SECTION 313 EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW ACT
GUIDANCE FOR CHEMICAL DISTRIBUTION FACILITIES
(Version 1.0)
OCTOBER 7, 1997
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TRI FORM R GUIDANCE DOCUMENT . CHEMICAL DISTRIBUTORS
TABLE OF CONTENTS
SECTION 1
INTRODUCTION 1-1
SECTION 2
SECTION 313 REPORTING REQUIREMENTS 2-1
WHO MUST REPORT? 2-1
Reduced Reporting 2-2
What is a Facility? 2-2
How to Determine Your SIC Code 2-3
How to Determine Your Number of Employees 2-4
CHEMICAL ACTIVITY THRESHOLDS 2-4
Manufacture 2-4
Process 2-5
Otherwise use 2-6
EXEMPTIONS 2-9
SUPPLIER NOTIFICATION REQUIREMENTS 2-13
LISTED SECTION 313 CHEMICALS 2-14
WHAT MUST BE REPORTED? 2-16
DOCUMENTING REPORTING EFFORTS 2-17
SECTION 3
MAKING THE THRESHOLD DETERMINATION 3-1
CONDUCTING THE THRESHOLD DETERMINATION 3-3
SECTION 4
OVERVIEW OF SECTION 313 RELEASE ESTIMATION 4-1
GENERAL CONCEPTS 4-1
Release Estimation 4-1
Reasonable Estimates: Significant Figures and Use of Range Codes 4-4
"NA" versus "0" 4-5
REPORTING RELEASES IN FORM R, PART II 4-5
Fugitive or Non-Point Emissions 4-6
Stack or Point-Source Air Emissions 4-8
Wastewater Discharges 4-9
Underground Injection On-Site 4-10
Release to Land On-Site 4-11
Transfers in Wastes to Other Off-site Locations 4-12
On-site Waste Treatment Methods and Efficiency 4-12
On-site Energy Recovery Processes 4-13
On-site Recycling Processes 4-14
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
Source Reduction and Recycling Activities 4-14
Quantity Released 4-14
Quantity Used for Energy Recovery On-site 4-14
Quantity Used for Energy Recovery Off-site 4-15
Quantity Recycled On-site 4-15
Quantity Recycled Off-site 4-15
Quantity Treated On-site 4-15
Quantity Treated Off-site 4-16
Quantity Released to the Environment as a Result of Remedial Actions,
Catastrophic Events, or One-time Events Not Associated
with Production Processes 4-16
SECTION 5 5-1
CALCULATING RELEASE ESTIMATIONS AT CHEMICAL AND ALLIED
PRODUCTS - WHOLESALE, NOT ELSEWHERE CLASSIFIED 5-1
Warehousing and Storage Activities 5-2
Transfer and Formulation 5-3
Plant Maintenance and Support Activities 5-5
APPENDIX A A-l
ALPHABETICAL LISTING OF SECTION 313 CHEMICALS A-l
APPENDIX B . '. B-l
BIBLIOGRAPHY B-l
APPENDIX C C-l
SECTION 313 RELATED MATERIALS AND ELECTRONIC ACCESS TO
INFORMATION C-l
LIST OF TABLES
Table 1-1. Summary of Reporting Requirements Under EPCRA 1-4
Table 3-1. Examples of Manufactured, Processed, and Otherwise Used Chemicals at Chemical
Distribution Facilities 3-1
Table 4-1. SOCMI Average Emission Factors 4-7
LIST OF FIGURES
Figure 5-1. Chemical Distributor Operations and Potential Releases 5-1
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
SECTION 1
INTRODUCTION
This guidance document has been prepared to assist chemical distributor facilities in complying
with the reporting requirements of Section 313 of the Emergency Planning and Community Right-
to-Know Act (EPCRA, Public Law 99-499, Title III of the Superfund Amendments and
Reauthorization Act of 1986, hereafter EPCRA Section 313) and Section 6607 of the Pollution
Prevention Act (PPA). This guidance document is intended for use along with the Toxic
Chemical Release Inventory Reporting Form R and Instructions document published annually by
the U.S. Environmental Protection Agency (EPA). For further assistance and to obtain copies of
the latest version of this instruction document, contact the EPCRA Hotline at 1-800-535-0202.
The other EPCRA reporting programs are summarized at the end of this section.
One of the primary goals of the EPCRA program is to increase the public's knowledge of, and
access to, information on both the presence of toxic chemicals in their communities and on
releases and other waste management activities of toxic chemicals into the environment. Since
1987, certain facilities hi the manufacturing sector have been reporting information on releases
and other waste management activities of toxic chemicals to EPA and states throughout the
United States. As a result of an EPA rulemaking (62 FR 23834, May 1, 1997), certain additional
industry groups, including chemical distribution facilities (Standard Industrial Classification (SIC)
code 5169, Wholesale Nondurable Goods-Chemicals and Allied Products, Not Elsewhere
Classified), are now required to evaluate their chemical use and management activities to
determine potential reporting responsibilities under EPCRA Section 313. Facilities within this
SIC code generally engage in the wholesale distribution of chemicals and allied products, such as
acids, industrial and heavy chemicals, dyestuffs, industrial salts, rosin, and turpentine.1
Section 313 establishes annual reporting requirements for Section 313 toxic chemicals provided
that certain activity thresholds are met. Section 313 includes a list of over 650 chemicals and
chemical categories. These chemicals and chemical categories were either originally selected by
Congress or were added by EPA through rulemaking.
The Section 313 reporting requirements apply to owners or operators of facilities which meet all
of the following three criteria:
The facility must be in SIC code 10 (except 1011, 1081, and 1094), or 12 (except 1241),
or 20-39 (manufacturing facilities), pr 4911 (limited to facilities that combust coal and/or
oil for the purpose of generating power for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the purpose of generating power for distribution
'OMB. Standard Industrial Classification Manual, pp.309-310.
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
in commerce) and 4939 (limited to facilities that combust coal and/or oil for the purpose
of generating power for distribution in commerce), or 4953 (limited to facilities regulated
under RCRA subtitle C), or 5169, or 5171, or 7389 (limited to facilities primarily engaged
in solvent recovery services on a contract or fee basis); and,
• The facility must have 10 or more full-time employees (or the total hours worked by all
employees is greater than 20,000 hours), and
• The facility manufactures (defined to include importing), processes, or otherwise uses any
Section 313 chemical in quantities greater than the established threshold in the course of a
calendar year.
For each Section 313 chemical or chemical category, covered facilities must report the total
annual releases, both routine and accidental, to all environmental media; and other on-site waste
management activities, including quantities recycled, combusted for energy recovery and treated
for destruction, and off-site transfers for disposal, waste treatment, energy recovery and recycling.
This information is submitted on the Toxic Chemical Release Inventory (TRI) Reporting Form,
which is called the "Form R." (As discussed in the following chapter, facilities meeting certain
conditions are eligible to report using an abbreviated Form A.)
The annual Form R or Form A reports are submitted to EPA headquarters and to a state
designated agency, usually a State Emergency Response Commission (SERC) but may be a Tribal
Emergency Response Commission (TERC), annually on or before July 1 st for activities occurring
during the previous calendar year (e.g., July 1, 1999, for activities during the period from January
1 to December 31,1998).
EPCRA mandated that EPA establish and maintain a national TRI database to assist in research
and the development of regulations, guidelines, and standards related to Section 313 chemicals
and to make the TRI data available to the general public and any interested parties. The TRI
database is computer-accessible to anyone with a modem via the National Library of Medicine's
TOXNET on-line system. The TRI data are also available through many other sources,
including EPA's Internet Web site; public libraries on microfiche; the Government Printing Office
on CD-ROM; and the National Technical Information Service on magnetic tape and individual
state diskettes.
Facility owners or operators who violate the Section 313 reporting provisions may be assessed
civil penalties of up to $25,000 per day for each violation. In addition, state enforcement
provisions may also be applicable depending on the state's EPCRA Section 313 reporting
regulations.
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
This document is organized into several sections to provide quick reference. Section 2 presents
an overview of the Section 313 reporting requirements. Section 3 provides a detailed discussion
of how to make threshold determinations regarding the manufacture, processing, and otherwise
use of Section 313 chemicals. Section 4 covers general concepts relating to reporting and release
estimating, and provides potential data sources for determining releases at chemical distribution
facilities and other amounts managed. Section 5 presents a detailed discussion of EPCRA Section
313 release and other waste management scenarios in the chemical distribution industry and
covers developing estimates of releases and other waste management activities for several types of
operations commonly encountered by the chemical distribution industry. Finally, Appendix A
provides an alphabetical listing of the Section 313 chemicals and chemical categories subject to
EPCRA Section 313, the de minimis concentrations for each Section 313 chemical, and the
RCRA status of the chemical. Appendix B provides a bibliography of relevant EPA documents
used to help chemical distribution facilities in complying with EPCRA Section 313. Appendix C
provides relevant online information sources.
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CHEMICAL DISTRIBUTORS
Table 1-1. Summary of Reporting Requirements Under EPCRA
EPCRA
Section
Reporting Requirements
Sections
302 - 303
Presence of
Extremely
Hazardous
Substances
(40 CFR
§355.30)
If a facility has one or more "extremely hazardous substances" present on site in
quantities greater than Threshold Planning Quantities (TPQs) established by EPA, it
must notify its State Emergency Response Commission (SERC) and Local Emergency
Planning Committee (LEPC) that it is subject to the emergency planning requirements
of these sections. A facility representative must be designated to participate in the
local emergency planning process. The facility also must provide any information
deemed necessary for development or implementation of a local emergency plan.
Section 304
Emergency
Notification
(40 CFR
§355.40)
A facility must notify the LEPC and SERC immediately of the release of any
"extremely hazardous substance" (listed in 40 CFR Part 355, Appendices A and B) or
any hazardous substance under CERCLA (listed in 40 CFR 302.4), in amounts at or
above the specified Reportable Quantities that EPA establishes for each substance.
The facility must follow up this initial notification with a written statement providing
details of the incident.
Section 311
Material
Safety Data
Sheet
(MSDS)
Reporting
(40 CFR
§370.21)
A facility must submit to the LEPC, SERC, and local fire department a list of Material
Safety Data Sheets (MSDSs), or copies of MSDSs, for any "hazardous chemicals" (as
defined under the Occupational Safety and Health Administration (OSHA) Hazard
Communication Standard) that are present on site in quantities greater than 10,000
pounds. A facility also must report any "extremely hazardous substances" (EHS) (as
defined under Section 302) that are present on site in quantities at or above the TPQ
or 500 pounds, whichever is less. Submissions are required within 90 days of the date
when new chemicals are first present at or above specified thresholds or if new
information on previously reported chemicals becomes available. Some states have
established lower activity thresholds.
Section 312
Hazardous
Chemical
Inventory
(40 CFR
§370.25)
A facility must submit to the LEPC, SERC, and local fire department certain
information for any "hazardous chemical" or EHS reportable under Section 311. This
information is most commonly submitted on a Tier I or Tier II Form and includes a
description of any type of hazard the material may pose, the quantities stored, general
storage locations, and type of storage. The reports for each calendar year are due on
or before March 1 of the following year. Most states require or request that facilities
submit the more detailed Tier II reporting form or a state-issued version of that form.
In addition, some states have established lower activity thresholds and require more
detailed or additional information.
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TRI FORM R GUIDANCE DOCUMENT
CHEMICAL DISTRIBUTORS
EPCRA
Section
Reporting Requirements
Section
313: Toxic
Chemical
Release
Inventory
Reporting
(Form R)
(40 CFR
§372)
A facility in certain SIC codes meeting threshold requirements is required to report
annually amounts of listed Section 313 toxic chemicals released or otherwise
managed to EPA and designated state agencies. Section 313 includes a list of over
650 chemicals and chemical categories. Release reporting information is submitted
on the Toxic Chemical Release Inventory (TRI) Reporting Form, Form R.
The Section 313 reporting requirements apply to owners or operators of facilities
which meet all of the following three criteria:
• Facility must be in SIC code 10 (except 1011, 1081, and 1094), or 12
(except 1241), or 20-39 (manufacturing facilities), or 4911 (limited to
facilities that combust coal and/or oil for the purpose of generating power
for distribution in commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating power for distribution in
commerce) and 4939 (limited to facilities that combust coal and/or oil for
the purpose of generating power for distribution in commerce), or 4953
(limited to facilities regulated under RCRA subtitle C), or 5169, or 5171, or
7389 (limited to facilities primarily engaged in solvent recovery services on
a contract or fee basis); and.
• Facility must have 10 or more full-tune employees (or the total hours
worked by all employees is greater than 20,000 hours), and
• Facility must manufacture (including importation), process, or otherwise
use a listed Section 313 chemical hi excess of specific threshold quantities.
The threshold quantities for reporting under Section 313 are based on the amount
of the Section 313 chemical manufactured, processed, or otherwise used during the
calendar year. Specifically, the thresholds are greater than 25,000 pounds if
manufactured, or 25,000 pounds if processed, or 10,000 pounds if otherwise used.
EPCRA mandated that EPA establish and maintain a national TRI database to
assist in research and the development of regulations, guidelines, and standards
related to Section 313 chemicals and to make the TRI data available to the general
public and any interested parties. The TRI database is computer-accessible to
anyone with a modem via the Internet or the National Library of Medicine's
TOXNET on-line system.
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SECTION 2
SECTION 313 REPORTING REQUIREMENTS
WHO MUST REPORT?
A facility is subject to the provisions of the Section 313 reporting requirements if it meets all three
of the following criteria:
The facility must be in SIC code 10 (except 101 1, 1081, and 1094), or 12 (except 1241),
or 20-39 (manufacturing facilities), or 491 1 (limited to facilities that combust coal and/or
oil for the purpose of generating power for distribution in commerce), 493 1 (limited to
facilities that combust coal and/or oil for the purpose of generating power for distribution
in commerce) and 4939 (limited to facilities that combust coal and/or oil for the purpose
of generating power for distribution in commerce), or 4953 (limited to facilities regulated
under RCRA subtitle C), or 5169, or 5171, or 7389 (limited to facilities primarily
engaged in solvent recovery services on a contract or fee basis) hereafter "covered SIC
codes": and.
Instructions regarding how to determine the facility SIC code, employee threshold, or activity
follows; for additional detail please consult the Toxic Chemical Release Inventory Reporting
Form R and Instructions, a document published annually by EPA.
In addition, pursuant to Executive Order (EO) 12856 signed by the President on August 3, 1993,
Federal facilities are required to determine the applicability of the EPCRA Section 313 reporting
requirements regardless of the facility's SIC codes. Federal facilities that have 10 or more full
time employees or the equivalent and manufacture, process, or otherwise use listed Section 313
chemicals at or above established thresholds are subject to EPCRA Section 313 reporting.
Federal facilities were required to begin reporting no later than reporting year 1994; their first
Form R or Form A reports were due by July 1, 1995.
The amount of the chemical released to the environment does not affect the need to report. Even
if there are no releases of a listed Section 313 chemical, a facility must report if it meets the
requirements regarding SIC code, number of employees, and activity threshold. A threshold
determination must be made individually for each Section 313 chemical.
Thresholds are based on operation year, this includes partial year reporting and reporting by a
facility that is going through closure. The facilities should consider the portion of the year for
which they operated to determine the actual employee hours worked as well as threshold
determination and release reporting.
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Reduced Reporting
On November 30, 1994, EPA published a final rule (59 FR 61488) that provides an alternative
reporting option to qualifying facilities. Eligible facilities wishing to take advantage of this
alternative reporting option may report on a simplified two page form referred to as Form A and
do not have to use Form R. The rule entitled "TRI Alternate Threshold for Facilities with Low
Annual Reportable Amounts," provides facilities that otherwise meet EPCRA Section 313 activity
thresholds the option of reporting on Form A, provided that they do not exceed 500 pounds for
the total annual reportable amount (defined below) for that chemical, and that the amounts
manufactured, processed or otherwise used do not exceed 1 million pounds. As with determining
an activity threshold to determine if the chemical activity has been exceeded, facilities must
evaluate each activity threshold separately; for example, a facility that manufactures 900,000
pounds per year of a Section 313 chemical and processes 150,000 pounds per year of a Section
313 chemical would still be eligible to use the Form A.
For the purpose of reporting on Form A, the annual reportable amount is equal to the combined
total quantities released (including disposed) at the facility, treated at the facility (as represented
by amounts destroyed or converted by treatment processes), recycled at the facility, combusted
for the purpose of energy recovery at the facility, and amounts transferred from the facility to off-
site locations for the purpose of recycling, energy recovery, treatment, and/or disposal. These
quantities do not include amounts of the chemical accidentally released. These volumes
correspond to the sum of amounts reported on Form R, as Part II column B of section 8, data
elements 8.1 (quantity released), 8.2 (quantity used for energy recovery on-site), 8.3 (quantity
used for energy recovery off-site), 8.4 (quantity recycled on-site), 8.5 (quantity recycled off-site),
8.6 (quantity treated on-site), and 8.7 (quantity treated off-site). See Section 4 of this document
for more guidance on completing Part II, Section 8 of Form R.
What is a facility?
Under EPCRA, a "facility" is defined as all buildings, equipment, structures, and other stationary
items which are located on a single site or 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). An "establishment" is generally a single physical location, where
business is conducted or where services or industrial operations are performed. A facility may
contain more than one establishment. For example, a chemical distribution area and solvent
recycling unit would be one facility if all three units were owned and operated by the same
company and are located on contiguous or adjacent properties. A single facility therefore can be a
multi-establishment complex. Such a facility may submit reports that cover all its establishments,
or the individual establishments may report separately. However, for the purposes of determining
thresholds, all chemical activities for the entire facility must be considered.
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How to determine your SIC Code"
Standard Industrial Classification (SIC) codes 10 (except 1011, 1081, and 1094), 12 (except
1241), 20-39 (manufacturing facilities), 4911, 4931 and 4939 (limited to facilities that combust
coal and/or oil for the purpose of generating power for distribution in commerce), 4953 (limited
to facilities regulated under RCRA subtitle C), 5169, 5171, and 7389 (limited to facilities
primarily engaged in solvent recovery services on a contract or fee basis) are covered under
section 313 of EPCRA. 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. A facility should
determine its own SIC code(s), based on its activities on-site and the "Standard Industrial
Classification Manual 1987." In some cases, a state agency or other organization may have
assigned SIC codes on a different basis than the one used in the SIC Manual. For the purposes
of TRI reporting, state assigned codes should not be used if they differ from ones assigned using
the SIC Manual.
Your facility may include multiple establishments that have different SIC codes. In order to
determine which SIC code best represents the facility, the facility should calculate the value of the
products or services produced or provided at/by or shipped from each establishment within the
facility and then use the following rule to determine if your facility comes within the covered SIC
codes, and the SIC code criterion is met.
• If the total value of the products or services shipped, produced or provided at establishments
in "covered" SIC codes is greater than 50 percent of the value of the entire facility's products
and services, the entire facility comes within the covered SIC codes, and the SIC code
criterion is met.
• If any one establishment in the specified set of SIC codes produces, provides or ships products
or service whose value exceeds the value of products and services produced or shipped by all
other establishments within the facility, the facility comes within the covered SIC codes, and
the SIC code criterion is met.
The value of production or service attributable to a particular establishment may be isolated by
subtracting the product or service value obtained from other establishments within the same
facility from the total product or service value of the facility. This procedure eliminates the
potential for "double counting" production or service in situations where establishments are
engaged in sequential production activities at a single facility.
Please note: The North American Industrial Classification System that appeared in the Federal Register on
April 9, 1997 will replace the 1987 Standard Industrial Classification System (SIC). Regulatory entities, including
EPA, will take steps to adopt the new classification system over the next few years. In the meantime, facilities should
consider their activities in relation to the 1987 SIC code system until further notification is made.
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How to Determine Your Number of Employees
A "full time employee," for the purpose of Section 313 reporting, is defined as 2,000 work hours
per year. The number of full time employees is dependent only upon the total number of hours
worked by all employees during the calendar year for that facility and not the number of persons
working. To determine the number of full time employees working for your facility, add up the
hours worked by all employees during the calendar year including contract employees and sales
and support staff, and divide the total by 2,000 hours. In other words, if the total number of
hours worked by all employees is 20,000 hours or more, your facility meets the ten employee
threshold.
Facilities may have contract workers present at times to conduct maintenance and service
operations, including equipment, motor vehicle, and building maintenance, construction, and
operating processes and waste management activities (e.g., remediation). The hours of all these
contract workers count toward the employee threshold for reporting under Section 313. In
addition, the hours worked by professionals (e.g., those on salary, that do not clock in or out) also
count towards the facility's employee threshold. Employees that perform activities which
routinely occur off-site such as truck drivers, but who are based at the facility are also counted
towards the employee threshold. Routine activities performed at the facility by outside personnel
such as contract drivers that are not based at the facility are not counted towards the employee
threshold.
CHEMICAL ACTIVITY THRESHOLDS
Section 313 requires a facility that meets the SIC code and employee criteria to submit Form R
reports for any listed Section 313 chemical or chemical category that it manufactures in annual
quantities greater than 25,000 pounds, processes in annual quantities greater than 25,000 pounds,
or otherwise uses in annual quantities greater than 10,000 pounds (40 CFR §372.3). These
thresholds (manufacture, process, or otherwise use) will be referenced throughout this document
as "activity thresholds." Chemicals must be evaluated in association with one or more of these
three categories when determining whether an activity threshold has been exceeded. These
categories are:
• Manufacture - "Manufacture" means to produce, prepare, compound, or import a listed
Section 313 chemical. Import is defined as causing the Section 313 chemical to be imported
into the customs territory of the United States. If you order a listed Section 313 chemical (or
a mixture containing the chemical) from a foreign supplier, then you have imported the
chemical when that shipment arrives at your facility directly from a source outside of the
United States. By ordering the chemical, you have "caused it to be imported," even though
you may have used an import brokerage firm as an agent to obtain the Section 313 chemical.
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If the importation was directed by the parent company, then the facility receiving the chemical is
not considered to have imported the chemical.
The term manufacture also includes coincidental production of a listed chemical (e.g., as a
byproduct or impurity) as a result of the manufacture, processing, otherwise use, or waste
management of other chemical substances. The fact that the coincidental manufacturing of
these byproducts is not the primary purpose of the facility is irrelevant. Listed EPCRA
Section 313 chemicals coincidentally manufactured by a facility must be factored into
threshold determinations and release calculations.
• Manufactured Activities and Definitions
• Produced or imported for on-site use/processing
A chemical that is produced or imported and then further processed or
otherwise used at the same facility.
• Produced or imported for sale/distribution
A chemical that is produced or imported specifically for sale or
distribution outside the facility.
• Produced as a by-product
A chemical that is produced coincidentally during the production,
processing, otherwise use, or disposal of another chemical substance or
mixture and, following its production, is separated from that other
chemical substance or mixture. Section 313 chemicals produced and
released as a result of waste treatment for disposal are also considered
byproducts.
• Produced as an impurity
A chemical that is produced coincidentally as a result of the
manufacture, processing, or otherwise use of another chemical but is
not separated and remains primarily in the mixture or product with that
other chemical.
• Process - "Process" means the preparation of a listed Section 313 chemical, after its
manufacture, for distribution in commerce. Processing is usually the intentional incorporation
of a Section 313 chemical into a product. Processing includes preparation of the Section 313
chemical hi the same physical state or chemical form as that received by your facility, or
preparation that produces a change in physical state or chemical form. The term also applies
to the processing of a mixture or other trade name product that contains a listed Section 313
chemical as one component. Processing activities include use of Section 313 chemicals as
reactants, in formulations, and as article components, and repackaging. Processing may also
include the recycling of a Section 313 chemical for distribution in commerce. For example, if
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
a facility receives a waste containing a Section 313 chemical from off-site, stabilizes, and
repackages the waste in one calendar year and then distributes the repackaged waste into
commerce in the following year. The facility would count the amount of the Section 313
chemical stabilized as being processed in the year it was treated.
Relabeling or redistributing of the Section 313 chemical where no repackaging of the Section
313 chemical occurs does not constitute processing of the Section 313 chemical.
• Processed Activities and Definitions
• As a reactant
A natural or synthetic chemical used in chemical reactions for the
manufacture of another chemical substance or product. This includes,
but is not limited to, feedstocks, raw materials, intermediates, and
initiators.
• 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 Section 313 chemicals used in this
capacity include, but are not limited to, additives, dyes, reaction
diluents, initiators, solvents, inhibitors, emulsifiers, surfactants,
lubricants, flame retardants, and rheological modifiers.
• As an article component
A chemical that becomes an integral component of an article distributed
for industrial, trade, or consumer use.
• Repackaging
Processing or preparation of a Section 313 chemical (or product
mixture) for distribution in commerce in a different form, state, or
quantity. This includes, but is not limited to, the transfer of material
from a bulk container, such as a tank truck, to smaller containers such
as cans or bottles.
• Otherwise use - Any use involving a listed Section 313 chemical at a facility that does not fall
under the definitions of 'manufacture" or "process" is an otherwise use of that chemical. A
chemical that is otherwise used by a facility is not incorporated into a product distributed in
commerce and includes use of the Section 313 chemical as a chemical processing aid or as a
manufacturing aid or for ancillary uses such as treating wastes. Otherwise use of a Section
313 chemical does not include disposal, stabilization (without subsequent distribution in
commerce), or treatment for destruction unless:
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(1) The Section 313 chemical that was disposed, stabilized, or treated for destruction
was received from off-site for the purposes of further waste management, or
(2) The Section 313 chemical that was disposed, stabilized, or treated for destruction
was manufactured as a result of waste management activities on materials received
from off-site for the purpose of further waste management.
Relabeling or redistributing of the Section 313 chemical where no repackaging of the Section
313 chemical occurs does not constitute the otherwise use of the Section 313 chemical.
• Otherwise Used Activities and Definitions
• 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
Section 313 chemicals include, but are not limited to, process solvents,
catalysts, inhibitors, initiators, reaction terminators, and solution
buffers.
• As a manufacturing aid
A chemical that aids the manufacturing process that does not become
part of the resulting product and is not added to the reaction mixture
during the manufacture or synthesis of another chemical substance.
Examples include, but are not limited to, process lubricants,
metalworking fluids, coolants, refrigerants, and hydraulic fluids.
. • Ancillary or other use
A chemical that is used at a facility for purposes other than aiding
chemical processing or manufacturing as described above. Examples of
such Section 313 chemicals include, but are not limited to, cleaners,
degreasers, lubricants, fuels, and chemicals used for treating wastes.
For purposes of the otherwise use definition, EPA interprets waste management activities to
include recycling, combustion for energy recovery, treatment for destruction, waste stabilization,
and release, including disposal. Waste management does not include the storage, container
transfer, or tank transfer of a Section 313 chemical if no recycling, combustion for energy,
treatment for destruction, waste stabilization, or release of the chemical occurs at the facility.
(See 62 FR 23850)
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
Recycling for the purposes of EPCRA Section 313 means the following: (1) the recovery for
reuse of a Section 313 chemical from a gaseous, aerosol, aqueous, liquid, or solid stream; or
(2) the reuse or the recovery for use of a Section 313 chemical that is a RCRA hazardous
waste as defined in 40 CFR Part 261. Recovery is the act of extracting or removing the
Section 313 chemical from a waste stream and includes: (1) the reclamation of the Section 313
chemical from a stream that entered a waste treatment or pollution control device or process
where destruction of the stream or destruction or removal of certain constituents of the stream
occurs (including air pollution control devices or processes, wastewater treatment or control
devices or processes, Federal or state permitted treatment or control devices or processes, and
other types of treatment or control devices or processes); and (2) the reclamation for reuse of
an "otherwise used" Section 313 chemical that is spent or contaminated and that must be
recovered for further use in either the original or any other operations. (See EPA document,
Interpretations of Waste Management Activities: Recycling, Combustion for Energy Recovery,
Waste Stabilization and Release.)
Combustion for energy recovery is interpreted by EPA to include the combustion of a Section
313 chemical that is (1) (a) a RCRA hazardous waste or waste fuel, (b) a constituent of a
RCRA hazardous waste or waste fuel, or ® a spent or contaminated "otherwise used" material;
and that (2) has a heating value greater than or equal to 5,000 British thermal units (BTU) per
pound in an energy or materials recovery device. Energy or materials recovery devices are
boilers and industrial furnaces as defined in 40 CFR §372.3 (See 62 FR 23891). In
determining whether an EPCRA Section 313 listed toxic chemical is combusted for energy
recovery, the facility should consider the BTU value of the Section 313 chemical and not of
the chemical stream. If the heating value of the Section 313 chemical is below 5,000 BTU,
the chemical is being treated for destruction. A facility that blends and subsequently
distributes in commerce a waste-derived fuel "processes" EPCRA Section 313 listed toxic
chemicals that are constituents of that waste-derived fuel. In contrast, if subsequent to
blending the waste-derived fuel, that same facility combusts on-site the waste-derived fuel in
an energy recovery unit, the facility "otherwise uses" EPCRA Section-313 listed toxic
chemicals that are constituents of that waste-derived fuel. An EPCRA Section 313 listed toxic
chemical that has a heat value of less than 5,000 BTUs and that is a constituent of a waste-
derived fuel is "otherwise used" if that fuel is combusted in an on-site energy recovery unit
(62 FR 23851).
EPA defines Treatment for destruction to mean the destruction of a Section 313 chemical in
waste such that the substance is no longer the Section 313 chemical subject to reporting under
EPCRA Section 313. Treatment for destruction does not include the destruction of a Section
313 chemical in waste where the Section 313 chemical has a heat value greater than 5,000
British Thermal Units (BTU) and is combusted in any device that is an industrial boiler or
furnace. (See 40 CFR §372.3.) "Treatment for destruction" includes acid or alkaline
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
neutralization if the Section 313 chemical is the entity that reacts with the acid or base.
"Treatment for destruction" does not include: (1) neutralization of a waste stream containing
Section 313 chemicals if the Section 313 chemicals themselves do not react with the acid or
base (See 40 CFR §372.3), (2) preparation of a Section 313 chemical for disposal, (3) removal
of Section 313 chemicals from waste streams, and (4) activities intended to render a waste
stream more suitable for further use or processing, such as distillation or sedimentation. For
example, neutralization of pure nitric acid is considered treatment for destruction. In contrast,
neutralization of nitric acid containing three percent lead is not considered treatment for
destruction of the lead component, because the lead has not reacted with the neutralizing agent
(See 62 FR 23852).
EPA defines Waste stabilization to mean any physical or chemical process used to either
reduce the mobility of hazardous constituents in a hazardous waste or eliminate free liquid as
determined by a RCRA approved test method (e.g., Test Method 9095). A waste stabilization
process includes mixing the hazardous waste with binders or other materials and curing the
resulting hazardous waste and binder mixture. Other synonymous terms used to refer to this
process are "stabilization," "waste fixation," or "waste solidification." (See 40 CFR §372.3.)
Release is defined by EPCRA Section 329(8) to mean 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 Section 313 chemical. (See 40 CFR §372.3.)
Disposal is defined by EPCRA to mean any underground injection, placement in
landfills/surface impoundments, land treatment, or other intentional land disposal. (See 40
CFR §372.3.)
Based on EPA's evaluation of the chemical distribution industry, the Agency believes that
chemical distribution activities routinely involve or result in the manufacturing, processing, or
otherwise use of EPCRA Section 313 chemicals (62 FR 23834, May 1, 1997). The term
manufacture includes the coincidental manufacture of a chemical, such as a byproduct or impurity,
from the manufacturing, processing, otherwise use or waste management of another chemical
substance or mixture. Thresholds must be calculated separately for manufacture, process, or
otherwise use of the same chemical. If any single threshold is exceeded for a listed Section 313
chemical, the facility must submit a Form R covering all nonexempt activities, chemical
distribution facilities will be required to factor into their threshold determinations and reporting
calculations the quantities of EPCRA Section 313 chemicals used in support activities such as
non-motor vehicle equipment maintenance. Chemicals involved in these support activities are
classified under the otherwise use category.
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
EXEMPTIONS
Section 313 provides for exemptions from reporting for specific "processing" or "otherwise use"
activities. The instructions provided in Toxic Chemical Release Inventory Reporting Form R and
Instructions should be reviewed carefully before proceeding. The following discussion
summarizes the exemption instructions. A facility does not have to consider amounts of listed
Section 313 chemicals involved in any of these processing or otherwise use activities when
determining if activity thresholds have been exceeded or when estimating environmental releases.
Limited exemptions apply to manufacturing activities. For example, manufacturing a Section 313
chemical for research and development purposes and manufacturing as an impurity below a
specified level in a product distributed beyond the facility both can be exempt. The EPA's Toxic
Chemical Release Inventory Questions and Answers, Revised 1990 Version [EPA 560/4/91-003
(will be revised in near future)] and the Toxic Release. Inventory Reporting Form R and
Instructions also contain information about these exemptions. (See Appendix B for ordering
information.)
• The de minimis exemption allows facilities to disregard certain minimal concentrations of
chemicals in mixtures or trade name products they "process" or "otherwise use" in making
threshold determinations and release and other waste management determinations. The de
minimis exemption does not apply to the "manufacture" of a Section 313 chemical except if
that Section 313 chemical is "manufactured" as an impurity and remains in the product
distributed in commerce below the appropriate de minimis level. The de minimis exemption
does not apply to a byproduct "manufactured" coincidentally as a result of "manufacturing,"
"processing," "otherwise use," or any waste management activities.
This de minimis exemption applies solely to "mixtures" and trade name products. EPA's
long-standing interpretation has been that "mixture" does not include waste. Therefore, the
de minimis exemption cannot be applied to Section 313 chemicals in a waste even if the waste
is being "processed" or "otherwise used."
When determining whether the de minimis exemption applies to a listed Section 313 chemical,
the owner or operator should only consider the concentration of the Section 313 chemical in
mixtures and trade name products in process streams in which the Section 313 chemical is
undergoing a reportable activity. If the Section 313 chemical in a process stream is
"manufactured" as an impurity, "processed," or "otherwise used" and is below the appropriate
de minimis concentration level, then the quantity of the Section 313 chemical in that process
stream does not have to be applied to threshold determinations nor included in release or
other waste management determinations. If a Section 313 chemical in a process stream meets
the de minimis exemption, all releases and other waste management activities associated with
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
the Section 313 chemical in that stream are exempt from EPCRA section 313 reporting. It is
possible to meet an activity (e.g., processing) threshold for a Section 313 chemical on a
facility-wide basis, but not be required to calculate releases or other waste management
quantities associated with a particular process because that process involves only mixtures or
trade name products containing the Section 313 chemical below the de minimis level.
Once a Section 313 chemical concentration is above the appropriate de minimis
concentration, threshold determinations and release and other waste management
determinations must be made, even if the chemical later falls below de minimis level in the
same process stream. Thus, all releases and other quantities managed as waste which occur
after the de minimis level has been exceeded are then subject to reporting. If a Section 313
chemical in a mixture or trade name product above de minimis is brought on-site, the de
minimis exemption never applies.
The de minimis concentration level is consistent with the OSHA Hazard Communication
Standard requirements for development of Material Safety Data Sheets (MSDSs). The de
minimis level is 1.0 percent except if the Section 313 chemical is an OSHA-defined
carcinogen. The de minimis level for OSHA-defined carcinogens is 0.1 percent. For mixtures
or other trade name products that contain one or more members of a listed Section 313 toxic
chemical category, the de minimis level applies to the aggregate concentration of all such
members and not to each individually. The list of Section 313 chemicals hi the publication
Toxic Chemical Release Inventory Reporting Form R and Instructions for the current
reporting year contains the de minimis values for each of the Section 313 chemicals and
chemical categories.
• Materials that are processed or used as articles - Quantities of a listed Section 313
chemical contained in an article do not have to be factored into threshold or release
determinations when that article is processed or otherwise 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 hi whole or hi part upon its shape or
design during end-use, and that does not release a Section 313 chemical under the normal
conditions of the processing or use of that item at the facility.
If the processing or otherwise use of like articles results hi a total release of less than 0.5
pounds of a Section 313 chemical in a calendar year to all environmental media, EPA will
allow this release quantity to be rounded to zero, and the manufactured items remain exempt
as articles. EPA requires facilities to round off and report all estimates to the nearest whole
number. The 0.5-pound limit does not apply to each individual article, but applies to the sum
of all releases from processing or otherwise use of like articles.
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
The article exemption applies to the normal processing or otherwise use of an article. It does
not apply to the manufacture of an article. Thus, Section 313 chemicals processed into
articles manufactured at a facility must be counted in threshold determinations.
A closed item containing Section 313 chemicals (e.g., a transformer containing PCBs) that
does not release the Section 313 chemicals during normal use is considered an article if a
facility uses the item as intended and the Section 313 chemicals are not released. If a facility
services the closed item (e.g., a transformer) by replacing the Section 313 chemicals, the
Section 313 chemicals added during the reporting year must counted in threshold and release
and other waste management calculations.
• Materials that are structural components of the facility - Chemicals present hi materials
used to construct, repair, or maintain a plant building are exempt from the activity thresholds.
For example, solvents and pigments present in paint used to coat the structural components of
a building would be exempt from threshold determination and release reporting.
• Materials used for janitorial or facility grounds maintenance - Chemicals present in
materials used for routine or facility grounds maintenance are exempt from the activity
thresholds. Examples include bathroom cleaners, fertilizers, and garden pesticides hi the same
form and concentration commonly distributed to consumers. Chemicals used for equipment
maintenance, such as the use of oil or cleaning solvents, are not exempt.
• Materials used with facility motor vehicles - Chemicals present hi materials used for
operating and maintaining motor vehicles operated by the facility are exempt from the activity
thresholds. Examples include gasoline, radiator coolant, and windshield wiper fluid used in
equipment such as cars, trucks, forklifts, and tow motors.
• Personal items - Chemicals present in materials such as foods, drugs, cosmetics, or other
personal items are exempt from the activity thresholds. Examples include materials used in the
facility cafeteria and infirmary. Chemicals used for heating and ah" conditioning solely to
provide comfort to personnel are also exempt from reporting. If a building's temperature is
regulated to facilitate a process or treatment operation, the Section 313 chemicals used to heat
or cool the building are not exempt. Units that supply both personal comfort and operational
needs may be apportioned, if it is possible to separate them.
• Laboratory materials - Chemicals used in certain laboratory activities that are conducted
under the supervision of a technically qualified individual (as defined under 40 CFR
§720.3(ee)) are exempt from the activity thresholds. The laboratory activities exemption
applies only to sampling and analysis, research and development, and quality assurance and
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
quality control activities. The exemption does not apply to the use or production of listed
Section 313 chemicals in pilot-plant operations and laboratories for distribution in commerce
(e.g., specialty chemicals) and laboratory support services.
• Materials as they are drawn from the environment or municipal sources - Chemicals
contained in intake water (used for processing or non-contact cooling) or in intake air (used
either as compressed air or for combustion) are exempt from the activity thresholds.
• Property owners - Property owners that merely own real estate on which a facility covered
by Section 313 is located and have no business interest in the operation of that facility (e.g., a
company owns an industrial park) are exempt for Section 313 reporting. The operator of that
facility, however, is subject to reporting requirements.
SUPPLIER NOTIFICATION REQUIREMENTS
Because manufacturers reporting under Section 313 must know the Section 313 chemical
composition of the products they use to be able to accurately calculate releases, EPA requires
some suppliers of mixtures or trade name products containing one or more of the listed Section
313 chemicals to notify their customers of the identity of the chemical in the mixture or the trade
name product. This requirement has been in effect since January 1, 1989.
A facility must comply with the Section 313 supplier notification requirements if it owns or
operates a facility which meets all of the following criteria.
• The facility is in SIC codes 20-39,
• The facility manufactures, imports, or processes a Section 313 chemical, and
• The facility sells or otherwise distributes in commerce a mixture or trade name product
containing the Section 313 chemical to either:
A facility described in 40 CFR §372.22 (covered facility group), or
A facility that then sells the same mixture or trade name product to a facility
described in 40 CFR §372.22 (covered facility group).
The supplier notification requirements do not apply to TRI chemicals that are themselves
wastestreams or are constituents of wastestreams.
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
LISTED SECTION 313 CHEMICALS
Appendix A to this document contains an alphabetical listing of the chemicals subject to Section
313 reporting at the time of publication of this document, including their de minimis
concentrations. EPA publications Common Synonyms for Section 313 Chemicals (EPA 745-R-
95-008) and Consolidated List of Chemicals Subject to Reporting Under the Act (Title III List of
Lists) (EPA-550-B-96-015) may also be useful references when reviewing the chemicals at your
facility for Section 313 coverage.
The list of Section 313 chemicals is amended frequently. Users of this guidance document or
other documents listing Section 313 chemicals are cautioned that changes may have occurred to
the list of Section 313 chemicals since publication of the original list or addition of the chemical
through administrative action. The list of Section 313 chemicals presented hi the Toxic Chemical
Release Inventory Reporting Form R and Instructions for the current reporting year should
always be consulted as the most up-to-date source of currently listed Section 313 chemicals. For
the latest information on Section 313 chemical listings, contact the EPCRA Hotline at 1-800-535-
0202.
Some of the Section 313 chemicals have qualifiers included with their names. Reporting on these
chemicals are determined by the conditions specified in the qualifiers. Chemicals that are listed
without parenthetic qualifiers are subject to reporting hi all forms in which they are manufactured,
processed, or otherwise used. Descriptions of the qualifiers are as follows:
• Fume or dust - Three of the metals on the list of Section 313 chemicals (aluminum,
vanadium, and zinc) contain the qualifier "fume or dust." Fume or dust refers to dry forms of
these metals, not to "wet" forms such as solutions or slurries. Thus, a facility should
determine if, for example, it generated more than 25,000 pounds of "aluminum (fume or
dust)." Similarly, there may be certain technologies in which one of these metals is processed
in the form of a fume or dust to make other Section 313 chemicals or other products for
distribution in commerce. In reporting releases, the facility would report only releases of the
fume or dusts.
EPA considers dusts to consist of solid particles generated by any mechanical processing of
materials including crushing, grinding, rapid impact, handling, detonation, and decrepitation of
organic and inorganic materials such as rock, ore, and metal. Dusts do not tend to flocculate,
except under electrostatic forces. A fume is an airborne dispersion consisting of small solid
particles created by condensation from a gaseous state, in distinction to a gas or vapor.
Fumes arise from the heating of solids such as aluminum. The condensation is often
accompanied by a chemical reaction such as oxidation. Fumes flocculate and sometimes
October?, 1997 2-14
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
coalesce. Other metals, (e.g., such as lead or copper) are not limited by this qualifier and are
subject to reporting in all forms (fume, dust, and wet).
• Manufacturing qualifiers -Two of the entries in the Section 313 chemical list contain a
qualifier relating to manufacture. For isopropyl alcohol, the qualifier is "manufacturing -
strong acid process". For saccharin the qualifier simply is "manufacturing." For isopropyl
alcohol, the qualifier means that only facilities manufacturing isopropyl alcohol by the strong
acid process are required to report. In the case of saccharin, only manufacturers of the
Section 313 chemical are subject to the reporting requirements. A facility that processes or
otherwise uses either Section 313 chemical would not be required to report for those
chemicals. In both cases, the facility is not required to provide supplier notification because
only the manufacturer, not the user, of the Section 313 chemical must report.
• Ammonia (includes anhydrous ammonia and aqueous ammonia from water dissociable
ammonium salts and other sources; 10 percent of total aqueous ammonia is reportable
under this listing) - The qualifier for ammonia means that anhydrous forms of ammonia are
100 percent reportable and aqueous forms are limited to 10 percent of total aqueous
ammonia. Therefore, when determining thresholds, releases, and other waste management
quantities all anhydrous ammonia is included but only 10 percent of total aqueous ammonia is
included. Any evaporation of ammonia from aqueous ammonia solutions is considered
anhydrous ammonia and should be included in the appropriate threshold and release
determinations.
• Phosphorus (yellow or white) - The listing for phosphorus is qualified by the term "yellow
or white" This means that only manufacturing, processing, or otherwise use of phosphorus in
the yellow or white chemical forms require reporting. Conversely, manufacturing, processing,
or otherwise use of "black" or "red" phosphorus does not trigger reporting.
• Asbestos (friable) - The listing for asbestos is qualified by the term "friable," referring to the
physical characteristic of being able to be crumbled, pulverized, or reducible to a powder with
hand pressure. Only manufacturing, processing, or otherwise use of asbestos in the friable
form triggers reporting.
• Aluminum oxide (fibrous forms) - The listing for aluminum oxide is qualified by the term
"fibrous forms." Fibrous refers to a man-made form of aluminum oxide that is processed to
produce strands or filaments which can be cut to various lengths depending on the application.
Only manufacturing, processing, or otherwise use of aluminum oxide in the fibrous form
triggers reporting.
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
• Hydrochloric acid and sulfuric acid (acid aerosols including mists, vapors, gas, fog, and
other airborne forms of any particle size) - The qualifier for hydrochloric acid and sulfuric
acid means that only aerosol forms of this chemical are reportable. Aqueous solutions are not
covered by this listing, but airborne forms generated from aqueous solutions are covered.
• Nitrate compounds (water dissociable; reportable only when in an aqueous solution) -
The qualifier for the nitrate compounds category limits the reporting to nitrate compounds
that dissociate in water, and thereby generate nitrate ions. For the purposes of threshold
determinations, the entire weight of the nitrate compound must be included in all calculations.
For the purposes of reporting releases and other waste management quantities, only the
weight of the nitrate ion should be included in the calculations of these quantities.
WHAT MUST BE REPORTED?
If your facility is included in the specified set of SIC codes, has ten or more full-time employees or
the equivalent, and manufactures, processes, or otherwise uses one of the listed Section 313
chemicals in amounts greater than the appropriate thresholds, you must report the following
information on Form R:
• Name and location of your facility;
• Identity of the listed Section 313 chemical (unless you claim its identity to be a trade secret);
• Whether you manufacture, process, or otherwise use the chemical any other way;
• Maximum quantity of the chemical on-site at any time during the year;
• Quantities of the chemical released during the year to environmental media, including both
accidental spills and routine emissions;
• Quantities of the chemical subject to on site waste management actions, including recycling,
energy recovery, or waste treatment;
• Off-site locations to which you shipped wastes containing the chemical and the quantities of
the chemical sent to those locations;
• Information on source reduction activities; and
October?, 1997 2-16
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
• Treatment methods used for wastes containing the chemical and estimates of their efficiency
for the reportable Section 313 chemical.
A release is defined under EPCRA Section 329(8) as any spilling, leaking, pumping, pouring,
emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the
environment of any listed Section 313 chemical. The definition of release includes the
abandonment or discarding of barrels, containers, and other closed receptacles. Separate release
estimates must be provided for releases to air, water, and land (e.g., deep well injection, surface
impoundment, permitted landfill).
DOCUMENTING REPORTING EFFORTS
Sound recordkeeping practices are essential for accurate and efficient TRI reporting. EPA
requires that facilities keep a copy of each Form R or Form A report filed for at least three years
from the date of submission (40 CFR §372.10). These reports will also be of use to facilities in
subsequent years when completing future Form R or Form A reports. EPA also requires that
facilities maintain those documents, calculations, worksheets, and other forms upon which they
relied to file Form R or Form A reports. EPA may request this supporting documentation from
the facility, for example, to conduct data quality reviews of present or past Form R or Form A
submissions.
Supporting documentation, organized by year, that a facility should maintain may include, if
applicable:
• Previous years' Forms Rs and Form As;
• Section 313 Reporting Threshold Worksheets (a sample worksheet is given in the Toxic
Chemical Release Inventory Reporting Form R and Instructions document;
• Engineering calculations and other notes;
• Purchase records from suppliers;
• Inventory data;
• EPA (NPDES) permits and monitoring reports;
• EPCRA Section 312, Tier II Reports;
• Monitoring records;
• Flowmeter data;
• RCRA Hazardous Waste Generator's Report;
• Pretreatment reports filed by the facility with the local government;
October?, 1997 2-17
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TRJ FORM R GUIDANCE DOCUMENT
CHEMICAL DISTRIBUTORS
Invoices from waste management companies;
Manufacturer's estimates of treatment efficiencies;
RCRA Manifests; and
Process diagrams.
October 7, 1997
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TRI FORM R GUIDANCE DOCUMENT
CHEMICAL DISTRIBUTORS
SECTION 3
MAKING THE THRESHOLD DETERMINATION
A separate Toxic Chemical Release Inventory Reporting Form must be submitted for each listed
chemical that is "manufactured," "processed," or "otherwise used" above an activity threshold at
your facility, assuming the SIC code and employee criteria are met. Current EPCRA Section 313
guidance for chemical distribution facilities is shown in Table 3-1:
Table 3-1. Examples of Manufactured, Processed, and Otherwise Used Chemicals at
Chemical Distribution Facilities *
Produced or imported for on-site
use/processing
May not occur in the chemical distribution industry group.
Produced or imported for
sale/distribution
Any Section 313 chemical that is imported by a chemical
distribution facility for sale and distribution.
Produced as a by-product
Generation of aerosol forms of hydrochloric acid as a
result of repackaging or reformulation activities.
Produced as an impurity
May not occur in the chemical distribution industry group.
The formulation or blending of EPCRA Section 313 reportable chemicals into products further
distributed in commerce is subject to the processing activity threshold.
The repackaging/transferring of listed EPCRA Section 313 reportable chemicals constitute the
processing of that chemical. The relabeling and redistribution of Section 313 chemicals where
no repackaging of the Section 313 chemical has occurred would not be subject to reporting.
October 7, 1997
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TRI FORM R GUIDANCE DOCUMENT
CHEMICAL DISTRIBUTORS
The recovery of a listed Section 313 chemical from a mixture for further distribution is
considered processing of that chemical. Solvent recovery and other reclamation of Section
313 chemicals manufactured as a byproduct or otherwise used by the facility, that result in a
product (e.g., lacquer thinners and sprayer gun washer fluids) that are further distributed
beyond the facility should be considered in the threshold determination for processing activities.
ii;: . . Activity *i .pb
A -V' - '"'' '--, ' " -^ """. •''' - 4- ' 'f/t'S
As a formulation component
Repackaging
As a reactant
As an article component
#>, ; Examples jis .-\\
t"S .-^; *, ,., ~t : , s- i' •>• MT- •*§%£„ .^'-sf- ,W-
The blending of chemicals (many of which may be EPCRA
section 313 listed toxic chemicals) to formulate, for
example, lacquer thinner for autobody shops.
The repackaging of organic chemicals (liquids), such as
xylene, into various size containers for resale to customers.
May not occur in the chemical distribution industry group.
May not occur in the chemical distribution industry group.
The use of EPCRA Section 313 chemicals in support activities such as equipment cleaning and
maintenance activities (e.g., line flushing) is subject to the otherwise use activity threshold.
,.?.•$:-,•- .. Activity^ • •--*-;•%
y £&,•,( &'.'. or-*.' 't, : "*+. /i*~*'Sii**£s,& • ' . '.^AiMfv
As a chemical processing aid
As a manufacturing aid
» ;>, -•'•:•> #A.t Examples :-.*£•••.>.•: • -'J^M^'i i
- - * »&$&?& w *& ( ' " "'"/ '.-•,„ ^™x.' ;•*' ffc '/„,/// ',*-,, , -.}•"', • .". */' ,' v^'^wfwwllm, %'*/> ~ '• '*".
May not occur in the chemical distribution industry group
in amounts exceeding de minimis or threshold use.
Ammonia or CFCs, such as R-12 and R-13, are commonly
used as refrigerants. Refrigerators are necessary for the
storage of certain chemicals, such as flammable materials.
October?, 1997
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TRI FORM R GUIDANCE DOCUMENT
CHEMICAL DISTRIBUTORS
Ancillary or other use
Line flushing is performed using water or the chemical
(which maybe a listed TRI toxic chemical) that is next in
line to be processed.
Cleaners, lubricants, or degreasers used in the maintenance
of mixers, stationary cranes, and other processing
equipment.
* More complete discussions of the industry-specific examples can be found in Section 5 of this guidance manual.
CONDUCTING THE THRESHOLD DETERMINATION
STEP ONE
Identify Section 313 chemicals that are
manufactured, processed or otherwise used.
An activity threshold determination must
be made individually for each Section 313
chemical by each activity in which the
chemical is manufactured, processed, or
otherwise used at your facility. The
threshold determination is one criterion
used to ascertain whether a Form R or
Form A is required to be submitted.
The primary function of a chemical distribution facility is the warehousing, formulation and
repackaging of a variety of bulk chemicals prior to their distribution to a variety of destinations
including retailers, other wholesale facilities, and in some cases to manufacturing facilities for
industrial use or for product formulation. Most activities performed by chemical distribution
facilities may involve Section 313 chemicals that are "processed" (such as repackaging or
formulations activities), or "otherwise used" (such as equipment maintenance activities).
To perform a comprehensive and accurate threshold determination, the facility must first
determine what Section 313 chemicals (such as formaldehyde, sodium cyanide, and methyl ethyl
ketone) are "processed" or "otherwise used" at the facility during the year, and the amount for
each of those chemicals. The amount of chemical "processed" is the amount of chemical that the
facility intends to incorporate into its product. It is not just the amount that actually makes it into
the product but includes the associated releases and wastes generated. For threshold
determinations for Section 313 metal compound categories, the entire weight of the metal
compound must be applied towards the threshold, not just the weight of the metal itself.
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TRJ FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
STEP TWO
Identify "processing" and "otherwise use"
activities that are subject to exemptions.
Exclude chemicals associated with these
activities from your threshold
determination.
Any chemical purchased by facilities for
use as processing or manufacturing aids or
for treating waste are considered
"otherwise used". In addition, EPCRA
Section 313 chemicals in materials
purchased to be used as fuel or for
maintaining equipment operations, other
than for maintaining motor vehicles,
should be included in the threshold
determination for "otherwise use"
activities. Any EPCRA Section 313 chemicals in materials purchased to be used in the waste
management processes should also be included in the threshold determination for "otherwise use"
activities.
When performing your threshold determinations, it is important to remember that exemptions
apply to certain facility-related activities. These exemptions were discussed in Section 2 of this
guidance document and may apply only to certain "manufacturing," "processing," or "otherwise
use" activities. For the purposes of an activity threshold analysis, the following areas should be
examined closely to determine whether the TRI Section 313 chemicals subject to certain activities
should be included in the activity threshold and reporting calculations:
• Laboratories: Sampling and analysis, research and development (R&D), and QA/QC
activities undertaken in laboratories are exempt if conducted under the supervision of a
technically qualified individual. Pilot plants and support services, such as photo processing,
waste water treatment, and instrument sterilization are not exempt. Wastes generated during
sampling and analysis, R&D, and QA/QC activities in an on-site laboratory are exempt.
• Motor vehicles: Use of products containing Section 313 chemicals for the purpose of most
motor vehicle maintenance activities are exempt, as well as fuel used in those vehicles.
• Routine janitorial or facility grounds maintenance: 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. Equipment
maintenance such as the use of oil or grease is not exempt.
• Structural component of the facility: This exemption covers Section 313 chemicals that are
incorporated into the structural components of the facility (e.g., metal in pipes) or that are
used to ensure or improve the structural integrity of a structure (e.g., paint). The facility is
October?, 1997 3-4
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CHEMICAL DISTRIBUTORS
not required to report the releases of Section 313 chemicals that result from "passive"
degradation (degradation or corrosion that occurs naturally in structural components of
facilities).
Materials as they are drawn from the environment or municipal sources- Chemicals
contained in intake water (used for processing or non-contact cooling) or in intake air (used
either as compressed air or for combustion) are exempt from the activity thresholds.
However, EPCRA Section 313 chemicals manufactured from use of the air or water are not
exempt and must be considered for the threshold determination.
In making threshold determinations, it is
important that you keep in mind that a de
minimis exemption applies only to Section
313 chemicals in mixtures or trade name
products manufactured as impurities or
processed or otherwise use in mixtures or
trade name products. This exemption
does not apply to chemicals that are
manufactured as byproducts nor does it
apply to chemicals in wastes that are
processed or otherwise used.
Section 313 chemicals present at less than
1 percent (10,000 ppm) for chemicals that
do not meet the OSHA carcinogen
standard or less than 0.1 percent (1,000
ppm) for chemicals that do meet the
OSHA carcinogen standard do not have to
be considered when making your threshold
determinations for processing or otherwise x '
use. Appendix A to this document
contains the list of Section 313 chemicals subject to reporting, along with the de minimis
concentration associated with the chemical. The list of Section 313 chemicals in the publication
Toxic Chemical Release Inventory Reporting Form R and Instructions for the current reporting
year should also be checked to determine whether the list of chemicals has been updated (e.g.,
changes in listed chemicals and chemical categories, and de minimis levels).
Finally, some waste treatment activities may involve the conversion or reaction of chemicals
to produce a new Section 313 chemical, such as occurs with chemical oxidation or chemical
precipitation. When the new Section 313 chemical is produced, it is considered "manufactured"
under EPCRA Section 313 and subject to the 25,000 pound threshold.
STEP THREE
Determine whether TRI chemicals are
present in mixtures or trade name products
that are processed or otherwise used below
the de minimis concentration threshold and
eliminate from further consideration in your
processing and otherwise use threshold
determination those chemicals below de
minimis, unless those chemicals are later
concentrated. Also determine whether
chemicals are present as impurities below
the de minimis concentration threshold in
manufactured products and eliminate from
further consideration in your manufacturing
threshold determination those chemicals
below de minimis.
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CHEMICAL DISTRIBUTORS
Threshold determinations are made based
on the best available information in your
possession. However, if a facility is
aware that a chemical is probably present
in a mixture but has no information on its
concentration in the mixture, then they are
not required to consider that chemical in
its threshold determinations. Though, in
general, the following methods should be
employed to determine the appropriate
concentrations to use in threshold
determinations:
• If the extract concentration is known
(e.g., 33.0% toluene), use it.
STEP FOUR
Gather data needed for calculations of
threshold determination, including:
• Inventory Data
• Consumption Information
• Supplier Notification
• Sampling and Analysis Data
MSDS
• Analysis of Waste Products
• Permits
If only the upper bound is known (e.g., <5% toluene), use it (e.g., 5% toluene).
If the concentration is know (e.g., 10-30% toluene), then use the midpoint (e.g., 20%
toluene).
If only the lower bound is known, assume the upper bound is 100%. Factor out other known
constituents (e.g., 10% water and >60%toluene), create a range (e.g., 60-90% toluene) and
then use the midpoint (e.g., 75% toluene).
In cases where certain materials that have
broad ranges or high upper bounds for
multiple constituents (e.g.,
%x+%y+%z=l 10% of mixture), the total
components of a mixture should not
exceed 100%. In these instances, the best
available information should be used to
estimate the approximate concentration of
the chemicals in the material. However, if
a facility is aware that a chemical is
probably present in a mixture but has no
information on its concentration hi the
mixture, then they are not required to
consider that chemical in its threshold
determinations.
STEP FIVE
Calculate the quantity of each chemical
manufactured, processed and otherwise
used, in pounds, to determine whether the
activity threshold has been exceeded. The
Form R must be completed for each
chemical otherwise used in excess of 10,000
pounds and for each chemical processed in
excess of 25,000 pounds, for each chemical
manufactured in excess of 25,000 pounds.
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SECTION 4
OVERVIEW OF SECTION 313 RELEASE ESTIMATION
This section presents general guidelines for preparing Section 313 release estimates. It begins with
a discussion of general ideas on estimating chemical releases. A summary of errors that
commonly occur in Section 313 reporting follows.
GENERAL CONCEPTS
Release Estimation
A Form R or Form A must be completed for each Section 313 chemical that meets the applicable
activity thresholds. Each form requests facility specific information and identifies the chemical for
which thresholds were exceeded. Form A (the abbreviated report) includes a statement that the
facility did not exceed specified amounts while, the main components of Form R are
environmental release estimates to all media for the reportable chemical during the preceding
calendar year. This includes all wastes containing the reportable Section 313 chemical that are
sent off-site from the facility for further waste management. Specifically, facility release estimates
must be made for the following release sources:
• Releases to air from fugitive or non-point sources (Section 5.1)
• Releases to air from stack or point sources (Section 5.2)
• Releases to water directly discharged to a receiving stream (Section 5.3)
• Releases in wastes that are injected underground (Section 5.4)
• Releases to land on-site (Section 5.5)
• Releases to water discharged to a publicly owned treatment works (POTW) (Section 6.1)
• Wastes transferred off-site for recycling, energy recovery, waste treatment, or disposal
(Section 6.2)
Development of accurate and comprehensive release estimates requires consideration of all
possible release pathways. The threshold determination provides valuable information when
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beginning the release estimation process for a Section 313 chemical: each material containing a
Section 313 chemical is identified. For each of these materials, the facility should identify all
potential release sources. A useful way to do this is to draw a process flow diagram that traces
the material's path through the plant. The process flow diagram should identify each major piece
of equipment (including pollution control devices) through which the material passes, from its
initial entry into the facility to its final disposition. The diagram should also identify all potential
release sources and pollution control equipment for the chemical.
After you have identified all the potential release sources for a chemical, you can estimate releases
for each source. Often, the starting point for a release estimate is chemical throughput data,
which are typically available from threshold determination calculations.
Given the chemical throughput quantities for a process, you must apply other data and
assumptions to complete the estimates. This information includes process-specific data (e.g.,
scrubber efficiency) and any data developed for other environmentally oriented purposes (e.g., air
and wastewater monitoring data, air and water permits and permit applications, RCRA manifest
data, monitoring data).
Section 313 does not require any new monitoring to be performed. Facilities should use existing
data to calculate release estimates. The accuracy of a release estimate is proportional to the
quantity and quality of the data used in its preparation. Situations may arise where estimates
based on one set of data contradict estimates based on another. In such cases, the facility should
document the rationale for using one data set (or method) versus another. If a facility is aware
that a chemical is probably present but has no method to estimate releases or quantities on site,
then they are not required to report on that chemical. «
Release estimates can be developed by combining all available data with assumptions concerning
the fate of each chemical in the process. There are four general methods for developing a release
estimate. These methods may be used together or in sequence in developing release estimates.
• Direct measurement (basis of estimate code = M; entered in Part II Sections 5 and 6) -
These are estimates based on actual monitoring of the concentration of a chemical. The
chemical's concentration in the waste stream multiplied by the flow rate or volume of the
waste stream and its density yields the mass of the chemical released. Direct measurement is
typically used to estimate releases via wastewater, solid waste, and hazardous waste, in part,
to ensure compliance with applicable environmental regulations. Although this estimation
method should yield the most accurate results, only rarely are sufficient data available for
direct measurement data to be applied without also resorting to other techniques (e.g.,
engineering calculations, mass balance). The frequency of the direct measurements should be
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
taken into account when determining if monitoring data alone are sufficient for making a
reasonable estimate. For example, if a facility has only gathered monitoring data once
throughout the year, other methods may provide a more accurate estimate.
Note an indication that reportable chemical is below detection is not equivalent to stating
that the chemical is not present. If the reportable Section 313 chemical is known to be
present, a concentration equivalent to half the detection limit should be used in subsequent
calculations of release estimate quantities (i.e., if the limit of detection is 10 mg/1, release
calculations should be performed using a concentration of 5 mg/1). If the reportable
Section 313 chemical is not known to be present in the waste, then 0 percent can be
assumed.
• Mass balance (basis of estimate code = C entered in Part II, Sections 5 and 6) - These are
estimates based on a knowledge of the quantity of a chemical entering and leaving a process.
An imaginary boundary is first drawn around the process, and all streams entering or leaving
the boundary are identified. Assuming the amount of the chemical in the process input
streams is known, a facility could calculate the quantity in waste streams by difference. A
facility would need to account for any accumulation or depletion of the chemical within the
mass balance boundary. The equation for mass balance is:
Input + Generation = Output + Amount Reacted + Accumulation
Using a mass balance to estimate a relatively small release of a chemical with a large
throughput can lead to inaccurate, or even negative release estimates. Even a small
percentage error in a large throughput could amount to a greater quantity than the release
recalculated. When several large values each with their respective errors are used to calculate
a small release, propagation of errors occurs which could yield a highly inaccurate value.
Other techniques should be considered in these situations.
Mass balance estimates usually require engineering calculations or assumptions to be made
(e.g., all usage results in air or water releases). These assumptions should be explicitly stated
in the documentation and should be checked for reasonableness.
• Emission factors (basis of estimate code = E entered in Part II, Sections 5 and 6) - Release
information derived from facilities or processes similar to yours can be used to estimate
releases. Emission factors come in two forms. The first expresses releases as a ratio of the
amount of chemical released to facility throughput or production (e.g., 0.5 pound of Chemical
X released per every pound of Material Y used). The second provides a typical concentration
of a chemical in a waste stream (e.g., 0.1 mg/L of Chemical Z in wastewater from scrubbers).
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These factors, combined with process throughput or waste stream flow data, can be used as a
basis for the release estimate. Many emission factors are available in Compilation of Air
Pollutant Emission Factors (AP-42). AP-42 can be accessed via the Internet at
http://l 34.67.104.12/html/chief/chief.hmi#CH 13. The basis of estimate code "E" can only be
used for published Section 313 chemical-specific emission factors.
The reliability of emission factors depends on the quality and quantity of data used hi their
derivation, plus the similarity of the process to which they are applied and the quality of raw
materials for the process.
• Engineering calculations and assumptions (basis of estimate code = O entered in Part II,
Sections 5 and 6) - Estimates that do not fall into any of the above categories are considered
engineering calculations. Typically, these estimates are based on standard engineering
principles using properties of the chemicals involved, process data, or process knowledge.
Example chemical properties include vapor pressure, solubility hi water, and density. Example
process parameters include temperature, pressure, and material flow rate. Other examples of
engineering calculations would be the use of general equipment emissions factors or non-
published, facility-developed emissions factors.
Reasonable Estimates: Significant Figures and Use of Range Codes
EPA recommends that two significant figures be used when reporting release and off-site transfer
quantities in Part II, Sections 5 and 6 of Form R. Use of two significant figures may prevent
errors from being reported on Form R, because a small calculating error may not impact the final
reported quantity if the quantity is rounded to two significant figures. If you have reason to
believe that your best estimate of a release quantity is particularly imprecise, you could use one
significant figure or one of the range codes in reporting releases hi Part II, Sections 5 and 6 of the
Form R, if applicable:
Range Code A = 1 to 10 pounds
Range Code B = 11 to 499 pounds
Range Code C - 500 to 999 pounds
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
"NA" versus "0"
If you have no releases of a Section 313 chemical to a particular medium, report either "NA,"
not applicable, or "0," as appropriate. Report "NA" only when there is no possibility a
release could have occurred to a specific medium or off-site location. If a release to a specific
medium or off-site location could have occurred, but either did not occur or the annual
aggregate release was less than 0.5 pounds, report zero. However, if you report zero releases,
a basis of estimate must be provided. If use of the Section 313 chemical began in the
reporting year, enter "NA" as the production ratio or activity index (Part II, Section 8.9 of the
Form R).
For example, if nitric acid is involved in the facility's processing activities but the facility
neutralizes the wastes to a pH of 6 or above, then the facility reports a "0" release for the
Section 313 chemical. If the facility has no underground injection well, "NA" would be
written in Part I, Section 4.10 and checked in Part II, Section 5.4.1 and 5.4.2 of Form R.
Also, if the facility did not use the Section 313 chemical in the previous year, the facility
would have no basis to develop a production ratio or activity index, "NA" would be checked
in Part II, Section 8.9 of Form R.
REPORTING RELEASES IN FORM R, PART II
The following sections discuss the types of release reporting required on the Form R. Releases
must be partitioned into land and air releases and should not be inadvertently "double counted."
For example, a single wastewater discharge should not be listed as both a release to water (on-
site) and a discharge to a POTW (off-site), nor should a release to land be listed as a release to
both land (on-site) and a transfer to an off-site landfill. Also, subsequent releases from land (such
as a leak from an impoundment) to groundwater is included as a land release in the year the
leakage occurred. No reporting is required past the year in which it occurred. Even if it leaches
out to ground water in the next year.
It is important to note that historical releases are not included in release reporting. For example,
contamination around an underground storage tank (UST) is discovered, but there is no active
leak from the tank. If you know that the contamination occurred during the reporting year (RY),
then report the leak as a release to land. However, if the leak did not occur during the RY, it
should not be included in release reporting.
Finally, the amount of leaks or spills onto pads or containment areas should not automatically be
reported as released to land. The amount should be considered as treated or disposed depending
on type of disposal activity. After releases to air, amounts cleaned up and disposed of off-site,
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amounts recycled, and amounts released to water are considered, then the amount remaining on
the pad is considered to be released to land. Amounts spilled into containment that are directly
reused within the same reporting year without requiring treatment prior to reuse are not subject to
release reporting.
Fugitive or Non-Point Emissions (Part II, Section 5.1 of Form R)
Fugitive emissions can occur from almost any part of a facility's operation. Potential sources
include the following:
• Normal leakage of valves, pump seals, flanges, connectors, and other devices
• Sampling, Packaging, Loading, and unloading of chemicals
• Cleaning and maintenance activities such as blowing out pipes
• Containers of raw materials, intermediates, or wastes
• Storage piles and spills
• Evaporation from cooling towers, ponds, surface impoundments, and on-site wastewater
management systems (including on-site sewers)
• Drum residues
Where actual monitoring or measurement
data are not available, data sources and
calculation methods that could be
employed in estimating fugitive emissions
include the following:
• Industrial Hygiene monitoring data
• AP-42 emissions factors (listed in
Tables 4-land 4-2)
• SOCMI emission factors (listed in
Table 4-3)
• Facility-specific emission factors
• Mass balance (for volatile solvents)
• EPA models such as WATER8 for
wastewater management systems
• Data from a leak detection and repair
(LDAR) program
• Engineering calculations
CHEMDAT8
Analytical models have been developed to estimate
emissions of organic compounds via various pathways
from wastewater and waste management units. Some of
these models have been assembled into a spreadsheet
called CHEMDAT8 for use on a PC. A user's guide
for CHEMDAT8 is also available. Area emission
sources for which models are included in the
spreadsheet are as follows: nonaerated impoundments,
which include surface impoundments and open top
wastewater treatment tanks; aerated impoundments,
which include aerated surface impoundments and
aerated WWT tanks; disposal impoundments, which
include nonaerated disposal impoundments; land
treatment; and landfills. These models can be used to
estimate the magnitude of site air emissions for
regulatory purposes. The CHEMDAT8 program and
manual can be downloaded from the world wide web at
http://www.epa. gov/ttnchie 1 /ees. htmlfrwaterS
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CHEMICAL DISTRIBUTORS
CHEMDAT8 and TANKS
Table 4-1. SOCMI AVERAGE EMISSION FACTORS*
Equipment tjpe /*
Valves
Pump seals'5
Compressor seals
Pressure relief valves
Connectors
Open-ended lines
Sampling connections
^Service ' , 0 iH
Gas
Light liquid
Heavy liquid
Light liquid
Heavy liquid
Gas
Gas
All
All
All
Emission factors3 (Ipsftir/source)^*
0.0131
0.00887
0.00051
0.0438
0.0190
0.502
0.229
0.00403
0.0037
0.033
*ProtocoI for Equipment Leak Emission Estimates (EPA, EPA-453/R-95-017)
a These factors are for total organic compound emissions
b The light liquid pump seal factor can be used to estimate the leak rate from agitator seals
Example Fugitive Emission Calculation Using SOCMI Emission Factors
A process has 100 flanges (connectors) which are in contact with a mixture containing
50% benzene (by weight) during 8000 hours of the year. What are the fugitive
emissions of benzene from this process?
Emission = emission factor x # of valves x concentration of chemical x # of hours
Emission = 0.00403 Ib/hr/source x 100 sources x 50% benzene x 8000 hours
Emission =1612 pounds of benzene
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Stack or Point-Source Air Emissions (Part II, Section 5.2 of Form R)
Point-source air emissions can occur from
numerous pieces of process equipment
throughout a facility. Potential sources
include the following:
• Air pollution control devices such as
scrubbers, condensers, baghouses
• Storage tanks, process tanks, and waste
tanks
• Process vessels such as reactors and
distillation columns
Where actual monitoring or measurement
data are not available, data sources and
calculation methods that could be
employed in estimating stack or point
source emissions include the following:
• Air emission inventories
• Air permit applications
• Process and production data
• Emission factors from EPA and
commercial models
• Engineering calculations
Typical releases from tanks at chemical
distributor facilities will include breathing
losses to air and working losses to ah-.
Air emissions from tanks depend
primarily on the quantity of materials
handled, the chemical composition of the
materials, and the number, size, and type
of tanks. Several options are available for
Acid Aerosols Generated in Storage Tanks
Sulfiiric and hydrochloric acid aerosols are generated in
the empty space (head space) above sulfuric and
hydrochloric acid solutions contained in storage tanks.
The amount of acid aerosol to be applied towards the
"manufacture" threshold is the average amount that
existed in the head space during the year. Each facility
should determine the average conditions for their storage
tank (i.e., capacity, average amount stored, average head
space, acid concentration, temperature, etc.). If the
storage tank is refilled and drawn down several times
during the year, calculations should be based on all of the
acid stored in the tank. For example, if a 10,000 pound
capacity tank is refilled and drawn down six times during
the year (such that 60,000 pounds of acid were stored in
the tank during the year) then the tank calculations, based
on tho average condition for ono 10,000 pound tank i
be multiplied by 6.
The TANKS program is designed to estimate emissions
of organic chemicals from several types of storage tanks.
The calculations are performed according to EPA's
AP-42, Chapter 12. After the user provides specific
information concerning a storage tank and its liquid
contents, the system produces a report which estimates
the chemical emissions for the tank on an annual or
partial year basis. The user can also determine individual
component losses by using one of the specification
options available in the program.
The TANKS program relies on a chemical database of
over 100 organic liquids and a meteorological database
which includes over 250 cities in the United States; users
may add new chemicals and cities to these databases by
providing specific information through system utilities.
On-line help provides documentation and user assistance
for each screen of the program. The TANKS program
and manual can be downloaded from the Internet at
http://l 34.67.104.12/html/chief/tank-dn.htm.
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TPT FORM R GTTTDANrF DOr.TTMFNT
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calculation of releases from storage tanks. Numerous equations and emission factors are available
in the EPA publication, Compilation of Air Pollutant Emission Factors (AP-42). For example,
Section 4.3 of AP-42 presents equations used for estimating VOC emissions from wastewater
collection, treatment, and storage systems. Many of these equations have been incorporated into
computer models such as TANKS (See box on TANKS for more information).
Another source of information for chemical distribution facilities to use in calculating air
emissions of reportable Section 313 chemicals is the calculations the facilities uses to calculate
total volatile organic compounds (VOC) to ensure compliance with 40 CFR Parts 264/265
Subpart CC (Air Emissions Standards for Tanks, Containers, and Surface Impoundments) or
other air emission regulations. Because those regulations focus on total VOC content, the VOC
emission rates would need to be speciated in order to use this information for TRI reporting.
Furthermore, TRI requires estimates of actual emissions of a given reportable Section 313
chemical, which could be substantially different (e.g., lower) than permitted quantities. However,
those calculations typically should be based on production measures, which could be adjusted to
reflect actual production data for the reporting year.
Wastewater Discharges (Part II, Section 5.3 and 6.1 of Form R)
Discharges to a stream or water body are reported in Part II, Section 5.3 of Form R, while
transfers to Publicly Owned Treatment Works (POTWs) are reported in Part II, Section 6.1 of
Form R. Because the release estimation approach is similar for both types of wastewater
discharges, they are discussed here together.
A facility that discharges or has the
potential to discharge water containing
regulated wastes must operate under the
terms of Federal, State, and/or local
permits, such as a NPDES direct
discharge permit, or a POTW indirect
discharge agreement. The permit(s) or
agreement usually require measurements
of the water volume and monitoring and
analyses of some generalized wastewater
parameters including concentrations of
various constituents. In some cases,,the
constituent analyses required for permit
compliance includes Section 313
chemicals. In these instances, releases can
WATERS
A computer program, WATERS, is available for
estimating the fate of organic compounds in various
wastewater treatment units, including collection systems,
aerated basins, and other units. WATERS is written to
run under DOS without the need to purchase other
programs. WATERS contains useful features such as the
ability to link treatment units to form a treatment system,
the ability for recycle among units, and the ability to
generate and save site-specific compound properties. The
WATERS program and users manual can be downloaded
from the world wide web at
htto://! 34.67.104.12/html/chief/dat7-dn.htm.
be calculated by multiplying the volume of wastewater
October?, 1997
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released by the concentration of the chemical released. Releases discharged to a POTW should be
reported as off-site transfers on Part II, Section 6.1 of Form R.
Based on the concentration and
wastewater flow data available, an
estimate of discharges to water can
be calculated. Facilities should
calculate the daily average
discharges of a reportable Section
313 chemical in pounds and must
use those estimates to determine
the annual discharge in pounds per
year. Using the daily concentration
data available for the reportable
chemical combined with the
wastewater flow data for each of
the sampling dates, calculate an
estimate of pounds per day for
each sampling date. After the
calculations are made for each
monitoring point (e.g., daily,
monthly), the pounds discharged
are averaged to determine an
average daily discharge amount
which would be multiplied by the
number of days discharges were
possible (e.g., 365 days a year).
Example Calculation of Yearly Wastewater
Discharge
A facility has monitoring data on discharges to water of xylene, a
listed Section 313 chemical, and a Form R report is required. In
this example, monitoring data on this chemical are only available
for two days in the year. The daily quantities of pounds of xylene
released for those two dates would then be divided by the number
of sample dates to determine the daily average for the whole
reporting year, which would be used to estimate the annual
discharge of xylene in wastewater:
,Date
3/1/96
9/8/96
Concentration
(me/I)
1.0
0.2
Flow
(MGD)
1.0
0.2
Daily
Discharge
8.33 Ibs.
0.332 Ibs.
Annual Calculation:
8.33 Ibs. + 0.332 lbs./2 days x 365 days/year = 1580.82 Ibs/yr
If no monitoring data exist, NPDES permit applications or POTW agreements may provide
information useful to estimating releases. Otherwise, process knowledge (or in some cases, mass
balance) needs to be utilized to develop an estimate.
Discharges of listed acids may be reported as zero if all discharges have been neutralized to pH 6
or above. If wastewater containing a listed acid is discharged below pH 6, then releases of the
acid must be calculated and reported. For more information on calculating such discharges of
acids, see EPA's Estimating Releases of Mineral Acid Discharges Using pH Measurements
(EPA745/F-97-003, June 1991).
Underground Injection On-Site (Part II, Section 5.4 of Form R)
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A facility that has an underground
injection well for waste disposal is
regulated by Safe Drinking Water Act
(SDWA) permits. The permit(s)
usually require measurements of the
waste volume and analyses of some
generalized waste parameters including
concentrations of various constituents.
When the constituents for which the
permit requires analyses include
reportable Section 313 chemicals,
releases via underground injection can
be calculated by multiplying the volume
of waste injected by the concentration
of the chemical in the waste. Facilities
must report amounts of Section 313
chemicals injected into Class I wells
(Part II, Section 5.4.1 of Form R) and
amounts injected into Class II-V (Part
II, Section 5.4.2 of Form R).
Release to Land On-Site (Part II,
Section 5.5 of Form R)
In most circumstances involving the
disposal of many Section 313
chemicals, land disposal is regulated by
RCRA and state regulations. In part II,
Section 5.5, TRI is concerned with the
total amount of the specified reportable
Section 313 chemical released to land,
regardless of the potential for the
chemical to leach from the disposed
waste.
Estimating Releases for Accidental Losses
Leaks, spills, and drips from the loading and transfer of
chemicals received at the facility should be considered and
reported in your release estimates. Data concerning specific
incidents (such as notification reports or incident logs)
should be included in release estimates. Equations found in
Section 6 of EPA's Estimating Releases and Waste
Treatment Efficiencies for the Toxic Chemical Release
Inventory Form (EPA 560/4-88-002, December 1987),
provides guidance on calculating releases from chemical
spills or leaks, including liquid discharges, fraction of
discharge flashed, vaporization, two-phase discharges, and
gas discharges.
EXAMPLE: A forklift operator hits a 50-gallon drum of
toluene and a spill occurs. It is estimated that 75% of the
toluene was released as a liquid and pooled on the ground.
In addition, it is estimated that 25% of the toluene vaporized
directly to the air from the rupture. How would these
releases be reported on the Form R? Assume a reported
threshold for toluene has been exceeded, the density of
toluene is 7.2 pounds per gallon, and the vapor pressure is
21.1 mmHgat68°F.
Quantity spilled = 50 gal x7.2 lbs./gal = 360 ibs.
Amount sent off site = 360 x 75% = 270 Ibs.
Amount vaporized = 360 x 25% = 90 Ibs.
Air emissions of toluene are expected due to the high vapor
pressure. Therefore, the total amount reported in Section
8.8 is the 270 pounds that pooled on the ground (and was
subsequently sent off-site), plus the 90 pounds that
vaporized in to the air, a total of 360 pounds. The quantity
that is sent off-site must also be reported in Section 6 (but
not in Section 8.7) and the quantity that vaporized must be
reported as a fugitive emission in Section 5 (but not in
Section 8.1). The code for final disposition should be used
in Section 6..
On-site disposal includes disposal in an
on-site RCRA Subtitle C landfill (Part
II, Section 5.5.1A of Form R), disposal hi other on-site landfills (Part II, Section 5.5. IB of Form
R), disposal hi a land treatment/application farming unit (Part II, Section 5.5.2 of Form R), and
disposal in a surface impoundment (Part II, Section 5.5.3 of Form R). Data concerning these
October 7, 1997
4-11
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TRI FOPJV1 R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
types of "intentional" on-site disposal are usually readily available because facilities are required to
monitor the quantity of waste and will have a waste profile that describes typical concentration
ranges for waste constituents. In some cases, concentrations of constituents in the waste have
been measured. If on-site waste treatment occurs prior to on-site land disposal, the treatment
efficiency and a mass balance can be conducted to determine the quantity of a chemical that is
land disposed. For example, a facility can determine the amount of the chemical present in the
untreated waste, determine the efficiency of treatment in removing or destroying the chemical in
the waste, account for other releases (i.e., fugitive emissions, leaks, spills, accidental releases,
losses to air pollution control devices, etc.), and determine that the remainder is the quantity of
the chemical land disposed.
Releases to land on-site/other disposal (Part II, Section 5.5.4 of Form R) include the amount of
chemical released to land on site not covered by any of the above categories and include spills,
leaks, or "unintentional" disposal, such as metal dust that is deposited onto soil. Incident logs or
spill reports can provide useful information.
Transfers in Wastes to Other Off-site Locations (Part II, Section 6.2 of Form R)
Similar to on-site disposal, data concerning off-site waste transfers are usually readily available
because facilities are required to monitor the quantity of waste and either measure concentrations
of chemicals or develop a waste profile that describes typical concentration ranges. Under
Section 313, off-site transfer estimates are based on the final, known disposition of the reportable
Section 313 chemical in the waste sent off-site for further waste management. For example, a
reportable Section 313 metal is contained in a waste solvent sent off-site for energy recovery
purposes. Even though the waste stream as a whole has a sufficient heat value to warrant energy
recovery, metals do not have a significant heat value and, therefore, cannot be combusted for
energy recovery. Unless the facility had additional information on the fate of the reportable
Section 313 metal in this waste, the facility must assume the metal is being disposed and should
report the quantity sent off-site accordingly in Part II, Sections 6.2 and 8.1 of Form R.
Even wastes that were minimally processed, such as wastes that were repackaged, such as small
containers removed from a lab pack that were not otherwise opened or managed, may need to be
reported if the article exemption (as discussed in Section 2) is not applicable.
On-site Waste Treatment Methods and Efficiency (Part II, Section 7A of Form R)
In Section 7A, the following information must be reported:
• General waste stream types containing the Section 313 chemical being reported;
October 7, 1997 4-12
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TR! FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
• Waste treatment methods or sequence used on all waste streams containing the Section 313
chemical;
• Range of concentration of the Section 313 chemical in the influent at the first step in a waste
treatment system;
• Efficiency of the waste treatment method or sequence in destroying or removing the Section
313 chemical; and
• Indication of whether the efficiency estimate was based on actual operating data.
Report any waste treatment step through which the reportable Section 313 chemical passes
regardless of treatment efficiency. Report all non-identical parallel steps and all sequential steps.
Waste treatment for the purpose of Section 7A is defined as removal of the Section 313 chemical
from the waste through destruction, biological degradation, chemical conversion, or physical
removal. Note that this definition of waste treatment is broader than the definition used in Part II,
Section 8 of Form R (discussed later). Section 7A treatment efficiency is calculated as follows:
percent efficiency = input - output x 100%
input
If your facility has a measurement of the pollutant concentration of input and output at the
treatment unit, these data should be used to calculate the treatment efficiency. If these
measurements are not available, data from literature or the equipment manufacturer can be used
for estimation purposes. Equipment manufacturer data on treatment efficiencies often represent
ideal operating conditions with an ideal waste matrix. Thus, you may want to adjust such data to
account for downtime, process upsets, and other less than optimum conditions during the year
that would result in lower efficiencies.
Estimates of treatment efficiencies by process for EPCRA Section 313 chemicals are available
from the ATTIC database via modem from ATTIC by calling data number (513) 569-7610.
Additional information can be obtained by calling the ATTIC Hotline at (513) 569-7272.
On-site Energy Recovery Processes (Part II, Section 7B of Form R)
In Section 7B, methods used to combust the Section 313 chemical in wastes for energy recovery
are reported. Two conditions need to be met to report the combustion of a Section 313 chemical
as energy recovery: (1) the chemical must have a heat of combustion high enough to support
combustion (e.g., 5,000 BTU per pound or greater), and (2) must be combusted in a unit
equipped with an energy recovery device, such as a waste heat boiler.
October?, 1997 4-13
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DTCTPTBTTTr'1I?<':
On-site Recycling Processes (Part II, Section 7C of Form R)
In Section 1C, methods used to recycle the Section 313 chemical in wastes are reported.
Source Reduction and Recycling Activities (Part II, Section 8 of Form R)
The following discussion for Sections 8.1 through 8.7 applies to the current reporting year (i.e.,
column B of Section 8 of the Form R).
Quantity Released (Part II, Section 8.1 of Form R)
The quantity reported in Section 8.1 is the quantity reported hi all of Section 5 plus the quantity
reported as sent off-site for disposal in Section 6.2 minus the quantity reported in Section 8.8 that
was released or transferred off site for disposal:
§8.1 = §5 + §6.2 (disposal only) - §8.8 (release or off-site disposal only)
Section 6.2 disposal codes are M10, M71, M72, M73, M79, M90, M94, and M99. In addition,
EPCRA Section 313 listed metals in waste streams sent off-site to POTWs or other off-site
locations for treatment for destruction should be reported in Section 8.1, unless the facility has
knowledge that the metal is being recovered.
Quantity Used for Energy Recovery On-site (Part II, Section 8.2 of Form R)
Estimate a quantity of the Section 313 chemical hi wastes combusted for energy recovery on-site.
This estimate should be the quantity of the chemical combusted in the process for which codes
were reported hi Section 7B. Test data from trial burns or other monitoring data may be used to
estimate the quantity of the Section 313 chemical combusted for energy recovery purposes. If
monitoring data are not available, vendor specifications regarding combustion efficiency may be
used as they relate to the reportable Section 313 chemical. A quantity must be reported in
Section 8.2 when a method of on-site energy recovery is reported hi Section 7B and vice versa.
Two conditions need to be met to report the combustion of a Section 313 chemical as energy
recovery: the chemical (1) must have a heat of combustion high enough to support combustion
(e.g., 5,000 BTU or greater), and (2) must be combusted in a unit equipped with an energy
recovery device, such as a waste heat boiler. Note that "NA" should be reported for Section 313
chemicals which are Halons (e.g., CFCs) and metals that do not have a heat of combustion
sufficient to sustain combustion.
October 7, 1997 4-14
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TPJ FORM R. GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
Quantity Used for Energy Recovery Off-site (Part II, Section 8.3 of Form R)
The quantity reported in Section 8.3 is the quantity reported in Section 6.2 for which energy
recovery codes are reported. Section 6.2 energy recovery codes are M56 and M92. If a quantity
is reported in Section 8.8, subtract any associated off-site transfers for energy recovery:
§8.3 = §6.2 (energy recovery) - §8.8 (off-site energy recovery)
Quantity Recycled On-site (Part II, Section 8.4 of Form R)
Estimate a quantity of the Section 313 chemical recycled in wastes on-site. This estimate should
be the quantity of the chemical recycled in the process for which codes were reported in Section
1C. A quantity should be reported in Section 8.4 when a method of on-site recycling is reported
in Section 7C and vice versa. To estimate this quantity, you should determine if operating data
exist which indicate a recovery efficiency and use that efficiency value combined with throughput
data to calculate an estimate. If operating data are unavailable, use available vendor
specifications.
Quantity Recycled Off-site (Part II, Section 8.5 of Form R)
The quantity reported in Section 8.5 must be the same as the quantity reported in Section 6.2 for
which recycling codes are reported. Section 6.2 recycling codes are M20, M24, M28, and M93.
If a quantity is reported in Section 8.8, subtract any associated off-site transfers for recycling:
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling)
Quantity Treated On-site (Part II, Section 8.6 of Form R)
Waste treatment hi Section 8 is limited to the destruction or chemical conversion of the Section
313 chemical. The quantities reported hi Section 8.6 will be those treated hi a subset of the
processes for which codes were reported in Section 7A, where treatment includes physical
removal from a waste stream. To estimate this quantity, you should determine if operating data
exist which indicate a treatment (e.g., destruction or chemical conversion of Section 313
chemical) efficiency and use that efficiency value combined with throughput data to calculate an
estimate. If operating data are unavailable, use available vendor specifications. Section 7A must
be completed if a quantity is entered hi Section 8.6.
October?, 1997 4-15
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
Quantity Treated Off-site (Part II, Section 8.7 of Form R)
The quantity reported in Section 8.7 must be the sum of the quantities reported in Section 6.2, for
which treatment codes are reported, and the quantities reported in Section 6.1, which were sent to
a POTW. Section 6.2 waste treatment codes are M40, M50, M54, M61, M69, and M95. If a
quantity is reported in Section 8.8, subtract any associated off-site transfers for treatment:
§8.7 = §6.1 + §6.2 (treatment) - §8.8 (off-site treatment).
Because metals cannot be destroyed or chemically converted, metals cannot be reported as treated
in Section 8. Quantities of metals reported in Section 6.1 and 6.2 as being treated should be
reported in Section 8.1 (Quantity released), unless the facility has knowledge that the metal is
being recovered.
Quantity Released to the Environment as a Result of Remedial Actions, Catastrophic
Events, or One-time Events Not Associated with Production Processes (Part II, Section 8.8
of Form R)
The quantity reported in Section 8.8 is the quantity of the Section 313 chemical released directly
into the environment or sent off-site for recycling, waste treatment, energy recovery, or disposal
during the reporting year due to any of the following events:
(1) Remedial actions
(2) Catastrophic events such as earthquakes, fires, or floods
(3) One-tune events not associated with normal or routine production processes
The quantity reported in Section 8.8 should not be included with quantities reported in Part II
Sections 8.1 through 8.7 of Form R, but should be included in Part II, Sections 5 and 6 of Form
R as appropriate.
Spills that occur as a routine part of production operations and could be reduced or eliminated by
improved handling, loading, or unloading procedures are included hi the quantities reported in
Section 8.1 through 8.7 as appropriate. Releases and off-site transfers from remediation of a
Section 313 chemical or an unpreventable accident unrelated to production (such as a hurricane)
that cause a reportable Section 313 chemical to be released are reportable in Section 8.8.
October?, 1997 4-16
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-TOT T7/^uiv^ t> rL
On-site treatment, energy recovery, or recycling of Section 313 chemicals in wastes generated as
a result of remedial actions, catastrophic events, or one-time events associated with production
processes are not reported in Part II, Section 8.8 nor Sections 8.1 through 8.7 of Form R.
October?, 1997 4-17
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-TRT i?r»T?iv/f D rujmAMrp nnrrTA/TPXTT rwFiwrrr'AT
October?, 1997 4-18
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TT?T
SECTION 5
CALCULATING RELEASE ESTIMATIONS AT CHEMICAL AND ALLIED
PRODUCTS - WHOLESALE, NOT ELSEWHERE CLASSIFIED
In Section 4, the tools and techniques available for estimating releases to the environment and
reporting disposition of wastes (including transfers off-site, land disposal, underground injection,
and wastewater discharges) were discussed. This section provides guidance on how chemical
distribution facilities report these releases and waste dispositions on the Form R. Typical
operations and the resulting wastes and releases are discussed.
Chemical distribution facilities should evaluate their activities on a site-specific basis. This
guidance is a starting point for considering possible releases and evaluating estimation methods.
Developing accurate and comprehensive release estimates requires the consideration of all
possible release pathways. Figure 5-1 identifies some of those release pathways for a hypothetical
site.
Chemical distribution facilities in SIC Code 5169 are involved in the warehousing, storage, and
refrigeration of products such as acids, industrial and heavy chemicals, dyestuffs, industrial salts,
rosin, and turpentines. These facilities are also engaged in the formulation and repackaging of
Storage/
ar chousing
Repackaging
Plant
2t4aintenan.ee
&. S upr>ort
~W as tew ater
Treatment
Plant
Products
Publicly
Owned
Treatment
AVorkis and/or
Water Body
Off-Site Waste Management
^™ ™ Fugitive Emissions
Stack: Emissions
Figure 5-1 Chemical Distributor Operations and Potential Releases
October 1, 1997
5-1
-------
TRI FORM R GUIDANCE DOCUMENT '~'1-rEMIr'AL
bulk or packaged materials to be transferred offsite. In addition, chemical distribution facilities
perform plant maintenance activities and wastewater treatment. All the above activities may
result in releases containing Section 313 chemicals.
Warehousing and Storage Activities
Chemical distributors typically use warehouses to store goods for the purpose of consolidating
small shipments or to improve the effectiveness of both manufacturing and marketing (e.g.,
matching supply to demand). Simple warehousing operations consisting of the loading, storage,
and offloading of packaged materials, are not considered to have undergone a "manufacturing",
"processing", or "otherwise use" activity. However, during the course of warehousing operations
some materials (possibly Section 313 chemicals) will become unsalable due to accidents.
Accidents may either occur when containers are moved in and out of the warehouse (e.g., a
forklift punctures a storage drum) and from sloppy storage procedures at the warehouse (e.g., a
storage bag splits opens from too much weight on top of it), or they may be the result of damages
that occurred during transport and are then assessed at the warehouse (e.g., several small bottled
chemicals overturned during transport and the spill is realized upon unloading of the truck). A
warehouse operator would salvage and repackage as much of the goods as possible and dispose
of the remaining goods. As a result of incidents such as these air, land, and water releases can
occur.
In addition, Section 313 chemical releases can occur during storage operations. Chemicals may
be stored in a variety of containers such as above ground and underground storage tanks, tote
bins, drums, sample bottles, supersacs, and bags. The puncture, leak, or rupture of any of these
containers could result in a potential release of Section 313 chemicals to the air, water, or soil.
The greatest potential for releases during storage is through air emission. Emissions from
chemical storage occurs because of evaporative loss of the liquid during its storage and as a result
of changes in the liquid level. Emissions from fixed roof tanks are a result of evaporative losses
during the storage (known as breathing losses or standing storage losses) and evaporative losses
during filling and emptying operations (known as working losses). External and internal floating
roof tanks are emission sources because of evaporative losses that occur during standing storage
and withdrawal of liquid from the tank. Standing storage losses are a result of evaporative losses
through rim seals, deck fittings, and/or deck seams. These amounts would be considered in the
facility's release and other waste management estimates provided that the facility has exceeded an
"threshold activity" as discussed below.
October?, 1997 5-2
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TPJ FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBU'rr'r>c
Some potential releases or waste generation sources associated with warehousing and storage are:
• Releases from the puncturing of liquid containers (fugitive air emissions are most likely to
occur with the potential for land and/or water release, §5.1, §5.3, §6.1, and/or §5.4),
• Accidental release of dust and participate fugitive emissions from the puncturing of solid
containers bags (fugitive air emissions, §5.1),
• Working and breathing emissions from storage tanks (point source emissions, §5.2),
• Leak in an underground storage tank (land releases, water releases and/or fugitive air
emissions (air emissions are possible if the storage tank is located close to the surface, §5.3,
§5.4, §6.1, and/or §5.1),
• Air emission leaks from valves or flanges (fugitive emissions, §5.1),
• Transfer of waste off-site for future waste management (§6.2).
Transfer and Formulation
The loading and off-loading of chemicals from tank trucks, rail cars or barges can provide a
significant source of release into the environment via air emissions and drips or spills entrained in .
rainwater. Typically, a loading line is used for unloading a tank truck into a large tank, and then,
at a later time, transferring the chemical into small drums to be sent to customers. Even where
the equipment used in chemical transfers is well designed to fit tightly and function automatically,
emissions do occur. Air emissions of TRI listed chemicals can occur when opening and
connecting tanks (e.g., venting, gaging, filling, and withdrawing and loading operations) and from
such sources as hoses, piping, lines, and transfer pumps.
The accumulation of rainwater can occur around diked areas. A facility will often place a dike
around drum, semi-bulk, or bulk storage areas, and around all hose connections, pipe manifold,
and packaging areas. The accumulation of stormwater runoff can also occur around drum storage
areas, yard areas, truck parking areas, truck unloading areas, and product transfer areas (e.g.,
hose and loading line hook-ups). A facility must report the amount of Section 313 chemicals in
stormwater runoff (including unchanneled runoff), if the facility already monitors for these
releases. If a facility does not have periodic measurements of stormwater releases, but has
submitted chemical-specific monitoring data in permit application, then it must use these data to
calculate the percent contribution from stormwater. This information would be reported in
Section 5.3 of the Form R. If a facility did not detect any toxic chemical in the storm water or
does not monitor for these releases, zero (0) or "N/A" would be reported on the Form,
respectively.
October 7, 1997 5-3
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TPT T?OT?IU R ruTmAWP nnrTTA/TPMT r-trpiv/rrr'AT
Example of Stormwater Runoff
A facility is located in a semi-arid region of the United States which has annual precipitation (including
snowfall) of 12 inches of rain. (Snowfall should be converted to the equivalent inches of rain; assume one foot
of snow is equivalent to one inch of rain.) The total area covered by the facility is 42 acres (about 170,000
square meters or 1,829,520 square feet) of which 50 percent is unimproved area, 10 percent is asphaltic
streets, and 40 percent is concrete pavement.
The total stormwater runoff from the facility is therefore calculated as follows:
Land Use % Total Area Runoff Coefficient
Unimproved area 50 0.20
Asphaltic streets 10 0.85
Concrete pavement 40 0.90
Weighted runoff coefficient = (50%) x (0.20) + (10%) x (0.85) + (40%) x (0.90) = 0.545
(Rainfall) x (land area) x (conversion factor) x (runoff coefficient) = stormwater runoff
(1 foot) x (1,829,520 ft2) x (7.48 gal/ft3) x (0.545) = 7,458,220 gallons/year
Total storm water runoff = 7.46 million gallons/year
The stormwater monitoring data shows that the average concentration of cumene in the stormwater runoff from
a facility is 1.0 milligrams per liter. The total amount of cumene discharged to surface water through the plant
wastewater discharge (non-storm water) is 250 pounds per year. The total amount of cumene discharged with
stormwater is:
(7,458,220 gallons stormwater) x (3.785 liters/gallon) = 28,229,360 liters stormwater
(28,229,360 liters stormwater) x (1 mg. cumene/liter) x (1 x 10"6) = 28.2 kg cumene= 62 pounds cumene.
The total amount of cumene discharged from all sources of your facility is:
250 pounds cumene from wastewater discharged
. +62 pounds cumene from stormwater runoff
312 pounds cumene total water discharged
312 pounds of cumene is reported in section 5.3A on Form R
The percentage of cumene discharge through stormwater reported in section 5.3C on Form is:
62-312x100 = 20%
October 7, 1997 5-4
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/-1TTT7A IT\r\ A T
V---1 AJJ/iV-
1_/J.D 1 J.VIJJ V_J 1 WJ.XO
Stormwater runoff rate of flow can be estimated by multiplying the annual amount of rain fall by
the land area of the facility and then multiplying that figure by the runoff coefficient. The runoff
coefficient represents the fraction of rainfall that does not seep into the ground but runs off as
Stormwater and is directly related to how the land in the drainage area is used. The runoff
coefficient can be found in Section 5 of the TRI Reporting Form R and Instructions or a facility
can calculate a weighted run-off coefficient that will take into account the different types of land
uses at a particular facility.
Many chemical distribution facilities are involved in the blending or formulation of different
chemicals (some of which may be EPCRA Section 313 chemicals). Blending/formulation can
occur hi drums in which chemicals are added in a specific order, or by air mixing within drums to
formulate the new product. An example is the blending of chemicals (many of them Section 313
listed chemicals) for the formulation of lacquer thinner used at autobody shops. The potential for
fugitive emissions is particularly great in a case where a drum is opened and closed several times
allowing volatile gases to escape into the surrounding environment. Some potential releases or
waste generation sources associated with repackaging or reformulation/blending are:
• Ah- emissions leaks from pump seals and/or compressors used hi the transfer of compounds
(fugitive emissions, §5.1)
• Air emissions occurring through pipes, stacks, or ducts during formulation (stack or point
source emissions, §5.2)
• Hose rupture during the loading and/or unloading of a tank truck (fugitive air emissions, land
and/or water releases, §5.1, §5.3, §6.1 and/or §5.4, plus the amount of waste that may be sent
off-site, §6.2)
• Spillage during the formulation or packaging of a chemical (fugitive air emissions, land and/or
water releases, §5.1, §5.3, §6.1 and/or §5.4)
• Stormwater accumulations around drum storage areas (§5.3 or §6.1)
Plant Maintenance and Support Activities
Potential Section 313 Chemicals Involved in Plant
Maintenance
Ammonia, CFC-12, CFC-13
Formaldehyde
Chloroform
Source
Ak conditioning and refrigerant
Loading line flushing
Drum or tank rinsing
October?, 1997
5-5
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TRI FORM R GUIDANCE DOCUMENT ^HEMICAL
Wastewater is produced from the process of loading line cleaning. A facility may route a number
of different chemicals through a single loading line over time. In order to ensure the purity of the
different chemicals and prevent contamination of products, the entire line is flushed every time a
different chemical is processed. The line may be flushed with water, or to ensure the line is
completely rinsed clean, with the chemical (possibly a Section 313 chemical) that is to be
processed next. The use of a Section 313 chemical in line flushing applies to the otherwise use
threshold of 10,000 pounds. The flushed out material, containing wastewater and chemicals
(some of which may be Section 313 chemicals) is then handled in one of three following ways:
• (1) The majority of the collected wastewater is collected over time and then sent off-site for
recycling, energy recovery, and/or disposal. The amount of waste that is sent off-site for
recycling, energy recovery and/or disposal would be reported in Sections 6.2 and in Sections
8.1, 8.3 or 8.5, as appropriate.
• (2) Some facilities perform on-site wastewater treatment. For example, a facility may
neutralize the line-flushing wastewater and chemicals that are processed to verify cleanliness
of hoses prior to further processing. This information would then be reported in Part II,
Section 7A of Form R with the code Cl 1 (Neutralization).
• (3) Some facilities may recycle the flushed out material for reuse in future formulations or
blends. The amount of Section 313 chemical that is utilized on-site for future formulations
would be reported at a later time when it is "processed" during formulation activities and
amounts would then apply to the processing threshold of 25,000 pounds.
In addition to line flushing, facilities perform a number of other tasks to ensure the purity of the
different chemicals they process. These activities include drum (or container) washing and tank
rinsing. The quantity of any EPCRA Section 313 chemicals that are used for these purposes must
apply to the threshold for otherwise use of that chemical and any waste generated from these
processes needs to be reported in the respective section of Form R (as explained above).
Most every warehouse uses cranes or forklifts for loading and unloading goods from and to
trucks or railcars, as well as moving goods within the facility for inventory control. The use of
non-stationary cranes and forklifts qualifies for the motor vehicle exemption under the reporting
requirements. However, the use of stationary cranes does not qualify for this exemption.
Therefore, the use of Section 313 chemicals found in fuel, engine fluids, oil and lubricants,
batteries, cleaning solutions, or solvents in paint used for touch ups on this equipment will apply
towards the 10,000 pound otherwise use threshold.
October 7, 1997 5-6
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
Refrigeration, freezing, and/or air conditioning systems are necessary for the storage of certain
chemicals, such as flammable chemicals (e.g., xylene, toluene). During the routine operation of
these systems, coolants will need to be replenished. A number of EPCRA Section 313 chemicals
are used as coolants or refrigerants, including ammonia (anhydrous), CFC-13, and CFC-12. For
the purposes of TRI reporting, the amount of refrigerant that is added during the reporting year,
(not the total volume in the system), applies to the otherwise use threshold for that chemical.
Also, the amount added to existing equipment would be a good measure of the fugitive emissions
of the Section 313 chemical, as long as any liquid spills or flushing of the whole system is
accounted for.
Some potential releases or waste generation sources associated with plant maintenance are:
• Evaporation from chemical or waste holding tanks (fugitive air emissions: §5.1 (open tanks)
and/or §5.2 (storage tanks - breathing losses))
• Line flushing solutions used for energy recovery (§8.2-8.3)
• Line flushing solutions used for recycling (§8.4-8.5)
8 Spills or leaks that occur during line flushing (§5.1, §5.3, and/or §5.5)
• Disposal of tank sludge and wash/rinsing solutions sent off-site for further waste management
(§6.2)
• Air emissions of refrigerants (fugitive air emissions, §5.1)
October?, 1997 5-7
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TRTFORMR (ITTTDANrF nnriTA/TPXTT rUPlV/nr1 A T r»TCTmmrrr»DC
October?, 1997 5-8
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TR! FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTOR'S
APPENDIX A
ALPHABETICAL LISTING OF SECTION 313 CHEMICALS
October 7, 1997 A-1
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> ru TTT^ \ xrrT'r>T TTVVO O
~ ^AU A AVAA-JW A V-/AVLJ
CAS No.
4080-31-3
354-11-0
630-20-6
71-55-6
354-14-3
79-34-5
79-00-5
13474-88-9
812-04-4
111512-56-2
1717-00-6
57-14-7
5124-30-1
96-18-4
120-82-1
95-63-6
106-88-7
96-12-8
106-93-4
422-44-6
354-23-4
431-86-7
1649-08-7
95-50-1
107-06-2
540-59-0
78-87-5
122-66-7
95-54-5
615-28-1
38661-72-2
106-99-0
507-55-1
136013-79-1
541-73-1
542-75-6
123-61-5
108-45-2
10347-54-3
2556-36-7
764-41-0
106-46-7
123-91-1
104-49-4
624-18-0
3173-72-6
82-28-0
35691-65-7
354-25-6
75-68-3
5522-43-0
16938-22-0
CHEMICAL NAME
l-(3-Chloroallyl)-3,5,7-triaza-l-azoniaadamantane chloride
1,1,1 ,2-Tetrachloro-2-fluoroethane (HCFC- 1 2 1 a)
1,1,1 ,2-tetrachloroethane
1,1,1-Trichloroethane (Methyl chloroform)
1 , 1 ,2,2-Tetrachloro- 1 -fluoroethane (HCFC- 121)
1 , 1 ,2,2-Tetrachloroethane
1 , 1 ,2-Trichloroethane
1 , 1 -Dichloro- 1 ,2,2,3,3-pentafluoropropane (HCFC-225cc)
1 , 1 -Dichloro- 1 ,2,2-trifluoroethane (HCFC- 1 23b)
1 , 1 -Dichloro- 1 ,2,3,3,3-pentafiuoropropane (HCFC-225eb)
1 , 1 -Dichloro- 1 -fluoroethane (HCFC- 1 4 1 b)
1,1 -Dimethyl hydrazine
1 , 1 -Methy lene bis(4-isocyanatocyclohexane)
1 ,2,3-Trichloropropane
1 ,2,4-Trichlorobenzene
1 ,2,4-Trimethylbenzene
1,2-Butylene oxide
1 ,2-Dibromo-3-chloropropane (DBCP)
1,2-Dibromoethane (Ethylene dibromide)
1 ,2-Dichloro- 1 , 1 ,2,3,3-pentafluoropropane (HCFC-225bb)
1 ,2-Dichloro- 1 , 1 ,2-trifluoroethane (HCFC- 1 23a)
l,2-Dichloro-l,l,3,3,3-pentafluoropropane(HCFC-225da)
1 ,2-Dichloro- 1 , 1 -difluoroethane (HCFC- 1 32b)
1 ,2-Dichlorobenzene
1,2-Dichloroethane (Ethylene dichloride)
1 ,2-Dichloroethy lene
1 ,2-Dichloropropane
1 ,2-Diphenylhydrazine (Hydrazobenzene)
1 ,2-Pheny lenediamine
1 ,2-Phenylenediamine dihydrochloride
l,3-Bis(methylisocyanate)cyclohexane
1,3-Butadiene
l,3-Dichloro-l,l,2,2,3-pentafluoropropane(HCFC-225cb)
1 ,3-Dichloro- 1 , 1 ,2,3,3-pentafluoropropane (HCFC-225ea)
1 ,3-Dichlorobenzene
1 ,3-Dichloropropylene
1,3-Phenylene diisocyanate
1 ,3-Phenylenediamine
l,4-Bis(methylisocyanate)cyclohexane
1,4-Cyclohexane diisocyanate
1 ,4-Dichloro-2-butene
1 ,4-Dichlorobenzene
1,4-Dioxane
1,4-Phenylene diisocyanate
1,4-Pheny lenediamine dihydrochloride
1,5-Naphthalene diisocyanate
1 - Amino-2-methy lanthraquinone
1 -Bromo- 1 -(bromomethyl)- 1 ,3-propanedicarbonitrile
1 -Chloro- 1 , 1 ,2,2-tetrafluoroethane (HCFC- 1 24a)
1 -Chloro- 1 , 1 -difluoroethane (HCFC- 1 42b)
1-Nitropyrene
2,2,4-Trimethylhexamethylene diisocyanate
De
Minimis
Cone
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
0.1 ,
1.0
0.1
1.0
1.0
1.0
0.1
0.1
.0
.0
.0
.0
.0
0.1
.0
.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
Appx
vm
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
RCRA
UTS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
RCRA
Code
U208
U226
U209
U227
U098
U066
U067
U070
U077
U083
U109
U071
U084
U074
U072
U108
October 7, 1997
A-2
-------
rv^ruvi
LJLd 1 IU.DU
128903-21-9
306-83-2
2655-15-4
422-48-0
78-88-6
15646-96-5
95-95-4
88-06-2
94-75-7
53404-37-8
1928-43-4
1929-73-3
94-80-4
2971-38-2
94-11-1
1320-18-9
2702-72-9
94-82-6
615-05-4
39156-41-7
95-80-7
120-83-2
75790-87-3
105-67-9
51-28-5
121-14-2
541-53-7
120-36-5
576-26-1
606-20-2
87-62-7
53-96-3
117-79-3
52-51-7
2837-89-0
75-88-7
532-27-4
110-80-5
149-30-4
109-86-4
75-86-5
109-06-8
88-75-5
79-46-9
90-43-7
422-56-0
91-94-1
612-83-9
64969-34-2
119-90-4
91-93-0
20325-40-0
111984-09-9
91-97-4
2,2-Dichloro-l,l,l,3,3-pentafluoropropane(HCFC-225aa)
2,2-Dichloro- 1,1,1 -trifluoroethane (HCFC- 1 23)
2,3,5-Trimethylphenyl methylcarbamate
2,3-Dichloro- 1,1,1 ,2,3-pentafluoropropane (HCFC-225ba)
2,3-Dichloropropene
2,4,4-Trimethylhexamethylenediisocyanate
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-D [Acetic acid, (2,4-dichloro-phenoxy)-]
2,4-D 2-ethyl-4-methylpentyl ester
2,4-D 2-ethylhexyl ester
2,4-D butoxyethyl ester
2,4-D butyl ester
2,4-D chlorocrotyl ester
2,4-D isopropyl ester
2,4-D propylene glycol butyl ether ester
2,4-D sodium salt
2,4-DB
2,4-Diaminoanisole
2,4-Diaminoanisole sulfate
2,4-Diaminotoluene
2,4-Dichlorophenol
2,4'-Diisocyanatodiphenyl sulfide
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,4-Dithiobiuret
2,4-DP
2,6-Dimethylphenol
2,6-Dinitrotoluene
2,6-Xylidine
2-Acetylaminofluorene
2-Aminoanthraquinone
2-Bromo-2-nitropropane- 1 ,3 -diol (Bronopol)
2-Chloro- 1,1,1 ,2-tetrafluoroethane (HCFC- 1 24)
2-Chloro- 1,1,1 -trifluoroethane (HCFC- 1 33 a)
2-Chloroacetophenone
2-Ethoxyethanol
2-Mercaptobenzothiazole (MBT)
2-Methoxyethanol
2-Methyllactonitrile
2-Methylpyridine
2-Nitrophenol
2-Nitropropane
2-Phenylphenol
3,3-Dichloro- 1,1,1 ,2,2-pentafluoropropane (HCFC-225ca)
3,3'-Dichlorobenzidine
3,3'-Dichlorobenzidine dihydrochloride
3,3'-Dichlorobenzidine sulfate
3,3'-Dimethoxybenzidine
3,3'-Dimethoxybenzidine-4,4'-diisocyanate
3,3'-Dimethoxybenzidine dihydrochloride (o-Dianisidine
dihydrochloride)
3,3'-Dimethoxybenzidine hydrochloride (o-Dianisidine
hydrochloride)
3,3'-Dimethyl-4,4'-diphenylenediisocyanate
.0
.0
.0
.0
.0
.0
.0 XX
0.1 X X
1.0 X X U240
0.
0.
0.
0.
0.
0.
0.
0.
1.0
0.1
0.1
0.1 X
1.0 X X U081
1.0
.0 XX U101
1.0 X X P048
1.0 X X U105
1.0 X P049
0.1
1.0
1.0 X X U106
0.1
0.1 X X U005
0.1
1.0
0.1
.0
.0
.0 X U359
.0 '
.0
.0 X P069
.0 X U191
.0 X
0.1 X U171
1.0
1.0
0.1 X U073
0.1
0.1
0.1 X U091
0.1
0.1
October?, 1997
A-3
-------
TRT FOP1U 1? rtTTTnAMPF FlOPI TA/TFXTT
119-93-7
612-82-8
41766-75-0
460-35-5
563-47-3
542-76-7
55406-53-6
101-80-4
4128-73-8
80-05-7
101-14-4
101-61-1
101-77-9
139-65-1
534-52-1
60-09-3
92-67-1
60-1N7
75790-84-0
92-93-3
100-02-7
3697-24-3
99-59-2
99-55-8
57-97-6
194-59-2
71751-41-2
30560-19-1
75-07-0
60-35-5
75-05-8
98-86-2
62476-59-9
107-02-8
79-06-1
79-10-7
107-13-1
15972-60-8
116-06-3
309-00-2
107-18-6
107-05-1
107-11-9
319-84-6
134-32-7
7429-90-5
1344-28-1
20859-73-8
834-12-8
3,3'-Dimethylbenzidine(o-Tolidine)
3,3'-Dimethylbenzidine dihydrochloride (o-Tolidine
dihydrochloride)
3,3'-Dimethylbenzidine dihydrofluoride (o-Tolidine
dihydrofluoride)
3-Chloro- 1,1,1 -trifluoropropane (HCFC-253fb)
3 -Chloro-2-methy 1- 1 -propene
3-Chloropropionitrile
3-Iodo-2-propynyl butylcarbamate
4,4'-Diaminodiphenyl ether
4,4'-Diisocyanatodiphenyl ether
4,4'-Isopropylidenediphenol
4,4'-Methylenebis(2-chloroaniline)(MBOCA)
4,4'-Methylenebis(N,N-dimethyl)benzenamine
4,4'-Methylenedianiline
4,4'-ThiodianiIine
4,6-Dinitro-o-cresol
4-Aminoazobenzene
4-Aminobiphenyl
4-Dimethylaminoazobenzene
4-Methyldiphenylmethane-3,4-diisocyanate
4-Nitrobiphenyl
4-Nitrophenol
5-Methylchrysene
5-Nitro-o-anisidlne
5-Nitro-o-toluidine
7, 12-Dimethylbenz(a)anthracene
7H-Dibenzo(c,g)carbazole
Abamectin [Avermectin Bl]
Acephate (Acetylphosphoramidothioic acid O,S-dimethyl
ester)
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
Acifluorfen, sodium salt [5-(2-ChIoro-4-
(trifluoromethyl)phenoxy)-2-nitrobenzoic acid, sodium salt]
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Alachlor
Aldicarb
Aldrin [l,4:5,8-Dimethanonaphthalene, 1,2,3,4,10,10-
hexachloro- 1 ,4,4a,5,8,8a-hexahydro-
(l.alpha,,4.alpha.,4a,beta.,5.alpha.,8.alpha.,8a.beta.)-]
Allyl alcohol
Allyl chloride
Allylamine
alpha-Hexachlorocyclohexane
alpha-Naphthylamine
Aluminum (fume or dust)
Aluminum oxide (fibrous form)
Aluminum phosphide
Ametryn (N-Ethyl-N'-( 1 -methylethyl)-6-(methylthio)- 1 ,3,5,-
triazine-2,4-diamine)
0.1
0.1
0.1
1.0
0.1
1.0
1.0
0.1
1.0
1.0
0.
0.
0.
0.
1.0
0.
0.
0.
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U095
P027
U158
P047
U093
U170
U181
U094
U001
U003
U004
P003
U007
U008
U009
P070
P004
POOS
U167
P006
October?, 1997
A-4
-------
TDT irr»T?\/f D nr nr» A XT/^T: r»r»r
-------
TRT FORM R OTTTDANrF DOn T1UKMT
1689-99-2
357-57-3
141-32-2
123-72-8
4680-78-8
6459-94-5
569-64-2
989-38-8
1937-37-7
28407-37-6
2602-46-2
16071-86-6
2832-40-8
81-88-9
3761-53-3
3118-97-6
842-07-9
97-56-3
492-80-8
128-66-5
7440-43-9
156-62-7
133-06-2
63-25-2
1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4
120-80-9
2439-01-2
133-90-4
57-74-9
115-28-6
90982-32-4
7782-50-5
10049-04-4
79-11-8
108-90-7
510-15-6
75-45-6
75-00-3
67-66-3
74-87-3
107-30-2
76-06-2
126-99-8
63938-10-3
Bromoxynil octanoate (Octanoic acid, 2,6-dibromo-4-
cyanophenyl ester)
Brucine
Butyl acrylate
Butyraldehyde
C.I. Acid Green 3
C.I. Acid Red 114
C.I. Basic Green 4
C.I. Basic Red 1
C.I. Direct Black 38
C.I. Direct Blue 218
C.I. Direct Blue 6
C.I. Direct Brown 95
C.I. Disperse Yellow 3
C.I. Food Red 15
C.I. Food Red 5
C.I. Solvent Orange 7
C.I. Solvent Yellow 14
C.I. Solvent Yellow 3
C.I. Solvent Yellow 34 (Auramine)
C.I. Vat Yellow 4
Cadmium
Calcium cyanamide
Captan [lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-tetrahydro-2-
[(trichloromethyl)thio]-]
Carbaryl [1-Naphthalenol, methylcarbamate]
Carbofuran
Carbon disulflde
Carbon tetrachloride
Carbonyl sulfide
Carboxin (5,6-Dihydro-2-methyl-N-phenyl- 1 ,4-oxathiin-3-
carboxamide)
Catechol
Chinomethionat (6-Methyl- 1 ,3-dithiolo[4,5-b]quinoxalin-2-
one)
Chloramben [Benzoic acid, 3-amino-2,5-dichloro-]
Chlordane [4,7-Methanoindan, 1,2,3,4,5,6,7,8,8-octachloro-
2,3,3a,4,7,7a-hexahydro-]
Chlorendic acid
Chlorimuron ethyl (Ethyl-2-[[[(4-chloro-6-methoxyprimidin-2-
yl)-carbonyl]-amino]sulfonyl]benzoate)
Chlorine
Chlorine dioxide
Chloroacetic acid
Chlorobenzene
Chlorobenzilate [Benzeneacetic acid,4-chloro-.alpha.-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
Chlorodifluoromethane (HCFC-22)
Chloroethane (Ethyl chloride)
Chloroform
Chloromethane (Methyl chloride)
Chloromethyl methyl ether
Chloropicrin
Chloroprene
Chlorotetrafluoroethane
1.0
.0
.0
.0
.0
0.1
.0
.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
.0
.0
.0
.0
.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
X P018
X U014
X X
X X
X X
X X P022
X X U211
X X U036
X X U037
X X
X
X X U044
X X U045
X U046
X X U210
October 7, 1997
A-6
-------
TPT POPA/T p
T
1J-*
1897-45-6
75-72-9
5598-13-0
64902-72-3
7440-47-3
7440-48-4
7440-50-8
8001-58-9
1319-77-3
4170-30-3
98-82-8
80-15-9
135-20-6
21725-46-2
'1134-23-2
1 10-82-7
108-93-0
68359-37-5
68085-85-8
28057-48-9
533-74-4
53404-60-7
1163-19-5
13684-56-5
117-81-7
2303-16-4
25376-45-8
333-41-5
334-88-3
226-36-8
224-42-0
5385-75-1
192-65-4
53-70-3
189-64-0
191-30-0
132-64-9
124-73-2
84-74-2
1918-00-9
99-30-9
90454-18-5
25321-22-6
75-27-4
75-71-8
Chlorothalonil [1,3-Benzenedicarbonitrile, 2,4,5,6-tetrachloro-
Chlorotrifluoromethane (CFC-13)
Chlorpyrifos methyl (O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate)
Chlorsulfuron(2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
triazin-2-yl)amino]carbonyl]benzenesulfonamide)
Chromium
Cobalt
Copper
Creosote
Cresol (mixed isomers)
Crotonaldehyde
Cumene
Cumene hydroperoxide
Cupferron [Benzeneamine, N-hydroxy-N-nitroso, ammonium
salt]
Cyanazine
Cycloate
Cyclohexane
Cyclohexanol
Cyfluthrin(3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid, cyano(4-fluoro-3-
phenoxyphenyl)methyl ester)
Cyhalothrin(3-(2-Chloro-3,3,3-trifluoro-l-propenyl)-2,2-
Dimethylcyclopropanecarboxylic acid cyano(3-
phenoxyphenyl) methyl ester)
d-trans-Allethrin [d-trans-Chrysanthemic acid of d-allethrone]
Dazomet(Tetrahydro-3,5-dimethyl-2H-l,3,5-thiadiazine-2-
thione)
Dazomet, sodium salt (Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione, ion(l-), sodium)
Decabromodiphenyl oxide
Desmedipham
Di(2-ethylhexyl) phthalate (DEHP)
Diallate [Carbamothioic acid, bis(l-methylethyl)-S-(2,3-
dichloro-2-propenyl)ester]
Diaminotoluene (mixed isomers)
Diazinon
Diazomethane
Dibenz(a,h)acridine
Dibenz(aJ)acridine
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)anthracene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
Dibenzofuran
Dibromotetrafluoroethane (Halon 2402)
Dibutyl phthalate
Dicamba (3,6-Dichloro-2-methyoxybenzoic acid)
Dichloran (2,6-Dichloro-4-nitroaniline)
Dichloro- 1 , 1 ,2-trifluoroethane
Dichlorobenzene (mixed isomers)
Dichlorobromomethane
Dichlorodifluoromethane (CFC-12)
1.0
1.0
1.0
1.0
0.1 X X
0.1
1.0
0.1
1.0 X
1.0 X
1.0
1.0
0.1
.0
.0 XX
.0
.0
.0
1.0
1.0
1.0 X
1.0
1.0
1.0
0.1 X X
1.0 X
0.1 X
1.0
1.0
1.0
.0
.0
.0 XX
.0
.0
.0
0.1 X
.0 X
.0 XX
U051
U052
U053
U055
U096
U056
U028
U062
U221
U063
U069
U075
October 7, 1997
A-7
-------
TRT FORM R rUTmATsir.F DOPTTA/TRMT
T T-»TOrrT>Tr>TTrrVVnO
.1-1 A^ikJ A A\J.J_» ^ A V-fAVLJ
75-43-4
75-09-2
127564-92-5
97-23-4
76-14-2
34077-87-7
62-73-7
51338-27-3
115-32-2
77-73-6
1464-53-5
111-42-2
38727-55-8
84-66-2
64-67-5
134190-37-7
35367-38-5
101-90-6
94-58-6
55290-64-7
60-51-5
2524-03-0
131-11-3
77-78-1
124-40-3
2300-66-5
79-44-7
88-85-7
25321-14-6
39300-45-3
957-51-7
122-39-4
2164-07-0
136-45-8
138-93-2
330-54-1
2439-10-3
106-89-8
13194-48-4
140-88-5
541-41-3
759-94-4
100-41-4
74-85-1
107-21-1
75-21-8
96-45-7
151-56-4
75-34-3
52-85-7
60168-88-9
Dichlorofluoromethane (HCFC-21)
Dichloromethane (Methylene chloride)
Dichloropentafluoropropane
Dichlorophene(2,2'-Methylenebis(4-chlorophenol)
Dichlorotetrafluoroethane (CFC-1 14)
Dichlorotrifluoroethane
Dichlorvos [Phosphoric acid, 2-dichloroethenyl dimethyl ester]
Diclofop methyl (2-[4-(2,4-Dichlorophenoxy)
phenoxy]propanoic acid, methyl ester)
Dicofol [Benzenemethanol, 4-chIoro-.alpha.~4-chlorophenyl)-
.alpha.-(trichloromethyl)-]
Dicyclopentadiene
Diepoxybutane
Diethanolamine
Diethatyl ethyl
Diethyl phthalate
Diethyl sulfate
Diethyldiisocyanatobenzene
Diflubenzuron
Diglycidyl resorcinol ether
Dihydrosafrole
Dimethipin (2,3,-Dihydro-5,6-dimethyl-l,4-dithiin 1,1,4,4-
tetraoxide)
Dimethoate
Dimethyl chlorothiophosphate
Dimethyl phthalate
Dimethyl sulfate
Dimethylamine
Dimethylamine dicamba
Dimethylcarbamyl chloride
Dinitrobutyl phenol (Dinoseb)
Dinitrotoluene (mixed isomers)
Dinocap
Diphenamid
Diphenylamine
Dipotassium endothall (7-Oxabicyclo(2.2.1)heptane-2,3-
dicarboxylic acid, dipotassium salt)
Dipropyl isocinchomeronate
Disodium cyanodithioimidocarbonate
Diuron
Dodine (Dodecylguanidine monoacetate)
Epichlorohydrin
Ethoprop (Phosphorodithioic acid O-ethyl S,S-dipropyl ester)
Ethyl acrylate
Ethyl chloroformate
Ethyl dipropylthiocarbamate (EPTC)
Ethylbenzene
Ethylene
Ethylene glycol
Ethylene oxide
Ethylene thiourea
Ethyleneimine (Aziridine)
Ethylidene dichloride
Famphur
Fenarimol (.alpha -(2-Chlorophenyl)-.alpha.-4-chlorophenyl)-
5-pyrimidinemethanol)
1.0
0.1 X X
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1 X
1.0
1.0
0.1
0.1
1.0
0.1
0.1 X
1.0
1.0 X
1.0
1.0 X X
0.1 X
.0
.0
0.1 X
.0
.0
.0
1.0
1.0 X
1.0
1.0
1.0
1.0
1.0
0.1 X
1.0
0.1
1.0
1.0 X X
1.0 X
1.0
1.0
0.1 X X
0.1 X
0.1 X
1.0 X X
1.0 X X
1.0
U080
U085
U088
U090
P044
U102
U103
U092
U097
P020
U041
U113
U115
U116
P054
U076
P097
October 7, 1997
A-8
-------
TRT FORM R GUIDANCE DOCUMF.NT
CHEMICAL DISTRIBUTORS
13356-08-6
66441-23-4
72490-01-8
39515-41-8
55-38-9
51630-58-1
14484-64-1
69806-50-4
2164-17-2
7782-41-4
51-21-8
69409-94-5
133-07-3
72178-02-0
50-00-0
64-18-6
76-13-1
76-44-8
87-68-3
118-74-1
77-47-4
67-72-1
1335-87-1
70-30-4
680-31-9
51235-04-2
67485-29-4
302-01-2
10034-93-2
7647-01-0
74-90-8
7664-39-3
123-31-9
35554-44-0
193-39-5
13463-40-6
78-84-2
465-73-6
25311-71-1
4098-71-9
67-63-0
Fenbutatin oxide (Hexakis(2-methyl-2-
phenylpropyl)distannoxane)
Fenoxaprop ethyl (2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic acid, ethyl ester)
Fenoxycarb (2-(4-Phenoxy-phenoxy)-ethyl]carbamic acid
ethyl ester)
Fenpropathrin (2,2,3,3-Tetramethylcyclopropane carboxylic
acid cyano(3-phenoxyphenyl)methyl ester)
Fenthion (O,O-Dimethyl O-[3-methyl-4-(methylthio) phenyl]
ester, phosphorothioic acid)
Fenvalerate (4-Chloro-alpha-( 1 -methy lethy l)benzeneacetic
acid cyano(3-phenoxyphenyl)methyl ester)
Ferbam(Tris(dimethylcarbamodithioato-S,S')iron)
Fluazifop butyl (2-[4-[[5-(Trifluoromethyl)-2-pyridinyl]oxy]-
phenoxyjpropanoic acid, butyl ester)
Fluometuron [Urea, N,N-dimethyl-N'-[3-
(trifluoromethyl)phenyl]-]
Fluorine
Fluorouracil (5-Fluorouracil)
Fluvalinate(N-[2-Chloro-4-(trifluoromethyl)phenyl]-DL-
valine(+)-cyano(3-phenoxyphenyl)methyl ester)
Folpet
Fomesafen(5-(2-Chloro-4-(trifluoromethyl)phenoxy)-N
methylsulfonyl)-2-nitrobenzamide)
Formaldehyde
Formic acid
Freon 113 [Ethane, l,l,2-trichloro-l,2,2,-trifluoro-]
Heptachlor [l,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-tetrahydro-
4,7-methano- 1 H-indene]
Hexachloro-l,3-butadiene
Hexachlorobenzene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloronaphthalene
Hexachlorophene
Hexamethylphosphoramide
Hexazinone
Hydramethylnon (Tetrahydro-5,5-dimethyl-2( 1 H)-
pyrimidinone[3-[4-(trifluoromethyl)phenyl]-l-[2-[4-
(trifluoromethyl)phenyl]ethenyl]-2-propenylidene]hydrazone)
Hydrazine
Hydrazine sulfate
Hydrochloric acid
Hydrogen cyanide
Hydrogen fluoride
Hydroquinone
Imazalil ( 1 -[2-(2,4-Dichloropheny l)-2-(2-propenyloxy)ethy 1]-
IH-imidazole)
Indeno[ 1 ,2,3-cd]pyrene
Iron .pentacarbony 1
Isobutyraldehyde
Isodrin
Isofenphos(2-[[Ethoxyl[(l-methylethyl)amino]
phosphinothioyl]oxy] benzoic acid 1-methylethyl ester)
Isophorone diisocyanate
Isopropyl alcohol (mfg-strong acid process)
1.0
1.0
1.0
1.0
1.0
1.0
1.0 X
1.0
1.0
.0 X
.0
.0
.0
.0
0.1 X
1.0 X
1.0 X
X X
1.0 X X
0.1 X X
.0 XX
.0 XX
.0
.0 X
0.1
.0
.0
. 0.1 X
0.1
.0
.0 X
.0 X
.0
.0
.0
.0
.0 X X
.0
.0
.0
P056
U122
U123
P059
U128
U127
U130
U131
U132
U133
P063
U134
U137
P060
October?, 1997
A-9
-------
TRT FORM R GUTnANr.F. nnr.TJMF.NT
120-58-1
77501-63-4
7439-92-1
58-89-9
330-55-2
. 554-13-2
108-39-4
99-65-0
108-38-3
121-75-5
108-31-6 .
109-77-3
12427-38-2
7439-96-5
93-65-2
7439-97-6
150-50-5
126-98-7
137-42-8
67-56-1
20354-26-1
2032-65-7
94-74-6
3653-48-3
72-43-5
96-33-3
79-22-1
78-93-3
60-34-4
74-88-4
108-10-1
624-83-9
556-61-6
80-62-6
298-00-0
1634-04-4
74-95-3
101-68-8
101-68-8
9006-42-2
21087-64-5
7786-34-7
90-94-8
2212-67-1
1313-27-5
76-15-3
150-68-5
505-60-2
Isosafrole
Lactofen(5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-nitro-2-
ethoxy-l-methyl-2-oxoethyl ester)
Lead
Lindane [Cyclohexane, 1,2,3,4,5,6-hexachloro-
,(l.alpha.,2.alpha.,3.beta.,4.alpha.,5.alpha.,6.beta.)-]
Linuron
Lithium carbonate
m-Cresol
m-Dinitrobenzene
m-Xylene
Malathion
Maleic anhydride
Malononitrile
Maneb [Carbamodithioic acid, 1,2-ethanediylbis-, manganese
complex]
Manganese
Mecoprop
Mercury
Merphos
Methacrylonitrile
Metham sodium (Sodium methyldithiocarbamate)
Methanol
Methazole (2-(3,4-Dichlorophenyl)-4-methyl- 1 ,2,4-
oxadiazolidine-3,5-dione)
Methiocarb
Methoxone ((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
Methoxone sodium salt ((4-Chloro-2-methylphenoxy) acetate
sodium salt)
Methoxychlor [Benzene, l,l'-(2,2,2-trichloroethylidene)bis [4-
methoxy-]
Methyl acrylate
Methyl chlorocarbonate
Methyl ethyl ketone
Methyl hydrazine
Methyl iodide
Methyl isobutyl ketone
Methyl isocyanate
Methyl isothiocyanate (Isothiocyanatomethane)
Methyl methacrylate
Methyl parathion
Methyl tert-butyl ether
Methylene bromide
Methylenebis(phenylisocyanate)(MBI)
Methylenebis(phenylisocyanate)(MDI)
Metiram
Metribuzin
Mevinphos
Michler's ketone
Molinate (IH-Azepine-l carbothioic acid, hexahydro-S-ethyl
ester)
Molybdenum trioxide
Monochloropentafluoroethane (CFC-1 15)
Monuron
Mustard gas [Ethane, l,r-thiobis[2-chloro-]
1.0
1.0
0.1
0.1
.0
.0
.0
.0
.0
.0
.0
1.0
1.0
.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
.0
.0
.0
.0
.0
.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X*
X*
X
X
X
X
X
X
X
X
X
X
X
X
U141
U129
U052
U239
U147
U149
U151
U154
U247
U156
U159
P068
U138
U161
P064
U162
P071
U068
October 7, 1997
A-10
-------
TRT FORM R OUTDANCF. DOCUMENT
88671-89-0
121-69-7
68-12-2
71-36-3
110-54-3
872-50-4
924-42-5
759-73-9
684-93-5
924-16-3
621-64-7
55-18-5
62-75-9
86-30-6
4549-40-0
59-89-2
16543-55-8
100-75-4
142-59-6
300-76-5
91-20-3
7440-02-0
1929-82-4
7697-37-2
139-13-9
98-95-3
1836-75-5
51-75-2
55-63-0
27314-13-2
90-04-0
134-29-2
95-48-7
528-29-0
95-53-4
636-21-5
95-47-6
2234-13-1
19044-88-3
20816-12-0
301-12-2
19666-30-9
42874-03-3
10028-15-6
104-94-9
95-69-2
106-47-8
104-12-1
120-71-8
106-44-5
100-25-4
Myclobutanil (.alpha -Butyl-.alpha.-(4-chlorophenyl)-lH-
1 ,2,4-triazole- 1 -propanenitrile)
N.N-Dimethylaniline
N,N-Dimethylformamide
n-Butyl alcohol
n-Hexane
N-Methyl-2-pyrrolidone
N-Methylolacrylamide
N-Nitroso-N-ethylurea
N-Nitroso-N-methylurea
N-Nitrosodi-n-butylamine
N-Nitrosodi-n-propylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
N-Nitrosonornicotine
N-Nitrosopiperidine
Nabam
Naled
Naphthalene
Nickel
Nitrapyrin(2-Chloro-6-(trichloromethyl)pyridine)
Nitric acid
Nitrilotriacetic acid
Nitrobenzene
Nitrofen [Benzene, 2,4-dichloro-l-(4-nitrophenoxy)-]
Nitrogen mustard [2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Nitroglycerin
Norflurazon(4-Chloro-5-(methylainino)-2-[3-
(trifluoromethyl)phenyl]-3(2H)-pyridazinone)
o-Anisidine
o-Anisidine hydrochloride
o-Cresol
o-Dinitrobenzene
o-Toluidine
o-Toluidine hydrochloride
o-Xylene
Octachloronaphthalene
Oryzalin(4-(Dipropylamino)-3,5-dinitrobenzenesulfonamide)
Osmium tetroxide
Oxydemeton methyl (S-(2-(Ethylsulfmyl)ethyl) O,O-dimethyl
ester phosphorothioic acid)
Oxydiazon (3-[2,4-Dichloro-5-(l-methylethoxy)phenyl]-5- .
(1,1 -dimethylethy 1)- 1 ,3,4-oxadiazol-2(3H)-one)
Oxyfluorfen
Ozone
p-Anisidine
p-Chloro-o-toluidine
p-Chloroaniline
p-Chlorophenyl isocyanate
p-Cresidine
p-Cresol
p-Dinitrobenzene
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.
0.
0.
0.
0.
0.
1.0
0.
0.
0.
0.
.0
.0
.0
0.1
.0
.0
0.1
1.0
0.1
0.1
1.0
1.0
0.1
0.1
1.0
1.0
0.1
0.1
.0
.0
.0
.0
.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
0.1
1.0
1.0
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X*
X
U031
U176
U177
U172
Ulll
U174
P082
P084
U179
U165
U169
P081
U052
U328
U222
U239
P087
P024
U239
October?, 1997
A-ll
-------
TRT FORM R rrTTTDANrF DOrjTMFMT
AT
100-01-6
156-10-5
106-50-3
106-42-3
123-63-7
1910-42-5
56-38-2
1114-71-2
40487-42-1
76-01-7
87-86-5
57-33-0
79-21-0
594-42-3
52645-53-1
85-01-8
108-95-2
26002-80-2
57-41-0
75-44-5
7803-51-2
7664-38-2
7723-14-0
85-44-9
1918-02-1
88-89-1
51-03-6
29232-93-7
1336-36-3
9016-87-9
7758-01-2
128-03-0
137-41-7
41198-08-7
7287-19-6
23950-58-5
1918-16-7
1120-71-4
709-98-8
2312-35-8
107-19-7
31218-83-4
60207-90-1
123-38-6
p-Nitroaniline
p-Nitrosodiphenylamine
p-Phenylenediamine
p-Xylene
Paraldehyde
Paraquat dichloride
Parathion [Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl) ester]
Pebulate (Butylethylcarbamothioic acid S-propyl ester)
Pendimethalin (N-( 1 -Ethylpropyl)-3,4-dimethy 1-2,6-
dinitrobenzenamine)
Pentachloroethane
Pentachlorophenol (PCP)
Pentobarbital sodium
Peracetic acid
Perchloromethyl mercaptan
Permethrin (3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropane carboxylic acid, (3-
phenoxyphenyl)methyl ester)
Phenanthrene
Phenol
Phenothrin (2,2-Dimethyl-3-(2-methy 1- 1 -
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester)
Phenytoin
Phosgene
Phosphine
Phosphoric acid
Phosphorus (yellow or white)
Phthalic anhydride
Picloram
Picric acid
Piperonyl butoxide
Pirimiphos methyl (O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-dimethylphosphorothioate)
Polychlorinated biphenyls (PCBs)
Polymeric diphenylmethane diisocyanate
Potassium bromate
Potassium dimethyldithiocarbamate
Potassium N-methyldithiocarbamate
Profenofos(O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propylphosphorothioate)
Prometryn (N,N'-Bis( 1 -methylethyl)-6-methylthio- 1,3,5-
triazine-2,4-diamine)
Pronamide
Propachlor (2-Chloro-N-( 1 -methylethyl)-N-phenylacetamide)
Propane sultone
Propanil(N-(3,4-Dichlorophenyl)propanamide)
Propargite
Propargyl alcohol
Propetamphos (3-
[(Ethylamino)methoxyphosphinothioyl]oxy]-2-butenoicacid,
1-methylethyl ester)
Propiconazole ( 1 -[2-(2,4-Dichlorophenyl)-4-propyl- 1 ,3-
dioxolan-2-yl]-methyl- 1 H- 1 ,2,4,-triazole)
Propionaldehyde
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
.0
.0
.0
.0
.0
.0
.0
.0
.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
X X P077
X* U239
X U182
X X P089
X X
X X U184
X X
X
X U188
X P095
X P096
X X U190
X
X
X
X X U192
X U193
X P102
October 7, 1997
A-12
-------
TRI FORM R GUIDANCE DOCUMENT
CHEMTCAT, DTSTRTRTTTORS
114-26-1
115-07-1
75-56-9
75-55-8
110-86-1
91-22-5
106-51-4
82-68-8
76578-14-8
10453-86-8
78-48-8
81-07-2
94-59-7
78-92-2
7782-49-2
74051-80-2
7440-22-4
122-34-9
26628-22-8
1982-69-0
128-04-1
62-74-8
7632-00-0
132-27-4
131-52-2
100-42-5
96-09-3
7664-93-9
2699-79-8
35400-43-2
34014-18-1
3383-96-8
5902-51-2
75-65-0
127-18-4
961-11-5
64-75-5
7696-12-0
7440-28-0
148-79-8
62-55-5
28249-77-6
59669-26-0
23564-05-8
23564-06-9
Propoxur [Phenol, 2-(l-methylethoxy)-, methylcarbamate]
Propylene (Propene)
Propylene oxide
Propyleneimine
Pyridine
Quinoline
Quinone
Quintozene (Pentachloronitrobenzene)
Quizalofop-ethyl(2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy] propanoic acid ethyl ester)
Resmethrin ([5-(Phenylmethyl)-3-furanyl]methyl 2,2-
dimethyl-3-(2-methyl-l-propenyl)cyclopropanecarboxylate])
S,S,S-Tributyltrithiophosphate (DBF)
Saccharin (manufacturing)
Safrole
sec-Butyl alcohol
Selenium
Sethoxydim (2-[l-(Ethoxyimino) butyl]-5-[2-
(ethylthio)propyl]-3-hydroxyl-2-cyclohexeri-l-one)
Silver
Simazine
Sodium azide
Sodium dicamba (3,6-Dichloro-2-methoxybenzoic acid,
sodium salt)
Sodium dimethyldithiocarbamate
Sodium fluoroacetate
Sodium nitrite
Sodium o-phenylphenoxide
Sodium pentachlorophenate
Styrene
Styrene oxide
Sulfuric acid
Sulfuryl fluoride (Vikane)
Sulprofos (O-Ethyl O-[4-
(methylthio)phenyl]phosphorodithioic acid S-propyl ester)
Tebuthiuron (N-[5-( 1 , 1 -Dimethy lethy 1)- 1 ,3,4-thiadiazol-2-yl)-
N,N'-dimethylurea)
Temephos
Terbacil (5-Chloro-3-(l,l-dimethylethyl)-6-methyl- 2,4
( 1 H,3H)-pyrimidinedione)
tert-Butyl alcohol
Tetrachloroethylene(Perchloroethylene)
Tetrachlorvinphos [Phosphoric acid, 2-chloro-l -(2,3,5-
trichlorophenyl) ethenyl dimethyl ester]
Tetracycline hydrochloride
Tetramethrin (2,2-Dimethyl-3-(2-methy 1- 1 -
propenyl)cyclopropanecarboxylic acid (1,3,4,5,6,7-hexahydro-
1 ,3-dioxo-2H-isoindol-2-yl)methy 1 ester)
Thallium
Thiabendazole (2-(4-Thiazolyl)- 1 H-benzimidazole)
Thioacetamide
Thiobencarb (Carbamic acid, diethylthio-, S-(p-chlorobenzyl))
Thiodicarb
Thiophanate-methyl
Thiophanate ethyl ([1,2-Phenylenebis (iminocarbonothioyl)]
biscarbamic acid diethyl ester)
1.0 X X
1.0
0.1
0.1 X
.0 XX
.0
.0 X
.0 XX
.0
*
1.0
1.0
0.1 X
0.1 X X
1.0
1.0 X X
1.0
1.0 X X
1.0
1.0
1.0
1.0 X
1.0 X
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1 X X
1.0
1.0
1.0
1.0 X X
1.0
0.1 X
1.0
1.0 X X
1.0 XX
1.0
P067
U196
U197
U185
U202
U203
P105
P058
U218
October?, 1997
A-13
-------
TRT FORM T?
AT r»Tcrrr>TDTTrr/^nc
79-19-6
62-56-6
137-26-8
1314-20-1
7550-45-0
108-88-3
584-84-9
91-08-7
26471-62-5
8001-35-2
10061-02-6
110-57-6
43121-43-3
2303-17-5
68-76-8
101200-48-0
1983-10-4
2155-70-6
52-68-6
76-02-8
79-01-6
75-69-4
57213-69-1
121-44-8
1582-09-8
26644-46-2
639-58-7
76-87-9
126-72-7
72-57-1
51-79-6
7440-62-2
50471-44-8
108-05-4
593-60-2
75-01-4
75-35-4
1330-20-7
7440-66-6
12122-67-7
Thiosemicarbazide
Thiourea
Thiram
Thorium dioxide
Titanium tetrachloride
Toluene
Toluene-2,4-diisocyanate
Toluene-2,6-diisocyanate
Toluene diisocyanate (mixed isomers)
Toxaphene
trans- 1 ,3-Dichloropropene
trans- 1 ,4-Dichloro-2-butene
Triadimefon ( 1 -(4-Chlorophenoxy)-3,3-dimethyl- 1 -( 1 H- 1 ,2,4-
triazol-l-yl)-2-butanone)
Triallate
Triaziquone [2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
aziridinyl)-]
Tribenuron methyl (2-(4-Methoxy-6-methyl-l,3,5-triazin-2-
yl)-methylamino)carbonyl)amino)sulfonyl)-, methyl ester)
Tributyltin fluoride
Tributyltin methacrylate
Trichlorfon [Phosphonic acid, (2,2,2-trichIoro-l-
hydroxyethyl)-,dimethyl ester]
Trichloroacetyl chloride
Trichloroethylene
Trichlorofluoromethane (CFC-1 1)
Triclopyr triethylammonium salt
Triethylamine
Trifluralin [Benezeneamine, 2,6-dinitro-N,N-dipropyI-4-
(trifluoromethyl)-]
Triforine (N,N'-[1 ,4-Piperazinediylbis(2,2,2-
trichloroethylidene)] bisformamide)
Triphenyltin chloride
Triphenyltin hydroxide
Tris(2,3-dibromopropyl) phosphate
Trypan blue
Urethane (Ethyl carbamate)
Vanadium (fume or dust)
Vinclozolin(3-(3,5-Dichlorophenyl)-5-ethenyl-5-methyl-2,4-
oxazolidinedione)
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride
Xylene (mixed isomers)
Zinc (fume or dust)
Zineb [Carbamodithioic acid, 1,2-ethanediylbis-, zinc
complex]
1.0 X
0.1 X
1.0 X
1.0
1.0
1.0 X X
0.
0.
0. X
0. XX
0. X
1.0
1.0
1.0 X X
1.0
1.0
1.0
1.0
1.0
1.0
0.1 X X
1.0 X X
1.0
1.0 X
1.0
1.0
1.0
1.0
0.1 X X
0.1 X
0.1 X
1.0 X
1.0
0.1
0.1
0.1 X X
1.0 X X
1.0 X
1.0 X
1.0
P116
U219
U244
U220
U223
P123
U228
U121
U235
U236
U238
U043
U078
U239
as mixed isomers (sum)
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Chemical Categories
Section 313 requires reporting on the toxic chemical categories listed below, in addition
to the specific toxic chemicals listed above.
The metal compounds listed below, unless otherwise specified, are defined as including
any unique chemical substance that contains the named metal (i.e., antimony, nickel, etc.)
as part of that chemical's structure.
Toxic chemical categories are subject to the 1 percent de minimis concentration unless
the substance involved meets the definition of an OSHA carcinogen in which case the 0.1
percent de minimis concentration applies. The de minimis concentration for each category is
provided in parentheses.
Chemical Categories
Antimony Compounds (1.0)
Includes any unique chemical substance that contains antimony as part of that
chemical's infrastructure.
Arsenic Compounds (inorganic compounds: 0.1; organic compounds: 1.0)
Includes any unique chemical substance that contains arsenic as part of that
chemical's infrastructure.
Barium Compounds (1.0)
Includes any unique chemical substance that contains barium as part of that
chemical's infrastructure.
This category does not include: Barium sulfate CAS Number 7727-43-7
Beryllium Compounds (0.1)
Includes any unique chemical substance that contains beryllium as part of
chemical's infrastructure.
Cadmium Compounds (0.1)
Includes any unique chemical substance that contains cadmium as part of that
chemical's infrastructure.
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CHEMICAL DISTRIBUTORS
Chlorophenols (0.1)
Where x = 1 to 5
Chromium Compounds (chromium VI compounds: 0.1; chromium III compounds: 1.0)
Includes any unique chemical substance that contains chromium as part of that
chemical's infrastructure.
Cobalt Compounds (0.1)
Includes any unique chemical substance that contains cobalt as chemical's
infrastructure.
Copper Compounds (1.0)
Includes any unique chemical substance that contains copper as part of that
infrastructure.
This category does not include copper phthalocyanine compounds that substituted
with only hydrogen, and/or chlorine, and/or bromine.
Cyanide Compounds (1.0)
X+CN~ where X = H+ or any other group where a formal dissociation may occur
For example KCN or Ca (CN)2.
Diisocyanates (1.0)
This category includes only those chemicals listed below.
38661-72-2 1,3-Bis(methylisocyanate)cyclohexane
10347-54-3 1,4-Bis(methylisocyanate)cyclohexane
2556-36-7 1,4-Cyclohexane diisocyanate
134190-37-7 Diethyldiisocyanatobenzene
4128-73-8 4,4'-Diisocyanatodiphenyl ether
75790-87-3 2,4'-Diisocyanatodiphenyl sulfide
91-93-0 3,3' -Dimethoxybenzidine-4,4' -diisocyanate
91 -97-4 3,3' -Dimethyl-4,4' -diphenylene diisocyanate
139-25-3 3,3' -Dimethyldiphenylmethane-4,4' -diisocyanate
822-06-0 Hexamethylene-1,6-diisocyanate
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
4098-71-9 Isophorone diisocyanate
75790-84-0 4-Methyldiphenylmethane-3,4-diisocyanate
5124-30-1 1,1-Methylene bis(4-isocyanatocyclohexane)
101-68-8 Methylenebis(phenylisocyanate) (MDI)
3173-72-6 1,5-Naphthalene diisocyanate
123-61-5 1,3-Phenylene diisocyanate
104-49-4 1,4-Phenylene diisocyanate
9016-87-9 Polymeric diphenylmethane diisocyanate
16938-22-0 2,2,4-Trimethylhexamethylene diisocyanate
15646-96-5 2,4,4-Trimethylhexamethylene diisocyanate
Ethylenebisdithiocarbamic acid, salts and esters (EBDCs) (1.0)
Includes any unique chemical substance that is or that contains EBDC or an EBDC
salt or ester as part of that chemical's infrastructure.
Certain Glycol Ethers (1.0)
R-(OCH2CH2)n-OR'
Where n = 1, 2, or 3
R = alkyl C7 or less; or
R = phenyl or alkyl substituted phenyl;
R' = H, or alkyl C7 or less; or
OR' consisting of carboxylic acid ester, sulfate, phosphate, nitrate, or sulfonate.
Lead Compounds (inorganic compounds: 0.1; organic compounds 1.0)
Includes any unique chemical substance that contains lead as part of that chemical's
infrastructure.
Manganese Compounds (1.0)
Includes any unique chemical substance that contains manganese as part of that
chemical's infrastructure.
Mercury Compounds (1.0)
Includes any unique chemical substance that contains mercury as part of that
chemical's infrastructure.
Nickel Compounds (0.1)
Includes any unique chemical substance that contains nickel as part of that
chemical's infrastructure.
Nicotine and salts (1.0)
Includes any unique chemical substance that contains nicotine or a nicotine salt part
of that chemical's infrastructure.
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Nitrate compounds (water dissociable; reportable only when in aqueous solution) (1.0)
Polybrominated Biphenyls (PBBs) (0.1)
(1 0-x)
Where x = 1 to 10
Poly chlorinated alkanes (CIO to C 13) (1.0, except for those members of the category that
have an average chain length of 12 carbons and contain an average chlorine content of 60
percent by weight which are subject to the 0. 1 percent de minimis)
where x = 10 to 13;
y - 3 to 12; and
the average chlorine content ranges from 40 - 70% with the limiting molecular
formulas C10H19C13 and C13H16C112.
Polycyclic aromatic compounds (PACs) (0.1, except for benzo(a)phenanthrene and
dibenzo(a,e)fluoranthene which are subject to the 1.0 percent de minimis)
This category includes only those chemicals listed below.
56-55-3 Benz (a) anthracene
205-99-2 Benzo(b)fluoranthene
205-82-3 Benzo(j)fluoranthene
207-08-9 Benzo(k)fluoranthene
189-55-9 Benzo(rst)pentaphene
218-01-9 Benzo(a)phenanthrene
50-32-8 Benzo(a)pyrene
226-36-8 Dibenz(a,h)acridine
224-42-0 Dibenz(a,j)acridine
53-70-3 Dibenzo (a, h) anthracene
194-59-2 7H-Dibenzo(c,g)carbazole
5385-75-1 Dibenzo (a, e)fluoranthene
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
192-65-4 Dibenzo(a,e)pyrene
189-64-0 Dibenzo(a,h)pyrene
191-30-0 Dibenzo(a,l)pyrene
57-97-6 7,12-Dimethylbenz(a)anthracene
193-39-5 Indeno[l,2,3-cd]pyrene
3697-24-3 5-Methylchrysene
5522-43-0 1-Nitropyrene
Selenium Compounds (1.0)
Includes any unique chemical substance that contains selenium part of chemical's
infrastructure.
Silver Compounds (1.0)
Includes any unique chemical substance that contains silver part of that chemical's
infrastructure.
Strychnine and salts (1.0)
Includes any unique chemical substance that contains strychnine or a strychnine salt
as part of that chemical's infrastructure.
Thallium Compounds (1.0)
Includes any unique chemical substance that contains thallium as part of that
chemical's infrastructure.
Warfarin and salts (1.0)
Includes any unique chemical substance that contains warfarin or a warfarin salt as
part of that chemical's infrastructure.
Zinc Compounds (1.0)
Includes any unique chemical substance that contains zinc as part of that chemical's
infrastructure.
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October 7, 1997 A-20
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APPENDIX B
BIBLIOGRAPHY
Office of Management and Budget, Standard Industrial Classification Manual, 1987.
Science Applications International Corporation, SIC Code Profile 50 and 51 Wholesale Trade-
Durable and Nondurable Goods, 1997.
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APPENDIX C
SECTION 313 RELATED MATERIALS AND ELECTRONIC ACCESS TO
INFORMATION
Ordering information for the following documents, in addition to Toxic Chemical Release
Inventory Reporting Form R and Instructions, can be obtained by calling the EPCRA Hotline
at 1-800-535-0202.
Common Synonyms for Section 313 Chemicals. EPA 745-R-95-008. March 1995.
Compilation of Air Pollutant Emission Factors, 5th Edition, Volume I: Stationary Point
and Area Sources (AP-42). EPA 450-AP-425ED. 1995.
Consolidated List of Chemicals Subject to Reporting Under the Act (Tide III List of Lists).
EPA550-B-96-015.
Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
Inventory Form. EPA 560/4-88-002. December 1987.
Estimating Releases of Mineral Acid Discharges Using pH Measurements. June 1991.
Interpretations of Waste Management Activities: Recycling, Combustion for Energy
Recovery, Waste Stabilization and Release. April, 1997.
Protocol for Equipment Leak Emission Estimates. EPA 453/R-95-017. November 1995.
Toxic Chemical Release Inventory Questions and Answers, Revised 1990 Version. EPA
560/4/91-003.
World Wide Web Resources
Code of Federal Regulations, 40 CFR
www.epa.gov/epacfr40
CHEMDAT8/WATER8
www. epa. go v/ttn/chief/software. html#water8
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TRI FORM R GUIDANCE DOCUMENT CHEMICAL DISTRIBUTORS
Clearinghouse for Inventories and Emission Factors (CHIEF)
www.epa.gov/ttn/chiefi'
Compilation of Air Pollutant Emission Factors (AP-42)
www. epa. go v/ttn/chief/ap4 2 etc. html
EPA homepage
www.epa.gov
Federal Registers
www. epa. go v/EP A-TRI
MSDSs (Note: A number of organizations maintain databases that contain MSDS
information. The following is a short list of web sites with MSDS information.)
www. dehs. umn. edu/msds. html
www. nwfsc. noaa. gov/msds. html
www. chem. Utah. edu/msds
SPECIATE
www.epa.gov/ttn/chief/software.htmWspeciate
TANKS
www. epa. go v/ttn/chief/tanks. html
TOXNET
www. nlm. nih. go v/pubs/factsheets/toxnetfs. html
TRI homepage
www. epa. gov/opptintr/tri
October?, 1997 C-2
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