0
75-05-8 Acetonitrile 1.0
53-96-3 2-Acetylaminofluorene 0.1
107-02-8 Acrolein 1.0
79-06-1 Acrylamide 0.1
79-10-7 Acrylic acid 1.0
107-13-1 Acrylonitrile 0.1
309-00-2 Aldrin 1.0
{1,4:5,8-Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro-1,4,4a,
5,8,8a-hexahydro-(1 .alpha.,
4.alpha.,4a.beta.,5.alpha.,
8.alpha.,8a.beta.)-}
107-05-1 Allyl chloride 1.0
7429-90-5 Aluminum (fume or dust) 1.0
1344-28-1 Aluminum oxide 1.0
117-79-3 2-Aminoanthraquinone 0.1
60-09-3 4-Aminoazobenzene 0.1
92-67-1 4-Aminobiphenyl 0.1
82-28-0 1-Amino-2-methylanthraquinone 0.1
7664-41-7 Ammonia 1.0
6484-52-2 Ammonium nitrate (solution) 1.0
7783-20-2 Ammonium sulfate (solution) 1.0
62-53-3 Aniline 1.0
90-04-0 o-Anisidine 0.1
104-94-9 p-Anisidine 1.0
134-29-2 o-Anisidine hydrochloride 0.1
120-12-7 Anthracene 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
1332-21-4 Asbestos (friable) 0.1
7440-39-3 Barium 1.0
98-87-3 Benzal chloride 1.0
55-21-0 Benzamide 1.0
71-43-2 Benzene 0.1
CAS Number
92-87-5
98-07-7
98-88-4
94-36-0
100-44-7
7440-41-7
92-52-4
111 -44-4
542-88-1
108-60-1
103-23-1
75-25-2
74-83-9
106-99-0
141-32-2
71 -36-3
78-92-2
75-65-0
85-68-7
106-88-7
123-72-8
4680-78-8
569-64-2
989-38-8
1937-37-7
2602-46-2
16071-86-6
2832-40-8
3761-53-3
81-88-9
3118-97-6
97-56-3
842-07-9
492-80-8
128-66-5
7440-43-9
156-62-7
133-06-2
Chemical Name
Benzidine
Benzoic trichloride
(Benzotrichloride)
Benzoyl chloride
Benzoyl peroxide
Benzyl chloride
Beryllium
Biphenyl
Bis(2-chloroethyl) ether
Bis(chloromethyl) ether
De Minimis
Concentration
0.1
0.1
1.0
1.0
1.0
0.1
1.0
1.0
0.1
Bis(2-chloro-1 -methylethyl) etherl .0
Bis(2-ethylhexyl) adipate 1.0
Bromoform 1.0
{Tribromomethane}
Bromomethane 1.0
{Methyl bromide}
1,3-Butadiene 0.1
Butyl acrylate 1.0
n-Butyl alcohol 1.0
sec-Butyl alcohol 1.0
tert-Butyl alcohol 1.0
Butyl benzyl phthalate 1.0
1,2-Butylene oxide 1.0
Butyraldehyde 1.0
C.I. Acid Green 3" 1.0
C.I. Basic Green 4* 1.0
C.I. Basic Red 1* 0.1
C.I. Direct Black 38* 0.1
C.I. Direct Blue 6* 0.1
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* 0.1
C.I. Solvent Orange 7* 1.0
C.I. Solvent Yellow 3* 0.1
C.I. Solvent Yellow 14* 0.1
C.I. Solvent Yellow 34*
(Auramine) 0.1
C.I. Vat Yellow 4* 1.0
Cadmium 0.1
Calcium cyanamide 1.0
Captan 1.0
{1 H-lsoindole-1,3(2H)-dione,
3a,4,7,7a-tetrahydro-
2-[(trichloromethyl)thio|-}
-------
Page 37
CAS Number
Chemical Name
De Mirtimis
Concentration
CAS Number
Chemical Name
De Minimis
Concentration
63-25-2 Carbaryl 1.0
{1-Naphthalenol, methylcarbamate}
75-15-0 Carbon disulfide 1.0
56-23-5 Carbon tetrachloride 0.1
463-58-1 Carbonyl sulfide 1.0
120-80-9 Catechol 1.0
133-90-4 Chloramben 1.0
{Benzoic acid, 3-amino-
2,5-dichloro-}
57-74-9 Chlordane 1.0
{4,7-Methanoindan, 1,2,4,5,6,7,
8,8-octachloro-2,3,3a,4,
7,7a-hexahydro-}
7782-50-5 Chlorine 1.0
10049-04-4 Chlorine dioxide 1.0
79-11 -8 Chloroacetic acid 1.0
532-27-4 2-Chloroacetophenone 1.0
108-90-7 Chlorobenzene 1.0
510-15-6 Chlorobenzilate 1.0
{Benzeneacetic acid,4-chloro-
.alpha.-(4-chlorophenyl)-
.alpha.-hydroxy-.ethyl ester}
75-00-3 Chloroethane 1.0
{Ethyl chloride}
67-66-3 Chloroform 0.1
74-87-3 Chloromethane 1.0
{Methyl chloride}
107-30-2 Chloromethyl methyl ether 0.1
126-99-8 Chloroprene 1.0
1897-45-6 Chlorothalonil 1.0
{1,3-Benzenedicarbonitrile,
2,4,5,6-tetrachloro-}
7440-47-3 Chromium 0.1
7440-48-4 Cobalt 1.0
7440-50-8 Copper 1.0
120-71-8 p-Cresidine 0.1
1319-77-3 Cresol (mixed isomers) 1.0
108-39-4 m-Cresol 1.0
95-48-7 o-Cresol 1.0
106-44-5 p-Cresol 1.0
98-82-8 Cumene 1.0
80-15-9 Cumene hydroperoxide 1.0
135-20-6 Cupferron 0.1
{Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt}
110-82-7 Cyclohexane 1.0
94-75-7 2,4-D 1.0
{Acetic acid,
(2,4-dichlorophenoxy)-}
1163-19-5 Decabromodiphenyl oxide 1.0
2303-16-4 Diallate 1.0
{Carbamothioic acid,
bis(l-methylethyl)-, S-(2,3-
dichloro-2-propenyl) ester)
615-05-4 2,4-Diaminoanisole 0.1
39156-41-7 2,4-Diaminoanisole sulfate 0.1
101-80-4 4,4'-Diaminodiphenyl ether 0.1
25376-45-8 Diaminotoluene (mixed isomers) 0.1
95-80-7 2,4-Diaminotoluene 0.1
334-88-3 Diazomethane 1.0
132-64-9 Dibenzofuran 1.0
96-12-8 1,2-Dibromo-3-chloropropane 0.1
{DBCP}
106-93-4 1,2-Dibromoethane 0.1
{Ethylene dibromide}
84-74-2 Dibutyl phthalate 1.0
25321-22-6 Dichlorobenzene (mixed 0.1
isomers)
95-50-1 1,2-Dichlorobenzene 1.0
541-73-1 1,3-Dichlorobenzene 1.0
106-46-7 1,4-Dichlorobenzene 0.1
91-94-1 3,3'-Dichlorobenzidine 0.1
75-27-4 Dichlorobromomethane 1.0
107-06-2 1,2-Dichloroethane 0.1
{Ethylene dichloride}
540-59-0 1,2-Dichloroethylene 1.0
75-09-2 Dichloromethane 0.1
{Methylene chloride}
120-83-2 2,4-Dichlorophenol 1.0
78-87-5 1,2-Dichloropropane 1.0
542-75-6 1,3-Dichloropropylene 0.1
62-73-7 Dichlorvos 1.0
{Phosphoric acid, 2,2-
dichloroethenyl dimethyl ester}
115-32-2 Dicofol 1.0
{Benzenemethanol, 4-chloro-
.a!pha.-(4-chlorophenyl)-
.alpha.- (trichloromethyl)-}
1464-53-5 Diepoxybutane 0.1
111 -42-2 Diethanolamine 1.0
117-81-7 Di-(2-ethylhexyl) phthalate 0.1
{DEHP}
84-66-2 Diethyl phthalate 1.0
64-67-5 Diethyl sulfate 0.1
119-90-4 3,3'-Dimethoxybenzidine 0.1
60-11-7 4-Dimethylaminoazobenzene 0.1
119-93-7 3,3'-Dimethylbenzidine 0.1
{o-Tolidine}
79-44-7 Dimethylcarbamyl chloride 0.1
57-14-7 1,1-Dimethyl hydrazine 0.1
105-67-9 2,4-Dimethylphenol 1.0
131-11-3 Dimethyl phthalate 1.0
77-78-1 Dimethyl sulfate 0.1
534-52-1 4,6-Dinitro-o-cresol 1.0
51-28-5 2.4-Dinitrophenol 1.0
121-14-2 2,4-Dinitrotoluene 1.0
606-20-2 2,6-Dinitrotoluene 1.0
117-84-0 n-Dioctyl phthalate 1.0
123-91-1 1,4-Dioxane 0.1
-------
Page 38
CAS Number
Chemical Name
De Minimis
Concentration
CAS Number
Chemical Name
De Minimis
Concentration
122-66-7 1,2-Diphenylhydrazine 0.1
{Hydrazobenzene}
106-89-8 Epichlorohydrin 0.1
110-80-5 2-Ethoxyethanol 1.0
140-88-5 Ethyl acrylate 0.1
100-41-4 Ethylbenzene 1.0
541-41-3 Ethyl chloroformate 1.0
74-85-1 Ethylene 1.0
107-21-1 Ethylene glycol 1.0
151-56-4 Ethyleneimine 0.1
{Aziridine}
75-21-8 Ethylene oxide 0.1
96-45-7 Ethylene thiourea 0.1
2164-17-2 Fluometuron 1.0
{Urea, N,N-dimethyl-N'-
[3-(trifluoromethyl)phenyl]-}
50-00-0 Formaldehyde 0.1
76-13-1 Freon113 1.0
{Ethane, 1,1,2-trichloro-1,2,2-
trifluoro-}
76-44-8 Heptachlor 1.0
{1,4,5,6,7,8,8-Heptachloro-
3a,4,7,7a-tetrahydro-
4,7-methano-1 H-indene}
118-74-1 Hexachlorobenzene 0.1
87-68-3 Hexachloro-1,3-butadiene 1.0
77-47-4 Hexachlorocyclopentadiene 1.0
67-72-1 Hexachloroethane 1.0
1335-87-1 Hexachloronaphthalene 1.0
680-31-9 Hexamethylphosphoramide 0.1
302-01-2 Hydrazine 0.1
10034-93-2 Hydrazine sulfate 0.1
7647-01-0 Hydrochloric acid 1.0
74-90-8 Hydrogen cyanide 1.0
7664-39-3 Hydrogen fluoride 1.0
123-31-9 Hydroquinone 1.0
78-84-2 Isobutyraldehyde 1.0
67-63-0 Isopropyl alcohol 0.1
(manufacturing-strong acid
process, no supplier notification)
80-05-7 4,4'-lsopropylidenediphenol 1.0
7439-92-1 Lead 0.1
58-89-9 Lindane 0.1
{Cyclohexane.1,2,3,4,5,6-
hexachloro-,(1. alpha.,2.alpha.,
3.beta.,4.alpha.,5.alpha.,6.beta.)-}
108-31-6 Malete anhydride 1.0
12427-38-2 Maneb 1.0
{Carbamodithioic acid, 1,2-
ethanediylbis-.manganese
complex}
7439-96-5 Manganese 1.0
108-78-1 Melamine 1.0
7439-97-6 Mercury 1.0
67-56-1 Methanol 1.0
72-43-5 Methoxychlor 1.0
{Benzene, 1,1 '-(2,2,2-
trichloroethylidene)bis
[4-methoxy-J
109-86-4 2-Methoxyethanol 1.0
96-33-3 Methyl acrylate 1.0
1634-04-4 Methyl tert-butyl ether 1.0
101-14-4 4,4'-Methylenebis (2- 0.1
chloroaniline)
{MBOCA}
101-61-1 4,4'-Methylenebis(N,N-dimethyl) 0.1
benzenamine
101 -68-8 Methylenebis (phenylisocyanate) 1.0
{MBI}
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 0.1
108-10-1 Methyl isobutyl ketone 1.0
624-83-9 Methyl isocyanate 1.0
80-62-6 Methyl methacrylate 1.0
90-94-8 Michler's ketone 0.1
1313-27-5 Molybdenum trioxide 1.0
505-60-2 Mustard gas 0.1
{Ethane, 1,1 '-thiobis[2-chloro-}
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
7697-37-2 Nitric acid 1.0
139-13-9 Nitrilotriacetic acid 0.1
99-59-2 5-Nitro-o-anisidine 0.1
98-95-3 Nitrobenzene 1.0
92-93-3 4-Nitrobiphenyl 0.1
1836-75-5 Nitrofen 0.1
{Benzene, 2,4-dichloro-1-
(4-nitrophenoxy)-}
51-75-2 Nitrogen mustard 0.1
{2-Chloro-N-(2-chloroethyl)-N-
methylethanamine}
55-63-0 Nitroglycerin 1.0
88-75-5 2-Nitrophenol 1.0
100-02-7 4-Nrtrophenol 1.0
79-46-9 2-Nitropropane 0.1
156-10-5 p-Nitrosodiphenylamine 0.1
121-69-7 N,N-Dimethylaniline 1.0
924-16-3 N-Nitrosodi-n-butylamine 0.1
55-18-5 N-Nitrosodiethylamine 0.1
62-75-9 N-Nitrosodimethylamine 0.1
86-30-6 N-Nitrosodiphenylamine 1.0
621-64-7 N-Nitrosodi-n-propylamine 0.1
4549-40-0 N-Nitrosomethylvinylamine 0.1
-------
Page 39
CAS Number
Chemical Name
De Minimis
Concentration
CAS Number
Chemical Name
De Minimis
Concentration
59-89-2 N-Nitrosomorpholine 0.1
759-73-9 N-Nitroso-N-ethylurea 0.1
684-93-5 N-Nitroso-N-methylurea 0.1
16543-55-8 N-Nitrosonornicotine 0.1
100-75-4 N-Nitrosopiperidine 0.1
2234-13-1 Octachloronaphthalene 1.0
20816-12-0 Osmium tetroxide 1.0
56-38-2 Parathion 1.0
{Phosphorothioic acid, o, o-
diethyl-o-(4-nitrophenyl) ester}
87-86-5 Pentachlorophenol 1.0
{PCP}
79-21-0 Peracelic acid 1.0
108-95-2 Phenol 1.0
106-50-3 p-Phenylenediamine 1.0
90-43-7 2-Phenylphenol 1.0
75-44-5 Phosgene 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
88-89-1 Picric acid 1.0
1336-36-3 Polychlorinated biphenyls 0.1
{PCBs}
1120-71-4 Propane sultone 0.1
57-57-8 beta-Propiolactone 0.1
123-38-6 Propionaldehyde 1.0
114-26-1 Propoxur 1.0
{Phenol, 2-(1-methylethoxy)-,
methylcarbamate}
115-07-1 Propylene 1.0
{Propene}
75-55-8 Propyleneimine 0.1
75-56-9 Propylene oxide 0.1
110-86-1 Pyridine 1.0
91-22-5 Quinoline 1.0
106-51-4 Quinone 1.0
82-68-8 Quintozene
{Pentachloronitrobenzene} 1.0
81-07-2 Saccharin (manufacturing, no 0.1
supplier notification)
{1,2-Benzisothiazol-3(2H)-one,
1,1-dioxide}
94-59-7 Safrole 0.1
7782-49-2 Selenium 1.0
7440-22-4 Silver 1.0
1310-73-2 Sodium hydroxide (solution) 1.0
7757-82-6 Sodium sulfate (solution) 1.0
100-42-5 Styrene 0.1
96-09-3 Styrene oxide 0.1
7664-93-9 Sulfuric acid 1.0
100-21 -0 Terephthalic acid 1.0
79-34-5 1,1,2,2-Tetrachloroethane 0.1
127-18-4 Tetrachloroethylene 0.1
{Perchloroethylene}
961-11-5 Tetrachlorvinphos 1.0
{Phosphoric acid, 2-chloro-1-
(2,3,5-trichlorophenyl) ethenyl
dimethyl ester}
7440-28-0 Thallium 1.0
62-55-5 Thioacetamide 0.1
139-65-1 4,4'-Thiodianiline 0.1
62-56-6 Thiourea 0.1
1314-20-1 Thorium dioxide 1.0
7550-45-0 Titanium tetrachloride 1.0
108-88-3 Toluene 1.0
584-84-9 Toluene-2,4-diisocyanate 0.1
91-08-7 Toluene-2,6-diisocyanate 0.1
95-53-4 o-Toluidine 0.1
636-21-5 o-Toluidine hydrochloride 0.1
8001-35-2 Toxaphene 0.1
68-76-8 Triaziquone 0.1
{2,5-Cyclohexadiene-1,4-dione,
2,3,5-tris(1-aziridinyl)-}
52-68-6 Trichlorfon 1.0
{Phosphonicacid,(2,2,2-trichloro-
1-hydroxyethyl)-,dimethyl ester}
120-82-1 1,2,4-Trichlorobenzene 1.0
71-55-6 1,1,1-Trichloroethane 1.0
{Methyl chloroform}
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 1.0
95-95-4 2,4,5-Trichlorophenol 1.0
88-06-2 2,4,6-Trichlorophenol 0.1
1582-09-8 Trifluralin 1.0
{Benzenamine, 2,6-dinitro-N,N-
dipropyl-4-(trifluoromelhyl)-}
95-63-6 1,2,4-Trimethylbenzene 1.0
126-72-7 Tris (2,3-dibromopropyl) 0.1
phosphate
51-79-6 Urethane 0.1
{Ethyl carbamate}
7440-62-2 Vanadium (fume or dust) 1.0
108-05-4 Vinyl acetate 1.0
593-60-2 Vinyl bromide 0.1
75-01-4 Vinyl chloride 0.1
75-35-4 Vinylidene chloride 1.0
1330-20-7 Xylene (mixed isomers) 1.0
108-38-3 m-Xylene 1.0
95-47-6 o-Xylene 1.0
106-42-3 p-Xylene 1.0
87-62-7 2,6-Xylidine 1.0
7440-66-6 Zinc (fume or dust) 1.0
12122-67-7 Zineb 1.0
{Carbamodithioic acid, 1,2-
ethanediylbis-, zinc complex}
-------
Page 40
b. List Bv CAS Number
CAS Number Chemical Name
De Minimis
Concentration
50-00-0 Formaldehyde 0.1
51-28-5 2,4-Dinitrophenol 1.0
51-75-2 Nitrogen mustard 0.1
{2-Chloro-N-(2-chloroethyl)-N-
methylanamine}
51-79-6 Urethane 0.1
{Ethyl carbamate}
52-68-6 Trichlorfon 1.0
{Phosphonic acid,(2,2,2-trichloro-
1-hydroxyethyl)-, dimethyl ester}
53-96-3 2-Acetylaminofluorene 0.1
55-18-5 N-Nitrosodiethylamine 0.1
55-21-0 Benzamide 1.0
55-63-0 Nitroglycerin 1.0
56-23-5 Carbon tetrachloride 0.1
56-38-2 Parathion 1.0
{Phosphorothioic acid, 0,0-
diethyl-o-(4-nitrophenyl)ester}
57-14-7 1,1 -Dimethyl hydrazine 0.1
57-57-8 beta-Propiolactone 0.1
57-74-9 Chlordane 1.0
{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-
hexachloro-,(1. alpha., 2.alpha.,
S.beta., 4.alpha.,5.alpha.,6.beta.)-}
59-89-2 N-Nitrosomorpholine 0.1
60-09-3 4-Aminoazobenzene 0.1
60-11-7 4-Dimethylaminoazobenzene 0.1
60-34-4 Methyl hydrazine 1.0
60-35-5 Acetamide 0.1
62-53-3 Aniline 1.0
62-55-5 Thioacetamide 0.1
62-56-6 Thiourea 0.1
62-73-7 Dichlorvos 1.0
{Phosphoric acid, 2,2-
dichloroethenyl dimethyl ester}
62-75-9 N-Nitrosodimethylamine 0.1
63-25-2 Carbaryl 1.0
{1-Naphthalenol,
methylcarbamate}
64-67-5 Diethyl sulfate 0.1
67-56-1 Methanol 1.0
67-63-0 Isopropyl alcohol 0.1
(manufacturing-strong acid process,
no supplier notification)
67-64-1 Acetone 1.0
67-66-3 Chloroform 0.1
67-72-1 Hexachloroethane 1.0
68-76-8 Triaziquone 0.1
(2,5-Cyclohexadiene-1,4-dione,
2,3,5-tris(1-aziridinyl)-}
CAS Number
71-36-3
71-43-2
71-55-6
72-43-5
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
75-35-4
75-44-5
75-55-8
75-56-9
75-65-0
76-13-1
76-44-8
77-47-4
77-78-1
78-84-2
78-87-5
78-92-2
78-93-3
79-00-5
79-01-6
79-06-1
79-10-7
79-11-8
79-21-0
79-34-5
79-44-7
79-46-9
Chemical Name
De Minimis
Concentration
n-Butyl alcohol 1.0
Benzene 0.1
1,1,1-Trichloroethane 1.0
{Methyl chloroform}
Methoxychlor 1.0
{Benzene, 1,1'-(2,2,2-
trichloroethylidene)bis
[4-methoxy-}
Bromomethane 1.0
{Methyl bromide}
Ethylene 1.0
Chloromethane 1.0
{Methyl chloride}
Methyl iodide 0.1
Hydrogen cyanide 1.0
Methylene bromide 1.0
Chloroethane 1.0
{Ethyl chloride}
Vinyl chloride 0.1
Acetonitrile 0.1
Acetaldehyde 1.0
Dichloromethane 0.1
{Methylene chloride}
Carbon disulfide 1.0
Ethylene oxide 0.1
Bromoform 1.0
{Tribromomethane}
Dichlorobromomethane 1.0
Vinylidene chloride 1.0
Phosgene 1.0
Propyleneimine 0.1
Propylene oxide 0.1
tert-Butyl alcohol 1.0
Freon113 1.0
{Ethane, 1,1,2-trichloro-1,2,2-
trifluoro-}
Heptachlor 1.0
{1,4,5,6,7,8,8-Heptachloro-
3a,4,7,7a-tetrahydro-
4,7-methano-1 H-indene}
Hexachlorocyclopentadiene 1.0
Dimethyl sulfate 0.1
Isobutyraldehyde 1.0
1,2-Dichloropropane 1.0
sec-Butyl alcohol 1.0
Methyl ethyl ketone 1.0
1,1,2-Trichloroethane 1.0
Trichloroethylene 1.0
Acrylamide 0.1
Acrylic acid 1.0
Chloroacetic acid 1.0
Peracetic acid 1.0
1,1,2,2-Tetrachloroethane 0.1
Dimethylcarbamyl chloride 0.1
2-Nitropropane 0.1
-------
Page 41
CAS Number
Chemical Name
De Minimis
Concentration
CAS Number
Chemical Name
De Minimis
Concentration
80-05-7 4,4'-lsopropylidenediphenol 1.0
80-15-9 Cumene hydroperoxide 1.0
80-62-6 Methyl meth aery late 1.0
81-07-2 Saccharin (manufacturing, no 0.1
supplier notification)
{1,2-Benzisothiazol-3(2H)-one,
1,1-dioxide}
81-88-9 C.I. Food Red 15* 0.1
82-28-0 1-Amino-2-methylanthraquinone 0.1
82-68-8 Quintozene 1.0
{Pentachloronitro-benzene}
84-66-2 Diethyl phthalate 1.0
84-74-2 Dibutyl phthalate 1.0
85-44-9 Phthalic anhydride 1.0
85-68-7 Butyl benzyl phthalate 1.0
86-30-6 N-Nitrosodiphenylamine 1.0
87-62-7 2,6-Xylidine 1.0
87-68-3 Hexachloro-1,3-butadiene 1.0
87-86-5 Pentachlorophenol 1.0
{PCP}
88-06-2 2,4,6-Trichlorophenol 0.1
88-75-5 2-Nitrophenol 1.0
88-89-1 Picric acid 1.0
90-04-0 o-Anisidine 0.1
90-43-7 2-Phenylphenol 1.0
90-94-8 Michler's ketone 0.1
91-08-7 Toluene-2,6-diisocyanate 0.1
91-20-3 Naphthalene 1.0
91-22-5 Quinoline 1.0
91-59-8 beta-Naphthylamine 0.1
91-94-1 3,3'-Dichlorobenzidine 0.1
92-52-4 Biphenyl 1.0
92-67-1 4-Aminobiphenyl 0.1
92-87-5 Benzidine 0.1
92-93-3 4-Nitrobiphenyl 0.1
94-36-0 Benzoyl peroxide 1.0
94-59-7 Safrole 0.1
94-75-7 2,4-D 1.0
{Acetic acid,
(2,4-dichlorophenoxy)-}
95-47-6 o-Xylene 1.0
95-48-7 o-Cresol 1.0
95-50-1 1,2-Dichlorobenzene 1.0
95-53-4 o-Toluidine 0.1
95-63-6 1,2,4-Trimethylbenzene 1.0
95-80-7 2,4-Diaminotoluene 0.1
95-95-4 2,4,5-Trichlorophenol 1.0
96-09-3 Styrene oxide 0.1
96-12-8 1,2-Dibromo-3-chloroproparte 0.1
{DBCP}
96-33-3 Methyl aery late 1.0
96-45-7 Ethylene thiourea 0.1
97-56-3 C.I. Solvent Yellow 3* 0.1
98-07-7 Benzoic trichloride 0.1
{Benzotrichloride}
98-82-8 Cumene 1.0
98-87-3 Benzal chloride 1.0
98-88-4 Benzoyl chloride 1.0
98-95-3 Nitrobenzene 1.0
99-59-2 5-Nitro-o-anisidine 0.1
100-02-7 4-Nitrophenol 1.0
100-21-0 Terephthalic acid 1.0
100-41-4 Ethylbenzene 1.0
100-42-5 Styrene 0.1
100-44-7 Benzyl chloride 1.0
100-75-4 N-Nitrosopiperidine 0.1
101-14-4 4,4'-Methylenebis (2- 0.1
chloroaniline)
{MBOCA}
101-61-1 4,4'-Methylenebis(N,N-dimethyl) 0.1
benzenamine
101-68-8 Methylenebis(phenylisocyanate) 1.0
{MBI}
101-77-9 4,4'-Methylenedianiiine 0.1
101-80-4 4,4'-Diaminodiphenyl ether 0.1
103-23-1 Bis(2-ethylhexyl) adipate 0.1
104-94-9 p-Anisidine 1.0
105-67-9 2,4-Dimethylphenol 1.0
106-42-3 p-Xylene 1.0
106-44-5 p-Cresol 1.0
106-46-7 1,4-Dichlorobenzene 0.1
106-50-3 p-Phenylenediamine 1.0
106-51-4 Quinone 1.0
106-88-7 1,2-Butylene oxide 1.0
106-89-8 Epichlorohydrin 0.1
106-93-4 1,2-Dibromoethane 0.1
{Ethylene dibromide}
106-99-0 1,3-Butadiene 0.1
107-02-8 Acrolein 1.0
107-05-1 Allyl chloride 1.0
107-06-2 1,2-Dichloroethane 0.1
{Ethylene dichlonde}
107-13-1 Acrylonitrile 0.1
107-21-1 Ethylene glycol 1.0
107-30-2 Chloromethyl methyl ether 0.1
108-05-4 Vinyl acetate 1.0
108-10-1 Methyl isobutyl ketone 1.0
108-31-6 Maleic anhydride 1.0
108-38-3 m-Xylene 1.0
108-39-4 m-Cresol 1.0
108-60-1 Bis(2-chloro-1-methylethyl) etheM.O
108-78-1 Melamine 1.0
108-88-3 Toluene 1.0
108-90-7 Chlorobenzene 1.0
108-95-2 Phenol 1.0
109-86-4 2-Methoxyethanol 1.0
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Page 42
De Minimis
CAS Number Chemical Name Concentration
110-80-5 2-Ethoxyethanol 1.0
110-82-7 Cyclohexane 1.0
110-86-1 Pyridine 1.0
111-42-2 Diethanolamine 1.0
111-44-4 Bis(2-chloroethyl) ether 1.0
114-26-1 Propoxur 1.0
{Phenol, 2-(1-methylethoxy)-,
methylcarbamate}
115-07-1 Propylene (Propene) 1.0
115-32-2 Dicofol 1.0
{Benzenemethanol, 4-chloro-
,alpha.-(4-chlorophenyl)-
.alpha.-(trichloromethyl)-}
117-79-3 2-Aminoanthraquinone 0.1
117-81-7 Di(2-ethylhexyl) phthalate 0.1
{DEHP}
117-84-0 n-Dioctyl phthalate 1.0
118-74-1 Hexachlorobenzene 0.1
119-90-4 3,3'-Dimethoxybenzidine 0.1
119-93-7 3,3'-Dimethyibenzidine 0.1
{o-Tolidine}
120-12-7 Anthracene 1.0
120-71-8 p-Cresidine 0.1
120-80-9 Catechol 1.0
120-82-1 1,2,4-Trichlorobenzene 1.0
120-83-2 2,4-Dichlorophenol 1.0
121-14-2 2,4-Dinitrotoluene 1.0
121-69-7 N,N-Dimethylaniline 1.0
122-66-7 1,2-Diphenylhydrazine 0.1
{Hydrazobenzene}
123-31-9 Hydroquinone 1.0
123-38-6 Propionaldehyde 1.0
123-72-8 Butyraldehyde 1.0
123-91-1 1,4-Dioxane 0.1
126-72-7 Tris(2,3-dibromopropyl) 0.1
phosphate
126-99-8 Chloroprene 1.0
127-18-4 Tetrachloroethylene 0.1
{Perchloroethylene}
128-66-5 C.I. Vat Yellow 4* 1.0
131-11-3 Dimethyl phthalate 1.0
132-64-9 Dibenzofuran 1.0
133-06-2 Captan 1.0
{1 H-lsoindole-1,3(2H)-dione,
3a,4,7,7a-tetrahydro-
2[(trichloromethy)thio]-}
133-90-4 Chloramben 1.0
{Benzole 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-nydroxy-
N-nitroso,ammonium salt}
Chemical Name
De Minimis
Concentration
CAS Number
139-13-9 Nitrilotriacetic acid 0.1
139-65-1 4,4'-Thiodianiline 0.1
140-88-5 Ethyl acrylate 0.1
141-32-2 Butyl acrylate 1.0
151-56-4 Ethyleneimine (Aziridine) 0.1
156-10-5 p-Nitrosodiphenylamine 0.1
156-62-7 Calcium cyanamide 1.0
302-01-2 Hydrazine 0.1
309-00-2 Aldrin 1.0
{1,4:5,8-Dimethanonaphthalene,
1,2,3,4,10,10-hexachloro-1,4,4a,
5,8,8a-hexahydro-(1 .alpha.,
4.alpha.,4a.beta.,5.alpha.,
8.alpha.,8a.beta.)-}
334-88-3 Diazomethane 1.0
463-58-1 Carbonyl sultide 1.0
492-80-8 C.I. Solvent Yellow 34* 0.1
{Auramine}
505-60-2 Mustard gas 0.1
{Ethane,1,1'-thiobis[2-chloro-}
510-15-6 Chlorobenzilate 1.0
{Benzeneacetic acid,4-chloro-
,alpha.-(4-chlorophenyl)-
.alpha.-hydroxy-.ethyl ester}
532-27-4 2-Chloroacetophenone 1.0
534-52-1 4,6-Dinitro-o-cresol 1.0
540-59-0 1,2-Dichloroethylene 1.0
541-41-3 Ethyl chloroformate 1.0
541-73-1 1,3-Dichlorobenzene 1.0
542-75-6 1,3-Dichloropropylene 0.1
542-88-1 Bis(chloromethyl) ether 0.1
569-64-2 C.I. Basic Green 4* 1.0
584-84-9 Toluene-2,4-diisocyanate 0.1
593-60-2 Vinyl bromide 0.1
606-20-2 2,6-Dinitrotoluene 1.0
615-05-4 2,4-Diaminoanisole 0.1
621-64-7 N-Nitrosodi-n-propylarnine 0.1
624-83-9 Methyl isocyanate 1.0
636-21-5 o-Toluidine hydrochloride 0.1
680-31-9 Hexamethylphosphoramide 0.1
684-93-5 N-Nitroso-N-methylurea 0.1
759-73-9 N-Nitroso-N-ethylurea 0.1
842-07-9 C.I. Solvent Yellow 14* 0.1
924-16-3 N-Nitrosodi-n-butylamme 0.1
961-11-5 Tetrachlorvinphos 1.0
{Phosphoric acid, 2-chloro-1-
(2,3,5-trichlorophenyl)ethenyl
dimethyl ester}
989-38-8 C.I. Basic Red 1* 0.1
1120-71-4 Propane sultone 0.1
1163-19-5 Decabromodiphenyl oxide 1.0
1310-73-2 Sodium hydroxide (solution) 1.0
1313-27-5 Molybdenum trioxide 1.0
1314-20-1 Thorium dioxide 1.0
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Page 43
CAS Number
Chemical Name
De Minimis
Concentration
CAS Number
Chemical Name
De Minimis
Concentration
1319-77-3 Cresol (mixed isomers) 1.0
1330-20-7 Xylene (mixed isomers) 1.0
1332-21-4 Asbestos (friable) 0.1
1335-87-1 Hexachloronaphthalene 1.0
1336-36-3 Polychlorinated biphenyls 0.1
{PCBs}
1344-28-1 Aluminum oxide 1.0
1464-53-5 Diepoxybutane 0.1
1582-09-8 Trifluralin 1.0
{Benzenamine, 2,6- dinitro-N,N-
dipropyl-4-(trifluoromethyl)-}
1634-04-4 Methyl tert-butyl ether 1.0
1836-75-5 Nitrofen 0.1
{Benzene, 2,4-dichloro-1-
(4-nitrophenoxy)-}
1897-45-6 Chlorothalonil 1.0
{1,3-Benzenedicar bonitrile,
2,4,5,6-tetrachloro-}
1937-37-7 C.I. Direct Black 38* 0.1
2164-17-2 Fluometuron 1.0
{Urea, N,N-dimethyl-N'-
[3-(trifluoromethyl)phenyl]-}
2234-13-1 Octachloronaphthalene 1.0
2303-16-4 Diallate 1.0
{Carbamothioic acid,
bis (1-methylethyl)-, S-(2,3-
dichloro-2-propenyl) ester}
2602-46-2 C.I. Direct Blue 6* 0.1
2832-40-8 C.I. Disperse Yellow3* 1.0
3118-97-6 C.I. Solvent Orange 7* 1.0
3761-53-3 C.I. Food Red 5* 0.1
4549-40-0 N-Nitrosomethylvinylamine 0.1
4680-78-8 C.I. Acid Green 3* 1.0
6484-52-2 Ammonium nitrate (solution) 1.0
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 0.1
7440-48-4 Cobalt 1.0
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 tetracrtloride 1.0
7647-01-0 Hydrochloric acid 1.0
7664-38-2 Phosphoric acid 1.0
7664-39-3 Hydrogen fluoride 1.0
7664-41-7 Ammonia 1.0
7664-93-9 Sulfuric acid 1.0
7697-37-2 Nitric acid 1.0
7723-14-0 Phosphorus (yellow or white) 1.0
7757-82-6 Sodium sulfate (solution) 1.0
7782-49-2 Selenium 1.0
7782-50-5 Chlorine 1.0
7783-20-2 Ammonium sulfate (solution) 1.0
8001-35-2 Toxaphene 0.1
10034-93-2 Hydrazine sulfate 0.1
10049-04-4 Chlorine dioxide 1.0
12122-67-7 Zineb 1.0
{Carbamodithioic acid, 1,2-
ethanediylbis-.zinc complex}
12427-38-2 Maneb 1.0
{Carbamodithioic acid, 1,2-
ethanediylbis-.manganese
complex}
16071-86-6 C.I Direct Brown 95* 0.1
16543-55-8 N-Nitrosonornicotine 0.1
20816-12-0 Osmium tetroxide 1.0
25321-22-6 Dichlorobenzene (mixed 0.1
isomers)
25376-45-8 Diaminotoluene (mixed isomers) 0.1
39156-41-7 2,4-Diaminoanisole sulfate 0.1
SECTION 313 CHEMICAL CATEGORIES
Section 313 requires emissions reporting on the chemical
categories listed below, in addition to the specific chemicals
listed above. The metal compounds listed below, unless
otherwise specified, are defined as including any unique
chemical substance that contains the named metal (i.e.,
antimony, copper, etc.) as part of that chemical's structure.
Chemical categories are subject to the 1 percent de minimis
concentration unless the substance involved meets the defini-
tion of an OSHA carcinogen.
Antimony Compounds - Includes any unique chemical sub-
stance that contains antimony as part of that chemical's
infrastructure.
Arsenic Compounds - Includes any unique chemical sub-
stance that contains arsenic as part of that chemical's infra-
structure.
Barium Compounds - Includes any unique chemical sub-
stance that contains barium as part of that chemical's infra-
structure.
-------
Page 44
Beryllium Compounds - Includes any unique chemical sub-
stance that contains beryllium as part of that chemical's
infrastructure.
Cadmium Compounds - Includes any unique chemical sub-
stance that contains cadmium as part of that chemical's
infrastructure.
Chloroohenols -
'(5-x)
where x = 1 to 5
Chromium Compounds - Includes any unique chemical sub-
stance that contains chromium as part of that chemical's
infrastructure.
Cobalt Compounds - Includes any unique chemical substance
that contains cobalt as part of that chemical's infrastructure.
popper Compounds - Includes any unique chemical sub-
stance that contains copper as part of that chemical's infra-
structure.
Cyanide Compounds - X* CM* where X = H* or any other
group where a formal dissociation may occur. For example
KCN or Ca(CN)2.
givcol Ethers - Includes mono- and di- ethers of ethylene
glycol, diethylene glycol, and triethylene glycol.
R-(OCH2CH2)n-OR'
Where n = 1,2,or3
R = alkyl or aryl groups
R'= R, H, or groups which, when
removed, yield glycol ethers with the
structure:
R-(OCH2CH2)n-OH
Lead Compounds - Includes any unique chemical substance
that contains lead as part of that chemical's infrastructure.
Manganese Compounds - Includes any unique chemical
substance that contains manganese as part of that chemical's
infrastructure.
Mercury Compounds - Includes any unique chemical sub-
stance that contains mercury as part of that chemical's infra-
structure.
Nickel Compounds - Includes any unique chemical substance
that contains nickel as part of that chemical's infrastructure.
Polvbrominated Biohenvls (PBBs^
"tlO-*)
where x = 1 to 10
Selenium Compounds - Includes any unique chemical sub-
stance that contains selenium as part of that chemical's
infrastructure.
Silver Compounds - Includes any unique chemical substance
that contains silver as part of that chemical's infrastructure.
Thallium Compounds - Includes any unique chemical sub-
stance that contains thallium as part of that chemical's infra-
structure.
Zinc Compounds - Includes any unique chemical substance
that contains zinc as part of that chemical's infrastructure.
*C.I. means "Color Index."
Polymers are excluded from this category.
-------
Page 45
TABLE III
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
STATE ABBREVIATIONS
AL Montana MT
AK Nebraska NE
AS Nevada NV
AZ New Hampshire NH
AR New Jersey NJ
CA New Mexico NM
CO New York NY
CT North Carolina NC
DE North Dakota ND
DC Commonwealth of the Northern Mariana Islands MP
FL Ohio OH
GA Oklahoma OK
GU Oregon OR
HI Pennsylvania PA
ID Puerto Rico PR
IL Rhode Island Rl
IN South Carolina SC
IA South Dakota SD
KS Tennessee TN
KY Texas TX
LA Utah UT
ME Vermont VT
MH Virginia VA
MD Virgin Islands VI
MA Washington WA
Ml West Virginia WV
MN Wisconsin Wl
MS Wyoming WY
MO
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Page 46
ADDITIONAL MATERIALS AVAILABLE ON
SECTION 313:
For copies of these materials, send in the request form
included in the booklet or write to:
Section 313 Document Distribution Center
P.O. Box 12505
Cincinnati, OH 45212
Q Section 313 Rule (PR Reprint)
A reprint of the final section 313 rule as it appeared in the
Federal Register (FR) February 16, 1988.
a TRI Magnetic Media Submission Guidance Package
(EPA 560/7-88-003)
Reports under section 313 may be submitted by computer
tape orf loppy disk. This guidance package gives the format
requirements and other details for such submissions.
Q Toxic Chemical Release Inventory Questions and
Answers (EPA 560/4-89-002)
Answers to frequently asked questions about the section
313 rule, organized by subject area.
Q Section 313 Technical Questions and Answers
Document
Q Common Synonyms for Section 313 Chemicals
(OTS-ETD-001)
This document contains common synonyms for the specifi-
cally listed section 313 chemicals (synonyms for chemicals
in covered categories are not included).
Q Comprehensive List of Chemicals Subject to Reporting
Under the Act
(Title III List of Lists) (EPA 560/4-88-003)
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 provides specific information on what reporting
requirement(s) the chemical is subject to.
Q Supplier Notification Requirements Brochure
(EPA 560/4-88-008)
Q Trade Secrets Rule and Form (FR Reprint)
A reprint of the final rule that appeared in the Federal
Register of July 29,1988. This rule implements the trade
secrets provision of the Emergency Planning and Commu-
nity Right-to-Know Act (Section 322). Includes a copy of the
trade secret substantiation form.
Q Industry Specific Technical Guidance Documents
The Agency has developed a group of smaller, individual
guidance documents that target activities in industries who
primarily process or use the listed toxic chemicals.
Also available:
G Comprehensive List of Chemicals Subject to Reporting
Under the Act
(Title III List of Lists)
Available as an IBM compatible disk from: The National
Technical Information Service, 5285 Port Royal Road, Spring-
field, VA 22161, (703) 487-4650, Document Number: PB
88-193255, $50.00.
Q Estimating Releases and Waste Treatment Efficiencies
for the Toxic Chemical Release Inventory
(EPA 560/4-88-002)
Suggested methods on the development of release esti-
mates and waste treatment efficiency calculations required
on Form R. Available from: Superintendent of Documents,
Government Printing Office, Washington, DC 20402-9325,
(202) 783-3238, Stock Number: 055-000-00270-3, $11.00.
-------
PI63S6 SGnd I
Section 313 Rule (FR Reprint)
Additional Copies of Instructions and Form R
(EPA 560/4-88-005)
TRI Magnetic Media Submission Guidance
Package (EPA 560/7-88-003)
Toxic Chemical Release Inventory Questions
and Answers (EPA 560/4-89-002)
Section 313 Technical Question and Answers
Document
Common Synonyms for Section 313
Chemicals (OTS-ETD-001)
Comprehensive List of Chemicals Subject to
Reporting under the Act (Title III List of
Lists) (EPA 560/4-88-003)
Supplier Notification Requirements Brochure
(EPA 560/4-88-008)
Trade Secret Rule and Substantiation Form
Oni (Please indicate the quantities you are requesting.)
Industry Specific Technical Guidance
Documents for Estimating Releases:
Monofilament Fiber Manufacture
(EPA 560/4-88-004a)
Printing Operations (EPA 560/4-88-004b)
Electrodeposition of Organic Coatings
(EPA 560/4-88-004C)
Spray Application of Organic Coatings
(EPA 560/4-88-004d)
Semiconductor Manufacture (EPA 560/4-88-oo4e)
Formulating Aqueous Solutions (EPA 560/4-88-004f)
Electroplating Operations (EPA 560/4-88-D04g)
Textile Dyeing (EPA 560/4-88-004h)
Presswood and Laminated Wood Products
Manufacturing (EPA 560/4-88-004J)
Roller, Knife, and Gravure Coating Operations
(EPA 560/4-88-004J)
Paper and Paperboard Production
(EPA 560/4-88-004k)
Leather Tanning and Finishing Processes
(EPA 560/4-88-004I)
Wood Preserving (EPA 560/4-88-Q04p)
Rubber Production and Compounding
(EPA 560/4-88-004q)
-------
Fold
FACILITY NAME
STREET
STATE ZIP CODE
Section 313 Document Distribution Center
P.O. Box 12505
Cincinnati, OH 45212
-------
Page 47
APPENDIX A
EXAMPLE OF A COMPLETED FORM R FOR A HYPOTHETICAL FACILITY
REPORTING UNDER TITLE III, SECTION 313
The following is a hypothetical example of how one manufac-
turer might complete the toxic chemical release inventory
reporting Form R. The facility information is purely fictitious
and does not represent any known manufacturing facility. The
example begins with descriptions of the facility (a lead-acid
storage battery manufacturer) and of the production process
at the facility. The completion of each section of Form R is
explained and a copy of Form R, as it would be completed by
this facility, follows.
Facility Description
Your company manufactures lead-acid batteries at a plant in
New Mexico. Yourcompany also operates a lead smelterthat
produces lead ingots at another location in New Mexico and
ships them to the battery plant. Lead scrap from the battery
plant is returned to the smelter for recovery and reuse. The
SIC code of the battery plant is 3691 (storage batteries); the
SIC code for the smelter is 3341 (secondary smelting and
refining of non-ferrous metals). A lead oxide production plant
located adjacent to the battery plant, on the same property,
also falls under SIC code 3691.
The lead oxide plant and the battery plant are considered, for
the purposes of section 313 reporting requirements, to be a
single facility. The facility is required to submit a completed
Form R for each reported chemical or chemical category.
Because activities at yourfacility involve both metallic lead and
lead compounds (e.g., lead oxide), you may file a single
reporting form for metallic lead (CAS number 7439-92-1) and
a single form for lead compounds manufactured, processed,
or used at yourfacility. Alternatively, and preferably, you may
file one reporting form for all lead compounds (a single listed
category under section 313) present at your facility, including
metallic lead. In this example, metallic lead and all lead
compounds are reported on a single reporting form.
Lead-acid batteries are produced using lead, sulfuric acid,
additives such as antimony, and various other raw materials.
Yourfacility's battery production capacity is 5000 batteries per
day, and the facility normally operates 24 hours per day, 300
days per year. If sulfuric acid was manufactured, processed,
or used at the battery plant in amounts that exceed the
applicable thresholds, you would be required to report re-
leases of sulfuric acid separately. Similarly, releases of lead
and lead compounds from the remotely located lead smelter
must be reported separately, if manufactured, processed, or
used in amounts that exceed the thresholds.
Process Description
A lead-acid battery consists of a number of electrolytic cells,
each containing an anode of porous lead, a cathode of
primarily lead peroxide (PbO2), and electrodes of metallic
lead. The anode and cathode are separated by non-conduct-
ing material (e.g., plastic) and surrounded by an electrolytic
(conductive) solution of sulfuric acid and water.
The first steps in the battery manufacturing process are grid
casting and lead oxide (PbO) production. Lead ingots are
melted and reformed by grid molding machines. The grids are
ejected from the molds, trimmed, and stacked. Lead fumes
from the lead melting and grid casting process are exhausted
to the atmosphere without emission controls. The melting and
casting process produces no wastewater.
The cast grids are made into battery anode and cathode plates
by the application of a lead oxide paste of 70 percent lead
oxide (PbO) and 30 percent metallic lead. Lead ingots are
tumbled in a ball mill with air producing lead oxide and fine lead
dust (referred to as "leady oxide"). Leady oxide particulates
are entrained in the mill exhaust air, which is treated sequen-
tially by a cyclone separator and fabric filter. The used fabric
filter bags are shipped to a RCRA-permitted commercially
operated hazardous waste landfill located in Colorado. The
leady oxide production process does not produce wastewater.
The leady oxide is mixed with metallic lead, water, sulfuric
acid, and additives in a paste mixer to form battery paste,
which is applied to the lead grids to form battery plates. Lead
and lead oxide dust are emitted from the paste mixer during
charging of the dry materials, and from the mixer exhaust
during wet mixing. The mixer is vented to a fabric filter during
charging and to a wet scrubber during wet mixing. The fabric
filter and wet scrubber vent to the same stack. The paste
mixing and application process produces wastewaterf rom the
wet scrubber blowdown and also from washdown of the paste
mixing equipment and mixing area. Scrubber blowdown is
treated on-site. Solids collected in a scrubber sump are
returned to the off-site smelter for recovery and reuse. Solids
collected in an evaporation pond are not recovered. Wash-
down water is treated in a multi-stage settler and entirely
reused in the paste mixing process. Sludge collected in the
settler is recycled. Small amounts of particulates are released
to the atmosphere during paste application. These emissions
are not ducted to a stack or controlled.
-------
Page 48
The plates are then dried and cured under controlled tempera-
ture and humidity conditions. The plate drying and curing
operation produces no wastewater or participate emissions.
Cured plates are sent to a three-process operation that
involves manual separation of the plates, stacking them with
non-conducting separators, and the welding on of metallic
lead battery leads (pronounced "leads") and lead terminals.
The plates are then assembled into battery cases.
Paniculate emissions of battery paste result from the manual
separation, stacking, and handling of the battery plates. Lead
fumes are emitted from the burning process. Exhaust gases
from the three-process operation are treated by a fabric filter,
and the collected particulates are returned to the smelter for
recovery and reuse. The three-process operation produces
no lead-containing wastewater, as only non-contact cooling
water is used in the burning process. [Note: Even though lead
is contained in the cooling water used by your facility (in the
form of dissolved and suspended solids), you are not required
to report releases of lead discharged with the cooling water
because the lead is naturally occurring and not added in the
battery production process.]
Suit uric acid is added to the assembled batteries and the
plates are formed within the batteries by applying electric
voltage. The formation process oxidizes the lead oxide in the
positive plates to lead peroxide and reduces the lead oxide in
the negative plates to metallic lead. The charging process
produces an acid mist that contains small amounts of lead
paniculate, which is released without emission controls.
Acid used in the formation process is removed from the
batteries and reused. The batteries are washed, fresh acid is
added, and the batteries are tested, re-washed, and inspected
before being shipped to an on-site warehouse. The interme-
diate and final washes generate process wastewater, as do
the battery repair and housekeeping (floor washing) opera-
tions. This wastewater is pretreated on-site and then piped to
the local publicly owned treatment works (POTW).
Determining Reporting Requirements Under Section 313
To determine your eligibility for reporting under section 313,
you must ascertain whether the total quantity of any listed
chemical orchemical compound manufactured, processed, or
used at your facility over the course of the calendar year
exceeds any applicable threshold. For the facility described
above, your determination of eligibility would proceed as
follows. [Note: In determining eligibility, you will generate
information you need to complete several portions of the
form.]
Both lead (CAS number 7439-92-1) and lead compounds (a
chemical category) are listed substances subject to reporting
under section 313. You have decided that if any of the
applicable thresholds are exceeded, you will report releases of
both lead and lead compounds on the same reporting form
under the listed chemical category "lead compounds." "Lead
compounds" should be entered in Part III, Section 1.3, of the
form. The CAS number for lead should npt be entered,
because that would imply that you are reporting only for lead.
You should enter not applicable, NA, in the CAS number
space.
According to the process description, the following activities
take place at your facility involving lead and lead compounds:
Q Your facility manufactures (produces) lead oxide (PbO)
for on-site use/processing, which occurs in the production
of lead oxide from metallic lead.
Q Your facility processes metallic lead (Pb) as a reactant
during lead oxide production.
Q Your facility also processes metallic lead as an article
component. This activity occurs at several points in the
process, including during the addition of lead to the
battery paste and the welding of metallic lead terminals
and leads in the three-process operation.
Q Your facility processes lead oxide as a reactant in the
formation process, where the lead oxide in the positive
battery plates is oxidized to lead peroxide.
Q Yourfacilitv manufactures (produces) lead peroxide. This
activity also occurs in the formation process, where lead
oxide is oxidized to lead peroxide.
You must indicate all of the activities involving lead and lead
compounds on Part III, Section 3, of the reporting form. (The
attached completed form shows how information for this
facility has been entered.)
Determining Reporting Eligibility. The manufacturing thresh-
old quantity for the 1988 reporting year is 50,000 pounds; the
threshold for processing is also 50,000 pounds. These thresh-
olds drop to 25,000 pounds for the 1989 reporting year. Your
facility both manufactures and processes, as it produces
1,500,000 batteries per year. Each battery contains 25
pounds of lead, half of which is in the form of metallic lead
(anode) and half in the form of lead peroxide (cathode). The
total amount of lead compounds manufactured during the
reporting year is the 18,750,000 pounds of lead peroxide,
which exceeds the threshold for manufacturing. Similarly, the
amounts of lead processed as an article component (18,750,000
pounds) and of lead compounds processed (18,750,000 pounds)
each exceed the threshold for processing. [Note: These
amounts are not first combined before being compared to the
processing threshold, because both lead and lead compounds
are separately listed chemicals. If you added the amount of
lead processed into lead oxide to that then processed into lead
-------
Page 49
peroxide, you would be double counting.] For sequential
processes, use the amount of the final process material to
determine whether the threshold is exceeded. Since your
facility employs more than 10 people and falls within SIC codes
20-39, your facility must report under section 313. [Note:
Once any of the applicable thresholds for lead compounds are
exceeded, you are required to identify all manufacturing,
processing, and use activities. You must report all releases of
all lead compounds present at your facility, regardless of the
activity from which they originate unless there is a specifically
exempted use, such as the use of an article or use of water
naturally containing lead.]
Calculating the Maximum Quantity of Lead and Lead Com-
pounds. To calculate the maximum amount of lead and lead
compounds present at your facility at any one time, you must
consider ajj types of metallic lead and M types of lead
compounds present at your facility, including stockpiled raw
materials (i.e., lead ingots), lead and lead oxide present in
process equipment (i.e., molten lead contained in the grid
casting system, lead and lead oxide contained in the paste
mixer), the inventory of metallic lead and lead peroxide con-
tained in finished batteries stored on-site, and stockpiled lead
scrap. Since the reporting form is being prepared for lead
compounds, the maximum amount reported is the total of the
inventories of these materials. The maximum amount of
metallic lead (2,305,000 pounds), lead oxide (205,000 pounds),
and lead peroxide (625,000 pounds) present at your facility is
3,135,000 pounds, which is between 1,000,000 and 9,999,999
pounds. You would therefore report range 06 on Part III,
Section 4, of the reporting form.
Calculation of Releases of Lead
Releases to Air. In April 1988, you conducted stack tests to
determine air releases from the battery facility. The release
data provided baseline data for a proposed 1989 air emission
reduction program. The tests were performed using EPA
Reference Method 12, which determines exhaust concentra-
tions as total elemental lead, and EPA Reference Methods 1 -
4, which determine total exhaust volumes. Releases from all
stacks and vents at the facility were measured, including those
from the following release points:
Q Grid casting furnace and casting machine;
Q Lead oxide mill fabric filter exhaust;
Q Paste mixer wet scrubber exhaust;
Q Paste mixer fabric filter exhaust; and
Q Three process fabric filter exhaust.
Non-point (fugitive) air releases of lead, such as from the
battery formation, grid paste application, and fabric filter dust
handling areas were not determined as part of the stack
testing program. These have been estimated by yourfacility's
engineering department to be less than 100 pounds per year.
Measurements of the inlet lead concentrations to the wet
scrubber or fabric filters were not performed. The process
conditions (e.g., temperature, exhaust rate) of the grid casting
furnace were changed significantly in June 1988 in response
to the stack test results. Current lead releases are estimated
by the engineering department to be 75 percent of those
measured during the stack test.
The total releases to air from the facility must be entered in
Part III, Section 5, of the form. The stack test results provide
the concentration of metallic lead in each exhaust stream in
grains per cubic foot and the exhaust rate in cubic feet per
minute. You are required to report releases or release ranges
in pounds per year. Using the appropriate conversion factors,
knowing the scrubber efficiency (from the manufacturer's
data), and assuming your facility operates 24 hours per day,
300 days per year, you can calculate the total lead releases
from the stack test data. Because point (stack) releases of
lead are 2400 Ib/yr, which is greater than 999 Ib/yr, you must
enter the actual calculated amount in column A.2 of Section
5.2. Non-point (fugitive) air releases are 100 Ib/yr (which is
less than 999 Ib/yr), so you may either enter the actual
calculated amount in column A.2, or enter the appropriate
range (1-499 Ib/yr) in column A.1. The basis for the estimate
of fugitive emissions, entered in column B of Section 5, is
engineering calculations (code O). The basis for the estimate
of stack emissions, entered in column B of Section 5, is
monitoring data (code M). Although engineering calculations
were used to estimate releases from the grid casting process,
actual emissions test data were used to calculate more than
50 percent of the total stack emissions, so code M is appropri-
ate.
Releases to Water. The only release of lead to a receiving
stream or water body comes from stormwater. Lead ingots
shipped from the off-site smelter are stored on a concrete pad
in an open area at your facility. Lead dust is entrained in the
stormwater runoff from the ingot storage area. You have
monitoring data concerning the concentration of lead in storm-
water releases from the facility property. Therefore, using
precipitation volumes and run-off coefficients appropriate to
the site, you are able to estimate that releases of lead
compounds to the nearby stream total 6.2 pounds per year.
Since the total quantity of lead released is less than 999 Ib/yr,
you may enter the actual amount calculated in column A.2 of
Section 5.3.1 a, or mark the applicable range (1-499 Ib/yr) in
column A.1, as is shown in the sample. Your facility has no
process discharges to surface waters except stormwater. You
must therefore report in Part III, Section 5.3.1c, that 100
percent of the lead released from your facility to surface water
is from stormwater. The basis for the estimate of stormwater
emissions, entered in column B of Section 5.3.1, is monitoring
data (code M). The number for the receiving stream or water
body you designated in Part I, Section 3.10 must be entered.
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Page 50
Wastewater from the grid paste application process is entirely
recycled within the process after treatment in a multi-stage
settler. Wastewater from the grid paste mixer wet scrubber is
piped to an on-srte surface impoundment and evaporated
after treatment by a single-stage separator (settling tank) and
pH adjustment for chemical precipitation. Wastewater from
other process areas is treated in the wastewater pretreatment
system and piped to the POTW. The following sections on
Releases to Land and Discharge to POTW illustrate reporting
of these wastes.
Releases to Underground Injection. Your facility performs no
underground injection and therefore has no Underground
Injection Well Code identification number. Not applicable, NA,
should be entered in Part I, Section 3.11 and in column A.2 of
Part III, Section 5.4.
Releases to Land. Wastewater from the grid paste mixing
scrubber is discharged to a surface impoundment and evapo-
rated. Although your facility historically has removed lead
sludge from the surface impoundment each year, this has not
been done for the past two years, as process changes have
caused the sludge to accumulate more slowly than in previous
years. Therefore, the impoundment must be considered an
on-site land disposal unit, and releases to the impoundment
must be reported in Part III, Section 5.5.1, of the form, and not
in Part III, Section 5.3.
The facility wastewater monitoring program does not deter-
mine the concentration of lead and lead compounds in the
scrubber discharge water, and releases to the surface im-
poundment (releases to land) must be calculated from mate-
rial balance information. These releases to land are deter-
mined from the amount of lead removed by the scrubber
(using the efficiency data provided by the scrubber manufac-
turer). The volume of the scrubber blowdown is found to be
1,500 pounds per year. Enter the estimate of the amount of
lead and lead compounds released to surface impoundments
in the space provided in Part III, Section 5.5.3 of the form.
Because releases of lead to the surface impoundment are
greater than 999 Ib/yr, you must enter the actual calculated
amount in column A.2 of Section 5.5.1. The basis for the
estimate of releases to the impoundment, entered in column
B of Section 5, is mass balance calculations (code C).
Calculation of Transfers of Lead to Off-Site Locations
Discharge to POTW. Wastewater from battery wash and
battery repair operations at your plant is discharged to the
local POTW. The discharge monitoring system data collected
by your plant provide the concentration of metallic lead in each
wastewater stream discharged to the POTW in milligrams/liter
and the flow rate in liters perminute. Yourfacility also monitors
the inlet concentration to the on-site wastewater treatment
system to determine the treatment system efficiency. You are
required to report releases or release ranges in pounds per
year. Assuming your facility operates 24 hours a day, 300
days a year, using appropriate conversion factors and the
monitoring data (i.e., lead concentrations and wastewater
volumes), the release is calculated to be 11 pounds per year.
The total releases to the POTW from the facility must be
entered in Part III, Section 6.1, of the form. Because the
releases of lead are less than 999 Ib/yr, you may mark the
appropriate range in column A.1 or enter the actual calculated
amount in column A.2 of Section 6.1.1. You must report
information concerning the multi-stage settler, single-stage
settler, and pH adjustment (chemical precipitation) on Part III,
Section 7, of the form, as these systems constitute wastewa-
ter treatment systems. You must also enter the name of the
POTW in Part II, Section 1.1.
Transfers to OtherOff-Site Locations. Yourfacility returns the
lead paniculate collected by the fabric filters to the off-site
smelterf or recovery and reuse. You are not required to report
releases of listed substances to off-site recovery facilities;
therefore, no information concerning the off-site smelter should
be entered in Part III, Sections 6.2.1, 6.2.2, or 6.2.3, of the
form. Your facility discharges used fabric filter bags contami-
nated with lead paniculate to a commercial RCRA landfill
located in Colorado. The RCRA I.D. number for the off-site
facility is COD554698764. The plant engineering department
estimates that the annual shipment of fabric filter bags contain
less than 500 pounds of lead. You may therefore report the
release as a range in column A.1 of Section 6.2.1. The basis
for the estimate of solid waste emissions, entered in column B
of Section 6.2.1, is engineering calculations (code O), and the
location and RCRA I.D. number of the commercial landfill is
entered in Part II, Section 2.1, of the form.
Estimation of Treatment System Efficiencies and Influent
Concentrations
Information on the types of treatment systems and their
treatment efficiencies is required to be entered in Part IV,
Section 7, of the form. For air emission treatment systems use
code A, for wastewater treatment systems use code W, and
for solid waste treatment systems use code S in column 1 of
Section 7 of the form. Table III of the instructions for Form R
provides treatment codes to be entered in column B of Section
7.
Air Treatment Systems. Fabric filters and cyclone collectors
are considered to be mechanical separation systems; the
treatment code forthese systems is A06. The treatment code
for wet scrubbers is A03. Information on each air treatment
system must be entered individually in Section 7. The cyclone
collector and fabric filter on the lead oxide mill exhaust are
considered to be sequential treatment systems, because both
systems treat the same wastestream in sequence. Therefore,
sequential treatment must be indicated for both systems in
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Page 51
column Oof Section 7. You are required to indicate the influent
concentration only to the first step of the sequential treatment
system (the cyclone collector) and must report the overall
treatment efficiency of the system entered on the line for the
last treatment step (the fabric fitter). Note that the wet
scrubber and fabric filter on the grid paste mixer exhaust are
not sequential treatment steps, because each treats a differ-
ent wastestream generated at different times during the same
process.
In Section 7, columns C and E, respectively, you must indicate
the range of influent concentration and treatment efficiency for
each treatment system listed. You must estimate the effi-
ciency and influent concentration of each air emission treat-
ment system, as the stack test program did not determine
influent concentrations. You have manufacturers' data on the
efficiency of each treatment system and should use this
information along with effluent concentration data to estimate
the influent concentrations. The efficiency estimates for air
treatment systems are not based on operating data; this must
be indicated in column F of Section 7.
Wastewater TreatmentSystems. The POTW discharge
monitoring system provides actual operating data concerning
the removal efficiencies, and influent and effluent concentra-
tions of all wastewater treatment systems at your facility
except the single-stage settler. The pH adjustment (chemical
precipitation) and filtration steps used in the wastewater pre-
treatment system are considered to be sequential treatment
steps, as are the single-stage settler, pH adjustment, and
evaporation (the surface impoundment) used to treat the grid
paste application discharge. The treatment code for chemical
precipitation (lime or sodium hydroxide) is C01, and the code
for filtration is P12.
significant cost-savings. The most significant savings is in the
cost of treating the sludge; the value of the recovered lead is
less significant. The amount of lead formerly disposed of at
the off-site facility is approximately 100 Ib/yr; the same
amount is now recovered by the smelter. The code f orthe type
of modification is M2 (recovery off-site) and that for the reason
for action is R2 (reduction in treatment/disposal cost). The
index value of 1.0 is based on the fact that production of
batteries was approximately the same in both years.
Completion of the Section 313 Reporting Form
As shown in the sample form that follows, your facility informa-
tion is entered in Part I of the reporting form. The reporting
year, Dun and Bradstreet Number, EPA Identification Number
and other required information have been entered. The
sample report contains no trade secret information and has
been completed for an entire covered facility, as previously
described. All non-applicable information on the form has
been marked NA. The vice president of your facility has been
briefed on the information contained in the report and has
signed the certification (Part I, Section 2). If separate reports
were being prepared for lead and lead compounds, your vice
president would have signed each reporting form. The com-
pleted form is now ready to be submitted to EPA and the
appropriate State agency.
The treatment code for treatment of grid paste application
washwater in the multi-stage settler is P11 (settling/clarifica-
tion), and the treatment code for process reuse of the waste-
water is R99(otherrecovery/reuse). Thecodeforevaporation
of wastewater in the surface impoundment is P99 (other
physical treatment). The overall treatment efficiencies for the
grid paste application discharge and scrubber discharge are
both 100 percent, because the wastewater streams are
completely eliminated through evaporation and reuse respec-
tively. Note that you do not report the precipitation of lead in
the surface impoundment as "metals recovery," because you
no longer remove the lead sludge from the impoundment for
reuse. This will be considered disposal to land for the 1,500
pounds of lead that were sent to the impoundment.
Information on Waste Minimization. Your facility formerly
shipped the lead-containing sludge from the multi-stage set-
tler used to treat the grid paste application wastewater to an
off-site disposal facility. In 1987, however, process modifica-
tions allowed you to return the sludge to the off-site smelter
operated by your company for recovery and reuse, resulting in
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Page 51 a
D
(Important: Type or print: read instructions before completing form.)
Form Approved OMB No. ._207Q-OQ93
Approval Fxpirog- 01/91
D
Page
1 of 5
EPA
U.S Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
Section 313 of the Emergency Planning and Community Rlght-to-Know Act of 1986,
also known as Title III of the Superfund Amendments and Reauthorlzatlon Act
EPA FORM
PART I.
FACILITY
IDENTIFICATION
INFORMATION
(This space for your optional use.
Public reporting burden for this
collection of information is estimated to
vary from 30 to 34 hours per response,
with an average of 32 hours per
response, including time for reviewing
instructions, searching existing data
sources, gathering and maintaining the
data needed, and completing and
reviewing the collection of information.
Send comments regarding this burden
estimate or any other aspect of this
collection of information, including
suggestions for reducing this burden, to
Chief. Information Policy Branch
(PM-223), US EPA, 401 M St., SW.
Washington. D C. 20460 Attn: TRI
Burden and to the Office of Information
and Regulatory Affairs. Office of
Management and Budget Paperwork
Reduction Project (2070-0093).
Washington. D C 20603
1.
1.1 Are you claiming the chemical identity on page 3 trade secret?
I I Yes (Answer question 1 2:
Attach substantiation forms.)
L x I No (Do not answer 1 2;
Go to question 1,3 )
1.2 If "Yes" in 1.1, is this copy:
[ J Sanitized [ J Unsamtized
1 .3 Reporting Year
19 88
2. CERTIFICATION (Read and sign after completing all sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true and
complete and that the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers of this report
Name and official title of owner/operator or senior management official
Mr. Stanley L. Pirx, III, Vice President, Battery Products Division
Signature
Date signed
February 12, 1989
3. FACILITY IDENTIFICATION
3.1
Fapillty or Establishment Name
Pirx-Lewis, Inc., Battery Products Div.
Road
uquerque
State
NM
County
Bernadillo
1?1T03-0420
WHERE TO SEND COMPLETED FORMS:
1. U.S. ENVIRONMENTAL PROTECTION AGENCY
P.O. BOX 70266
WASHINGTON, DC 20024-0266
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE (See instructions
Appendix E)
3.2
This report contains information for (Check one)'
a. I X J An entire facilr
lity
'• L J par* °(a fai
.cihty
3.3
Technical Contact
Mr. Roberto Garcia
Telephone Number Cnclude area code)
(505) 752-5360
3.4
Public Contact
Ms. Sandy A. Range
Telephone Number (include area code)
(505) 752-5363
3.5
SIC C.
3
a.
4 digit)
NA
Latitude
Longituae
3.6
Degrees
Minutes
10
Seconds
00
Degrees
106
Minutes
30
Seconas
oo
3.7
Dun & Bradstreet Number(s)
a.91-976-2270
NA
3.8
EPA Identification Number(s) (HCRAi.D No.)
a. NMD91976227Q
3.9
NPDES Permit Number (s)
a. NA
Receiving Streams or Water Bodies (enter one name per box)
a Tiieros Arrovo
NA
3.10
3.11
Underground Injection Well Code (UIC) identification Number(s)
a NA
4. PARENT COMPANY INFORMATION
4.1
4.2
Name of Parent Company
Cibola Motor Works
Parent Company's Dun & Sradstreet Number
91-783-4567
EPA Form 9350-1 (1-89) Revised—Do not use previous versions.
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Page 51 b
D
(Important: Type or print; read instructions before completing form.)
D
R(Thls space for your optional use.)
_-..,..
& tPA PART II. OFF-SITE LOCATIONS TO WHICH TOXIC
CHEMICALS ARE TRANSFERRED IN WASTES
1. PUBLICLY OWNED TREATMENT WORKS (POTWs)
1.1 POTW name
City of Albuquerque Treatment Works
Street Address
50100 U.S. Route 66
City
Albuquerque
State
NM
2. OTHER OFF-SITE LOCATIONS
County
Bernadillo
Zip
87105-9987
1.2 POTW name
NA
Street Address
City County
State Zip
(DO NOT REPORT LOCATIONS TO WHICH WASTES ARE SENT ONLY FOR RECYCLING OR REUSE).
2.1 Off-site location name
Colorado Waste Disposal^ Inc.
EPA Identification Number (RCRA ID. No. )
COD554698764
Street Address
10500 County Route 76
City
Golden
State
CO
Is location under control of reporting facility
County
Jefferson
Zip
80305-1311
or parent company?
1 JYes L XJN°
2.2 Off-site location name
EPA Identification Number (RCRA ID. No.)
NA
Street Address
City County
State Zip
Is location under control of reporting facility or parent company?
1 JYes I JNO
2.3 Off-site location name
2.4 Off-site location name
EPA Identification Numoer (RCRA ID. No )
EPA Identification Number (RCRA ID. No.)
Street Address
Street Address
City
County
City
County
State
Zip
State
Zip
Is location under control ot reporting facility or parent company?
Is location under control of reporting facility or parent company9
[ ]Yes
No
2.5 Off-site location name
2.6 Off-site location name
EPA Identification Number (RCRA ID. No.)
EPA Identification Number (RCRA ID. No.)
Street Address
Street Address
City
County
City
County
State
Zip
State
Is location under control of reporting facility or parent company7
[ ]ves
No
Is location under control of reporting facility or parent company7
[ JYes [ ]
NO
[ ] Check if additional cages of Pan II are attached. How many?
EPA Form 9350-1(1-89) Revised—Do not use previous versions.
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Page 51 c
D
(Important: Type or print; read instructions before completing form.)
D
Page 3 of 5
A EPA
EPA FORM R
PART III. CHEMICAL-SPECIFIC INFORMATION
(This space for your optional use.)
1. CHEMICAL IDENTITY(Do not complete this section if you complete Section 2.)
1.1
[Reserved]
1.2
CAS Number (Enter the number exactly as it appears on the 313 list. Enter NA if reporting a chemical category.)
NA
1.3
Chemical or Chemical Category Name (Enter the name exactly as it appears on the 313 list.)
Lead Compounds
1.4
Generic Chemical Name (Complete only if Part I, Section 1.1 is checked "Yes." Generic name must be structurally descriptive.)
MIXTURE COMPONENT IDENTITY (Do not complete this section if you complete Section 1.)
2.
Generic Chemical Name Provided by Supplier (Limit the name to a maximum of 70 characters (e.g., numbers, letters, spaces, punctuation).)
3. ACTIVITIES AND USES OF THE CHEMICAL AT THE FACILITY (Check all that apply.)
3.1
Manufacture the
chemical:
a. I XJ Produce
b.[ J Import
If produce or import:
[xl For on-site
•I use/processing
e. [ J As a byproduct
I For sale/
•" distribution
f . [ J
As an impurity
3.2
Process the
chemical:
a. [ x] As a reactant b.[
d. [ J Repackaging only
1 As a formulation
•I component
[xl As an article
J component
3.3
Otherwise use
the chemical:
a.I
1 As a chemical
J processing aid
I As a manufacturing aid c.L J Ancillary or other use
4. MAXIMUM AMOUNT OF THE CHEMICAL ON-SITE AT ANY TIME DURING THE CALENDAR YEAR
(enter code)
5. RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
You may report releases of less than
1,000 Ibs. by checking ranges under A. 1.
(Do not use both A.1 and A.2)
5.1 Fugitive or non-point air emissions
5.2 Stack or point air emissions
5.3 Discharges to receiving A
streams or water bodies 5-3-'
(Enter letter code from Part I
Section 3.10 for stream(s) In 5.3.2
the box provided.)
5.3.3
5.4 Underground injection
5.5 Releases to land
5.5.1 On-site landfill
5.5.2 Land treatment/application farming
5.5.3 Surface impoundment
5.5.4 Other disposal
5.1a
5.2a
5.3.1a
5.3.2a
5.3.3a
5.4a
5.5.1a
5.5.2a
5.5.3a
5.5.4a
A. Total Release
(Ibs/yr)
A.1
Reporting Ranges
0 1^»99 500-999
[ ]
[ ]
[ ] [A] [ ]
A.2
Enter
Estimate
2400
NA
NA
NA
NA
1500
NA
B. Basis of
Estimate
(enter code)
5.2b
5.3.1b
Ml
5.3.2b
5.3.3b
n
C % From Stormwater
5.3.1c 100
5.3.2c NA
5.3.3c
5.4b
5.5.1b
5.5.2b
5.5.3b
5.5.4b
(Check If additional information is provided on Part IV-Supplwnental Information.)
EPA Form 9350-1(1-89) Revised—Do not use previous versions.
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Q Page 51 d
(Important: Type or print; read instructions before completing form.)
Page 4 of 5
3 EPA
EPA FORMR
PART III. CHEMICAL-SPECIFIC INFORMATION
(continued)
(This space for your optional use.
6. TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
You may report transfers
of less than 1,000 Ibs. by checking
ranges under A.1, (Do not use
both A.1 and A.2)
Discharge to POTW
(enter location number
6.1.1 'rom Part II, Section 1.)
Other off-site location
,. - , (enter location number 5
O.Z.I from Part II, Section 2.) If! •
A. Total Transfers
(Ibs/yr)
A.1
Reporting Ranges
0 1-499 500-999
[ ] [X] [ ]
MMM
A.2
Enter
Estimate
B. Basis of Estimate
(enter code)
C.Type of Treatment/
Disposal
[enter code
6.2.1b
Other off-site location
e - - (enter location number
o.Z.2 from Part II, Sections.)
[ 1 [ 1 [ 1
NA
6.2.2b
Other otf-site location
(enter location number
tenter location numoer 5
6.2.3 from Part II. Section 2 j *
6.2.3b
[ ] (Check if additional information is provided on Part IV-Supplemental Information )
7. WASTE TREATMENT METHODS AND EFFICIENCY
A. General
Wastestream
(enter code)
B. Treatment
Method
(enter code)
7.10a W 7.iob R 9 9
C. Range of
Influent
Concentration
(enter code)
D. Sequential
Treatment?
(check if
applicable)
E. Treatment
Efficiency
Estimate
F. Based on
Operating
Data?
Yes No
7.1a
7.1c
7.1d
7.1e
7.
1f [ ] [ ]
7.2a
7.2c
7.2d
7.2e 99.5
72f
[x]
7.3a
7.3c
7.3d
[ 1
7'3e 98.0
7.
3f [ ] [x]
7.4a
7.4c
7.4d
7-4e 90.0
7
4f [ ] [ x ]
7.5a
7.5c
7.5d
[ 1
98.0
75f
7.6a
7.6c
7 6d
7.6e NA
7.6f
7.7a
7.7c
7.7d
7.7e
7 7f
7.8a
7.8c
7.3d
7 8e 100
7 8f [ x ] [ ]
7.9c
7.9d
7.9e NA
7.9f
7.10c
7.10d
[>
100
[ x ] (Check if additional information is provided on Part IV-Supplemental Information )
8. OPTIONAL INFORMATION ON WASTE MINIMIZATION
(Indicate actions taken to reduce the amount of the chemical being released from the facility. See the instructions for coded
items and an explanation of what information to include.)
A. Type of
Modification
(enter code)
B. Quantity of the Chemical in Wastes
Prior to Treatment or Disposal
C, Index
D. Reason for Action
(enter code)
Current
reporting
year (Ibs/yr)
Prior
year
(Ibs/yr)
Or percent
change
121,700 121,800
EPA Form 9350-1 (1-89) Revised - Do not use previous versions.
-------
I—i Page 51 e
(Important: Type or print; read instructions before completing form.)
D
Page 5 of 5
A EPA
EPA FORM R
PART IV. SUPPLEMENTAL INFORMATION
Use this section if you need additional space for answers to questions in Part III.
Number the lines used sequentially from lines in prior sections (e.g., 5.3.4, 6.1.2, 7.11)
(This space for your optional use.)
ADDITIONAL INFORMATION ON RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
(Part III, Section 5.3)
You may report releases of less than
1,000 IDS. by checking ranges under A.1.
(Do not use both A.1 and A.2)
5.3 Discharges to
receiving streams or
water bodies 5.3..
(Enter letter code from Part I
Section 3,10 for stream(s) in c o
the box provided.) O.J.-
5.3..
5.3,.
5.3,.
5.3 a
A. Total Release
(Ibs/yr)
A.1
Reporting Ranges
0 1-499 500-999
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code
in box
provided
bi
5.3.
5.3.
5.3.
C.% From Stormwater
5.3 c
5.3.
5.3.
ADDITIONAL INFORMATION ON TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
(Part III, Section 6)
You may report transfers
of less than 1,000 Ibs. by checking
ranges under A.1. (Do not use
both A.1 and A.2)
Discharge to POTW
_ , (enter location number
o. 1. from Part II, Section 1.)
Other off-site location
e •) (enter location number
•*" from Part II, Section 2.)
A.Total Transfers
(Ibs/yr)
A.1
Reporting Ranges
0 1-499 500-999
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code
in box
provided)
C. Type of Treatment/
Disposal
(enter code
in box
provided)
6.1.
6.2.
Other off-site location
6 2 (enter location number
from Part II. Section 2.)
6.2.
6.2.
Other off-site location
(enter location number •>
- from Part II, Section 2.)
6.2.
ADDITIONAL INFORMATION ON WASTE TREATMENT METHODS AND EFFICIENCY (Part III, Section 7)
A. General
Wastestream
(enter code
in box provided)
B. Treatment
Method
(enter code
in box provided)
C.Range of
Influent
Concentration
(enter code)
D. Sequential
Treatment?
(check if
applicable)
E. Treatment
Efficiency
Estimate
F. Based on
Operating
Data?
Yes No
7.
7.
]
7.
7.
-
-------
Page 52
APPENDIX B
HOW TO DETERMINE LATITUDE AND LONGITUDE FROM TOPOGRAPHIC MAPS
Latitude is the distance north or south o1 the equator. Longi-
tude is the distance east or west of the prime meridian
(Greenwich, England). Latitude and longitude are measured
in seconds, minutes, and degrees.
60" (seconds) = 1' (minute)
60' (minutes) s 1° (degree)
To determine the latitude and longitude of your facility you will
need the following:
Q Topographic map from United States Geological
Survey (USGS)
Q Ruler graduated in decimal units (cm or inches)
Q Pencil
Q Small calculator (optional).
How to Obtain USGS Maps
USGS maps used for determining latitude and longitude may
be obtained from the USGS distribution center. These maps
are available in both the 7.5 minute and 15 minute series. For
maps of the United States, including Alaska, Hawaii, American
Samoa, Guam, Puerto Rico, and the U.S. Virgin Islands, con-
tact:
Branch of Distribution
U.S. Geological Survey
Box 25286 Federal Center
Denver, CO 80225
If you are not sure on which map your site is located, consult
an index to topographic maps for your state, which USGS will
provide free of charge. USGS maps cost about $3.00 and are
often available in local libraries and at commercial dealers
such as surveyors or outdoor recreation equipment dealers.
The index for your state lists these alternative sources for
obtaining maps. If you need help in determining your facility's
latitude and longitude, the National Cartographic Information
Center located in Denvercan provide assistance. The Center
can be contacted at (303) 236-5829.
Determining Your Facility's Latitude and Longitude
(See diagram next page.)
Once you have obtained the correct map for your facility,
follow these steps:
1. Mark the location of your facility on the map with a point.
If your facility is large, choose a point central to the pro-
duction 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 quadrangle (a four-sided figure) around
the point with fine pencil lines connecting the nearest 21 /
2' or 5' graticules. Graticules are intersections of latitude
and longitude lines that are marked on the map edge, and
appear as black crosses at four points in the interior of the
map.
3. Read and record the latitude and longitude for the south-
east corner of the small quadrangle drawn in step two.
The latitude and longitude are printed at the edges of the
map.
4. To determine the increment of latitude above the latitude
line recorded in step 3,
- position the map so that you face its west edge;
- place the ruler in approximately a north-south align-
ment, with the "0" on the latitude line recorded in step
3 and the edge intersecting the point.
Without moving the ruler, read and record:
- the measurement from the latitude line to the desired
point (the point distance);
- the measurement from the latitude line to the north line
of the small quadrangle (the total distance).
Determine the number of seconds to be added to the
latitude recorded in step 3 by using the ratio:
Point distance
Total distance
between lines
x 150" = increment of latitude
[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.]
-------
Page 53
For example:
Point distance =
Total distance =
99.5 X150'
192.0
99.5
192.0
77.7" = OV17.7"
(60" =1'; 77.7"- 60"
01-17.7")
Latitude in step 3
Increment
Latitude of point
32°17'30"
+ 01'17.7"
32°18'47.7"
to the nearest second
32°18'48"
5 .To determine the increment of longitude west of the lon-
gitude line recorded in step 3,
- position the map so that you face its south edge;
- place the ruler in approximately an east-west align-
ment with the "0" on the longitude line recorded in step
3 and the edge intersecting the point.
Without moving the ruler, read and record:
- the measurement from the longitude line to the de-
sired point (the point distance);
- the measurement from the longitude line to the west
line of the small quadrangle (the total distance).
Determine the number of seconds to be added to the
longitude recorded in step 3 by using the ratio:
x 150" = increment of longitude
Point distance
Total distance
between lines
For example:
Point distance = 65.0
Total distance = 149.9
65.0 x 150" = 66.4" = 01'06.4"
149.9
(60" = V; 66.4" - 60" = 01'06.4")
78°05'00"
Longitude in step 4
Increment
Longitude of point
01'06.4"
78°06'06.4"
to the nearest second = 78°06'06"
Latitude/Longitude Diagram
QUADRANGLE]
W
GRATICULE
I
t I
.pi L. 32«17'30- +
78'OS'OO-
32'22'30-
I 2 1/2-
32°17'30" LATITUDE
78'07130" 78°05'00" 78'02'30" 78°00'00"
LONGITUDE
Point: Latitude 32° 18'48" North
Longitude 78° 06'06" West
Note: This diagram is based on a USGS 7.5 Minute Series Topographic Map.
Not drawn to scale.
-------
Page 54
APPENDIX C
WORKSHEET FOR PERFORMING THRESHOLD DETERMINATIONS
1. Identify all chemicals used on-site. This survey will include
all chemicals purchased, produced, present as impuri-
ties/by-products, intermediate chemicals, and chemicals
produced during waste treatment. Sources of information
on chemicals used are:
Q Purchasing department, which should have a list of all
items the facility has purchased; and
Q Process engineers, production supervisors, mainte-
nance supervisors, and plant managers, who can iden-
tify the purchased items that are actually chemicals and
other chemicals used which may not enter the plant as
purchased items, such as by-products, impurities, in-
termediates, or chemicals formed as part of a waste
treatment process.
2. Determine what the chemical is used for from the person-
nel in the operation actually using the chemical. If the
chemical is used for routine janitorial services, operation
or maintenance or transportation equipment, or is used in
the laboratory under the supervision of qualified person-
nel ft should be excluded from threshold determinations.
3. Fill in columns A, B, and C of Table I for all chemicals or
mixtures containing section 313 chemicals identified in
Step I and not excluded from Step 2. For purchased
chemicals, the material safety data sheet (MSDS) may
have a list of all components which are section 313
chemicals. For chemicals or mixtures generated on-site,
the process personnel may be able to provide composi-
tions. Several points to remember:
Q Check MSDSs for impurities which may also be section
313 chemicals;
Q The section 313 chemical list is not the same as toxic
chemical lists developed by OSHA or other agencies;
Q For chemicals which are only reportable if they are in
solution form, only the weight of the chemical is used in
threshold determination, not the weight of the solution;
Q For compounds containing metals, the weight of the
compound is used, not the weight of the parent metal;
and
Q Do not perform threshold determinations or report
chemicals which are not on the section 313 list.
For pure components, columns A and B may be identical.
For mixtures, there may be multiple entries in column B if
the mixture contains more than one section 313 chemical.
4. Determine the amount of the chemical or mixture used by
filling the appropriate columns in Table 2 based on the
data you have available and what data you believe to be
the most accurate. If a chemical/mixture has multiple
uses (e.g., it is produced and otherwise used), do sepa-
rate estimates for the different uses and make two entries
for this chemical/mixture in Table 1.
If a basis other than purchases/inventories or production
rate is used, attach calculations showing how the use was
derived to Table 2.
5. Calculate values for column E for each specific chemical
compound or category present in the mixture. For pure
compounds, columns D and E will have the same value.
6. Determine the type of use and mark the appropriate
column (i.e., M = manufacture, P = processed, O =
otherwise used).
7. Complete Table 3. Take values from column E for each
specific chemical and sum them. Do separate calcula-
tions for chemicals with different uses.
8. From Table 3 identify all chemicals which exceed the ap-
plicable threshold. Points to remember:
Q For chemicals with multiple uses, if you exceed any
threshold then the chemicals must be reported.
Q For metals, use the mass of the metal compound.
Q For solutions, use the weight of the chemical, not the
solution.
Q If a specific chemical belongs in a chemical category,
other chemicals in that category should be included as
part of the general category.
9. As a final reminder, did you:
Q Check with all plant personnel who may purchase or
use chemicals?
Q Review MSDSs for all purchased chemicals?
Q Check MSDSs of commercial grade chemicals to deter-
mine if any impurities/by-products are present?
Q Check to determine if a particular chemical has multiple
uses?
Q Identify all chemicals produced by your process, either
-------
Page 55
intentionally (products or intermediates) or uninten-
tionally?
Q Retain all notes, calculations, and other materials nec-
essary to support use estimates?
-------
Page 56
TABLE 1. THRESHOLD DETERMINATION CALCULATIONS
Q) O
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-------
Page 57
TABLE 2. USE CALCULATIONS
in
a
CO
<5
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oun
sed
U.
X
UJ
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1 2
-------
Page 58
TABLE 3. SUMMARY OF AMOUNTS OF CHEMICALS USED
Amount •
Section 313 Used Type of Use
Chemical (1b) (M, P, O)
Sum of all values in Column E of Table 1 for this chemical or chemical category for each type of use.
RETAIN THIS TABLE AS DOCUMENTATION OF FORM R REPORTS - DO NOT SUBMIT WITH FORM R
-------
Page 59
APPENDIX D
REPORTING CODES FOR EPA FORM R
Part III, Section 4- Maximum Amount of the Chemical On-
Slte at Any Time During the Calendar Year
Weight Range in Pounds
Range Code From...
01
02
03
04
05
06
07
08
09
10
11
0
100
1,000
10,000
100,000
1,000,000
10,000,000
50,000,000
100,000,000
500,000,000
1 billion
99
999
9,999
99,999
999,999
9,999,999
49,999,999
99,999,999
499,999,999
999,999,999
more than 1 billion
M61 Wastewater Treatment (Excluding POTW)
M69 Other Treatment
M71 Underground Injection
M72 Landfill/Disposal Surface Impoundment
M73 Land Treatment
M79 Other Land Disposal
M90 Other Off-Site Management
M91 Transfer to Waste Broker
M99 Unknown
Part III, Section 7 • Waste Treatment Methods and Efficiency
General Waste Stream
A = Gaseous (gases, vapors, airborne particulates)
W = Wastewater (aqueous waste)
L = Liquid waste (non-aqueous waste)
S = Solid waste (including sludges and slurries)
Part III, Section 5 - Releases of the Chemical to the
Environment On-Slte and Section 6 • Transfers of the
Chemical In Waste to Off-Site Locations
M -Estimate is based on monitoring data or measurements for
the toxic chemical as released to the environment and/or off-
site facility.
C -Estimate is based on mass balance calculations, such as
calculation of the amount of the toxic chemical in streams
entering and leaving 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 engineer-
ing 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 characterized by monitoring data.
Part III, Section 6 • Transfers of the Chemical in Waste to
Off-Site Locations
Type of Treatment/Disposal
M10 Storage Only
M40 Solidification/Stabilization
M50 Incineration/Thermal Treatment
Part III, Section 7 - Waste Treatment Methods and
Efficiency
Air Emissions Treatment
A01 Flare
A02 Condenser
A03 Scrubber
A04 Absorber
A05 Electrostatic Precipitator
A06 Mechanical Separation
A07 Other Air Emission Treatment
BiQlogical Treatment
B11 Biological Treatment - Aerobic
B21 Biological Treatment - Anaerobic
B31 Biological Treatment - Facultative
B99 Biological Treatment - Other
Chemical Treatrnent
C01 Chemical Precipitation -- Lime or Sodium
Hydroxide
C02 Chemical Precipitation -- Sulfide
C09 Chemical Precipitation -- Other
C11 Neutralization
C21 Chromium Reduction
C31 Complexed Metals Treatment (other than pH
Adjustment)
C41 Cyanide Oxidation -- Alkaline Chlorination
C42 Cyanide Oxidation - Electrochemical
-------
Page 60
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
F11 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
P11 Settling/Clarification
P12 Filtration
P13 Sludge Dewatering (non-thermal)
P14 Air Flotation
P15 Oil Skimming
P16 Emulsion Breaking -- Thermal
P17 Emulsion Breaking -- Chemical
P18 Emulsion Breaking -- Other
P19 Other Liquid Phase Separation
P21 Adsorption -- Carbon
P22 Adsorption -- Ion Exchange (other than for
recovery/reuse)
P23 Adsorption -- Resin
P29 Adsorption - Other
P31 Reverse Osmosis (other than for recovery/reuse)
P41 Stripping - Air
P42 Stripping -- Steam
P49 Stripping - Other
P51 Acid Leaching (other than for recovery/reuse)
P61 Solvent Extraction (other than recovery/reuse)
P99 Other Physical Treatment
Recovery/Reuse
R01 Reuse as Fuel - Industrial Kiln
R02 Reuse as Fuel - Industrial Furnace
R03 Reuse as Fuel -- Boiler
R04 Reuse as Fuel - Fuel Blending
R09 Reuse as Fuel - Other
R11 Solvents/Organics Recovery - Batch Still
Distillation
R12 Solvents/Organics Recovery -- Thin-Film
Evaporation
R13 Solvents/Organics Recover/ -- 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
R29 Metals Recovery -- Other
R99 Other Reuse or Recovery
Solidification/Stabilization
G01 Cement Processes (including Silicates)
G09 Other Pozzolonic Processes (including Silicates)
G11 Asphaltic Processes
G21 Thermoplastic Techniques
G99 Other Solidification Processes
Part III, Section 7 - Waste Treatment Methods and
Efficiency
Range of Influent Concentration
1 = Greater than 1 percent
2 = 100 parts per million (0.01 percent) to 1 percent
(10,000 parts per million)
3 = 1 part per million to 100 parts per million
4 = 1 part per billion to 1 part per million
5 = Less than 1 part per billion
[Notp: 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 chemi-
cal/kilogram of airfor 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.)
Part III, Section 8 - Optional Information on Waste
Minimization
Type of Modification
M1 - Recycling/Reuse On-Site
M2 - Recycling/Reuse Off-Site
M3 - Equipment/Technology Modifications
-------
Page 61
M4 - Process Procedure Modifications
M5 - Reformulation/Redesign of Product
M6 - Substitution of Raw Materials
M7 - Improved Housekeeping, Training, Inventory Control
M8 - Other Waste Minimization Technique
Reason for Action
R1 - Regulatory Requirement for the Waste
R2 - Reduction of Treatment/Disposal Costs
R3 - Other Process Cost Reduction
R4 - Self-Initiated Review
R5 - Other (e.g., discontinuation of product, occupational
safety, etc.)
-------
Page 62
APPENDIX E
STATE DESIGNATED SECTION 313 CONTACTS
(Note: Use the appropriate address for submission of Form R
reports to your State.]
Alabama
Mr. E. John Williford, Chief of Operations
Alabama Emergency Response Commission
Alabama Department of Environmental Management
Field Operations Division
1751 Congressman W.G. Dickinson Drive
Montgomery, AL 36109
(205)271-7700
Alaska
Ms. Amy Kyle, Chairman
Alaska Emergency Response Commission
Department of Environmental Conservation
P.O. Box 0
Juneau.AK 99811
(907) 465-2600
American Samoa
Mr. Pati Faiai, Director
American Samoa EPA
Office of the Governor
Pago Pago, AS 96799
International Number (684) 633-2682
Arizona
Mr. Carl F. Funk, Executive Director
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, A2 85008
(602) 244-0504
Arkansas
Ms. Becky Bryant
Depository of Documents
Arkansas Department of Labor
10421 West Markham
Little Rock, AR 72205
(501)682-4534
California
Mr. Charles M. Shulock
Office of Environmental Affairs
P.O. Box2815
Sacramento, CA 95812
Attn: Section 313 Reports
(916)324-8124
(916) 322-7236 (Completed Form R information)
Colorado
Colorado Emergency Planning Commission
Colorado Department of Health
Division of Hazardous Materials and Waste Management
4210 East 11th Avenue
Denver, CO 80220
Ms. Pam Hariey (303) 331 -4858
Mr. Richard Bardsley (303) 273-1789
Commonwealth of the Northern Marianas Islands
Mr. Russell Meecham, III
Division of Environmental Quality
P.O. Box1304
Saipan, MP 96950
(670) 234-6984
Connecticut
Ms. Sue Vaughn
State Emergency Response Commission
Department of Environmental Protection
Room 161
165 Capitol Avenue
Hartford, CT 06106
(203) 566-4856
Delaware
Mr. Phillip G. Retallick
Division of Air and Waste Management
Department of Natural Resources and Environmental
Control
Richardson and Robbins Building
89 Kings Highway
Dover, DE 19901
(302) 736-4764
District of Columbia
Ms. Pamela Thurber
Environmental Planning Specialist
Office of Emergency Preparedness
2000 14th Street, NW, 8th Floor
Washington. DC 20009
(202)727-6161
Florida
Mr. Thomas G. Pelham, Chairman
Florida Emergency Response Commission
Secretary, Florida Department of Community Affairs
2740 Centerview Drive
Tallahassee, FL 32399-2149
(904)487-1472
(in Florida 800-635-7179)
-------
Page 63
Georgia
Mr. Jimmy Kirkland
Georgia Department of Natural Resources
205 Butler Street, S.E.
Floyd Tower East
Atlanta, GA 30334
(404) 656-6905
Guam
Mr. Charles P. Crisostomo
Guam EPA
P.O. Box 2999
Agana, GU 96910
(671)646-8863
Hawaii
Dr. John C. Lewin, M.D., Director
Hawaii State Department of Health
P.O. Box 3378
Honolulu, HI 96801-9904
(808) 548-6505
Idaho
Ms. Jennie Records, Program Coordinator
Idaho Emergency Response Commission
State House
Boise. ID 83720
(208) 334-5898
Illinois
Mr. Joe F. Goodner, P.E.
Emergency Planning Unit
Illinois EPA
P.O. Box 19276
2200 Churchill Road
Springfield, IL 62794-9276
(217)782-3637
Indiana
Mr. Philip Powers, Director
Indiana Department of Environmental Management
Emergency Response Branch
5500 West Bradbury Avenue
Indianapolis, IN 46241
(317)243-5176
(317) 243-5147 (General information only)
Iowa
Mr. Jim Taylor
Iowa Emergency Response Commission
301 East 7th Street
DesMoines, IA 50319
(515)281-6175
Kansas
Right-to-Know Program
Kansas Department of Health and Environment
Building 740, Forbes Field
Topeka, KS 66620-7430
(913)296-1690
Kentucky
Ms. Valerie Hudson
Kentucky Department of Environmental Protection
18ReillyRoad
Frankfort, KY 40601
(502)564-2150
Louisiana
Mr. R. Bruce Hammatt
Emergency Response Coordinator
Department of Environmental Quality
P.O. Box 44091
Baton Rouge, LA 70804-4091
(504) 342-6363
Maine
Mr. David Brown, Director
State Emergency Response Commission
State House Station 72
State Office Building
Augusta, ME 04333
(207) 289-4080
(In Maine 800-452-8735)
Maryland
Ms. Masha Ways
Toxics Information Center
SARA Title III
c/o Maryland Department of the Environment
O'Conor State Office Building
2500 Broening Highway
Baltimore, MD 21224
(301)631-3800
Massachusetts
Mr. Arnold Sapenter
c/o Title III Emergency Response Commission
Department of Environmental Quality Engineering
One Winter Street, 10th Floor
Boston, MA 02108
(617)292-5810
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Page 64
Michigan
Mr. David Warner, Director
Michigan Department of Natural Resources
Environmental Response Division
Title III Notification
P.O. Box 30028
Lansing, Ml 48909
(517)373-8481
Minnesota
Mr. Lee Tischler, Director
Minnesota Emergency Response Commission
Division of Emergency Management
Room B5
State Capitol
St. Paul, MN 55155
(612)296-2233
Mississippi
Mr. J.E. Manor, Chairman
Mississippi Emergency Response Commission
Director, Mississippi Emergency Management Agency
P.O. Box 4501
Fondren Station
Jackson, Ml 39296-4501
(601)960-9973
Missouri
Mr. Dean Martin, Coordinator
Missouri Emergency Response Commission
Missouri Department of Natural Resources
P.O. Box 3133
Jefferson City, MO 65102
(314)751-7929
Montana
Mr. Tom Ellerhoff, Co-Chairman
Montana Emergency Response Commission
Environmental Sciences Division
Department of Health and Environmental Sciences
Cogswell Building A-107
Helena, MT 59620
(406) 444-3948
Nebraska
Mr. Craig Bagstad
Technical Services Section
Nebraska Department of Environmental Control
P.O. Box 98922
State House Station
Lincoln, NE 68509-8922
(402)471-4230
Nevada
Mr. Bob King, Director
Division of Emergency Management
2525 South Carson
Carson City, NV 89710
(702) 885-4240
New Hampshire
Mr. Richard H. Strome, Director
State Emergency Management Agency
State Office Park South
107 Pleasant Street
Concord, NH 03301
(603)271-2231
New Jersey
Richard A. Dime
Department of Environmental Protection
Division of Environmental Quality
CN-405
Bureau of Hazardous Waste Information
SARA Title III Project
401 East State Street
Trenton, NJ 08625
(609)292-6714
New Mexico
Mr. Sam Larcombe
New Mexico Emergency Response Commission
New Mexico Department of Public Safety
P.O. Box 1628
Santa Fe, NM 87504-1628
(505) 827-9222
New York
New York Department of Environmental Conservation
Bureau of Spill Response
SARA Title III Section 313
50 Wolf Road
Albany, NY 12233
(518)457-4107
North Carolina
Mr. Vance E. Kee
North Carolina Division of Emergency Management
116 West Jones Street
Raleigh, NC 27603-1335
(919) 733-3867
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Page 65
North Dakota
Mr. Dean Monteith, Coordinator
North Dakota Emergency Response Commission
North Dakota State Department of Health and Consolidated
Laboratories
1200 Missouri Avenue
P.O. Box 5520
Bismarck, ND 58502-5520
(701)224-2374
Ohio
Ms. Cindy Sferra-DeWulf
Division of Air Pollution Control
1800 Watermark Drive
Columbus, OH 43215
(614)644-2270
Oklahoma
Mr. Jack W. Muse, Coordinator
Emergency Response Commission
Office of Civil Defense
P.O. Box 53365
Oklahoma City, OK 73152
(405)521-2481
Oregon
Oregon Emergency Response Commission
c/o Oregon State Fire Marshall
3000 Market Street Plaza
Suite 534
Salem, OR 97310
(503) 378-2885
Pennsylvania
Mr. James Tinney
Bureau of Right-to-Know
Room 1503
Labor and Industry Bldg.
Harrisburg, PA 17120
(717)783-8150
Puerto Rico
SERC Commissioner
Title III-SARASection 313
Puerto Rico Environmental Quality Board
P.O. Box11488
Santurce, PR 00910
(809) 722-0077
Rhode Island
Department of Environmental Management
Division of Air and Hazardous Materials
291 Promenade Street
Providence, Rl 02908-5767
Attn: Toxic Release Inventory
(401)277-2808
South Carolina
Mr. Ron Kinney
Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 734-5200
South Dakota
Mr. Brad Schultz
South Dakota Emergency Response Commission
Department of Water and Natural Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501-3181
(605)773-3153
Tennessee
Mr. Lacy Suiter, Chairman
Tennessee Emergency Response Commission
Director, Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204-1502
1-800-262-3300 (In Tennessee)
1-800-258-3300 (Out of state)
Texas
Mr. David Barker, Supervisor
Emergency Response Unit
Texas Water Commission
P.O. Box 13087 - Capitol Station
Austin, TX 78711-3087
(512)463-8527
Utah
Mr. Neil Taylor
Utah Hazardous Chemical Emergency Response
Commission
Utah Division of Environmental Health
288 North 1460 West
P.O.Box 16690
Salt Lake City, UT 84116-0690
(801)538-6121
Vermont
Dr. Jan Carney, Deputy Commissioner
Department of Health
60 Main Street
P.O. Box 70
Burlington, VT 05402
(802) 863-7281
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Page 66
Virginia
Mr. Wayne Halbleib, Director
Virginia Emergency Response Council
Department of Waste Management
James Monroe Building
18th Floor
101 North 14th Street
Richmond, VA 23219
(804)225-2513
Virgin Islands
Mr. Allan D. Smith, Commissioner
Department of Planning and Natural Resources
U.S. Virgin Islands Emergency Response Commission
Title III
179 Altona and Welgunst
Charlotte Amalie
St. Thomas, VI 00802
(809) 774-3320
Washington
Washington Emergency Response Commission
Department of Community Development
Mail Stop GH-51
9th & Columbia Building
Olympia, WA 98504
(800) 633-7585
West Virginia
Mr. William Pinnell
Office of Environmental Health Services
West Virginia Department of Health
1800 East Washington Street East
Room 507
Charleston, WV 25305
(304) 348-2967
Wisconsin
Wisconsin Department of Natural Resources
Office of Technical Services TS-2
P.O. Box 7921
Madison, Wl 53707
(608) 266-9255
Attn: Russ Dunst
[Note§: (1) If an Indian tribe has chosen to act independently
of a state for the purpose of section 313 reporting, facilities
located within that Indian community should report to the tribal
SERC, or until the SERC is established, the Chief Executive
Officer of the Indian tribe, as well as to EPA; (2) Facilities
located within the Territories of the Pacific should send a report
to the Chief Administrator of the appropriate territory, as well
as to EPA.]
Wyoming
Mr. Ed Usui, Coordinator
Wyoming Emergency Response Commission
Wyoming Emergency Management Agency
Comprehensive Emergency Management
5500 Bishop Blvd.
Cheyenne, WY 82003
(307) 777-7566
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Page 67
APPENDIX F
SECTION 313 EPA REGIONAL CONTACTS
Region 1
Pesticides & Toxics Branch
USEPA Region 1 (APT2311)
JFK Federal Building
Boston, MA 02203
(617)565-3273
Connecticut, Massachusetts, Maine, New Hampshire, Rhode
Island, Vermont
Region 2
Pesticides & Toxics Branch
USEPA Region 2 (MS240)
Woodbridge Avenue, Building 209
Edison, NJ 08837
(201)906-6890
New Jersey, New York, Puerto Rico, Virgin Islands
Region 3
Toxics & Pesticides Branch
USEPA Region 3 (3HW42)
841 Chestnut Street
Philadelphia, PA 19107
(215)597-1260
Delaware, Maryland, Pennsylvania, Virginia, West Virginia,
District of Columbia
Region 4
Pesticides & Toxics Substances Branch
USEPA Region 4
345 Courtland Street
Atlanta, GA 30365
(404) 347-5053
Alabama, Florida, Georgia, Kentucky, Mississippi, North
Carolina, South Carolina, Tennessee
Region 5
Pesticides & Toxic Substances Branch
USEPA Region 5 (5SPT-7)
536 South Dearborn Street
Chicago, IL 60604
(312)353-5867
Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin
Region 6
Pesticides & Toxic Substances Branch
USEPA Region 6 (6TPT)
1445 Ross Avenue
Dallas, TX 75202-2733
(214)655-7244
Arkansas, Louisiana, New Mexico, Oklahoma, Texas
Region 7
Office of Congressional and Intergovernmental Liaison
USEPA Region 7 (CIGL)
726 Minnesota Avenue
Kansas City, KS 66101
(913)236-2806
Iowa, Kansas, Missouri, Nebraska
Region 8
Toxic Substances Branch
USEPA Region 8 (8AT-TS)
999 18th Street
Denver, CO 80202-2405
(303) 293-1 730
Colorado, Montana, North Dakota, South Dakota, Utah,
Wyoming
Region 9
Pesticides & Toxics Branch
USEPA Region 9 (T-5-3)
215 Fremont Street
San Francisco, CA 94105
(415)974-7054
Arizona, California, Hawaii, Nevada, American Samoa, Guam,
Commonwealth of the Northern Mariana Islands
Region 10
Pesticides & Toxic Substances Branch
USEPA Region 10 (AT083)
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-1091
Alaska, Idaho, Oregon, Washington
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Page 68
APPENDIX G
SECTION 313 FINAL RULE
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Federal Register / Vol. S3. No. 30 / Tuesday. February- IB. 1988 / Rules and Regulations 4525
[fslpte: Subparts D and E of the
regulatory text are not reproduced
here because they appear in
substance elsewhere in this
document.]
PART 372-TOXIC CHEMICAL
RELEASE REPORTING; COMMUNITY
RIGHT-TO-KNOW
Subpart A—General Provisions
Sec.
372.1 Scope and purpose.
372.3 Definitions.
372J Penont *ubject io thi* Part
372.10 Recordlteeping.
372.18 Compliance and enforcement.
Subpart 8—Reporting Requirements
372.22 Covered facilities for toxic chemical
release reporting.
372.25 Threshold* for reporting.
372-30 Reporting requirements and schedule
fur reporting.
372.38 Exemption*.
Subpart C—Suppfter Motlflcatton
Requirement*
372.45 Notification about toxic chemicals.
Subpart D—Specific Toxic Chemical
Usttngs
372.05 Chemical* and chemical categories to
* hich this Part applies.
Subpart E—f orrns and Instructions
372.85 Toxic chemical release reporting
form and instruction*.
Authority: 42 U.S.C 11013.11028.
Subpart A—General Provision*
{372.1 Scope and purpose.
This Part sets forth requirements for
the submission of information relating to
the release of toxic chemicals under
section 313 of Title III of the Superfund
Amendments and Reauthorizatioo Act
of 1986. The information collected under
this Part is intended to inform the
general public and the communities
surrounding covered facilities about
releases of toxic chemicals, to assist
research, to aid in the development of
regulations, guidelines, and standards,
and for other purposes. This Part also
sets forth requirements for suppliers to
notify persons to whom they distribute
mixtures or trade name products
containing toxic chemicals that they
contain such chemicals.
§372.3 Definitions.
Terms defined in sections 313(b)(l)(c)
and 329 of Title III and not explicitly
defined herein are used with the
meaning given in Title III. For the
purpose of this Part:
"Acts" means Title IIL
"Article" means a manufactured item:
(1) Which is formed to a specific shape
or design during manufacture: (2) which
has end use functions dependent in
whole or in part upon its shape or design
during end use: and (3) which does not
release a toxic chemical under normal
conditions of processing or use of that
item at the facility or establishments.
"Customs territory of the United
States" means the 50 States, the District
of Columbia, and Puerto Rico.
"EPA" means the United States
Environmental Protection Agency.
"Establishment" means an economic
unit, generally at a single physical
location, where business is conducted or
where services or industrial operations
are performed.
"Facility" means 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 (or by any person
which controls, is controlled by. or
under common control with such
person). A facility may contain more
than one establishment
"Full-time employee" means 2.000
hours per year of full-time equivalent
employment A facility would calculate
the number of full-time employees by
totaling the hours worked during the
calendar year by all employees,
including contract employees, and
dividing that total by 2.000 hours.
"Import" means to cause a chemical
to be imported into the customs territory
of the United States. For purposes of this
definition, "to cause" means to intend
that the chemical be imported and to
control the identity of the imported
chemical and the amount to be
imported.
"Manufacture" means to produce,
prepare, import or compound a toxic
chemical Manufacture also applies to a
toxic chemical that is produced
coincidentally during the manufacture,
processing, use. or disposal of another
chemical or mixture of chemicals,
including a toxic chemical that is
separated from that other chemical or
mixture of chemicals as a byproduct
and a toxic caemicai that remains in
that other chemical or mixture of
chemicals as an impurity.
"Mixture" means any combination of
two or more chemicals, if the
combination is not. in whole or in part.
the result of a chemical reaction.
However, if the combination was
produced by a chemical reaction but
could have been produced without a
chemical reaction, it is also treated as a
mixture. A mixture also includes any
combination which consists of a
chemical and associated impurities.
"Otherwise use" or "use" means any
use of a toxic chemical that is not
covered by the terms "manufacture" or
"process" and includes use of a toxic
chemical contained in a mixture or trade
name product. Relabeling or
redistributing a container of a toxic
chemical where no repackaging of the
toxic chemical occurs does not
constitute use or processing of the toxic
chemical.
"Process" means the preparation of a
toxic chemical, after its manufacture, for
distribution in commerce:
(1) In the same form or physical state
as. or in a different form or physical
state from, that in which it was received
by the person so preparing such
substance, or
(2) As part of an article containing the
toxic chemical. Process also applies to
the processing of a toxic chemical
contained in a mixture or trade name
product
"Release" means any spilling, leaking.
pumping, pouring, emitting, emptying,
discharging, injecting, escaping.
leaching, dumping, or disposing into the
environment (including the
abandonment or discarding of barrels,
containers, and other closed
receptacles) of any toxic chemical.
"Senior management official" means
an official with management
responsibility for the person or persons
completing the report or the manager of
environmental programs for the facility
or establishments, or for the corporation
owning or operating the facility or
establishments responsible for certifying
similar reports under other
environmental regulatory requirements.
Title (IT means Title III of the
Superfund Amendments and
Reauthorizao'on Act of 1986, also titled
the Emergency Planning and Community
Right-To-Know Act of 1988.
'Toxic chemical" means a chemical or
chemical category listed in i 372.65.
'Trade name product" means a
chemical or mixture of chemicals that is
distributed to other persons and that
incorporates a toxic chemical
component that is not identified by the
applicable chemical name or Chemical
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4528 Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1986 / Rules and Regulations
Abstracts Service Registry number
listed in S 372.65.
§372.5 Persons subject to IMs Part
Owners and operators of facilities
described in § J 372.22 and 372.45 are
subject to the requirements of this Part.
If the owner and operator of a facility
are different persons, only one need
report under 5 372.17 or provide a notice
under S 372.45 for each toxic chemical in
a mixture or trade name product
distr.buted from the facility. However, if
no report is submitted or notice
provided. EPA will hold both the owner
and the operator liable under section
325(c) of Title HI. except as provided in
§J372.38(e)and372.45{g).
§37110 Recordkeepins.
(a) Each person subject to the
reporting requirements of this Part must
retain the following records for a penod
of 3 years from the date of the
submission of a report under } 372.30:
(1) A copy of each report submitted by
the person under 5 372.30.
(2) All supporting materials and
documentation used by the person to
make the compliance determination that
the facility or establishments ia a
covered facility under } 372.22 or
§ 372.45.
(3) Documentation supporting the
report submitted under $ 372.30
including:
(i) Documentation supporting any
determination that a claimed allowable
exemption under { 372.38 applies.
(il) Data supporting the determination
of whether a threshold under S 372.25
applies for each toxic chemical.
(iii) Documentation supporting the
calculations of the quantity of each toxic
chemical released to the environment or
transferred to an off-site location.
(iv) Documentation supporting the use
indications and quantity on site
reporting for each toxic chemical.
including dates of manufacturing,
processing, or use.
(v ] Documentation supporting the
basis of estimate used in developing any
i elease or off-site transfer estimates for
each toxic chemical.
(vi) Receipts or manifests associated
with the transfer of each toxic chemical
in waste to off-site locations.
(vii) Documentation supporting
reported waste treatment methods.
estimates of treatment efficiencies.
ranges of influent concentration to such
treatment, the sequential nature of
treatment steps, if applicable, and the
actual operating data, if applicable, to
support the waste treatment efficiency
estimate for each toxic chemical.
(b) Each person subject to the
notification requirements of this part
must retain the following records for a
period of 3 years from the date of the
submission of a notification under
$ 372,45.
(1) All supporting materials and
documentation used by the person to
determine whether a notice is required
under $ 372.45.
(2) All supporting materials and
documentation used in developing each
required notice under 5 372.45 and a
copy of each notice.
(c) Records retained under this section
must be maintained at the facility to
which the report applies or from which a
notification was provided. Such records
must be readily available for purposes
of inspection by EPA.
§ 372.1S Compliance and enforcement
Violators of the requirements of this
Part shall be liable for a civil penalty in
an amount not to exceed $25.000 each
day for each violation as provided in
section 325(c) of Title III.
Subpart B—Reporting Requirements}
$ 372.22 Covered facilities for toxic
chemical release reporting.
A facility that meets all of the
following criteria for a calendar year is
a covered facility for that calendar year
and must report under { 372.30.
(a) The facility has 10 or more full-
time employees.
(b) The facility is in Standard
Industrial Classification Codes 20
through 39 (as in effect on January 1,
1987) by virtue of the fact that it meets
one of the following criteria:
(1) The facility is an establishment
with a primary SIC code of 20 through
39.
(2) The facility is a multi-
establishment complex where all
establishments have a primary SIC code
of 20 through 39.
(3) The facility is a multi-
establishment complex in which one of
the following is true:
(i) The sum of the value of products
shipped and/or produced from those
establishments that have a primary SIC
code of 20 through 39 is greater than 50
percent of the total value of all products
shipped and/or produced from ail
establishments at the facility.
(ii) One establishment having a
primary SIC code of 20 through 39
contributes more in terms of value of
products shipped and/or produced than
any other establishment within the
facility.
(c) The facility manufactured
(including imported), processed, or
otherwise used a toxic chemical hi
excess of an applicable threshold
quantity of that chemical sot forth in
$ 372.25.
} 372.25 Thresholds for reporting.
The threshold amounts for purposes of
reporting under 5 372.30 for toxic
chemicals are as follows:
(a) With respect to a toxic chemical
manufactured (including imported) or
processed at a facility during the
following calendar years:
1987—75.000 pounds of the chemical
manufactured or processed for the year.
1988—50.000 pounds of the chemical
manufactured or processed for the year.
1989 and thereafter—25.000 pounds of
the chemical manufactured or processed
for the year.
(b) With respect to a chemical
otherwise used at a facility, 10.000
pounds of the chemical used for the
applicable calendar year.
(c) With respect !o activities involving
a toxic chemical at a facility, when more
than one threshold applies to the
activities, the owner or operator of the
facility must report if it exceeds any
applicable threshold and must report on
all activities at the facility involving the
chemical, except as provided in f 372.38.
(d) When a facility manufactures.
processes, or otherwise uses more than
one member of a chemical category
listed in { 372,65(c), the owner or
operator of the facility must report if it
exceeds any applicable threshold for the
total volume of all the members of the
category involved in the applicable
activity. Any such report must cover all
activities at the facility involving
members of the category.
(e) A facility may process or
otherwise use a toxic chemical in a
recycle/reuse operation. To determine
whether the facility has processed or
used more than an applicable threshold
of the chemical, the owner or operator of
the facility shall count the amount of the
chemical added to the recycle/reuse
operation during the calendar year. In
particular, if the facility starts up such
an operation during a calendar year, or
in the event that the contents of the
whole recycle/reuse operation are
replaced in a calendar year, the owner
or operator of the facility shall also
count the amount of the chemical placed
into the system at these times.
(f) A toxic chemical may be listed in
$ 372.65 with the notation that only
persons who manufacture the chemical.
or manufacture it by a certain method.
are required to report. In that case, only
owners or operators of facilities that
manufacture that chemical as described
in i 372.65 in excess of the threshold
applicable to such manufacture in
i 372^5 are required to report. In
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Federal Register / Vol. 53. No. 30 f Tuesday. February 16. 1908 / Rules and Regulations
4527
completing the reporting form, the owner
or operator is only required to account
for the quantity of the chemical so
manufactured and releases associated
with such manufacturing, but not
releases associated with subsequent
processing or use of the chemical at that
facility. Owners and operators of
facilities that solely process or use such
a chemical are not required to report for
that chemical.
(g) A toxic chemical may be listed in
f 372.65 with the notation that it is in a
specific form (e.g.. fume or dust.
solution, or friable) or of a specific color
(e.g.. yellow or white). In that case, only
owners or operators of facilities that
manufacture, process, or use that
chemical in the form or of the color.
specified in § 372.95 in excess of the
threshold applicable to such activity in
? 372.25 are required to report. In
completing the reporting form, the owner
or operator is only required to account
for the quantity of the chemical
manufactured, processed, or used in the
form or color specified in § 372.85 and
for releases associated with the
chemical in that form or color. Owners
or operators of facilities that solely
manufacture, process, or use such a
chemical in a form or color other than
those specified by f 372.63 are not
required to report for that chemical.
(h) Metal compound categories are
listed in { 372-65(c). For purposes of
determining whether any of the
thresholds specified in i 372.25 are met
fur metal compound category, the owner
or operator of a facility must make the
threshold determination based on the
total amount of all members of the metal
compound category manufactured.
processed, or used at the facility. In
completing the release portion of the
reporting form for releases of the metal
compounds, the owner or operator is
only required to account for the weight
of the parent metal released. Any
contribution to the mass of the release
attributable to other portions of each
compound in the category ia excluded.
$372.30 Reporting requirement* and
schedule tor tootling.
(a) For each toxic chemical known by
the owner or operator to be
manufactured (including imported).
processed, or otherwise used in excess
of an applicable threshold quantity in
§ 372.25 at its covered facility described
in 5 372.22 for a calendar year, the
owner or operator must submit to EPA
and to the State in which the facility is
located a completed EPA Form R (EPA
Form 935O-1) in accordance with the
instructions in Subpart E.
(b)(l) The owner or operator of a
covered facility is required to report at
described in paragraph (a] of this
section on a toxic chemical that the
owner or operator knows is present as a
component of a mixture or trade name
product which the owner or operator
receives from another person, if that
chemical is imported, processed, or
otherwise used by the owner or operator
in excess of an applicable threshold
quantity in § 372.25 at the facility as part
of that mixture or trade name product.
(2) The owner or operator knows that
a toxic chemical is present as a
component of a mixture or trade name
product (i) if the owner or operator
knows or has been told the chemical
identity or Chemical Abstracts Sen-ice
Registry Number of the chemical and the
identity or Number corresponds to an
identity or Number in ! 372.65, or (
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4528 Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations
trade name product, but has been told
the upper bound concentration of the
chemical in the mixture or trade name
product, the owner or operator shall
assume that the toxic chemical is
present in the mixture or trade name
product at the upper bound
concentration, shall determine whether
the chemical has been imported,
processed, or otherwise used at the
facility in excess of an applicable
threshold as provided in paragraph
(b)(3}(iv) of this section, and shall report
as provided in paragraph (b)(3)(iv) of
this section.
(vi) If the owner or operator has been
told that a mixture or trade name
product contains a toxic chemical, docs
not know the specific chemical identity
of the chemical, does not know the
specific concentration at which the
chemical is present in the mixture or
trade name product, including
information they have themselves
developed, and has not been told the
upper bound concentration of the
chemical in the mixture or trade name
product the owner or operator is not
required to report with respect to that
toxic chemical.
(c) A covered facility may consist of
more than one establishment. The
owner or operator of such a facility at
which a toxic chemical was
manufactured (including imported),
processed, or otherwise used in excess
of an applicable threshold may submit a
separate Form R for each establishment
or for each group of establishments
within the facility to report the activities
involving the toxic chemical at each
establishment or group of
establishments, provided that activities
involving that toxic chemical at all the
establishments within the covered
facility are reported. If each
establishment or group of
establishments files separate reports
then for all other chemicals subject to
reporting at that facility they must also
submit separate reports, However, an
establishment or group of
establishments does not have to submit
a report for a chemical that is not
manufactured (including imported),
processed, otherwise used, or released
at that establishment or group of
establishments.
(d) Each report under this section for
activities involving • toxic chemical that
occured during a calendar year at a
covered facility must be submitted on or
before July 1 of the next year. The first
such report for calendar year 1987
activities must be submitted on of before
July 1.1968.
(e) For reports applicable to activities
For calendar years 1987,1988, and 1989
only, the owner or operator of a covered
facility may report releases of a specific
toxic chemical to an environmental
medium, or transfers of wastes
containing a specific toxic chemical to
un off-site location, of less than 1.000
pounds using the ranges provided in the
form and instructions in Subpart E. For
reports applicable to activities in
calendar year 1990 and beyond, theje
ranges may not be used.
Exemption*.
(a) De minimis concentrations of a
toxic chemical in a mixture, if a toxic
chemical is present in a mixture of
chemicals at a covered facility and the
toxic chemical is in a concentration in
the mixture which is below i percent of
the mixture, or 0.1 percent of the mixture
in the case of a toxic chemical which is
a carcinogen as defined in 29 CFR
1910.1200(d)(4). a person is not required
to consider the quantity of the toxic
chemical present in such mixture when
determining whether an applicable
threshold has been met under 1 372.25 or
determining the amount of release to be
reported under 1 372.30. This exemption
applies whether the person received the
mixture from another person or the
person produced the mixture, either by
mixing the chemicals involved or by
causing a chemical reaction which
resulted in the creation of the toxic
chemical in the mixture. However, this
exemption applies only to the quantity
of the toxic chemical present in the
mixture. If the toxic chemical is also
manufactured (including imported),
processed, or otherwise used at the
covered facility other than as part of the
mixture or in a mixture at higher
concentrations, in excess of an
applicable threshold quantity set forth in
i 372.25, the person is required to report
under 1 372JO.
(b) Articles. If a toxic chemical is
present in an article at a covered
facility, a person is not required to
consider the quantity of the toxic
chemical present in such article when
determining whether an applicable
threshold has been met under i 372.25 or
determining the amount of release to be
reported under | 372.30. This exemption
applies whether the person received the
article from another person or the
person produced the article. However,
this exemption applies only to the
quantity of the toxic chemical present in
the article. If the toxic 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 set forth in { 372^5,
the person is required to report under
i 372.30. Persons potentially subject to
this exemption should carefully review
the definitions of "article" and "release"
in i 372.3. If a release of a toxic
chemical occurs as a result of the
processing or use of an item at the
facility, that item does not meet the
definition of "article."
(c) Uses. If a toxic chemical is used at
a covered facility for a purpose
described in this paragraph (c), a person
is not required to consider the quantity
of the toxic chemical used for such
purpose when determining whether an
applicable threshold has been met under
} 372.25 or determining the amount of
releases to be reported under { 372.30.
However, this exemption only applies to
the quantity of the toxic chemical used
for the purpose described in this
paragraph (c). If the toxic chemical is
also manufactured (including imported),
processed, or otherwise used at the
covered facility other than as described
in this paragraph (c). in excess of an
applicable threshold quantity set forth in
§ 372.25, the person is required to report
under | 372.30.
(1) Use as a structural component of
the facility.
(2) Use of products for routine
janitorial or facility grounds
maintenance. Examples include use of
janitorial cleaning supplies, fertilizers,
and pesticides similar in type or
concentration to consumer products.
(3) Personal use by employees or
other persons at the facility of foods,
drugs, cosmetics, or other personal items
containing toxic chemicals, including
supplies of such products within the
facility such as in a facility operated
cafeteria, store, or infirmary.
(4) Use of products containing toxic
chemicals for the purpose of maintaining
motor vehicles operated by the facility.
(5) Use of toxic chemicals present in
process water and non-contact cooling
water as drawn from the environment or
from municipal sources, or toxic
chemicals present in air used either as
compressed air or as part of combustion.
(d) Activities in laboratories. If a toxic
chemical is manufactured, processed, or
used in a laboratory at a covered facility
under the supervision of • technically
qualified individual as defined in
S 720.3(ee) of this title, a person is not
required to consider the quantity so
manufactured, processed, or used when
determining whether an applicable
threshold has been met under | 372.25 or
determining the amount of release to be
reported under i 372.30. This exemption
does not apply in the following cases:
(1) Specialty chemical production.
(2) Manufacture, processing, or use of
toxic chemicals in pilot plant scale
operations.
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Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations 4529
(3) Activities conducted outside the
laboratory.
(e) Certain owners of leased property.
The owner of a covered facility is not
subject to reporting under { 372.30 if
such owner's only interest in the facility
is ownership of the real estate upon
which the facility is operated. This
exemption applies to owners of facilities
such as industrial parks, all or part of
which are leased to persons who
operate establishments within SIC code
20 through 39 where the owner has no
other business interest in the operation
of the covered facility.
(f) Reporting by certain operators of
establishments on leased property such
as industrial parks. If two or more
persons, who do not have any common
corporate or business interest (including
common ownership or control), operate
separate establishments within a single
facility, each such person shall treat the
establishments it operates as a facility
for purposes of this Part. The
determinations in { 372.22 and { 372.25
shall be made for those establishments.
If any such operator determines that its
establishment is a covered facility under
S 372.22 and that a toxic chemical has
been manufactured (including imported),
processed, or otherwise used at the
establishment in excess of an applicable
threshold in } 372.25 for a calendar year,
the operator shall submit a report in
accordance with f 372.30 for the
establishment. For purposes of this
paragraph (f), a common corporate or
business interest includes ownership.
partnership, joint ventures, ownership of
a controlling interest in one person by
the other, or ownership of a controlling
interest in both persons by a third
person.
Subpart C—Supplier Nottflcajtton
f 372.45 Notification about toxto
(a) Except as provided in paragraphs
(c), (d). and (e) of this section and
t 372.65, a person who owns or operates
a facility or establishment which;
(1) Is in Standard Industrial
Classification codes 20 through 39 as set
forth in paragraph (b) of I 372^2.
(2) Manufactures (including imports)
or processes a toxic chemical and
(3) Sells or otherwise distributes •
mixture or trade name product
containing the toxic chemical to (i) t
facility described in | 372.22. or (ii) to •
person who in turn may sell or
otherwise distributes such mixture or
trade name product to • facility
described in f 372.22(b). must notify
each person to whom the mixture or
trade name product is sold or otherwise
distributed from the facility or
establishment in accordance with
paragraph (b) of this section.
(b) The notification required in
paragraph (a) of this section shall be in
writing and shall include:
(1) A statement that the mixture or
trade name product contains a toxic
chemical or chemicals subject to the
reporting requirements of section 313 of
Title III of the Superfund Amendments
and Reauthorization Act of 1986 and 40
CFR Part 372.
(2) The name of each toxic chemical,
and the associated Chemical Abstracts
Service registry number of each
chemical if applicable, as set forth in
} 372.65.
(3) The percent by weight of each
toxic chemical in the mixture or trade
name product
(c) Notification under this section
shall be provided as follows:
(1) For a mixture or trade name
product containing a toxic chemical
listed in \ 373.65 with an effective date
of January 1,1987, the person shall
provide the written notice described in
paragraph (b) of this section to each
recipient of the mixture or trade name
product with at least the first shipment
of each mixture or trade name product
to each recipient in each calendar year
beginning January 1.1989.
(2) For a mixture or trade name
product containing a toxic chemical
listed in \ 372.65 with an effective date
of January 1,1989 or later, the person
shall provide the written notice
described in paragraph (b) of this
section to each recipient of the mixture
or trade name product with at least the
first shipment of the mixture or trade
name product to each recipient in each
calendar year beginning with the
applicable effective date.
(3) If t person changes a mixture or
trade name product for which
notification was previously provided
under paragraph (b) of this section by
adding • toxic chemical removing •
toxic chemical, or changing the percent
by weight of a toxic chemical in the
mixture or trade name product the
person shall provide each recipient of
the changed mixture or trade name
product a revised notification reflecting
the change with the first shipment of the
changed mixture or trade name product
to the recipient
(4) If • person discovert (i) that •
mixture or trade name product
previosuly sold or otherwise distributed
to another person during the calendar
year of the discovery contains ona or
more toxic chemicals and (ii), that any
notification providied to such other
persons in that calendar year for the
mixture or trade name product either did
not properly identify any of the toxic
chemicals or did not accurately present
the percent by weight of any of the toxic
chemicals in the mixture or trade name
product the person shall provide a new
notification to the recipient within 30
days of the discovery which contains
the information described in paragraph
(b) of this section and identifies the prior
shipments of the mixture or product in
that calendar year to which the new
notification applies.
(5) If a Material Safety Data Sheet
(MSDS) is required to be prepared and
distributed for the mixture or trade
name product in accordance with 29
CFR 1910.1200. the notification must be
attached to or otherwise incorporated
into such MSDS. When the notification
is attached to the MSDS. the notice must
contain clear instructions that the
notifications must not be detached from
the MSDS and that any copying and
redistribution of the MSDS shall include
copying and redistribution of the notice
attached to copies of the MSDS
subsequently redistributed.
(d) Notifications are not required in
the following instances:
(1) If a mixture or trade name product
contains no toxic chemical in excess of
the applicable de minimi § concentration
as specified in | 372.38(a).
(2) If a mixture or trade name product
is one of the following:
(i) An "article" as defined in i 372.3
(ii) Foods, drugs, cosmetics, alcoholic
beverages, tobacco, or tobacco products
packaged for distribution to the general
public.
(iii) Any consumer product as the term
is defined in the Consumer Product
Safety Act (15 U.S.C 1251 et seq.)
packaged for distribution to the general
public.
(e) If the person considers the specific
identity of a toxic chemical in a mixture
or trade name product to be a trade
secret under provisions of 29 CFR
1910.1200. the notice shall contain a
generic chemical name that is
descriptive of that toxic chemical.
(f) If the person considers the specific
percent by weight composition of a toxic
chemical in the mixture or trade name
product to be a trade secret under
applicable State law or under the
Restatement of Torts section 757,
comment b, the notice must contain a
statement that the chemical is present at
a concentration that does not exceed a
specified upper bound concentration
value. For example, a mixture contains
12 percent of a toxic chemical. However,
the supplier considers the specific
concentration of the toxic chemical in
-------
4536 Fedaral Register / Vol. S3. No. 30 / Tuesday. Fcbroary 16. 1988 / Kulea and Regulations
the product to be • tnde secret. The
notice would indicate that th« toxic
chemical ia present in the mixture in a
concentration of no mot* than IS
percent by weight. The upper bound
value chosen must be no larger than
necessary to adequately protect the
trade secret
(g) A person rs not subject to the
requirements of this section to the
extent the person does not know that
the facility or establishment(s) is selling
or otherwise distributing a toxic
chemical to another person in a mixture
or trade name product. However, for
purposes of this section, a person has
such knowledge if the person receives a
notice under this section from a supplier
of a mixture or trade name product and
the person in turn aella or otherwise
distributes that mixture or trade name
product to another person.
(h) If two or more persona, who do not
have any common corporate or business
interest (including common ownership
or control), as described in f 372.38(f),
operate separate establishments within
a single facility, each such persons shall
treat the establishment^) it opera1 -s as
a facility for purposes of this section.
The determination under paragraph (a)
of this section shall be made for those
establishments.
-------
Page 75
INDEX
Article.7,8,17,18, 20, 48, 49
Auxiliary Facility, 45
Byproduct, 5, 6,16, 17
CAS Number, 15. 47, 48
Chemical Categories, 6, 8,15,19. 20, 21, 36,43,47,48, 54,
58
Chemical Compounds, 48, 54
Codes, 2,3, 5,8,12,13,14,16.19,21,22,25, 26,27,29,30,
47,49,50,51,59
Contacts (State), 62
De Minimis Limitation, 6, 8, 9, 36
Dun and Bradstreet Number, 13,14, 51
Employees (number required), 2, 3
EPA Identification Number, 13, 15, 51
Establishment, 3, 5, 13
Exemption, 5, 6, 7, 8
Facility, 1, 2-24, 26, 28, 47-52, 54, 59
Formulation Component, 16
Fugitive Air Emissions, 19, 20, 49
Full-Time Employee, 2, 3
General Information, 1,16
Generic Chemical Name, 1,15,16
Import, 2, 6, 9, 16
Impurity. 5, 6, 8, 16, 17
Laboratory.5, 34, 35, 54
Latitude and Longitude, 13, 52, 53
Manufacture, 1,2,5,6,7,8,9,12,13,16,17,29,47,48,54,
56
Mixtures, 6. 8, 9, 15, 16, 17. 19, 20, 21, 25, 32, 54, 56, 57
Multi-Establishment Facility, 3, 5
NPDES Permit Number, 13, 14
Off-Site Location, 1, 7, 14, 15, 17, 19, 20, 21, 25, 28, 29, 47,
49,50.51,59.60
Otherwise Use, 1, 2, 5, 6, 7. 8. 9, 12. 13, 16, 17. 54, 56
Parent Company, 14, 15
Process, 1-9,12,13,15-20,22,26,27,28,29,30,34,35,38,
40, 46, 47, 48, 49, 50, 54, 56, 59, 60, 61
Publicly-Owned Treatment Works (POTWs), 14, 15, 19, 25,
28, 48, 50, 51, 59
Reactant, 6,16, 17,48
Receiving Streams or Water Bodies, 14, 19, 22, 29
Recordkeeping, 1
Release Estimate, 22, 46
Repackaging, 17
Reporting Ranges, 20
Reporting Rule, 68
Reporting Year, 12, 25, 29, 36, 48, 51
Runoff Coefficient, 24
Sate/Distribution, 5, 6.14, 15,16,17. 20
Sanitized, 1,2, 12. 15, 16
Standard Industrial Classification (SIC) Codes, 2, 3, 5, 8,13,
30, 47, 49
Supplier Notification, 5, 8, 38, 40, 41, 46
Threshold, 2-11, 13, 16, 17,21,47,48,49,54,56
Trade Name Products, 8, 9, 20
Trade Secret Claims.1. 9,12.15, 16, 46, 51
Transfers, 15, 19, 20, 21, 25, 50, 59
Treatment Efficiency, 25, 27, 28, 46, 51
Treatment Method, 25, 26, 28, 59, 60
Underground Injection, 14, 20, 25, 50, 59
Unsanitized, 12,15,16
Voluntary Revision, 2,12
Waste Minimization, 15, 28, 29, 51, 60, 61
Waste Stream, 20, 22, 25, 26, 27, 28. 59
Waste Treatment, 5, 6, 8, 15,16, 25, 46, 50, 54, 59, 60
Worksheet, 7, 54
-------
D
(Important: Type or print; read instructions before completing form.)
Form Approved OMB No.: 2070-0093
Approval Expires:.
01/91
Page 1 of 5
A EPA
U.S. Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
Section 313 of the Emergency Planning and Community Rlght-to-Know Act of 1986,
also known as Title III of the Superfund Amendments and Reauthorteatlon Act
EPA FORM
PART I.
FACILITY
IDENTIFICATION
INFORMATION
(This space for your optional use.)
Public reporting burden for this
collection of information is estimated to
vary from 30 to 34 hours per response,
with an average of 32 hours per
response, including time for reviewing
instructions, searching existing data
sources, gathering and maintaining the
data needed, and completing and
reviewing the collection of information.
Send comments regarding this burden
estimate or any other aspect of this
collection of information, including
suggestions for reducing this burden, to
Chief, Information Policy Branch
(PM-223), US EPA, 401 M St., SW,
Washington, D.C. 20460 Attn: TRI
Burden and to the Office of Information
and Regulatory Affairs, Office of
Management and Budget Paperwork
Reduction Project (2070-0093),
Washington, D.C. 20603.
1.
1.1 Are you claiming the chemical identity on page 3 trade secret?
I J Yes (Answer question 1.2; I J No (Do not answer 1.2;
Attach substantiation forms.) Go to question 1.3.)
1.2 If "Yes" in 1.1, is this copy:
|_ J Sanitized [ J Unsanitized
1.3 Reporting Year
19
2. CERTIFICATION (Read and sign after completing all sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true and
complete and that the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers of this report.
Name and official title of owner/operator or senior management official
Signature
Date signed
3. FACILITY IDENTIFICATION
3.1
Facility or Establishment Name
Street Address
City
State
County
Zip Code
WHERE TO SEND COMPLETED FORMS:
1. U.S. ENVIRONMENTAL PROTECTION AGENCY
P.O. BOX 70266
WASHINGTON, DC 20024-0266
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE (See instructions
Appendix E)
3.2
This report contains information for (Check one):
a. I J An entire facility b. [ J Part of a facility.
3.3
Technical Contact
Telephone Number (include area code)
3.4
Public Contact
Telephone Number (include area code)
3.5
SIC Code (4 digit)
a.
Latitude
Longitude
3.6
Degrees
Minutes
Seconds
Degrees
Minutes
Seconds
3.7
Dun & Bradstreet Number(s)
3.8
EPA Identification Number(s) (RCRAI.D. No.)
3.9
NPDES Permit Number(s)
Receiving Streams or Water Bodies (enter one name per box)
a.
3.10
3.11
Underground Injection Well Code (UIC) Identification Number(s)
4. PARENT COMPANY INFORMATION
4.1
4.2
Name of Parent Company
Parent Company's Dun & Bradstreet Number
EPA Form 9350-1 (1-89) Revised—Do not use previous versions.
-------
D
(Important: Type or print; read instructions before completing form.)
Page 2 of 5
R(This space for your optional use.)
t? tKA PART II. OFF-SITE LOCATIONS TO WHICH TOXIC
CHEMICALS ARE TRANSFERRED IN WASTES
1. PUBLICLY OWNED TREATMENT WORKS (POTWs)
1.1 POTW name
Street Address
City
State
County
Zip
1.2 POTW name
Street Address
City County
State Zip
2. OTHER OFF-SITE LOCATIONS (DO NOT REPORT LOCATIONS TO WHICH WASTES ARE SENT ONLY FOR RECYCLING OR REUSE).
2.1 Off-site location name
EPA Identification Number (RCRA ID. No.)
Street Address
City
State
County
Zip
Is location under control of reporting facility or parent company?
[ ]YBS [ ]NO
2.2 Off-site location name
EPA Identification Number (RCRA ID. No.)
Street Address
City County
State Zip
Is location under control of reporting facility or parent company?
[ jYes I JNO
2.3 Off-site location name
2.4 Off-site location name
EPA Identification Number (RCRA ID. No.)
EPA Identification Number (RCRA ID. No.)
Street Address
Street Address
City
County
City
County
State
Zip
State
Zip
Is location under control of reporting facility or parent company?
NO
Is location under control of reporting facility or parent company?
I ]ves [ ]
No
2.5 Off-site location name
2.6 Off-site location name
EPA Identification Number (RCRA ID. No.)
EPA Identification Number (RCRA ID. No.)
Street Address
Street Address
City
County
City
County
State
Zip
State
Zip
Is location under control of reporting facility or parent company?
[ Ives [ ]
Is location under control of reporting facility or parent company?
[ ]
Yes
I No
I Check if additional pages of Part II are attached. How many?
EPA Form 9350-1 (1-89) Revised—Do not use previous versions.
-------
D
(Important: Type or print; read instructions before completing form.)
D
Page 3 of 5
* EPA
EPA FORM R
PART III. CHEMICAL-SPECIFIC INFORMATION
(This space for your optional use.)
1. CHEMICAL IDENTITY(Do not complete this section if you complete Section 2.)
1.1
[Reserved]
1.2
CAS Number (Enter the number exactly as it appears on the 313 list. Enter NA if reporting a chemical category.)
1.3
Chemical Or Chemical Category Name (Enter the name exactly as it appears on the 313 list.)
1.4
Generic Chemical Name (Complete only if Part I, Section 1.1 is checked "Yes." Generic name must be structurally descriptive.)
MIXTURE COMPONENT IDENTITY (Do not complete this section if you complete Section 1.)
2.
Generic Chemical Name Provided by Supplier (Limit the name to a maximum of 70 characters (e.g., numbers, letters, spaces, punctuation).)
3. ACTIVITIES AND USES OF THE CHEMICAL AT THE FACILITY (Check all that apply.)
3.1
Manufacture the
chemical:
a.
I J Produce
b. [ ] Import
If produce or import:
[ 1 For on-site
c.L J use/processing
e.[ J As a byproduct
[ 1 For sale/
d-l J distribution
f. [ J As an impurity
3.2
Process the
chemical:
a. [ J As a reactant
d. [ J Repackaging only
b.
[1 As a formulation
•I component
f 1 As an article
2-L J component
3.3
Otherwise use
the chemical:
a. I
1 As a chemical
J processing aid
,[ 1
As a manufacturing aid
I Ancillary or other use
4. MAXIMUM AMOUNT OF THE CHEMICAL ON-SITE AT ANY TIME DURING THE CALENDAR YEAR
5. RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
You may report releases of less than
1,000 Ibs. by checking ranges under A.1.
(Do not use both A.1 and A.2)
5.1 Fugitive or non-point air emissions
5.2 Stack or point air emissions
5.3 Discharges to receiving . . .
strAame nr watar hnriiAe O.J.I
streams or water bodies
(Enter letter code from Part I
Section 3.10 for stream(s) in 5
the box provided.)
.3.2 n
5.3.3
5.4 Underground injection
5.5 Releases to land
5.5.1 On-site landfill
5.5.2 Land treatment/application farming
5.5.3 Surface Impoundment
5.5,4 Other disposal
5.1a
5.2a
5.3.1a
5.3.2a
5.3.3a
5.4a
5.5.1a
5.5.2a
5.5.3a
5.5.4a
A. Total Release
(Ibs/yr)
A.1
Reporting Ranges
1-499 500-999
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code)
5.1b
5.2b
5.3.1b
5.3.2b
5.3.3b
5.4b
5.5.1b
5.5.2b
5.5.3b
5.5.4b
(Check if additional Information is provided on Part IV-Supplemental Information.)
C. % From Stormwater
5.3.1c
EPA Form 9350-1(1-89) Revised—Do not use previous versions.
-------
D
(Important: Type or print; read instructions before completing form.)
Page 4 of 5
EDA EPA FORMK
PART III. CHEMICAL-SPECIFIC INFORMATION
(continued)
(This space for your optional use.)
6. TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
You may report transfers
of less than 1,000 Ibs. by checking
ranges under A.1. (Do not use
both A.1 and A.2)
Discharge to POTW . .
(enter location number «
' | 10 I I-
6.1.1 from Part II, Section
Other off-site location
c. n * (enter location number
6.2.1 from Part II, Section 2.)
Other off-site location
_ „ „ (enter location number I 2
6.2.2 from Part II, Section 2.) I
A. Total Transfers
(Ibs/yr)
A.1
Reporting Ranges
0 1-499 500-999
] [ ] [ 3
A.2
Enter
Estimate
B. Basis of Estimate
(enter code)
C.Type of Treatment/
Disposal
(enter code
6.2.1b
6.2.2b
Other off-site location .
(enter location number 5
6.2.3 from Part II, Section 2.) | *
6.2.3b
D
[ ] (Check if additional information is provided on Part IV-Supplemental Information.)
7. WASTE TREATMENT METHODS AND EFFICIENCY
A. General
Wastestream
(enter code)
B. Treatment
Method
(enter code)
C. Range of
Influent
Concentration
(enter code)
D. Sequential
Treatment?
(check if
applicable)
E. Treatment
Efficiency
Estimate
F. Based on
Operating
Data?
Yes No
7.1a
7.1b
7.1c
7.1d
7.1e
7.1f
7.2a
7.2b
7.2c
7.2d
7.2e
7.2f
[ ] [ I
7.3a
7.3b
7.3c
7.3d
[ J
7.3e
7 3f [ 1 [ ]
7.4a
7.4b
7.4c
7.4d
7.4e
7.4f
7.5a [
7.5b
7.5c
7.5d
7.5e
7.5f
7.6a
n
7.6b
7.6c
7.6d
7.6e
7.6f
7.7a
7.7b
7.7c
7.7d
7.7e
7.
7f [ ] [ ]
7.8a
7.8b
7.8c
7.8d
7.8e
7.8f
7.9a
7.9b
7.9c
7.9d
7.9e
7.9f
7.10a
D
7.10b
7.10c
7.10d
7.10e
% 7.10f
[ ] (Check if additional information is provided on Part IV-Supplemental Information.)
8. OPTIONAL INFORMATION ON WASTE MINIMIZATION
(Indicate actions taken to reduce the amount of the chemical being released from the facility. See the instructions for coded
items and an explanation of what information to Include.)
A. Type of
Modification
(enter code)
B. Quantity of the Chemical in Wastes
Prior to Treatment or Disposal
C. Index
D. Reason for Action
(enter code)
Current
reporting
year (Ibs/yr)
Prior
year
(Ibs/yr)
, Or percent
. change
EPA Form 9350-1(1-89) Revised - Do not use previous versions.
-------
D
n
(Important: Type or print; read instructions before completing form.)
Page 5 of 5
S EPA
PART IV.
EPA FORM R
SUPPLEMENTAL INFORMATION
Use this section if you need additional space for answers to questions in Part III.
Number the lines used sequentially from lines in prior sections (e.g., 5.3.4, 6.1.2, 7.11)
(This space for your optional use.
ADDITIONAL INFORMATION ON RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
(Part III, Section 5.3)
You may report releases of less than
1,000 Ibs. by checking ranges under A.1.
(Do not use both A.1 and A.2)
5.3 Discharges to
receiving streams or
water bodies 5.3
(Enter letter code from Part I
Section 3,10 for stream(s) in c o
the box provided.) °-°
5.3..
5.3..
5.3..
5.3..
A. Total Release
(Ibs/yr)
A.1
Reporting Ranges
0 1-499 500-999
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code
in box
provided
5.3..
5.3.
5.3.
C.% From Stormwater
5.3 c
5.3.
5.3.
ADDITIONAL INFORMATION ON TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
(Part III, Section 6)
You may report transfers
of less than 1,000 Ibs. by checking
ranges under A.1. (Do not use
both A.1 and A.2)
Discharge to POTW
„ .. [enter location number .
0.1 . from Part II, Section 1.) '
6.2.
Other off-site location
(enter location number
- from Part II, Section 2.)
A.Total Transfers
(Ibs/yr)
A.1
Reporting Ranges
0 1-499 500-999
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code
in box
provided)
C. Type of Treatment/
Disposal
(enter code
in box
provided)
6.1.
6.2.
Other off-site location
6.2. (enter location number
——- from Part II, Section 2.)
6.2. b
Other off-site location
(enter location number
from Part II, Section 2.)
6.2.
ADDITIONAL INFORMATION ON WASTE TREATMENT METHODS AND EFFICIENCY (Part III, Section 7)
A. General
Wastestream
(enter code
in box provided)
B. Treatment
Method
(enter code
In box provided)
C. Range of
Influent
Concentration
(enter code)
D. Sequential
Treatment?
(check if
applicable)
E. Treatment
Efficiency
Estimate
F. Based on
Operating
Data?
Yes No
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EPA Form 9350-1 (1-89) Revised—Do not use previous versions.
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United States
Environmental Protection
Agency
Office of Toxic
Substances
Washington, D.C. 20460
January 1989
EPA 560/4-89-002
&ER& Toxic Chemical Release Inventory
Questions and Answers
Section 313
of the Emergency Planning and
Community Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthorization Act of 1986)
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INTRODUCTION
This Questions and Answers document has been prepared to help clarify
reporting requirements under section 313 of the Emergency Planning and
Community Right-to-Know Act (Title III of the Superfund Amendments and
Reauthorization Act of 1986, Public Law 99-499). Under section 313,
facilities that meet all three of the following criteria are required to
report releases to the air, water, and land of any specifically listed toxic
chemicals:
• The facility has 10 or more full-time employees;
• The facility is included in Standard Industrial Classification (SIC)
Codes 20 through 39; and
• The facility manufactured (defined to include imported), processed,
or otherwise used in the course of a calendar year any specified
chemical in quantities greater than a set threshold.
Reports under section 313 (EPA Form R) must be submitted annually to EPA and
designated State agencies. Reports are due by July 1 and cover activities at
the facility during the previous calendar year.
This document has been developed to expedite facility reporting and to
provide additional explanation of the reporting requirements. It supplements
the instructions for completing Form R. Copies of EPA Form R, instructions
for completing the form, and related guidance documents are available from the
Section 313 Document Distribution Center, P.O. Box 12505, Cincinnati, Ohio
45212. (A request form is provided at the end of this document for use in
obtaining copies of these documents.)
The questions and answers in this document are organized in sections as
listed in the table of contents on the following page. An index at the end of
the document lists question numbers by topic.
To remain responsive to section 313 issues that may arise in the future,
this Questions and Answers document will be updated periodically. If you have
comments or possible additions to this document, please send them to the
Emergency Planning and Community Right-to-Know Information Hotline at the U.S.
Environmental Protection Agency, WH-562A, 401 M Street, S.W., Washington, D.C.
20460, (800) 535-0202 (or (202) 479-2449, Washington, D.C. and Alaska).
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TABLE OF CONTENTS
Page
I. Determining Whether or Not to Report: Facility 1
A. Types of Facilities That Must Report 1
B. Employee Threshold 3
C. Persons Responsible for Reporting 3
D. Multi-Establishment Facilities 5
E. Form R Requirements 6
F. Chemical Activity Threshold Determinations 7
G. Auxiliary Facilities 9
II. Determining Whether or Not to Report: Listed Chemicals. . . 11
A. General Questions 11
B. Chemicals in Solution 13
C. Chemical-Specif ic Questions 14
III. Mixtures 17
IV. Supplier Notification 18
V. Activities and Uses of the Chemical at the Facility 20
VI. Exemptions 25
A. General, Personal Use, and Intake Water and Air 25
B. Facility Maintenance and Structural Components 26
C. Vehicle Maintenance 26
D. Laboratories 27
E. De Minimis 28
F. Articles 29
VII. Releases of the Chemical 32
VIII. Waste Treatment Methods and Efficiency 39
IX. Transfers to Off-Site Locations 41
X. Waste Minimization 43
XI. Trade Secrets 44
XII. Certification and Submission 45
XIII. EPA's Section 313 Program and General Information 48
XIV. Index 49
XV. Additional Materials Available on Section 313 51
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I. DETERMINING WHETHER OR NOT TO REPORT: FACILITY
A. Types of Facilities That Must Report
1. What facilities are subject to section 313 reporting?
Section 313 reporting applies to facilities that meet three criteria: have 10
or more full-time employees; are in the manufacturing sector (in SIC major
groups 20 through 39 inclusive); and exceed any one threshold for
manufacturing (including importing), processing, or otherwise using a toxic
chemical listed in 40 CFR Part 372.65.
2. When a facility has been sold or otherwise changed hands during the year,
who is responsible for making the report?
The last owner/operator of the facility during a reporting year is responsible
for making the report, unless the sales or transfer agreement states that the
seller will assume this reporting responsibility. In either event, the report
will be submitted to cover the full year.
3. Is a facility meeting the criteria described in question one required to
report if they had no releases of the toxic chemicals during the calendar
year?
Yes. The requirements for reporting under section 313 are based only upon the
industrial classification of the facility, number of employees, and what
quantity of a toxic chemical was manufactured, processed, or otherwise used
during the calendar year. The amount of toxic chemical released does not
affect reporting requirements (except in the case of exemptions for articles).
The facility described would report zeros in the release estimate section of
the form.
4. Must an annual report be submitted by July 1, 1989 for facilities which
vere in operation part of 1988 but which were closed on December 31, 1988?
Yes. A facility that operated during any part of a reporting year must report
if it meets the reporting criteria.
5. Is a facility with SIC code 5161 required to report?
If the primary SIC code of a facility falls outside of the range of 20-39,
then the facility is not required to report. A facility with SIC code 5161 is
not required to report.
6. Suppose a facility is comprised of several establishments, some of which
have primary SIC codes within the 20-39 range, and some of which have primary
SIC codes outside that range. How would this facility determine if it needs
to report?
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The facility must report if those establishments that are in SIC codes 20-39
have a combined value of more than 50 percent of the total value of products
shipped or produced by the whole facility, or one of those SIC code 20-39
establishments has a value of products shipped or produced that is greater
than any other establishment in the facility.
7. Do pilot plants within the SIC classification have to report?
A pilot plant within the appropriate SIC codes would be a covered facility,
provided it meets the employee and threshold criteria.
8. Must a Treatment, Storage or Disposal Facility (TSDF) report under section
313?
A TSDF may or may not be subject to section 313 reporting, depending on the
activities at the site. The TSDF must determine its primary SIC code based on
the various types of activities that occur at the site.
9. An ancillary wastewater treatment plant has taken on the SIC code of a
covered facility because it primarily services a covered facility. Does the
facility where the treatment plant is located have to report even if the rest
of the establishments at that facility are not in SIC codes 20-39?
No, a facility must report only if it meets employee, SIC code and activity
criteria. The SIC code criteria are not met by the establishments that
represent the major part of the goods and services produced at the facility
containing the wastewater treatment plant. Therefore, the facility as a whole
need not report. The covered facility producing the waste must report the
off-site transfer to the facility containing the wastewater treatment plant.
10. In Alaska, several fish processors have factories on ships. They use
ammonia and chlorine in their fish processing operations. Is each ship a
"facility" covered under section 313 or is the whole group of ships (assume
one company) a covered facility?
A facility is defined as all buildings, equipment, structures, and other
stationary items which are located on a single site or adjacent contiguous
sites owned or operated by the same person. A ship is not a facility as
defined under section 313. It is not stationary and it is not located on a
single site (if it moves to other locations). Therefore the ships should not
report even if they are in SIC Codes 20-39.
11. A barge repair facility (SIC Code 3731 - ship building and repairing)
cleans barges at their facility by vacuuming out residual chemicals and
selling the waste to a chemical recovery company. Must the facility report
for the waste? Is it a processor under section 313? What if the waste is not
sold?
Because the facility sells the waste, it is a processor. The amount of waste
sold does not need to be reported as an off-site transfer because off-site
transfers for recycling/reuse are exempt from reporting. Releases such as
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spills and cleanup of tools must be reported if the facility exceeds the
processing threshold. If the waste is not sold, the facility is not
manufacturing, processing or using the chemical and is not subject to
reporting.
B. Full-Time Employee Threshold
12. Does the full-time employee determination include the hours worked by
sales staff whose office is included in the same building as the production
staff? This sales staff is not connected with the production facility in any
way.
Yes. All employees at a facility, regardless of function or location in a
building, count toward the employee threshold determination.
13. Would a facility with nine full-time employees and four part-time
employees be required to report under section 313?
The total hours worked by all employees should be reviewed. A "full-time
employee" is defined on a full-time equivalent basis of 2000 labor hours per
year. If the total hours worked by all employees at a facility, including
contractors, is 20,000 or more, the criterion for number of employees has been
met.
14. An establishment leases one acre of land adjacent to the reporting
facility from a three-acre strawberry farm. The facility imports and
repackages methyl bromide for sale and distribution. Does the facility have
to include the strawberry pickers when determining whether the 10 full-time
employee equivalent criterion applies?
The reporting facility should not tabulate the hours worked by farm workers it
does not pay. If, however, the reporting facility actually employs or
contracts with these farm workers, then the hours worked on-site by these
workers would count towards the 10 full-time employee equivalent.
C. Persons Responsible for Reporting
15. Is the owner or the operator responsible for reporting?
Either the owner or the operator is subject to the section 313 reporting
requirements. If no report is received from a covered facility, both persons
are liable for penalties. As a practical matter, EPA believes that the
operator is more likely to have the information necessary for reporting.
16. Would an owner of a facility who has no knowledge of any operations at
the facility be responsible for reporting?
An owner with business interest in the facility, beyond owning the real estate
on which the covered facility is located, must report. Neither owners who are
part of the same business organization as the operators, nor owners of
businesses that contract out the operation of a particular site, are exempt
from reporting.
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17. Who is the parent company for a 50/50 joint venture?
The 50/50 joint venture is its own parent company.
18. Company A owns a facility which manufactures crude oil. It sells the
crude oil to Company B, but the oil is kept in tanks on Company A's facility
that are leased to Company B. Who is subject to reporting under section 313?
Since tanks are part of Company A's facility and they are the owner and/or
operator of the facility, Company A would be subject to section 313 reporting
for any releases from the tanks.
19. How would a facility report chemicals in wastes that are treated in waste
treatment units that it does not own? For example, if a facility sold a unit
that is within its contiguous property to another company, which facility
should report?
The facility creating the waste would report the chemicals as an off-site
transfer. The treating facility would not need to report unless they
manufacture, process or otherwise use the same chemical in excess of the
thresholds. In that case, they would report any releases resulting from
wastes as part of their total annual releases of the chemical.
20. Must importers/exporters report for materials stored in public
warehouses?
Owners or operators of covered facilities must report. If importers/exporters
neither own nor operate the warehouse, they would not need to report for that
warehouse.
21. A fish processor rents space in a building. The refrigeration system in
the building uses ammonia. The building owner supplies the ammonia, runs the
refrigeration system, and bills the fish processor based on the amount of fish
processed. Must the fish processor report for ammonia? Another business, a
frozen food packager, also uses the refrigeration system, but is a separate
company from the fish processor.
The owner of the building should report on the ammonia, if the threshold for
ammonia is exceeded, since he is operating the system --he has more than just
a real estate interest in the property. Since the facility (both businesses)
is in SIC 20-39 and he is operating part of that facility, he should report.
22. Mom and Fop Plastics is a wholly owned subsidiary of a major chemical
company which is a wholly owned subsidiary of Big Oil Corp. Which is the
parent company?
Big Oil Corporation is the parent company.
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D. Multi-Establishment Facilities
23. Each establishment of a multi-establishment facility files its own Form R
for a toxic chemical. The waste that this multi-establishment facility ships
off-site is inventoried on an entire facility basis. To report this waste,
does each establishment estimate their percentage of the total waste or can
one establishment report the entire waste?
If individual establishments or groups of establishments report separately for
one chemical, they must continue to report separately for all chemicals.
Therefore, in the case cited above one establishment cannot report the offsite
transport quantity of a chemical in waste from the entire facility. Each
establishment would have to report their percentage of the transfer quantity.
24. Two manufacturing establishments, owned by the same corporation, are
divided by a public railroad. One establishment has rented parking lot space
from the other establishment, and a walkway was constructed so the employees
can go over the railroad tracks to the parking lot. Is this a multi-
establishment facility or two separate facilities?
Two establishments owned by the same corporation separated by a railroad
constitute one facility for section 313, since they are still physically
adjacent to one another' except for a public right-of-way. Therefore,
reporting thresholds would be determined by the combined chemical volumes
processed, manufactured, or used at both establishments.
25. A facility is filing separate reports for section 313 for each
establishment within a facility. How would a transfer of a toxic chemical to
another establishment within the facility be reported? (i.e., transfers waste
to another establishment that then treats and disposes the toxic chemical).
Inter-facility transfer of wastes would not constitute off-site transport and
would not be reported. An establishment need only report releases to the
environment and wastes that are transferred off-site from the facility.
26. Do I have to report if the value of laboratory research at my facility is
greater than 50 percent of the total value of goods and services produced at
my facility?
If the research laboratory is a separate establishment from the manufacturing
activities and its SIC code is not between 20 and 39, then the 50 percent test
is used to determine if the whole facility is in SIC codes 20-39. Some
laboratories may be considered within SIC codes 20-39 because they are
"auxiliary" facilities providing research to support manufacturing operations.
In which case, the whole facility is covered.
27. Is an off-site landfill subject to reporting under section 313 if it a)
is not part of a "covered facility" in that it is not contiguous or adjacent
to the property of the reporting facility, and/or b) does not fall within SIC
Codes 20-39?
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A landfill, as a separate facility, is not subject to reporting because it is
not in SIC Codes 20-39. However, a manufacturing facility, within SIC Codes
20-39 which meets reporting criteria, must list an off-site landfill
(company-owned or not) on the reporting form (Part II of EPA Form R) if they
transfer wastes containing the toxic chemical to that landfill for disposal.
28. For reporting year 1988, if a company has a plant in one state which
processes 27,000 pounds of methanol and a plant in another state which
processes the same amount of methanol, do both plants have to report as
"establishments" of a "facility"?
No. The two processing plants are separate facilities because they are not
located within the same contiguous physical boundary. Thus, their activities
are not additive, and neither would report for methanol in 1988 because the
processing threshold of 50,000 pounds has not been met by either facility.
However, if either facility processes 27,000 pounds of methanol in 1989, it
would have to file a Form R by July 1, 1990.
E. Form R Requirements
29. After contacting Dun & Bradstreet several times to obtain DUNS numbers
for several facilities, a consulting firm was told by D&B that they will give
out the DUNS number only to the individual facilities. Does the consulting
firm have any recourse for obtaining these numbers?
The facility or financial officers may know the number, or may need to call
D&B themselves. Company headquarters DUNS numbers are in Dun and Bradstreet
reference publications, Reference Book of Corporate Management and Million
Dollar Directory, available at some public libraries. Some libraries conduct
computer searches of the DUNS Market Identifiers database for a fee to obtain
individual facility DUNS numbers. DUNS numbers are also available through
online services (e.g., DIALOG). If a facility does not subscribe to the D&B
service, a "support number" can be obtained from the Dun & Bradstreet center
located in Allentown, Pennsylvania (telephone (215) 391-1886).
30. If a facility does not have a Dun & Bradstreet number but the parent
corporation does, should this number be reported?
Report the Dun and Bradstreet Number for the facility. If a facilitjr does not
have a Dun and Bradstreet Number, enter N/A in Part I, Section 3.7. The
corporate Dun and Bradstreet Number should be entered in Part I, Section 4.2
relating to parent company information.
31. If two plants are separate establishments under the same site management,
must they have separate Dun & Bradstreet numbers?
They may have separate Dun & Bradstreet numbers, especially if they are
distinctly separate business units. However, different divisions of a company
located in the same facility usually do not have separate Dun & Bradstreet
numbers.
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32. If you have an NPDES permit, but do not discharge toxic chemicals to
surface water, do you have to fill in Section 3.10?
Yes. This information is part of the facility identification section of Form
R and is intended for use in obtaining other information about the facility.
33, A facility is composed of two separate establishments and is filing two
separate Form R's for section 313 reporting. For Part I, Section 3.5, what
SIC codes are to be listed?
Enter only the SIC codes of the establishments whose data is included in the
report (Part I Section 3.5). SIC codes for the other establishments of the
facility would be included in their own Form R submittal.
34. What is the definition of primary SIC code? How can there be more than
one primary SIC code for a facility?
A primary SIC code generally represents those goods produced or services
performed by an establishment that have the highest value of production or
produce the most revenues for the establishment. The form provides space for
more than one primary SIC code because a facility may be made up of several
establishments, each of which may have a different primary SIC code.
35. Clarify the application of SIC Codes for facility versus establishment?
The SIC code system classifies businesses on the basis of an "establishment",
which is generally a single business unit at one location. Many section 313
covered facilities will be equivalent to an establishment. However, a
reporting facility can encompass several establishments located within a
property boundary, owned/operated by the same "entity." Therefore, a facility
can be a multi-establishment complex.
36. Our facility operations cover a large area. What longitude should be
reported for our facility and how can we locate this information?
Report the latitude and longitude for a location central to the operations for
which you are reporting. You may find this information on your NPDES permit.
See the instructions for completing Form R for a detailed description for
determining longitude and latitude from USGS maps of your facility location.
F. Chemical Activity Threshold Determinations
37. If a facility buys 10,000 pounds of a listed chemical in 1988 and creates
a mixture, for example a metal cleaning bath, and then uses the bath that year
and the next calendar year, how do they determine thresholds for both years?
The threshold applies to the total amount of the chemical otherwise used
during the calendar year. The facility would count the entire 10,000 pounds
and any amount added to the bath during that year toward the otherwise use
threshold the first year. The use of this bath during the second year
constitutes reuse/recycle of the mixture. Therefore, only the amount of the
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chemical added to the bath during the second year (1989) would be counted
toward the use threshold determination for the second year.
38. A facility manufactures "non-article" metal items. If all wastes from
both manufacturing processes are recycled, are the items still subject to
threshold determinations?
If a "non-article" metal item is processed, but all wastes are recycled, the
item is still subject to threshold determinations, the chemicals therein must
be reported if thresholds are met, but releases would be reported as zero.
39. A facility knows only the minimum concentration of a chemical in a
mixture used in their operations. How should they report?
The facility should use the minimum concentration for threshold and release
calculations because this is the best information they have.
40. If you operate a treatment plant as part of remediating a Superfund site
on your facility, do contaminants (already there, not being added to) have to
be included in calculating thresholds? Releases?
Such material is not included in threshold determinations since it is not
being manufactured, processed, or used. Release reporting is required if the
SIC code, employee number and threshold criteria are met for the chemical. In
that event, a release does not include material already in a landfill, but
does include any material released to the environment by remedial activity or
transferred off-site.
41. Must a facility include welding rods, solders, and the metals being
joined during a welding or soldering job in threshold determination?
Yes, however, if no releases occur from the joined metal parts themselves they
may be considered articles and only the welding rods or solder must be
assessed for threshold purposes.
42. A chemical manufacturer (SIC Code 28) receives other facilities' wastes
containing toxic chemicals and disposes of them in their deep well. Does the
receiving facility need to report these toxic chemicals?
The receiving and disposing of toxic chemicals would not be factored into a
threshold determination because it does not fit any definition of process or
otherwise use. However, if the manufacturing facility manufactures, processes
or "otherwise uses" the same toxic chemical above the threshold amount, the
disposal would be reported as a release on Form R even though the amount of
waste was not included in the threshold determination.
43. If a facility uses a recycle or reuse system, how does it determine the
amount that it must consider for threshold determinations?
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For recycle or reuse, the amount considered used for a threshold determination
is the amount added to the system during the year. If the system is
completely empty and is started up during the year, a facility determines the
amount used by adding the total amount needed to charge the system to any
amount which is added to the system during the year.
44. If & facility manufacturers 47,000 pounds, processes 28,000 pounds, and
imports 6,000 pounds of chemical X during 1988, is it required to report for
chemical X?
For 1988, the facility would have to report chemical X because it would have
exceeded the manufacture threshold of 50,000 pounds. Note that importing is
the equivalent of manufacturing and therefore the amounts must be added
together for threshold determinations.
45. Are barge loading/unloading releases exempt?
Such releases must be reported if the barge terminal is part of a covered
facility.
46. Our facility purchases a mixture containing toxic chemicals. We store it
and then sell it to our customers without even opening the boxes. Must we
report on these chemicals?
Report on toxic chemicals that your facility manufactures, processes, or
otherwise uses in excess of the thresholds, but do not report on standing
inventory. Since you are not using the chemicals, you do not have to report.
47. How are warehouses affected by section 313?
A warehouse located within the physical boundary of a "covered facility" is
covered for estimating releases. Warehouse contents are not used in threshold
determinations, because thresholds are based on manufacture, process, or use
(i.e., throughput rather than storage volume). Repackaging at a warehouse is
considered processing and the quantities would have to be factored into
facility process threshold determinations.
G. Auxiliary Facilities
48. Are "auxiliary" facilities associated with manufacturing operations in
SIC codes 20 through 39 exempt from reporting under section 313?
No. An "auxiliary facility" is one that directly supports another
establishment's activities and therefore takes the SIC code of the facility
supported. Auxiliary facilities located on separate property must report if
they meet the employee and chemical thresholds. Auxiliary establishments that
are part of multi-establishment facilities should be included in facility
threshold determinations. For example, a spill from the warehouse would be
included in the covered facility's release quantities.
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49. An airplane engine repair shop (generally SIC 7699) owns an "auxiliary"
facility at a separate location that does metal plating (generally SIC 3471 --
Plating of Metals and Formed Products). Would the plating facility be exempt?
According to the SIC code manual, this plating facility would not be
"auxiliary" but would be considered a separate operating establishment
conducting a manufacturing activity. It would, therefore, need to make the
employee and threshold determinations and report, if appropriate, because it
falls between SIC codes 20-39.
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II. DETERMINING WHETHER TO REPORT: LISTED CHEMICALS
A. General Questions
50. What list of chemicals is subject to reporting under section 313?
The law defined the list of toxic chemicals. The initial list (with certain
technical modifications and revisions) appears in the final rule and in the
instruction booklet for completing EPA Form R.
51. What is the difference between the section 313 list and other Title III
lists?
Some overlaps exist between lists of chemicals covered by different sections
of the law. Section 313 focuses on chemicals that may cause chronic health
and environmental effects. The section 313 list was developed from lists of
regulated chemicals in New Jersey and Maryland. The EPA "List of Lists"
document identifies chemicals that are specifically listed and must be
reported under Sections 304 and 313 of Title III.
52. Can common or trade names other than those listed in the rule be used" for
submissions?
No. EPA has provided a list of standard chemical names and CAS numbers for
all chemicals which must be reported. The rule requires the use of these
standard names. Many 1987 forms could not be processed because unlisted CAS
numbers or names were used.
53. We use a chemical with a CAS number not on the list of section 313 toxic
chemicals. There are similar chemicals on the list, but none with the same
CAS number. How can I be sure I don't have to report?
Only chemicals that are specifically listed or part of a specifically listed
category of chemicals need to be reported. If neither the name nor the CAS
number fits the list (and the chemical is not part of a listed category), it
is not reportable.
54. How are chemical categories handled under section 313 threshold
determinations and release reporting?
All chemicals in the category that are manufactured, processed or otherwise
used at a facility must be totaled and compared to the appropriate thresholds.
Threshold determination for chemical categories is based on the total weight
of the compound. Releases of metal compounds are reported as releases of the
parent metal portion of the compounds. If the metal and corresponding metal
compounds exceed thresholds, a joint report for metal compounds, including the
parent metal, can cover both reporting requirements.
55. If an item on the section 313 list covers chemicals with multiple CAS
numbers (e.g., nickel compounds), how is the CAS number of the item described?
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Do not enter CAS number in such cases. Instead, enter "N/A" in the space for
the CAS number on Form R. The individual chemical members of a listed
category are not required to be and should not be identified in the report,
56. Do the chemical categories such as nickel compounds include all
compounds, even those which have not been associated with adverse health
effects? What is the authority for this decision?
The section 313 list established by Congressional legislation included
categories. EPA interprets these listings to mean all compounds of nickel for
example, regardless of whether specific toxicological problems have been
identified for a specific compound in the category.
57. Must uses of listed chemicals as fumigants be reported if other criteria
and thresholds are met?
Yes.
58. Some chemicals released into the environment react to form other
chemicals or chemical compounds, for example phosphorus (a listed chemical)
oxidizes in air to form phosphorus pentoxide (not a listed chemical). Which
should be reported, the transformed chemical or the source chemical? How
would the report(s) be prepared if both the source and result chemical are
listed?
Report releases of the listed chemical. The facility is not responsible for
reporting a chemical resulting from a conversion in the environment.
59. I have hydrochloric acid with a listed content of 100 percent HC1. I
know that means 37 percent HC1 and 63 percent water - there is no higher
concentration made. Which concentration must I use for threshold
determination?
You should calculate the HC1 content based upon the 37 percent concentration.
60. A facility meets the threshold for "otherwise use" of 1,1,1-
Trichloroethane as a cleaner. Would the release of that chemical contained in
the office supply product "white-out" also be included?
Office products fall within the same realm as the personal use and janitorial
maintenance exemptions; the release of 1,1,1, trichloroethane in "white-out"
would not be reported.
61. A facility receives a chemical mixture, 70 percent of which is toluene
diisocyanate. Of this 70 percent, the supplier has told them that 80 percent
is 2,4-TDI, with CAS number 584-84-9, and 20 percent is 2,6-TDI, with CAS
number 91-08-7. The CAS number that appears on the MSDS for TDI is
26471-62-5, which is not on the section 313 list. Should the facility report?
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CAS number 26471-62-5 represents the mixture of the 2,4 and 2,6 TDI isomers.
Each of these isomers are reportable under section 313. Since the facility
knows that the two listed isomers are in the formulation and knows the
concentration of each isomer, the facility should report if the individual
thresholds are exceeded.
B. Chemicals in Solution
62. What is the strict interpretation of a sodium sulfate solution? Does it
have to be in solution when it leaves your facility? Should I consider the
quantity of the entire solution or just the weight fraction of sodium sulfate?
Why did EPA add the qualifier (solution) to the listing of sodium hydroxide
and sodium sulfate. Should sodium hydroxide pellets be ignored?
Only the actual quantity of sodium sulfate in the solution should be
considered for threshold or release determinations. Congress included the
solution qualifier on the section 313 list because this qualifier was used in
one of the state lists which served as the basis for the 313 list. Solid
forms of chemicals which are listed as solutions should not be included in
threshold and release calculations. Solid pellets of sodium hydroxide should
not be factored into threshold release calculations. However, if the solid is
made into a solution at any point in the process, then it becomes reportable.
63. In determining maximum amount on-site and thresholds, do we count the
water in solutions (e.g., NaOH, NH4N03, NA2SOA)? Do we count the nonmetal
portion of metal compounds?
Exclude the water in solutions. The nonmetal portion of metal compounds is
included.
64. How is ammonium hydroxide in solutions (i.e., "aqua ammonia") counted?
Ammonia is the listed chemical; ammonium hydroxide is not a listed section 313
chemical and has it's own CAS number. Commercial products of "aqua ammonia"
or "ammonium hydroxide" solutions are approximately 30 percent solutions of
ammonia in water. These products are considered mixtures of the reportable
chemical ammonia in water for section 313 threshold determinations and release
reporting. Report as ammonia, CAS number 7664-41-7.
65. Does the qualifier "solution" as used with sodium hydroxide, for example,
apply only to aqueous solutions? How would we interpret an aqueous-based
slurry such as a drilling mud? What about molten sodium hydroxide?
The qualifier "solution" is not limited to aqueous solutions. For example,
petroleum based solutions would also be included. Regarding slurries, NaOH
would be dissolved in water in the slurry, and should be considered as a
solution. Molten sodium hydroxide is not a solution and is not covered.
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C. Chemical-specific Questions
66. Vanadium pentoxide is not explicitedly listed under section 313, although
vanadium does appear on the list. Are we correct in assuming that we don't
need to report for vanadium pentoxide?
Yes. Vanadium is listed only as a fume or dust under section 313. Therefore,
a compound such as vanadium pentoxide is not subject to reporting.
67. For releases of sodium hydroxide (solution) in NPDES effluent discharges
within pH 6-9 range, does EPA agree that no reportable amounts are in the pH
6-9 effluent?
Yes, EPA agrees that a neutralized discharge (i.e., with pH between 6-9)
contains no reportable amount of sodium hydroxide (solution).
68. Although the category of glycol ethers requires reporting under section
313, I am not clear on whether the simplest glycol ether, diethylene glycol,
requires reporting?
Diethylene glycol is not subject to reporting. Glycol ethers, with the
following structure, are reportable: R-(OCH2CH2)n-OR', where n - 1,2, or 3, R
= alkyl or aryl groups, and R1 = R,H, or groups which, when removed, yield
glycol ethers with the structure: R-(OCH2CH2)n-OH. R groups for this
structure are unsubstituted alkyl or aryl groups. For diethylene glycol, R =
hydroxyethyl, and R1 = H, and is not subject to reporting under 313.
69. Is dipropylene glycol having the following structure considered a glycol
ether for section 313 toxic chemical reporting? H3R-(OCH2OCH)-OR
Dipropylene glycol is an ether but not a glycol ether since it does not fit
the general formula by having an (R-0-C-C-O-R) group in its structure.
70. We manufacture and use copper wire. We also use copper chemicals in
various parts of our processes. The section 313 list contains both copper and
copper compounds. Should we combine these categories for our determination of
thresholds and reporting? Do we report the release of copper compounds as
copper metal?
Copper is a separate entry on the section 313 list, and therefore should be
tallied separately to determine if you exceed manufacture, process, or use
thresholds for copper. Copper compounds are a listed category and will
include the aggregate of all copper compounds (other than the metal). For
both reports, report releases as copper (e.g., as the copper ion in
wastewater) not the total mass of copper compounds released. If you meet the
threshold for both, you may file one report for copper compounds that includes
copper.
71. I use copper wire in one of my products. I cut it and bend it and then
heat seal it into a glass bulb. How do I consider the copper wire for section
313 reporting?
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First, the wire would remain an article if no releases of copper (e.g., dusts)
occur during manufacture of the glass bulbs. If the wire is not an article,
then for an element such as copper, both the metal and its compounds are
subject to section 313 reporting. Determine first how it is present in the
wire. If it is pure copper wire, the entire weight of the wire must be used.
If it is an alloy, the weight percent times the wire weight must be used. If
there are copper compounds, the entire compound's weight must be used for
threshold determination.
72. Are vinyl chloride, a listed toxic chemical, and polyvinyl chloride, not
listed, the same thing?
Polyvinyl chloride is not a listed chemical or a listed synonym of vinyl
chloride, and it does not need to be reported. It is a polymer based on the
reaction of vinyl chloride. Only "free" vinyl chloride within the polymer
should be evaluated for threshold.
73. A facility was advised by one supplier that alumina oxide, CAS number
1344-28-1, is a toxic chemical under section 313 and is therefore reportable.
The facility was advised by another supplier that this chemical was on the
list in error, and that alumina oxide is not reportable. Is alumina oxide
reportable under 313?
Aluminum oxide, CAS number 1344-28-1, is reportable under section 313. Be
aware that naturally occurring aluminum oxide, known by the name corundum, has
a CAS number of 1302-74-5. Since the list of section 313 chemicals is
chemical-specific, corundum is not reportable.
74. Are chemical monomers such as acrylonitrile, butadiene and styrene, which
are contained in a plastic co-polymer known as ABS, reportable under section
313? The ABS is in pellet form and melted and molded; therefore, it doesn't
meet the article exemption.
If the acrylonitrile, butadiene, and styrene are present in an unreacted form
in excess of de minimis concentration then they are reportable. Although
those monomers comprise ABS, they are probably in the form of another compound
and, therefore, are not reportable under section 313.
75. The CAS number for Di-(2-ethylhexyl) phthalate (DEHP) is listed as
177-81-7 on page 4531 of the February 16, 1988 Federal Register. The CAS
number for DEHP is also listed on page 4536 of this Federal Register, but is
given as 117-81-7. Which CAS number is the correct one?
The correct CAS number for DEHP is 117-81-7.
76. For section 313 reporting, a catalyst contains 61 percent total nickel,
which includes 26 percent free nickel and nickel contained in compounds.
Should the threshold determination be based on the 61 percent total Ni?
The 61 percent total nickel cannot be used in the threshold determinations.
Nickel compounds are a listed category, therefore the full weight of nickel
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compounds must be used in the threshold determination for nickel compounds. A
separate threshold determination is required for the free nickel since nickel
is also a listed chemical under section 313.
77. Asbestos, with CAS number 1332-21-4, is a listed chemical under 313. The
synonym list does not contain reportable asbestos forms. Our facility uses
the following forms of asbestos and would like to know if they are reportable:
Azbolen (CAS 17068-78-9), Actinolite (CAS 77536-66-4), Amosite (CAS
12172-73-5), Anthropylite (CAS 77536-67-5), Tremolite (CAS 77536-68-6), and
Serpentine.
The section 313 listing for asbestos (CAS 1332-21-4) includes the specific
forms of asbestos, such as those mentioned above, that have their own
individual CAS numbers. Therefore, those types of asbestos are reportable as
long as they are in the "friable" form.
78. How is the process of removing asbestos from a site reported?
A facility that manufactures, processes, or otherwise uses friable asbestos in
excess of an applicable threshold must report asbestos waste disposal (e.g.,
accumulated asbestos waste pile disposal requires reporting). But a facility
that only "uses" the asbestos (e.g., insulation) is exempt from reporting for
structural components of the facility and removing the material does not
trigger reporting.
79. Are releases of asbestos from demolition of an old plant reportable?
No.
80. A product is immersed into a plating bath containing nickel chloride
(NiCl). This is done to bond nickel to the product prior to distribution in
commerce. Nickel is incorporated into the final product (processed) whereas
the chloride remains in the plating bath (otherwise used). Since nickel
chloride is reportable under the nickel compound category of section 313,
which threshold applies for this situation?
The determination is made based on the total amount of nickel chloride
processed and the report will be filed for nickel compounds.
81. 53 FR 4538 describes cyanide compounds as X+CN- where X=H+ or any other
group where a formal dissociation may occur; examples are KCN and Ca(CN)2.
Are cyanide compounds that do not dissociate reportable?
Cyanide compounds that do not dissociate are not reportable. Most of the
cyanide compounds that dissociate are cyanide salts which are subject to
section 313.
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III. MIXTURES AND ALLOYS
82. What is the difference between a mixture and a compound?
When a compound is formed, the identities of the reactant chemicals are lost,
but in a mixture, the individual components retain their own identity and
could be separated again. For example, polyethylene is a reaction product,
not a mixture, and is not subject to reporting under section 313. Steel
fabricated into its solid form is considered a mixture because the individual
metals retain their chemical identity.
83. When a company has a mixture on-site which does not have its own CAS
number, what CAS number should be used?
The company should attempt to identify the listed section 313 chemicals in the
mixture. A separate report must be filed for each chemical for which the
fraction of the chemical in the mixture multiplied by the total weight of the
mixture used or processed exceeds the applicable threshold. The chemicals are
treated as if they were present in pure form and each is reported with its CAS
number.
84. If a facility only knows the range of concentration of a section 313
chemical in a mixture, are they required to use the upper bound concentration
to determine threshold as stated in the Federal Register? Use of the average
or midpoint of the range will avoid overestimating emissions. If a metal
mixture contains a range of 1 to 10 percent of three metals together, how can
this information be used to determine thresholds?
The final rule does not discuss ranges, it only says that the upper bound
should be used "if the person knows only the upper bound concentration". If a
range is available, using the midpoint or average value is reasonable. For
the combination of three chemicals, the facility should split the range among
the three chemicals based on the knowledge that they have, so the total equals
10 percent. They do not have to assume 10 percent maximum for each chemical.
85. I run a metal fabrication facility, SIC code 34. If I cut the metal
sheets and send the shavings off-site for reuse, can I consider the metal
sheets articles?
If the shavings that are formed during the cutting are the sole releases, and
if all the shavings are sent off-site for reuse, then the metal sheets are
articles and are exempt.
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IV. SUPPLIER NOTIFICATION
86. MSDSs for the solvents we use give trade name or generic names only. Do
I have to contact the manufacturer for more information to report under Part
III of Form R?
If only a trade name or generic name is known and the presence of a section
313 chemical is known, then that can be reported in Part III. Beginning in
January 1989, suppliers will be required to provide the identity of the listed
chemical (CAS number and chemical name) and concentration in mixtures. The
manufacturer may claim the information trade secret, but must provide a name
that is descriptive of the chemical and at least an upper bound concentration
in the mixture.
87. By what exact date must 1989 mixture notification by suppliers be done?
A supplier must notify each customer with at least the first shipment of the
mixture or trade name product in each calendar year beginning January 1, 1989.
88. Is a facility subject to supplier notification requirements if it
distributes products containing more than the de minimis level of a listed
metal compound?
Yes, if you distribute these products to other manufacturers or processors,
and you are in SIC Code 20-39, you may be subject to supplier notification
requirements. Articles and consumer products are exempt from supplier
notification.
89. Does a supplier have to tell a customer that a section 313 chemical is
present below the de minimis level (1.0 percent, or 0.1 percent for OSHA
carcinogens)?
No. Such information is not required.
90. Is supplier notification required for distributors in Standard Industrial
Classification (SIC) code 51 which do not manufacture or process any listed
toxic chemicals for mixtures containing toxic chemicals?
Distributors in SIC code 51 which do not manufacture or process a toxic
chemical are not required to prepare notice that the mixture or trade name
products which they distribute contain a toxic chemical. They should,
however, pass along such notices prepared by their supplier to anyone who
purchases a mixture or trade name product containing a toxic chemical.
91. I am a small chemical company who supplies some section 313 toxic
chemicals to customers. My customers are requesting MSDS information and want
the CAS number for every chemical in my mixtures. I thought I only had to
supply that information for the listed toxic chemicals.
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If you wish, you may provide them with the CAS numbers for all of the
chemicals in your mixtures, but you are only required to provide information
on the listed toxic chemicals (i.e., those chemicals subject to reporting
under section 313).
92. How will the supplier notification work for imported products --do
exporters from Japan have to comply?
No. Foreign suppliers are not required to comply with supplier notification.
However, we strongly encourage importers to request content and composition
data on imported mixtures. EPA will also be exploring means of voluntary
notification by foreign suppliers.
93. Is supplier notification required from a manufacturer of a toxic chemical
in SIC codes 20 through 39 which sells a waste mixture containing a toxic
chemical off-site to a recycling or recovery facility that is covered by
section 313?
Yes, because the toxic chemical is sold to the recycler it is the equivalent
of selling a product and notification is required. The notice the facility
would be required to give is the percentage and identity of the toxic chemical
in the mixture that is sent to the recycling or recovery facility. If the
material is, however, sent off-site as a waste for the treatment or disposal,
then no supplier notification is required.
94. A facility sends empty drums containing toxic chemicals residue to a drum
recycler (within SIC Code 20-39.) Must the facility provide a supplier
notification?
No, the supplier notification requirement only applies to products that are
supplied or distributed. The only chemicals being transferred are in the form
of waste and the supplier notification does not apply to waste.
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V. ACTIVITIES AND USES OF THE CHEMICAL AT THE FACILITY
95. Are the thresholds for manufacture and process considered separately?
That is, if one manufacturers 49,000 pounds of chemical A and processes 49,000
pounds of chemical A, does chemical A need to be reported?
Thresholds are considered separately for manufacture, process, or use of the
same chemical. Therefore, chemical A would not have to be reported for the
1988 reporting year. However, reporting would be required for 1989 when the
threshold decreases to 25,000 pounds.
96. Are materials in inventory (i.e., amounts on hand at year end) to be
factored into threshold determinations?
No. Only quantities of a chemical actually manufactured (including imported),
processed, or "otherwise used" during the calendar year are to be counted
toward a threshold.
97. Under manufacture/import, what constitutes import? Does the threshold
apply if you have a broker who imports the chemical for you, stores for you,
and then ships to you? What criteria apply?
Use of a broker does not negate facility "importation" of a covered chemical.
If your facility specified that a listed chemical or mixture be obtained from
a foreign source and you specified the amount, then your facility "imported"
the chemical. The criteria are that you caused the chemical to be brought
into the customs territory of the U.S. and you "control the identity of the
chemical and the amount to be imported."
98. Do chemicals produced coincidentally to manufacturing, processing, or
using other chemical substances have to be reported?
Chemicals produced coincidentally are subject to reporting. In the case of
coincidental production of an impurity, however, the de minimis limitation
applies. An impurity is the residual amount of chemical remaining in a final
product for distribution in commerce.
99. How can wastewater treatment "products" be considered as manufactured
from a treatment process?
The rule's definition of "manufacture" includes the coincidental generation of
a listed toxic chemical as a consequence of the facility's waste treatment or
disposal activities. These chemicals may not be produced for commercial
purposes. They are, nevertheless, created as a result of the facilities
activities and released to the environment must be accounted for.
100. A facility adds hydrochloric acid and sodium hydroxide to waste water to
neutralize the waste water prior to discharge. Are these activities
manufacturing or processing (with thresholds of 50,000 pounds), or are these
chemicals "otherwise used" with thresholds of 10,000 pounds each?
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The hydrochloric acid and sodium hydroxide are "otherwise used" with
thresholds of 10,000 pounds each.
101. A facility draws steel rods into a smaller diameter. Is this
manufacture, process or otherwise use? How do I report?
This is processing and only the toxic chemicals in the steel rods actually
processed need to be included toward the threshold. Report for the total
amount of each chemical in the rods.
102. A facility manufactures fire fighting and fire protection equipment.
The facility has a training school on how to use that equipment. As part of
the training school, on-site fires are set using gasoline containing benzene,
a toxic chemical. For section 313 threshold determination, would this be an
"otherwise use" of benzene, or would this use be exempt as product testing?
This would be considered otherwise used for the section 313 threshold
determination, since the benzene is being used in a non-incorporative activity
in order to train individuals to use a product. Training is not considered
product testing or research and development.
103. We are taking part in an experimental shale oil extraction process.
When the shale is extracted, concentrations of a toxic chemical are present in
trace amounts far below the de minimis concentration. It probably would never
trigger the threshold, but can it be considered an impurity or is it a
byproduct?
The de minimis exemption applies to the toxic chemical present in the shale.
104. What is the difference between a manufacturing aid and processing aid?
A chemical processing aid is added directly to the reaction mixture to aid in
processing and does not intentionally remain in the product. Examples include
catalysts, solvents, and buffers. A manufacturing aid helps to run the
equipment and is never incorporated into the product. Examples include
lubricants, coolants, and refrigerants.
105. We have purchased in excess of 100,000 pounds of aluminum material in
block form to make a mold which stays on site. When making the mold, fumes
and dust are a byproduct. Do we report aluminum as the chemical?
Aluminum appears on the list of chemicals as "aluminum (fume or dust)". You
must determine if you manufacture, process, or use aluminum fume or dust. In
this case, you are not processing or using, but do "manufacture" aluminum fume
or dust coincidentally as a byproduct of making molds. Therefore, you must
report for aluminum (fume or dust) if you exceed the threshold.
106. A facility melts aluminum ingots, reshapes them, and injects them into a
die to form parts. Does the 50,000 pounds processing threshold apply to the
amount of molten aluminum processed?
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For calendar year 1988, 50,000 pounds threshold applies to the amount of
aluminum fume or dust generated at the facility, not the aluminum in molten
(liquid) or solid form. Therefore, the facility must determine whether they
produce more than 50,000 pounds of aluminum fume or dust air emissions in
their processing operation.
107. A facility in the textile industry buys ammonium sulfate in dry form and
then makes a solution by adding water. The solution is then "otherwise used"
at the facility. Are they manufacturing ammonium sulfate solution and subject
to the 50,000 pound threshold, or does the 10,000 pound use threshold apply?
They are both manufacturing and using the solution and should indicate both
activities on the form. If the facility uses in excess of 10,000 pounds of
ammonium sulfate (solution), then reporting is triggered. Remember that if
you must report for any reason you must report all activities involving the
chemical.
108. A remanufacturer of auto engines cleans the engine parts and thereby
produces a lead-containing waste (from gasoline lead deposits). Are they a
manufacturer, processor, or user of lead compounds?
The facility neither manufactures, processes, nor otherwise uses lead. Lead
is not incorporated into products for distribution nor is it a manufacturing
aid or a. processing aid as those terms are defined. Lead in the waste would
not be included for threshold determination.
109. What's the difference between "process" and "otherwise use"?
"Process" implies incorporation; the chemical added is intended to become part
of a product distributed in commerce. "Otherwise use" implies
non-incorporation; the chemical is not intended to become part of a product.
110. If a solvent is used in a process and 85 percent evaporates but
15 percent stays with product, is this process or use? The 15 percent was not
necessarily intended to stay with product.
In this case, the entire quantity of the solvent should be considered
"otherwise used" and subject to the 10,000 pound threshold. If the solvent
was intended to remain in the product, this would be processing.
111. Is soldering light bulbs using lead solder considered processing of the
solder?
Yes, it incorporates the solder into a product for distribution in commerce,
112. An electroplating facility uses metal cyanide compounds in their
electroplating operations. Are they processing or using those cyanide
compounds, and how do they determine whether they meet the threshold and which
threshold applies?
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The parent metal from the metal cyanide compound is plated onto a substrate
electrochemically, leaving the cyanide as waste product. The parent metal is
"processed", while the cyanide is "otherwise used". Metal cyanides are
reportable under section 313 as both cyanide compounds and metal cyanides.
Select the threshold based on the action that involves the portion of the
compound that identifies the category (i.e., cyanide for cyanide compounds).
The total weight of the compound counts for both the metal threshold and the
cyanide threshold.
113. A facility uses sulfuric acid to etch chips, then neutralizes with
ammonia forming ammonium sulfate. Which thresholds apply to each chemical? L
facility uses sodium hydroxide solution in a scrubber to control fluoride
emissions. Which activity and threshold applies to the sodium hydroxide?
Chemicals not incorporated into a product for distribution in commerce are
otherwise used. A 10,000 pound threshold applies to the sulfuric acid,
ammonia, and sodium hydroxide if the byproducts are not sold. The 50,000
pound manufacturing threshold applies to ammonium sulfate because it is
manufactured coincidentally as a result of the neutralization process.
114. Does the placing of a bulk liquid containing a small percentage of a
section 313 chemical into small bottles for consumer sale constitute a "use"
of the mixture?
No, but it is a type of "processing." If the bulk liquid contains a section
313 covered chemical in excess of the de minimis level, the chemical in the
liquid would have to be factored into calculations in determining whether the
processing threshold is exceeded for that chemical.
115. Faint containing listed chemicals is applied to a product and becomes
part of the article. Does the 50,000 pound threshold apply? What about the
volatile chemicals from the painting operation -- are they "otherwise used,"
thus subject to the 10,000 pound threshold?
Yes to both questions. This is a case in which listed chemicals in the same
mixture may have different thresholds. The listed chemicals that remain as
part of the coating are "processed," whereas the volatile solvents in the
paint are "used" because they are not intended to be incorporated into the
article.
116. A facility removes chemicals from groundwater in a. cleanup action. The
listed chemicals, after treatment, are sent off-site for disposal. Are they
required to report? Does the exemption for intake water apply?
Since the chemicals are not manufactured, processed, or otherwise used, no
reporting threshold applies to the cleanup action. If the chemicals are
manufactured, processed, or otherwise used elsewhere at the facility and
exceed a threshold, releases from the cleanup must also be reported on the
form. Intake water exemption does not apply since the chemicals are not being
used in process water or noncontact cooling water.
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117. For section 313 reporting, are PCBs contained in transformers that leak
reportable as "otherwise use" of PCBs?
Yes, if the transformer is leaking, then it is no longer considered an
article; therefore it would be reportable if the 10,000 pound threshold for
"otherwise use" is exceeded.
118. A covered facility includes an agricultural establishment that use
pesticides to spray crops. The pesticides contain toxic chemicals subject to
section 313 reporting. Is the pesticide considered "otherwise used"?
Use of the chemicals in pesticides is considered "otherwise used" and the
entire amount is reported as a release.
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VI. EXEMPTIONS
A. General, Personal Use, and Intake Water or Air
119. Does a material retain its exemption even if other formulations,
articles, or fuels with the same chemical are not exempt?
Yes, the material retains its exemption.
120. Do office supply type products require coverage under section 313
reporting?
EPA does not intend to require covered facilities to account for listed
chemicals in office supplies such as correction fluid and copier machine
fluids. Although not specifically exempt in the regulation, EPA interprets
such mixtures or products to be equivalent to personal use items or materials
present in a facility's cafeteria, infirmary, or materials used for routine
janitorial activities and facility grounds maintenance.
121. A facility uses river water as process water. The water taken from the
river contains more lead (1.0 ppb) than the water returned to the river (0.5
ppb). Is it subject to the process water exemption? If not, is the facility
treating the water?
The process water can be considered exempt because the toxic chemical was
present as drawn from the environment (Section 372.38 (c)(5)).
122. Would a listed chemical present in compressed air be exempt? What if
the chemical is present in boiler emission air?
A listed chemical present in compressed air would not have to be counted
toward a threshold determination. If that same chemical is present in the
boiler emission air only because it was in the compressed air fed to the
boiler, then that would remain an exempt use. However, if the chemical is
created as a result of combustion, you have coincidentally manufactured the
chemical and must consider it for reporting.
123. A facility pumps naturally occurring sodium sulfate brine solution from
the ground, processes it to produce solid sodium sulfate, and returns the
solution water to the brine reservoir. They do not pump other water into the
formation to dissolve sodium sulfate. Are they exempt due to "chemical in
incoming process water?" If not, how do they report the "release" of sodium
sulfate in water returned to the brine reservoir?
They are NOT exempt because they are processing brine for its sodium sulfate
content, not using process water that happens to contain an impurity. They
should not report underground injection or similar disposal for water returned
to the reservoir since the net effect of the operation is to remove sodium
sulfate. Recovering sodium sulfate is not "waste treatment", however, any
other releases or treatment should be reported.
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B. Facility Maintenance and Structural Components
124. How is routine maintenance defined in the exemption list? Is equipment
maintenance included?
Equipment maintenance is not exempt. The routine maintenance exemption is
intended to cover janitorial or other custodial or plant grounds maintenance
activities using such substances as bathroom cleaners, or fertilizers and
pesticides used to maintain lawns, in the same form and concentration commonly
distributed to consumers. Painting of equipment is exempt because it is
intended to become part of the structure of the facility.
125. Are solvents and other listed chemicals in paint used to maintain a
facility exempt?
Yes. Painting to maintain the physical integrity of the facility is
consistent with the "structural component" exemptions, even though the
solvents in the paint don't become part of the structure.
126. Does the "structural component" exemption cover the small amounts of
abraded/corroded metals from pipes and other facility equipment that become
part of process streams?
Yes.
127. If a facility stores a toxic chemical on-site, and then uses it by
installing it in the facility (i.e., copper pipes) is the facility required to
consider the toxic chemical (a component) for section 313 submission?
If the chemical is in an article (i.e. copper pipe) it is not considered in
threshold determinations. When the substance is installed, it then falls
under the structural component exemption and is exempt.
128. Are pesticides which are used to control algae in cooling water towers
exempt?
No, such pesticides would not fit the routine maintenance exemption. The
"otherwise use" threshold would apply.
129. Are degreasers used in plant maintenance shops exempt?
No, using degreasers would be considered "otherwise used."
C. Vehicle Maintenance
130. Please verify that any motorized vehicle operated by the facility,
whether licensed or not, is subject to the exemption listed in section 372.38.
This includes forklifts, tow motors, automobiles, etc., that contain a motor.
Also, please verify that gasoline, lubricants, oils, and anti-freeze are all
considered to be substances subject to this exemption.
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Yes. The exemption Includes benzene in gasoline and glycol ether in
antifreeze used to maintain and operate a facility motor vehicle. This
exemption would not apply, however, in the case of an automobile manufacturing
plant. As part of the production of vehicles, such a facility would be
incorporating the chemicals into an article for distribution in commerce.
131. In the process of maintaining fork lift truck batteries, they are opened
to add sulfuric acid as needed. Is this sulfuric acid reportable under
section 313?
No. Section 313 exempts the "use of products containing toxic chemicals for
the purpose of maintaining motor vehicles operated by the facility" (40 CFR
Part 372.38). That amount would not be included in the threshold
determination.
D. Laboratories
132. Does section 313 reporting include laboratory chemicals?
The quantity of a listed chemical manufactured, processed, or "otherwise used"
in a laboratory under the supervision of a technically qualified person is
exempt from threshold and release calculations. This exemption includes
laboratories performing quality control activities and those located in
manufacturing facilities.
133. What is meant by "specialty chemical production" as an exception to the
laboratory activities exemption?
Specialty chemical production refers to chemicals produced in a laboratory
setting that are distributed in commerce.
134. Assume that a quality control laboratory, or area control laboratory, is
part of a manufacturing facility. Would it be exempt from calculating
threshold quantities for listed chemicals?
Yes, assuming that such a laboratory is under the supervision of a technically
qualified .person and is not engaged in pilot plant scale or specialty chemical
production.
135. A facility sends materials which are sampled from processing operations
to a laboratory for quality control purposes. Are these quantities exempted
under the laboratory exemption, provided that they are handled by a
technically qualified individual?
No, any quantity of a covered chemical manufactured, processed, or "otherwise
used" must be counted for the purpose of threshold determination. The fact
that it is drawn from a process for purposes of quality control testing does
not allow the facility to subtract that quantity from the total amount of the
chemical factored into the threshold determinations.
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136. Is a bench scale or pilot scale reactor for a pilot plant excluded from
the laboratory exemption?
A bench scale reactor would not be exempted as part of the pilot plant if it
is used to make products (in quantities above the threshold) distributed in
commerce.
137. Are the following engine testing operations that use listed section 313
chemicals exempt under the laboratory activities exemption: (a) testing of
production engines intended for sale in specialized engine test cells; (b)
testing engines for research and development purposes in specialized engine
test cells; (c) testing for research and development purposes in open water
bodies?
Yes, all of the noted operations are considered "product testing" and as such
are intended to be included under the laboratory activities exemption.
138. Section 372.38 lists uses of chemicals in laboratories which are exempt
from threshold determination and release reporting. It states, "if a toxic
chemical is manufactured, processed, or otherwise used in a laboratory at a
covered facility under the supervision of a technically qualified individual,
as defined in Section 720.3(ee) of this title," it is excluded from 313
reporting requirements. What is that reference?
Section 720.3(ee) is found in Toxic Substances Control Act (TSCA) regulations
(40 CFR 720.3(ee)) and defines "technically qualified individual" as "a person
or persons who, because of education, training or experience, or a combination
of these factors, is capable of understanding" and minimizing risks associated
with the substance, and is responsible for safe procurement, storage, use, and
disposal within the scope of research.
E. De Minimis
139. What is "de minimis" under Section 313?
De minimis refers to a concentration of the chemical so low that reporting is
not required. It does not apply to wastestreams, but applies to products
purchased, sold, or commercially used by the facility.
140. Please explain the de minimis limitation for mixtures and trade name
products.
Listed toxic chemicals present in mixtures or trade name products at
concentrations below the de minimis level of 1.0 percent, or 0.1 percent for
OSHA-defined carcinogens, do not have to be factored into threshold or release
determinations. This de minimis level is consistent with the OSHA Hazard
Communication Standard requirements for development of Material Safety Data
Sheets (MSDSs).
141. Does the de minimis exemption apply regardless of whether a chemical is
present as an ingredient, an impurity, or in a waste?
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The de minimis exemption applies to ingredients of mixtures or to impurities
present in products you process or use. It does not apply to wastes when you
manufacture, process or use chemicals in mixtures above the de minimis level
(and meet the threshold), wastes and releases must be reported regardless of
concentration. Further, when your operations create (manufacture) the
chemical in waste treatment, the de minimis exemption does not apply.
142. What does OSHA consider as a carcinogen under the hazard communication
standard? Does a potential carcinogen need to be included under this
definition?
According to OSHA's definition: "a chemical is a carcinogen or potential
carcinogen for hazard communication purposes" if it is found on any of three
lists: (1) the National lexicological Program, Annual report on Carcinogens;
(2) the International Agency for Research on Cancer (IARC) Monographs; or
(3) 29 CFR Part 1910, Subpart 2, OSHA Toxic and Hazardous Substances. Both
actual and potential carcinogens are included under OSHA's definition.
143. How do we determine whether the de minimis level for a section 313
listed chemical should be 1 percent or 0.1 percent?
The instructions for completing Form R for 1988 contains a list of covered
toxic chemicals with the de minimis level for each.
144. A facility uses a chemical mixture that contains a toxic chemical. If
the maximum and minimum concentrations listed on the MSDS range above and
below the de minimis concentration levels, how can the facility determine
quantities for section 313 compliance?
The amount of the chemical in the mixture that is present above the de minimis
level and therefore counts toward the threshold, can be assumed to be
proportional to the ratio of the above-de minimis concentration range to the
overall concentration range. The concentration of the chemical in the mixture
that is not exempt is the average of the de minimis and the maximum
concentration.
145. A raw material contains less than the de minimis level of a listed
chemical. During processing, the chemical is concentrated to above the de
minimis level in a solid waste that is disposed in an on-site landfill.
Should the chemical handled in the process line be included in the facility
threshold determination? Do releases from the process line or wastestreams
containing above the de minimis level require reporting?
The de minimis exemption applies to the raw material. You do not have to
consider it further even if a toxic chemical is concentrated above the de
minimis level in a waste.
F. Articles
146. Are metal "articles" exempt from threshold determinations in normal
processing, use, or disposal?
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Metal "articles" are exempt from threshold determinations if, during their
normal processing or use no toxic chemical is released. Disposal of solid
wastes that are recognizable as the processed article is not a release that
negates the article status.
147. Does the article exemption in the 313 rule apply to preparation of the
article? What about processing or using that article?
The article exemption does not apply to the processing of chemicals to make
articles. Manufacturing of articles such as tableware is not exempt. When a
facility manufactures a metal part and coats it, neither process is exempt.
148. We take copper wire, cut it, and wind it around smaller spools. Is the
wire still an article?
If there is no release of a toxic chemical during normal processing of the
copper wire, then the wire remains an article.
149. Can facilities who extrude copper bars or rods into wire treat the bar
or rod as an article?
No, an article has end use functions dependent in whole or in part upon its
shape or design during end use. The end use function is dependent upon the
copper being in the shape of the wire, so the copper bar cannot be considered
an article. If you are changing the shape or form of an item substantially,
you are processing the chemicals -- they are not articles.
150. A facility uses a product that is in pellet form in its manufacturing
operations. Is this product considered an article and therefore exempt from
reporting under section 313?
A pelletized product is not an article. If it is a chemical or mixture that
is in a. pelletized form because such form is convenient for further processing
by the facility or its customers, then the pellet is not an article. The
amount of a toxic chemical in the pellets would have to be reported as a
transfer to an off-site location if, for example, floor sweepings were sent as
part of refuse to a land fill.
151. A facility uses FOB transformers. Are these considered to be articles,
and therefore exempt from reporting under section 313?
PCB transformers are considered to be articles, as long as they do not release
PCBs during normal use or if the facility does not service the transformer by
replacing the fluid with other PCB containing fluid.
152. A facility (ship builder) uses lead bricks in ships as ballast. They
remain permanently with the ship. The lead bricks could be considered
articles and therefore be exempt from reporting. However, they infrequently
cut some of the bricks, generating lead dust, which they collect and send to
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an off-site lead reprocessor. How should they report? What should be counted
towards the threshold if they are not considered articles?
If all of the lead solid waste is recycled (i.e., none released to air) then
no "release" occurs. Shipment off-site for recycle does not have to be
reported. Therefore, the cut bricks retain their article status. If
emissions of lead occur that are not recycled, then the cut bricks would not
be considered articles. In the non-article case, only count the lead in
bricks actually "processed" (i.e., cut) toward the threshold. Account for
lead not recycled as lead released.
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VII. RELEASES OF THE CHEMICAL
153. What is the definition of a chemical "release" under section 313?
The law defines a release as any "spilling, leaking, pumping, pouring,
emitting, emptying, discharging, injecting, escaping, leaching, dumping, or
disposing to the environment". Under section 313, facilities are required to
take into account in their reports both "routine" and "accidental" releases to
any environmental medium.
154. Is the disposal of wastes such as dusts, shavings, or turnings -- that
result from grinding or drilling of metal items -- considered releases of
toxic chemicals?
Yes, such releases of "non-recognizable" solid wastes such as dusts, shavings,
or turnings are considered releases of toxic chemicals.
155. Tank trucks and rail cars physically enter a facility. While loading,
emissions occur. Are these emissions subject to reporting under section 313?
Because the loading and the releases occur within the facility boundary, the
releases must be reported.
156. Do we need to report leaking, abandoned landfills? What if we don't
know if it is leaking?
Leaks from landfills need not be reported. EPA requires reporting of the
amount of a chemical placed in an on-site landfill during the year, It is not
necessary to estimate migration from the landfill.
157. I process a plastic pipe which is 3 percent formaldehyde. I also know
how much formaldehyde is emitted when I process the pipe. Do I need to report
these emissions?
Yes, if the processing threshold for formaldehyde is exceeded.
158. A facility buys and sells rigid polyurethane foam insulation containing
a fluorocarbon. If the fluorocarbon is Freon 113, would they have to report
the Freon 113 released to the air when they cut the insulation?
Freon 113 is a frothing agent to produce rigid polyurethane foam and is
intended to remain in the foam cells to give it density and insulating value.
Foam containing higher than the de minimis concentration of Freon 113 that is
cut, releasing the chemical, cannot be considered an article. The Freon 113
in cut foam pieces counts toward the processing threshold and if the threshold
is met, the facility must report the chemical released when the insulation is
cut. Normal/natural diffusion of Freon 113 from the foam does not have to be
considered a release.
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159. Our facility paints metal cabinets and the paint solvents contain a
listed toxic chemical. The system consists of a closed vacuum vented painting
room and a closed oven room vented by an oven stack. Is the vent to the
outside of the building over the painting room a "releases from building
ventilation systems" fugitive emission?
No, fugitive releases are emissions that are not in a confined directional air
flow. Since your building vent system over the painting room is a confined
air stream, it can be combined with the oven stack as a stack or point
emission for Form R, Section 5.2.
160. A facility has a liquid wastestream which is incinerated. The
incineration is 99.9 percent effective and it is no longer a liquid
wastestream. However, the 0.1 percent is released to air as a gaseous
wastestream. Does the facility not need to report this wastestream?
The facility does not need to report a gaseous wastestream. The liquid
wastestream is 100 percent treated through incineration. The air emissions
created, if any, would be reported as a release to air and the quantity would
be included in Part III, Section 5.2, stack or point air emissions. If the
air emission is further treated then that air emission would be listed as a
gaseous wastestream and the treatment documented in Part III, Section 7.
161. Where does one report routine leaks from pipes? Would you report as
disposal to land or underground injection?
Reporting leaks from pipes requires determining where the released material
goes. A material that evaporates would be reported as a fugitive air
emission. A nonvolatile material leaking onto land, or any material leaking
from an underground pipe, would be reported as a release to land, entering the
amount in Section 5.5.4, Other disposal. Material that is cleaned up might be
reported as a release to water or an off-site transfer, and would be included
in the appropriate section of the form.
162. A 313 substance is emitted as an air particulate which deposits on the
facility grounds or roof, such that it will be washed into a NPDES pond or
swept into a solid waste pit for landfill. Will the release be reported as a
release to land or water, but not air? This would prevent a substance from
being reported twice, once as an air emission, and once as a water/land
emission.
If the facility can develop a supportable estimate that part of a release to
air is deposited within the facility (and subsequently collected or deposited
in an on-site landfill or surface impoundment), then these quantities can be
separated from the air release figure(s) and reported as released to land
(on-site). The remaining air releases, not deposited on the facility, would
be reported as releases to air.
163. Is it true that the facility need not make any special effort to measure
or monitor releases for section 313 reporting and may use information that is
on hand? If this is true, how will section 313 reporting produce complete
data for the public on environmental releases?
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The law states that covered facilities need not conduct monitoring or other
activities beyond that required by other statutory or regulatory requirements.
Congress included this language to limit the burden on the affected industry
for development of release and other required data. Without measurement or
monitoring data, the facility is required to make reasonable estimates.
164. Section 313(g)(2) of the statute states that the owner or operator of a
facility may use readily available data (not must use). In some cases, the
available data may be known to be non-representative and reasonable estimates
offer more accurate release information. Would EPA, in this instance, favor
use of the estimates rather than data?
Yes, it is preferable to use reasonable estimates if monitoring data is known
to be non-representative.
165. Don't the section 313 reporting requirements overlook the possibility
that a substance can lose its identity as a side product in a reaction, and
that the difference between "input and output" volumes may not always be due
to a release?
The section 313 rule does recognize that a chemical can lose its identity in a
reaction. Determining or reporting total mass balance accounting, total
annual production, initial annual inventory, or amounts processed or used are
not required. The rule requires an estimate of the total annual amount of a.
chemical released to the environment and the maximum quantity on-site at any
time during the year.
166. If a facility monitors for a chemical and the measurement is below the
limit of detection of the method, can they report zero releases?
Although monitoring results may be below detectable limits, this does not mean
that the chemical is not present. The facility must use reasonable judgment
as to the presence and amount of the chemical; one approach is to use half the
detection limit as the wastestream concentration. The facility should not
estimate releases based solely on monitoring devices, but also on their
knowledge of specific conditions at the plant.
167. If a company measures its own leaks (valve, flange, pump, etc.) and
determines a new fugitive factor, is this code "E" or "M" or "0"?
Use the code "M" if you measured releases of the chemical from your equipment
at the facility. Use "E" only for published emission factors which are
chemical specific. Use "0" if you measured leaks generally or applied
non-published factors developed at other facilities.
168. If total releases are obtained using combination of basis, how do we
report "Basis of Estimate" in Section 5, Column B?
Report the basis used to calculate the major portion of each release entry.
See the examples in the instructions to the form.
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169. Are SOCMI (Synthetic Organic Chemicals Manufacturing Industry) emission
factors applicable to the petroleum refining industry as well as organic
chemical manufacturers?
Yes, SOCMI fugitive emission factors can be used for the petroleum refining
industry even though they are based upon synthetic organic manufacturing. The
refinery user would have to correct for differences in concentrations of the
mixtures, because SOCMI factors are based upon pure substances being released.
170. EPA's fugitive emission factors for equipment leaks for the Synthetic
Organic Chemical Manufacturing Industry (SOCMI) and some air emissions factors
listed in EPA's document AP-42, "Compilation of Air Pollutant Emission
Factors," are not chemical specific. Should the basis of estimate code be
entered as "E" or "0"?
Use "0" for non-chemical-specific emission factors.
171. Should we report the composition of stormwater as it falls from the sky
-- or do we count its composition once the rainwater has run onto and off
soil?
You count the composition once the rainwater has run onto and off the soil,
equipment, concrete pads, etc. as a portion of the total facility release- to
surface water.
172. A facility processes anhydrous ammonia. "Low concentrations" of
ammonia, ammonium hydroxide, ammonium chloride, and other ammonia salts are
released into a wastestream that is not treated but is deep well injected. Is
the facility required to report releases of ammonia?
The facility should count the quantity of ammonia (i.e., "free" ammonia) as
the amount released to the wastestream. In-stream conversions do not negate
the fact that ammonia, as a listed chemical, is released.
173. How does one use the storage tank equations in Appendix C of the
technical guidance to estimate air emissions for a specific chemical in a
liquid mixture?
You must estimate emissions of the total mixture using average molecular
weight and vapor pressure for the mixture, then multiply by the weight
fraction of the chemical in the gaseous emission. The required formulas are
found in the technical guidance but are not listed in a step-by-step
procedure.
174. The emission factors used to estimate releases to air from leaks in
pipes are time dependent. What amount of time should be used to determine
fugitive emissions from emission factors?
In using emission factors to determine fugitive emissions to the air from
leaks in pipes, a facility must use the total amount of time which a pipe
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contains the toxic chemical, since a release will occur whether a chemical is
moving or stagnant in the pipe.
175. How does a facility estimate fugitive or working losses from drums
contained in a warehouse or storage facility?
Fugitive emissions from drums in storage at a covered facility ma.y include
emissions from opening and emptying the drums. The facility may consider each
drum as a small tank and estimate the amount of toxic chemical contained in
the vapor space using methods such as partial pressure determinations found in
the technical guidance document.
176. Is there any recommended approach for estimating emissions from
facilities whose raw material is of a constantly varying and unknown
composition. For example, tar plants receive crude coal tar in batches. No
analysis is done on incoming raw materials or on products (or on
intermediates) at such facilities.
If available, data on the average composition for the specific material or
published data on similar substances should be used.
177. If off-site reclaimers are not to be included in the off-site locations
which handle wastes, are emissions discharged by these reclaimers included as
point emissions or are they not reported?
A facility should report neither transfers for off-site recycling of the
chemical nor the chemical releases from such a reclaimer.
178. If the calculated threshold of sodium hydroxide, for example, is based
on the mass utilization of the solution, would the emission of a wastewater
stream containing 1 ppm of NaOH be the actual mass of NaOH or the mass of
wastewater?
Only the actual mass of the toxic chemical being released should be reported,
in this case the mass of sodium hydroxide. Note, however, that in this
specific case, if the wastestream has been neutralized so that the pH is in
the range 6-9, the release of sodium hydroxide would be zero for reporting
purposes.
179. We manufacture paint and one of the chemicals we use is toluene. We
used the "Estimating Releases" guidance document but the answer is for toluene
and mineral spirits and is much too high. Can we use the 6 percent present in
the paint mixture times the number and report that?
The partial vapor pressure of toluene in formulations, which is a function of
its vapor fraction and mole fraction (not weight percent), can be used. See
Appendix C, Note (1), p. C-6 of Estimating Releases and Waste Treatment
Efficiencies for the Toxic Chemical Release Inventory Form. EPA document
560/4-88-002.
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180. How should a facility estimate emissions from horizontal storage tanks?
The AP-42 equations were developed for vertical tanks.
For fixed roof tanks, the working loss equation for vertical tanks can be
used. For breathing losses, one can still use the vertical tank equation,
except that an effective tank diameter must be substituted for D in the
equation. D is the square root of {(4)(area of liquid surface)}/3.14. H is
the same as for vertical tanks.
181. How can one estimate emissions of chlorine from use in cooling water
treatment? We have tried to estimate the emissions for some cooling water
systems based on the amount of water evaporation, wind drift, and the amount
of chlorine used, but the releases seem too high.
Estimating emissions based on the amount used overestimates release since:
chlorine is only slightly soluble in water, reacts with chemicals in the
water, and dissipates in side reactions. Measured residual chlorine times
recirculation rate times lost water fraction may also overestimate release
(residual includes other forms of chlorine), but may be the only way to make a
reasonable estimate. There are no readily available emission data on chlorine
from cooling water systems .
182. If EzSO^/ECl (sulfuric acid/ hydrochloric acid) were spilled outside a
facility and an absorbent (e.g., kitty litter) was used to absorb the toxic
chemicals, would the use of the absorbent be listed as a treatment and be
reported under Section 7?
No, the use of the absorbent would not be considered a treatment. Only if the
acids were neutralized would that activity be considered treatment. If the
absorbent were drummed and sent to a landfill, that would be listed as a
transfer to an off-site location. Any acid left on the ground must be
accounted for as a release to land.
183. Form R requires estimates of the release to the environment of chemicals
in specific release categories. If a facility is unable to complete its
estimate of these releases by the deadline, should the company leave that
entry blank and promise a future estimate, or make the best estimate possible
and submit later revisions?
Any covered facility must report by July 1, and the data provided should be
the best estimate using the best data available; records supporting the data
must be kept for three years. If more accurate data are developed, the
facility may submit revised forms. EPA can take enforcement action if they
believe that the data do not represent reasonable estimates.
184. For releases or transfers off-site that are reported as zero, what
should be reported as a basis of estimate?
Leave the basis of estimate box blank or enter N/A.
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185. Explain the naming of receiving streams.
You are required to report the name of each stream "to which chemicals being
reported are directly discharged". If you have no such discharge, enter
"N/A".
186. A facility determines that it can estimate stormwater releases of a
listed chemical from the facility. However, such releases go to a city-owned
storm sewer system and the facility has no direct knowledge of the receiving
stream or surface water body to which the chemical is ultimately released.
What do they report as the "receiving stream" on Part I, Section 3.10(a) of
the form?
The facility would put "city-owned storm sewer" or the equivalent because this
is all they know. To leave the receiving stream item blank or put N/A would
be identified as an error when the form is entered to the computerized
database of section 313 data.
187. If a facility has a cement lining or other leak restricting device in
the area where they store toxic chemical containers and a release from the
stored chemicals occurs, how is this reported in Section III?
If the facility does not have specific measures for land filling, land
farming, or land disposal, then for the purposes of Form R Section III the
releases would be entered to 5.5.4, Other Disposal. This would apply to
amounts released that were not "cleaned up" and removed from the site or
otherwise treated and disposed on-site.
188. If a POTW has no current estimate of treatment efficiency for each
section 313 chemical, is "N/A" acceptable?
You need not report the treatment efficiency for any off-site facility to
which transfers of toxic chemicals occur. Thus, facilities must account for
the annual quantity of the listed toxic chemical(s) released to a POTW, but
are not required to estimate the treatment efficiency of the POTW.
189. What are the technical guidance manuals for specific industries?
These documents help specific industries or operations to determine reporting
requirements and estimate releases. They cover: electroplating;
semiconductors; textile dyeing; wood products manufacture and preservation;
organic coatings application; rubber production; printing; paper and
paperboard; leather tanning; monofilament fiber manufacture; formulating
aqueous solutions.
190. Why are the range codes grouped together in logarithmic scale?
For quantities on-site, the ranges were patterned after TSCA inventory
reporting as suggested by Congress.
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VIII. WASTE TREATMENT METHODS AND EFFICIENCY
191. Does the waste treatment section apply only to the facility completing
the report?
Yes.
192. Where multiple sources are combined for treatment, should each source be
listed in the treatment efficiencies section and a common efficiency shown or
should only the combined stream be shown?
Report only the combined (or aggregate) wastestream and report the treatment
and its efficiency. However, a wastestream that is treated before combination
with other wastes, which are then subsequently treated, should be reported on
a separate line.
193. A facility has a sequential treatment process in which the influent
concentration and treatment efficiency for each step is known. How should
they report on the form?
The facility may report in either of two ways. (1) Report influent
concentration for the first step and report overall treatment efficiency for
the process as per instructions. Check the sequential treatment for each
step. (2) Report each influent concentration and efficiency'for each step.
Do not check sequential treatment boxes, as this will create confusion as to
the meaning of the efficiency listed by the last treatment step.
194. If a wastewater treatment system contains an oil skimmer or other phase
separation treatment, is this reported as a sequential treatment step for each
of the separated phases, or just for one phase?
The separation step is a sequential treatment step for one liquid phase (the
one with the larger volume, in this case, water). The other phase must be
considered a new wastestream and must be listed separately on the form if
treated subsequent to its separation.
195. We send our sludge to a biological treatment device on-site. The
microbes in the system exist in a buffered solution. As a result, the toxic
chemical (a mineral acid) in the sludge is neutralized (pH 7.3). How do I
account for biological and neutralization treatment in one process in- Fart III
Section 7? After that, the waste goes to settling ponds where solids settle
out. Is this also a sequential treatment step?
List the biological treatment first with a zero efficiency because it does
nothing to the toxic chemical. Enter the neutralization treatment with a
100 percent efficiency since pH 7.3 is considered complete neutralization for
an acid. Check the sequential treatment box. As for the settling ponds, the
toxic chemical ceased to exist upon complete neutralization, so this step does
not need to be included on the form for mineral acid.
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196. On-slte wastewater treatment plant sludges which may contain trace
amounts of section 313 chemicals are composted on-site. The finished compost
is then used as daily cover for the on-site sanitary landfill and for
landscaping around the site. Is this considered land treatment, land
impoundment, or not a release?
It is a release and the code DOS for Land Treatment/Application/Farming should
be entered in Part III, Section 7B of the form.
197. We have two waste streams, one contains NaOH and the other HC1. These
streams are combined for neutralization; they then stay in the settling pond
until the solid settles out. The water is sent to a POTW, the solid to a
landfill. I know that we meet thresholds and must file reports for both
chemicals, but how do I report on what? When does a toxic chemical cease to
exist by neutralization?
Neutralization is the treatment method for both chemicals. If the pH is
between 6 and 9, then the efficiency is 100 percent --no toxic chemicals are
released --no off-site transfer need be reported. If the waste is acidic,
report transfer of HC1 off-site and calculate efficiency from input and
remaining acid; no NaOH is released. For a basic waste, acid is 100 percent
neutralized and the efficiency is 100 percent with no HC1 transfer off-site,
but the NaOH must be reported as an off-site transfer.
198. If sodium hydroxide (solution) is spilled, but neutralized before
leaving plant boundaries, should the quantity spilled be included in the
facility's release report?
No.
199. How is an auxiliary scrubber that is designed and used only to mitigate
emergency releases reported?
The influent concentration and treatment efficiency of the scrubber as it
operates during an emergency event should be reported. The emergency scrubber
is not considered to be "sequential" treatment with a scrubber which treats
routine emissions from the same process, unless the two units function in
series on a single wastestream.
200. Should the influent concentration to treatment for metal compounds be
reported for the parent metal only?
Yes.
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IX. TRANSFERS TO OFF-SITE LOCATIONS
201. A facility sends a 313 toxic chemical in waste off-site to a TSDF which,
in turn, sends the 'waste to another facility for recycling. Does the facility
not list this activity, since the waste is ultimately recycled? Or should
they report as M90: Other Off-site Management in Part III Section 6C, since
it is a location to which they transfer wastes?
Part VII of the preamble to the section 313 final rule states that "transfer
to a reprocessor or recycler of chemical waste are not reportable as off-site
transfers." Since the reporting facility knows the toxic chemical is
ultimately being recycled or reprocessed, the facility would not report the
off-site transfer. If the facility could not document that the waste was
being recycled, it must report the off-site transfer.
202. What about shipment for recycle? For example "empty" drums containing a
residue of a toxic chemical are sent to a drum remediation site which is not a
treatment, storage, or disposal facility. Are such facilities listed as
off-site TSD facilities? (The chemical is not being recycled, but the
carrier, that is the container, is.)
Shipments for recycle of the chemical should not be reported. However,
recycle of drums or recycle of other constituents of a waste does not qualify
as recycle of the chemical: such transfers should be reported. The example
cited should be reported as an off-site transfer with appropriate code such as
M99- unknown, or M61- wastewater treatment.
203. Why does the section 313 form require disclosure of off-site locations
to which toxic chemicals are transferred? The Act only requires the disposal
method employed.
The conference committee report directed EPA to require reporting of releases
to air, water, land, and waste treatment and disposal facilities. Legislative
history treats off-site facilities as an equivalent environmental medium. EPA
believes Congress intended to include reporting of quantities and locations of
off-site waste treatment and disposal facilities to identify how and where
chemicals enter the environment.
204. Why is there a treatment code in Table I for reuse/recovery when the
section 313 final rule specifically states in the preamble that "transfers to
a reprocessor or recycler of chemical waste are not reportable as off-site
transfers?"
Recycle of the chemical need not be reported. The facility can use a recycle
code for the waste shipped offsite when that best describes the activity and
the chemical is not being recycled. For example, a report on metal containing
pigment could report off-site distillation to recover solvent, although the
metal (or pigment) is not being recovered.
205. How do we treat a solvent sent off-site for distillation and returned to
us for use?
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The amount of solvent sent to another facility for distillation is not
reported as a transfer of the chemical to an off-site location (i.e., it
should not be reported in Part III, Section 6 of the form). The quantity of
the solvent returned to you must be treated as if it were a quantity of the
chemical purchased from any other supplier and must be used for threshold
determination.
206. What RCRA ID Number do we list if we send a non-hazardous waste
containing a section 313 chemical to a solid waste landfill?
If an off-site location such as a solid waste landfill does not have a RCRA ID
Number, you would enter N/A in the space provided. If the facility does have
such an ID number, you must list it if you know it, even though the waste
being transferred may not be a listed RCRA hazardous waste.
207. Our facility produces 200,000 pounds of waste annually. Of that amount,
we treat 100,000 pounds on-site and send 100,000 pounds to an off-site
treatment plant that has a 99.9 percent efficiency. Can we factor in the
efficiency when we report the off-site transfer amount in Part III Section 6
of Form R?
That section of Form R requires you to report the actual amount of toxic
chemical you send off-site. The efficiency would be taken into account by the
off-site facility if they are reporting.
208. A printer uses a solvent to clean presses and sends soiled rags to a
launderer. Is the material sent to the launderer considered waste transferred
to an off-site location? Which disposal code should be used?
Yes, it is considered an off-site transfer. The facility could us€>. code M90 -
Other Off-site Management or M99 - Unknown.
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X. WASTE MINIMIZATION
209. What is included in waste minimization? Are solid wastes as well as
hazardous wastes included?
Waste minimization means reduction of the generation of listed toxic chemicals
in wastes. Waste minimization reporting applies to air emissions, solid
wastes, wastewater and liquid materials that are released, disposed, or
treated.
210. What do facilities that have not performed any waste minimization
include in the report?
The waste minimization portion of the reporting form is optional.
211. Where can facilities obtain figures from the previous year?
Companies can obtain waste minimization information about the year prior to
reporting from various sources including but not limited to inventory data,
recycle/reuse data, engineering reports on process modification, and product
development studies.
212. If a facility modifies a process for economic reasons resulting in a
waste reduction, should this be reported as minimization?
Yes. Any changes that result in less of the listed toxic chemical being
generated in waste may be included. Codes are provided to identify changes
such as equipment and technology modifications, as well as process changes,
procedure modifications, and improved housekeeping.
213. Would RCRA-permitted incineration of waste count as waste minimization
under M8 (Other Treatment Methods)?
Treatment or disposal can not be reported as waste minimization on Form R.
The emphasis is placed on facility activities that reduce generation of wastes
and not treatment of wastes.
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XI. TRADE SECRETS
214. How can the identity of a listed toxic chemical be protected from
disclosure for trade secrecy purposes?
Section 313 allows only the specific identity of a chemical to be claimed as a
trade secret. The rest of the reporting form must be completed including
releases of the chemical. For trade secrecy claims, two versions of the form
(one identifies the chemical and one contains only a generic chemical
identity) and a trade secret substantiation form must be completed.
215. On Form R, if I don't check the "Trade Secrets" box in Part III Section
1.1, what other blocks can I leave blank? Do I still have to fill in the CAS
number?
If the chemical you are reporting is not a trade secret, the CAS number must
be filled in along with the chemical name (Part III, Section 1.3). However,
if you are reporting for a chemical category, no CAS number applies. Trade
secret claims require that the generic name (Section 1.4) be completed.
216. How can competitors find out what has been reported to EPA?
Any person, including a competitor, can gain access to the non-trade secret
reports received under section 313. All information received under section
313 is public information except the specific identity of the reported
chemical that is claimed trade secret. All non-trade secret information
reported will be available in a computer database.
217. For claiming trade secrets under Title III, would disclosure without a
confidentiality agreement to the State and/or city having jurisdiction negate
the chemical identity's trade secret status under Federal provisions?
In general, any disclosure of the chemical identity would negate the chemical
identity's trade secret status under Federal provisions. Once the trade
secret claim is made, State governors are permitted to request the specific
chemical identity, and they have the discretion as to whether they provide the
information to any State employees.
218. How will trade secret data be protected when EPA publishes health
effects notices for the public?
A generic statement of the health and environmental effects of the chemical
will be made available through the computer database.
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XII. CERTIFICATION AND SUBMISSION
219. Where and how do I get copies of the forms?
Copies of the form and other support documents may be obtained by contacting:
Emergency Planning and Community Right-To-Know Document Distribution Center,
P.O. Box 12505, Cincinnati, Ohio 45212.
220. Are there any extensions that a facility could get for filing Form R?
No, all toxic chemical release inventory forms must be postmarked no later
than July 1, and no extensions will be given.
221. Can computer generated forms be submitted for compliance with section
313?
The Agency has approved the facsimile outputs of certain privately developed
software packages. A list of the providers of software packages will be made
available by EPA.
222. What is the status of magnetic media submission (e.g., on tape or floppy
disk) for section 313 reports?
The Agency has published instructions for magnetic media submission. Contact
the Emergency Planning and Community Right-To-Know Information Hotline or
write to the Emergency Planning and Community Right-to-Know Document
Distribution Center.
223. The instructions state that photocopied versions of Part I may be
submitted. Does that mean that the senior official at a facility certifying
the validity of the forms only has to sign one submission?
No. The final rule states that each unique chemical submission must contain
an original signature. The purpose of this requirement is to ensure that the
certifying official has reviewed each chemical submission. A photocopied
signature does not fulfill this purpose and would be considered an incomplete
submission.
224. If a facility has a manager who is the originator of the data in the
form report, would he/she sign the form or would it be the facility manager to
whom this manager reports?
Your facility must make the determination regarding who meets the definition
in the rule of a "senior management official."
225. Are facilities required to include an original signature on forms going
to the State as well as EPA?
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An original signature on the certification statement is not required under
EPA's rule for the copy that is sent to the State. However, if the state
requires an original signature under their state right-to-know laws, the
facility must comply.
226. If the public contact item (Part I, Section 3.4) is left blank, can the
facility later use a public contact to speak to the news media on behalf of
the technical contact, who may not be publicly conversant?
If a public contact is not identified, EPA will enter the technical contact
into this information element in the database. Thus this person would receive
public inquiries. You may, of course, use any other person you choose to deal
with the public in response to such inquiries.
227. Regarding the technical contact, can this person be a different person
for (a) each chemical? (b) each separate part of a facility?
Yes. It is allowable to have different technical contacts for different
chemicals or different establishments within the facility provided that only
one "technical contact" is listed on each form.
228. On enforcement: Are your plans to go after non reporters first before
you begin "auditing" reports from complying facilities?
Enforcement efforts during 1989 will focus on identifying non reporters. In
addition, notices of non-compliance will be issued for forms containing errors
or omissions, allowing a period of time for corrections before penalties are
assessed. Also, submissions with questionable technical entries will be
investigated not purely as enforcement, but to identify problems in
calculating releases to improve EPA's guidance and instruction documents.
229. Are specific audit provisions in the regulations? Will audit results be
made public? Can released information be changed? What about resolving
differences of opinion, i.e., does the auditor have final judgement?
Specific audit provisions are not in the regulations. The Agency, however,
has the responsibility to assure that the data submitted is based on
reasonable estimates. Audit results will be used to identify problems with
calculating releases. In resolving difference of opinion, we expect that
final judgement will be made by the Agency.
230. What type of quality control check will EPA make on each form it
receives?
EPA plans to incorporate edit checks in the database to identify missing,
incomplete, incorrect, and suspect data elements.
231. How will questionable data be identified by EPA?
OTS is developing checks of completeness and, for some types of data,
reasonableness of an entry. For example, zero air emissions of a volatile
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chemical would be flagged. OTS envisions contacting the facility for
clarification of such "questionable" data.
232. The enforcement requirements of Title III (Section 325), state that the
civil and administration penalties for section 313 non-compliance shall not
exceed $25,000 for each violation. Is a non-compliance violation determined
on a per facility or per toxic chemical basis? Also, is that penalty assessed
on a per day basis?
Section 325(c)(i) states: "any person who violates any requirement of section
313 shall be liable to the United States for a civil penalty in an amount not
to exceed $25,000 for each such violation", for each day a violation
continues. Therefore, the facility can be assessed a penalty for each Form R
not submitted or willfully submitted wrong, and the penalty can be assessed on
a per day basis. EPA intends to assess penalties on a per chemical/facility
basis with the option of also including per day penalties depending on the
circumstances of the violation.
233. In some sections of Form R, facilities are asked to report "N/A" if that
section does not apply to a submission. Are blank spaces left on the form the
equivalent of "N/A"?
No. The rule requires "N/A" to be entered to inform the Agency that the
submitter has not just overlooked a section of the form. Leaving blanks would
be considered non-compliance with the rule.
234. Can a facility submit one original copy each of Parts I (Facility
Identification Information) and II (Off-Site Locations) with several copies of
Part III (Chemical Specific Information) for different listed chemicals?
No. The final rule clearly requires that each completed submission contains
all parts of Form R (including Part IV, even if it is left blank). Submission
of multiple copies of Part III, with only one copy of Parts I and II, would be
considered non-compliance. A Part I can be filled out once and photocopied
for inclusion in each report, but each copy of Part I requires an original
certification signature.
235. How can a facility be assured that the Agency has received a submitted
form?
To be acknowledged of receipt of submissions, facilities should send forms
using the U.S. Post Office "Return Receipt Requested" mail service. The
Agency will not respond to cover letters requesting acknowledgement.
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XIII. EPA'S SECTION 313 PROGRAM AND GENERAL INFORMATION
236. Where is the court case citation that defines Title III of the Superfund
Amendments and Reauthorization Act (SARA) as a distinct law separate from the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA)?
The court case was decided on August 25, 1987 in the U.S. Court of Appeals
(D.C. Circuit), case number 87-1334, A.L. Laboratories vs. EPA, 826 F. 2d 1123
(D.C. Circuit 1987).
237. Where will information on toxic chemical emissions and health effects be
made available?
The toxic release inventory database will provide information on the toxic
chemicals which are routinely released to the environment. A computer
database should be available to the public through the National Library of
Medicine's TOXNET computer system by the spring of 1989. Health and
environmental effects information on the §313 chemicals will also be available
through TOXNET. EPA also intends to make the data available on microfiche to
all county public library systems. In addition, EPA will publish a national
report summarizing the data submitted. A magnetic tape of the entire database
may also be purchased from NTIS.
238. Will EPA be calculating or monitoring concentrations of toxics in
ambient air?
The Agency plans to use the TRI data for the purposes of screening and
identifying potential environmental problems. To date, no decision has been
made regarding how the EPA program offices will utilize the TRI data.
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INDEX TO QUESTIONS
Article #3, #38, #41, #71, #74, #85, #88, #115, #118, #119,
#127, #130, #146, #147, #148, #149, #150, #151, #152,
#158,
Auxiliary Facility #26, #48, #49
Chemical Compounds #58
De Minimis #74, #88, #89, #98, #103, #114, #139, #140, #141,
#143, #144, #145, #158
Enforcement #144, #183, #221, #231, #232
Establishment #6, #9, #14, #23, #24, #25, #26, #28, #118, #31, #33,
#34, #35, #48, #49, #227
Exemption #3, #60, #74, #103, #116, #119, #121, #124, #125,
#126, #127, #128, #130, #132, #133, #135, #136, #137,
#141, #147
Fugitive Air #161
Generic Name #86, #215
Import #1, #14, #20, #44, #92, #96, #97
Laboratory #26, #132, #133, #134, #135, #136, #137, #138
Manufacture #1, #3, #11, #18, #19, #24, #26, #27, #39, #40, #42,
#44, #46, #47, #48, #49, #54, #70, #71, #78, #86,
#88, #90, #93, #95, #96, #97, #98, #99, #100, #101,
#102, #104, #105, #107, #108, #113, #116, #122, #130,
#132, #134, #135, #138, #141, #147, #169, #170, #179,
#189
Maximum Amount On-Site #63
Mixtures #37, #39, #46, #61, #64, #82, #83, #84, #86, #87,
#90, #91, #92, #93, #97, #104, #114, #115, #120,
#140, #141, #144, #150, #169, #173, #179
Off-Site Location #150, #177, #182, #203, #205, #206, #208, #234
Owner/Operator #2
Parent Company #17, #22
POTW #188, #197
Release Estimate #3
Release to Land #161, #162, #182
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Repackage #14, #47
Reporting Year #2, #4, #28, #95
SIC Codes #5, #6, #7, #8, #9, #10, #11, #26, #27, #33, #34,
#35, #40, #42, #48, #49, #88, #90, #93, #94
Supplier Notification #88, #90, #92, #93, #94
Threshold #1, #7, #11, #12, #19, #21, #24, #37, #38, #39, #40,
#41, #42, #43, #44, #46, #47, #48, #49, #54, #57,
#59, #60, #62, #63, #64, #70, #72, #76, ##78, #80,
#83, #84, #95, #96, #97, #100, #101, #102, #103,
#105, #106, #107, #110, #112, ##113, #114, #115,
#116, #118, #122, #127, #131, #132, #134, #135, #136,
#138, #140, #141, #144, #145, #146, #152, #157, #158,
#178, #197
Trade Name Products #87, #90, #140
Trade Secret #86, #214, #215, #216, #217, #218
Treatment Efficiency #188, #192, #193, #199
Treatment Method #197, #213
Underground Injection #123, #161
Waste Minimization #209, #210, #211, #213
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Tuesday
February 16, 1988
Part II
Environmental
Protection Agency
40 CFR Part 372
Toxic Chemical Release Reporting;
Community Right-to-know; Final Rule
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4500 Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 372
(OPTS-400002A; FRL 32M-21
Toxic Chemical Release Reporting;
Community Right-to-know
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Final rule.
SUMMARY: This rule contains the
uniform toxic chemical release reporting
form as required by section 313 of Title
111 of the Superfund Amendments and
Reauthonzation Act of 1986. Section 313
requires that owners and operators of
certain facilities that manufacture.
import, process, or otherwise use certain
toxic chemicals report annually their
releases of those chemicals to each
environmental medium. This rule also
requires certain suppliers of toxic
chemicals to notify recipients of such
chemicals in mixtures and trade name
products.
DATE: Th;.-> rule is effective March 17,
1988.
FOR FURTHER INFORMATION CONTACT
Sam K Sdsnett, Deputy Proiect
Coordinator (TS-779), Emergency
Planning and Community Right-to-Know
Hotline, Environmental Protection
Agency. Room. WH 562A. 401 M Street.
SW. (Washington, DC 20460. (800-535-
0202). In Washington, DC and Alaska.
202-T9-2449)
SUPPLEMENTARY INFORMATION:
I. Authority
The Agency is promulgating this rule
pursuant to sections 313 and 328 of Title
III of the Superfund Amendments and
Re-iuthonzat;cn Act of 1986, Pub. L. 99-
•449 (42 USC 11013 and 11028). Title III
is rflso ti'led "The Emergency Planning
and Community Right-To-Know Act of
1986 " Section 313 ot Title III requires
owners and operators of covered
facilities to report annually their
releases of listed toxic chemicals.
Section 313 also specifies that EPA must
publish a uniform toxic chemical release
form. In addition, section 328 provides
EPA with the authonty to promulgate
such regulations as may be necessary to
carry out the purposes of Title III.
II. Background
A Regulatory History and Summary of
Pubhc Participation
On October 17. 1986, the President
signed into law the Superfund
Amendments and Reauthorization Act
of 1986 (SARA). Pub. L. 99-499. The
major function of this legislation is to
amend and reauthorize provisions of the
Comprehensive Environmental
Response. Compensation, and Liability
Act of 1980 (CERCLA). However, Title
HI of SARA is a free-standing statute
(not part of CERCLA) that is titled "The
Emergency Planning and Community
Right-To-Know Act of 1986." In general.
Title 111 contains authorities relating to
emergency planning, emergency
notification, community right-to-know
on chemicals, and a toxic chemical
release inventory.
The focus of this rule is the toxic
chemical release inventory provision
contained in section 313 of Title 111 of
SARA. Section 313 requires owners and
operators of certain facilities that
manufacture, process, or otherwise use a
listed chemical to report annually their
releases of such chemicals (o any
environmental medium. The reports are
to be sent to both EPA and the State in
which the facility is located. The basic
purpose of this provision is to make
available to the public information
about releases of certain toxic chemicals
that result from operations of certain
facilities in their community.
EPA issued a proposed rule, published
tn the Federal Register of June 4,1987 (52
FR 21152). The proposed rule contained
the toxic cherrucal release inventory
reporting form and interpretive
requirements for reporting. The
preamble of the proposed rule outlined
the public participation activities that
led up to the development of the
proposal. After publication. EPA
received over 100 written comments on
the proposed rule, in addition. EPA held
public msetings in \\ ashmgton. DC.
Chicago, II. and San Francisco, CA.
Attendees at these meetings presented
oral comments representative of wide
range of interests including the affected
industry, environmental and other
public interest groups. State and local
governments, and individual citizens.
In addition. EPA has held other
meetings with, and received other
communications from, interested parties.
8. Overview of Final Rule Requirements
The reporting requirements of this rule
apply to owners and operators of
covered facilities that manufacture,
process, or otherwise use listed toxic
chemicals. A covered facility is one that:
Has 10 or more full-time employee*.
Is m SIC codes 20 through 39.
Exceeds an applicable manufacture.
process, or use threshold.
EPA interprets "in SIC codes 20
through 39" to relate to the primary SIC
code of the facility If Ihe facility is
comprised of multiple establishments,
facility coverage is based on a relative
comparison of the value of products
shipped and/or produced at 20 through
39 establishments versus non-20 through
39 establishments in that facility.
EPA has included a definition of "full-
time employee" and guidance on
determining SIC coverage.
EPA has not included a small business
exemption in this rule different from that
provided by section 313. However, the
Agency is allowing reporting in ranges
for releases to an environmental
medium and for off-site transfers of
wastes that are below 1.000 pounds per
year. EPA expects that small businesses
will benefit most from this provision.
The range reporting is for calendar years
1987.1988. and 1989 only.
The thresholds are those provided by
the statute:
For manufacturing or processing as
defined—75.000 pounds for 1987. 50.000
pounds for 1988. 2S.OOO pounds per year
for 1989 and thereafter.
For toxic chemicals otherwise used
the threshold is 10.000 pounds per year
for all years.
Reports must be submitted annually
on or before July 1 for the preceding
year's data.
The chemicals subject to reporting
initially are those chemicals as provided
by section 313(c). with certain technical
modifications.
Additions or deletions of chemicals
from the list may result from petitions or
EPA's own review of the list. Any such
changes will be by notice and comment
rulemakjng. and EPA will identify the
reporting years which they apply.
Mixtures and trade name products
imported, processed, or used at a facility
must be evaluated for the presence of
listed toxic, chemicals. However, EPA
has applied a de mininus concentration
limitation of 1 percent (or 0.1 percent if
the chemical is a carcinogen) consistent
with ;he Occupational Safety and
Health Administration (OSHA) Hazard
Communications Standard (HCS) in 29
CFR 1910.1200. Toxic chemicals present
in concentrations below the de minimis
limit do not have to be factored into
threshold ar.d release reporting
calculations.
In relation to reporting on mixtures.
EPA has developed a supplier
requirement. Owners or operators of
facilities m SIC codes 20 through 39 who
supply mixtures or trade name products
containing listed toxic chemicals must
notify their customers about the
presence and concentration of those
chemicals in their products. However.
the de mir.imis limit as described above
also applies to this requirement. The
supplier notification requirement lakes
effect with the first product shipment >n
1980.
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Federal Register / Vol. 53, No. 30 / Tuesday, February 16. 1988 / Rules and Regulations 4501
Certain definitions .have been
modifed. The definition of "article" has
been revised to more closely parallel the
OSMA HCS article definition. In
addition, article processing or use is
exempt from threshold and release
detenr.inations under this rule.
However, respondents must pay careful
attention to the non-release criteria in
this definition.
The definition of "manufacture"
retains the interpretation that
coincidentally produced impurities and
other byproducts must be accounted for.
However, the consideration of an
impurity is subject to the above-
referpnced de minimi's limitation. This
de rr.tnimis limitation does not apply to
the byproducts produced coincidentally
as a result of manufacturing, processing,
use. waste treatment, or disposal.
EPA has attempted to clarify the
differences between processing and use.
Processing activities are basically those
that incorporate a chemical into a
product for distribution in commerce.
Use activities are primarily non-
incorporative activities.
A new part of the rule is an
exemptions section. The major function
of this section is to outline activities that
are not subject to certain requirements.
In particular, this section exempts
activities in laboratories from threshold
and release determinations.
There are a number of specific
changes from the proposed rule in Form
R. the Toxic Chemical Release Inventory
Reporting Form. The form is more
modular in design in order to reduce the
frequency of the same information
having to be filled in for each chemical-
specific submission. Other specific
changes are as follows:
1. The certification statement (Part 1,
Section 2) has been modified.
2. The facility identification section of
the form (Part 1. Section 3) contains the
name and telephone number of a public
contact person for the facility. In the
first reporting year, if this information is
available, the facility must provide its
latitude and longitude. In subsequent
years, if this information is not readily
available, the facility must develop it
and provide it.
3. In the chemical identity section of
the form (Part III, Section 1) one change
in the reporting requirements affects the
generic chemical identity to be provided
in cases where the specific chemical
identity is claimed trade secret. The
respondent it to develop its own generic
chemical name rather than using a
predefined generic name as EPA had
proposed. The generic name is to be
structurally descriptive of the chemical.
Reporting may also be based on a
genetically identified mixture or trade
name product component. (See Part 111.
Section 2 of the form.) This reporting
would occur in cases where a user has
information that a genencally identified
component of a mixture or trade name
product is a section 313 chemical that.
by itself, exceeds a threshold but the
user does not know the specific identity.
4. The release reporting section of the
form (Part IIL Section 5) contains
several modifications. As mentioned
above, for calendar years 1987,1988,
and 1989. facilities may take advantage
of range reporting check boxes for
releases of a toxic chemical to an
environmental medium of less than 1.000
pounds per year. The releases to water
portion of the form has been
disaggregated by stream and
respondents must indicate what
percentage of the release was
contributed by stormwater runoff if they
have monitoring data. In addition,
underground injection of wastes at a
facility must be entered on a specific
line in the release section.
The proposed columns indicating
section 304 releases or that a permit
applies to releases have been deleted
from the final form.
5. EPA has included the reporting of
transfers of section 313 toxic chemicals
in waste to off-site locations. However.
these transfers are to be reported in a
separate section of the form (Part 111.
Section 6).
a. The waste treatment section of the
form remains unchanged from the
proposal except that EPA has provided
for reporting sequential waste treatment.
7. The optional section on waste
minimization has been retained but the
narrative part of this section has been
removed. A 3-year sunset provision will
apply to this form section.
8. The form also contains a
Preformatted supplemental information
sheet (Part IV).
IIL Issues Relating to Facility coverage
A. Interpretation of SIC Code Coverage
Standard Industrial Classification
(SIC) code coverage is one of three
criteria specified in section 313(b) for
determining whether a facility is subject
to reporting. The preamble of the
proposed rule stated that "in SIC codes
20-39" meant that the primary SIC code
for the facility is within the 20 through
39 designations. The proposed rule also
included facilities that engage in one or
more activities in SIC codes 20 through
39 even if the primary SIC code for the
facility itself is not SIC 20 through 39.
Many commenters argued against
including "secondary" SIC activities.
First commenters stated that the
definition of a facility is the whole
collection of buildings, not parts thereof.
Second, they argued that SIC codes are
used to define the primary purpose of an
establishment, nol all activities.
Therefore, including facilities that
engage in activities in SIC code 20
throuah 39 but for which the primary SIC
code for the facility is outside SIC code
20 through 39 is in direct contradiction
to the established assignment ar.d usage
of SIC codes Third, commenters s'.ated
that it exceeded the intent of the
legislation and stretched the capabilities
of the industrial classification system.
Finally, the commenters stated that any
increase in SIC code coverage should be
through discrete and more focused
rulemakings, as prescribed in section
313(b)(l)(B) and (b)(2), with substantial
sector-by-sector justification to warrant
increased reporting on non-
manufacturing sectors.
The SIC code system was developed
to calssify establishments by type of
economic activity. A SIC code applies to
an establishment, which was defined as
an economic unit, generally at a single
physical location, where business is
conducted or where services or
industrial operations are performed. SIC
codes are not directly applicable to
facilities as defined in section 329(4) of
Title III and this rule. A "facility" is
defined as all buildings, equipment,
structures, and other stationary items
which are located on a single site or
adjacent contiguous sites owned or
operated by the same person. Therefore.
a facility can be a much larger, more
complex operation than an
establishment. The definition of primary
SIC code is generally considered to be
the code related to the types of products
distributed from an establishment that
have the highest dollar value added.
Based on the public comments
received on the proposed rule, the
Agency has revised its interpretation of
"in SIC Codes 20 through 39." The
revision is designed to remove the
confusion and ambiguity in the proposed
rule caused by linking the concepts of
facility and primary SIC code. The final
rule provides that a facility is m SIC
codes 20 through 39 based on the SIC
codes for the one or more
establishments that comprise the
facility.
EPA has identified the following three
possible scenanos relating
establishments. SIC codes, and facilities:
1. The establishment is the some as
the facility. Where an establishment is
the same as a facility, given that the
other eligibility criteria are met, ar.d the
establishment's primary SIC code is in
20 through 39. die facility is covered for
purposes of reporting. Because there is
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4502 Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations
no distinction between the
establishment and the facility, reporting
of releases from the facility it
straightforward.
2. The facility is comprised of two or
more establishments, all of which have
a primary SIC code of 20 through 39. For
multi-establishment facilities, when all
of the establishments' primary SIC
codes are in 20 through 39, given that the
other eligibility criteria are met for the
facility, the facility is covered for
purposes of reporting.
3. The facility is comprised of two or
more establishments, one or more of
which have a primary SIC code of 20
through 39. For multi-establishment
facilities when one or more of the
establishments' primary SIC codes are
in 20 through 39, the facility is covered
for purposes of reporting if either of the
following criteria apply for the reporting
year:
a. The sum of the value of products
shipped from and/or produced at all
establishments with primary SIC codes
in 20 through 39 is greater than 50
percent of the total value of products
shipped from and/or produced at all
establishments that comprise the
facility.
b. One establishment whose primary
SIC code is in 20 through 39 has a value
of products shipped and/or produced
that is larger than that of any other
establishment in the facility.
Facilities may refer to data they
submitted to the U.S. Department of
Commerce. Bureau of the Census, for the
Annual Census of Manufacturers (Form
MA-1000) to calculate the relative
values of products shipped and/or
produced.
Once a facility is covered in either of
the above cases, all releases of listed
toxic chemicals must be accounted for,
even from individual establishments in
the facility that fall outside of the 20
through 39 SIC codes.
B. Reporting by Multi-Establishment
Facilities
Several commentera raised the
concern that it will be difficult for
facilities consisting of more than one
establishment to submit • tingle report
covering the entire facility. Commenters
noted that individual establishments,
owned by the same parent company,
often have different management lines
of authority within the company. In
these cases, commentera noted, it would
be difficult to combine information into
one reporting form.
As explained in A. of this unit the
facility it the unit that it responsible for
reporting. While EPA could continue to
require a tingle tubmittion for multi-
establishment facilitiet, EPA hat
decided to require a compliance
determination by the whole facility
covering all its establishments, but to
allow individual establishments or
groups of establishments to report
separately, provided all releases and
waste treatment methods are accounted
for. However, if individual
establishments or groups of
establishments report separately for one
chemical they must continue to report
separately for all other chemicals at the
facility.
Under this approach the entire facility
must determine compliance as a single
unit. Thus the Agency ensures no
reporting will be missed because certain
individual establishmentt do not meet
thresholds for employees or chemical
activities. For example, a facility is
comprised of two establishments, with
combined employment totaling 60 full-
time workers. Establishment A uses
5,000 pounds of benzene and
establishment B uses 8.000 pounds of
benzene. The facility as a whole
exceeds 10 full-time employees and
combined use by both establishments
exceeds the 10.000 pound threshold for
the use of benzene at the facility.
Therefore this facility must report for
benzene. It has two options. It can file a
report that represents the combined
data associated with all activities with
benzene at both establishments.
Alternatively, both establishments can
file separate reports accounting for their
individual releases and other related
data. If both establishments file separate
reports, then they must submit separate
reports for all chemicals subject to
reporting. However, if, for example, a
toxic chemical is used at one
establishment but is not present at all at
the other establishment, only the
establishment that uses the chemical
must report for that chemical.
The form provides a way for users of
the data to know whether all or only
part of a facility is included in a specific
report. Check boxes correspond to (1)
the entire covered facility or (2) one or
more establishments within a covered.
multi-establishment facility.
A second issue regarding multi-
establishment facilitiet relates to the
requirement that the owner or operator
of a facility must report. EPA proposed
that if no report was filed, both the
owner and operator (if different) would
be liable. Commenters requested
clarification on the liabilities -and
obligation! of an owner of leased
property, where the owner's interest is
solely one of real estate. These
commenten believe that such an owner
should not have obligation! to report
because it it not in a position which
would allow it to determine compliance
or report the required information. The
owner would not be able to submit a
report without the cooperation of the
operator.
EPA recognizes these difficulties. The
final rule exempts certain owners of
leased property from reporting
requirements. These exemptions apply
only to those owners of property who
have no business interest in the property
other than real estate. Owners who are
part of the same business organization
as the operators would not be exempt.
nor would owners of businesses that
contract out the operations of a
particular site. In these cases, the owner
has a business interest beyond that of
the real estate and has the ability to
exert some control over the operator.
A commenter identified an additional
problem that occurs when the
establishments in a multi-establishment
facility are operated by different
persons which have no common
corporate relationship, such as in an
industrial park. EPA identified two
possible scenarios. In the first scenario.
the owner of the facility operates an
establishment in the facility but leases a
portion of the facility to another person
who operates another establishment.
The owner and this other operator do
not have any business relationship other
than landlord and tenant. Also, the
owner does not know what chemicals
are manufactured, processed, or used in
that operator's establishment. In the
second scenario, the owner of the
facility, having only a real estate
interest in the facility, does not operate
any establishment in the facility and
leases all of the facility to two or more
persons who operate establishments in
the facility. Under the exemption
discussion above, the owner would not
be subject to reporting. However, in
both scenarios, the operators would be
subject to reporting, but they have no
common corporate or business interest
and do not know what chemicals are
manufactured, processed, or used in
each other's establishments.
In neither of these situations it one
person in a position to know all of the
information necessary to make a
determination whether the facility as a
whole is a covered facility and whether
a toxic chemical is manufactured.
processed, or used at the facility in
excess of an applicable threshold.
Accordingly, EPA hat decided that, in
such a situation, each operator should
treat the establishments it operates as a
facility for purposes of reporting. These
operators must make the determinations
under the rule for SIC code coverage.
number of full-time employees, and
whether a toxic chemical it
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Federal Register / Vol. 53. No. 30 / Tuesday, February 16. 1988 / Rales and Regulations 4503
manufactured, processed, or otherwise
usnd in excess of an applicable
threshold, but only for those
establishments they operate.
Appropriate provisions have been
added to the rule. form, and instructions
to provide for this approach. To ensure
that related companies do not avoid
reporting for multi-establishment
facilities. EPA has limited use of this
approach to operators of separate
establishments in the same facility who
do not have any common corporate or
business interest, i.e. they are not
engaged in partnerships, joint ventures,
ownership of a controlling interest in
one by the other, or ownership of a
controlling interest in both by a third
person.
Another situation may arise where a
person owns a parcel of land on which it
operates one or more establishments
and also leases land immediately
adjacent to it on which that same person
operators one or more additional
establishments. Section 329(4) of Title III
defines "facility" to include "a single
site or * * * contiguous or adjacent sites
* * * which are owned or operated by
the same person * * *." Thus in this
situation the "facility" would be the
total site including the land owned by
the person and the adjacent land leased
by the person. To make the SIC code
determinations and reporting threshold
determinations, the person is required to
consider the activities at all the
establishments he or she operates on the
total site. Having made the
determinations that the total facility is a
covered facility and that an applicable
reporting threshold has been met, the
person may submit separate reports for
the establishments as described above.
C. Auxiliary Facilities—Laboratory
Activity Exemption
Commenters requested that EPA
clarify whether auxiliary operations
which have primary SIC codes within 20
through 39 (manufacturing) are covered
for purposes of section 313 reporting.
Auxiliary establishments are defined
under the SIC code system as operations
which primarily support other
establishments, Common types of
auxiliary operations are research and
development laboratories, warehouses.
storage facilities, and waste treatment
facilities. The SIC code system assigns
these facilities SIC codes according to
the establishment they service; thus.
auxiliary establishments tied to
manufacturing establishments are given
a manufacturing SIC code.
Commenters argued that the statute
did not contemplate including
establishments that do not engage in
manufacturing. They stated further that
EPA has the discretion to modify the
facility coverage criteria to correct such
anomalies.
1. Auxiliary facilities must make a
compliance determination. EPA has
determined that the most consistent way
to treat a stand-alone auxiliary
establishment (i.e. one that is not a part
of a larger facility) is to require that it
make a compliance determination. If
such an establishment is classified in
SIC codes 20 through 39 because it
supports a manufacturing activity, it
must review its chemical activities and
the level of such activities to determine
if it must report. It is possible that an
establishment such as a warehouse
standing alone will not be subject to
reporting. If no manufacture (including
importation), processing (including
repackaging}, or use of covered toxic
chemicals occurs, the facility is not
subject.
Similarly, persons who own or
operate auxiliary establishments that
are within the defined boundaries of a
larger multi-establishment facility must
review the manufacture, processing, or
use activities involving listed toxic
chemicals at all the establishments in
the facility. Such auxiliary
establishments must be factored into the
"value of shipments and/or production"
calculation to the extent it is applicable.
and must be counted toward the
employee threshold. The activity of
manufacturing, processing, or using a
toxic chemical in the auxiliary
establishment counts toward the
chemical thresholds for the facility.
2. Exemption of laboratory activities.
Commenters stated that it would be
burdensome to require laboratories to
determine whether they must comply
because of the potentially large number
of mixtures and chemicals on-site in
small volumes and the relatively rapid
turnover of such chemicals and mixtures
in the laboratory setting.
EPA agrees with comments that
manufacturing, processing, or use of
chemicals in a laboratory under the
supervision of a technically qualified
individual should be exempt from the
provisions of this rule. This exemption is
consistent with the exemption provided
in rules implementing sections 311 and
312 of Title III. and the OSHA HCS. The
exemption does not apply to specialty
chemical production or pilot plant scale
operations.
The Agency believes that this
exemption provides a consistent and
necessary reduction m the reporting
burden. For example a stand-alone
laboratory is classified in SIC codes 20
through 39 because it is an auxiliary
facility supporting a manufacturing
operation of a company. This laboratory
is. in essence, exempt from the threshold
determination and reporting
requirements of this rule. Also a covered
facility will not have to review chemical
manufacture, processing, or use in a
laboratory within that facility, provided
such operation is not conducting
specialty chemical production or pilot
plant scale activities.
If a toxic chemical is removed from
such a laboratory for further processing
or use in the facility, the facility must
factor such amounts into threshold
determinations and release reporting.
The Agency does retain certain
concerns about releases of toxic
chemicals from laboratories. Therefore,
EPA will review laboratories as part of
its overall review of the types of
facilities that should be covered by
amendments to this rule.
D. The Rule Contains no Modification of
Facility Coverage
EPA has discretionary authority to
modify the coverage of facilities under
section 313(b)(l)(B). The report of the
congressional conference committee for
Title III states that any such
modifications are limited "* * " to
adding SIC codes for facilities which.
like facilities within the manufacturing
sectors SIC codes 20 through 39,
manufacture, process or use toxic
chemicals in a manner such that
reporting by these facilities is relevant
to the purposes of this section." (H.R.
Rep. No. 962. 99th Cong.. 2nd sess. 292—
hereafter referred to as the conference
report.) The conference report further
states that section 313(b)(l)(B) is given
to provide EPA with the authority to
adjust coverage but that "it does not
provide EPA the authority to change the
overall scope of the reporting program
for Toxic Chemical Release Forms." Id.
at 293.
The Agency proposed that facilities
within SIC codes 20 through 39 be
required to report. Comments from trade
associations, private companies, State
agencies, public interest groups and
academia requested that EPA use its
authority under section 313(b)(l)(B) to
include other facilities. These
commenters noted that other kinds of
facilities beyond those in the
manufactunng sector can have
significant releases of toxic chemicals.
They contend that if the current scope of
reporting is not expanded, the public
will not realize that manufacturing
releases constitute only a part of the
total releases of these chemicals into the
environment.
Most commenters provided specific
examples of facilities that they would
like to see added. They include:
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4504 Federal Register / Vol. 53. No. 30 / Tuesday, February 16. 1986 / Rules and Regulations
Commercial waste treatment facilities,
transportation sites, federal facilities.
municipal waste treatment facilities and
publicly owned treatratnt works,
disposal sites, petroleum and chemical
bulk stations and terminals, tank farms,
electrical services, petroleum
wholesalers, farm suppliers, paint and
varnish suppliers, and industrial
launderers. Commenters suggested that
SIC codes should not be a primary
determinant of coverage and that EPA
should consider the intent of the law to
provide citizens information about
releases from all important sources of
emissions.
Modification of facility coverage
could also involve deletions of certain
industries from the currently covered
SIC codes. In deleting SIC codes the
Agency will consider to what extent
certain manufacturing operations
produce or use toxic chemicals in a
manner more similar to operations
outside the manufacturing sector. The
conference report includes an example
of such an operation for facilities within
SIC code 2875 that mix or blend
fertilizer products for sale at the retail
level. It is also possible that certain
manufacturing operations, for example
those that conduct simple article
assembly, may not produce, import.
process, use, or release significant
amounts of covered toxic chemicals. If
by the inherent nature of their activities
such facilities are unlikely to otherwise
be subject to reporting, then it would
serve no purpose to continue to include
them in the SIC code designations.
The Agency is choosing not to modify
the facility coverage of the rule at this
time. The issues raised in the comments
are important ones for EPA to consider
in exercising its authority to modify
coverage. Such issues should be dealt
with through full notice and comment
rulemaking. The Agency must carefully
evaluate additional types of facilities
that may be manufacturing, processing.
or using listed toxic chemicals as well as
facilities in SIC codes 20 through 39 that
do not handle such chemicals. EPA is
planning to initiate an evaluation of
facility coverage in 1988. Af part of this
analysis. EPA will examine the
predominant activities in SIC codes 20
through 39. The results of this evaluation
and any recommended additions or
deletions to the scope of covered
facilities will be published as a
proposed amendment io this rule.
As part of this analysis EPA will also
look at the concept of value of products
shipped and/or produced from
designated SIC code establishments.
Another potentially more equitable
approach of determining multi-
establishment facility coverage is by
using "value added" instead of the value
of products shipped and/or produced
The value-added approach may create
less distortion and duplication when
comparing the contribution by
individual establishments for purposes
of the overall facility coverage
determination. However, value-added
information may be less available and
more burdensome to determine than
value of shipments and/or production.
EPA will review the first few years of
reported data and will attempt to
evaluate how the value of shipments
and/or products approach affects
overall facility coverage.
IV. Definitional Issues
A. Definition of Manufacture
1. Coincidental production of toxic
chemicals. EPA proposed to interpret
"manufacture" to include coincidental
production of a listed toxic chemical as
a byproduct or impurity during the
manufacture, processing, use. or
disposal of any other chemical
substance or mixture. Congress adopted
the definition of "manufacture" used in
regulations under the Toxic Substances
Control Act (TSCA) where such an
approach is used. The proposed rule's
approach was intended to cover those
situations in which a listed toxic
chemical is created (intentionally or
unintentionally) and then passed on in
commerce or disposed of, but never
otherwise accounted for.
Commenters objected to this
interpretation of the manufacture
definition on grounds that it exceeded
the statutory authority of Title III. They
also stated that having to make such
determinations would require
expensive, detailed monitoring that most
facilities do not do and would not be
required to do under section 313. Other
commenters stated that, if such a
determination were required, a de
minimis cut-off should apply, consistent
with OSHA HCS requirements, to
reduce the burden on the facility.
EPA believes that the definition of
manufacture in section 313 includes the
coincidental production of toxic
chemicals. Section 313(b)(l)(C) states
that "[t]he term 'manufacture' means to
produce, prepare, import, or compound a
toxic chemical." There is no limitation in
this definition that would exclude
manufacture of a toxic chemical
coincidental to the production.
processing,'use. or disposal of another
chemical, nor is there any indication in
the legislative history of Title III that
Congress intended to exclude toxic
chemicals produced coincidentally.
Accordingly, EPA believes that such
production is included in the definition
of manufacture under section 313. For
purposes of the rule however. EPA has
distinguished between toxic chemicals
which are impurities that remain with
another chemical that is processed.
distributed, or used, from toxic
chemicals that are byproducts either
sent to disposal or processed.
distributed, or used in their own right.
EPA also considers that it would be
reasonable to apply a de minimis
concentration limitation to toxic
chemicals that are impurities in another
chemical or mixture. In essence, the de
minimis cut-off adopted for mixtures
(see Unit VI.) would apply to the
presence of impurities created as a
result of making that mixture, or a
component of the mixture. Because the
covered toxic chemical as an impurity
ends up in a product, most producers of
the product will frequently know
whether the chemical is present in
concentrations that exceed the de
minimis level, and, thus may be listed
on the Material Safety Data Sheet
(MSDS) for that product under the
OSHA HCS.
This final rule does not adopt a de
minimis concentration limitation in
connection with the production of a
byproduct. EPA believes that the facility
should be able to quantify the annual
aggregate pounds of production of a
byproduct which is not an impurity
because the substance is separated from
the production stream and used. sold, or
disposed of, unlike an impurity which
remains in the product.
The major problem with applying a de
minimis exemption to a toxic chemical
produced as a result of use or disposal
of another chemical is the difficulty of
determining where and how to make a
precentage determination. For example.
there may be various points in a
treatment process at which a percentage
determination could be taken. Also.
those doing a better job of treatment
could be unfairly penalized because
such treatment may concentrate the
chemical in waste prior to disposal.
Therefore, the conscientious facility may
exceed the de minimis concentration of
the toxic chemical in a waste whereas
another facility having much more dilute
waste would not be subject to reporting.
Therefore. EPA believes that the
estimation of a total annual mass
quantity for such coincidental
production during use or disposal is a
fair approach.
In any case, EPA wishes to emphasize
that the determination of such
coincidental production should be based
on the facility's existing production
records, monitoring, or analytical data.
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Federal Register / Vol. 53. No. 30 / Tuesday, February 16. 1988 / Rul^s and Regulations 4505
and reasonable judgment on the part of
the facility's management. No further
monitoring or analysis of production,
process, use. or disposal streams is
required, consistent with section 313.
2. Import of toxic chemicals. Section
313(b)(l)(c) defines "manufacture" to
include import. Thus the owner or
operator of a facility that manufactures
or imports a toxic chemical is
potentially subject to the reporting and
supplier notification provisions of the
final rule, if a toxic chemical is both
manufactured and imported at a facility.
the total amount manufactured and
imported is aggregated for purposes of
determining whether the reporting
threshold for manufacturing has been
met. Thus it is important for a facility to
determine whether it 11 importing a toxic
chemical, either in relatively pure form
or as part of a mixture.
The U.S. Customs Service defines an
importer as a person who imports a
chemical into the customs territory of
the United States anJ includes the
person primarily liable for the payment
of any duties on the merchandise or an
authorized agent acting on that person's
behalf, the consignee, the importer of
record, the actual owner if an actual
owner's declaration and superseding
bond hds been filed in accordance with
19 CFR 141.20, and the transferee, if the
right to draw merchandise in a bonded
warehouse has been transferred in
accordance with Subpart C of 19 CFR
Part 144.
Section 313 refers to a facility which
manufactured (including imported) a
toxic chemical. Section 313 does not
define "import" or explain when a
facility is considered to have imported a
chemical. Given the broad Customs
definition of who is an importer, several
persons may be "importers" for any
given shipment of a toxic chemical
brought into the customs territory of the
U.S. For example, a facility may conduct
the entire import transaction using its
own personnel in which case it would
be the only importer. In other cases,
facilities may act through import brokers
or others who do the paperwork and pay
the duties but provide for direct
shipment of the chemical to the facility.
EPA determined that for a given
imported shipment of a toxk chemical,
only one facility should be considered to
have imported the shipment. Otherwise,
there could be double counting of each
shipment. Thus for purposes of the final
rule, EPA has defined "import" to mean
to cause a chemical to be imported into
the customs territory of the U.S. For
purposes of the definition of "import"
EPA has defined "to cause" in a way
which designates the person who in
effect controls the importing of the
chemical, Le. the person whe intends
that it be imported and controls the
identity of the chemical and the amount
to be imported, not those who are
merely involved in the transaction.
Accordingly, through this definition, a
facility which completes the entire
import transaction for toxic chemical
using its own personnel would be
considered to have imported the
r.hemical. Further, a facility that ordered
the import of a toxic chemical through
an import broker, specifying the identity,
amount, and that it is to be imported.
also would be considered to have
imported the chemical. However, if a
facility ordered a toxic chemical from a
chemical supplier in the U.S.. who in
turn decided to import the chemical to
fill the order or filled the order from a
previously imported stock of the
chemical, the chemical supplier's facility
would be considered to have imported
the toxic chemical. The facility which
ordered the chemical would not be
considered to have imported the
chemical because it did not control the
amount to be imported or specify that it
was to be imported.
In most cases, determining whether a
facility caused the import of a toxic
chemical will not be critical because a
facility in SIC codes 20 through 39 which
receives such a toxic chemical from an
import shipment is also likely to process
or otherwise use the chemical. Since the
thresholds for manufacturing and
processing are the same and the use
threshold is lower than the
manufacturing threshold, EPA does not
believe that defining "import" in this
way will result in any facility escaping
the reporting requirements of the final
rule. In addition. EPA does not believe
that facilities will evade supplier
notification requirements under this
approach.
3. Toll Manufacturers of Toxic
Chemicals. EPA recognizes that it is a
practice in the chemical industry for one
company to contract with another
company to produce a chemical
exclusively for it. This may be done to
use available production facilites, to
take advantage of cheaper production
techniques, or to avoid building
additional plant capacity. The company
initiating the activity typically retains
control over the identity of the chemical,
the amount to be produced, and the
production technology. The company
actually producing the chemical in these
situations is often referred to as a "toll
manufacturer."
Under TSCA. which authorizes EPA to
apply certain requirements to persons
who manufacture chemical substances
and mixtures, EPA has sometimes
treated both companies in a toll
manufacturer relationship as
"manufacturers" subject to the
requirements. However, for purposes of
section 313 reporting. EPA interprets the
definition of manufacture to apply only
to a facility that actually produces a
toxic chemical. Thus, in a toll
manufacturer situation, the facility
actually producing a toxic chemical
would be subject to reporting, if it
produced more than the threshold for
manufacturing. The other company's
facility would be subject to the reporting
for that chemical only if it also actually
manufactured the chemical in excess of
the manufacturing threshold, or if it
processed or otherwise used the
chemical in excess of an applicable
threshold. EPA believes this
interpretation is consistent with
congressional intent to capture releases
associated with manufacturing
activities.
B. Clarifications Regarding Process and
Otherwise Use; Exemption of Certain
Uses
EPA included the statutory definition
of "process" in the proposed rule and
proposed a definition of "otherwise
use." The statute does not specifically
define "use" or "otherwise use" yet
there are different reporting thresholds
associated with manufacturing and
processing activities versus the
"o'herwise using" of a listed toxic
chr-mical. Therefore, the basic purpose
of including a definition of "otherwise
use" was to distinguish for the potential
respondent what activities would be
subject to the different thresholds. The
proposed "otherwise use" definition was
broad in scope, basically encompassing
all uses of a chemical at a facility not
covered by the definitions of the terms
"manufacture" or "process." The
preamble of the proposed rule contained
one example of processing versus use of
a chemical, and the proposed
instructions for the form gave examples
of manufacturing, processing, and use
activities.
Commenters from industry took issue
with the proposed definition of
otherwise use and requested further
clarification of the differences between
processing and use activities. Still other
commtjnters recommended that certain
uses be exempted from the final rule
reporting requirements.
1. Clarification of the terms "process"
and "othenvise use". In the public
meetings, workshops, and in a
preliminary question and answer
document on section 313 issues, EPA
has made the following basic distinction
between processing and use activities.
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4506 . Federal Register / Vol. 53. No. 30 / Tuesday. Februaiv 16. 1988 / Rules and Regulations
a. Processing is an incorporative
activity. The process definition focuses
on the incorporation of a chemical into a
product that is distributed in commerce.
This incorporation can involve reactions
that convert the chemical, actions that
change the form or physical state of the
chemical, the blending or mixing of the
chemical with other chemicals, the
inclusion of the chemical in an article, or
the repackaging of the chemical.
Whatever the activity, a listed toxic
chemical is processed if (after its
manufacture) it is ultimately made part
of some material or product distributed
in commerce. Examples of the
processing of chemicals include
chemicals used as raw materials or
intermediates in the manufacture of
other chemicals, the formulation of
mixtures or other products where the
incorporation of the chemical imparts
some desired property to the product
(e.g . a pigment, surfactant, or solvent),
the preparation of a chemical for
distribution in commerce in a desirable
form, state, and/or quantity (i.e.
repackaging), and incorporating the
chemical into an article for industrial.
trade, or consumer use.
b. Otherwise use is a non-
incorporative activity. EPA is
interpreting otherwise using a covered
toxic chemical to be activities that
support, promote, or contribute to the
facility's activities, where the chemical
does not intentionally become part of a
product distributed in commerce.
Examples would be a chemical
processing aid such as a catalyst.
solvent, or reaction terminator. These
chemicals may be integral parts of a
reaction but do not become part of a
product. Other examples would be
manufacturing aids such as lubricants.
refrigerants, or metalworking fluids, or
chemicals used for other purposes at the
facility such as cleaners, degreasers, or
fuels.
2. Comments relating to EPA s
interpretive distinction derween process
and use. One commenter disagreed with
EPA's interpretation that a non-
mcorporative use of a solvent in
chemical processing should be classified
as otherwise using it. This commenter
stated that the solvent can be integral to
a reaction and that the solvent can be in
the same equipment as other processed
chemicals, with the same low
probability of release. Another
commenter stated that a catalyst should
not be classified as a processing aid (i.e.
otherwise used) because it participates
in a reaction. EPA disagrees with these
comments on the grounds that it is
necessary and appropriate to distinguish
processing from otherwise using based
on the thrust of the process definition
(i.e., whether :he toxic chemical in
question becomes part of some product
distributed in commerce).
Another commenter raised the
example of a paint that is applipd during
the manufacture of automobiles Certain
toxic chemical components of the paint
mixture would become part of the
automobile and other toxic chemicals
such as the solvents would evaporate as
intended. Is the mixture processed, used.
or both? EPA's interpretation is that the
activity of each relevant component of
the mixture would have to be evaluated.
The solvents would be "used."
Therefore, they would be subject to the
10.000 pound threshold. The other
components of the mixture such as the
pigments, would be "processed"
because they are incorporated into the
article. Therefore, those mixture
components would be subject to
reporting based on the process
threshold.
3. Exemptions of certain uses. Several
commenters stated that the proposed
definition of otherwise use was too
broad. They stated that without some
limitations or exemptions the presence
at the facility of a listed chemical in any
form would have to be factored into
threshold calculations. One example
given was copper in copper pipes that
are part of the facility. This can be
interpreted as an ancillary use of
copper. They claimed that such a
situation would be unreasonable, would
place an unnecessary reporting burden
on many facilities, and would result in
many meaningless reports. One
commenter suggested that the otherwise
use definition be modified to include the
concept of "active" uses at the facility.
Based on a review of the comments
and questions received. EPA has
determined that it is appropriate to
place some limitations on the definition
of "otherwise use." EPA has developed
(8 372.38 of the rule) a listing of certain
exempt uses of toxic chemicals as
follows:
(1) Use as a structural component of
the facility,
(2) Use of products for routine
janitorial or facility grounds
maintenance. Examples include use of
janitorial cleaning supplies, fertilizers.
and pesticides similar in type or
concentration to consumer products.
(3) Personal uses by employees or
other persons at the facility of foods.
drugs, cosmetics, or other personal items
containing toxic chemicals, including
supplies of such products within the
facility such as in a facility operated
cafeteria, store, or infirmary.
(4) Use of products containing toxic
chemicals for the purpose of maintaining
motor vehicles operated by the facility
(5) Use of toxic chemicals present in
process water and non-contact cooling
water as drawn from the environment or
from municipal sources, or toxic
chemicdls present in air used either as
compressed air or as part of combust.on
(6) L'se of articles
C. Full- Time Employee
One commenter requested that EPA
define what it means to have 10 or more
full-time employees for compliance with
section 313 reporting
The Bureau of the Census defines a
full-time employee as a person working
35 hours or more per week, persons v\ho
worked 1 to 34 hours for non-economic
reasons and usually work full-time, and
persons with a job but not at work who
usually work full-time. The Bureau of
Labor Statistics has a very similar
definition. Their definition does not
include contract employees. The above
two definitions are used in surveys
conducted as of a particular week, not
for an entire year.
EPA considered two factors in the
development of the employee threshold
determination. First, the definition
should reasonably apply to the annual
basis of the reporting. Many facilities
may have large seasonal variations in
employment, and trie standard must
apply to those situations in an equitable
manner. Second, facilities with large
numbers of contract employees should
not escape reporting because of
different employment arrangements.
EPA considered options for
determining whether a facility meets the
employee threshold as follows. First.
full-time employee determinations could
be made based on the highest number of
full-time employees during any week of
the calendar year. This method would
ensure that facilities with highly
variable employment patterns would be
covered for reporting if they met the
other requirements (SIC codes and
chemical thresholds). Second, full-time
employee counts could be determined
by the number of employees as of a
particular date during the year. Such an
option would limit the burden of
checking through employment records.
but is arbitrary with respect to the
choice of a date. Third, the
determination could be based on the
concept of full time equivalents. A
generally accepted level of annual full
time hours worked is 2.000 hours. The
number of payroll hours for the year
would be divided by 2.000 to determine
the equivalent number of full-time
employees. Fourth, full-time employee
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Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1986 / Rules and Regulations 450?
counts could be determined by an
nveragc of tbe quarterly maximum
r umber of full-time employees for the
calendar year. This'option would he the
most burdensome to calculate.
EPA decided to define full-time
pmpioyec on the basis of a full-time
equivalent calculation. Total annual
hours worked by all employees.
including contract employees, at thr>
l.'cility is divided by 2,000. In this way. a
facility is able to make an easy
determination of whether it equals or
exceeds a 10 employee equivalent level
by determining if the total hours worked
at the facility equals or exceeds 20,000
hours. EPA believes that this approach
provides a fair and consistent measure
of employment.
D. Definition of Article and Article
Exemption
These issues deal with the definition
of article and whether articles should be
explicitly exempt for the purposes of
threshold determinations and release
calculations.
1. Modification of the article
definition. The definition of article that
appeared in the proposed rule is the
same definition used in regulations
under TSCA. One commenter asserted
that the definition of article that appears
in the OSHA HCS should be substituted
for the proposed article definition. The
commenter contended that the OSHA
a;"cle definition is more appropridte for
section 313 because the language in the
Litter part of the OSHA definition
relates to the potential for release and
exposure during normal end use. Also, it
would be consistent with provisions of
the Title HI sections 311 and 312 rule (52
FR 38344). The instructions for the
sections 311 and 312 reporting forms
incorporate exemption language from
the OSHA HCS, part of which is the
exemption of articles.
The a-ticle definition in the proposed
rule read as follows:
"Article ' means a manufactured item
which is formed to a ipeciflc shape or design
daring manufacture, which has end use
f mrlionis) dependent in whole or in part
•:pm us sh;ipe or design during end use. and
h JS «Mther no change in chemical composition
during I's end use or only those change* of
coir position which have no commercial
purpose separate from that of the article, or
result mixtures or articles, except that fluids
jnd pa-tides are not considered articles
r«>gj,-dless of shape or design. The article
definition m the OSHA HCS reads as follows:
'Article ' means a manufactured item: (i)
Which is formed to a specific shape or design
during manufacture: (ii) which has end use
funrtion(s) dependent in whole or in part
upon its stupe or design during end use: and
(HI) which does not release, or otherwise
result in exposure lo a hazardous chemical
under normal conditions of use.
The first part of each definition are
identical. The latter parts of the
definitions differ significantly. The
rommenter pointed out that the OSHA
HCS definition will function more
appropriately because it will keep
certain exposure-causing items from
being considered articles whereas the
proposed definition would not. The
commenter also asserts that the
exception at the end of the proposed
definition for fluids and particles is
unnecessary.
In its review of this issue EPA
Considered several options, including
retaining the article definition as
proposed, retaining the proposed
definition but clarifying the wording of
the latter part, and adapting the OSHA
IICS article definition for use in this
rule. EPA has determined that it agrees
with the commenter and has adopted
the OSHA HCS article definition with
some modifications because it is more
rippropnate for section 313 purposes
than the TSCA definition. The TSCA
article definition is worded primarily to
distinguish "chemical substances" and
"mixtures" from those manufactured
items that contain chemical substances
and mixtures. The OSHA HCS definition
was adapted from the TSCA regulatory
definition, for the purpose of exempting
certain items from the MSDS
preparation requirements; the
supposition being that the item's normal
end use would not release or cause
exposure to a "hazardous chemical" in
the article.
The revised article definition in the
final rule reads as follows:
"Article" means a manufactured item: (i)
Which is formed to a specific shape or design
dunng manufacture: (n) which has end use
functions dependent in whole or m part upon
its shape or design during end use: and (m)
which does not release a toxic chemical
under normal conditions of processing or use
of that item at the facility.
EPA wishes to emphasize that under
this definition an item will not qualify as
an article if there are releases of toxic
chemicals from the normal use or
processing of that item. When
attempting to apply this definition to an
item used or processed at a facility, the
facility should keep this release factor in
mind. For example, under normal
conditions the milling of metals (e.g.
topper) can generate fume or dust
containing listed toxic chemicals. Thus.
the metal or plastic item being
processed would not qualify as an
article in that manufacturing setting.
However, if the only "release" from
processing an item is the disposal of
solid scrap (e.g.. pieces of cloth or
sections of pipe that are recognizable as
having the same form as the item) then
EPA considers that the processed item
still qualifies as an article.
Toxic chemicals in an item that
qualifies as an article are not subject to
reporting even if the facility disposes of
the article after use. For example, the
facility uses n battery that contains lead.
Lead is not released from the battery
during normal use at the facility. When
the facility disposes of the battery, it
does not have to factor the amount of
lead in that article into a threshold or
release calculation.
2. Articles exemption. The proposed
rule covered the processing and use of
toxic chemicals and mixtures containing
such toxic chemicals. EPA included a
proposed definition of article but, as
certain commenters pointed out, dtd not
specifically exclude the use or
processing of articles. Commenters
encouraged EPA to specifically exempt
the use and processing of articles from
the threshold determination and release
reporting requirements of the rule.
According to these comments, the
normal end uses of such articles by
definition do not result in the release of
toxic chemcials contained within such
articles. Therefore, such an exemption
will reduce the burden on industry
significantly because fewer materials
will have to be evaluated for threshold
and release determinations.
The purpose of including an article
definition in the rule was for the
expressed purpose of exempting such
articles. The final rule contains a new
exemption section (| 372.38). This
section exempts articles containing
covered toxic chemicals as defined
under section D above from threshold
and release determinations. EPA
cautions facilities to evaluate carefully
normal processing and use of an item to
determine if release of a toxic chemical
occurs (i.e., if indeed the item qualifies
under the definition as an article).
V. Threshold Issues
A. Comments Requesting Mo
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4508 Federal Regis : / Vol. S3. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations
A wide range of commer vas
received regarding potent!
modifications to the thmh^.ds.
Commenters from environmental and
public interest groups asserted that
thresholds shoud be lowered to increase
release reporting. One commenter stated
that a 10.000 pound threshold, over 3
years should be used rather than a
graduated threshold. Commenters
representing the industry asserted that
thresholds could be raised without
affecting data quality or reporting
requirements. Other related comments
stated that thresholds should be
modified to include only larger facilities
and that the "user" threshold should be
raised to the same level as thresholds
for the manufacturing or processing of a
toxic substance. Additionally, one
company commented that the
determination of a need to modify
thresholds should be based on the first
few years' reporting levels.
Comments from a professional society
and a State government indicated that
the proposed thresholds are valid and
should not be raised.
Additional comments presented
alternatives to the type of thresholds
presented in the proposal. Two
commenters indicated that toxic effects
could be used to determine threshold
adjustments. One commenter
recommended a different series of
thresholds based on standard container
sizes to make threshold determinations
easier. Another commenter proposed
that the statutory employee size
limitation of 10 or fewer employees be
removed rather than reducing threshold.
amounts for reporting purposes. One
commenter proposed an emissions-
based approach to exclude small
releases of toxic chemicals, regardless
of the quantity manufactured, processed.
or used.
The final rule contains the statutory
thresholds present in the proposed rule.
EPA does not believe that it has
received in the comments sufficient data
to support any overall modification of
the statutory thresholds. In addition.
EPA did not propose any such change.
EPA agrees with comment* to the effect
that the first few yean' data should be
evaluated to determine whether
modifications of the threshold would
meet the statutory test of obtaining
reporting on a substantial majority of
the releases (i.e.. pounds released per
year) of each chemical from subject
facilities. EPA may consider changing
the reporting thresholds based on
several years of data collection.
Revising the threshold amount can be
based on specific chemicals, classes of
chemicals, or categories of facilities.
EPA may consider a number of factors
for threshold modification including
exposure factors such as population
density, the distance of population from
covered facilities, and the types of
releases. Threshold modifications could
also take into account the relative
potency of the chemical or class of
chemicals and the effects of concern.
Another type of threshold modification
the Agency will investigate relates to
the type of facility, either generally by
size or by type of industry.
B. Threshold Determination Issues
Several issues arose as a result of
comment on EPA's proposed approaches
to determining whether a facility has
exceeded a threshold.
1. Recycle and reuse. EPA proposed
that a threshold determination in
connection with on-site recycle and
reuse activities be calculated by
determining the amount of the toxic
chemical in the recycle/reuse operation
at the beginning of the year and add to
that any quantity of the chemical
brought on site. Commenters reacted to
this proposal with the following:
a. The threshold should be based on
the amount of the chemical "acted
upon." This would include the operating
capacity of the recycle activity plus only
the amount added during the year, not
the total quantity brought on site.
b. The amount calculated for the
purpose of threshold determinations
should only be the quantity added to or
actually consumed by the recycle
operations.
c. EPA should clarify that the
threshold amount recycled should not
count a pound of chemical more than
once as it cycies through the activity.
After a review of the comments. EPA
has determined that the threshold
determinations should be based on the
amount of the material added to a
recycle/reuse system during the
reporting year. This would fairly depict
the amount of a chemical "consumed"
during a year in connection with this
particular use. During start-up of such a
recycle/reuse operation or in the event
that the contents of the whole recycle
system had to be replaced, this total
system quantity would have to be
factored into the facility's threshold
determination for that chemical. EPA
believes that this approach is consistent
with the objectives of encouraging
recycle/reuse activities.
2. Amount brought on site versus
amount processed or used. The previous
issue points toward a more general
problem of distinguishing whether the
threshold must be calculated based on
the amount of a chemical brought on site
during the year or the amount actually
processed or used. One commenter cited
a situation in which a facility may have
a running inventory of over 10,000
pounds of toluene but actually uses only
9.000 pounds during the year. Provided
that this is the only use of toluene, the
commenters contended that the
threshold for use has not been met.
EPA agrees with this comment. The
final rule provides that the threshold for
processing and use is based upon the
total amount actually used or processed
at the facility, not the total amount
brought to the facility during the year.
This would not apply, however, in cases
where importation contributes to a
calculation of whether the facility
exceeds a "manufacture" threshold. The
act of importing the chemical to the
facility is within the definition of
manufacture. Therefore, any quantity
brought on site due to importation has to
be counted along with any amount of
the same chemical produced at that
facility. However when a facility does
exceed a threshold, any emissions from
amounts of the chemical in the running
inventory (i.e. storage) would have to be
factored into the emissions calculations.
3. Exceeding any threshold captures
the facility for alt releases of that
chemical. A commenter objected to the
interpretation that if a facility exceeds
any threshold for a listed chemical, it
must report all emissions of that
chemical from the facility. The
commenter claims that reporting should
be limited to the activity that triggers the
threshold to be consistent with
Congressional intent because Congress
set such thresholds to limit the burden
on industry and provide the public with
useful and manageable information.
EPA disagrees with this comment.
Congress indicated that section 313
should cover releases from the facility to
all environmental media. The thresholds
are provided as the means for
determining facility coverage, not as a
factor in determining which emissions
from the facility must be reported.
VI. Mixtures and Trade Name Products
The proposed rule indicated that
mixtures and trade name products that a
facility imports, processes, or uses
would be evaluated and any covered
toxic chemicals in those products would
be factored into threshold
determinations and release reporting.
However, EPA recognizes that facilities
may not always have full information
regarding mixture components. EPA
provided detailed guidance in the
preamble of the proposed rule for
making a reasonable determination of
what is "known to be present at the
facility" with respect to determining the
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Federal Register / Vol. 53, No. 30 / Tuesday. February 16, \988 / Rule* and Regulations 4509
presence and composition of covered
toxic chemicals ID mixuaes At the
facility. The proposed instructions for
the form alto o»tlmed • method for
factoring mixture* into the threshold
determinations. In .addition, the proposal
presented EPA 'a belief that suppliers of
mixtures and trade name prodocU have
a responsibility to provide their
customers with io/omvaUoa saffitcjerti
for them to comply with the
requirements of section 313. EPA
requested comment on several optioas
for a supplier notification requirement in
connection with, or in lieu of. a user
detenninalion requirement £PA
received a wide range of comment on
the mixture issue.
A. De Minimis Concentration Limit
A predominant area of comment was
the request for some type of de minimi's
concentration limitation for listed toxic
chemicals "m mixtures. Commenters
argued that many mixtures or trade
name products may contain "trace"
quantities of section 313 chemicals.
They asserted that it would be both
unreasonable and extremely
burdensome for processors and users of
such products to have to account for
these quantities in developing threshold
determinations. In addition, commerrters
asserted that it would be equally as
burdensome for suppliers of these
products to have to determine and
disclose small percentages of section
313 chemicals in their products beyond
that currently required under the OSHA
HCS. Most commenters suggested that
EPA adopt a de minimis concentration
limitation consistent with the OSHA
HCS requirement. The HCS provides
that a supplier does not have to list a
"hazardous chemical" component in a
mixture if that chemical comprises lea*
than 1 percent of the mixture or 0.1
percent where the chemical is a
carcinogen (as defined in the HCS}.
Other commenters suggested de minimis
levels ranging from 2 percent to 10
percent. Other related concepts weald
exempt from consideration eolations
containing grea ter than 75 percent water
or would establish de minims release
standards.
Based on the comment* received. EPA
has determined that it is reasonable and
appropriate -to adopt a demiaimjs
concentration limitation for toxic
chemicals in mixtures under section 313.
EPA believes that it h necessary to
provide a de minimis limitation to help
reduce the information development
burden both on the part of the user and
the supplier of such products. For the
final rule EPA has adopted « de auniau'i
limitation of 1 percent, or 0.1 percent in
the case o/ an OSHA HCS defined
carcinogen. EPA aeiietvs that the de
minimis level chosen is appropriate for
two reasons. Fust il is consistent with
existing OSHA HCS rernnremeBis for
development of MSDS information tod
with other requirements under sections
311 and 312 of Title 11L Suppliers of
products are fwruTiar with these levels
and. at least for the first two years of
reporting, users of these mixtures are
only likely to be able to rely on the
product MSDS for information about the
content and percentage composition of
covered toxic chemicals in these
products. Second. EPA does not expect
that tke processing and use of mixtures
containing less than the de minimis
concentration would, in most instances.
contribute significantly to the threshold
determinations or releases of listed toxic
chemicals from any given facility.
Therefore, any listed toxic chemical
that is present in a mix tore below these
de minimi's concentrations does not
have to be factored into threshold or
release determinations by the facility.
This exemption apphes to all mixtures
or trade name products imported,
processed, or otherwise used at the
facility.
EPA defined "mixture" in the final
rule to cover combinations of chemicals
that are mixed together, as well as
relatively pure chemicals which have
impurities present. Thus, if a toxic
chemical were present as an impurity
with another chemical at a level lea
than 1 percent or 0.1 percent in the case
of a carcinogen, the de minimis
exemption would apply, and the person
processing or -using the toxic chemical
impurity woord not be required to count
the quantity present as an impurity
toward the threshold determination.
They would aura not be required to
consider that quantity when determining
releases to the environment.
The de minimis exemption applies
only to die presence of the toxic
chemical in the mixture. If a person
formulates a mixture by mixing various
chemicals together, including a toxic
chemical, the person is a processor of
the toxic chemical The person must
consider the quantity of the toxic
chemical added to the mixture, both for
threshold determinations and release
reporting, including releases from the
formulation activity. However, such «
person would not be required to
consider releases of the toxic chemical
resulting from its presence in the
mixture at less man 1 percent or 0.1
percent as appropriate.
If a person manufactures a chemical
and in the process creates a toxic
chemical impurity present at less than 1
percent or 0.1 percent, as appropriate.
the person is not required to consider
the amount of the toxic chemical so
manufactured for threshold
determinations or release reporting
(provided that the impurity is not
separated from the commercial productV
EPA plans to review this de mir:m:s
policy vnd the assumptions «pon which
it is based in light of data that will be
collected under this rule.
fl. User Deteraucation Versus Supplier
Notification
As stated m the introduction to fhrs
unit. EPA proposed a detailed approach
for users to make a reasonable
determination of the presence of section
313 chemicals in products they use. in
response to the proposed approach, one
commenter stated that the standard in
the statute is "known to be present at
the facility" and asserted that a facility
has no affirmative obligation to seek
information where there is wo apparent
information about * section 313
chemical in a mixture beyond such
readily available sources as the MSDS
for that product.
Others commented on the options in
the proposed rule preamble for suppliers
to notify customers or EPA about the
presence and percent composition of
corered toxic chemicals in their
products. A mimber of commenters
stated that a supplier should be required
to notify its customers about the
presence and •composition of listed toxic
chemicals in the product. From an
overall burden standpoint, these
commenters stated that there are
naturafly fewer suppliers than users.
Without« supplier notification
provision, osers would have to contact
each of their suppliers each year. These
commenters stated that a supplier
notification requirement would
ultimately place less burden on the
suppliers themselves because their
staffs would not have to be constantly
responding to wser requests. Also, most
suppliers coold "piggyback" such notice
with the OSHA HCS required MSDS for
the product and thereby not incur a
significant additional biirden. Other
commenters agreed with the supplier
notification concept but preferred that
EPA allow a voluntary customer/
supplier interaction, not require such
notification as part of the rale. Other
commenters staled that EPA does not
have the authority under section 313 to
require this type of notification nor
would it be appropriate to invoke the
general rulemaking authority under
section 328 of Title III to authorize such
requirement
Other comments addressed trade
secret related implications of a supplier
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4510 Federal Register / Vol. 53. No. 30 / Tuesday •-.•-_
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Federal Register / VoL 53. No. 30 / Tuesday. February 16, 1988 / Rules and Regulations
4511
present. it« generic chenucal ideality.
and its upper bound concentration in the
mixture or trade name product
However, even after supplier
notification begins, customers may
receive such mixtures or trade name
products from persons not in SIC codes
20 through 39 or from foreign suppliers.
Neither of these suppliers would be
subject to the supplier notification
requirements. Therefore, customers
might receive less information about
toxic chemicals in such mixtures and
products. Accordingly, EPA has
included in the final rule and
instructions delated provisions for
reporting by owoera and operators of
covered facilities who import, process.
or otherwise use toxic chemicals as part
of mixtures or trade name products.
All reporting by persons who import.
process, or use mixtures or trade name
products containing toxic chemicals is
predicated on those persons knowing
that toxic chemicals are present in the
mixture or trade name product If such a
person receives a mixture or trade name
product, the person must determine
whether it meets an applicable reporting
threshold in either of the following
situations: (i)The person was told, or
had determined through chemical
analysis or otherwise, the specific
identity or CAS Registry' Number of a
chemical in the mixture or trade name
product and that chemical appears in
§ 372.65 of the rule: or fn) 'he person
was told that the mixture or trade name
product contains a toxic chemical
subject to section 313. If either of these
situations applies, the person is not
required to inquire further about the
mixture or trade name product. Section
313 and the final rule do not impose any
obligation to test a mixture or trade
name product to determine whether it
contains a toxic chemical. However, if a
person has tested such a mixture or
trade name product for its own reasons.
it must consider th« results in
determining whether to report.
The final rule identifies six scenarios
for persons making reporting
determinations for toxic chemicals in
mixtures or trade name products:
1. The person knows the tpecific
chemical identity of the toxic chemical
in the mixture or trade name product,
and
a. The person know its specific
concentration in the mixture or product;
b. The person knows only its upper
bound concentration in the mixture or
product or
c. The person haj ao m/omutkm
about iu concentration m the mixture or
product
2. The person does not know the
specific chemical identity of the toxic
chemical in the mixture or trad* name
product and
a. The person knows its sped He
concentration in the mixture or product:
b. The person knows only its upper
bound concentration in the mixture or
product or
c. The person has no information
about its concentration in the mrxhire or
product.
When the person knows the specific
chemical identity of the toxic chemical
in the mixture or trade name product.
making the threshold determination will
involve combining the amount of'the
chemical in that mixture or product with
amounts of the same chemical also
manufactured, processed, or otherwise
used at the facility. However, me person
is only required to consider the weight
of the toxic chemical in the mixture or
trade name product, not the total weight
of the mixture or trade name product.
Determining the weight of the toxic
chemical in the mixture or trade name
product depends on the information the
person has about the percentage
composition of the chemical in the
mixture or product. ft the person knows
the specific concentration, determining
the weight of the chemical Is
straightforward. However, if the person
knows only the upper bound
concentration, the person is required to
assume that the toxic chemical is
present at that concentration and
calculate the weight accordingly. In the
event that the person does not know the
specific concentration or the upper
bound concentration then the person is
not required to further estimate or
otherwise factor that chemical in that
mixture or product into threshold or
release calculations.
Where the person does not know the
specific caermoal identity of the toxic
chemical in the mixture or trade name
product, the person is required oaJy to
consider the quantity of that chemical
component in that mixture or product m
making a threshold determination. Since
the person does not know the specific
identity of the chemical, the person
cannot cos bine the weight of the
chemical in the mixture with any other
toxic chemicals manufactured.
processed, or otherwise used at the
facility because die person cannot
determine that they are the same
chemical. Accordingly, the threshold
determinations and the reporting, if any,
will be specific to the toxic chemical in
the mixture or product
Determining d» weight of the toxic
chemical in the mixture or product in
this case is the same as for determining
the weight when the specific chemical
identity is known.
Determining toe weigct of the toxic
chemical in the mixture or product in
this case is the same as for determining
the weight when the specific chemical
identity is known.
Once the applicable thresh. Id \*. met.
reporting the chemical identity varies
with the degree of knowledge. IT the
specific identity is known, the person
must report the identity and CAS
Registry Number, if any. in Part 111.
Section 1 of Form R. If only a generic
chemical name i* known, that name
must be reported in Part III. Section 2 of
Form R. If no generic name is known.
the trade name or other name applied to
the chemical, or to the mixture or
product of which it w a component, must
be reported in Part UL Section 2 of Form
R.
With respect to estimating releases.
such estimates must be based on the
concentration oT the toxic chemical in
the mixture or trade name product.
VII. Fom Specific Issues
A. Certification Statement
Section 713 requires that a senior
management official sign a certification
statement for submitted forms. The
proposed statement would have
required that the person certify/ that the
submitted information is true, accurate.
and complete based upon his or her
personal examination of the completed
forms.
The Agency received several
comments on certification relating to
three issues: (1) The definition of a
senior management official. (2) the
requirement that the certifier has
"personally examined and is familiar
with" the submitted information, and {3)
the requirement that the company must
certify that the submitted information is
true, accurate, and complete.
1. Senior management official Section
313(g)(l)(B) defines a senior
management official as "a senior official
with management responsibility for the
person or persons completing the
report."
In the preamble to the proposed rule.
EPA stated that a senior management
official could be an officer of a
company, a facility manager (rather than
a corporate officer), or the manager of
environmental programs {for the facility
or for the corporation) responsible for
certifying similar reports under other
environmental regulatory requirements.
Commwiters were concerned that
neither definition appeared in EPA's
regulations or in the instructions to the
proposed form. Also, commeoters
wanted to naintain flexibility of having
either a facility management officer or
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4512 Federal Register / Vol. 53, No. 30 / Tuesday. February 16, 1988 / Rules and Regulations
corporate manager sign the certification
statement by allowing signature by a
manager of the persons preparing the
report or by the manager of
environmental programs for either the
facility or the corporation.
The Agency has added a definition of
senior management official to { 372.3 of
the rule. The definition gives facilities
appropriate flexibility in determining
who may sign the form while retaining
the emphasis that the person have
management responsibility over the
persons preparing the form.
2. Review of prepared form. The
proposed rule required that the person
certify that "I have personally examined
and am familiar with the information
• * *." Commenters stated that this
statement was too stringent because it
would require that the senior
management official duplicate all the
calculations performed in the
preparation of the form. A few
commenters suggested that EPA adopt
the certification statement used in the
National Pollutant Discharge
Elimination System (NPDES)
regulations. Those regulations require a
certification that the information was
prepared under a system designed to
assure that qualified personnel property
gathered and evaluated the information
submitted, and that the certifying official
has queried those persons responsible
for the system. Commenters noted that
the NPDES certification has already
received full notice and comment and
has been tested in court.
However, the conference report stales
that "(t]he purpose of the certification
requirement is to assure that a senior
management official reviews the report
for accuracy and completeness." The
Agency believes that the NPDES
certification, because it does not require
the certifying official to review the form,
does not meet the intent of Congress.
However, the proposed certification
statement could be interpreted to
require more than a view of the
submitted information. Therefore, the
certification statement was modified
and now requires a review by the
official, which EPA believe* fulfills the
intent of Congress.
3. Submissions that an true
accurate, and complete. "The proposed
certification statement would have
required the certifying official to state
that the submitted information is true.
accurate, and complete. Commenters
objected to this statement, stating that it
is unreasonable because much of the
information, particularly release
estimates, can be subject to
considerable uncertainty. They point to
section 313(g)(2), which allows facilities
to use available data collected under
other provisions of law or to provide
"reasonable estimates of the amounts
involved." Because estimates are
allowed, these commenters stated that
"accuracy" must be set in context of the
estimating procedures used.
Commenters further noted that a facility
may choose to use emissions factors
developed by EPA for the purposes of
reporting, even though the facility does
not believe the estimates are accurate.
Commenters suggested a variety of
changes to the certification statement to
correct the problem. Several
commenters suggested that the burden
of the accuracy of reports be placed on
the Agency's instructions to the form.
Another proposed approach would
provide a certification that the
information is "substantially accurate
and complete."
The Agency has decided to modify the
certification statement to tie the concept
of accuracy with reasonable estimates
of amounts and values reported. Such
estimates must be based on the
information available to the preparer of
the report. This revision addresses the
commenters' concerns and sets accuracy
of reporting within the context set forth
by Congress. The revised certification
statement reads as follows:
"I hereby certify that I have reviewed
the attached documents and. to the best
of my knowledge and belief, that the
submitted information is true and
complete and that the amounts and
values in this report report are accurate
based on reasonable estimates using
data available to the preparers of this
report."
B. Facility Identification
1. Technical contact, addition of a
public contact. In the proposed rule EPA
asked for a technical contact to be
listed. The primary purpose for including
a technical contact on the proposed
form was to allow EPA to follow up
reporting with questions pertaining to
the completeness and technical integrity
of the data. Commenters stated that
only EPA or State officials should be
designated to contact the "technical
contact" of a facility. In addition.
commenters recommended that they be
allowed to provide a public contact
different from the technical contact.
EPA has done two things regarding
the technical contact. First, for
clarification, it should be noted that the
technical contact does not have to work
at the geographic location for which the
report is submitted. The technical
contact can be: (a) Someone at the
facility: (b) someone at the same
company, but at a different location: or.
(c) a consultant. The name and
telephone number of the technical
contact must be provided on the form.
The technical contact information will
not be included in the public data base.
Second, in addition to the technical
contact. EPA is requiring facilities to
provide the name and telephone number
of a public contact for the facility. The
public contact may be the same as the
technical contact, or someone different.
EPA added a public contact to provide
firms within the flexibility of designating
types of personnel most appropriate to
the task of handling technical inquiries
about the submission versus general
information inquiries from the public.
The public contact information will be
included in the public data base.
2. Latitude/longitude. EPA did not
propose to require companies to submit
the latitude and longitude of their
facilities in the proposed form. Several
commenters expressed great interest in
having this data included as a facility
identifier. The primary reason for asking
for this information is its importance for
geographic information systems. These
computer-based systems enable EPA
and other ogranizations to model
exposures resulting from chemical
releases and produce graphic
representations of such exposures.
In addition, these coordinates help to
verify the location of facilities and will
help EPA and other users of the section
313 data base interface with other data
bases containing such geographic
coordinates.
Therefore, EPA has added latitude
and longitude as a reporting element for
identifying the facility. However, EPA is
adopting a phase-in approach for
providing this data. For reports due by
July 1,1988 (covering 1987). EPA is
requiring firms that have the information
readily available to report it. For
example, certain environmental permits
held by a facility may already contain
this information. Also, county property
records or facility plans or blueprints
may show the latitude and longitude
coordinates. Latitude and longitude
information for all facilities is required
on the forms due by July 1,1989
(covering the 1988 calendar year). EPA
believes that the approach adopted
serves two basic purposes: (1) Latitude
and longitude information is provided.
which is important to geographic
information systems: and (2) there is a
low burden of developing the data.
3. EPA I.D. Number. NPDES permit.
and receiving streams. In the proposed
rule. EPA provided a single line each for
listing the EPA Identification Number
(the identification number assigned to a
facility in connection with hazardous
waste generation and disposal activities
under the Resource Conservation and
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Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations 4513
Recovery Act (RCRA)), the NPDF.S
permit numbers, and the receiving
stream or body of water for the facility.
Commenters pointed out that some
multi-establibhment facilities can have
more than one of these identifiers or
permits, or may discharge a reported
toxic chemical into two or more streams
or bodies or water. Therefore, the
Agency has provide additional lines on
the form for these reporting elements.
C. Releases to the Environment
1. Total release. EPA proposed that
reporting und>jr section 313 account for
the total amount of toxic chemicals
entering each environmental medium
from the facility. EPA based this
interpretation on the statutory
provisions.
The definition of "releases" contained
in section 329 of Title 111 covers all types
of releases, both intentional as well as
unintentional. Section 313 requires
reporting of "the annual quantity of the
toxic chemical entering each
environmental medium" This led EPA to
ask for information on total releases
from the facility. Commenters cited the
conference report to support their claim
that Congress did not intend for
facilities to include accidential or
unintentional type of releases in the
quantities reported under section 313. In
discussing section 313 the conference
report begins by saying that:
This section establishes requirements for
annu.il reporting on fvleases of certain toxic
chemicals to the environment. This reporting
covers r-leises that ocrur as a result of
normal business operations, as dutinct from
abnormal, emergency releases which mu^t be
reported under section 3O4.
Thus, commenters v/ould argue, the
statutory definition of release is
modified by the conference report.
EPA believes that the above-quoted
conference report language was
provided for the purpose of clarifying
differences between the basic types of
reporting that occur under section 313
versus section 304 of Title HI. A section
313 report is an annual report involving
annual aggregate estimates of releases
to all environmental media. A report
under section 304 is an emergency
notification. EPA does not find language
in section 313 or any other conference
report language that precludes the
quantity of a toxic chemical released
during an "abnormal, emergency
release" from being included in the total
annual amount reportable under section
313.
One of the purposes of section 313 is
assessment of cumulative exposure to
toxic chemicals. EPA believes that the
best way to accomplish this assessment
is to include all releases of toxic
chemicals over the reporting year
regardless of the mode of release. EPA
also believes that most facilities will
calculate their releates based on a total
release concept. Therefore, it could be
more burdensome to require a facility to
"back-out" the section 304 releases and
other "accidential" type releases than to
just leave them as part of the total. Also,
if the quantities of section 304 releases
were excluded from the annual
aggregate total, most data users would
not have ready access to this additional
data. This is because section 304
releases quantities will not be entered
into a nationally accessible computer
data base as will section 313 data. Thus
the public can do no automated cross-
matching of facilities in order to obtain
this additional release data for exposure
analysis purposes. Therefore. EPA is
retaining its interpretation of total
releases for the purpose of section 313
reporting.
2. Removing the section 304 release
indicator. EPA proposed that companies
indii.ate by checking a box whether or
rot any part of the reported release was
an accidental release reported under
section 304 of Title III. Section 304
releases are certain occidental releases
of specific chemicals listed under
section 302 of Title III as well as section
103 of CERCLA (RQ chemicals). The
purpose of asking about section 304
releases on the section 313 form was to
provide the public with an additional
means of obtaining information about
total releases (both routine and
occidental] of chemicals subject to
reporting under section 313. Several
(.ommenters protested that asking for
information about section 304 was not in
keeping with congressional intent and
created trade secret problems.
Concerning trade secrets, commenters
were concerned about linkages that
( ould be made between the section 313
report and the section 304 report. Under
section 304, companies are not allowed
to claim chemical identity as trade
secret: under section 313, chemical
identity is the only information element
that can be claimed as a trade secret.
The situation could arise where the
release of a particular chemical reported
under section 304 was the only release
of thai chemical during the calendar
year. By checking the section 304 box on
the section 313 form, commenters
asserted that competitors could find the
chemical identity by referring to the
section 304 report.
EPA believes that the section 304
check-box would create unnecessary
reporting complications. Therefore. EPA
has decided to delete the check-box.
3. Deletion of the permit indication.
EPA proposed that for each aggregate
release, facilities would indicate
whether the toxic chemical is
specifically cited in a permit by
chocking a "yes" or "no" box. The intent
of the permit indication was to provide a
starting point for the public to obtain
relevant permit information on the
specific chemical released. It vvas also a
way of providing some kind of
information on air permits without
requinng facilities to list numerous air
permit numbers. Most of the comments
on this issue *ere negative. There was
strong concern that this check-box
would be misleading and confusing to
the public. Commenters asserted that a
"no" answer may lead the public to
believe the release is unpermitted or
"unallowed" and thereby imply that a
facility is in violation of the law. The
permit indication also does not reveal
how much of the release is covered by
permits. Some commenters noted that
confusion is bound to result on the part
of the reporting facilities as to when the
permit indication should apply since
most permits do not cite or limit releases
by specific chemical. For example, most
air permits apply to categones of
chemicals, such as volatile organic
compounds (VOCs) and particulates. In
addition, many permits may limit the
release of a chemical by specifying that
a control device or particular type of
treatment be employed. Therefore, many
permitted releases would not be allowed
to be checked under the proposed rule's
approach. Certain commenters believed
that EPA should broaden the permit
indication to include most other types of
permitted releases or drop it altogether.
Because the permit indication has a
high potential to provide misinformation
to the public. EPA has decided not to
include the permit check box in the final
form. EPA believes that it would
inevitably lead to misunderstanding and
confusion, not only on the part of the
public, but also by the reporting
community. EPA chose not to broaden
the interpretation of which releases
would be covered by a permit because
this would no longer serve the original
purpose of providing a link to chemical-
specific permit data. Additionally, it
would be difficult in some situations to
give a clear indication of when a permit
actually controls the release of a
specific chemical versus other
components in the wastestream. EPA
requires the listing of specific permit
numbers in the facility identification
part of the form. EPA believes that these
permit numbers provide a useful link
between the release information and
any relevant permit data.
4. Accuracy of reporting. EPA
proposed that the annual release daf
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4514 Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations
be estimated as accurately as possible
and that figures be rounded off to the
nearest pound. Recognizing, however.
the aggregate nature of the data and
potential error in the estimates. EPA
asked for comment on other reporting
alternatives. EPA received comment on
three proposed alternative reporting
options.
(1) Report in ranges.
[2] Report to 1 to 2 significant figures.
(3) Report to a specified degree of
precision.
Many comrr.enters on this issue were
in favor of either option 1 or 2, because
they believed that the data will not be
exact due to the error involved in
measurements and estimates, and that
these options would not misrepresent
the accuracy of the data. Several
commenters expressed concerns about
the liabilities involved for verifying the
accuracy of the data and the potential
for public misperception of the data
accuracy.
Certain disadvantages of reporting in
ranges were noted by some commenters.
Use of ranges could misrepresent data
accuracy because the low or high end
range numbers may not really be that
close to the estimated value, even taking
into account its inherent error. For
example, a release of 11.000 pounds/
year with a 50 percent error could be
misinterpreted as 100.000 pounds/year if
reported as a range of 10.000 to 100.000
pounds/year. Reporting in ranges may
not only misconstrue the data accuracy.
it would also make analysis and use of
the data more difficult according to
these commenters.
Because facilities are not required to
do additional monitoring and are
allowed to provide "reasonable
estimates." it would be unfeasible to
dictate that they report to a specified
degree of precision that cannot be
attained given the range of error
inherent in the estimates.
Therefore. EPA is requiring that
estimates of releases and transfers of
toxic chemicals to off-site locations be
expressed as a figure rounded to a
degree of accuracy no greater than two
significant digits.
As noted in the discussion in Unit
XV.B EPA has adopted an optional
range reporting concept for releases to
an environmental medium of less than
1.000 pounds. Where the facility
believes that it has no release in relation
to a particular line item it could check a
box for "0". If the release is estimated to
be between 1 and 499 pounds, or 500 to
999 pounds, the facility has the option of
checking a range box or entering a
specific figure. For releases of 1.000
pounds or more the facility is required to
provide a figure rounded to no more
than two significant digits. This range
reporting is for calendar years 1987,
1988. and 1989 only.
5. Peak release. Several commenters
raised the issue of having the release
data reported in terms of its frequency.
duration, or peak value in addition to
the annual release amounts. EPA did not
discuss this issue in the proposed rule
Commenters froTi environmental and
public interest groups stated that ihe
annual release data may not g:\e
enough information to assess some risks
accurately. Knowing how often and/or
how long the releases occur, and the
maximum (peak) amount of chemical
released per day would allow a better
evaluation of exposure and risk to the
public according to these commenters.
One commenter stated that the annual
estimates may be appropriate for
evaluating potential cancer risks but
that hourly or daily emission estimates
are useful for assessing risks for
chemicals with acute effects, other
short-term exposure effects, and
environmental effects.
Some industry commenters
maintained that more detailed
information about the frequency,
duration, and peaks of releases will be
difficult or impossible to provide. They
stated that man> facilities have
numerous operations or processes
involving a chemical. They claim that
peak data would be misused and
misinterpreted. They fear that users of
the data would assume that such peaks
occur every day. They also state that the
annual data should be used as a
screening tool and that further studies
should then be undertaken to gather the
information needed to fully characterize
exposure.
EPA considers the need for more
detailed release information to be valid
and considered the following options for
possible inclusion in the final rule:
(1) Days of release.
(2) Indication of intermittent versus
continuous release.
(3) Peak data (maximum daily
amount).
(4) Days of operation.
In reviewing the options. EPA
considered how the data would be used
in a screening for levels of risk with the
currently used exposure models. Days of
release is not currently used for
modeling exposure in ambient air to
carcinogens or chemicals with chronic
(long-term) health effects. Current air
dispersion models for these types of
effects use ihe toUl annual release for
estimating exposure. The number of
days of release is used for estimating
drinking water exposure for chemicals
with non-carcinogenic health effects and
environmental effects. EPA considered
that facilities may have difficulty in
prov idmg the number of days per year
over which the chemical is released into
tiie environment Facilities may not have
this information available, especially for
the first year's reporting and may find it
difficult to provide in some cases Also
this data may not be meaningful in
cases of mult'pie releases of different
magnitude and durations.
Reporting whether the release is
largely continuous or intermittent rr.av
be less burdensome for facilities to do.
but it may not be as useful as other
potential indicators. This is because it
does not provide quantitative
information needed for a risk
assessment and may be meaningless for
an aggregate release amount that is
compiled for all releases from many
types of processes or sources at one
facility.
Peak release data in the form of
maximum daily amounts is useful for
analysis of risks from chemicals
released to air or water with acute or
chronic non-carcinogenic effects, and
also for chemicals with environmental
effects. Peak release data can be used to
model the highest one-day acute
exposure to human and environmental
receptors on a worst-case basis to
determine if a more detailed
investigation is warranted. EPA is
uncertain about possible difficulties that
facilities may have in providing this
datum, given that several release
sources and several activities at the
facility may contribute to a single daily
release amount. It may not be possible
to estimate the maximum daily release
using some estimation techniques, such
as overall mass balance or emission
factors, which are available for
estimating the annual release data.
The number of days of operations
mvoK mg the chemical may be easier for
facilities to provide than other types of
indicators. It could be used to estimate
an average daily release using the
annual data, but there are weaknesses
for using this data in modeling because
the releases may not actually occur
during all the days of operation.
EPA has not included an additional
peak release type reporting element in
the final rule. Such an additional
reporting element would require a
significant change to the form. The
Agency believes that it will be
necessary to further analyze the above
options and to investigate additional
options. In its analysis the Agency will
determine what type of data is needed
to better characterize exposure and risk.
and determine how this data can best be
reported by facilities. Because of the
need for further analysis and input from
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Federal Register / Vol. 53. No. 30 / Tuesday, February 16. 1968 / Rules and Regulations 4515
the public and regulated community,
EPA plans to propose an amendment to
this rule dealing with this issue within
the second quarter of 1986. At that time.
EPA will seek comment on this issue in
order to develop the most appropriate
way of obtaining this data.
6. Disusgregation of air emissions.
EPA proposed that fugitive or non-point
air emissions be reported separately
from stack or point source air emissions.
Facilities would include all emissions to
air of a listed chemical and separate
sjch omissions quantities into fugitive or
stdck type emissions. The instructions
gave clarification as to how to
differentiate between the two types of
sources. EPA proposed to distinguish
between these two source ca'.egories for
two reasons. First, estimates of stack
emissions are likely to be more accurate
than estimates of fugitive emissions
because stack emissions can be directly
measured. Better overall information on
air releases can be obtained if fugitive
emissions are reported separately and
the accuracy of the data on stack
emissions is preserved. Second.
separate reporting of fugitive and stack
emissions will enable regulatory
agencies and other users of the data to
judge the relative significance of the two
sources of releases.
Many commenters thought EPA
should not require this disaggregation.
Two commpnters agreed with the
proposal while one commenter stated
that the form should collect five
categones of release on air emissions:
Process, fugitive, storage, transfer
operations, and waste treatment
emissions. Some commenters thought
EPA should require only reporting of
point source releases because fugitive
emissions are too difficult to estimate
accurately.
EPA has retained the reporting of air
emissions as proposed. This issue
received much discussion and review
before the rule was proposed and the
reasons for not further disaggregating air
emissions still remain the same. First.
f.irther d;scggregation would not be
consistent with EPA's approach of not
requiring specific information on the
sources of releases to minimize trade
secret claims. Second, the burden on
facilities would increase tremendously if
f.irther desegregation were required.
For example, a facility will be able to
estimate an aggregate non-point ai.recm. For direct discharges, the issue
of how to report multiple receiving
streams for one facility was raised by
one commenter. The proposed form
allowed only one line on page 1 of the
form to report a stream or body of water
that receives a facility's wastewater
flow. EPA has revised the form to allow
r°porting of up to three receiving
streams. These streams are to be
numbered and the applicable stream
numbers reported in connection with the
direct discharge release amount to that
stream.
b. Inclusion of stormwater releases.
KPA proposed that the total releases of
a chemical to surface waters include the
contribution from stormwater if the
fjcility's permit included storr.iwater
sources. Given the potential difficulty in
estimating the contribution of
ftormwater to the total release of a
(-hymic.il. EPA specifically asked for
comment on the inclusion of stormwater
discharges and how these releases
should be estimated and reported.
Many commenters thought that EPA
should not require reporting on release
in stonrwater because it is very difficult
to estimate amounts of toxic chemicals
present and intermittent flowrates
without monitoring and measurement.
Without such information, it would be
virtually impossible to estimate these
types of releases to any degree of
accuracy. Several commenters pointed
out that EPA has not yet developed final
stomiwater regulations or guidelines
under the Clean Water Act because of
the technical problems involved. Two
commenters believed that facilities
should be required to include
stormwator releases to surface waters
and publicly owned treatment works
(POTWs) and that these should be
reported separately on the form.
Some facilities have submitted permit
applications relative to stormwater
discharges. As a result of passage of the
Clean Water Act Amendments in
February 1987, EPA is currently drafting
new stonrwater regulations. Some
facilities may have stormwater
discharges permitted under N'PDES
industry subcategory effluent limitations
or through the discretion of the permit
writer. Even if a facility's stormwater is
covered by a permit. howe\ er. it may
not have any specific chemical
monitoring data depending on when the
permit was issued. Also, most permitted
stormwater releases are required to be
monitornd for conventional pollutants
such as biological oxygen demand
(BOD), total organic carbon (TOC). etc..
rather than specific chemicals.
Therefore EPA is requiring facilities
to indicate the stormwater contribution
to surface water releases only if the
facility has monitoring data on the
section 313 chemicals in such
stormwater and a measurement or
estimate of flowrate. If so. the facility
must enter the percent of the release
that is attributable to stormwater in Part
III. Section 5.3C of the form. If the
facility does not have periodic
measurements of the chemical releases
but has submitted chemical-specific
monitoring data in its permit
application, it should use these data as a
basis for its estimate. Flowrate data can
either be data submitted in a permit
application or measurements as required
by tlie permit (either periodic or
continuous), or can be estimated by
multiplying the annual rainfall times the
land area times the degree of
imperviousness or by another
appropriate method.
Appropriate responses to b« entered
on the form include: (1) A numerical
figure representing the percent
contribution to the total release. (2) "0"
if tlie facility has monitored but not
detected the chemical in stormwater
discharges, and (3) "N/D" if the facility
has no monitoring information relative
to the chemical in stormwater
discharges.
8. Specific line for reporting
underground injection release. One
commenter raised the issue of how
releases to groundwater are reported on
the form. The commenter stated that
EPA should break out reporting of direct
and indirect groundwater discharges as
a category distinct from releases to land.
By looking at the form only, it is not
clear how and where facilities would
repr-rt releases via underground
injection discharges. On the proposed
form, these releases were to be reported
in tr e Release To Land section by
entering a disposal code for
underground injection next to the annual
amount. To further clarify releases by
nndjrground injection of listed toxic
chemicdls. EPA has included a separate
sub-section in the final reporting form
entiled Underground Injection (Part III,
Sec'ion 5.4).
9. Bnsis of estimate. For each
dggiegHte release. EPA proposed to
require an indication of the basis used
to account for the estimation of the
largest portion of the release quantity.
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The basis of estimates provided in the
instructions were:
(1) Based on monitored or measured
data.
(2) Based on mass balance
calculations.
(3) Based on published emission
factors.
(4) Based on other approaches
(engineering judgment, etc.) Each
method would be indicated on the form
by the use of a code.
The basis of estimate provides some
indication of data quality and will
identify situations in which monitoring
data might be obtained in follow-up
activities by EPA or the States. This
indication would also allow EPA to
identify facilities and industries that
may be having difficulty estimating
releases so that further guidance may be
developed for them.
Several commenters thought that EPA
should require more detailed
information on how the releases were
estimated, such as the percentage of the
release for each method, the emission
factors used, or a brief explanation for
how other approaches were applied.
Most of the commenters representing
industry supported the use of the
proposed basis of estimate. One
commenter wanted clarification on
whether indicating the use of emission
factors applied only to the use of EPA
emission factors.
Requiring reporting of the emission
factors could result in revealing
production volume or throughput
amount of the chemical: information that
many companies consider trade secret.
Also, requiring reporting of the specifics
of the calculations used to develop the
estimates would be similar to collecting
information on each source of release,
as opposed to the aggregate release.
Such data could involve information on
quantities of process streams, also often
considered proprietary. EPA wishes to
minimize trade secret claims so that
most of the data on the specific
chemicals will be available and useful
to the public. Collecting this sort of
detailed information would be more of a
"mass balance" reporting approach, and
EPA does not have the authority to
collect mass balance information from
facilities under section 313. Such an
approach will undergo study by the
National Academy of Sciences as
required by section 313(1) to determine
the feasibility of its use for future toxic
chemical release inventory reporting.
The final rule requires the basis of
estimation as proposed. Any reasonable
emission factor may be used to estimate
releases. It is not EPA's intent that
facilities be constrained or limited to the
use of any one estimation method. The
burden is on the facilities to provide the
most accurate and "reasonable"
estimate of releases, and they should
use all available data and means to
provide these estimates. The data or
methods used must be documented in
the facility's records and made available
for review upon request by EPA
inspectors. EPA will use the basis of
estimate provided on the form as a tool
to ascertain data quality, availability of
information, and reporting problems for
facilities.
D. Off-Site Transport
EPA proposed that facilities report the
amount of the toxic chemical in waste
transferred to the off-site treatment and
disposal facilities (including POTWs).
the name and address of the off-site
location, whether the off-site location is
under the control of the reporting
facility, and the treatment/disposal
methods used off-site, if known. The
rationale for inclusion of the off-site
waste transfers was to complete the
picture of chemical waste generated
from a facility and enhance the public's
understanding of the locations of toxic
chemicals in their community. Off-site
locations would also include waste
brokers, storage facilities, privately or
publicly owned wastewater treatment
works, and off-site underground
injection wells.
Most industry commenters objected to
the reporting of off-site waste transfers
for several reasons. First, commenters
stated that such information is not
required by the statute, was not
intended by Congress, and is duplicative
because of RCRA reporting
requirements for hazardous waste. The
strongest objection, however, was that
the off-site chemical, transfers do not
constitute "a release into the
environment" by the reporting facility
and should not be reported as such on
the form.
Other comments focused on whether
reporting of off-site treatment/disposal
methods is required or not and how to
report recycling and reuse of the
chemical waste off-site. A few
commenters suggested that EPA should
require the EPA Identification Number
of the off-site facility because these
numbers would help provide a better
identification of the off-site facility and
would aid in access to related
information in other data bases.
EPA has interpreted the statute to
require reporting on wastes sent off-site
because the conference report states
that reportable releases shall also
include releases "to waste treatment
and storage facilities." Also. EPA
believes that reporting wastes sent off-
site is important because the absence of
this information regarding the
generation of chemical wastes by a
facility could be misleading to the
public. Many facilities transfer a
significant portion of their chemical
wastes to off-site locations
The information to be collected on off-
site waste transfers is different from
that required under RCRA because this
information is chemical-specific and
makes no distinction between
wastestreams which are hazardous and
non-hazardous. This type of chemical-
specific information is not currently
available to the public or EPA for many
chemical wastes. Facilities are to report
the amount of the listed toxic chemical
in waste transferred off-site. Facilities
are not to report the total amount of the
waste containing the chemical.
EPA has retained the requirement to
report transfers of a chemical in waste
to off-site locations. However. EPA has
revised the form so that off-site transfers
are distinguished from direct facility
releases to the environment, because the
disposal fate is not always known and
the off-site treatment may reduce the
amount of chemical ultimately released
into the environment. The off-site
transfers of chemicals are to be reported
in a separate section (Part III. Section 6)
of the form. Reporting of treatment/
disposal methods is required only if this
information is readily available to the
reporting facility.
Transfers to a reprocessor or recycler
of chemical waste are not reportable as
off-site transfers under the final rule.
First, the material being sent is not
bound for ultimate disposal. Second.
these types of facilities may themselves
be covered as manufacturers or
processors of the chemical and, thus.
would be accounting for any releases to
the environment.
EPA agrees with the comment that an
EPA Identification Number should be
included in connection with the name
and address of off-site locations (to be
reported in Part II. Section 2 of the
form). If the chemical is part of a
hazardous waste, this information
element should be readily available
from information that the facility must
supply on the Uniform National
Hazardous Waste Manifest Form. If the
facility does not know the EPA
Identification Number of this off-site
location, it would enter N/A in this
space on the form.
E. Waste Treatment Information
1. Wastestream and treatment
methods. Section 313(g)(i)(c)(iii) states
that facilities must report "for each
wastestream, the waste treatment or
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disposal methods employed, and an
estimate of the treatment efficiency
typically achieved * * *." EPA
proposed thai a wasiestream be
considered as the aggregate wastes
treated in a particular manner or the
influent stream to a single treatment
method. For example, aggregate waste
going to secondary wastewater
treatment on site would be considered
as a wastestream and reporting would
not be required for each of the numerous
waters from various process points that
are combined for treatment EPA
proposed that the wastestream be
characterized as gaseous emissions.
wastewater. non-aqueous liquid waste,
and solid waste (includes sludge and
slurries).
In the proposed rule EPA also
requested comment on a more detailed
wastestream characterization approach.
The example used would have required
each individual wastestream containing
the reported toxic chemical to be
identified by an appropriate RCRA
waste code. Where a wastestream did
not have a RCRA waste code, other
source codes would have to be
developed.
Commenters representing industry
trade groups and individual companies
supported EPA's proposed aggregate
wastestream approach. Commenters
representing environmental or public
interest groups disagreed with the
proposal and urged EPA to adopt a
source-specific wastestream
characterization system, such as
requiring individual wastestreams to be
identified by the RCRA codes. These
commenters claimed that an aggregate
wastestream approach would severely
reduce the utility of the data and that
EPA will lose the ability to identify
particularly efficient means of
treatment
EPA has determined that it will retain
the aggregate wastestream
characterization approach as proposed.
EPA was not convinced by comments
received (hat a source-specific
wastestream characterization would
add materially to the data received or to
understanding mom about relative
efficiencies of particular treatment
methods applied to those wastestreams.
EPA remains concerned that a very
specific wastestream approach would
add a significant degree of complexity to
the form. It would also increase the
burden associated with completing the
form without a commensurate increase
in benefits. For example, in larger
facilities several different individually
coded wastestreams. containing the
same chemical may be sent to one type
of treatment The form would have to
provide for multiple entries for each of
these wastestrearas. Yet the type of
treatment and the relative efficiency of
removal of the chemical would be the
same. There also remains the concern
about disclosure of trade secret
information if facilities were required to
identify source-specific wastestreams.
For example, many of the RCRA waste
codes are themselves specific toxic
chemicals as listed in section 313. If a
facility can substantiate that the
manufacture, processing, or use of a
toxic chemical at their facility is a trade
secret and they must then identify a
treated wastestream as that same
chemical, then trade secret protection is
effectively negated Furthermore, to the
degree that process specific
wastestream information could reveal
sensitive process related trade secret
information, companies that might
otherwise not claim the chemical
identity as a trade secret may have more
reason to do so in order to protect the
linkage to process detail This result
would adversely affect the public's
access to information.
Finally, in many cases where more
detailed wastestream information may
be of use, such information would be of
use only in conjunction with other
detailed information, such as the
characterization of the wastestream. It
is EPA's belief that such detailed
information is more appropriately
gathered in followup activities after the
reports under this rule have been
screened to identify particular facilities
or classes of facilities of greatest
interest. EPA believes that the level of
detail in the final form will satisfy the
needs for such screening.
EPA proposed a list of treatment
codes in the instructions from which
facilities could specify the treatment
methods used for each wastestream.
This list has been revised slightly to be
more consistent with treatment methods
and codes that will be used for future
RCRA annual/biennial reporting. Such
consistency will result in less confusion
and burden for many facilities who will
be reporting waste treatment
information under two different EPA
rules. Treatment methods are to be
reported for all wastestreams containing
reportable chemicals whether this
treatment actually removes the specific
chemical or not
2. Treatment efficiency. EPA proposed
that treatment efficiency, expressed as
percent removal would represent any
destruction, biological degradation.
chemical reaction or conversion, or
physical removal of the listed chemical
in the wastestream being treated. A few
commenters noted that some of the
treatment methods, such as
encapsulation and fuel blending, could
be reported as 100 percent efficient from
the standpoint of protection of health
and the environment EPA proposed that
these treatment methods be reported
with a 0 percent efficiency because they
do not remove the chemical by any of
the previously mentioned mechanisms.
For the final rule. EPA does not belie\ e
that "removal efficiency" should be
stretched to include wastes rendered
"safe," "harmless." or "non-toxic" to
health and the environment without
being removed from the wastestream
because such determinations are
abstract and subjective, and would
result in inconsistent and confused
reporting, and would be misleading to
the public. Knowledge of the treatment
method used should be sufficient to
indicate to data users the mechanism of
the "treatment" employed and how it
works.
Several commenters were confused
about how to report the efficiency of
neutralization processes because this
type of treatment involves a change in
pH and they believed that the concept of
percent removal would not apply.
Neutralization does involve a chemical
reaction or conversion, such as an acid
reacting with a base to form a salt or
vice versa. Therefore, percent removal
would apply to the percent of acid (or
base) in the wastestream that was
reacted during treatment. Neutralization
also involves pH adjustment because pH
is just a measure of the acid or base
concentration in the wastestream. A pH
of 7 or above after neutralization would
indicate 100 percent treatment efficiency
of an acidic influent wastestream while
conversely, a post-treatment pH of 7 or
below would indicate 100 percent
efficiency for a basic influent
wastes trearn.
3. Sequential treatment. In the
proposed rule, the reporting form did not
allow tracking of sequential treatment
processes, and an efficiency was to be
reported for each treatment method.
Several commenters pointed out that for
sequential treatments, an overall
efficiency for the process would be more
useful data than a separate efficiency
for each treatment without an indication
that they are part of a sequence. EPA
also realizes that, in many cases.
facilities may not know the individual
treatment step efficiencies for a
sequential process, but would have a
good estimate of the efficiency of the
overall treatment process.
EPA has revised the waste treatment
section of the form to allow the option of
reporting sequential treatment methods
and an overall treatment efficiency if the
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individual treatment step efficiencies
are not known. The sequential treatment
steps would be linked together by
checking a box next to etch step to
indicate that it is part of a sequence. See
Part 111, Section 7, column D of the form.
This revision will allow facilities to
report more accurate and relevant (in
the case of sequential treatment) data.
will reduce their reporting burden, and
will increase the usefulness and
understanding of the treatment data
reported. For sequential treatments,
facilities are to list the individual
treatment codes for the various steps in
the process, report the influent
concentration for the entire process by
entering the code next to the first
treatment step, and report the overall
sequential treatment efficiency next to
the last treatment step in the sequence.
4. Influent concentration. EPA
proposed that facilities report the pre-
treatment concentration of the chemical
in the wastestream for each treatment
method. Submitters would enter a code
corresponding to one of five ranges of
concentration. Each range covers 2 to 3
orders of magnitude, relieving facilities
of the burden of having to report the
exact concentration which may not be
measured and may fluctuate. Influent
concentration data will enhance the
evaluation and comparison of waste
treatment methods by helping users of
the data determine the effectiveness of
treatment methods for wastestreams
containing different amounts of a given
chemical.
Most commenters on this issue stated
that this information should not be
required because it was not specified in
the statute, but little comment was
received on the burden or technical
difficulties of supplying this data. EPA
has retained the reporting of the influent
concentration for each treatment
method in the final rule. The influent
concentration will aid in the evaluation
of treatment methods used throughout
industry by putting the treatment
efficiency data into better perspective.
This requirement should not
significantly increase a facility'*
reporting burden because it can report
the data in fairly broad ranges. For
sequential treatments, the influent
concentration will be required only for
the firs1 treatment step in the overall
treatment sequence.
F. Optional Reporting on Waste
Minimization
The proposed form included an
optional section to allow the respondent
to indicate any action taken in the past
year (other than the waste treatment
methods specified in Part III. Section 8
of the form) to minimize the generation
of waste related to the chemical being
reported. This section was made
optional because the reporting of this
type of information is not required in
section 313. However, the information
that would be provided about waste
reduction is considered by EPA to be an
important indicator of how industry is
responding to the Agency's emphasis on
better waste management through waste
reduction.
In comments on the proposed rule, the
regulated community stated that this
request went beyond the scope of the
statute and that the Agency was not
authorized to collect such information
under Title HI. Reporting on waste
minimization puts an additional burden
and cost on the regulated community.
One commenter noted that if a facility
chooses not to report on waste
minimization, readers of the report may
conclude that no emission reduction is
in place at that facility. On the other
hand, public interest groups stated that
information on waste minimization
would be very useful to the public and
requested that this reporting element be
made mandatory.
The Agency has decided to retain the
optional section on waste minimization.
EPA has no coercive intent in requesting
this optional information. On the
contrary, EPA believes that this section
will provide respondents with a positive
way to demonstrate to the public the
beneficial waste reduction activities
they have undertaken. EPA believes that
the information provided by industry
can indicate longer-term trends in waste
reduction activities. However, the
Agency has attached a 3 year sunset to
this optional section. EPA intends to
study the benefits of this section and
will review the potential overlap
between this reporting question and
reporting on waste minimization under
RCRA regulations.
The proposed optional reporting
section also included space for
providing a narrative description of
waste minimization activities. The
Agency has decided to drop the
narrative space because it will be
difficult for the computerized data base
to accommodate such textual data.
V11I. Chemical List IMUM
A. Modifications to the List
EPA received many comments
suggesting modifications to the list of
chemicals subject to section 313
reporting. Among these comments were
suggested additions to the list
corresponding to other regulated
chemicals such as the 47 toxic pollutants
regulated under the Clean Water Act.
Another comment reflected that all
known carcinogens should be on the list.
Many other comments were made
suggesting specific chemical deletions
from the list of section 313 chemicals.
EPA realizes that some of these
recommendations may be valid.
However, the Agency chose not to use
this initial rulemaking as means to
modify the list of covered toxic
chemicals. EPA plans to begin an m-
depth review of the list of chemicals
currently subject to reporting and an
evaluation of chemicals that should be
added to the initial list beginning in the
first quarter of 1988. The comments
which the Agency has received will be
useful in helping the Agency develop its
methodology for this list review. Any
changes to the section 313 list of
chemicals that appear appropriate
based upon this review will be proposed
for public comment.
B. Nomenclature
1. CAS preferred name versus
common trade name. The list of
chemicals mandated by section 313
contained certain entries identified by
trade names, not chemical names. For
example. Parathion is a trade name. The
chemical name with the corresponding
CAS registry number is Phosphoric acid.
O,O-dimethyl-O-(4-nitrophenyl)ester.
EPA stated in the proposed rule that
reporting facilities should not have to
use a competitor's trade name for
reporting purposes and so, in the case of
a listed trade name, an alternative CAS
preferred name was offered in solid
brackets. The Agency intends to use the
CAS registry number as the unique
identifier for all chemicals except for the
20 chemical categories. Therefore,
reporting facilities can use either the
trade name or the CAS preferred name
that appears in § 372.65 (a) and (b) of the
rule as long as the corresponding CAS
registry number appears on the form.
2. Cyanide compounds. Although
cyanide compounds are described with
a CAS registry number, cyanide
compounds are considered a chemical
category as defined in 5372.65(c) of the
rule. The CAS registry number refers to
the cyanide anion (CN—), which is not a
discrete reportable chemical without a
countenon. Therefore the CAS registry
number listing for cyanide compounds in
§ 372.65 (a) and (b) of the rule has been
removed.
3. Metal and metal compounds. The
original committee print of the list of
chemicals subject to reporting under
section 313 listed metals and their
compounds with the CAS registry
number which corresponded to the
metal only. In its proposal, EPA sought
to separate the metal from metal
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compounds. The distinct metal appears
with its CAS registry number in f 372.65
(a) and (b). and the corresponding metal
compounds category appears in
§ 372.as(c) because tt is a chemical
category.
4. Dyes and Color Index names. EPA
received comment that some dy«
chemicals are listed by a common name
whereas others are listed by a Color
Index (C.I.) name. For example.
Auramme (CAS No. 492-80-8) has the
Color Index name of C.I. Solvent Yellow
34. It was suggested that the list would
be much clearer if all of the dye
chemicals were listed by their Color
Index names. Furthermore, the
chemicals Direct Black 38. Direct Blue 6.
and Direct Brown 95 should also be
listed with the "C.I." prefix. The Agency
agrees wiih these suggestions. Listing
these chemicals using Ihe Color Index
name makes the list consistent. In
§ 37Z.65(a) of the rule all of these dye
chemicals are listed together. EPA has
included the common name in brackets
in the case of Auramine.
5. Glycol ethers. Commenters
suggested that the Agency should
include specific glycol ethers in the
chemical specific listings of 1372.65 (a)
and (b) of the rule and remove it as a
category from 5 372.65(c). EPA considers
this an amendment or modification to
the list of chemicals and is not changing
the list in this culemaking.
C. Reporting Substances of a Certain
Form
Certain of the chemicals listed in the
Committee Print have parenthetic
qualifiers listed next to them. EPA
attempted to clarify these qualifiers in
its proposal. A chemical that is listed
without a qualifier is subject to reporting
in all forms in which it is manufactured.
processed, and used.
1. Fume or dust. Three of the metals
on the list (aluminum, vanadium, and
zinc) contain the qualifier "fume or
dust." EPA interpret* this qualifier to
mean that a facility is manufacturing.
processing, or using the metal in the
form of fume or dust Fume or dust does
not refer to "wet" forms, solutions, or
slurries, for example, but only dry or
anhydrous forms of these metals. As
explained in Unit IV.A. of this preamble.
the term manufacture includes the
generation of a chemical as a byproduct
or impurity. In such cases, a facility
should determine if. for example, it
generated more than the 1987 threshold
of 75,000 pounds per year of aluminum
fume or dust as a byproduct of ils
activities. If so then the facility must
report that it manufactures aluminum
(fume or dust). Similarly, there may be
certain technologies in which one of
these metal* is processed in the form of
a fume or dust to make other chemicals
or other products for distribution in
commerce. In reporting releases, the
facility would only report releases of the
fume or dust.
2 Manufacturing qualifiers. Two of
the entries contain a qualifier relating to
manufacture. For isopropyl alcohol the
qualifier read "mfg.—strong acid
process." For saccharin, the qualifier
sirr.ply reads "manufacturing." In the
case of isopropyl alcohol EPA interprets
the qualifier to mean that only persons
who manufacture isopropyl alcohol by
the strong acid process are required to
report In the case of saccharin, only
manufacturers of saccharin are required
to b« reported. A facility that processes
or otherwise uses either chemical would
not be required to report for those
chemicals. In both of these cases.
supplier not.Lcation does not apply.
3. Solutions. Four substances on the
list are qualified by the term "solution."
These substances are ammonium
nitrate, ammonium sulfate. sodium
hydroxide, and sodium sulfate. EPA
interpret* the term "solution" to refer to
the physical state of these chemicals.
Only facilities that manufacture,
process, or use these chemicals in die
form of a solution would be required to
report these chemicals. See D. of this
Unit for a further discussion of
solutions. la these cases supplier
notification applies only if the chemical
is distributed as a solution.
4. Phosphorus (yellow or ^ite). The
listing for phosphorus is qualified by the
term "yellow or white." This refers to a
chemical state of phosphorus meaning
that only manufacturing, processing, or
use of phosphorus in the yellow or white
states triggers reporting. Conversely,
manufacturing, processing, or use of
"black" or "red" phosphorus would not
trigger reporting. Supplier notification
applies to distribution of yellow or white
phosphorus.
5. Asbestos (friable). The lifting for
ajbesto* is qualified by the term
"friable." Thi* term refers to a physical
characteristic of asbestos. EPA
interprets "friable" as being crumbled.
pulverized, or reducible to a powder
with hand pressure. Again, only
manufacturing, processing, or use of
asbestos in the friable form triggers
reporting. Similarly, supplier notification
applies only to distribution of friable
asbestos. EPA received comment to
include other forms of asbestos. As
noted above, the Agency has chosen not
to use this rulemaking as a vehicle for
modifying the initial list of chemicals.
D. Reporting Chejnical Solutions
1. De minima cut-off for chemical
solutions. The list of chemicals in
5S 372.65 (a) and (b) contain the
qualifier "solution" for some entries
such as sodium sulfate (solution). This
qualifier is defined in C.3. of this Unit.
Technically, a solution is a mixture or
formulation. Certain commenters
suggested that a de minimis cut-off be
applied to the reporting of chemical
solutions consistent with the concept of
a de minimis limitation for mixtures.
EPA agree* with this suggestion because
reporting on these four substances is
consistent with mixture reporting.
Chemicals with the qualifier "solution,"
such as sodium sulfate that are
manufactured processed, or otherwise
used in excess of the de minimis levels
must be factored into threshold and
release reporting requirements of this
rule.
2. Neutralizations and pH
adjustments. EPA received comment
regarding neutralization of solutions
such as dye baths and pH adjustments
of wastewater.
Neutralization is interpreted by EPA
as a chemical reaction. For example.
sodium hydroxide solution is used to
neutralize a dye bath and a solution of
sodium sulfate is formed. Assuming that
other reporting requirements are met
this facility is viewed by EPA as a user
of sodium hydroxide [solution), and a
manufacturer of sodium sulfate
(solution), even if the sodium sulfate is
destined for disposal. Releases of
sodium hydroxide (solution) and of
sodium sulfate (solution) would be
reported.
Adjustments of the pH of a solution
present a more complex circumstance in
establishing reporting with respect to
threshold requirements. The input of a
chemical such as sodium hydroxide
(solution) into wastewater for pH
adjustment constitutes a use of that
chemical and is reportable. Therefore
EPA is requiring facilities that use
section 313 chemicals for pH
adjustments and neutralizations to
report if they meet an applicable
threshold, even if these chemicals are
consumed and no releases result.
However. EPA realizes that there may
be many situations where pH
adjustments are made to complex
mixtures such as wastewater. where il
may be very difficult to determine
whether a section 313 chemical is being
"manufactured" during this
neutralization. Furthermore, quantifying
these chemicals for the purposes of
meeting reporting thresholds may be just
as difficult. The facility must report if it
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knows that a listed toxic chemical is
generated as a result of such
neutralization and has data that allows
for a reasonable estimate of the quantity
generated.
IX. Trade Secret Provision*
A. General Trade Secret Issues
The Agency received a number of
comments relating to the trade secrecy
implications of certain proposed form
elements. Many of these comments have
been addressed in the applicable units
of this preamble. EPA also received a
number of other general comments on
trade secrecy as they relate to claims
under section 313.
EPA proposed a rule in the Federal
Register of October 15,1987 (52 FR
38312). Part of this proposed rule
contains procedures for claims of trade
secrecy under Title III. including a
proposed trade secret claim
substantiation form. General comments
on trade secrecy under the proposed
section 313 rule will be reviewed and
considered as part of the above-
referenced proposed rule.
Until such time as the trade secret rule
is finalized, persons subject to this final
rule are required to comply with section
322. Accordingly, to do so persons who
claim the chemical identity of a toxic
chemical as a trade secret should follow
the provisions of the proposed trade
secret rule. (One exception is noted in B.
of this unit regarding the generic
chemical name which is required to be
provided in the section 313 submission.)
Persons should also use the proposed
trade secret claim substantiation form
until a final form is published.
D. Identifying Adverse Health and
F.rn ironmental Effects Information in
the Data Base
Suction 322(h)(2) of Title DI requires
FPA to identify the adverse health and
environmental effects associated with a
toxic chemical that is claimed trade
secret and assure that such information
is included in the computer data base.
The conference report further explains
it-at "[tjhe adverse effects identified
should be described in general terms so
us not to provide a unique identifier of a
Particular trade secret chemical."
EPA identified several options in its
proposed rule for meeting this
requirement of providing adverse effects
information relating to trade secret
claims. One option would be to develop
a cumulative, worst-case effects
characterization for the predefined
g'-nrnc class of the chemical.
A second option discussed was a
modified generic identification approach
v. here companies would be required to
develop and submit a generic identity
for the chemical, and the EPA would
develop the associated adverse health
effects description that relates to the
general class or category of the
chemical.
A third approach mentioned in the
proposed rule would be to attempt to
develop individual adverse effect
profiles that would be substance-
specific but would mask any particular
effect that is unique and that could
divulge its chemical identity.
EPA received comments on the above
options. Comments generally pointed
towards the obvious difficulty of
maintaining chemical identity as trade
secret while providing adverse health
and environmental effects information.
It is the EPA's intention to provide the
public with as much detailed
information as possible on adverse
effects. However, the Agency is also
obligated to protect the chemical
identity from disclosure through the data
base when a legitimate trade secret
claim is made.
EPA approached this issue by
developing a matrix of the 309 listed
chemicals against the 10 health and
environmental effects specifically
mentioned in section 313(d). Toxicity
data were accumulated from standard
literature sources and. where applicable,
interpreted using Agency guidelines. The
results showed that there were
approximately 70 chemicals that
exhibited unique toxicity patterns
within the 10 effects. EPA proceeded
with this analysis by collapsing the 10
adverse effects categories to attempt to
arrive at a point where there were no
chemicals dial exhibited a unique
toxicity pattern. To reach the "no
unique" result it was necessary to
collapse the categories to the following 4
general categories: Carcinogenicity,
acute toxicity, other human health
effects, and environmental toxicity.
EPA was surprised by the results of
this analysis. EPA believes that
Congress did not anticipate that its
mandate to balance trade secret
protection with the ready availability of
effects information would lead to such a
low degree of specificity for the effects
information. EPA will continue to
explore alternatives for providing the
public with more specific effects
information in connection with
chemicals claimed trade secret. The
Agency plans to publish the analysis
mentioned above for comment sometime
in the second quarter of 1988 before
making any final decisions on the
adverse effects identified in the data
base.
The only impact of this analysis on
the final rule is that EPA will not use the
predefined generic classes as originally
proposed. The analysis indicated that
even the four-effects matrix, when put in
the context of these generic
classifications, created unique patterns
for certain chemicals. As a result the
Agency has decided to require the
reporting facility to provide a suitable
generic chemical name that is
structurally descriptive of the chemical
that is claimed trade secret.
X. Recordltovping
EPA proposed a 5-year recordkeoping
period. Several commenten objected to
this proposed provision. They asserted
that 5 years was an excessively long
period of time to require facilities to
maintain records relative to the reports
under section 313. They asserted that a
3-year recordk«eping period would be
sufficient and would be consistent with
the 3-year recordkeeping period in other
EPA regulations relative to air, solid
waste, and water.
One reason EPA proposed a 5-year
recordkeeping period for section 313
submissions is the expected high
number of facilities potentially subject
to reporting. A 5-year period would
allow EPA to inspect a larger number of
facilities. However, after a review of the
issue EPA believes that • 3-year
recordkeeping period will be sufficient
given that EPA will be receiving
submissions annually from covered
facilities. Therefore, the recordkeeping
period is 3 j ears from the date of
submission of a report for all
information relative to the preparation
of that report
In addition to persons who must
submit reports under the final rule, a
supplier of a mixture or trade name
product must keep records of the fact
that they provided the required
notification relative to the presence and
composition of covered toxic chemicals
in products they distribute in commerce.
Such records must where applicable,
include an explanation of why the
specific chemical identity was
determined to be a trade secret and the
appropriateness of the generic chemical
name provided in the notification
relative to that chemical. If the supplier
provides an upper bound concentration
value instead of a specific
concentration, the supplier must provide
in its records an explanation of why the
specific concentration is deemed a trade
secret and the basis for the upper bound
concentration limit.
XI. Economic Impact
EPA has prepared a Regulatory
Impact Analysis (RIA) in connection
with this final rule. The RIA assesses
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Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations 4521
the economic impact of the final
regulation on the affected industry
(manufacturing. SIC codes 20 through
39) and State and Federal governments.
The following cost result* are presented
in the analysis document titled.
"Regulatory Impact Analysis in Support
of Final Rulemaking Under Section 313
of the Superfund Amendments and
Reauthonzation Act of 1986."
Three alternatives are considered in
the RLA for implementing section 313:
Alternative I—Facilities report by letter.
Alternative II—Facilities report on the
proposed version of Form R. Users
must contact supplier concerning
mixtures and trade name products.
Alternative III—Facilities report on the
final version of Form R. Supplier
notification.
The population of facilities that would
be required to submit reports under
section 313 is based on three sources:
census data for national totals of
facilities engaged in manufacturing,
surveys of toxic substances use
conducted by 6 States and localities
involving a subset of the substances
contained in the list of 329 chemicals
convered by section 313. and production
of toxic chemicals reported for the Toxic
Substances Control Act Inventory.
Section 313 requires annual reports on
releases of toxic chemicals from an
estimated 31.800 facilities. Overall, the
Agency may receive an estimated
318,000 reports annually. This equals an
average of 10 reports per facility.
The total costs per average facility, as
well as per chemical report costs, are
shown in Table I below.
TABLE I.—TOTAL COSTS PER AVERAGE REPORTING FACILITY AND PER CHEMICAL REPORT ($/YR.)
Compliance determination ....
RecordKeepmg
Report completion (\Q chemtcafs)
Identification of mixtures - . ..
Report completion (3 mixtures) .. .- - ...
Mailing -
Total cottt per facitity
Total costs par chemcal report _
Regulatory alternative 1
First year
1,195.20
101 78
172312
8,03668
2.22293
23266
694
14.019.30
1,401.93
Subse-
quent
year*
296.60
41 92
6.14496
200.72
15834
6.94
6.851.70
685.17
Regulatory alternative
II
First year
1.195.20
101 76
11.295.80
272293
291.22
6.94
1S.113.8S
1.511.39
Subse-
quent
years
296.80
41 92
7,660.60
200.72
197.78
694
8.426.76
842.68
Regulatory alternative in
First year
1,19520
101 76
11.59500
0.00
0.00
6.04
12,69600
1789.80
Subse-
quent
years
29680
41 92
7.8*406
9634.
88776
000
604
8,32716-
9,11856
63272-
911 86
Source—RIA 1987.
The costs represented in Table I are
for reporting facilities. The final rule will
cause costs to be incurred by more
facilities than will actually be subject to
reporting. All facilities with 10 or more
full time employees in SIC code* 20
through 39 will incur some costs
associated with compliance
determination! (i.e., becoming familiar
with the rule and the form, and
determining if they meet the threshold
requirements for any of the section 313
chemicals). An estimated 146,450
facilities will incur the compliance
determination costs. These costs, which
do not vary across the alternatives, are
included in the aggregate industry costs
shown in Table 0 below.
TABLE ll.—AGGREGATE COSTS FOR INDUSTRY: FIRST AND SUBSEQUENT REPORTING YEARS
[Million dollar* par year]
CompUanci
Formatting
Report con
Userxonti
Report con
SuppUertK
Tota
( deiermnaMn
yleoon for rtMfntals
ipteoon for nusjaa . .... ... ., .... ....
lerttification of marlme .— .-
iforffunq usari
Regulatory
alternative 1
Ftrat
year
1373
37
389
2876
277
43.S
7.4
0.8
10.3
5567
Subse-
quent
year*
343
1.3
19S.6
2.0
4.4
5.1
0.1
t.O
243.8
Regulatory
anematrvell
First
year
137.3
37
3564
277
43.S
87
OJ
10.3
59VO
Subee-
quent
year*
34.3
13
2444
2.0
44
6.3
O.t
1.0
283.9
Regulatory alternative
III
Rrat
year
1373
37
358.4
277
527.1
Subsequent
years
343
1 3
2509-2539
2.0
01-08
0.7-6.9
289.3-2992
Source—HIA.
Range of costs m subsequent yew* of Attemetn* ill i
represent* subaaquenl year*.
i' that are pnaseoHn. That •. the high end of the ranges represent* year 2, and the tow end
The other major costs that will be
incurred by non-reporting facilities
involve mixtures and trade name
products. The proposed rule would have
required that processors and users of
mixtures and trade name products
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4522 Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations
contact suppliers and document the
information provided by suppliers, if
infonnaiton were not provided by
suppliers, processors and users were
required to submit partial reports for
mixtures and trade name products. The
final rule places the burden on the
supplier to provide the information to
users. Suppliers and users would incur
costs under all alternatives, as shown in
Table II. Supplier costs are lower for the
final rule, because suppliers would be
initialing the information, rather than
responding to requests from users.
The costs of users will also be lower
for the final rule, as the information on
mixtures will be made available to them
and consequently there will be no costs
for contacting suppliers and
documenting the contacts.
To compare costs of the proposed rule
to the final rule it is necessary first to
understand that the costs for the
proposed rule have been revised. The
four major reasons for revisions to the
cost estimates are summarized as
follows:
t. The number of chemcial reports per
facility increased from 4 to 10. Basis for
change: Public comments, section 313
pretest, and data from five additional
State and local data bases on chemical
use.
2. Costs for compliance
determinations increased by 33.0
percent. Basis for change: Revisions to
costs developed in the R1A for the
proposed Comprehensive Assessment
Information Rule (CAIR).
3. Estimates for calculating releases in
the proposal were based on pretest of
CAIR form and contractor estimates.
These estimates have been reduced by
30 percent. Basis for change: Re\ isions
to proposed CAIR costs and section 313
pretest.
4. Costs for suppliers (screening
mixtures and informing users) and users
(screening mixtures) were not originally
included.
These costs are compared in Table III
below.
TABLE III.—SUMMARY OF COST COMPARISON BETWEEN PROPOSED AND FINAL RULE
(Rrst-year cost)
Proposed
«u va
Total nunber of cnefrvcal reports j 132 340 r-
Total numoer of partial mixture J 3? 7Rn
Total jndustry costs
Reports per facditv J
$472 7 million, $527 \ million
4 cnenwcaJ. 1 mixture.. . ..
1 Revised proposed final j
1 ]
' 31ft 000 310000
i a* "V1
. - ... ' $591 0 million I
, 3 chemical. 7 fun reporu-modurea, 3 I 3 cnemcm.
7 ful repOftt-fflutues
The number of chemical reports per
facility increased 2.5 times but initial
doubling of CAJR estimates was found
to be unnecessary and inclusion of
supplemental time to estimate releases
was also found to be double counting.
First year costs per reporting facility
increased from about $12,500 in the June
R1A to $15.100 for this same (proposed)
version of the form, reflecting the above
factors and an increase from the more
thorough accounting for the
responsibilities attributed to mixtures.
Phdse-in of mixtures and placement of
the burden upon supplier* rather than
users account for the final rule's
(Alternative HI) lower cost of $12.900 per
facility.
EPA has chosen to develop the form
and rule in order to provide for uniform
reporting, so that a computerized data
base of high quality and utility can be
created and maintained EPA will incur
costs to process, check, store, and make
available the data reported under
section 313. EPA's costs will vary
depending upon its choice of data
management systems and policies, but
are estimated to range from between
$7.7 and $28.4 million per year. States
will also have some expense* for
processing, storing, and distributing
reports sent to them. State costs are
estimated to be from $17 to $2.2 million
per year.
XII. Duplication of Reporting
Under both section 313 of SARA and
section 103 of CERCLA. EPA requires
companies to submit information on
chemical releases into the environment.
While the two statutory provisions are
similar in their reporting requirements,
they differ in both scope and purpose.
Section 313 requires reporting only by
facilities in SIC codes 20 through 39.
Section 103(f)(2) places no such
restrictions on iU applicability. Alto,
some chemicals covered under CERCLA
section 103 are not subject to SARA
section 313 reporting requirements, and
certain additional chemicals not subject
to CERCLA notification are included in
•ection 313 notification requirements.
The two statutory provisions also
differ in purpose. While the purpose of
section 313 of SARA is to create a
Federal inventory of the listed
chemicals, the purpose of the CERCLA
section 103 reporting requirements is to
gather information for emergency
response.
A review of the issue found that
significant amounts of duplication do
not exist between these two
requirement*.
Xm. Public Data Baa«
Section 313(jJ states that the
Administrator shall establish and
maintain in a computer data base a
national toxic chemical inventory basf i
on data submitted to the Administrator
under section 313. EPA shall make this
data accessible by computer
telecommunications and other means to
any person on a cost reimbursable
basis.
EPA is reviewing potential options
through which the toxic chemical
inventory can be made available to the
public. There are numerous vehicles and
mechanisms under consideration by
EPA for the wide dissemination and
accessibility of the inventory to the
public on a cost reimbursement basis
with the potential for fee reductions or
waivers.
EPA developed early draft options as
examples of potential vehicles and
mechanisms for the public availability
of a toxic chemical inventory data base.
This preliminary draft options paper
was the subject of a public meeting held
on April 20,1987. Comment* from thi*
public meeting and subsequent
discussion* with other Federal agencies.
industry. State*, and environmental
groups are serving as the basis for
further analysis by EPA.
After further review of public
availability options, EPA will determine
which set of products and services will
provide the most feasible and widest
dissemination of the toxic chemical
inventory to the public. EPA expects to
be able to make the data base available
in the first quarter of 1989.
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Federal Register / Vol. 53. No. 30 / Tuesday, February 16, 1988 / Rules and Regulations 4523
XIV. Rulemaking Record
The following documents constitute
the rulemaking record for this rule
(docket control number OPTS-400002A).
All documents, including the index of
this record, are available to the public in
the OTS Reading Room from 8 a.m. to 4
p.m.. Monday through Friday, excluding
legal holidays. The OTS Reading Room
is located at EPA Headquarters. Rm.
NE-G004, 401 M St., SW.. Washington.
DC 20460. The record includes the
following information considered by the
Agency in developing this rule:
1. Documents in docket no. 400002 at
the date of publication of the proposed
rule.
2. The proposed rule.
3. Transcripts of public meetings held
July 24 and 27, and August 4,1967.
4. Written comments received on the
proposed rule.
5. Summaries of meetings held with
representatives of industry, public
interest groups, and State government
officials.
6. The document titled "Regulatory
Impact Analysis in Support of the Final
Rulemaking Under section 313 of the
Superfund Amendments and
Reauthorization Act of 1986" (1967).
XV. Regulatory Assessment
Requirements
A. Executive Order 22291
Under Executive Order 12291. EPA
must judge whether a rule is "major"
and therefore requires a R1A. EPA has
developed a RIA as described in Unit
XI. This RIA shows that the combination
of impacts of the statutory provisions of
section 313 and the interpretive
provisions of this rule may create a first
year impact of $527 million and a second
year impact of S299 million. EPA has
determined that this rule is "major"
because it may have an effect of $100
million or more on the economy. EPA
does not, however, anticipate that this
rule will have a significant effect on
competition, costs, or pnces.
This rule was submitted to the Office
of Management and Budget (OMB) for
review as required by Executive Order
12291.
B. Regulatory Flexibility Act
Section 313 and the final rule exempt
certain small businesses from reporting,
i.e., those facilities in SIC codes 20
through 39 with fewer than 10 full-time
employees. The statutory exclusion of
facilities with fewer than 10 full-time
employees exempts 48 percent of ail
manufacturing facilities in SIC codes 20
through 39. After also considering the
volume thresholds. EPA estimates that
section 313 will require reporting from
approximately 3.0 percent (9,400 of
277,100) of all small manufacturing
facilities with less than 50 employees.
Analysis to support the proposed rule
indicated that for some segments of the
manufacturing sector the compliance
costs of reporting will have a significant
impact. Specifically, reporting costs are
estimated to be between 1.0 and 2.0
percent of median sales for facilities
with fewer than 50 employees: and
between 2.0 and 4.0 percent of median
sales for facilities with 10 to 19
employees. Subsequent to proposal, the
Agency developed and included a
Regulatory Flexibility Analysis in the
RIA to examine options that might
reduce the burden to small businesses.
The Agency received extensive
comments on the impacts of the
proposed rule on small businesses from
the small Business Administration
(SBA). SBA presented several
alternatives designed to reduce the
burden to small businesses, based on
the premise that small facilities (those
with fewer than 100 employees) have
nothing significant to report. These
alternatives are discussed below.
SBA proposed the development of
thresholds based on risks posed by
various emission sources. SBA
maintains that data exists from the
Agency's regional studies that would
allow the Agency to calculate risks from
air and water emissions, from which the
Agency could develop thresholds for
reporting based on specific risks. From
its review of the data. SBA concludes
that "small firms collectively contribute
only a small fraction, generally less than
10 to 15 percent, of the toxic chemical
emissions included in the local area
studies." SBA acknowledges that "there
may be a lack of information on toxicity
which would make [a risk] analysis
infeasible for certain chemicals."
SBA's second proposed alternative is
to combine section 313 with CERCLA
section continuous release reporting,
using 10 pounds a day Reportable
Quantity (RQ) for any section 313
chemicals not covered under CERCLA.
SBA states that this would ensure that
"facilities of primary concern (those
with significant emissions) are
included." SBA believes this approach
would also alleviate the significant
economic burden on small businesses.
SBA recommends as a third
alternative a de minimi's reporting range
of 0 to 1 pound of emissions per day or 0
to 250 pounds per year. SBA's fourth
alternative was a total exemption of
small facilities (defined by SBA as those
with fewer than 100 employees) from
reporting; and/or an abbreviated or
shortened reporting form.
The Agency received comments both
in support of an in opposition to SBA's
position. The Agency identified 8
regulatory alternatives as part of the
Regulatory flexibility Analysis for this
rule. The alternatives, evaluated on the
basis of cost and economic criteria,
represent options for reducing the
reporting burden for small businesses.
Each alternative is described and
discussed below.
Alternative 1: Rule as proposed;
statutory exclusion of facilities having
fewer than 10 employees. This
alternative allows complete coverage of
reporting on emissions, but provides no
reduction in burden to small facilities.
Alternative 2: Exempt all small
businesses (defined as facilities with
fewer than 50 employees). [The RIA
analyzes alternative definitions of small
businesses.) This alternative not only
reduces the reporting burden for small
businesses, but eliminates any burden of
compliance determination from small
facilities. However, this alternative
would result in no reporting of emissions
from small facilities, which could lead to
substantial gaps in the Emissions
Inventory, especially at the community
level.
The costs are summarized in Table IV
below.
TABLE IV.—REGULATORY FLEXIBILITY
STUDY OPTIONS: COSTS PER FACILITY
(Present Value 'or '0 Years of Reporting}
Coat(')
Option
1
2
3 ..
4
5 ..
6
7 ..
8
$54.320
0
' $54.320
$5.100 to $54,320
$5.100
$24.680
$47.130(0 '$52.630
$34.410 to'$50.990
1 In present value 1987 dollars at a 10 percent
discount rate tor years 1988-1997
' Given me absence of any SIC codes that would
meet exemption cntena.
3 Average cost But this option would offer me
benefit of limiting the extent to which individual
facilities would exceed the average
• Assume* all 10 chemicals per facility ertroy 10 lo
50 percent cost savings lor estimates ol air and
water releases in ranges.
Alternative 3: Exempt facilities in
specific SIC codes if they account for
low aggregate emissions. This
alternative would exempt small
businesses in particular industries that
might trigger the need to report based on
the volume threshold for use, but have
little actual emissions. However, after
examining the available data (six State
and local data bases that contain
emissions data for some of the section
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4524 Federal Register / Vol. 53, No. 30 / Tuesday. February 16. 1988 / Rules and Regulations
313 chemicals), no SIC codes were
identified that met the criterion.
Alternative 4: Require annual
reporting by small businesses only of
Parts I through VI of proposed Form R.
Parts Vll through X of tile proposed form
would be due only upon request by EPA.
This alternative would eliminate the
most onerous part of the reporting
burden (i.e.. estimating releases).
However, while small facilities would
be identified in the data base, the most
important information (i.e., emissions)
would not be captured. Therefore the
utility to the public of the date base
would be reduced. There also would be
likely increased administrative costs
with such an approach when the
emissions data are requested. These
costs would be incurred by the public
(for requesting information), industry
(for having to essentially fill out a form
for some chemicals twice), and the
Agency (for establishing procedures of
how and to whom the request should be
made, response times, etc.).
Alternative 5: Require annual
reporting by small businesses only of
Parts I through VI of proposed Form R
plus data on quantity used or produced;
EPA estimates releases from small
business facilities. This alternative
would eliminate the most onerous part
of the reporting burden as described m
Alternative 4. EPA would provide
emissions estimates in the data base
that were more consistently derived.
However, the information that EPA
would have to require to estimate
releases may actually increase the
information required on the form. For
example. EPA would have to require
production, processing, or use volume
information. This approach would
increase Agency costs for calculating
releases- It would also require industry's
willingness to report such potentially
confidential or trade secret information
^as a tradeoff for the lowered burden.
Alternative 6. Require reporting by
small businesses every third year, rather
than annually This alternative would
reduced the burden to small facilities
over time, while still providing data on
small facilities and their emissions in
tbe data base. However, the frequency
of reporting cannot be changed until
1993 under section 313(i).
Alternative 7: Require •mall
businesses tr report only up to a certain
number of chemicals per year. This
alternative would place a cap on the
number of chemicals that small
businesses would report each year. The
burden would be reduced for those
small facilities with more than the
average number of chemicals per
Facility. Data on small facilities and
estimates of emissions would still be
provided in the data base. However, in
the intervening years until facilities
have reported on all section 313
chemicals, the data base will not be as
complete or as accurate.
Alternative 8: Allow small businesses
to mark ranges check-boxes for release
less than 1,000 pounds per year to any
environmental medium. The check
boxes would apply to 0,1 to 499 pounds
per year, and 500 to 999 pounds per year.
The facility would have the option of
reporting a specific figure rather than
checking a box. Tbe facility would have
to provide a specific figure estimate /or
releases of 1,000 pounds or more per
year. The reporting burden would be
reduced by not requiring small facilities
to further refine estimates of these lower
level releases. A certain degree of
precision might be lost relative to
analyzing the releases reporting in such
ranges. However, the data base would
maintain a higher degree of
completeness relative to other options
(except option l) because all data
required by the form would be reported
each year by all facilities.
Conclusions: The Agency has the
authority to establish different
thresholds for a chemical, class of
chemicals, or categories of facilities.
However, any revised threshold must
obtain reporting on a substantial
majority of total releases of the
chemicals at all facilities subject to
reporting. Based on the limited available
data the Agency cannot support any
modification of thresholds based on size
of facility, and still be able to maintain
that a substantial majority of the total
releases would be captured through
reporting. EPA analyzed certain limited
use and release data available on a
subset of the section 313 chemicals from
the states of New Jersey. Michigan, and
Massachusetts. These data were used to
estimate the potential impact on
coverage of aggregate emissions,
coverage of chemical-by-chemical
emissions, and coverage of emissions at
the community level. This analysis
shows that facilities with fewer than 49
employees account for a least 30 percent
of the air releases for 12 of 87 chemicals
listed in the New jersey data base. EPA
concluded that exempting facilities of '
this size range from reporting may lead
to lack of coverage of certain chemicals.
Therefore, the Agency is not modifying
the thresholds (i.e- the annual pounds of
a toxic chemical manufactured,
processed, or otherwise used) for small
facilities.
However, aa a result of this analysis
and consultation with SEA. the Agency
has incorporated alternative No. A,
limited range reporting, into the
reporting requirements of the rale. It is
difficult from the data available to EPA
to estimate exact burden savings
associated with this approach. Savings
for any individual small facility will
depend upon the number of chemicals
being reported and the number of
environmental media to which each
chemical is released. For example, a
simple mass balance around a process
may be adequate to show that air
releases are less than 1.000 pounds. The
information necessary to complete such
a mass balance should be readily
available and tabulated, at least partly,
to determine whether the reporting
threshold is met. By relying on a rough
mass balance calculation, the facility
could avoid calculating releases from
individual process points (for example.
valve and flanges leaks, or storage tanks
vents). Completing these calculations
requires that additional information be
tabulated (e.g., the number of valves, or
the size of storage tanks).
For a release to a single medium, the
savings could be as high as 50 percent of
the time for completion of the release
section of the form (12 of 24 hours). For
releases of a chemical to several media
the savings are likely to be
approximately 10 percent because of the
time required to determine how such
releases are apportioned per media.
These savings are reflected in the cost
per facility for option 8 in Table IV. SBA
believes that EPA's estimates of savings
are conservative and that small facilities
would benefit substantially from this
approach.
EPA expects that small facilities will
realize the most benefit from the
optional range reporting concept
because larger facilities are more likely
to have the technical capabilities to
develop more specific estimates.
However. EPA believes that this
optional range reporting provision could
provide a burden reducing benefit to any
subject facility regardless of size.
Therefore. EPA has extended tbe
optional range reporting provision to all
subject facilities.
EPA believes that it will be necessary
to evaluate the relative costs and
benefits of this alternative in light of the
first few years of section 313
submissions. Therefore, a 3-year
limitation has been attached to this
provision. The limited range reporting
option will apply to the 1987,1988. and
1989 reporting years unless EPA Lakes
action to extend or permanently adopt
this reporting provision. EPA will
publish its analysis prior to allowing the
provisions to expire.
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Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations 4525
C. Papenvork Reduction Act
OMB has reviewed the information
collection requirements contained in this
rule under the provisions of the
Paperwork Reduction Act of 1980. 44
U.S.C. 3501 et $eq. and has assigned
OMB control number 2070-0093.
List of Subjects in 40 CFR Part 372
Environmental protection.
Recordkeeping, reporting, and
notification requirements, Toxic
chemicals.
Dated-. February 2.1906.
A. )ama* Barnes.
Acting Administrator.
Therefore. Chapter I of 40 CFR is
amended by adding a new Part 372 to
read as follows:
PART 372—TOXIC CHEMICAL
RELEASE REPORTING; COMMUNITY
RIGHT-TO-KNOW
Subpart A—General Provision*
Sec.
372.1 Scope and purpose.
3713 Definitions.
372-S Person* subject to this Part
372.10 Recordkeeping.
372.18 Compliance and enforcement.
Subpart S—Reporting R*quir*m«fits
372.22 Covered facilities for toxic chemical
release reporting.
372.25 Thresholds tor reporting.
372.30 Reporting requirements and schedule
for reporting.
372.38 Exemptions.
Subpart C-6uppft*r Motif teatton
Requirement*
372.45 Notification about toxic chemicals.
Subpart 0—Specific Toxic Chemical
Listings
372.65 Chemicals and chemical categories to
which this Part applies.
Subpart E forma and Instruction*
372.85 Toxic chemical release reporting
form and instruction!.
Authority: 42 U.S.C. 11013. 11028.
Subpart A—General Provision*
{ 372.1 Scop* and purpose.
This Part sets forth requirements for
the submission of information relating to
the release of toxic chemicals under
section 313 of Title III of the Superfund
Amendments and Reauthorization Act
of 1986. The information collected under
this Part is intended to inform the
general public and the communities
surrounding covered facilities about
releases of toxic chemicals, to assist
research, to aid in the development of
regulations, guidelines, and standards,
and for other purposes. This Part also
sets forth requirements for suppliers to
notify persons to whom they distribute
mixtures or trade name products
containing toxic chemicals that they
contain such chemicals.
§372.3 Definition*.
Terms defined in sections 313(bj(l)(c)
and 329 of Title 111 and not explicitly
defined herein are used with the
meaning given in Title III. For the
purpose of this Part:
"Acts" means Title IIL
"Article" means a manufactured item:
(1) Which is formed to a specific shape
or design during manufacture: (2) which
has end use functions dependent in
whole or in part upon its shape or design
during end use; and (3) which does not
release a toxic chemical under normal
conditions of processing or use of that
item at the facility or establishments.
"Customs territory of the United
States" means the 50 States, the District
of Columbia, and Puerto Rico.
"EPA" means the United States
Environmental Protection Agency.
"Establishment" means an economic
unit, generally at a single physical
location, where business is conducted or
where services or industrial operations
are performed.
"Facility" means 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 (or by any person
which controls, is controlled by, or
under common control with such
person). A facility may contain more
than one establishment
"Full-time employee" means 2.000
hours per year of full-time equivalent
employment. A facility would calculate
the number of full-time employees by
totaling the hours worked during the
calendar year by all employees,
including contract employees, and
dividing that total by 2.000 hours.
"Import" means to cause a chemical
to be imported into the customs territory
of the United States. For purposes of this
definition, "to cause" means to intend
that the chemical be imported and to
control the identity of the imported
chemical and the amount to be
imported.
"Manufacture" means to produce,
prepare, import or compound a toxic
chemical Manufacture also applies to a
toxic chemical that is produced
coincidentaily during the manufacture,
processing, use, or disposal of another
chemical or mixture of chemicals.
including a toxic chemical that is
separated from that other chemical or
mixture of chemicals as a byproduct
and a toxic chemical that remain* in
that other chemical or mixture of
chemicals as an impurity.
"Mixture" means any combination of
two or more chemicals, if the
combination is not. in whole or in part,
the result of a chemical reaction.
However, if the combination was
produced by a chemical reaction but
could have been produced without a
chemical reaction, it is also treated as a
mixture. A mixture also includes any
combination which consists of a
chemical and associated impurities.
"Otherwise use" or "use" means any
use of a toxic chemical that is not
covered by the terms "manufacture" or
"process" and includes use of a toxic
chemical contained in a mixture or trade
name product. Relabeling or
redistributing a container of a toxic
chemical where no repackaging of the
toxic chemical occurs does not
constitute use or processing of the toxic
chemical.
"Process" means the preparation of a
toxic chemical, after its manufacture, for
distribution in commerce;
(1) In the same form or physical state
as. or in a different form or physical
state from, that in which it was received
by the person so preparing such
substance, or
(2) As part of an article containing the
toxic chemical. Process also applies to
the processing of a toxic chemical
contained in a mixture or trade name
product
"Release" means any spilling, leaking.
pumping, pouring, emitting, emptying,
discharging, injecting, escaping,
leaching, dumping, or disposing into the
environment (including the
abandonment or discarding of barrels.
containers, and other closed
receptacles) of any toxic chemical.
"Senior management official" means
an official with management
responsibility for the person or persons
completing the report or the manager of
environmental programs for the facility
or establishments, or for the corporation
owning or operating the facility or
establishments responsible for certifying
similar reports under other
environmental regulatory requirements.
Title III" means Title III of the
Superfund Amendments and
Reauthorization Act of 1986. also titled
the Emergency Planning and Community
Right-To-Know Act of 1986.
"Toxic chemical" means a chemical or
chemical category listed in ( 372.65.
'Trade name product" means a
chemical or mixture of chemicals that is
distributed to other persons and that
incorporates a toxic chemical
component that is not identified by the
applicable chemical name or Chemical
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4528 Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 198fl / Rules and Regulations
Abstracts Service Registry number
listed in § 372.65.
§372.5 Persons subject to this Part
Owners and operators of facilities
described in |J 372.22 and 372.45 are
sublet to the requirements of this Part.
If the owner and operator of a facility
are different persons, only one need
report under § 372.17 or provide a notice
under § 372.45 for each toxic chemical in
a mixture or trade name product
distributed from the facility. However, if
no report is submitted or notice
provided, EPA will hold both the owner
and the operator liable under section
325(c) of Title 111. except as provided in
§ § 372.38(e) and 372.45{g).
§372.10 Recordkeeptag.
(a) Each person subject to the
reporting requirements of this Part must
retain the following records for a period
of 3 years from the date of the
submission of a report under 5 372.30:
(1) A copy of each report submitted by
the person under { 372.30.
(2) All supporting materials and
documentation used by the person to
make the compliance determination that
the facility or establishments is a
covered facility under § 372.22 or
§ 372.45.
(3) Documentation supporting the
report submitted under § 372.30
including:
(i) Documentation supporting any
determination that a claimed allowable
exemption under } 372.38 applies.
(li) Data supporting the determination
of whether a threshold under $ 372.25
applies for each toxic chemical.
(iii) Documentation supporting the
calculations of the quantity of each toxic
chemical released to the environment or
transferred to an off-site location.
(iv) Documentation supporting the use
indications and quantity on site
reporting for each toxic chemical,
including dates of manufacturing,
processing, or use.
(v) Documentation supporting the
basis of estimate used in developing any
telease or off-site transfer estimates for
each toxic chemical.
(vi) Receipts or manifests associated
\vith the transfer of each toxic chemical
in waste to off-site locations.
(vii) Documentation supporting
reported waste treatment methods,
estimates of treatment efficiencies.
ranges of influent concentration to such
treatment, the sequential nature of
treatment steps, if applicable, and the
actual operating data, if applicable, to
support the waste treatment efficiency
estimate for each toxic chemical.
(b) Each person subject to the
notification requirements of this part
must retain the following records for a
period of 3 years from the date of the
submission of a notification under
I 372.45.
(1) All supporting materials and
documentation used by the person to
determine whether a notice is required
under § 372.45.
(2) All supporting materials and
documentation used in developing each
required notice under I 372.45 and a
copy of each notice.
(c) Records retained under this section
must be maintained at the facility to
which the report applies or from which a
notification was provided. Such records
must be readily available for purposes
of inspection by EPA.
§ 372.18 Compliance and enforcement
Violators of the requirements of this
Part shall be liable for a civil penalty in
an amount not to exceed $25.000 each
day for each violation as provided in
section 325(c) of Title III.
Subpart B—Reporting Requirements
§ 372.22 Covered facilities for toxic
chemical release reporting.
A facility that meets all of the
following criteria for a calendar year is
a covered facility for that calendar year
and must report under $ 372.30.
(a) The facility has 10 or more full-
time employees.
(b) The facility is in Standard
Industrial Classification Codes 20
through 39 (as in effect on January 1,
1987) by virtue of the fact that it meets
one of the following criteria:
(1) The facility is an establishment
with a primary SIC code of 20 through
39.
(2) The facility is a multi-
establishment complex where all
establishments have a primary SiC code
of 20 through 39.
(3) The facility is a multi-
establishment complex in which one of
the following is true:
(i) The sum of the value of products
shipped and/or produced from those
establishments that have a primary SIC
code of 20 through 39 is greater than 50
percent of the total value of all products
shipped and/or produced from ail
establishments at the facility.
(ii) One establishment having a
primary SIC code of 20 through 39
contributes more in terms of value of
products shipped and/or produced than
any other establishment within the
facility.
(c) The facility manufactured
(including imported), processed, or
otherwise used a toxic chemical in
excess of an applicable threshold
quantity of that chemical set forth in
$ 372.25.
§ 372.2S Thresholds for reporting.
The threshold amounts for purposes of
reporting under | 372.30 for toxic
chemicals are as follows:
(a) With respect to a toxic chemical
manufactured (including imported) or
processed at a facility during the
following calendar years:
1987—75.000 pounds of the chemical
manufactured or processed for the year.
1988—50.000 pounds of the chemical
manufactured or processed for the year.
1989 and thereafter—25,000 pounds of
the chemical manufactured or processed
for the year.
(b) With respect to a chemical
otherwise used at a facility, 10.000
pounds of the chemical used for the
applicable calendar year.
(c) With respect to activities involving
a toxic chemical at a facility, when more
than one threshold applies to the
activities, the owner or operator of the
facility must report if it exceeds any
applicable threshold and must report on
all activities at the facility involving the
chemical, except as provided in f 372.38.
(d) When a facility manufactures,
processes, or otherwise uses more than
one member of a chemical category
listed in $ 372.65(c). the owner or
operator of the facility must report if it
exceeds any applicable threshold for the
total volume of all the members of the
category involved in the applicable
activity. Any such report must cover all
activities at the facility involving
members of the category.
(e) A facility may process or
otherwise use a toxic chemical in a
recycle/reuse operation. To determine
whether the facility has processed or
used more than an applicable threshold
of the chemical, the owner or operator of
the facility shall count the amount of the
chemical added to the recycle/reuse
operation during the calendar year. In
particular, if the facility starts up such
an operation during a calendar year, or
in the event that the contents of the
whole recycle/reuse operation are
replaced in a calendar year, the owner
or operator of the facility shall also
count the amount of the chemical placed
into the system at these times.
(f) A toxic chemical may be listed in
$ 372.85 with the notation that only
persons who manufacture the chemical.
or manufacture it by a certain method.
are required to report. In that case, only
owners or operators of facilities that
manufacture that chemical as described
in $ 372.65 in excess of the threshold
applicable to such manufacture in
i 372.25 are required to report. In
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Federal Register / Vol. 53, No. 30 / Tuesday. February 16. 1908 / Rules and Regulations 4527
completing the reporting form, the owner
or operator 13 only required to account
for the quantity of the chemical so
manufactured and releases associated
with such manufacturing, but not
releases associated with subsequent
processing or use of the chemical at that
facility. Owners and operators of
fdcilities that solely process or use such
a chemical are not required to report for
that chemical.
(g) A toxic chemical may be listed in
§ 372.65 with the notation that it is in a
specific form (e.g.. fume or dust.
solution, or friable) or of a specific color
(e.g.. yellow or white). In that case, only
owners or operators of facilities that
manufacture, process, or use that
chemical in the form or of the color,
specified in J 372.65 in excess of the
threshold applicable to such activity in
§ 372.25 are required to report. In
completing the reporting form, the owner
or operator is only required to account
for the quantity of the chemical
manufactured, processed, or used in the
form or color specified in § 372.65 and
for releases associated with the
chemical in that form or color. Owners
or operators of facilities that solely
manufacture, process, or use such a
chemical in a form or color other than
those specified by \ 372.65 are not
required to report for that chemical.
(h) Metal compound categories are
listed in { 372-B5(c). For purposes of
determining whether any of the
thresholds specified in { 372.25 are met
for metal compound category, the owner
or operator of a facility must make the
threshold determination based on the
total amount of all members of the metal
compound category manufactured,
processed, or used at the facility. In
completing the release portion of the
reporting form for releases of the metal
compounds, the owner or operator it
only required to account for the weight
of the parent metal released. Any
contribution to the mass of the release
attributable to other portions of each
compound in the category is excluded.
§ 372.30 Reporting requirements and
•chedul* for tepoitlng.
[a) For each toxic chemical known by
the owner or operator to be
manufactured (including imported),
processed, or otherwise used in excess
of an applicable threshold quantity in
§ 372.25 at its covered facility described
in { 372.22 for a calendar year, the
owner or operator must submit to EPA
and to the State in which the facility is
located a completed EPA Form R (EPA
Form 9350-1) in accordance with the
instructions in Subpart E.
(b)(l) The owner or opera tor of a
covered facility is required to report as
described in paragraph (a) of this
section on a toxic chemical that the
owner or operator knows is present as a
component of a mixture or trade name
product which the owner or operator
receives from another person, if that
chemical is imported, processed, or
otherwise used by the owner or operator
in excess of an applicable threshold
quantity in § 372.25 at the facility as part
of that mixture or trade name product.
(2) The owner or operator knows that
a toxic chemical is present as a
component of a mixture or trade name
product (i) if the owner or operator
knows or has been told the chemical
identity or Chemical Abstracts Service
Registry Number of the chemical and the
identity or Number corresponds to an
identity or Number in { 372.65, or (ii) if
the owner or operator has been told by
the supplier of the mixture or trade
name product that the mixture or trade
name product contains a toxic chemical
subject to section 313 of the Act or this
Part.
(3) To determine whether a toxic
chemical which is a component of a
mixture or trade name product has been
imported, processed, or otherwise used
in excess of an applicable threshold in
§ 372.25 at the facility, the owner or
operator shall consider only the portion
of the mixture or trade name product
that consists of the toxic chemical and
that is imported, processed, or otherwise
used at the facility, together with any
other amounts of the same toxic
chemical that the owner or operator
manufactures, imports, processes, or
otherwise uses at the facility as follows:
(i) If the owner or operator knows the
specific chemical identity of the toxic
chemical and the specific concentration
it which it is present in the mixture or
ade name product, the owner or
^perator shall determine the weight of
the chemical Imported, processed, or
otherwise used as part of the mixture or
trade name product at the facility and
shall combine that with the weight of
the toxic chemical manufactured
(including imported) processed, or
otherwise used at the facility other than
as part of the mixture or trade name
product. After combining these amounts,
if the owner or operator determines that
the toxic chemical was manufactured,
processed, or otherwise used in excess
of an applicable threshold in { 372.25,
the owner or operator shall report the
specific chemical identity and all
releases of the toxic chemical on EPA
Form R in accordance with the
instructions in Subpart E.
(ii) If the owner or operator knows the
specific chemical identity of the toxic
chemical and does not know the specific
concentration at which the chemical is
present in the mixture or trade name
product, but has been told the upper
bound concentration of the chemical in
the mixture or trade name product, the
owner or operator shall assume that the
toxic chemical is present in the mixture
or trade name product at the upper
bound concentration, shall determine
whether the chemical has been
manufactured, processed, or otherwise
used at the facility in excess of an
applicable threshold as provided in
paragraph (b)(3)(i) of this section, and
shall report as provided in paragraph
(b)(3)(i) of this section.
(iii) If the owner or operator knows
the specific chemical identity of the
toxic chemical, does not know the
specific concentration at which the
chemical is present in the mixture or
trade name product, has not been told
the upper bound concentration of the
chemical in the mixture or trade name
product, and has not otherwise
developed information on the
composition of the chemical in the
mixture or trade name product, then the
owner or operator is not required to
factor that chemical in that mixture or
trade name product into threshold and
release calculations for that chemical.
(iv) If the owner or operator has been
told that a mixture or trade name
product contains a toxic chemical, does
not know the specific chemical identity
of the chemical and knows the specific
concentration at which it is present in
the mixture or trade name product, the
owner or operator shall determine the
weight of the chemical imported.
processed, or otherwise used as part of
the mixture or trade name product at the
facility. Since the owner or operator
does not know the specific identity of
the toxic chemical the owner or
operator shall make the threshold
determination only for the weight of the
toxic chemical in the mixture or trade
name product. If the owner or operator
determines that the toxic chemical was
imported, processed, or otherwise used
as part of the mixture or trade name
product in excess of an applicable
threshold in 5 372.25. the owner or
operator shall report the generic
chemical name of the toxic chemical, or
a trade name if the generic chemical
name is not known, and all releases of
the toxic chemical on EPA Form R in
accordance with the instructions in
Subpart E.
(v) If the owner or operator has been
told that a mixture or trade name
product contains a toxic chemical, does
not know the specific chemical identity
of the chemical, and does not know the
specific concentration at which the
chemical is present in the mixture or
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4528 Federal Register / Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations
trade name product but has been told
the upper bound concentration of the
chemical in the mixture or trade name
product, the owner or operator shall
assume that the toxic chemical is
present in the mixture or trade name
product at the upper bound
concentration, shall determine whether
the chemical has been imported.
processed, or otherwise used at the
facility in excess of an applicable
threshold as provided in paragraph
(b)(3)(iv) of this section, and shall report
as provided in paragraph (b)(3Kiv) of
this section.
(vi) If the owner or operator has been
told that a mixture or trade name
product contains a toxic chemical, does
not know the specific chemical identity
of the chemical, does not know the
specific concentration at which the
chemical is present in the mixture or
trade name product including
information they have themselves
developed, and has not been told the
upper bound concentration of the
chemical in the mixture or trade name
product, the owner or operator is not
required to report with respect to that
toxic chemical.
(c) A covered facility may consist of
more than one establishment. The
owner or operator of such a facility at
which a toxic chemical was
manufactured (including imported),
processed, or otherwise used in excess
of an applicable threshold may submit a
separate Form R for each establishment
or for each group of establishments
within the facility to report the activities
involving the toxic chemical at each
establishment or group of
establishments, provided that activities
involving that toxic chemical at all the
establishments within the covered
facility are reported. If each
establishment or group of
establishments Hies separate reports
then for all other chemicals subject to
reporting at that facility they must also
submit separate reports. However, an
establishment or group of
establishments does not have to submit
a report for a chemical that is not
manufactured (including imported),
processed, otherwise used, or released
at that establishment or group of
establishments.
(d) Each report under this section for
activities involving a toxic chemical that
occured during a calendar year at a
covered facility must be submitted on or
before July 1 of the next year. The first
such report for calendar year 1987
activities must be submitted on of before
July 1.1888.
(e) For reports applicable to activities
for calendar years 1987.1988. and 1989
only, the owner or operator of a covered
facility may report releases of a specific
toxic chemical to an environmental
medium, or transfers of wastes
containing a specific toxic chemical to
an off-site location, of less than 1.000
pounds using the ranges provided in the
form and instructions in Subpart E. For
reports applicable to activities in
calendar year 1990 and beyond, iheue
ranges may not be used.
{37^38 Exemptions.
(a) De minimi's concentrations of a
toxic chemical in a mixture. If a toxic
chemical is present in a mixture of
chemicals at a covered facility and the
toxic chemical is in a concentration in
the mixture which is below 1 percent of
the mixture, or 0.1 percent of the mixture
in the case of a toxic chemical which is
a carcinogen as defined in 29 CFR
1910.1200(d)(4), a person is not required
to consider the quantity of the toxic
chemical present in such mixture when
determining whether an applicable
threshold has been met under { 372.25 or
determining the amount of release to be
reported under { 372.30. This exemption
applies whether the person received the
mixture from another person or the
person produced the mixture, either by
mixing the chemicals involved or by
causing a chemical reaction which
resulted in the creation of the toxic
chemical in the mixture. However, this
exemption applies only to the quantity
of the toxic chemical present in the
mixture. If the toxic chemical is also
manufactured (including imported).
processed, or otherwise used at the
covered facility other than as part of the
mixture or in a mixture at higher
concentrations, in excess of an
applicable threshold quantity set forth in
{ 372.25, the person is required to report
under 1372JO.
(b) Articles. If a toxic chemical is
present in an article at a covered
facility, a person is not required to
consider the quantity of the toxic
chemical present in such article when
determining whether an applicable
threshold has been met under § 372.25 or
determining the amount of release to be
reported under f 372.30. This exemption
applies whether the person received the
article from another person or the
person produced the article. However,
this exemption applies only to the
quantity of the toxic chemical present in
the article. If the toxic 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 set forth in { 372.25,
the person is required to report under
S 372.30. Persons potentially subject to
this exemption should carefully review
the definitions of "article" and "release"
in | 372.3. If a release of a toxic
chemical occurs as a result of the
processing or use of an item at the
facility, that item does not meet the
definition of "article."
(c) Uses. If a toxic chemical is used at
a covered facility for a purpose
descnbed in this paragraph (c), a person
is not required to consider the quantity
of the toxic chemical used for such
purpose when determining whether an
applicable threshold has been met under
S 372.25 or determining the amount of
releases to be reported under i 372.30.
However, this exemption only applies to
the quantity of the toxic chemical used
for the purpose described in this
paragraph (c). If the toxic chemical is
also manufactured (including imported),
processed, or otherwise used at the
covered facility other than as described
in this paragraph (c), in excess of an
applicable threshold quantity set forth in
S 372.25. the person is required to report
under t 372.30.
(1) Use as a structural component of
the facility.
(2) Use of products for routine
janitorial or facility grounds
maintenance. Examples include use of
janitorial cleaning supplies, fertilizers.
and pesticides similar in type or
concentration to consumer products.
(3) Personal use by employees or
other persons at the facility of foods,
drugs, cosmetics, or other personal items
containing toxic chemicals, including
supplies of such products within the
facility such as in a facility operated
cafeteria, store, or infirmary.
(4) Use of products containing toxic
chemicals for the purpose of maintaining
motor vehicles operated by the facility.
(5) Use of toxic chemicals present in
process water and non-contact cooling
water as drawn from the environment or
from municipal sources, or toxic
chemicals present in air used either as
compressed air or as part of combustion.
(d) Activities in laboratories. If a toxic
chemical is manufactured, processed, or
used in a laboratory at a covered facility
under the supervision of a technically
qualified individual as defined in
S 720.3(ee) of this title, a person is not
required to consider the quantity so
manufactured, processed, or used when
determining whether an applicable
threshold has been met under i 372.25 or
determining the amount of release to be
reported under i 372.30. This exemption
does not apply in the following cases:
(1) Specialty chemical production.
(2) Manufacture, processing, or use of
toxic chemicals in pilot plant scale
operations.
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Federal Register /Vol. 53. No. 30 / Tuesday. February 16. 1988 / Rules and Regulations
4529
(3) Activities conducted outside the
laboratory.
(e) Certain owners of leased property.
The owner of • covered facility is not
subject to reporting under | 372JO if
such owner's only interest in the facility
is ownership of the naJ estate upon
which the facility is operated. This
exemption applies to owners of facilities
such as industrial parks, all or part of
which are leased to persons who
operate establishments within SIC code
20 through 39 where the owner has no
other business interest in the operation
of the covered facility.
(f) Reporting by certain operators of
establishments on leased property such
as industrial parks. If two or more
persons, who do not have any common
corporate or business interest (including
common ownership or control), operate
separate establishments within a single
facility, each such person shall treat the
establishments it operates as a facility
for purposes of this Part. The
determinations in { 372.22 and { 372.25
shall be made for those establishments.
If any such operator determines that its
establishment is a covered facility under
} 372.22 and that a toxic chemical has
been manufactured (including imported),
processed, or otherwise used at the
establishment in excess of an applicable
threshold in { 372.25 for a calendar year.
the operator shall submit a report in
accordance with I 372.30 for the
establishment For purposes of this
paragraph (f), a common corporate or
business interest includes ownership,
partnership, joint ventures, ownership of
a controlling interest in one person by
the other, or ownership of a controlling
interest in both persons by a third
person.
Subpart C—Supplier Notification
Requirement
1372.45 Notification about toxto
(a) Except as provided in paragraphs
(c). (d). and (e) of this section and
S 372.65. a person who owns or operates
a facility or establishment which:
(i) Is in Standard Industrial
Classification codes 20 through 39 at set
forth in paragraph (b) of I 37Z32,
(2) Manufactures (including Imports)
or processes a toxic chemical, and
(3) Sells or otherwise distributes •
mixture or trade name product
containing the toxic chemical, to (i) a
facility described in I 372.22. or (ii) to a
person who in turn may sell or
otherwise distributes such mixture or
trade name product to a facility
described in | 372.22(b). must notify
each person to whom the mixture or
trade name product is sold or otherwise
distributed from the facility or
establishment in accordance with
paragraph (b) of this section.
(b) The notification required in
paragraph (a) of this section shall be in
writing and shall include:
(1) A statement that the mixture or
trade name product contains a toxic
chemical or chemicals subject to the
reporting requirements of section 313 of
Title III of the Superfund Amendments
and Reauthorization Act of 1986 and 40
CFR Part 372.
(2) The name of each toxic chemical.
and the associated Chemical Abstracts
Service registry number of each
chemical if applicable, as set forth in
{ 372,85.
(3) The percent by weight of each
toxic chemical in the mixture or trade
name product
(c) Notification under this section
shall be provided as follows:
(l) For a mixture or trade name
product containing a toxic chemical
listed in | 373.65 with an effective date
of January 1,1987. the person shall
provide the written notice described in
paragraph (b) of this section to each
recipient of the mixture or trade name
product with at least the first shipment
of each mixture or trade name product
to each recipient in each calendar year
beginning January 1.1989.
(2) For a mixture or trade name
product containing a toxic chemical
listed in i 372.85 with an effective date
of January 1.1989 or later, the person
shall provide the written notice
described in paragraph (b) of this
section to each recipient of the mixture
or trade name product with at least the
first shipment of the mixture or trade
name product to each recipient in each
calendar year beginning with the
applicable effective date.
(3) If a person changes a mixture or
trade name product for which
notification was previously provided
under paragraph (b) of this section by
adding a toxic chemical removing a
toxic chemical, or changing the percent
by weight of a toxic chemical in the
mixture or trade name product the
person shall provide each recipient of
the changed mixture or trade name
product a revised notification reflecting
the change with the first shipment of the
changed mixture or trade name product
to the recipient.
(4) If a person discovers (i) that a
mixture or trade name product
previosuly sold or otherwise distributed
to another person during the calender
year of the discovery contains one or
more toxic chemicals and (ii), that any
notification providied to such other
persons in that calendar year for the
mixture or trade name product either did
not properly identify any of the toxic
chemicals or did not accurately present
the percent by weight of any of the toxic
chemicals in the mixture or trade name
product the person shall provide a new
notification to the recipient within 30
days of the discovery which contains
the information described in paragraph
(b) of this section and identifies the prior
shipments of the mixture or product in
that calendar year to which the new
notification applies.
(5) If a Material Safety Data Sheet
(MSDS) is required to be prepared and
distributed for the mixture or trade
name product in accordance with 29
CFR 1910.1200. the notification must be
attached to or otherwise incorporated
into such MSDS. When the notification
is attached to the MSDS, the notice must
contain clear instructions that the
notifications must not be detached from
the MSDS and that any copying and
redistribution of the MSDS shall include
copying and redistribution of the notice
attached to copies of the MSDS
subsequently redistributed.
(d) Notifications are not required in
the following instances:
(1) If a mixture or trade name product
contains no toxic chemical in excess of
the applicable de minimis concentration
as specified in I 372.38(a).
(2) If a mixture or trade name product
la one of the following:
(i) An "article" as defined In i 372.3
(ii) Foods, drugs, cosmetic*, alcoholic
beverages, tobacco, or tobacco products
packaged for distribution to the general
public.
(iii) Any consumer product as the term
is defined in the Consumer Product
Safety Act (15 U.S.C 1251 et teq.}
packaged for distribution to the general
public.
(e) If the person considers the specific
identity of a toxic chemical in a mixture
or trade name product to be a trade
secret under provisions of 29 CFR
1910.1200, the notice shall contain a
genenc chemical name that is
descriptive of that toxic chemical.
(f) If the person considers the specific
percent by weight composition of a toxic
chemical in the mixture or trade name
product to be a trade secret under
applicable State law or under the
Restatement of Torts section 757,
comment b, the notice must contain a
statement that the chemical is present at
a concentration that does not exceed a
specified upper bound concentration
value. For example, a mixture contains
12 percent of a toxic chemical. However.
the supplier considers the specific
concentration of the toxic chemical in
-------
4530 Federal Register / Vol. 53. No. 30 / Tuesday, February 16. 1986 / Rules and Regulations
the product to be • trade secret. The
notice would indicate that the toxic
enemies! is present in die mixture in a
concentration of no more than 15
percent by weight The upper bound
vaiue cnosen must be no larger than
necessary to adequately protect the
trade secret.
{g) A person n not subject to the
requirements of this section to the
extent the person does not know that
tne facility or establishments) is selling
or otherwise distributing a toxic
cnermcal to another person in a mixture
or trade name product. However, for
purposes of this section, a person has
sucn knowledge if the person receives a
notice under this section from a supplier
of a mixture or trade name product and
tne person in turn Mlia or otherwise
distnbutes that mixture or trade name
proouct to another person.
(h) If two or more persons, who do not
nave any common corporate or ousinesa
interest | including common ownership
or control), as described in J 372.38(fl,
operate separate establishments within
a single facility, each such persons shall
treat the estabhshment(s) it operates as
a facility for purposes of this section.
The determination under paragraph (a)
of this section shall be made for those
establishments.
(Note: Suboarts D and E of the
regulatory text are not reproduced
nere because tney appear in
substance elsewnere in this
document.]
-------
Revised December 1988
EPA 560/4-88-003
TITLE III LIST OF LISTS
Consolidated List of
Chemicals Subject to
Reporting Under Title III of
the Superfund Amendments and
Reauthorization Act (SARA)
of 1986
Office of Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C. 20460
-------
SARA TITLE III
CONSOLIDATED CHEMICAL LIST
This consolidated chemical list includes chemicals subject to reporting
requirements under Title III of the Superfund Amendments and Reauthorization
Act of 1986 (SARA)1. It has been prepared to help firms handling chemicals
determine whether they need to submit reports under Sections 304 or 313 of
Title III and, for a specific chemical, what reports need to be submitted.
The list includes chemicals referenced under four federal statutory
provisions, as follows:
(1) SARA Section 302 Extremely Hazardous Substances, the presence of any
of which, in sufficient quantities, requires certain emergency planning
activities to be conducted. Releases of reportable quantities (RQ) of these
substances are also subject to reporting under Section 304 of Title III. The
final rule listing the extremely hazardous substances and their threshold
planning quantities (TPQ) was published on April 22, 1987 (52 FR 13378).
(2) CERCLA Hazardous Substances ("RQ chemicals"), releases of which are
subject to reporting under the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA, or "Superfund"). Such
releases are also subject to reporting under Section 304 of Title III.
CERCLA hazardous substances, and their reportable quantities, are listed in 40
CFR Part 302, Table 302.4.
(3) SARA Section 313 Toxic Chemicals, emissions or releases of which
must be reported annually as part of SARA Title Ill's community right-to-know
provisions. The rule containing these chemicals was published on February 16,
1988 (53 FR 4500) (40 CFR 372).
(4) RCRA Hazardous Wastes from the P and U lists only (40 CFR 261.33),
which consist of lists of specific chemicals. RCRA hazardous wastes
consisting of waste streams on the F and K lists are not included here; such
waste streams are also CERCLA hazardous substances. This listing is provided
as an indicator to companies that they may already have data on a specific
chemical that can be used for Title III reporting purposes.
There are four columns in the consolidated list corresponding to these
four statutory provisions. If a chemical is listed as an extremely hazardous
substance under Section 302, its TPQ is given in the Section 302 column.
Similarly, the CERCLA RQ is given for those chemicals that are CERCLA
hazardous substances which must be reported under Section 304 of Title III,
and Section 302 listed chemicals. A key to the symbols used in the Section
302 and CERCLA columns is at the end of the list. An "X" in the column for
1 Not specified in this consolidated list are all chemicals subject to
the reporting requirements in Sections 311 and 312 of SARA Title III. These
hazardous chemicals, for which material safety data sheets (HSDS) must be
developed under Occupational Safety and Health Act Hazard Communication
Standards, are identified as such by broad criteria, rather than by
enumeration. There are over 50,000 such substances that satisfy the criteria.
-------
- 2 -
Section 313 indicates that, the chemical is subject to reporting under Section
313. The letter-and-digit code in the RCRA column is the chemical's RCRA
hazardous waste code. A blank in any of these columns indicates that the
chemical is not subject to the corresponding statutory authorities. A fifth
column, headed "State," is left entirely blank, to be checked if state
reporting requirements apply to a chemical. The heading "Section 304" over
the Section 302 and CERCLA RQ lists indicates that the reporting requirements
in Section 304 of SARA Title III apply to Section 302 extremely hazardous
substances and CERCLA hazardous substances. [1] indicates that a CERCLA
reportable quantity has not been established under Section 102(a) of CERCLA;
notice must be given of releases of one pound or more under SARA Section 304.
As indicated, most chemicals on the consolidated list are subject to reporting
requirements under more than one statutory provision.
The chemicals on this list are ordered by Chemical Abstracts Service
(CAS) registry number. Categories of chemicals, which do not have CAS
registry numbers, but which are cited under CERCLA and Section 313, are placed
at the end of the list. For reference purposes, the chemicals (with their CAS
numbers) are ordered alphabetically at the end of this document. The listed
chemicals are grouped by fours to facilitate reading.
For additional copies of this document address requests to:
Section 313 Document Distribution Center
P.O. Box 12505
Cincinnati, OH 45212
Questions concerning changes to the list or other aspects of Title III
may be submitted in writing to:
Emergency Planning and Community Right-to-Know Information Hotline
U.S. Environmental Protection Agency (OS-120)
401 M Street, SW
Washington, DC 20460
Alternatively, you may call (800) 535-0202 between the hours of 8:30 AM and
7:30 PM Eastern Time (in Washington, D.C. and Alaska call (202) 479-2449).
-------
SARA TITLE III
CONSOLIDATED CHEMICAL LIST
02/02/89
Page 1
CAS Number Chemical Name
Section 304
Section 302 Section
TPQ RQ 313
RCRA
STATE
50-00-0 Formaldehyde
50-07-7 Mitomycin C
50-14-6 Ergocalciferol
50-18-0 Cyclophosphamide |
50-29-3 DDT
50-32-8 Benzo [a] pyrene
50-55-5 Reserpine
51-21-8 Fluorouracil
51-28-5 2,4-Dinitrophenol
51-43-4 l,2-Benzenediol,4-[l-hydroxy-2-(methylamino)ethyl]-
51-75-2 Mechlorethamine
51-79-6 Carbamic acid, ethyl ester
51-83-2 Carbachol chloride
52-68-6 Trichlorophon
52-85-7 Famphur
53-70-3 Dibenz [a, h] anthracene
53-96-3 Acetamide, N-9H-f luoren-2-yl-
54-11-5 Nicotine
54-62-6 Aminopterin
55-18-5 Ethanamine, N-ethyl-N-nitroso-
55-21-0 Benzamide
55-63-0 Nitroglycerine
55-91-4 Isofluorphate
56-04-2 Methylthiouracil
56-23-5 Carbon tetrachloride
56-25-7 Cantharidin
56-38-2 Parathion
56-49-5 Benz[j]aceanthrylene,l,2-dihydro-3-methyl-
56-53-1 Diethylstilbestrol
56-55-3 Benz [a] anthracene
56-72-4 Coumaphos
57-12-5 Cyanides (soluble cyanide salts)
57-14-7 Dimethylhydrazine
57-24-9 Strychnine
57-47-6 Physostigraine
57-57-8 Propiolactone, beta-
57-64-7 Physostigmine, salicylate (1:1)
57-74-9 Chlordane
57-97-6 1,2-Benzanthracene, 7,12-dimethyl-
58-36-6 Phenoxarsine, 10,10'-oxyd1-
500 |
500/10,000 |
1,000/10,000* |
1
1
1
500/10.000*
1
1
10* |
1
500/10,000*
1
100
500/10,000*
100
100/10,000*
100
100/10,000
1,000
100/10,000
100/10,000*
500*
100/10,000*
1,000
500/10,000*
10001 |
1* 1
1
It 1
1* 1
If 1
5000 |
10
1000
1
If 1
1
100
1000
If
If
100
If
10
100
If
5000*
If
If
If
If
10
10
If
10
If
If
x 1
1
1
1
1
1
1
1
x 1
1
x 1
x 1
x
X
X
X
X
X
X
X
X
X
U122
U010
U058
U061
U022
U200
P048
P042
U238
P097
U063
U005
P075
U174
P081
P043
U164
U211
P089
U157
U089.
U018
P030
U098
P108
U036
U094
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 2
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
================:======
Section
313 RCRA
STATE
58-89-9 Lindane
58-90-2 Phenol, 2,3,4,6-tetrachloro-
59-50-7 4-Chloro-m-cresol
59-88-1 Phenylhydrazine hydrochloride
59-89-2 N-Nitrosomorpholine
60-00-4 Ethylenediamine tetraacetic acid (EDTA)
60-09-3 4-Aminoazobenzene
60-11-7 Benzenamine, N,N-dimethyl-4-phenylazo-
60-29-7 Ethane, l,l'-oxybis-
60-34-4 Methylhydrazine
60-35-5 Acetamide
60-41-3 Strychnine, sulfate
60-51-5 Oimethoate
60-57-1 Dieldrin
61-82-5 Amitrole
62-38-4 Phenylmercury acetate
62-44-2 Acetamide, N-(4-ethoxyphenyl)-
62-50-0 Ethyl methanesulfonate
62-53-3 Aniline
62-55-5 Ethanethioamide
62-56-6 Carbamide, thio-
62-73-7 Dichlorvos
62-74-8 Sodium f luoroacetate
62-75-9 Nitrosodimethylamine
63-25-2 Carbaryl
64-00-6 Phenol, 3-(l-methylethyl)-, methylcarbamate
64-18-6 Formic acid
64-19-7 Acetic acid
64-67-5 Diethyl sulfate
64-86-8 Col chic ine
65-30-5 Nicotine sulfate
65-85-0 Benzoic acid
66-75-1 Uracil, 5-[bis(2-chloroethy1)amino]-
66--81-9 Cycloheximide
67-56-1 Methanol
67-63-0 Isopropyl alcohol (mfg. -strong acid processes)
67-64-1 Acetone
67-66-3 Chloroform
67-72-1 Ethane, 1,1, 1,2,2, 2-hexachloro-
68-76-8 Triaziquone
1,000/10,000
1,000/10,000*
500
100/10.000*
500/10,000
500/10,000
1,000
1,000
10/10,000
1,000
500/10,000*
10/10,000*
100/10,000*
100/10,000*
10,000
It
10
5000
5000
If
100
10
10
If
If
100
If
If
5000
If
If
10
10
If
100
5000
5000
5000
If
5000
5000
SOOOf
If
X
x
x
x
x
x
X
X
X
X
X
X
x
X
X
X
X
x
X
U129
U039
U093
U117
P068
P044
P037
U011
P092
U187
U119
U012
U218
U219
P058
P082
U123
U237
U154
U002
U044
U131
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 3
CAS Number Chemical Name
Section 304
Section 302
TPQ
RQ
Section
313 RCRA
STATE
70-25-7 Guanidlne, N-nitroso-N-methyl-N'-nltro-
70-30-4 Hexachlorophene
70-69-9 Propiophenone, 4'-am1no-
71-36-3 1-Butanol
71-43-2 Benzene
71-55-6 Methyl chloroform
71-63-6 Dlgitoxin
72-20-8 Endrin
72-43-5 Ethane, l,l.l-trichloro-2,2-bis(p-methoxyphenyl)-
72-54-8 ODD
72-55-9 ODE
72-57-1 Trypan blue
74-83-9 Methyl bromide
74-85-1 Ethylene
74-87-3 Methane, chloro
74-88-4 Methane, iodo-
74-89-5 Monomethylamine
74-90-8 Hydrocyanic acid
74-93-1 Methyl mercaptan
74-95-3 Methane, dibromo-
75-00-3 Chloroethane
75-01-4 Vinyl chloride (monomer)
75-04-7 Monoethylamine
75-05-8 Acetonitrile
75-07-0 Acetaldehyde
75-09-2 Methane, dichloro-
75-15-0 Carbon dlsulflde
75-18-3 Dimethyl sulfide
75-20-7 Calcium carbide
75-21-8 Ethylene oxide
75-25-2 Bromoform
75-27-4 Dichlorobromomethane
75-34-3 1,1-Dlchloroethane
75-35-4 I.l-D1chloroethy1ene
75-36-5 Acetyl chloride
75-44-5 Phosgene
75-50-3 Trimethylamine
75-55-8 Propylenelmine
75-56-9 Propylene oxide
75-60-5 Cacodylic add
100/10,000*
100/10,000*
500/10,000
1,000
100
500
10,000
100*
1,000
10
10,000
10,000
1#
100
5000
1000*
1000
1
1
1*
1#
lift
1000
1*
1*
100
10
100
1000
100
If
100
5000
1000
1000
100
10
1*
100
5000
1000
5000*
5000
10
100
It
100
It
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U163
U132
U031
U019
U226
P051
U247
U060
U236
U029
U045
U138
P063
U153
U068
U043
U003
U001
U080
P022
U115
U225
U076
U078
U006
P095
P067
U136
Releases 1n excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(I.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 4
CAS Number Chemical Name
Section 304
Section 302
TPQ
RQ
Section
313 RCRA STATE
75-64-9 tert-Butylamine
75-65-0 tert-Butyl alcohol
75-69-4 Methane, trichlorof luoro-
75-71-8 Oichlorodif luoromethane
75-74-1 Tetramethyllead
75-77-4 Trimethylchlorosilane
75-78-5 Oimethyldichlorosilane
75-79-6 Methyltrichlorosilane
75-86-5 Acetone cyanohydrin
75-87-6 Acetaldehyde, trichloro-
75-99-0 2,2-Dichloropropionic acid
76-01-7 Pentachloroethane
76-02-8 Trichloroacetyl chloride
76-13-1 Chlorinated fluorocarbon (Freon 113)
76-44-8 Heptachlor
77-47-4 Hexachlorocyclopentadiene
77-78-1 Dimethyl sulfate
77-81-6 Tabun
78-00-2 Tetraethyllead
78-34-2 Dioxathion
78-53-5 Amiton
78-59-1 Isophorone
78-71-7 Oxetane, 3,3-bis(chloromethyl)-
78-79-5 Isoprene
78-81-9 iso-Butylamine
78-82-0 Isobutyronitrile
78-83-1 Isobutyl alcohol
78-84-2 Isobutyraldehyde
78-87-5 1,2-Dichloropropane
78-88-6 2,3-Oichloropropene
78-92-2 sec-Butyl alcohol
78-93-3 2-Butanone
78-94-4 Methyl vinyl ketone
78-97-7 Lactonitrile
78-99-9 1,1-Dichloropropane
79-00-5 Ethane, 1,1,2-trichloro-
79-01-6 Trichloroethylene
79-06-1 Acrylamide
79-09-4 Propionic acid
79-10-7 Acrylic acid
100*
1,000*
500*
500*
1,000
500*
100
500
10*
100
500*
500*
500*
1,000*
10*
1,000*
1,000/10,000
1000
5000
5000
10
1*
5000
\i
11
It
It
10
5000
100
1000
5000
1000
100
5000
1000
1*
1000*
5000
5000
5000
X
X
X
X
X
X
X
X
X
X
X
X
X
U121
U075
P069
U034
U184
P059
U130
U103
P110
U140
U083
Ul 59
U227
U228
U007
U008
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 5
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
79-11-8 Chloroacetic acid | 100/10,000*
79-19-6 Thiosemicarbazide | 100/10,000
79-21-0 Peracetic acid | 500*
79-22-1 Methyl chloroformate (Methylchlorocarbonate) | 500
79-31-2 iso-Butyric acid |
79-34-5 Ethane, 1,1,2,2-tetrachloro-
79-44-7 Carbamyl chloride, dimethyl- |
79-46-9 2-Nitropropane |
80-05-7 4,4'-Isopropylidenediphenol |
80-15-9 alpha, alpha-Dimethylbenzylhydroperoxide |
80-62-6 Methyl methacrylate |
80-63-7 Methyl 2-chloroacrylate | 500*
81-07-2 l,2-Benzisothiazolin-3-one,l,l-dioxide, and salts
81-81-2 Warfarin j 500/10,000
81-88-9 C.I. Food Red 15 j
82-28-0 l-Amino-2-methylanthraquinone |
82-66-6 Diphacinone | 10/10,000*
82-68-8 Benzene, pentachloronitro- |
83-32-9 Acenaphthene
84-66-2 1,2-Benzenedicarboxylic acid, diethyl ester |
84-74-2 Oibutyl phthalate |
85-00-7 Diquat |
85-01-8 Phenanthrene |
85-44-9 1,2-Benzenedicarboxylic acid anhydride |
85-68-7 Butyl benzyl phthalate |
86-30-6 N-Nitrosodiphenylamine |
86-50-0 Azinphos-methyl 1 10/10,000
86-73-7 Fluorene
86-88-4 Antu 500/10,000
87-62-7 2,6-Xylidine
87-65-0 2,6-Dichlorophenol
87-68-3 Hexachloro-l,3-butadiene
87-86-5 Pentachlorophenol
88-05-1 Aniline, 2,4,6-trimethyl- 500*
88-06-2 Phenol, 2,4,6-trichloro
88-72-2 o-Nitrotoluene
88-75-5 o-Nitrophenol
88-85-7 Dinoseb 100/10,000
88-89-1 Picric acid
90-04-0 o-Anisidine
100
1000
5000
1#
1#
1#
10
1000
1#
100
1#
100
1000
10
1000
5000
5000
100
100
1#
5000
100
100
1#
10#
10#
1000
100
1000
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
P116
U156
U209
U097
U171
U098
U162
U202
P001-
U185
U088
U069
U190
P072
U082
U128
P020
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 6
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
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
91-58-7 beta-Chloronaphthalene
91-59-8 2-Naphthylamine
91-80-5 Methapyrilene
91-94-1 (l,l'-Biphenyl)-4,4'-diamine,3,3'-dichloro-
92-52-4 Biphenyl
92-67-1 4-Aminobiphenyl
92-87-5 Benzidine
92-93-3 4-Nitrobiphenyl
93-72-1 Propionic acid, 2-(2,4,5-trichlorophenoxy)-
93-76-5 2,4,5-T
93-79-8 2,4,5-T esters
94-11-1 2,4-0 Esters
94-36-0 Benzoyl peroxide
94-58-6 Benzene, l,2-methylenedioxy-4-propyl-
94-59-7 Benzene, l,2-methylenedioxy-4-a11yl-
94-75-7 2,4-D Acid
94-79-1 2,4-D Esters
94-80-4 2,4-0 Esters
95-47-6 Benzene, o-dimethyl-
95-48-7 o-Cresol
95-50-1 Benzene, 1,2-dichloro-
95-53-4 o-Toluidine
95-57-8 2-Chlorophenol
95-63-6 Pseudocumene
95-80-7 Diaminotoluene
95-94-3 Benzene, 1,2,4,5-tetrachloro-
95-95-4 Phenol, 2,4,5-trichloro-
96-09-3 Styrene oxide
96-12-8 l,2-Dibronio-3-chloropropane
96-33-3 Methyl acrylate
96-45-7 Ethylenethiourea
97-18-7 Phenol, 2,2'-thiobis(4,6-dichloro-
97-56-3 C.I. Solvent Yellow 3
97-63-2 Ethyl methacrylate
98-01-1 2-Furancarboxaldehyde
100
1,000/10,000
100/10,000*
1 x
1 x
100 | X
100 I X
5000 | X
5000 j
1* | X
5000 |
1# | X
1 x
1 x
1# | X
1 x
100 |
1000 I
1000 |
100 |
1 x
1* 1
1# | X
100 | X
100 j
100 |
It \ X
1000 | X
100 j X
11 | X
100 |
1 x
1* | X
5000 1
io# 1 x
I x
11 | X
1 x
1# | X
1
1 x
1000 |
5000 1
U165
U047
U168
U155
U073
U021
U090
U203
U240
U052
U070
U328
U048
U207
U066
U116
U118
U125
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 7
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
98-05-5 Benzenearsonic acid
98-07-7 Benzotri chloride
98-09-9 Benzenesulfonyi chloride
98-13-5 Trichlorophenylsilane
98-16-8 Benzenamine, 3-(trif luoromethyl)-
98-82-8 Benzene, 1-methylethyl-
98-86-2 Acetophenone
98-87-3 Benzal chloride
98-88-4 Benzoyl chloride
98-95-3 Nitrobenzene
99-08-1 m-Nitrotoluene
99-35-4 Benzene, 1,3,5-trinitro-
99-55-8 Benzenamine, 2-methyl-5-nitro-
99-59-2 5-Nitro-o-anisidine
99-65-0 m-Oinitrobenzene
99-98-9 D imethy 1 -p-pheny lened iam i ne
99-99-0 p-Nitrotoluene
100-01-6 Benzenamine, 4-nitro-
100-02-7 p-Nitrophenol
100-14-1 Benzene, l-(chloromethyl)-4-nitro-
100-21-0 Terephthalic acid
100-25-4 p-Dinitrobenzene
100-41-4 Ethylbenzene
100-42-5 Styrene
100-44-7 Benzyl chloride
100-47-0 Benzonitrile
100-75-4 N-Nitrosopiperidine
101-14-4 Benzenamine, 4,4'-methy1enebis(2-chloro-
101-55-3 Benzene, l-bromo-4-phenoxy-
101-61-1 4,4'-Methylene bis(N.N-dimethyl) benzenamine
101-68-8 Methylene bis(phenylisocyanate) (MBI)
101-77-9 4,4'-Methylene dianiline
101-80-4 4,4'-Diaminodiphenyl ether
102-36-3 Isocyanic acid, 3,4-dichlorophenyl ester
103-23-1 Bis(2-ethylhexyl) adipate
103-85-5 Phenylthiourea
104-94-9 p-Anisidine
105-46-4 sec-Butyl acetate
105-67-9 2,4-Dimethylphenol
106-42-3 Benzene, p-dimethyl-
10/10,000*
100
500*
500*
500
10,000
10/10,000*
500/10,000*
500
500/10.000*
100/10,000
u
100
5000
5000
5000
1000
1000
1000
10
11
100
1000
5000
100
100
1000
1000
100*
5000
It
I*
100
100
5000
100
1»
x
x
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U023
U020
U055
U004
U017
1)169
U234
U181
P077
U170
P028
U179
U158
U030
P093
U101
1
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 8
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
106-44-5 p-Cresol
106-46-7 Benzene, 1,4-dichloro-
106-47-8 Benzenamine, 4-chloro-
106-49-0 4-Amino-l-methyl benzene
106-50-3 p-Phenylenediamine
106-51-4 p-Benzoquinone
106-88-7 1,2-Butylene oxide
106-89-8 Epichlorohydrin
106-93-4 Ethane, 1,2-dibromo-
106-96-7 Propargyl bromide
106-99-0 Butadiene
107-02-8 Acrolein
107-05-1 Allyl chloride
107-06-2 1,2-Dichloroethane
107-07-3 Chloroethanol
107-10-8 1-Propanamine
107-11-9 Allylamine
107-12-0 Propionitrile
107-13-1 Acrylonitrile
107-15-3 Ethylenediamine
107-16-4 Formaldehyde cyanohydrin
107-18-6 Ally! alcohol
107-19-7 Propargyl alcohol
107-20-0 Cbloroacetaldehyde
107-21-1 Ethylene glycol
107-30-2 Chloromethyl methyl ether
107-44-8 Sarin
107-49-3 Tepp
107-92-6 Butyric acid
108-05-4 Vinyl acetate monomer
108-10-1 Methyl isobutyl ketone
108-23-6 Isopropyl chloroformate
108-24-7 Acetic anhydride
108-31-6 2,5-Furandione
108-38-3 Benzene, m-dimethyl-
108-39-4 m-Cresol
108-46-3 1,3-Benzenediol
108-60-1 Bis(2-chloroisopropyl) ether
108-78-1 Melamine
108-88-3 Benzene, methyl-
1,000
10*
500
500*
500*
500
10,000
10,000
1,000*
1,000
100
10*
100
1,000
1,000*
1000*
100
1000
1*
10
1000*
10001
1
1000
5000*
5000
10
1001
5000
100
1000
1000
11
10
5000
5000
5000
5000
5000
11
1000
5000
1000
1000
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U052
U072
P024
U353
U197
U041
U067
P003
U077
U194
P101
U009
POOS
P102
P023
U046
Pill
U161
U147
U052
U201
U027
U220
1
1
1
1
1
1
1
1
1
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 9
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
=:===:===:=;: s=
Section
313 RCRA
STATE
108-90-7 Benzene, chloro-
108-91-8 Cyclohexylamine
108-94-1 Cyc lohexanone
108-95-2 Phenol
108-98-5 Thiophenol
109-06-8 2-Picoline
109-61-5 Propyl chloroformate
109-73-9 Butylamine
109-77-3 Malononitrile
109-86-4 2-Methoxyethanol
109-89-7 Diethylamine
109-99-9 Furan, tetrahydro-
110-00-9 Furan
110-16-7 Maleic acid
110-17-8 Fumaric acid
110-19-0 iso-Butyl acetate
110-57-6 Trans-1 ,4-dichlorobutene
110-75-8 2-Chloroethyl vinyl ether
110-80-5 2-Ethoxyethanol
110-82-7 Benzene, hexahydro-
110-86-1 Pyridine
110-89-4 Piperidine
111-42-2 Diethanolamine
111-44-4 Dichloroethyl ether
111-54-6 1,2-Ethanediylbiscarbamodithioic acid
111-69-3 Adiponitrile
111-91-1 Bis(2-chloroethoxy) methane
114-26-1 Propoxur
115-02-6 Azaserine
115-07-1 Propylene (Propene)
115-21-9 Trichloroethylsilane
115-26-4 Dimefox
115-29-7 Endosulfan
115-32-2 Dicofol"
115-90-2 Fensulfothion
116-06-3 Aldicarb
117-79-3 2-Aminoanthraquinone
117-80-6 Dichlone
117-81-7 1,2-Benzenedicarboxylic acid, [bis(2-ethylhexyl)]ester
117-84-0 Dioctyl phthalate
10.000*
500/10,000
500
500*
500/10,000
500
500*
1,000*
10,000
1,000*
500*
500*
10/10,000
500*
100/10,000
100
5000
1000
100
5000
1000
1000
100
1000
100
5000
5000
5000
1000
1#
1000
1000
1#
5000
1000
1#
1
10
1
1
1#
5000
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U037
U057
U188
P014
U191
U149
U213
U124
U042
U359
U056
U196
U025
U114
U024
U015
P050
P070
U028
U107
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 10
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
118-74-1 Benzene, hexachloro
119-38-0 Isopropylmethylpyrazolyl dimethylcarbamate
119-90-4 (l,l'-Biphenyl)-4,4'-diamine,3,3'-dimethoxy-
119-93-7 (l,l'-Biphenyl)-4,4'-diamine,3,3'-dimethyl-
120-12-7 Anthracene
120-58-1 Benzene, l,2-methylenedioxy-4-propenyl-
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 Benzene, l-methyl-2,4-dinitro-
121-21-1 Pyrethrins
121-29-9 Pyrethrins
121-44-8 Triethylamine
121-69-7 N,N-Dimethy Ian i line
121-75-5 Malathion
122-09-8 alpha.alpha-Dimethylphenethylamine
122-14-5 Fenitrothion
122-66-7 1,2-Diphenylhydrazine
123-31-9 Hydroquinone
123-33-1 l,2-Dihydro-3,6-pyridazinedione
123-38-6 Propionaldehyde
123-62-6 Propionic anhydride
123-63-7 Paraldehyde
123-72-8 Butyraldehyde
123-73-9 Crotonaldehyde, (E)-
123-86-4 Butyl acetate
123-91-1 1,4-Diethylene dioxide
123-92-2 iso-Amyl acetate
124-04-9 Adipic acid
124-40-3 Dimethylamine
124-41-4 Sodium methylate
124-48-1 Chlorodibromomethane
124-65-2 Sodium cacodylate
124-87-8 Picrotoxin
126-72-7 1-Propanol, 2,3-dibromo-, phosphate (3:1)
126-98-7 Methacrylonitrile
126-99-8 Chloroprene
127-18-4 Ethene, 1. 1,2,2-tetrachloro-
127-82-2 Zinc phenol sulfonate
500*
500*
500/10,000*
1,000
100/10,000*
500/10,000*
500
11
1#
1#
5000
1#
100
100
10001
1
1
5000
100
5000
1#
5000
5000
1000
100
5000
111!
5000
5000
1000
1000
100
If
1000
1#
5000
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U127
U091
U095
U141
U081
U105
P046
U109
U148
U182
U053
U108
U092
U235
U152
U210
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 11
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
128-66-5 C.I. Vat Yellow 4
129-00-0 Pyrene
129-06-6 Warfarin sodium
130-15-4 1,4-Naphthalenedione
131-11-3 Dimethyl phthalate
131-52-2 Sodium pentachlorophenate
131-74-8 Ammonium picrate
131-89-5 4,6-Dinitro-o-cyclohexylphenol
132-64-9 Dibenzofuran
133-06-2 Captan
133-90-4 Chloramben
134-29-2 o-Anisidine hydrochloride
134-32-7 1-Naphthylamine
135-20-6 Cupferron
137-26-8 Bis(dimethylthiocarbamoyl)disulfide
139-13-9 Nitrilotriacetic acid
139-65-1 4,4'-Thiodianiline
140-29-4 Benzyl cyanide
140-76-1 Pyridine, 2-methyl-5-vinyl-
140-88-5 Ethyl acrylate
141-32-2 Butyl acrylate
141-66-2 Dicrotophos
141-78-6 Acetic acid, ethyl ester
142-28-9 1,3-Dichloropropane
142-71-2 Cupric acetate
142-84-7 Dipropylamine
143-33-9 Sodium cyanide (Na(CN))
143-50-0 Kepone
144-49-0 Fluoroacetic acid
145-73-3 Endothall
148-82-3 Alanine. 3-[p-bis(2-chloroethyl)amino]phenyl-,L-
149-74-6 Dichlorontethylphenylsilane
151-38-2 Metnoxyethylmercuric acetate
151-50-8 Potassium cyanide
151-56-4 Ethylene inline
152-16-9 Diphosphoramide, octamethyl-
156-10-5 p-Nitrosodiphenylamine
156-60-5 1,2-trans-Dichloroethylene
156-62-7 Calcium cyanamide
189-55-9 l,2:7,8-Dibenzopyrene
1,000/10.000
100/10,000*
100/10,000*
500*
500*
100*
100
10/10,000*
1,000*
500/10,000*
100
500
100
1
1
1
1
5000
5000
5000
10
100
10
1*
10
1000
5000
1000
100
5000
10
1*
1000
If
10
11
100
1000
11
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U166
U102
P009
P034
U167
U244
U113
U112
U110
P106
U142
P088
U150
P098
P054
P085
U079
U064
1
1
1
1
1
1
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 12
CAS Number Chemical Name
Section 304
Section 302
TPQ
RQ
Section
313 RCRA STATE
191-24-2 Benzo[ghi]perylene
193-39-5 Indeno(l,2.3-cd)pyrene
205-99-2 Benzol [b]f luoranthene
206-44-0 Benzo[j,k]fluorene
207-08-9 Benzo[k]f luoranthene
208-96-6 Acenaphthylene
218-01-9 1,2-Benzphenanthrene
225-51-4 Benz[c]acridine
297-78-9 Isobenzan
297-97-2 Thionazin
298-00-0 Parathion-methyl
298-02-2 Phorate
298-04-4 Disulfoton
300-62-9 Amphetamine
300-76-5 Naled
301-04-2 Acetic acid, lead salt
302-01-2 Hydrazine
303-34-4 Lasiocarpine
305-03-3 Butanoic acid, 4-[bis(2-chloroethyl)amino] benzene-
309-00-2 Aldrin
311-45-5 Diethyl-p-nitrophenyl phosphate
315-18-4 Mexacarbate
316-42-7 Emetine, dihydrochloride
319-84-6 alpha-BHC
319-85-7 beta-BHC
319-86-8 delta-BHC
327-98-0 Trichloronate
329-71-5 2,5-Dinitrophenol
330-54-1 Diuron
333-41-5 Diazinon
334-88-3 Diazomethane
353-42-4 Boron trifluoride compound with methyl ether (1:1)
353-50-4 Carbon oxyfluoride
357-57-3 Brucine
359-06-8 Fluoroacetyl chloride
371-62-0 Ethylene f luorohydrin
379-79-3 Ergotamine tartrate
460-19-5 Cyanogen
463-58-1 Carbonyl sulfide
465-73-6 Isodrin
100/10,000*
500
100/10,000
10
500
1,000*
1,000
500/10,000
500/10,000
1/10,000*
500*
1,000*
10*
10*
500/10,000*
100/10,000
5000
11
If
100
It
5000
It
1*
100
100
10
1
10
5000*
1*
If
11
If
100
1000
If
If
1
10
100
1
1000
100
100
1
X
X
X
X
U137
U120
U050
U016
P040
P071
P094
P039
U144
U133
U143
U035
P004
P041
U033
P018
P031
P060
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 13
CAS Number Chemical Name
Section 304
Section 302 Section
TPQ RQ 313 RCRA STATE
470-90-6 Chlorfenv infos
492-80-8 C.I. Solvent Yellow 34 (Auramine)
494-03-1 Chlornaphazine
496-72-0 Oiaminotoluene
502-39-6 Methylmercuric dicyanamide
504-24-5 Pyridine, 4-amino-
504-60-9 1-Methylbutadiene
505-60-2 Mustard gas
506-61-6 Potassium silver cyanide
506-64-9 Silver cyanide
506-68-3 Cyanogen bromide
506-77-4 Chlorine cyanide
506-78-5 Cyanogen iodide
506-87-6 Ammonium carbonate
506-96-7 Acetyl bromide
509-14-8 Tetranitromethane
510-15-6 Ethyl 4,4'-dichlorobenzilate
513-49-5 sec-Butylamine
514-73-8 Dithiazanine iodide
528-29-0 o-Dinitrobenzene
532-27-4 2-Chloroacetophenone
534-07-6 Bis(chloromethyl) ketone
534-52-1 Dinitrocresol
535-89-7 Crimidine
538-07-8 Ethylbis(2-chloroethyl)amine
540-59-0 1,2-Oichloroethylene
540-73-8 1,2-Dimethylhydrazine
540-88-5 tert-Butyl acetate
541-09-3 Uranyl acetate
541-25-3 Lewisite
541-41-3 Ethyl chloroformate
541-53-7 Dithiobiuret
541-73-1 Benzene, 1,3-dichloro-
542-62-1 Barium cyanide
542-75-6 1,3-Dichloropropene
542-76-7 Propionitrile, 3-chloro-
542-88-1 Chloromethyl ether
542-90-5 Ethyl thiocyanate
543-90-8 Cadmium acetate
544-18-3 Cobaltous formate
500*
500/10,000*
500/10,000
500*
500
500/10,000
1,000/10,000*
500
500/10,000*
10/10,000*
10/10,000
100/10,000*
500*
10*
100/10,000
1,000
100
10,000*
1#
1*
It 1
1000
100
1
1
1000
10
5000
5000
10
It
1000
100
10
11
5000
100
100
100
10
100
1000
li
100#
1000
X
X
X
X
X
X
X
X
X
X
U014
U026
POOS
U186
P099
P104
U246
P033
P112
U038
P047
U099
P049
U071
P013
U084
P027
P016
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 14
CAS Number Chemical Name
Section 304
Section 302
TPQ
RQ
Section
313 RCRA
STATE
544-92-3 Copper cyanide | | 10 | | P029
554-84-7 m-Nitrophenol | | 100 | |
555-77-1 Tris(2-chloroethyl)amine | 100* j | j
556-61-6 Methyl isothiocyanate | 500* | | |
556-64-9 Methyl thiocyanate | 10,000* | | |
557-19-7 Nickel cyanide | 1# | | P074
557-21-1 Zinc cyanide | 10 | | P121
557-34-6 Zinc acetate | 1000 | |
557-41-5 Zinc formate | 1000 | |
558-25-8 Methanesulfonyl fluoride | 1,000* | |
563-12-2 Ethion | 1,000 10 | |
563-41-7 Semicarbazide hydrochlonde | 1,000/10,000* j |
563-68-8 Acetic acid, thallium(I) salt | 100 | | U214
569-64-2 C I. Basic Green 4 | | X |
573-56-8 2,6-Dinitrophenol | 10 | |
584-84-9 Toluene 2,4-diisocyanate | 500 100 | X |
591-08-2 Acetamide, N-(aminothioxomethyl)- | 1000 | | P002
592-01-8 Calcium cyanide j 10 j j P021
592-04-1 Mercuric cyanide | | 1 | |
592-85-8 Mercuric thiocyanate | | 10 | |
592-87-0 Lead thiocyanate | | 100 | |
593-60-2 Vinyl bromide | | | X j
594-42-3 Perchloromethylmercaptan | 500 100 | |
597-64-8 Tetraethyltin | 100* j |
598-31-2 Bromoacetone | 1000 | P017
606-20-2 Benzene, l-methyl-2,6-dinitro- | 1000 X | U106
608-93-5 Benzene, pentachloro- 10 | U183
609-19-8 3,4,5-Trichlorophenol 10#
610-39-9 3,4-Dimtrotoluene 1000#
614-78-8 Thiourea, (2-methylphenyl)- 500/10,000*
615-05-4 2,4-Diaminoanisole X
615-53-2 Carbamic acid, metnylnitroso-,ethyl ester 1# U178
621-64-7 Di-n-propylnitrosamine 1# X Ulll
624-83-9 Methyl isocyanate 500 1## X P064
624-92-0 Methyl disulfide 100*
625-16-1 tert-Amyl acetate | 5000
625-55-8 Isopropyl formate 500* |
626-38-0 sec-Amy 1 acetate | 5000
627-11-2 Chloroethyl chloroforraate 1,000* |
628-63-7 Amyl acetate | 5000
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 15
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STAT
628-86-4 Fulminic acid, mercury(II)salt
630-10-4 Carbamimidoselenoic acid
630-20-6 Ethane, 1,1,1,2-tetrachloro-
630-60-4 Ouabain
631-61-8 Ammonium acetate
636-21-5 Benzenamine, 2-methyl-, hydrochloride
639-58-7 Triphenyltin chloride
640-19-7 Fluoroacetamide
644-64-4 Dimetilan
675-14-9 Cyanuric fluoride
676-97-1 Methyl phosphonic dichloride
680-31-9 Hexamethylphosphoramide
684-93-5 Carbamide, N-methyl-N-mtroso-
692-42-2 Arsine, diethyl-
696-28-6 Phenyl dichloroarsine
732-11-6 Phosmet
757-58-4 Hexaethyl tetraphosphate
759-73-9 Carbamide, N-ethyl-N-nitroso-
760-93-0 Methacrylic anhydride
764-41-0 2-8utene, 1,4-dichloro-
765-34-4 Glycidylaldehyde
786-19-6 Carbophenothion
814-49-3 Diethyl chlorophosphate
814-68-6 Acrylyl chloride
815-82-7 Cupric tartrate
823-40-5 Diaminotoluene
824-11-3 Trimethylolpropane phosphite
842-07-9 C.I. Solvent Yellow 14
900-95-8 Stannane, acetoxytriphenyl-
919-86-8 Demeton-S-methyl
920-46-7 Methacryloyl chloride
924-16-3 1-Butanamine, N-butyl-N-nitroso-
930-55-2 N-Nitrosopyrrolidine
933-75-5 2,3,6-Trichlorophenol
933-78-8 2,3,5-Trichlorophenol
944-22-9 Fonofos
947-02-4 Phosfolan
950-10-7 Mephosfolan
950-37-8 Methidathion
959-98-8 alpha-Endosulfan
100/10,000*
1
i
500/10,000*
100/10,000
500/10,000*
100*
100*
500
10/10,000*
500*
500*
500*
100*
100/10,000*
500/10,000*
500*
100*
500*
100/10,000*
500*
500/10,000*
10
1000
1#
5000
1#
100
1#
1#
1#
100
1#
If
If
100
If
If
If
10#
lOf
1
x
x
x
x
X
X
P065
P103
U208
U222
P057
U177
P038
P036
P062
U176
U074
U126
U172
U180
1
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 16
CAS Number Chemical Name
Section 304
Section 302
TPQ
RQ
Section
313 RCRA
STATE
961-11-5
989-38-8
991-42-4
998-30-1
999-81-5
1024-57-3
1031-07-8
1031-47-6
1066-30-4
1066-33-7
1066-45-1
1072-35-1
1111-78-0
1116-54-7
1120-71-4
1122-60-7
1124-33-0
1129-41-5
1163-19-5
1185-57-5
1194-65-6
1300-71-6
1303-28-2
1303-32-8
1303-33-9
1306-19-0
1309-64-4
1310-58-3
1310-73-2
1313-27-5
1314-20-1
1314-32-5
1314-56-3
1314-62-1
1314-80-3
1314-84-7
1314-87-0
1319-72-8
1319-77-3
1320-18-9
Tetrachlorvinphos
C.I. Basic Red 1
Norbormide
Triethoxysilane
Chlormequat chloride
Heptachlor epoxide
Endosulfan sulfate
Triamiphos
Chromic acetate
Ammonium bicarbonate
Trimethyltin chloride
Lead stearate
Ammonium carbamate
Ethanol, 2,2'-(nitrosoimino)bis-
1,2-Oxathiolane, 2,2-dioxide
Nitrocyclohexane
Pyridine, 4-nitro-, i-oxide
Metolcarb
Decabromodiphenyl oxide
Ferric ammonium citrate
Dichlobenil
Xylenol
Arsenic pentoxide
Arsenic disulfide
Arsenic trisulfide
Cadmium oxide
Antimony trioxide
Potassium hydroxide
Sodium hydroxide
Molybdenum trioxide
Thorium dioxide
Thai lie oxide
Phosphorus pentoxide
Vanadium pentoxide
Phosphorus pentasulfide
Zinc phosphide
Lead sulfide
2,4,5-T amines
Cresol(s)
2,4-0 Esters
100/10,000*
500*
100/10,000*
500/10,000*
500/10,000*
500*
500/10,000*
100/10,000*
100/10,000
100/10,000*
10*
100/10,000
500
1*
1
1000
5000
5000
5000
1#
1#
1000
100
1000
5000#
5000#
5000#
1000
1000
1000
100
1000
100
100
5000
5000
1000
100
X
X
U173
X U193
X
P011
X
X
X
P113
P120
U189
P122-
X U052
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 17
CAS Number Chemical Name
Section 304
Section 302 Section
TPQ RQ 313
RCRA
STATE
1321-12-6
1327-53-3
1330-20-7
1332-07-6
1332-21-4
1333-83-1
1335-32-6
1335-87-1
1336-21-6
1336-36-3
1338-23-4
1338-24-5
1341-49-7
1344-28-1
1397-94-0
1420-07-1
1464-53-5
1558-25-4
1563-66-2
1582-09-8
1600-27-7
1615-80-1
1622-32-8
1634-04-4
1642-54-2
1746-01-6
1752-30-3
1762-95-4
1836-75-5
1863-63-4
1888-71-7
1897-45-6
1910-42-5
1918-00-9
1928-38-7
1928-47-8
1928-61-6
1929-73-3
1937-37-7
1982-47-4
Nitrotoluene
Arsenous oxide
Benzene, dimethyl-
Zinc borate
Asbestos
Sodium bifluoride
Lead subacetate
Hexach 1 oronapht ha lene
Ammonium hydroxide
Polychlorinated biphenyls (PCBs)
2-Butanone peroxide
Naphthenic acid
Ammonium bifluoride
Aluminum oxide
Antimycin A
Dinoterb
Oiepoxybutane
Trichloro(chloromethyl)si lane
Carbofuran
Trif luralin
Mercuric acetate
N , N ' -D i ethyl hydraz i ne
Ethanesulfonyl chloride, 2-chloro-
Methyl tert-butyl ether
Diethylcarbamazine citrate
2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD)
Acetone thiosemicarbaride
Ammonium thiocyanate
Nitrofen
Ammonium benzoate
Hexach 1 orop ropene
Chlorothalonil
Paraquat
Dicamba
2,4-D Esters
2,4,5-T esters
2,4-0 Esters
2,4-D Esters
C.I. Direct Black 38
Chloroxuron
1000
100/10,000 5000# P012
1000 j X U239
| 1000
It X
100
1# U146
X
1000
10# X
10 U160
100
100
X
1,000/10,000*
500/10,000*
500 1# X U085
100*
10/10,000 10
X
500/10,000*
1# UQ86
500*
X
100/10,000*
1#
1,000/10,000*
5000
X
5000
1000 U243
1 x
10/10,000*
1000
100
1000
100
100
X
500/10,000*
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 18
CAS Number Chemical Name
Section 304
Section 302
ame TPQ
Section
RQ 313 RCRA STATE
2001-95-8 Valinomycin
2008-46-0 2,4, 5-T amines
2032-65-7 Methiocarb
2074-50-2 Paraquat methosulfate
2097-19-0 Phenylsilatrane
2104-64-5 EPN
2164-17-2 Fluometuron
2223-93-0 Cadmium stearate
2231-57-4 Thiocarbazide
2234-13-1 Detach loronaphthalene
2238-07-5 Oiglycidyl ether
2275-18-5 Prothoate
2303-16-4 Diallate
2312-35-8 Propargite
2497-07-6 Oxydisulfoton
2524-03-0 Dimethyl phosphorochloridothioate
2540-82-1 Formothion
2545-59-7 2, 4, 5-T esters
2570-26-5 Pentadecylamine
2587-90-8 Phosphorothioic acid, 0.0-dimethyl-S-(2-methylthio)ethyl est
2602-46-2 C.I. Direct Blue 6
2631-37-0 Promecarb
2636-26-2 Cyanophos
2642-71-9 Azinphos-ethyl
2650-18-2 C.I. Acid Blue 9, diammonium salt
2665-30-7 Phosphonothioic acid, methyl-, 0-(4-nitrophenyl) 0-phenyl es
2703-13-1 Phosphonothioic acid, methyl-, 0-ethyl 0-(4-(methy1thio)phen
2757-18-8 Thallous malonate
2763-96-4 Muscimol
2764-72-9 Diquat
2778-04-3 Endothion
2832-40-8 C.I. Disperse Yellow 3
2921-88-2 Chlorpyrifos
2944-67-4 Ferric ammonium oxalate
2971-38-2 2,4-D Esters
3012-65-5 Ammonium citrate, dibasic
3037-72-7 Si lane, (4-aminobutyl)diethoxymethyl-
3118-97-6 C.I. Solvent Orange 7
3164-29-2 Ammonium tartrate
3165-93-3 Benzenamine, 4-chloro-2-methyl-,hydrochloride
1,000/10,000*
500/10,000
10/10,000*
100/10,000*
100/10,000*
1,000/10,000*
1,000/10,000*
1,000*
100/10.000*
500*
500*
100*
100/10,000*
500*
500/10,000*
1,000*
100/10,000*
500*
500*
100/10,000*
10,000
500/10,000*
1,000*
5000
10
It
10
1000
1000
1000
1
1000
100
5000
5000
11
X
X
X
X
X
X
X
U062
P007
U049
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 19
CAS Number Chemical Name
Section 304
Section 303
TPQ
RQ
Section
313 RCRA STATE
3251-23-8 Cupric nitrate
3254-63-5 Phosphoric acid, dimethyl 4-(methylthio) phenyl ester
3288-58-2 0,0-Diethyl S-methyl dithiophosphate
3486-35-9 Zinc carbonate
3569-57-1 Sulfoxide, 3-chloropropyl octyl
3615-21-2 Benzimidazole, 4,5-dichloro-2-(trif luoromethyl)-
3689-24-5 Sulfotep
3691-35-8 Chlorophacinone
3734-97-2 Amiton oxalate
3735-23-7 Methyl phenkapton
3761-53-3 C.I. Food Red 5
3813-14-7 2,4,5-T amines
3844-45-9 C.I. Acid Blue 9, disodium salt
3878-19-1 Fuberidazole
4044-65-9 Bitoscanate
4098-71-9 Isophorone diisocyanate
4104-14-7 Phosacetim
4170-30-3 Crotonaldehyde
4301-50-2 Fluenetil
4418-66-0 Phenol, 2,2'-thiobis[4-chloro-6-methyl-
4549-40-0 Ethenamine, N-methyl-N-nitroso-
4680-78-8 C.I. Acid Green 3
4835-11-4 Hexamethylenediamine, N,N'-dibutyl-
5281-13-0 Piprotal
5344-82-1 Thiourea, (2-chlorophenyl)-
5836-29-3 Coumatetralyl
5893-66-3 Cupric oxalate
5972-73-6 Ammonium oxalate
6009-70-7 Ammonium oxalate
6369-96-6 2,4,5-T amines
6369-97-7 2,4,5-T amines
6484-52-2 Ammonium nitrate (solution)
6533-73-9 Thallous carbonate
6923-22-4 Monocrotophos
7005-72-3 4-Chlorophenyl phenyl ether
7421-93-4 Endrin aldehyde
7428-48-0 Lead stearate
7429-90-5 Aluminum (fume or dust)
7439-92-1 Lead
7439-96-5 Manganese and compounds
500*
500*
500/10,000*
500
100/10,000*
100/10,000*
500*
100/10,000*
500/10,000*
100*
100/10,000*
1,000
100/10,000*
100/10,000*
500*
100/10,000*
100/10,000
500/10,000*
100/10,000
10/10,000*
100
5000
1000
100
5000
100
1#
100
100
5000
5000
5000
5000
100
5000
1
5000
If
X
X
X
X
X
X
X
X
U087
P109
U053
P084
P026
U215
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 20
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
7439-97-6
7440-02-0
7440-22-4
7440-23-5
7440-28-0
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-g
7440-47-3
7440-48-4
7440-50-8
7440-62-2
7440-66-6
7446-08-4
7446-09-5
7446-11-9
7446-14-2
7446-18-6
7446-27-7
7447-39-4
7487-94-7
7488-56-4
7550-45-0
7558-79-4
7580-67-8
7601-54-9
7631-89-2
7631-90-5
7632-00-0
7637-07-2
7645-25-2
7646-85-7
7647-01-0
7647-18-9
7664-38-2
7664-39-3
7664-41-7
7664-93-9
Mercury
Nickel
Silver
Sodium
Tha 1 1 i urn
Ant imony
Arsenic
Barium and compounds
Beryllium
Cadmium
Chromium
Cobalt
Copper
Vanadium (fume or dust)
Zinc
Selenium dioxide
Sulfur dioxide
Sulfur trioxide
Lead sulfate
Thallous sulfate
Lead phosphate
Cupric chloride
Mercuric chloride
Selenium disulfide
Titanium tetrachloride
Sodium phosphate, dibasic
Lithium hydride
Sodium phosphate, tribasic
Sodium arsenate
Sodium bisulfite
Sodium nitrite
Boron trifluoride
Lead arsenate
Zinc chloride
Hydrochloric acid (Hydrogen chloride (gas only))***
Antimony pentachloride
Phosphoric acid
Hydrogen fluoride
Ammonia
Sulfuric acid
500*
100*
100/10,000
500/10,000*
100*
100*
1,000/10,000
500*
500
100
500
1.000
1
1#
1000
10
1000
5000
1#
1#
li
1#
5000
1000
10
100
100
1#
10
1#
5000
5000
1000*
5000
100
5000*
1000
5000
1000
5000
100
100
1000
X U151
X
X
x
x 1
X
X
X P015
X
x
x
x
x
x
1
P115
U145
U205
X
x
x
X U134
x
x
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 21
CAS Number Chemical Name
Section 304
Section 302
TPQ
RQ
Section
313 RCRA
STATE
7681-49-4
7681-52-9
7697-37-2
7699-45-8
7705-08-0
7718-54-9
7719-12-2
7720-78-7
7722-64-7
7722-84-1
7723-14-0
7726-95-6
7733-02-0
7738-94-5
7757-82-6
7758-29-4
7758-94-3
7758-95-4
7758-98-7
7761-88-8
7773-06-0
7775-11-3
7778-39-4
7778-44-1
7778-50-9
7778-54-3
7779-86-4
7779-88-6
7782-41-4
7782-49-2
7782-50-5
7782-63-0
7782-82-3
7782-86-7
7783-00-8
7783-06-4
7783-07-5
7783-18-8
7783-20-2
7783-35-9
Sodium fluoride
Sodium hypochlorite
Nitric acid
Zinc bromide
Ferric chloride
Nickel chloride
Phosphorus trichloride
Ferrous sulfate
Potassium permanganate
Hydrogen peroxide (Cone > 52%)
Phosphorus
Bromine
Zinc sulfate
Chromic acid
Sodium sulfate (solution)
Sodium phosphate, tribasic
Ferrous chloride
Lead chloride
Cupric sulfate
Silver nitrate
Ammon i urn sulfamate
Sodium chromate
Arsenic acid
Calcium arsenate
Potassium bichromate
Calcium hypochlorite
Zinc hydrosulfite
Zinc nitrate
Fluorine
Selenium
Chlorine
Ferrous sulfate
Sodium selenite
Mercurous nitrate
Selenous acid
Hydrogen sulfide
Hydrogen selenide
Ammonium thiosulfate
Ammonium sulfate (solution)
Mercuric sulfate
| 1000
j 100
1,000 j 1000 X
1000
| 1000
j 5000#
1,000 | 1000
| 1000
1 100 |
1,000* | |
100 I 1 | X
500* I |
1000
1 iooo# |
1 1 x
| 5000 |
| 100
| 100
1 10
1 1
| 5000 |
| 1000#
1 1* 1
500/10,000 | 1000# |
| 1000# |
1 10
j 1000
| 1000
500 | 10 |
100 X
100 10 X
1000
100
10#
1,000/10,000 10
500 100
10*
5000"
X
10
1
1
1
1
1
1
1
1
1
1
P010
1
P056
U204
U135
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 22
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
7783-46-2
7783-49-5
7783-50-8
7783-56-4
7783-60-0
7783-70-2
7783-80-4
7784-34-1
7784-40-9
7784-41-0
7784-42-1
7784-46-5
7785-84-4
7786-34-7
7786-81-4
7787-47-5
7787-49-7
7787-55-5
7788-98-9
7789-00-6
7789-06-2
7789-09-5
7789-42-6
7789-43-7
7789-61-9
7790-94-5
7791-12-0
7791-23-3
7803-51-2
7803-55-6
8001-35-2
8001-58-9
8003-19-8
8003-34-7
8014-95-7
8065-48-3
10022-70-5
10025-73-7
10025-87-3
10025-91-9
Lead fluoride
Zinc fluoride
Ferric fluoride
Antimony trifluoride
Sulfur tetraf luoride
Antimony pentaf luoride
Tellurium hexaf luoride
Arsenous trichloride
Lead arsenate
Potassium arsenate
Arsine
Sodium arsenite
Sodium phosphate, tribasic
Mevinphos
Nickel sulfate
Beryllium chloride
Beryllium fluoride
Beryllium nitrate
Ammonium chromate
Potassium chromate
Strontium chromate
Ammonium bichromate
Cadmium bromide
Cobaltous bromide
Antimony tribromide
Chlorosulfonic acid
Thallous chloride
Selenium oxychloride
Phosphine
Ammonium vanadate
Toxaphene (Camphechlor)
Creosote
Dichloropropane - Oichloropropene (mixture)
Pyrethrins
Sulfuric acid (fuming)
Demeton
Sodium hypochlorite
Chromic chloride
Phosphorus oxychloride
Antimony trichloride
100
1000
100
1000
100*
500*
100*
500 5000#
5000#
10001
100*
500/10,000 1000*
5000
500 10
5000#
5000#
5000#
5000#
1000#
lOOOif
1000#
1000#
100#
1000
1000
1000
100/10,000 100
500*
500 100
1000
500/10,000 If
It
100
1
1000
500*
100
1/10,000*
500 1000
1000
X
U216
P096
P119
P123
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 23
CAS Number Chemical Name
Section 304
Section 302
TPQ
RQ
Section
313
RCRA
STATE
10026-11-6 Zirconium tetrachloride
10026-13-8 Phosphorus pentachloride
10028-15-6 Ozone
10028-22-5 Ferric sulfate
10031-59-1 Thallium sulfate
10034-93-2 Hydrazine sulfate
10039-32-4 Sodium phosphate, dibasic
10043-01-3 Aluminum sulfate
10045-89-3 Ferrous ammonium sulfate
10045-94-0 Mercuric nitrate
10049-04-4 Chlorine dioxide
10049-05-5 Chromous chloride
10099-74-8 Lead nitrate
10101-53-8 Chromic sulfate
10101-63-0 Lead iodide
10101-89-0 Sodium phosphate, tribasic
10102-06-4 Uranyl nitrate
10102-18-8 Sodium selenite
10102-20-2 Sodium tellurite
10102-43-9 Nitric oxide
10102-44-0 Nitrogen dioxide
10102-45-1 Thallium(I) nitrate
10102-48-4 Lead arsenate
10108-64-2 Cadmium chloride
10124-50-2 Potassium arsenite
10124-56-8 Sodium phosphate, tribasic
10140-65-5 Sodium phosphate, dibasic
10140-87-1 Ethanol, 1,2-dichloro-, acetate
10192-30-0 Ammonium bisulfite
10196-04-0 Ammonium sulfite
10210-68-1 Cobalt carbonyl
10265-92-6 Methamidophos
10294-34-5 Boron trichloride
10311-84-9 Oialifos
10361-89-4 Sodium phosphate, tribasic
10380-29-7 Cupric sulfate ammoniated
10415-75-5 Mercurous nitrate
10421-48-4 Ferric nitrate
10476-95-6 Methacrolein diacetate
10544-72-6 Nitrogen dioxide
500*
100*
100/10,000
100/10,000
500/10,000*
100
100
500/10,000
1,000*
10/10,000*
100/10,000*
500*
100/10,000*
1,000*
5000
1000
100
5000
5000
1000
10
1000
100
1000
100
5000
100
100
10
10
100
5000#
100#
1000#
5000
5000
5000
5000
5000
100
10
1000
10
X
X
P076
P078
U217
1
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 24
CAS Number Chemical Name
Section 304
Section 302
TPQ
RQ
Section
313 RCRA
STATE
10588-01-9 Sodium bichromate
11096-82-5 Aroclor 1260
11097-69-1 Aroclor 1254
11104-28-2 Aroclor 1221
11115-74-5 Chromic acid
11141-16-5 Aroclor 1232
12002-03-8 Paris green (Cupric acetoarsenite)
12039-52-0 Thallium(I) selenide
12054-48-7 Nickel hydroxide
12108-13-3 Manganese, tricarbonyl methylcyclopentadienyl
12122-67-7 Zineb
12125-01-8 Ammonium fluoride
12125-02-9 Ammonium chloride
12135-76-1 Ammonium sulfide
12427-38-2 Maneb
12672-29-6 Aroclor 1248
12674-11-2 Aroclor 1016
12771-08-3 Sulfur monochloride
13071-79-9 Terbufos
13171-21-6 Phosphamidon
13194-48-4 Ethoprophos
13410-01-0 Sodium selenate
13450-90-3 Gallium trichloride
13463-39-3 Nickel carbonyl
13463-40-6 Iron, pentacarbonyl-
13494-80-9 Tellurium
13560-99-1 2,4,5-T salts
13597-99-4 Beryllium nitrate
13746-89-9 Zirconium nitrate
13765-19-0 Calcium chromate
13814-96-5 Lead fluoborate
13826-83-0 Ammonium fluoborate
13952-84-6 sec-Butylamine
14017-41-5 Cobaltous sulfamate
14167-18-1 Salcomine
14216-75-2 Nickel nitrate
14258-49-2 Ammonium oxalate
14307-35-8 Lithium chromate
14307-43-8 Amnonium tartrate
14639-97-5 Zinc ammonium chloride
500/10,000
100*
100*
100*
1.000*
100/10,000*
500/10,000*
1
100*
500/10,000*
500/10,000*
1000*
10*
10*
lot
1000#
10#
100#
1000
1000#
100
5000
100
10#
10*
1000
If
1000
5000#
5000
1000*
100
5000
1000
1000
5000*
5000
1000*
5000
5000*
X
X
P114
P073
U032
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 25
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
14639-98-6 Zinc ammonium chloride
14644-61-2 Zirconium sulfate
15271-41-7 Bicyc1o[2.2.1]heptane-2-carbonitrne, 5-chloro-6-((((methyla
15699-18-0 Nickel ammonium sulfate
15739-80-7 Lead sulfate
15950-66-0 2,3,4-Trichlorophenol
16071-86-6 C.I. Direct Brown 95
16543-55-8 N-Nitrosonornicotine
16721-80-5 Sodium hydrosulfide
16752-77-5 Methomyl
16871-71-9 Zinc silicof luoride
16919-19-0 Ammonium silicof luoride
16923-95-8 Zirconium potassium fluoride
17702-41-9 Decaborane(14)
17702-57-7 Formparanate
18883-66-4 D-Glucopyranose, 2-deoxy-2-(3-metnyl-3-n1trosoureido)-
19287-45-7 Diborane
19624-22-7 Pentaborane
20816-12-0 Osmium tetroxide
20830-75-5 Oigoxin
20830-81-3 Oaunomycin
20859-73-8 Aluminum phosphide
21548-32-3 Fosthietan
21609-90-5 Leptophos
21908-53-2 Mercuric oxide
21923-23-9 Chlorthiophos
22224-92-6 Fenamiphos
23135-22-0 Oxamyl
23422-53-9 Formetanate hydrochloride
23505-41-1 Pirimifos-ethyl
23950-58-5 3,5-Oichloro-N-{l,l-d1methyl-2-propynyl)benzam1de
24017-47-8 Triazofos
24934-91-6 Chlormephos
25154-54-5 Oinitrobenzene (mixed)
25154-55-6 Nitrophenol (mixed)
25155-30-0 Sodium dodecylbenzene sulfonate
25167-82-2 Trlchlorophenol
25168-15-4 2,4,5-T esters
25168-26-7 2,4-D Esters
25321-14-6 Olnltrotoluene
500/10,000*
500/10,000
500/10,000*
100/10,000*
100*
500*
10/10,000*
500
500*
500/10,000*
500/10,000*
500*
10/10,000*
100/10,000*
500/10,000*
1,000*
500*
500*
5000*
5000
5000#
100
10*
5000
100
5000
1000
1000
1*
1000
«
100
5000
100
100
1000
10#
1000
100
1000*
X
X
X
P066
U206
P087
U059
P006
U192
Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 26
CAS Number Chemical Name
Section 304
Section 302
TPQ RQ
Section
313 RCRA
STATE
25321-22-6
25376-45-8
25550-58-7
26264-06-2
26419-73-8
26471-62-5
26628-22-8
26638-19-7
26952-23-8
27137-85-5
27176-87-0
27323-41-7
27774-13-6
28300-74-5
28347-13-9
28772-56-7
30525-89-4
30674-80-7
32534-95-5
33213-65-9
36478-76-9
37211-05-5
39156-41-7
39196-18-4
42504-46-1
50782-69-9
52628-25-8
52652-59-2
52740-16-6
53467-11-1
53469-21-9
53558-25-1
55488-87-4
56189-09-4
58270-08-9
61792-07-2
Dichlorobenzene (mixed)
Diaminotoluene
Dinitrophenol
Calcium dodecyl benzene sulfonate
Carbamic acid, methyl-, 0-( ((2,4-dimethyl-l, 3-dithiolan-2-y 100/10,000*
Benzene, 2,4-diisocyanatomethyl-
Sodium azide (Na(N3)) 500
Dichloropropane
Dichloropropene
Trichloro(dichloropheny1)si lane 500*
Dodecylbenzenesulfonic acid
Triethanolamine dodecyl benzene sulfonate
Vanadyl sulfate
Antimony potassium tartrate
Xylylene dichloride 100/10,000*
Bromadiolone 100/10,000*
Paraf orma Idehyde
Methacryloyloxyethyl isocyanate 100*
2,4,5-TP acid esters
beta-Endosulfan
Uranyl nitrate
Nickel chloride
2,4-Diaminoanisole sulfate
Thiofanox 100/10,000
Isopropanolamine dodecyl benzene sulfonate
Phosphonothioic acid, methyl-, S-(2-(bis(l-methylethyl)amino 100*
Zinc ammonium chloride
Lead stearate
Calcium arsenite
2,4-D Esters
Aroclor 1242
Pyriminil 100/10,000*
Ferric ammonium oxalate
Lead stearate
Zinc, dichloro(4,4-dimethyl-5((((methylamino) carbonyl)oxy)i 100/10,000*
2,4,5-T esters
100 X
j W X
1 10
1000
1
1 1*
1000
1 1000
| 100
1000
1 1000
| 1000
1 100
| 1000
100
1
100"'
5000#
X
100
1000
1000
5000
1000#
100
10#
1000
j 5000
1000
U221
U223
P105
1
P045
62207-76-5 Cobalt, ((2,2'-(l,2-ethanediylbis (nitrilotnethylidyne))bis(6 | 100/10,000* | | |
* Releases in excess of the CERCLA RQ must be reported under Section 304. If an RQ has not been assigned to a chemical
(i.e., the chemical is an EHS but not a CERCLA hazardous substance), releases of 1 pound or greater must be reported
under Section 304.
-------
Page 27
CAS Number Chemical Name
Organorhodium Complex
Barium Compounds
Cobalt Compounds
Cyanide and Compounds
Glycol Ethers
Manganese Compounds
Polybrominated Biphenyls (PBBs)
Antimony and Compounds
Arsenic and Compounds
Beryllium and Compounds
Cadmium and Compounds
Chlordane (Technical Mixture and Metabolites)
Chlorinated Benzenes
Chlorinated Ethanes
Chlorinated Naphthalene
Chlorinated Phenols
Chloroalkyl Ethers
Chromium and Compounds
Coke Oven Emissions
Copper and Compounds
DDT and Metabolites
Dichlorobenzidine
0 i pheny 1 hydraz i ne
Endosulfan and Metabolites
Endrin and Metabolites
Haloethers
Halomethanes
Heptachlor and Metabolites
Lead and Compounds
Mercury and Compounds
Nickel and Compounds
Nitrophenols
Nitrosamines
Phthalate Esters
Polynuclear Aromatic Hydrocarbons
Radionuclides
Selenium and Compounds
Silver and Compounds
Thallium and Compounds
Zinc and Compounds
Section 304
Section 302
TPQ
RQ
Section
313
RCRA
STATE
=================================
10/10,000*
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
r
**
**
**
**
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Page 1
CAS Number Chemical Name
CAS Number
Chemical Name
83-32-9 Acenaphthene 7789-09-5
208-96-8 Acenaphthylene 1341-49-7
75-07-0 Acetaldehyde 10192-30-0
75-87-6 Acetaldehyde, trichloro- 1111-78-0
60-35-5 Acetamide 506-87-6
591-08-2 Acetamide, N-(aminothioxomethyl)- 12125-02-9
62-44-2 Acetamide, N-(4-ethoxyphenyl)- 7788-98-9
53-96-3 Acetamide, N-9H-fluoren-2-yl- 3012-65-5
64-19-7 Acetic acid 13826-83-0
141-78-6 Acetic acid, ethyl ester 12125-01-8
301-04-2 Acetic acid, lead salt 1336-21-6
563-68-8 Acetic acid, thallium(I) salt 6484-52-2
108-24-7 Acetic anhydride 5972-73-6
67-64-1 Acetone 6009-70-7
75-86-5 Acetone cyanohydrin 14258-49-2
1752-30-3 Acetone thiosemicarbazide 131-74-8
75-05-8 Acetonitrile 16919-19-0
98-86-2 Acetophenone 7773-06-0
506-96-7 Acetyl bromide 7783-20-2
75-36-5 Acetyl chloride 12135-76-1
107-02-8 Acrolein 10196-04-0
79-06-1 Acrylamide 3164-29-2
79-10-7 Acrylic acid 14307-43-8
107-13-1 Acrylomtnle 1762-95-4
814-68-6 Acrylyl chloride 7783-18-8
124-04-9 Adipic acid 7803-55-6
111-69-3 Adiponitrile 300-62-9
148-82-3 Alanine, 3-[p-bis(2-chloroethyl)amino]phenyl-,L- 628-63-7
116-06-3 Aldicarb 123-92-2
309-00-2 Aldrin 626-38-0
107-18-6 Allyl alcohol 625-16-1
107-05-1 Allyl chloride 62-53-3
107-11-9 Allylamine 88-05-1
7429-90-5 Aluminum (fume or dust) 90-04-0
1344-28-1 Aluminum oxide 104-94-9
20859-73-8 Aluminum phosphide 134-29-2
10043-01-3 Aluminum sulfate 120-12-7
106-49-0 4-Amino-l-methyl benzene 7440-36-0
82-28-0 l-Amino-2-methylanthraquinone - -0
117-79-3 2-Aminoanthraquinone 7647-18-9
60-09-3 4-Aminoazobenzene 7783-70-2
92-67-1 4-Aminobiphenyl 28300-74-5
54-62-6 Aminopterin 7789-61-9
78-53-5 Amiton 10025-91-9
3734-97-2 Amiton oxalate 7783-56-4
61-82-5 Amitrole 1309-64-4
7664-41-7 Aimtonia 1397-94-0
631-61-8 Ammonium acetate 86-88-4
1863-63-4 Ammonium benzoate 12674-11-2
1066-33-7 Ammonium bicarbonate 11104-28-2
Ammonium bichromate
Ammonium bifluoride
Ammonium bisulfite
Ammonium carbamate
Ammonium carbonate
Ammonium chloride
Ammonium chromate
Ammonium citrate, dibasic
Ammonium fluoborate
Ammonium fluoride
Ammonium hydroxide
Ammonium nitrate (solution)
Ammonium oxalate
Ammonium oxalate
Ammonium oxalate
Ammonium pi crate
Ammonium si licofluoride
Ammonium sulfamate
Ammonium sulfate (solution)
Ammonium sulfide
Ammonium sulfite
Ammonium tartrate
Ammonium tartrate
Ammonium thiocyanate
Ammonium thiosulfate
Ammonium vanadate
Amphetamine
Amyl acetate
iso-Amy1 acetate
sec-Amyl acetate
tert-Amyl acetate
Aniline
Aniline, 2,4,6-trimethyl-
o-Anisidine
p-Anisidine
o-Anisidine hydrochlonde
Anthracene
Antimony
Antimony and Compounds
Antimony pentachloride
Antimony pentafluoride
Antimony potassium tartrate
Antimony tribromide
Antimony trichloride
Antimony trifluoride
Antimony trioxide
Antimycin A
Antu
Aroclor 1016
Aroclor 1221
-------
Page 2
CAS Number
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Chemical Name CAS Number Chemical Name
11141
53469-
12672
11097
11096-
7440-
7778-
1303
1303
1303-
1327-
7784-
7784-
692-
1332-
115-
2642-
86-
319-
319-
319-
7440-
542-
56-
225-
98-
55-
56-
57-
106-
3165-
636-
99-
101-
60-
100-
98-
71-
101-
108-
100-
95'
541-
106-
26471
1330
108
95
16-5
21-9
29-6
69-1
82-5
38-2
39-4
-0
32-8
28-2
33-9
53-3
34-1
42-1
42-2
21-4
02-6
71-9
50-0
84-6
85-7
86-8
39-3
• -0
62-1
•49-5
•51-4
87-3
•21-0
•55-3
•97-6
-47-8
•93-3
•21-5
•55-8
•14-4
•11-7
•01-6
•16-8
•43-2
-55-3
•90-7
-14-1
•50-1
-73-1
-46-7
-62-5
-20-7
-38-3
-47-6
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Arsenic
Arsenic acid
Arsenic and Compounds
Arsenic disulfide
Arsenic pentoxide
Arsenic trisulfide
Arsenous oxide
Arsenous trichloride
Arsine
Arsine, diethyl-
Asbestos
Azaserme
Azinphos-ethyl
Azinphos-methyl
alpha-BHC
beta-BHC
delta-BHC
Barium and compounds
Barium Compounds
Barium cyanide
8enz[j]aceanthrylene,l,2-dihydro-3-methyl-
Benz[c]acridine
Benzal chloride
Benzamide
Benz [a]anthracene
1,2-Benzanthracene, 7,12-dimethyl-
Benzenamine, 4-chloro-
Benzenamine, 4-chloro-2-methy1-,hydrochloride
2-methyl-, hydrochloride
2-methyl-5-mtro-
4,4'-methylenebi s(2-ch loro-
N,N-dimethyl-4-phenylazo-
4-nitro-
3-(trifluoromethyl)-
Benzenamine
Benzenamine
Benzenamine
Benzenamine
Benzenamine
Benzenamine
Benzene
Benzene
Benzene
Benzene
Benzene
Benzene
Benzene
Benzene
Benzene
Benzene
1-bromo-4-phenoxy-
chloro-
1 -(enloromethy1)-4-nitro-
1,2-dichloro-
1,3-dichloro-
1,4-dichloro-
2,4-diisocyanatomethyl-
dimethyl-
m-dimethyl-
Benzene, o-dimethyl-
106-42-3 Benzene, p-dimethyl-
118-74-1 Benzene, hexachloro
110-82-7 Benzene, hexahydro-
108-88-3 Benzene, methyl-
121-14-2 Benzene, l-methyl-2,4-dinitro-
606-20-2 Benzene, l-methyl-2,6-dinitro-
94-59-7 Benzene, l,2-methylenedioxy-4-allyl-
120-58-1 Benzene, l,2-methylenedioxy-4-propenyl-
94-58-6 Benzene, l,2-methylenedioxy-4-propyl-
98-82-8 Benzene, 1-methylethyl-
608-93-5 Benzene, pentachloro-
82-68-8 Benzene, pentachloronit.ro-
95-94-3 Benzene, 1,2,4,5-tetrachloro-
99-35-4 Benzene, 1,3,5-trimtro-
98-05-5 Benzenearsonic acid
85-44-9 1,2-Benzenedicarboxylic acid anhydride
117-81-7 1,2-Benzenedicarboxylic acid,[bis(2-ethylhexyl)]este
84-66-2 1,2-Benzenedicarboxylic acid, diethyl ester
108-46-3 1,3-Benzenediol
51-43-4 l,2-Benzenediol,4-[l-hydroxy-2-(methylamino)ethyl]-
98-09-9 Benzenesulfonyl chloride
92-87-5 Benzidine
3615-21-2 Benzimidazole, 4,5-dichloro-2-(trifluoromethyl)-
81-07-2 l,2-Benzisothiazolin-3-one,l,l-dioxide, and salts
207-08-9 Benzo[k]fluoranthene
206-44-0 Benzo[j,k]fluorene
65-85-0 Benzoic acid
205-99-2 Benzol [b]fluoranthene
100-47-0 Benzonitrile
191-24-2 Benzo[ghi]perylene
50-32-8 Benzo[a]pyrene
106-51-4 p-Benzoquinone
98-07-7 Benzotrichloride
98-88-4 Benzoyl chloride
94-36-0 Benzoyl peroxide
218-01-9 1,2-Benzphenanthrene
100-44-7 Benzyl chloride
140-29-4 Benzyl cyanide
7440-41-7 Beryllium
- -0 Beryllium and Compounds
7787-47-5 Beryllium chloride
7787-49-7 Beryllium fluoride
7787-55-5 Beryllium nitrate
13597-99-4 Beryllium nitrate
15271-41-7 Bicyclo[2.2.1]heptane-2-carbonitrile, 5-chloro-6-(((
92-52-4 Biphenyl
91-94-1 (1,1'-Biphenyl)-4,4'-diamine,3,3'-dichloro-
119-90-4 (l,l'-Biphenyl)-4,4'-diamine,3,3'-dimethoxy-
119-93-7 (l,r-Biphenyl)-4,4'-diamine,3,3'-dimethyl-
111-91-1 B1s(2-chloroethoxy) methane
-------
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Page 3
CAS Number
Chemical Name
CAS Number Chemical Name
108-60-1
534-07-6
137-26-8
103-23-1
4044-65-9
10294-34-5
7637-07-2
353-42-4
28772-56-7
7726-95-6
598-31-2
75-25-2
357-57-3
106-99-0
924-16-3
305-03-3
71-36-3
78-93-3
1338-23-4
764-41-0
123-86-4
110-19-0
105-46-4
540-88-5
141-32-2
78-92-2
75-65-0
85-68-7
109-73-9
78-81-9
513-49-5
13952-84-6
75-64-9
106-88-7
123-72-8
79-31-2
107-92-6
2650-18-2
3844-45-9
4680-78-8
569-64-2
989-38-8
1937-37-7
2602-46-2
16071-86-6
2832-40-8
3761-53-3
81-88-9
3118-97-6
97-56-3
Bis
Bis
Bis
Bis
Bit
Bon
Bon
Bon
Broi
Broi
Broi
Broi
Brui
But,
1-Bi
But,
1-Bi
Z-Bi
2-Bi
2-Bi
But;
ISO
sec
ter
But;
sec
ter
But;
But;
i so-
sec-
sec-
ter
1,2
But;
ISO-
But;
C.I
C.I
C.I
C.I
C.I
C.I
C.I
C.I
C.I
C.I
C.I
C.I
C.I
Bis(2-chloroisopropy1) ether
Bis(chloromethyl) ketone
Bis(dimethyHhiocarbamoyl)d1sulf ide
Bis(2-ethylhexyl) adipate
Bitoscanate
Boron trichloride
Boron trifluoride
Boron trifluoride compound with methyl ether (1:1)
Bromadiolone
Bromine
Bromoacetone
rm
ie
1-Butanamine, N-butyl-N-nitroso-
Butanoic acid, 4-[bis(2-chloroethyl)amino] benzene-
3l
3ne
2-Butanone peroxide
2-Butene, 1,4-dichloro-
Butyl acetate
iso-Butyl acetate
sec-Butyl acetate
tert-Butyl acetate
Butyl acrylate
sec-Butyl alcohol
tert-Butyl alcohol
Butyl benzyl phthalate
Butylamine
iso-Butylamine
sec-Butylamine
sec-Butylamine
tert-Butylamine
1,2-Butylene oxide
Butyraldehyde
iso-Butyric acid
acid
C.I. Acid Blue 9, diammonium salt
Acid Blue 9, disodium salt
C.I. Acid Green 3
Basic Green 4
Basic Red 1
Direct Black 38
Direct Blue 6
Direct Brown 95
Disperse Yellow 3
Food Red 5
Food Red 15
Solvent Orange 7
C.I. Solvent Yellow 3
842-07-9 C.I. Solvent Yellow 14
492-80-8 C.I. Solvent Yellow 34 (Auramine)
128-66-5 C.I. Vat Yellow 4
75-60-5 Cacodylic acid
7440-43-9 Cadmium
543-90-8 Cadmium acetate
- -0 Cadmium and Compounds
7789-42-6 Cadmium bromide
10108-64-2 Cadmium chloride
1306-19-0 Cadmium oxide
2223-93-0 Cadmium stearate
7778-44-1 Calcium arsenate
52740-16-6 Calcium arsenite
75-20-7 Calcium carbide
13765-19-0 Calcium chromate
156-62-7 Calcium cyanamide
592-01-8 Calcium cyanide
26264-06-2 Calcium dodecylbenzene sulfonate
7778-54-3 Calcium hypochlorite
56-25-7 Cantharidin
133-06-2 Captan
51-83-2 Carbachol chloride
51-79-6 Carbamic acid, ethyl ester
26419-73-8 Carbaroic acid, methyl-, 0-(((2,4-dimethyl-l, 3-dithi
615-53-2 Carbamic acid, methylnitroso-,ethyl ester
759-73-9 Carbamide, N-ethyl-N-nitroso-
684-93-5 Carbamide, N-methyl-N-nitroso-
62-56-6 Carbamide, thio-
630-10-4 Carbamimidoselenoic acid
79-44-7 Carbamyl chloride, dimethyl-
63-25-2 Carbaryl
1563-66-2 Carbofuran
75-15-0 Carbon disulfide
353-50-4 Carbon oxyfluoride
56-23-5 Carbon tetrachloride
463-58-1 Carbonyl sulfide
786-19-6 Carbophenothion
120-80-9 Catechol
133-90-4 Chloramben
57-74-9 Chlordane
- -0 Chlordane (Technical Mixture and Metabolites)
470-90-6 Chlorfenvinfos
- -0 Chlorinated Benzenes
- -0 Chlorinated Ethanes
76-13-1 Chlorinated fluorocarbon (Freon 113)
- -0 Chlorinated Naphthalene
- -0 Chlorinated Phenols
7782-50-5 Chlorine
506-77-4 Chlorine cyanide
10049-04-4 Chlorine dioxide
-------
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Page 4
CAS Number
24934-
999-
494-
59-
107-
79-
532-
124-
75-
107-
627-
110-
67-
542-
107-
91-
3691-
95-
7005-
126-
7790-
1897-
1982-
2921-
21923-
1066-
7738-
11115-
10025-
10101-
7440-
10049
7440-
10210-
62207-
7789
544
14017-
64
7440
544
56
5836
8001
120
91-6
81-5
03-1
50-7
20-0
11-8
27-4
-0
48-1
00-3
07-3
11-2
75-8
66-3
88-1
30-2
58-7
35-8
57-8
72-3
99-8
94-5
45-6
47-4
88-2
23-9
30-4
94-5
74-5
•73-7
•53-8
47-3
• -0
•05-5
•48-4
• -0
•68-1
•76-5
•43-7
•18-3
•41-5
• -0
•86-8
•50-8
• -0
•92-3
-72-4
•29-3
•58-9
•71-8
Chlormephos
Chlormequat
Chlornaphaz
4-Chloro-m-i
Chloroaceta
Chloroacetn
2-Chloroace
Chloroalkyl
Chlorodibroi
Chloroethane
Chloroethanol
Chloroethy
2-Chloroeti
Chloroform
Chlorometh
Chlorometh;
beta-Chlor
Chlorophac
2-Chlorophi
4-Chloroph'
Chloroprene
Chlorosulfoi
Chlorothalom
Chloroxuron
Chlorpyrifos
Chlorthlophos
Chromic
Chromic acid
Chromic acid
Chromic i
Chromic :
Chromium
Chromium
Chromous
Cobalt
Cobalt Ci
Cobalt Ci
Cobalt,
Cobaltou;
Cobaltou
Cobaltou:
Coke Ovei
Colchicine
Copper
Copper an-
Copper cy
Coumaphos
Coumatetralyl
Creosote
p-Cresidine
IS
;t chloride
izine
i-cresol
:aldehyde
ic acid
;etophenone
'1 Ethers
•omomethane
me
mol
'1 chloroformate
:hyl vinyl ether
i
lyl ether
lyl methyl ether
•onaphthalene
nnone
lenol
\enyl phenyl ether
le
:onic acid
oni 1
m
:os
ihos
:etate
:id
:id
iloride
i If ate
ind Compounds
:hloride
ipounds
•bonyl
;2,2'-{l,2-ethanediylbis
bromide
formate
sulfamate
Emissions
!
1 Compounds
inide
ilyl
le
1319-77-3
108-39-4
95-48-7
106-44-5
535-89-7
4170-30-3
123-73-9
135-20-6
142-71-2
7447-39-4
3251-23-8
5893-66-3
7758-98-7
10380-29-7
815-82-7
- -0
57-12-5
460-19-5
506-68-3
506-78-5
2636-26-2
675-14-9
108-94-1
66-81-9
108-91-8
50-18-0
94-75-7
94-11-1
94-79-1
94-80-4
1320-18-9
1928-38-7
1928-61-6
1929-73-3
2971-38-2
25168-26-7
53467-11-1
(nitrilomethylidyn 72-54-8
72-5579
50-29-3
- -0
20830-81-3
17702-41-9
1163-19-5
8065-48-3
919-86-8
621-64-7
10311-84-9
2303-16-4
615-05-4
Cresol(s)
m-Cresol
o-Cresol
p-Cresol
Crimidine
Crotonaldehyde
Crotonaldehyde, (£)-
Cupferron
Cupric acetate
Cupric chloride
Cupric nitrate
Cupric oxalate
Cupric sulfate
Cupric sulfate ammoniated
Cupric tartrate
Cyanide and Compounds
Cyanides (soluble cyanide salts)
Cyanogen
Cyanogen bromide
Cyanogen iodide
Cyanophos
Cyanuric fluoride
Cyclohexanone
Cycloheximide
Cyclohexylamine
Cyclophosphamide
2,4-D Acid
2,4-0 Esters
2,4-D Esters
2,4-D Esters
2,4-D Esters
2,4-D Esters
2,4-D Esters
2,4-D Esters
2,4-D Esters
2,4-D Esters
2,4-0 Esters
ODD
DDE
DDT
DDT and Metabolites
Daunomyc i n
Decaborane(14)
Decabromodi phenyl oxide
Demeton
Demeton-S-methyl
Di-n-propylnitrosamine
Dialifos
Dial late
2,4-Oiaminoanisole
-------
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Page 5
CAS Number Chemical Name CAS Number Chemical Name
39156-41-7
101-80-4
95-80-7
496-72-0
823-40-5
25376-45-8
333-41-5
334-88-3
53-70-3
132-64-9
189-55-9
19287-45-7
96-12-8
84-74-2
1918-00-9
1194-65-6
117-80-6
23950-58-5
25321-22-6
- -0
75-27-4
110-57-6
75-71-8
75-34-3
107-06-2
111-44-4
75-35-4
540-59-0
156-60-5
149-74-6
120-83-2
87-65-0
26638-19-7
78-99-9
78-87-5
142-28-9
8003-19-8
26952-23-8
542-75-6
78-88-6
75-99-0
62-73-7
115-32-2
141-66-2
60-57-1
1464-53-5
111-42-2
814-49-3
64-67-5
311-45-5
2,
4,
D'
Di
D^
D-
D'
D:
D-
D'
1,
D-
1,
D-
D
D
D
3
D
D
0
Ti
D
1
1
D
1
1
1
D
2
2
D
1
1
1
D
D
1
2
2
0
D
D
D
0
D
D
D
0
2,4-Diaminoanisole sulfate 109-89-7
4,4'-Oiaminodiphenyl ether 1642-54-2
Diaminotoluene 123-91-1
Diaminotoluene 56-53-1
Diaminotoluene 71-63-6
Diaminotoluene 2238-07-5
Diazinon 20830-75-5
Diazomethane 123-33-1
Dibenz [a,h]anthracene 115-26-4
Dibenzofuran 60-51-5
l,2:7,8-Dibenzopyrene 2524-03-0
Diborane 131-11-3
l,2-Dibromo-3-chloropropane 77-78-1
Oibutyl phthalate 75-18-3
Dicamba 99-98-9
Dichlobenil 124-40-3
Dichlone 80-15-9
3,5-Dichloro-N-(l,l-dimethyl-2-propynyl)benzamide 75-78-5
Dichlorobenzene (mixed) 57-14-7
Dichlorobenzidine 540-73-8
Oichlorobromomethane 122-09-8
Trans-1.4-d1chlorobutene 105-67-9
Dichlorodifluoromethane 644-64-4
1,1-Dichloroethane 131-89-5
1,2-Oichloroethane 25154-54-5
Dichloroethyl ether 99-65-0
1,1-Dichloroethylene 528-29-0
1,2-Dichloroethylene 100-25-4
1,2-trans-Dichloroethylene 534-52-1
DichloromethylphenyIsilane 51-28-5
2,4-Dichlorophenol 329-71-5
2,6-Dichlorophenol 573-56-8
Dichloropropane 25550-58-7
1,1-Dichloropropane 610-39-9
1,2-Oichloropropane 25321-14-6
1,3-Dichloropropane 88-85-7
Dichloropropane - Dichloropropene (mixture) 1420-07-1
Dichloropropene 117-84-0
1,3-Dichloropropene 78-34-2
2,3-Dichloropropene 82-66-6
2,2-Dichloropropionic acid 122-66-7
Dichlorvos - -0
Oicofol" 152-16-9
Dicrotophos 142-84-7
Dieldrin 85-00-7
Oiepoxybutane 2764-72-9
Diethanolamine 298-04-4
Diethyl chlorophosphate 514-73-8
Diethyl sulfate 541-53-7
Qiethyl-p-nitropnenyl phosphate 330-54-1
Diethylamine
Diethylcarbamazine citrate
1,4-Diethylene dioxide
Diethylstilbestrol
Digitoxin
Diglycidyl ether
Digoxin
1,2-Dihydro-3,6-pyridazined i one
Dimefox
Dimethoate
D imethy 1 phosphoroch londoth ioate
Dimethyl phthalate
Dimethyl sulfate
Dimethyl sulfide
Dimethyl-p-phenylenediamine
Dimethylamine
alpha,aIpha-DimethyIbenzylhydroperoxide
Dimethyldichlorosilane
Oimethylhydrazine
1,2-DimethyIhydrazine
alpha,aIpha-Dimethylphenethylamine
2,4-Dimethylphenol
Dimetilan
4,6-Din i tro-o-cyclohexy1pheno1
Dinitrobenzene (mixed)
m-Dinitrobenzene
o-Dimtrobenzene
p-Dimtrobenzene
Dinitrocresol
2,4-Oinitrophenol
2,5-Dimtrophenol
2,6-Dinitrophenol
Dinitrophenol
3,4-Dinitrotoluene
Dinitrotoluene
Dinoseb
Oinoterb
Dioctyl phthalate
Dioxathion
Diphacinone
1,2-DiphenyIhydrazine
D i pheny1hydraz i ne
Diphosphoramide, octamethyl-
Dipropylamine
Diquat
Diquat
Disulfoton
Dithiazanine iodide
Dithiobiuret
Diuron
-------
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Page 6
CAS Number Chemical Name CAS Number Chemical Name
27176-87-0 Dodecylbenzenesulfonic acid 52-85-7
316-42-7 Emetine, dihydrochloride 22224-92-6
115-29-7 Endosulfan 122-14-5
- -0 Endosulfan and Metabolites 115-90-2
959-98-8 alpha-Endosulfan 1185-57-5
33213-65-9 beta-Endosulfan 2944-67-4
1031-07-8 Endosulfan sulfate 55488-87-4
145-73-3 Endothall 7705-08-0
2778-04-3 Endothion 7783-50-8
72-20-8 Endrin 10421-48-4
7421-93-4 Endrin aldehyde 10028-22-5
- -0 Endrin ano Metabolites 10045-89-3
106-89-8 Epichlorohydrin 7758-94-3
2104-64-5 EPN 7720-78-7
50-14-6 Ergocalciferol 7782-63-0
379-79-3 Ergotamine tartrate 4301-50-2
55-18-5 Ethanamine, N-ethyl-N-mtroso- 2164-17-2
106-93-4 Ethane, 1,2-dibromo- 86-73-7
67-72-1 Ethane, 1,1,1,2,2,2-hexachloro- 7782-41-4
60-29-7 Ethane, l,l'-oxybis- 640-19-7
630-20-6 Ethane, 1,1,1,2-tetrachloro- 144-49-0
79-34-5 Ethane, 1,1,2,2-tetrachloro- 359-06-8
79-00-5 Ethane, 1,1.2-trichloro- 51-21-8
72-43-5 Ethane, l,l,l-trichloro-2,2-bis(p-methoxyphenyl)- 944-22-9
111-54-6 1,2-Ethanediylbiscarbamodithioic acid 50-00-0
1622-32-8 Ethanesulfonyl chloride, 2-chloro- 107-16-4
62-55-5 Ethanethioamide 23422-53-9
10140-87-1 Ethanol, 1,2-dichloro-, acetate 64-18-6
1116-54-7 Ethanol, 2,2'-(nitrosoimino)bis- 2540-82-1
4549-40-0 Ethenamine, N-methyl-N-nitroso- 17702-57-7
127-18-4 Ethene, 1,1,2,2-tetrachloro- 21548-32-3
563-12-2 Ethion 3878-19-1
13194-48-4 Ethoprophos 628-86-4
110-80-5 2-Ethoxyethanol 110-17-8
140-88-5 Ethyl acrylate 110-00-9
541-41-3 Ethyl chloroformate 109-99-9
510-15-6 Ethyl 4,4'-dichlorobenzilate 98-01-1
97-63-2 Ethyl methacrylate 108-31-6
62-50-0 Ethyl methanesulfonate 13450-90-3
542-90-5 Ethyl thiocyanate 18883-66-4
100-41-4 Ethylbenzene 765-34-4
538-07-8 Ethylbis(2-chloroethyl)amine - -0
74-85-1 Ethylene 70-25-7
371-62-0 Ethylene fluorohydrin - -0
107-21-1 Ethylene glycol - -0
75-21-8 Ethylene oxide 76-44-8
107-15-3 Ethylenediamine - -0
60-00-4 Ethylenediamine tetraacetic acid (EOTA) 1024-57-3
151-56-4 Ethyleneimine 87-68-3
96-45-7 Ethylenethiourea 77-47-4
Famphur
Fenamiphos
Fenitrothion
Fensulfothion
Ferric ammonium citrate
Ferric ammonium oxalate
Ferric ammonium oxalate
Ferric chloride
Ferric fluoride
Ferric nitrate
Ferric sulfate
Ferrous ammonium sulfate
Ferrous chloride
Ferrous sulfate
Ferrous sulfate
Flueneti1
Fluometuron
Fluorene
Fluorine
Fluoroacetamide
Fluoroacetic acid
Fluoroacetyl chloride
Fluorouracil
Fonofos
Formaldehyde
Formaldehyde cyanohydnn
Formetanate hydrochloride
Formic acid
Formothion
Formparanate
Fosthietan
Fuberidazole
Fulminic acid, mercury(Il)salt
Fumaric acid
Furan
Furan, tetrahydro-
2-Furancarboxaldehyde
2,5-Furandione
Gallium trichloride
D-Glucopyranose, 2-deoxy-2-(3-methyl-3-nitrosoureido
Glycidylaldehyde
Glycol Ethers
Guanidine, N-nitroso-N-methyl-N'-nitro-
Haloethers
Halomethanes
Heptachlor
Heptachlor and Metabolites
Heptachlor epoxide
Hexachloro-l,3-butadiene
Hexachlorocyclopentadiene
-------
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Page 7
CAS Number
Chemical Name
CAS Number Chemical Name
1335-87-1 Hexachloronaphthalene 56189-09-4
70-30-4 Hexachlorophene 1335-32-6
1888-71-7 Hexachloropropene 7446-14-2
757-58-4 Hexaethyl tetraphosphate 15739-80-7
4835-11-4 Hexamethylenediamine, N,N'-dibutyl- 1314-87-0
680-31-9 Hexamethylphosphoramide 592-87-0
302-01-2 Hydrazine 21609-90-5
10034-93-2 Hydrazine sulfate 541-25-3
7647-01-0 Hydrochloric acid (Hydrogen chloride (gas only))*** 58-89-9
74-90-8 Hydrocyanic acid 14307-35-8
7664-39-3 Hydrogen fluoride 7580-67-8
7722-84-1 Hydrogen peroxide (Cone > 52%) 121-75-5
7783-07-5 Hydrogen selenide 110-16-7
7783-06-4 Hydrogen sulfide 109-77-3
123-31-9 Hydroquinone 12427-38-2
193-39-5 Indeno(l,2,3-cd)pyrene 7439-96-5
13463-40-6 Iron, pentacarbonyl- - -0
297-78-9 Isobenzan 12108-13-3
78-83-1 Isobutyl alcohol 51-75-2
78-84-2 Isobutyraldehyde 108-78-1
78-82-0 Isobutyronitrile 950-10-7
102-36-3 Isocyanic acid, 3,4-dichlorophenyl ester 1600-27-7
465-73-6 Isodrin 7487-94-7
55-91-4 Isofluorphate 592-04-1
78-59-1 Isophorone 10045-94-0
4098-71-9 Isophorone dnsocyanate 21908-53-2
78-79-5 Isoprene 7783-35-9
42504-46-1 Isopropanolamine dodecylbenzene sulfonate 592-85-8
67-63-0 Isopropyl alcohol (mfg.-strong acid processes) 7782-86-7
108-23-6 Isopropyl chloroformate 10415-75-5
625-55-8 Isopropyl formate 7439-97-6
80-05-7 4,4'-Isopropylidenediphenol - -0
119-38-0 Isopropylmethylpyrazolyl dimethyIcarbamate 10476-95-6
143-50-0 Kepone 760-93-0
78-97-7 Lactonitrile 126-98-7
303-34-4 Lasiocarpine 920-46-7
7439-92-1 Lead 30674-80-7
- -0 Lead and Compounds 10265-92-6
7645-25-2 Lead arsenate 74-87-3
7784-40-9 Lead arsenate 74-95-3
10102-48-4 Lead arsenate 75-09-2
7758-95-4 Lead chloride 74-88-4
13814-96-5 Lead fluoborate 75-69-4
7783-46-2 Lead fluoride 558-25-8
10101-63-0 Lead iodide 67-56-1
10099-74-8 Lead nitrate 91-80-5
7446-27-7 Lead phosphate 950-37-8
1072-35-1 Lead stearate 2032-65-7
7428-48-0 Lead stearate 16752-77-5
52652-59-2 Lead stearate 109-86-4
Lead stearate
Lead subacetate
Lead sulfate
Lead sulfate
Lead sulfide
Lead thiocyanate
Leptophos
Lewisite
Lindane
Lithium chromate
Lithium hydride
Malathion
Maleic acid
Malononitri le
Maneb
Manganese and compounds
Manganese Compounds
Manganese, tricarbonyl methylcyclopentadienyl
Mechlorethamine
Melamine
Mephosfolan
Mercuric acetate
Mercuric chloride
Mercuric cyanide
Mercuric nitrate
Mercuric oxide
Mercuric sulfate
Mercuric thiocyanate
Mercurous nitrate
Mercurous nitrate
Mercury
Mercury and Compounds
Methacrolein diacetate
Methacrylic anhydride
Methacrylonitrile
Methacryloyl chloride
Methacryloyloxyethyl isocyanate
Methamidophos
Methane, chloro
Methane, dibromo-
Methane, dichloro-
Methane, iodo-
Methane, trichlorofluoro-
Methanesulfonyl fluoride
Methane 1
Methapyrilene
Methidathion
Methiocarb
Methomy!
2-Methoxyethanol
-------
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Page 8
CAS Number Chemical Name CAS Number Chemical Name
=:===:=======:================================================== ========================================================
151-38-2 Methoxyethylmercunc acetate
96-33-3 Methyl acrylate
74-83-9 Methyl bromide
1634-04-4 Methyl tert-butyl ether
8Q-63-7 Methyl 2-chloroacrylate
71-55-6 Methyl chloroform
79-22-1 Methyl chloroformate (Methylchlorocarbonate)
624-92-0 Methyl disulfide
108-10-1 Methyl isobutyl ketone
624-83-9 Methyl isocyanate
556-61-6 Methyl isothiocyanate
74-93-1 Methyl mercaptan
80-62-6 Methyl raethacrylate
3735-23-7 Methyl phenkapton
676-97-1 Methyl phosphomc dichloride
556-64-9 Methyl thiocyanate
78-94-4 Methyl vinyl ketone
504-60-9 1-Methylbutadiene
101-61-1 4,4'-Methylene bis(N,N-dimethyl) benzenamine
101-68-8 Methylene bis(phenylisocyanate) (MBI)
101-77-9 4,4'-Methylene dianiline
60-34-4 Methylhydrazine
502-39-6 Methylmercuric dicyanamide
56-04-2 Methylthiouracil
75-79-6 Methyltrichlorosilane
1129-41-5 Metolcarb
7786-34-7 Mevinphos
315-18-4 Mexacarbate
90-94-8 Michler's ketone
50-07-7 Mitomycin C
1313-27-5 Molybdenum trioxide
6923-22-4 Monocrotophos
75-04-7 Monoethylamine
74-89-5 Monomethylamine
2763-96-4 Muscimol
505-60-2 Mustard gas
1615-80-1 N.N'-Diethylhydrazine
121-69-7 N,N-Dimethylaniline
86-30-6 N-Nitrosodiphenylamine
59-89-2 N-Nitrosomorpholine
16543-55-8 N-Nitrosonornicotine
100-75-4 N-Nitrosopiperldine
930-55-2 N-Nitrosopyrrolidine
300-76-5 Naled
91-20-3 Naphthalene
130-15-4 1,4-Naphthalenedione
1338-24-5 Naphthenic acid
134-32-7 1-Naphthylamine
91-59-8 2-Naphthylamine
7440-02-0 Nickel
15699-18-0 Nickel ammonium sulfate
- -0 Nickel and Compounds
13463-39-3 Nickel carbonyl
7718-54-9 Nickel chloride
37211-05-5 Nickel chloride
557-19-7 Nickel cyanide
12054-48-7 Nickel hydroxide
14216-75-2 Nickel nitrate
7786-81-4 Nickel sulfate
54-11-5 Nicotine
65-30-5 Nicotine sulfate
7697-37-2 Nitric acid
10102-43-9 Nitric oxide
139-13-9 Nitrilotriacetic acid
99-59-2 5-Nitro-o-anisidine
98-95-3 Nitrobenzene
92-93-3 4-Nitrobiphenyl
1122-60-7 Nitrocyclohexane
1836-75-5 Nitrofen
10102-44-0 Nitrogen dioxide
10544-72-6 Nitrogen dioxide
55-63-0 Nitroglycerine
25154-55-6 Nitrophenol (mixed)
554-84-7 m-Nitrophenol
88-75-5 o-Nitrophenol
100-02-7 p-Nitrophenol
- -0 Nitrophenols
79-46-9 2-Nitropropane
- -0 Nitrosamines
62-75-9 Nitrosodimethylamine
156-10-5 p-Nitrosodiphenylamine
1321-12-6 Nitrotoluene
99-08-1 m-Nitrotoluene
88-72-2 o-Nitrotoluene
99-99-0 p-Nitrotoluene
991-42-4 Norbormide
3288-58-2 0,0-Diethyl S-methyl dithiophosphate
2234-13-1 Octachloronaphthalene
- -0 Organorhodium Complex
20816-12-0 Osmium tetroxide
630-60-4 Ouabain
23135-22-0 Oxamyl
1120-71-4 1,2-Oxathiolane, 2,2-dioxide
78-71-7 Oxetane, 3,3-bis(chloromethyl)-
2497-07-6 Oxydisulfoton
10028-15-6 Ozone
30525-89-4 ParaformaIdehyde
123-63-7 ParaIdehyde
1910-42-5 Paraquat
2074-50-2 Paraquat methosulfate
-------
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Page 9
CAS Number
Chemical Name CAS Number Chemical Name
56-38-2 Parathion
298-00-0 Parathion-methyl
12002-03-8 Pans green (Cupric acetoarsenite)
19624-22-7 Pentaborane
76-01-7 Pentachloroethane
87-86-5 Pentachlorophenol
2570-26-5 Pentadecylamine
79-21-0 Peracetic acid
594-42-3 Perch loromethylmercaptan
85-01-8 Phenanthrene
108-95-2 Phenol
64-00-6 Phenol, 3-(l-methylethyl)-, methyIcarbamate
58-90-2 Phenol, 2,3,4,6-tetrachloro-
4418-66-0 Phenol, 2,2'-thiobis[4-chloro-6-methyl-
97-18-7 Phenol, 2,2'-thiobis(4,6-dichloro-
88-06-2 Phenol, 2,4,6-trichloro
95-95-4 Phenol, 2,4,5-trichloro-
58-36-6 Phenoxarsine, 10,10'-oxydi-
696-28-6 Phenyl dichloroarslne
106-50-3 p-Phenylenedlamine
59-88-1 Phenylhydrazine hydrochloride
62-38-4 Phenylmercury acetate
90-43-7 2-Phenylphenol
2097-19-0 Phenylsilatrane
103-85-5 Phenylthiourea
298-02-2 Phorate
4104-14-7 Phosacetira
947-02-4 Phosfolan
75-44-5 Phosgene
732-11-6 Phosmet
13171-21-6 Phosphamidon
7803-51-2 Phosphine
2703-13-1 Phosphonothioic acid, methyl-, 0-ethyl 0-(4-(methylt
2665-30-7 Phosphonothioic acid, methyl-, 0-(4-nitrophenyl) 0-p
50782-69-9 Phosphonothioic acid, methyl-, S-(2-(bis(l-methyleth
7664-38-2 Phosphoric acid
3254-63-5 Phosphoric acid, dimethyl 4-(methylthio) phenyl este
2587-90-8 Phosphorothioic acid, 0,0-dimethyl-S-(2-methylthio)e
7723-14-0 Phosphorus
10025-87-3 Phosphorus oxychloride
10026-13-8 Phosphorus pentachloride
1314-80-3 Phosphorus pentasulfide
1314-56-3 Phosphorus pentoxide
7719-12-2 Phosphorus trichloride
- -0 Phthalate Esters
57-47-6 Physostigmine
57-64-7 Physostigmine, salicylate (1:1)
109-06-8 2-Picoline
88-89-1 Picric acid
124-87-8 Picrotoxin
110-89-4 Piperidine
5281-13-0 Piprotal
23505-41-1 Pirimifos-ethyl
- -0 Polybrommated Biphenyls (PBBs)
1336-36-3 Polychlorinated biphenyls (PCBs)
- -0 Polynuclear Aromatic Hydrocarbons
7784-41-0 Potassium arsenate
10124-50-2 Potassium arsenite
7778-50-9 Potassium bichromate
7789-00-6 Potassium chromate
151-50-8 Potassium cyanide
1310-58-3 Potassium hydroxide
7722-64-7 Potassium permanganate
506-61-6 Potassium silver cyanide
2631-37-0 Promecarb
107-10-8 1-Propanamine
126-72-7 1-Propanol, 2,3-dibromo-, phosphate (3:1)
2312-35-8 Propargite
107-19-7 Propargyl alcohol
106-96-7 Propargyl bromide
57-57-8 Propiolactone, beta-
123-38-6 Propionaldehyde
79-09-4 Propionic acid
93-72-1 Propionic acid, 2-(2,4,5-trichlorophenoxy)-
123-62-6 Propionic anhydride
107-12-0 Propionitrile
542-76-7 Propionitrile, 3-chloro-
70-69-9 Propiophenone, 4'-amino-
114-26-1 Propoxur
109-61-5 Propyl chloroformate
115-07-1 Propylene (Propene)
75-56-9 Propylene oxide
75-55-8 Propyleneimine
2275-18-5 Prothoate
95-63-6 Pseudocumene
129-00-0 Pyrene
121-21-1 Pyrethrins
121-29-9 Pyrethrins
8003-34-7 Pyrethrins
110-86-1 Pyridine
504-24-5 Pyridine, 4-amino-
140-76-1 Pyridine, 2-methyl-5-vinyl-
1124-33-0 Pyridine, 4-nitro-, 1-oxide
53558-25-1 Pyriminil
91-22-5 Quinoline
- -0 RadionucTides
50-55-5 Reserpine
14167-18-1 Salcomine
107-44-8 Sarin
7782-49-2 Selenium
-------
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Page 10
CAS Number
Chemical Name
CAS Number
Chemical Name
- -0 Selenium and Compounds
7446-08-4 Selenium dioxide
7488-56-4 Selenium disulfide
7791-23-3 Selenium oxychlonde
7783-00-8 Selenous acid
563-41-7 Semicarbazide hydrochloride
3037-72-7 Silane, (4-aminobutyl)diethoxymethyl-
7440-22-4 Silver
- -0 Silver and Compounds
506-64-9 Silver cyanide
7761-88-8 Silver nitrate
7440-23-5 Sodium
7631-89-2 Sodium arsenate
7784-46-5 Sodium arsenite
26628-22-8 Sodium azide (Na(N3)J
10588-01-9 Sodium bichromate
1333-83-1 Sodium bifluoride
7631-90-5 Sodium bisulfite
124-65-2 Sodium cacodylate
7775-11-3 Sodium chromate
143-33-9 Sodium cyanide (Na(CH))
25155-30-0 Sodium dodecylbenzene sulfonate
7681-49-4 Sodium fluoride
62-74-8 Sodium fluoroacetate
16721-80-5 Sodium hydrosulfide
1310-73-2 Sodium hydroxide
7681-52-9 Sodium hypochlorite
10022-70-5 Sodium hypochlorite
124-41-4 Sodium methylate
7632-00-0 Sodium nitrite
131-52-2 Sodium pentachlorophenate
7558-79-4 S -dium phosphate, dibasic
10039-32-4 Sodium phosphate, dibasic
10140-65-5 Sodium phosphate, dibasic
7601-54-9 Sodium phosphate, tribasic
7758-29-4 Sodium phosphate, tribasic
7785-84-4 Sodium phosphate, tribasic
10101-89-0 Sodium phosphate, tribasic
10124-56-8 Sodium phosphate, tribasic
10361-89-4 Sodium phosphate, tribasic
13410-01-0 Sodium selenate
7782-82-3 Sodium selenite
10102-18-8 Sodium selenite
7757-82-6 Sodium sulfate (solution)
10102-20-2 Sodium tellurite
900-95-8 Stannane, acetoxytriphenyl-
7789-06-2 Strontium chromate
57-24-9 Strychnine
60-41-3 Strychnine, sulfate
100-42-5 Styrene
96-09-3
3689-24-5
3569-57-1
7446-09-5
12771-08-3
7783-60-0
7446-11-9
7664-93-9
8014-95-7
93-76-5
1319-72-8
2008-46-0
3813-14-7
6369-96-6
6369-97-7
93-79-8
1928-47-8
2545-59-7
25168-15-4
61792-07-2
13560-99-1
32534-95-5
77-81-6
13494-80-9
7783-80-4
107-49-3
13071-79-9
100-21-0
1746-01-6
961-11-5
78-00-2
597-64-8
75-74-1
509-14-8
1314-32-5
7440-28-0
- -0
10102-45-1
12039-52-0
10031-59-1
6533-73-9
7791-12-0
2757-18-8
7446-18-6
2231-57-4
139-65-1
39196-18-4
297-97-2
108-98-5
79-19-6
Styi
Sul1
Suli
Suli
Suli
Suli
Suli
Suli
Sull
2,4
2.4
2,4
2,4
2,4
2,4
2,4
2,4
2,4
2,4
2,4
2,4
2,4
Tabi
Tel
Tel
Tepi
Terl
Ten
2,3
Teti
Teti
Teti
Tef
Tet'
Tha
Tha
Tha
Tha
Tha
Tha
Tha
Tha
Tha
Tha
Thii
4,4
Thii
Thii
Thii
Thii
Styrene oxide
Sulfotep
Sulfoxide, 3-chloropropyl octyl
Sulfur dioxide
Sulfur monochloride
Sulfur tetrafluoride
Sulfur trioxide
Sulfuric acid
Sulfuric acid (fuming)
5-T
5-T amines
5-T amines
5-T amines
5-T amines
5-T amines
5-T esters
5-T esters
5-T esters
5-T esters
5-T esters
5-T salts
5-TP acid esters
n
urium
Tellurium hexafluoride
Tepp
Terbufos
Terephthalic acid
2.3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD)
Tetrachlorvinphos
Tetraethyllead
Tetraethyltin
Tetramethyllead
Tetranitromethane
Thai lie oxide
Tha11i urn
Thallium and Compounds
Thallium(I) nitrate
Thallium(I) selenide
Thallium sulfate
Thallous carbonate
Thallous chloride
Thallous malonate
Thallous sulfate
Thiocarbazide
4,4'-Thiodianiline
Thiofanox
Thionazin
Thiophenol
Thiosemicarbazide
-------
Page 11
CAS Number
ALPHABETICAL LISTING OF CHEMICAL NAME AND CAS NUMBER
Chemical Name
CAS Number Chemical Name
5344-83-1 Thiourea, (2-chlorophenyl)-
614-78-8 Thiourea, (2-methylphenyl)-
1314-20-1 Thorium dioxide
7550-45-0 Titanium tetrachloride
584-84-9 Toluene 2,4-diisocyanate
91-08-7 Toluene 2.6-diisocyanate
95-53-4 o-Toluidine
8001-35-2 Toxaphene (Camphechlor)
1031-47-6 Triamiphos
68-76-8 Triaziquone
24017-47-8 Triazofos
76-02-8 Trichloroacetyl chloride
120-82-1 1,2,4-Trichlorobenzene
1558-25-4 Trichloro(chloromethyl)silane
27137-85-5 Trichloro(dichlorophenyl)silane
79-01-6 Trichloroethylene
115-21-9 Trichloroethylsilane
327-98-0 Trichloronate
25167-82-2 Trichlorophenol
15950-66-0 2,3,4-Tnchlorophenol
933-78-8 2,3,5-Trichlcrophenol
933-75-5 2,3,6-Tnchlorophenol
609-19-8 3,4,5-Tnchlorophenol
98-13-5 Trichlorophenylsilane
52-68-6 Trichlorophon
27323-41-7 Triethanoiamine dodecylbenzene sulfonate
998-30-1 Triethoxysilane
121-44-8 Triethylamine
1582-09-8 Trifluralin
75-50-3 Trimethylamine
75-77-4 Trimethylchlorosilane
824-11-3 Trimethylolpropane phosphite
1066-45-1 Trimethyltin chloride
639-58-7 Triphenyltin chloride
555-77-1 Tris(2-chloroethyl)araine
72-57-1 Trypan blue
66-75-1 Uracil, 5-[bis(2-chloroethyl)amino]-
541-09-3 Uranyl acetate
10102-06-4 Uranyl nitrate
36478-76-9 Uranyl nitrate
2001-95-8 Valinomycin
7440-62-2 Vanadium (fume or dust)
1314-62-1 Vanadium pentoxide
27774-13-6 Vanadyl sulfate
108-05-4 Vinyl acetate monomer
593-60-2 Vinyl bromide
75-01-4 Vinyl chloride (monomer)
81-81-2 Warfarin
129-06-6 Warfarin sodium
1300-71-6 Xylenol
87-62-7 2,6-Xylidine
28347-13-9 Xylylene dichloride
7440-66-6 Zinc
87-62-7 2,6-Xylidine
28347-13-9 Xylylene dichloride
7440-66-6 Zinc
557-34-6 Zinc acetate
14639-97-5 Zinc ammonium chloride
14639-98-6 Zinc ammonium chloride
52628-25-8 Zinc ammonium chloride
- -0 Zinc and Compounds
1332-07-6 Zinc borate
7699-45-8 Zinc bromide
3486-35-9 Zinc carbonate
7646-85-7 Zinc chloride
557-21-1 Zinc cyanide
7783-49-5 Zinc fluoride
557-41-5 Zinc formate
7779-86-4 Zinc hydrosulfite
7779-88-6 Zinc nitrate
127-82-2 Zinc phenolsulfonate
1314-84-7 Zinc phosphide
16871-71-9 Zinc silicofluoride
7733-02-0 Zinc sulfate
58270-08-9 Zinc, dichloro(4,4-dimethyl-5((((methylamino) carbon
12122-67-7 Zineb
13746-89-9 Zirconium nitrate
16923-95-8 Zirconium potassium fluoride
14644-61-2 Zirconium sulfate
10026-11-6 Zirconium tetrachloride
-------
KEY TO SYMBOLS IN THE CONSOLIDATED CHEMICAL LIST
# Indicates that an adjusted RQ has been proposed but a final adjustment
has not been made; until then the statutory RQ applies. See 52 Federal
Register 8140 (March 16, 1987) and 53 Federal Register 4890 (April 11,
1988).
## EPA may adjust the RQ for methyl isocyanate in a future rulemaking; until
then the statutory 1-pound RQ applies. See 53 Federal Register 6765
(March 2, 1988).
EPA has proposed to adjust the RQ for radionuclides by establishing RQs
in units of curies; until then the statutory 1-pound RQ applies. See 52
Federal Register 8172 (March 16, 1987).
The trademark name "Kelthane" has been proposed to be changed to the
generic name "dicofol" in Table 302.4 of 40 CFR Part 302, Table 116.4 of
40 CFR 116, and Table 117.3 of 40 CFR Part 117. See 53 Federal Register
6762 (March 2, 1988).
** Indicates that no RQ is assigned to this generic or broad class, although
the class is a CERCLA hazardous substance. See 50 Federal Register 13456
(April 4, 1985).
*** xhe chemical name associated with this CAS registry number is listed as
"hydrochloric acid" under the CERCLA hazardous substances and the Section
313 toxic chemicals and as "hydrogen chloride (gas only)" under the
Section 302(a) extremely hazardous substances.
1' Ammonium thiosulfate was designated as a hazardous substance under CERCLA
because of its listing under Section 311 of the Clean Water Act (CWA).
EPA has proposed to delist ammonium thiosulfate under CWA Section 311 and
CERCLA Section 102(a). Therefore, EPA has also proposed to remove
ammonium thiosulfate from the lists of hazardous substances in 40 CFR
116.4, 117.3, and 302.4. See 53 Federal Register 6768-69 (March 2,
1988).
Warfarin is also listed under RCRA in U248. See 53 Federal Register
13384, 13387 (April 22, 1988).
Zinc Phosphide is also listed under RCRA in U249. See 53 Federal
Register 13384, 13387 (April 22, 1988).
-------
United States
Environmental Protection
Agency
Office of Toxic
Substances
Washington, D.C. 20460
Revised January 1989
EPA 560/7-88-003
oEPA
Toxic Chemical Release Inventory
Magnetic Media Submission
Instructions
Section 313
of the Emergency Planning and
Cpmmunity Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthonzation Act of 1986)
-------
MAGNETIC MEDIA REPORT SPECIFICATIONS FOR THE
TOXIC RELEASE INVENTORY SYSTEM (TRIS)
This document provides basic specifications for the use of magnetic media
to submit EPA Form R reports required by Section 313 of the Emergency Planning
and Community Right-to-Know Act (Title III of the Superfund Amendments and
Reauthorization Act of 1986), Public Law 99-499. The specifications and
requirements presented in this document supplement the reporting requirements
presented in the Section 313 final rule (40 CFR Part 372) . Submission of
magnetic media reports does not relieve the submitter from any of the
regulatory requirements of the Section 313 final rule.
A complete Form R report contains information on the release of one toxic
chemical or chemical category listed in the Section 313 final rule. For the
1988 and subsequent reporting years, there is no maximum or minimum number of
reports that may be submitted on magnetic media for each reporting facility.
While the rule provides for submission of information on chemicals whose
identity may be claimed trade secret, you may not use magnetic media for
submissions in which chemical identity is claimed trade secret. In addition,
the reporting of corrections to previously reported 313 data may not be made
through magnetic media. For detailed instructions concerning reporting
requirements, calculation of thresholds and releases, and assembly of required
data, please see the Toxic Chemical Release Inventory Reporting Form R and
Instructions, document number EPA 560/4-88-005, revised January 1989
(available from EPA). The instruction document is also contained in the Toxic
Chemical Release Inventory Reporting Package, document number EPA 560/4-89-
001. For more information on Section 313 contact the Emergency Planning and
Community Right-to-Know Information Hotline, U.S. EPA, at (800) 535-0202 or,
in Washington D.C, and Alaska, (202) 479-2499.
States are not required to accept reports submitted on magnetic media.
Reporting of 313 information to state agencies on magnetic media must be
discussed with, and authorized by, the state involved. For more information
consult the appropriate state contact listed in Appendix B of the Toxic
Chemical Release Inventory Reporting Form R and Instructions.
Note that these instructions do not apply to the Title III. reporting
requirements under Sections 311 and 312.
1. CONTENT OF MAGNETIC MEDIA REPORTS - GENERAL SPECIFICATIONS
Reports may be made to EPA using either 9 track magnetic tape or
microcomputer diskettes formatted in DOS 2.1 or higher from an IBM PC/XT/AT or
compatible microcomputer. File format specifications are substantially
different for these two types of media. Data structures and magnetic media
must conform to the formats specified in Part 3 of this document.
EPA will make every effort to process the magnetic media received. If the
media cannot be read, the tapes or diskettes will be returned to the
submitter, who will be held responsible for providing readable media within 30
-------
-2-
days. A facility that has not provided readable media before the July 1
deadline will be considered in non-compliance status until EPA receives either
readable media or complete Form R reports. EPA strongly encourages facilities
to read the information that is contained on the tapes or diskettes before
they are submitted to assure data accessibility and avoid non-compliance.
Non-readable media will be returned via the required return packaging and pre-
paid postage provided by the submitter. All readable media received will
become the property of EPA.
Any number of multiple reports from a single facility or reports from
multiple facilities may be included on a single tape or diskette. However,
individual reports for a facility should be completely contained on a single
tape. Diskette files should be completely contained on a single diskette.
Reporting on magnetic media does not affect the requirement to maintain a
record of all information used to complete the reports. This information must
be maintained in a form available for review by EPA or state officials for a
period of three years from the date of submission.
Several independent software firms are marketing computer systems to
assist facilities in meeting their reporting requirements under Section 313.
Some software products will be designed to produce reports on magnetic media
in the format specified in this document. The Bureau of National Affairs
(BNA) Right-to-Know Planning Guide includes a listing of companies that offer
Title III software. For information on obtaining a copy of this document
contact the BNA Customer Response Center at 1-800-372-1033, or from the
Washington D.C. metropolitan area call (202) 258-1033.
EPA1 s Office of Toxic Substances, Information Management Division will
validate magnetic media formats produced by software packages upon the request
of the vendors. Facilities should be cautious and select a software package
that will produce a valid format.
Exhibit 1 on the following page is a checklist for submission of magnetic
media reports.
-------
-3-
==Exhibit 1. MAGNETIC MEDIA PACKAGE CHECKLIST FOR SUBMITTING MEDIA TO EPA==
A magnetic media package is complete only after you perform the following
steps. Use this checklist as an aid to preparing your magnetic media package.
'—' 1. Prepare a cover letter which includes all the required information as
well as an original signature for each facility reporting on the
magnetic media. (See Part 2.1 of this document.)
'—' 2. Prepare an additional cover page listing all facilities in the order in
which they appear on the magnetic media, if your package includes
reports from multiple facilities. (See Part 2.2 of this document.)
D
3. Verify that the data have been formatted and transferred to magnetic
media as specified in this document. (See Parts 3 and 4 of this
document.)
'—'4. Confirm there are no reports for a chemical whose identity is claimed as
a trade secret. No trade secret information may be submitted on
magnetic media.
'—' 5. Confirm that your reports contain all required information. (See the
Toxic Chemical Release Inventory Reporting Form R and Instructions,
available from EPA.)
6. Verify that all the reported information is correct to the best of your
knowledge.
D
D7.
D
D
Perform a data dump or otherwise access the data contained on the
magnetic media to confirm that the data is readable from the copy which
is to be sent to EPA.
8. Label the media properly. (See Part 5.1 of this document.)
'—' 9. Package the media safely and include return packaging and postage,
the cover letter(s), and cover page (if applicable) in the package
with the magnetic media. (See Part 5.2 of this document.) Return
packaging and postage allow EPA to return unreadable media.
10. Address the package to: U.S. Environmental Protection Agency
P.O. Box 70266
Washington, D.C. 20024-0266
Attn: Toxic Chemical Release Inventory
Magnetic Media Submission
-------
-4-
2. COVER LETTER AND CERTIFICATION
2.1 Single Facility Packages
Each facility that provides reports on magnetic media must enclose a cover
letter containing the following information:
1. Full name and address of the submitting facility;
2. Number of tapes or diskettes enclosed;
3. List of chemical (or chemical category) names and CAS numbers
covered by the report;
4. Name and phone number of a data processing contact person who is
available to provide clarification;
5. A statement that the information that you are submitting does not
contain any trade secret data.
6. Certification statement identical to the certification statement
from EPA Form R. (See example in Exhibit 1 of this document.) As
required by the regulation, this certification statement must be
signed by a senior management official, not the data processing
contact. The signed name must also be typed, followed by the
official title of the signee. The date on which the statement was
signed must also be on the letter.
7. Specification of the page number of the cover letter in the
following format: "Page 1 of N Pages."
The certification provided in the cover letter is the same certification
statement contained on reporting Form R. The certification will apply to all
reports provided by the company which are identified by chemical name in the
cover letter. The name of the owner/operator or senior management official
contained on the cover letter must match the name provided in the data field
for Section 2 of Part I of the form (Certification Name and Official Title) in
each of the reports contained on the magnetic media.
Exhibit 2 is a sample cover letter that includes each of the required
elements.
-------
-5-
-Exhibit 2. SAMPLE COVER LETTER ACCOMPANYING A MAGNETIC MEDIA PACKAGE=
Page 1 of 1 Pages.
Pirx-Lewis, Incorporated
Battery Products Division
10545 Cerillas Road
Albuquerque, N.M. 81103-0420
May 2, 1989
U.S. Environmental Protection Agency
P.O. Box 70266
Washington, D.C. 20024-0266
Attn: Toxic Chemical Release Inventory
Magnetic Media Submission
To Whom It May Concern:
Enclosed please find two (2) microcomputer diskettes (numbers 1 and 2) containing
toxic chemical release reporting information for Pirx-Lewis, Inc., Battery Products
Division, as required under section 313, Title III of the Superfund Amendments and
Reauthorization Act of 1986.
A total of two (2) reports are included from our facility, concerning the following
chemicals:
Report
Chemical Name Number CAS Number
Lead compounds 00001 N/A
Zinc 00002 7440-66-6
Our data processing contact is Jeffrey Mills, who can be reached at (505) 752-5369.
Mr. Mills is available should any questions or problems arise in your processing of
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.
Sincerely yours,
Stanley L. Pirx, III
Vice President
Battery Products Division
Pirx-Lewis, Incorporated
Enclosures
-------
-6-
2.2 Multiple Facility Packages
When multiple facilities provide reports on a single magnetic media, each
facility must prepare a separate cover letter containing each of the required
elements noted in Section 2.1 of this document. An additional cover page must
also be enclosed which lists the names of the facilities in the order in which
they appear on the media. Pages should be numbered sequentially starting with
the cover page and continuing through all of the cover letters.
A sample of a multiple facility cover page is included as Exhibit 3.
-Exhibit 3. SAMPLE COVER PAGE FOR MULTIPLE FACILITIES*
REPORTING IN A SINGLE MAGNETIC MEDIA PACKAGE
Page 1 of 3 Pages.
American Manufacturing, Inc.
Corporate Headquarters
2625 McDowell Road
Phoenix, AZ 85008
May 8, 1989
U.S. Environmental Protection Agency
P.O. Box 70266
Washington, D.C. 20024-0266
Attn: Toxic Chemical Release Inventory
Magnetic Media Submission
To Whom It May Concern:
Enclosed please find a total of two (2) 3.5 inch microcomputer diskettes containing
toxic chemical release reporting information required under section 313, Title III of
the Superfund Amendments and Reauthorization Act of 1986.
Please also find attached a total of two (2) cover letters, one for each of our
subsidiaries that is reporting. The letters include certification statements from each
of these facilities and the signatures of senior management officials responsible for
reporting. The report data is arranged on the two diskettes in the following order:
1. Pirx-Lewis Incorporated, Battery Products Division (2 reports)
2. Larson Plastics (1 report)
Our data processing contact is John Berg, who can be reached at (602) 258-1234.
Mr. Berg is available should any questions or problems arise in your processing of these
diskettes.
Sincerely,
Michael J. Noonan
Vice President, Operations
American Manufacturing, Inc.
Enclosures
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-7-
3. FORMAT OF MAGNETIC TAPE REPORTS
3.1 Technical Specifications and Structural Records
The following technical requirements apply for magnetic tape reports:
• Density and recording technique: 9-Track, 1600 BPI, odd parity.
• Logical record length (for all record types): 500 Bytes.
• Blocksize: 2000 Bytes.
• Record format: Fixed Blocked (FB).
• Character Type: 7 Bit ASCII.
• Label Type: No Label (NL) with no leading tape mark.
• File Name: TRIDATA.DAT.
As previously described in this document, a Form R report contains
information on releases of one chemical or chemical category. All reports for
all the facilities reporting on any one tape must be in a single data file
that is entirely contained on that tape. The data file must not span multiple
tapes.
The file itself is made up of records, some of which contain Form R
information (described in Part 3.2 of this document) and others which contain
information on the data (structural records). Each record has a fixed length
of 500 bytes, some of which are used by the current data fields and some
reserved for future use. All data are to exist as unquoted, fixed field ASCII
format, and should not include commas, control characters, or other
delimiters.
Structural records contain specific data on the number of records, reports,
and facilities contained on the tape. There are four types of structural
records required in tape reporting, as follows:
1. Header (type hh) is the first record of the data file TRIDATA.DAT.
2. Report start (type ss). which is located at beginning of each report.
3. Report end (type se). which is located at the end of each report.
4. Trailer (type tr) is the last record of the data file TRIDATA.DAT.
The field layout for these four record types is shown in Table 1. All four
record types are required for magnetic tapes, regardless of the number of
facilities reporting on the tape. All information on the tape should be in a
single file named TRIDATA.DAT.
-------
Table 1
STRUCTURAL RECORD SPECIFICATIONS FOR FORM R DATA REPORTS ON TAPE
Sequence
Byte
Position Tot
Number Field Name
Record Type
1
2
Record Type
1
2
Record Type
1
2
3
Record Type
1
2
HH (Header Record)
Record Type
BLANK
SS (Report Start)
Record Type
Report Number
SE (Report End)
Record Type
Report Number
Number of Records
TH (Trailer)
Record Type
Number of Submissions
Start
1
3
1
3
1
3
8
1
3
End
2
7
2
7
2
7
12
2
7
Len,
2
5
2
5
2
5
5
2
5
Char Enter hh
Char Leave blank
Char Enter se
Num Sequential report number, right justified
Char Enter ss
Num Sequential report number, right justified
Num Total number of type 01-14 records in report
Char Enter tr
Num Total number of submissions on tape
-------
-9-
3.2 Structure of Data Records for Tapes
Table 3 specifies the data structure of each of the data record types and
relates to the information requested in the individual sections and blanks of
EPA Form R. Each data element is contained in a data record of a predefined
record type (numbered 01 through 14). The record type is identified by the
first two byte positions of the record. The report number is a sequential
number assigned by the submitting facility to each report contained on the
magnetic media and is used to cross reference the records of a report. [Note:
Reports from multiple facilities on a single media must be numbered
sequentially and uniquely throughout the media. Therefore, no two reports on
the same tape will have the same report number, whether the reports originate
from the same or different facilities.]
The start byte, end byte, and total length of each data field has been
defined as shown in Table 3. Blank data fields will be represented by blank
bytes on the report media and should not be considered to be the same as data
fields filled by N/A, which is used to designate data not applicable to the
submitting facility. (See the Form R instructions for further clarification.)
Table 3 also provides information on data formats including the right or
left justification required for data and the pre-defined placement of decimal
points (e.g., a left justified 3 will be read as 300,000,000 in a 9 byte.
field; a right justified 4369 for percentage change will be read as 43.69
percent, while 43 will be read as 0.43 percent).
Exhibit 4 presents a sample data structure for a magnetic tape record
prepared by a facility which conforms to the data structure specified in Table
3. Exhibit 5 illustrates how the six structural records described in Part 3.1
of this document and the records which contain Form R data should be ordered
on the tape package.
-Exhibit 4. EXAMPLE DATA STRUCTURE FOR MAGNETIC TAPE REPORTS*
Bell Products is completing Record Type 10 for its first report. Bell has
two receiving streams for this report, and so will have two Type 10 records.
The following format is used for Bell's data:
Data Stream Explanation
lOOOOOlab nam 10000 Type 10 record for a release to water; 10 is
the record type; 00001 is the report number;
"a" is the alphabetical index assigned to the
receiving stream; "b" is the range code; "na"
is the estimate; "m" is the basis of estimate
code for monitoring data; 10000 corresponds to
a stormwater percentage of 100.00%
IQOOOOlbnaOOOOOOOOlSOo 05167 A second type 10 record, for a second receiving
stream (assigned index "b") which is estimated
to receive 150 pounds of the chemical with
stormwater percentage 51.67%.
-------
-10-
=Exhibit 5. EXAMPLE OF RECORD ORDER FOR TAPE REPORTS-
Gates Photographic Supply is reporting for two of its facilities on one
tape. Gates has two reports for its first facility and one report for its
second facility. All of this information should be contained in a single file
named "TRIDATA.DAT". Gates should structure its data stream as shown below:
Record Type Explanation .
hh Header record for tape.
ss Report start record for report 1 in facility 1; this report
is assigned report number 00001.
01 to 14 Record types 01 through 14 for report 1 go here. They
contain Form R data for the first report as defined in Table
3
se Report end record for report 1. This record contains a field
which indicates the number of Form R type records in the
first report. (The number can vary, depending on the number
of multiple records in the report; see above example)
ss Report start record for report 2 in facility 1; this report
is assigned report number 00002.
01 to 14 Record types 01 through 14 for report 2.
se Report end record for report 2. This record contains a field
which indicates the number of Form R type records in the
second report.
ss Report start record for the first report from facility 2.
Because this is the third report on the tape, it is assigned
report number 00003, to avoid its confusion with the first
report from facility 1.
01 to 14 Record types 01 through 14 for this report.
se Report end record for this report.
tr Trailer record for this tape. This record has a field which
indicates the total number of submissions from all facilities
on the tape.
-------
-11-
4. MICROCOMPUTER DISKETTE REPORTS
4.1 Technical Specifications and Special Files
Diskettes may be either 5.25 inch or 3.5 inch in size and either double
density or high density in data capacity. They must be formatted using DOS
2.1 or higher, on an IBM PC/XT/AT or compatible, as follows:
Size Double density High density
5.25" 360 Kbytes 1.2 Mbytes
3.5" 720 Kbytes 1.4 Mbytes
All diskettes contained in a single package must be of a single type and
format, and must be properly labeled with the format used.
For diskette submissions, records of different types must be contained in
separate files. These files are named with a combination of the letters "TRI"
and the record type (e.g., type 08 records will be in the file "TRIOS.").
Multiple records of the same type which are part of a single report, as well
as all records of the same type provided for all other reports in the package,
must be contained in a single file. Files containing records of a type should
be completely contained on a single floppy diskette which has been properly
labeled to identify the files it holds.
Two additional files must be created to contain information on the numbers
of records and reports provided in the diskette package. They are:
1. Report end records (type se). created for each report and placed in a
data file named "TRISE."
2. Trailer records (type tr). created to identify the total number of
submissions being provided by all facilities which are reporting on
the diskettes. These are placed in a data file named "TRITR."
The structure for these record types is shown in Table 2 on the following
page.
It is very important that each report have a unique report number used
throughout the records pertaining to that report. Report numbers may be
assigned in any order, so long as no two reports share the same number.
-------
-12-
Table 2
STRUCTURAL RECORD SPECIFICATIONS FOR FORM R DATA REPORTS OH DISKETTE
Byte
Sequence Position Total
Number Field Name Start End Length Type Format Notes
Record Type SE (Report End), contained in Diskette File TRISE.
1 Record Type 122 Char Enter se
2 Report Number 375 Num Sequential report number, right justified
3 Number of Records 8 12 5 Num Total number of type 01-14 records in report
Record Type TR (Trailer), contained in Diskette File TRITR.
1 Record Type 122 Char Enter tr
2 Number of Facilities 375 Num Total number of submissions on diskette package
-------
-13-
4.2 Structure of Form R Data Records for Diskettes
Each record has a fixed length of 500 bytes, some of which are used by the
current data fields, some reserved for future use, and some reserved for a
carriage return and line feed (positions 499 and 500 respectively). All data
are to exist as unquoted, fixed field ASCII format, and should not include
commas, control characters, or other delimiters.
Table 3 specifies the data structure of each of these records and relates
the data to the individual sections and blanks of EPA Form R. Each data
element is contained in a record of a predefined record type (numbered 01
through 14). The record type is identified by the first two byte positions of
the record. The report number is a sequential number assigned by the
submitting facility to each report contained on the magnetic media and is used
to cross reference the records of a report. Multiple entries of facility data
(e.g., SIC code, NPDES permit numbers) should be contained in multiple records
of the type that is appropriate for that data. For example, a facility with
two SIC codes would have two records of type 03. [Note: Reports from
multiple facilities on a single media must be numbered sequentially and
uniquely throughout the media. Therefore, no two reports on the same diskette
will have the same report number, whether the reports originate from the same
or different facilities.]
The start byte, end byte, and total length of each data field has been
defined as shown in Table 3. Blank data fields will be represented by blank
bytes on the report media and should not be considered to be the same as data
fields filled by N/A, which is used to designate data not applicable to the
submitting facility. (See the instructions for completing Form R for further
clarification.)
Table 3 also provides information on data formats including the right or
left justification required for data and the pre-defined placement of decimal
points (e.g., a left justified 3 will be read as 300,000,000 in a 9 byte
field; a right justified 4369 for percentage change will be read as 43.69
percent, while a right justified 43 will be read as 0.43 percent).
An example of how a company might prepare diskette files for Form R
reporting is contained in Exhibit 6.
-------
-14-
-Exhibit 6. EXAMPLE FILE AND DATA STRUCTURE FOR DISKETTE REPORTING-
American Manufacturing is preparing reports for two of its facilities and
submitting reports on diskettes. The facilities are assigned facility numbers
00001 and 00002. There are a total of three reports from the two facilities
combined. American assigns report numbers 00001 and 00002 to the two reports
from the first facility, and report number 00003 to the one report from the
second facility, so that each report will have a unique report number.
After consulting the Toxic Chemical Release Inventory Reporting Form R and
Instructions to assemble the information it needs, American can proceed to
Table 3 to determine how this information should be entered on the diskettes.
The first diskette contains files TRI03 and TRI07, both of which contain
Form R data, and files TRIFE and TRITR. Facility 1 has an SIC code of 3691,
and facility 2 has an SIC code of 4567. Table 3 of this document describes
the data structure of record type 03. The first two columns of this record
contain the record type, the next 5 columns contain the report number, and the
last four contain the facility SIC code. American must prepare three records
for this file, one record for each report it is completing, and store all
three in file TRI03. File TRI03 contains the following formatted data:
03000013691
03000023691
03000034567
To prepare file TRI07 American must determine how many receiving streams
each report names. The first report names two receiving streams, and the
other two reports name one receiving stream each; American must report a total
of four receiving streams. After determining the structure of record type 07
from Table 3 of this report, American stores the following information in file
TRI07 [Note: For report number 00001, with two receiving streams named, the
first, "tijeros arroyo", is assigned alphabetical stream code "a", and the
second, "rio grande", is assigned stream code "b". The other reports (00002
and 00003), assign stream code "a" to the only stream that they contain.]:
0700001atijeros arroyo
0700001brio grande
0700002ario grande
0700003asanta cruz river
After completing the other records for the reports, American finds a total
of 18 records for report 00001, 21 records for report 00002, and 14 records
for report 00003. [Note: The count of records includes record types 01 to 14
only. It does not include the number of records of types se or tr.] File
TRISE contains the following end of report records:
se0000100018
se0000200021
se0000300014
Record type tr contains the number of submissions in the diskette package,
therefore file TRITR contains the following formatted data:
tr00003
-------
-15-
TabLe 3
DATA RECORD STRUCTURAL SPECIFICATIONS FOR FORM R DATA
Reference to
Sequence Reporting Form R
Number Page Sect. Title/Topic
Byte
Position
Total
Start End Length Type Format Notes
Record Type 01
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
(Diskette file TRI01)
Record type
1.
1.
1.
2
2
2
3.
3.
3.
3
3.
3
3
3
3
3
3
3
3
3
3
3
3
4
4
1
2
3
1
.1
.1
.1
.1
.1
.1
.1
.2
.3
.3
.4
.4
.6
.6
.11
.11
.1
.2
Report number
Trade secret
Sanitized copy
Reporting year
Certification name
Certification title
Certification date
Facility name (1st part)
Facility name (2nd part)
Facility st. (1st part)
Facility st. (2nd part)
Facility city
Facility county
Facility state
Facility zip
Entire/part facility
Technical contact name
Technical contact phone
Public contact name
Public contact phone
Facility latitude
Facility longitude
1st UIC ident. number
2nd UIC ident. number
Parent company name
Parent company D&B num.
1
3
8
9
11
15
60
105
111
141
171
201
231
256
281
283
292
293
338
348
393
403
410
417
429
441
486
2
7
8
10
14
59
104
110
140
170
200
230
255
280
282
291
292
337
347
392
402
409
416
428
440
485
494
2
5
1
2
4
45
45
6
30
30
30
30
25
25
2
9
1
45
10
45
10
7
7
12
12
45
9
Char
Hum
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Enter 01
Sequential number
Enter Na
Enter NAa
Enter reporting year (e.g., 1988)
Left justified
Left justified
Date format MMDDYYb
Left justified0
Left justified0
Left justified0
Left justified0
Left justified
Left justified
Left justified
Left justified, no dashes
Enter A (entire) or B (part)
Left justified
Includes area code
Left justified
Includes area code
Format DDD^«SSe
Format DDDWSS8
Right justified with leading zeros
Right justified with leading zeros
Left justified
Right just., no dashes, leading zeros
a This is the only acceptable value for the field, because no trade secret data may be submitted on
magnetic media.
b e.g., March 17, 1989, would be entered as 031789.
c Two fields are provided to allow ample room to report this information.
d Do not include parentheses or dashes, e.g., (202) 555-1212 would be entered as 2025551212.
e.g., 91 degrees, 15 minutes, 5 seconds would be entered as "0911505". North latitude and west
longitude are assumed.
-------
-16-
TabLe 3: DAIA RECORD STRUCTURAL SPECIFICATIONS FOR FORM R DATA (Cont'd)
Sequence
Number
Reference to
Reporting Form R
Page
Record Type 02
1
2
3
A
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
-------
-17-
Table 3: DATA RECORD STRUCTURAL SPECIFICATIONS FDR FQBM R DATA (Conf d)
Reference to
Secruence Reporting Form R
Number
Record
1
2
3
Record
1
2
3
Record
1
2
3
Record
1
2
3
Record
1
2
3
4
Record
1
2
3
4
5
6
7
8
9
10
11
Page
Type 03
1
Type 0*
1
Type 05
1
Type 06
1
Type 07
1
1
Type 08
2
2
2
2
2
2
2
2
2
Sect.
Title/Topic
Byte
Position Toti
Start
End
Lenj
(Diskette file TRI03)
3.5
Record type
Report number
SIC code
1
3
8
2
7
11
2
5
4
(Diskette file TRI04)
3.7
(Disk)
3.8
Record type
Report number
D&B Number
3tte file TRIOS)
Record type
Report number
EPA ID Number
1
3
8
1
3
8
2
7
16
2
7
19
2
5
9
2
5
12
(Diskette file TRI06)
3.9
Record type
Report number
NPDES Permit Number
1
3
8
2
7
16
2
5
9
(Diskette file TRI07)
3.10
3.10
Record type
Report number
Receiving Stream Code
Receiving Stream Name
1
3
8
9
2
7
8
38
2
5
1
30
(Diskette file TRIOS)
1
1
1
1
1
1
1
1
1
Record type
Report number
POTW Code
POTW Name (1st part)
POTW Name (2nd part)
POTW Street Ust part)
POTW Street (2nd part)
POTW City
POTW County
POTW State
POTW Zip
1
3
8
9
39
69
99
129
154
179
181
2
7
8
38
68
98
128
153
178
180
189
2
5
1
30
30
30
30
25
25
2
9
Type Format Notes
Char Enter 03
Num Sequential number
Char SIC code
Char Enter 04
Num Sequential number
Char Right justify, use leading zeros, no dashes
Char Enter 05
Num Sequential number
Char Right justify, use leading zeros, no dashes
Char Enter 06
Num Sequential number
Char Right justify with leading zeros
Char Enter 07
Num Sequential number
Char Sequential alphabetic character3
Char Left justify
Char Enter 08
Num Sequential number
Char Sequential numeric character3
Char Left justify13
Char Left justify13
Char Left justify^
Char Left justify*3
Char Left justify
Char Left justify
Char Left justify
Char Left justify, no dashes
a Each distinct receiving stream must be assigned a distinct alphabetic code (a, b, c, etc.).
POTWs be assigned distinct numeric codes. The code must also be entered in the corresponding location in
Record Type 10 or 12 so release estimate data can be matched to the receiving location's descriptive
information.
Two fields are provided to allow ample room to report this information.
-------
-18-
Table 3: DATA RECCED STRUCTURAL SPECIFICATIOHS FOR FORM R DATA (Cont'd)
Reference to
Sequence Reporting Form R
Number Page Sect. Title/Topic
Byte
Position
Total
Start End Length Type Format Notes
Record Type 09 (Diskette file TRI09)
1
2
3
4
5
6
7
8
9
10
11
12
13
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Record type
Report number
Off Site Code
RCRA ID Number
Off Site Name (1st part)
Off Site Name (2nd part)
Off Site St. (1st part)
Off Site St. (2nd part)
Off Site City
Off Site County
Off Site State
Off Site Zip
Off Site Control Ind.
1
3
8
9
21
51
81
111
1^1
166
191
193
202
2
7
8
20
50
80
110
140
165
190
192
201
203
2
5
1
12
30
30
30
30
25
25
2
9
2
Char
Num
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Enter 09
Sequential number
Sequential numeric character3
Right justify with leading zeros
Left justify13
Left justifyb
Left justify13
Left justifyb
Left justify
Left justify
Left justify
Left justify
Enter Y, N, or NA
Record Type 10 (Diskette file TRI10)
1 Record type
2 Report number
3 3/55.3 Water: Stream code
4 3/5 5.3 Water: Range code
5 3/5 5.3 Water: Release estimate
6 3/55.3 Water: Basis of estimate
7 3/5 5.3 Water: Stormwater percent 24
1
3
8
9
11
22
24
2
7
8
10
21
23
28
2
5
1
2
11
2
5
Char Enter 10
Num Sequential number
Char Matches Record Type 07, alphabetic character0
Char Range code (A through C)d or NA
Char Right justify num. (no decimal places) or NA
Char Basis code (M, C, E, or 0) or NA
Char Right justify percent (no decimal point) or NAe
a Off-site transfer points must be assigned distinct numeric codes. The code must also be entered in
the corresponding location in Record Type 13.
Two fields are provided to allow ample room to report this information.
0 The code entered must be an alphabetical character code that matches the code used in Record Type 07
for the receiving stream. Each receiving stream should have a distinct Record Type 10.
d "A" should be entered for 0 pounds, "B" for 1-499 pounds, or "C" for 500-999 pounds.
e Enter percent without a decimal point (e.g., 23.45 percent would be entered as "02345").
-------
-19-
Table 3: DATA RECORD STRUCTURAL SPECIFICATIONS FCR FORM R DATA (Cont'd)
Reference to
Sequence Reporting Form R
Number
Record
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Record
1
2
3
4
5
6
Record
1
2
3
4
5
6
7
Page Sect.
Byte
Position
Title/Topic Start
Type 11 (Diskette file TRI11)
Record type
3/5 5.
3/5 5.
3/5 5.
3/5 5.
3/5 5.
3/5 5.
3/5 5.
3/5 5.
3/5 5.
3/5 5.
3/5 5.
3/5 5.
5
.5
5
5
5
5
5
5
5
.5
.5
.5
Report number
On-site landfill.: Range
On-site landfill:Release
On-site landfill: Basis
Land treat: Range code
Land treat: Release est.
Land treat: Basis of est
Surf. Imp: Range code
Surf. Imp: Release est.
Surf. Imp: Basis of est.
Other land: Range code
Other land: Release est.
Other land: Basis of est
1
3
8
10
21
23
25
36
38
40
51
53
55
66
End
2
7
9
20
22
24
35
37
39
50
52
54
65
67
Total
Length Type
2
5
2
11
2
2
11
2
2
11
2
2
11
2
Char
Num
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Char
Format
Enter
Notes
11
Sequential number
Range
Right
Basis
Range
Right
Basis
Range
Right
Basis
Range
Right
Basis
code (A
justify
code (M,
code (A
justify
code (M,
code (A
justify
code (M,
code (A
justify
code (M,
through C)a or NA
num. (no decimal places)
C, E, or 0) or NA
through C)a or NA
num. (no decimal places)
C, E, or 0) or NA
through C)a or NA
num. (no decimal places)
C, E, or 0) or NA
through C)a or NA
num. (no decimal places)
C, E, or 0) or NA
or NA
or NA
or NA
or NA
Type 12 (Diskette file TRI12)
4/5 6
4/5 6
4/5 6.
4/5 6
.1
.1
.1
.1
Record type
Report number
POTW Code
POTW Range code
POTW Release estimate
POTW Basis of estimate
1
3
8
9
11
22
2
7
8
10
21
23
2
5
1
2
11
2
Char
Num
Char
Char
Char
Char
Enter
12
Sequential number
Matches Record Type 08, numeric character"
Range
Right
Basis
code (A
justify
code (M,
through C)a or NA
num. (no decimal places)
C, E, or 0) or NA
or NA
Type 13 (Diskette file TRI13)
4/5 6
4/5 6
4/5 6
4/5 6
4/5 6
.2
.2
.2
.2
.2
Record type
Report number
Off site: Code
Off site: Range code
Off site: Release est.
Offsite: Basis of est.
Off site: Treatment type
1
3
8
9
11
22
24
2
7
8
10
21
23
26
2
5
1
2
11
2
3
Char
Num
Char
Char
Char
Char
Char
Enter
13
Sequential number
Matches Record Type 09, numeric character13
Range
Right
Basis
code (A
justify
code (M,
through C)a or NA
num. (no decimal places)
C, E, or 0) or NA
or NA
Offsite Treatment code
"A" should be entered for 0 pounds, "B" for 1-499 pounds, or "C" for 500-999 pounds.
The code entered must match the numeric code used in Record Type 08 for the corresponding POTW or
Record Type 09 for the corresponding off-site transfer point. Record Types 12 and 13 are designed to
contain data on the amounts of toxic chemical transferred to each distinct POTW or off-site location; the
numeric code facilitates cross-referencing with other records containing descriptive information.
-------
-20-
Table 3: DATA RECORD STRUCTURAL SPECIFICATIONS FOR FORM R DATA (Conf d)
Reference to
Sequence Reporting Form R
Number Page Sect. Title/Topic
Byte
Position
Total
Start End Length Type Format Notes
Record Type 1* (Diskette file TRI14)
4/5 7
4/5 7
4/5 7
4/5 7
4/5 7._e
4/5 7. f
Record type
Report number
WTME: Wastestream
WTME: Treatment
WTME: Influent cone. rng. 12
WTME: Seq. treatment
WTME: Efficiency est.
WTME: Based on data
1
3
8
9
L2
.4
.6
:i
2
7
e,
11
13
15
20
22
2
5
1
3
2
2
5
2
Char
Mum
Char
Char
Char
Char
Num
Char
Enter 14
Sequential number
Wastestream code
Treatment code
Range code (A through C)a or NA
Y, N, or NA
Right justify percent (no decimal point) or NAb
Y, N, or NA
"A" should be entered for 0 pounds, "B" for 1-499 pounds, or "C" for 500-999 pounds.
Enter percent without a decimal point (e.g., 23.45 percent would be entered as "02345").
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-21-
5. LABELING AND PACKAGING REQUIREMENTS
5.1 Labeling Requirements
A label must be attached to each tape reel (not tape band) and diskette
(not jacket) which conforms to the following format:
A. Name of the submitting facility (or for
multiple facility packages the name of
the company which prepared the reports).
B. Date the tape or diskette was created,
C. Floppy diskette format density. Use HD
for high density or DD for double
density. (Applicable only to
diskettes.)
D. Year for which the data are reported.
E. Number of this diskette or tape.
F. Total number of diskettes or tapes in
the package.
G. Name and phone number of a facility
computer contact person.
H. File name or names on the tape or
diskette.
Labels may be typed or legibly handwritten. Any media submitted without a
proper label attached will not be processed and will be returned to the
submitter. Exhibit 7 contains a sample diskette label.
TRIS Report
Date
Report
Contact
Files
(A)
(B)
Yr.
Density
Num.(E>
(G)
(C)
of
(H)
EXHIBIT 7
TRIS Report
Date
57,
, 5
Report Yr. 1
Contact
Files
Density
Num.
of
TR103 >
At left is a sample diskette label for
American Manufacturing, which has two double
density diskettes in its package. The
package contains information on two of
American's facilities, but the labels should
only list the parent company, American
Manufacturing, and the data processing
contact at American. Diskette 1 contains the
files TRI03, TRI07, TRIFE, and TRITR.
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-22-
5.2 Packaging and Shipping Requirements
The type of packaging and shipping used for magnetic media are left to the
discretion of the submitting facility. EPA accepts no responsibility for
packages lost or damaged during transit. It is recommended that the package
be marked with the words "Magnetic Media --Do Not X-Ray".
All magnetic media packages must include self-addressed, postage paid
return packaging sufficient to allow EPA to return unreadable media to the
facility.
Send complete magnetic media (properly labeled) along with a cover letter
(containing an original certification signature from each submitting company)
to:
U.S. Environmental Protection Agency
P.O. Box 70266
Washington, D.C. 20024-0266
Attn: Toxic Chemical Release Inventory
Magnetic Media Submission
Reports to the appropriate State agency must be made in accordance with
the instructions for completing Form R (see page 1 of this document). A State
contact list is provided in the instructions document. However, a State may
not have the capability to accept magnetic media as specified in this
document. In these cases, you must send copies of Form R to the State.
Alternatively, the State may have established a computer database but have
different specifications for submission of Section 313 data on magnetic media,
in which case you should contact the State representative listed in the
instructions document for details.
"5-U.S. GOVERNMENT PRINTING OFFICE: 1989 619-898
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